Loading...
HomeMy WebLinkAbout07-5636 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY, ) PRIMUS FINANCIAL AUTOMOTIVE ) SERVICES ) Plaintiff, ) V. ) DANIEL LONGWELL AND ) JANE DOE LONGWELL, ) Defendant. ) NO. b7 - 5(c3(o (iiv t t ~CfM PRAECIPE FOR APPEARANCE, TRANSFER OF JUDGMENT, ASSESSMENT OF DAMAGES AND VERIFICATION OF ADDRESS, VALIDITY AND NONMILITARY SERVICE AGAINST DANIEL LONGWELL ONLY I hereby certify that the true and correct address of Plaintiff is: C/O Patenaude & Felix, A.P.C. Plaintiff 213 E. Main Street Carnegie, PA 15106 and that the last known address of Defendant(s) is: 6002 ROBERT DR MECHANICSBURG, PA 17050 The Law Offices of Patenaude & Felix, A.P.C. Filed on behalf of Ford Motor Credit Co. Primus Financial Automotive Services Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 Esquire 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY, ) PRIMUS FINANCIAL AUTOMOTIVE ) NO. SERVICES ) Plaintiff, ) V. ) DANIEL LONGWELL AND ) JANE DOE LONGWELL, ) Defendant. ) PRAECIPE FOR APPEARANCE, TRANSFER OF JUDGMENT, ASSESSMENT OF DAMAGES AND VERIFICATION OF ADDRESS, VALIDITY AND NONMILITARY SERVICE AGAINST DANIEL LONGWELL ONLY. TO: PROTHONOTARY Please enter my appearance for the Plaintiff in the above matter; enter judgment in favor of Plaintiff against Defendant(s) on the duly authenticated copy of the judgment contained in the docket entries hereto attached, entered in the jurisdiction noted therein, and assess damages as follows: Judgment Due $ 7,582.08 Interest $ 1,212.25 Costs 249.50 TOTAL $ 9,043.83 With continuing interest on the principal amount of $ 9,043.83, plus costs. Pursuant to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, I hereby verify that: (1) the precise last known address of the Plaintiff and Defendant(s) are as above; (2) that said judgments were entered in the said jurisdiction in said amount with costs and interest due as noted, no part of which has been paid (except as noted) and which is valid, enforceable and unsatisfied; (3) and that Defendant(s) is (are) over 18 years of age and not in the military service of the United States of America or its allies or otherwise within coverage of the Soldiers and Sailors Relief Act of 1940, as amended, and has (have) civilian occupation(s) to the best of his knowledge, information and belie & Felix, A.P.C. Sworn to and subscribed before me this ~ day of .J J~~ 2007, By: ~ ~. 7 Notary Public ~~ NOtia21At SEAL w -Et21N N BALTZELL Notary Pudic CAkNEGIE BOROUGH, ALLEGHENY CO My Commission Expires Jul 21, 201 Gregg L. Morris, Esquire Patenaude & Felix, A.P.C 21 E. Main Street Pit burgh, PA 15106 ~l 1429-7675 In the Superior Court of the State of Washington, ,~ , " In and for Snohomish County. , I~'MC DBA PRIM[IS FINANCIAL SERVICES Plaintiff/Petitioner ` p I V. Case/Cause No. ~ - 2„ - ~ 7 D q ' DANIEL LONGWELL AND JANE DOE LONGWELL Certificate Defendant/Respondent I, Pam L. Daniels, County Clerk and ex Officio Clerk of the Superior Court of the State of Washington, in and for Snohomish County, do hereby certify that the foregoing is/are a true and correct copy(ies) of: as the same now appears in my office. IN WITNESS WHEREOF, I By: gave hereunto set my hand and fixed the seal of said at Sno mish, thi~ d _ 20 D(p Clerk ancj,@x Offio clerk of said Superior Court Deputy STATE OF WASHINGTON ss Judges Certificate Snohomish County I, GEORGE N : BOWDEN ,Judge of the Superior Court of the State of Washington, for Snohomish County, do hereby certify that Pam L. Daniels, whose signature is attached to the above and foregoing Certificate, now is, and was at the signing and sealing of said Certificate, the duly elected, qualified and acting County Clerk, and ex Officio Clerk of said Superior Court, and the person having by law the custody of the Seal of said Court; that said certificate is in due form, and that said Clerk's signature thereto is genuine, and that the above seal impress is the genuine impress of said seal. Witness my hand and the seal of said Superior Ccurt hereto affixed this 1 day of~_ 20 a Judge oft a said erior ourt STATE OF WASHINGTON ss Clerk's Certificate Snohomish County I, Pam L. Daniels, County Clerk, and ex Officio Clerk of the Superior Court of the State of Washington, in and for Snohomsh County, said State, do hereby certify that Hon. GEORGE N. BOWDEN whose signature is affixed to the above and foregoing Certificate, now is, and was at the signing, the duly elected, qualified and acting Judge of the Superior Court of the State of Washington, in and for Snohomish County, said State, and that his/her said signature is genuine. Witn ss my hand n~he seal of said . erior C rt hereto affixed this Clerk of the said Su'p~erior Court ,~. ~~ _ _. 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 1$ 19 2d 21 22 23 24 25 26 i~~'r nr~'rr ~,eo~e, ~~~~~~ 205 SEA 28 APi 9~ :~ S .JE,i:l~i,:i %;3UiJ ~ Y Ci_ERK aNOHOMiSN CO. YIASN. IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON FOR SNOHOMISH COUNTY r-~ FMC d/b/a PRIMUS FINANCIAL SERVICES ~ ~~ ~ ~ ~ ` Plaintiff, ~ No. vs. ~ ORDER OF DEFAULT AND DEFAULT DANIEL LONGWELL and JANE DOE ~ JUDGMENT LONGWELL, husband and wife, and their marital ~ community composed thereof, ; (Clerk's Action Required] Defendants. JUDGMENT SUMMARY Judgment Creditor: FMC d/b/a PRIMUS FINANCIAL SERVICES Attorney for Judgment Krista L. White, Patrick J Layman Creditor: BISHOP, WHITE & MARSHALL, P.S. Judgment Debtors: DANIEL LONGWELL and JANE DOE LONGWELL .w/t/n/i TARA LONGWELL and their. marital community Principal Amount: Interest to Date of Judgment: Taxable Costs: Filing Fee: Service of Process: TOTAL JUDGMENT: ORIGINAL ~~ ORDER OF DEFAULT AND DEFAULT JUDGHENT - 1 $7,582.08 $1,212.25 $200.00 $49.50 $9,043.83 BISHOP, WHITE & MARSHALL, P.S. PO Hox 2186 5eaale, Washington 98111-2186 720 olive way, suiu 130! seaale, Washington 9910! 206/622-5306 Fax: 206/622-0354 877/259-1016 1 ~1~. - . Past Judgment interest accrues at the rate of 23.25% per annum on the total judgment. II. ORDER AND JUDGMENT Plaintiffs motion for an order of default and default judgment against the above named defendants came on for hearing on this date before the undersigned judge/court commissioner of this court. The court, having found that: (1) the defendants were duly served with a summons and complaint and have failed to appear, answer, or otherwise defend within the time provided by law; (2) finds that the venue is proper; and {3) the defendants are justly indebted to the plaintiff, as evidenced by the proof presented herewith, now, therefore, it is hereby ORDERED, ADJUDGED and DECREED that the defendants are in default. It is further ORDERED, ADJUDGED and DECREED that plaintiff have and is hereby granted judgment against defendants, DANIEL LONGWELL and JANE DOE LONGWELL w/t/n/i TARA LONGWELL and their marital community, jointly and severally, in the principle amount of $7,582.08, plus interest of $1,212.25, court costs and disbursements totaling $249.50, for a total judgment of $9,(}43.83. 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 ~~ ORDER OF DEFAULT AND DEFAULT JUDGMFN'C - 2 BISHOP, WHITE & MARSHALL, P.S. 1'0 Box 2186 Scattlt:, Washington 98111-2186 720 Olive Way, Suite 1301 Seattle. Washington 98101 206/622-5306 Fax; 206/622-0354 877lZ59-1016 "Y 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 ~' Postjudgment interest shall accrue on the judgment total at the rate of at 23.25% per annum. DONE IN OPEN COURT this day o$EP 2 8 ZD~3 2005. ~ ~~~~~ J E/C URT COMMISSIONER Presented by: BISHOP, WHITE & MARSHALL, P.S. ~c~ Patrick J. La SB# 5707 Krista L. White WSB# 8612 Attorney's for Plaintiff 1 ORDER OF DEFAULT AND DEFAULT JUDGMENT - 3 BISHOP, WHITE & MARSHALL, P.S. PO Box 2186 Seattle, Washington 981! 1-218fi 720 Olive Way. Suiu 1301 Seattle. Washington 98101 2061622-5306 Fax: 206/622-0334 877/259-1016 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY, ) PRIMUS FINANCIAL AUTOMOTNE ) NO. SERVICES ) Plaintiff, ) V. ) DANIEL LONGWELL AND ) JANE DOE LONGWELL, ) Defendant. ) NOTICE OF ORDER, DECREE OR JUDGMENT Filed on behalf of Ford Motor Credit Co. Primus Financial Automotive Services, Plaintiff Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Pittsburgh, PA 15106 (412) 429-7675 • " r ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY, ) PRIMUS FINANCIAL AUTOMOTIVE ) NO. SERVICES ) Plaintiff, ) V. ) DANIEL LONGWELL AND ) JANE DOE LONGWELL, ) Defendant. ) NOTICE OF ORDER. DECREE OR JUDGMENT TO: ( )Plaintiff (x )Defendant ( )Garnishee ( )Additional Defendant You are hereb notified that the following Order, Decree, or Judgment has been entered against you on oZ ~ b'~ Decree Nisi in Equity Final Decree in Equity Judgment of ( )Confession ( )Verdict ( )Court Order ( )Default ( )Non-suit ( )Non-Pros ( )Arbitration Award (X) Judgment in the amount of 9 043.83, plus costs. ( )District Justice Transcript of Judgment in the amount of $ , plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Department of Transportation. Prothonotary By S ~G~I.S If you have questions concerning the above, please contact: Name of Attorney: Gregg L. Morris Esquire 213 E. Main Street Pittsburgh PA 15106 X412) 429-7675 ~ r,~ --- . -, r~ ti :•',S -~~ ~ ~ ~ ~ :r f T7 T. /y~ ~ O , I '~ r ~ ~~ r C..a ~f„ a `:; r., _.,. -~ FILED-OFFICE a . 'fHE PROTHONOTARY 201 i JUi 24 PM 1:39 rU PENNSYLVANIA COUNTY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY, PRIMUS FINANCIAL AUTOMOTIVE SERVICES Plaintiff V. DANIEL LONGWELL AND JANE DOES LONGWELL, Defendant(s) NO. 07-5636 ) PRAECIPE FOR SATISFACTION OF JUDGMENT Filed on behalf of: PRIMUS FINANCIAL AUTOMOTIVE SERVICES Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 PA-147 Prcp Sat Jg P& I File No. 2800.5089 f 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY, PRIMUS FINANCIAL AUTOMOTIVE SERVICES Plaintiff NO. 07-5636 V. DANIEL LONGWELL AND JANE DOE LONGWELL Defendant(s) PRAECIPE TO SATISFY JUDGMENT TO: PROTHONOTARY Please satisfy the Judgment at the above captioned action of record upon payment of your costs, only. Thank you. Respectfull A.P.C. Date. June 14, 2011 uire PA-147 Prcp Sat Jg 7arnegie,AM 15106 (412) 429-7675 P&I File No. 2800.5089 41 I, GREGG MORRIS, attorney for Plaintiff, PRl MUS FINANCIAL AUTOMOTIVE SERVICES , hereby certify that a true and correct copy of foregoing document was served this date by ordinary mail upon the following: DANIEL LONGWELL 200 LIPPERT DR WESTAPT G137 PORT ORCHARD WA 98366 Date: June 14, 2011 PA-147 Prcp Sat Jg P&I' File No. 2800.5089 Carnegie, PA 15106 (412) 429-7675