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HomeMy WebLinkAbout07-6998Leonard A. Sanguedolee, Esquire Attorney for Plaintiff, CACH, LLC. Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. CIVIL ACTION - LAW DENISE ROSS, Defendant NO. 7-- (p C/'? Er- C c` J r NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 800-990-9108 Respectfully submitted, Leonard A. S g do ce, Esquire IMPORTANT NOTICE If this is the first Communication you have received from this office, please be advised of the following: Unless, within thirty (30) days after receipt of this notice, you dispute the validity of the debt, or any portion thereof, the debt will be assumed to be valid by CACH, LLC. If you notify me in writing within the thirty-day period that you dispute the debt, or any portion thereof, I will obtain verification of the debt or a copy of the judgment against you and a copy of that verification will be mailed to you. Additionally, if, within the previously described thirty (30) days, you request in writing the name and address of your original creditor, I will furnish you with that information if that creditor is different than the current creditor (CACH, LLC.). Please note, that the law does not require me to wait until the end of the thirty-day period before suing you to collect this debt. If, however, you request proof of the debt or the name and address of the original creditor within the thirty-day period that begins with your receipt of this Notice, the law requires me to suspend my efforts (through litigation or otherwise) to collect the debt until I mail the requested information to you. Please be guided accordingly. "This is an attempt to collect a debt and any information obtained will be used for that purpose." Leonard A. Sanguedolce, Esquire Attorney for Plaintiff, CACH, LLC. Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. Plaintiff CIVIL ACTION - LAW DENISE ROSS, Defendant NO. AND NOW, comes the Plaintiff, CACH, LLC, by and through its Attorney, Leonard A. Sanguedolce, Esquire, and files this, its Complaint, against the Defendant, DENISE ROSS, and in support thereof avers as follows: 1. That, the Plaintiff, CACH, LLC, is a Delaware corporation with its principal place of business located at 370 17th Street, Suite 5000, Denver, Colorado, 80202. 2. That, the Defendant, DENISE ROSS, is an adult and competent individual who resides at 148 E. North Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. That, on or about December 14, 2006, the Defendant, Denise Ross was indebted to GE Money Bank on credit card account number 6032 2014 0194 4296 in the amount of $2,036.09. A copy of the final statement is attached hereto, made a part hereof and labeled Exhibit "A". 4. That, on or about January 4, 2007, GE Money Bank assigned the above referenced debt, for good and valuable consideration, to CACH, LLC. A copy of Certificate of Purchase is attached hereto, made a part hereof and labeled Exhibit "B". 5. That, pursuant to the cardholder agreement entered into by the Defendant and GE Money Bank, the Plaintiff is entitled to pre-litigation interest of $1.53 per day from the date of charge-off which is calculated as follows: 27.49% annual percentage rate x $2,036.09 - 365 days or $1.53 x 171 days, which equals an additional $262.23, reimbursement of costs and reasonable attorneys fees, in the amount of $250.00. 6. That, despite repeated demands by the Plaintiff, Defendant has failed to pay the sum of $2,548.32 which remains due and owing on the above referenced account. 7. That, the claims raised in the Complaint are subject to an agreement to submit these claims to arbitration. WHEREFORE, Plaintiff, CACH, LLC, prays this Honorable Court for Judgment in favor of Plaintiff and against Defendant, DENISE ROSS, for $2,548.32 together with costs and interest. Respectfully submitted, Leonard A. Sang olce, Esquire Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 (570) 823-0101 Attorney for Plaintiff, CACH, LLC VERIFICATION I, Charles Shisler , hereby depose and state that: The language of the foregoing document is that of counsel and not necessarily my own; however, I have read the foregoing document and the factual information contained therein is true and correct to the best of my personal knowledge. I am the Authorized Representative and a duly authorized representative of the plaintiff; The factual allegations set forth in the foregoing pleading are true and correct to the best of my knowledge, information and belief, and they are that DENISE ROSS owes the balance of $2,036.09 to CACH, LLC on previously submitted invoices, which balance is due and unpaid as if the date of the execution of this Verification. I am aware that if any of the foregoing is willfully false, I am subject to punishment. I understand that false statements made herein are subject to the penalties relating to unsworn falsification to authorities. JUN 2 4 2007 Dated: s Shisler Bye _- Authorized Representative P"%" 4 . Aliot?OV MOW* 12116106 $0.00 $0.00 a(M 2014 0194 4296 Fig in alrlpullt oomootey $00000-00 NNa aadnua ar aaat7 hOx n ISM and A1FdmwA payrrANnl dtre prW, - P on back :o Ott Pant duo. :udaa PbmwPay pfty &vsffowMPRObPTLY. 6032201401944296 OENISE M ROSS 148 E NORTH ST CARLISLE PA 170132430 AtWo Pry14an1 To. WAL-MART P.O. SOX 630027 11701324304871 ATLANTA, GA 30363.0027 1303530927279! 00000000009200 000000000000000 023 6032201401944296 23 O Mau &&a p Ism In us caum a7 wa mwt use bA» or woo +rar. osddr and may eft Paten wKn your d,ea1 a tM addraaa above. O .AGCQWff ACMJM NUWAW: a= 2014 0194 4290 6salaaierr DAM : 12114r2m Paymwrt Due Do* 1211arA06 Deya In 00ft Padod 26 Praelws Balanaa 52007.12 - Pawwft $0.00 aA FINANCE CHARGE (nal) So.o9 • Now Pumha $0.00 • Caeb A4varsaa $0.00 +a Aft Seatty. lnmmnaa. Faaa A Oa0Wad0AOAUMM(no) 42.007.12 Now adarwe $41071 Mlrllra , Payrnat 50.00 ber rm ft%-. ca ,OasNOAbn M Amount DaAS 1114 12M4 FN 1200P000900000 CHARGE OFF ACCOUNT-PRINCIPALS 5/.54MC 1114 12n4 F9112OWCO ROM CHARGE OFF ACCOUNIT'FINANM CHARGES' $406.660 1112 12M2 LATE FEE 526.67 THE PERIODIC RATE SHOWN ON THIS STATEMENT MAY VARY. Ownpubdon PAW was CakrAlMS CfIARGE Awrpa Daly Ualrrca Type PWbde Rala M.PWO~ PertMrkw RaM CHARGE Ptm%M&WCM*AdMMS =0.oo REG .07531% 27.40% $aam ANNUAL PEINMWAGff RATE 27.490% ToWParl M FIANCECNAROE $0.00 PAYMENT DUE EY MOD PM ON THE DUE DATE wo may w~ your payment b" an dedr a debit sea r4wane MIS trddek. NOTICE: Saa rwels.at. (a BMrq R19taa and deer important intormaLon. 5404 0000 RFD 3 s 16 041214 1 x 04 5 1 01 1 5117 1400 0131 a EXHIBIT a N CERTIFICATE OF PURCHASE I, Charles Shisler , hereby depose and state that: 1. I am an Authorized Agent of CACH, LLC, a Colorado Limited Liability Company. 2. As such, I am authorized to give this Certificate, and possess sufficient personal knowledge to do so regarding: Customer Name: Original Creditor: Money Bank Account Number: DENISE ROSS Ge Electric Capital Corp/Ge 6032201401944296 3. On or about January 4, 2007 this account was sold by the original creditor. CACH, LLC is the current owner of the account and purchased the account for good and valuable consideration. Date: " U'Y 2 S 2007 By: is er /, aj_q "?- - . day of L?--? Sw nand subscrib d to before me this 200. STEPHANIE--- ?&A(?F?R1S TA ?Y PUBLIC O?? f O' ORADQ Notary Publi ----..®? MY commission Expires 05/22/2011 My Commission Expires: j 0 EXHIBIT a Ca rv ? C-7 " 71, r _.., -r; r n SHERIFF'S RETURN - REGULAR CASE NO: 2007-06998 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACH LLC VS ROSS DENISE SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE ROSS DENISE was served upon the DEFENDANT , at 1907:00 HOURS, on the 3rd day of December-, 2007 at 148 E NORTH STREET CARLISLE, PA 17013 DENISE ROSS by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge/ `4o." Sworn and Subscibed to before me this of So Answers: 18.00 4.80 .00 10.00 R. Thomas Kline .00 32.80 12/04/2007 JOHN P RODGER i By: day /olffeputy Sheriff A.D. Y Leonard A. Sanguedolce, Esquire Attorney for Plaintiff, CACH, LLC Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVILACTION - - LAW VS. DENISE ROSS, Defendant No.07-6998-cv PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT TO: Prothonotary, Cumberland County Enter judgment by default, in favor of the Plaintiff, CACH, LLC, and against the Defendant, Denise Ross for her failure to plead to the Complaint in this action within the required time. The Complaint contained a Notice to defend within twenty (20) days of the date of service thereof. The Defendant was served with the Complaint on December 3, 2007. Attached hereto as Exhibit "A" is a copy of the Plaintiffs written Notice of intent to file Praecipe for Entry of Judgment by Default, which I can certify was mailed by first class mail to the Defendant at her last known addresses on December 28, 2007, which is at least ten (10) days prior to the filing of this Praecipe. Please assess damages in the amount of two thousand five hundred forty eight and 32/100 ($2,548.32) Dollars, being the amount demanded in the Complaint, together with costs and interest. Respectfully submitted, Leonard A. Sang dolc , Esquire r Leonard A. Sanguedolce, Esquire Attorney for Plaintiff, CACH, LLC Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - - LAW VS. DENISE ROSS, Defendant No.07-6998-cv AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF LUZERNE SS 1, Leonard A. Sanguedolce, attorney for Plaintiff, CACH, LLC, being duly sworn, depose and say that: To the best of my knowledge, information and belief the Defendant, DENISE ROSS is not in the Military Service of the United States nor any State or Territory thereof, or its allies as defined in the Soldiers and Sailors Civil Relief Act of 1940 and amendments thereto. Dated: D . j I %. g4 Leonard A. an ed e, squire Sworn to and subscribed before me this. day of? a_muCLjW 1' 2008. NOTARY PUBLIC ?MNar4v/kMl? M OP WTA1RIAL SEAL LINDA L YAM. No1ry Pub1c City d W rw, umme Co?x? Commlwlon 25, 11 4 Leonard A. Sanguedolce, Esquire Attorney for Plaintiff, CACH, LLC Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - - LAW VS. ANDREW RAMOS, Defendant No.07-6999-cv CERTIFICATE OF SERVICE I, Leonard A. Sanguedolce, Esquire, certify that on the above stamped date & time, I caused to be served a time-stamped copy of each of the following documents: Praecipe for Entry of Judgment by Default, Entry of Judgment and Notice of Entry of Judgment along with a Certificate of Service, upon the below listed Defendant, by United States, first class mail, postage prepaid, addressed as follows: Denise Ross 148 E. North Street Carlisle, PA 17013 Respectfully submitted, eonard A. S gu olc ,Esquire Attorney for Plaintiff, CACH, LLC Leonard A. Sanguedolee, Esquire Attorney for Plaintiff, CACH, LLC Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. CIVIL ACTION - LAW DENISE ROSS, Defendant NO. 07-6998-civil IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 800-990-9108 Respectfully submitted, Dated: I a a$ D 7 P i - '?L iw-?' Leonard A. Sang olce, Esquire EXHIBIT A Leonard A. Sanguedolce, Esquire Attorney for Plaintiff, CACH, LLC Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. DENISE ROSS, CIVIL ACTION - LAW Defendant NO. 07-6998-civil CERTIFICATE OF SERVICE I, Leonard A. Sanguedolce, Esquire, certify that on the c?R day of December 2007, 1 made service of the Original Important Notice of intention to enter default judgment upon the below listed Defendant, by United States, first class mail, postage prepaid, addressed as follows: Denise Ross 148 E. North Street Carlisle, PA 17013 0 0 m P vm W V TN Cn . 00 2. 0 3 ao E V) c 'm 'z $ g my m n $ g C < Ul (D pA m O ' io (D C s a ' q s 1if W 0 XT m ?? - (n a I - c N Dm D e C CI) (D D O M 0 V C O (D 0 m 3n Sos D o z D r o W ab3000 L O ?± 05 L 00 $ z o 0' 1 S3M09 A3Nlld ?? Z ; Respectfully submitted, Leonard A. Sangu olce, Esquire Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 (570) 823-0101 70 d ? 173 ? T _ Leonard A. Sanguedolee, Esquire Attorney for Plaintiff, CACH, LLC Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - - LAW VS. DENISE ROSS, Defendant No.07-6998-cv ENTRY OF JUDGMENT Pursuant to Praecipe filed for Entry of Default Judgment, Judgment is hereby entered in favor of the Plaintiff, CACH, LLC and against the Defendant, DENISE ROSS, in the amount of two thousand five hundred forty eight and 32/100 ($2,548.32) Dollars, together with costs and interest from the time of the present and continuing to accrue until the time of payment. PRO ONO CU ERLAND COUNTY BY: a . Leonard A. Sanguedolce, Esquire Attorney for Plaintiff, CACH, LLC Identification No. 204325 Law Offices: Harrison Ross Byck, Esq., P.C. 15 Public Square, Suite 202 Wilkes-Barre, PA 18701 Phone: (570) 823-0101 Fax: (570) 825-7799 CACH, LLC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - - LAW VS. : DENISE ROSS, Defendant No.07-6998-cv NOTICE OF ENTRY OF JUDGMENT TO: Denise Ross 148 E. North Street Carlisle, PA 17013 AS PRESCRIBED BY LAW, YOU ARE NOTIFIED THAT A JUDGMENT HAS BEEN FILED IN THIS OFFICE AGAINST YOU BY PLAINTIFF, CACH, LLC, IN THE AMOUNT OF $2,548.32 TOGETHER WITH COSTS AND INTEREST FROM THE TIME OF THE PRESENT, AND CONTINUING TO ACCRUE UNTIL THE TIME OF PAYMENT. Protho otary, C D COUNTY BY: r -7 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PEN?rVANIA, CACH, LLC., Plaintiff No. 07-6998-CV <= y -L7 4._5 -T VS. : wC i{ CIVIL ACTION DENISE ROSS, Defendant CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO Pa.R.C.P. No. 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule I/ 4009.22, I, Alan R. Mege, Esquire, hereby certify that: 1. Notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed to Defendant at least twenty days prior to the date the subpoena is sought to be served; 2. A true and correct copy of the notice of intent, including the proposed subpoena, are attached hereto; 3. No objection to the subpoena has been received; and 4. The subpoena that will be served is identical to the subpoena which was attached to the notice of intent to serve subpoena. By: Mege, Esquire Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., Plaintiff No. 07-6998-CV vs. CIVIL ACTION DENISE ROSS, Defendant NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO Pa.R.C.P. No. 4009.21 Plaintiff intends to serve a subpoena identical to the one that is attached to the notice. You have twenty (20) days from the date listed below in which to file of record and serve the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: May 23, 2012 Alan R. Mege, Esq., Attorney for Plaintiff 'i 4 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., Plaintiff No. 07--6998-CV vs. ern"M M CIVIL ACTION DENISE Ross, > " Defendant C7) : =1Z) PLAINTIFF'S MOTION TO COMPEL DEFEN+ ANT'S ANSWE1§;c4:'-'0 rn INTERROGATORIES IN AID OIL EXECUTION And now conies Plaintiff and submits the instant Motion to Compel, and in support thereof avers as follows: 1. Judgment for Plaintiff and against Defendant in the sum of$2,548.32 plus costs was entered in Cumberland County on January 16, 2008. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on April 3, 2013. 3. Pursuant to Pa.R.C.P. 4006 (a) (2), Defendant's responses to the Interrogatories were due within thirty days after they had been served, but none has been received as of the date of giving notice herein. 4. Counsel for Plaintiff has made a good faith effort to confer with Defendant, but Defendant has still failed to reply. 5. A copy of this Motion and proposed Order were mailed to .Defendant, via first class mail on May 6, 2013. A certificate of Service is attached. hereto as Exhibit "A". 6. As of May 28, 2013, Plaintiff has not received answers to the Interrogatories. 7. Plaintiff requires an Order pursuant to Pa.R.C.P. 4019 (a) (1) (I), compelling the Defendants to answer the Interrogatories. 8. No Judge has ruled upon other issues in this platter. 9. Concurrence with the Pro'Sd'Ddfendant has been sought and denied. WHEREFORE, Plaintiff, requests that this Honorable Court grant its motion and enter an Order directing the Defendant to answer Plaintiff's Interrogatories within twenty (20) days or risk sanctions;pay fees in the amount of$100.00, as well as such other and further relief as the Court may deem just and appropriate. 'AIEKk. Mege/Es Attorney ID N88 Attorney for P s P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 -2- COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., Plaintiff No. 07-6998-CV VS. CIVIL ACTION DENISE ROSS, Defendant CERTIFICATE OF SERVICE I,Alan R.Mege,Esquire,hereby certify that on May 28,2013,I served a true correct copy of Plaintiffs Motion to Compel Defendant's Answers to Interrogatories in Aid of Execution and proposed Order,by mailing same, first class,postage prepaid to: Denise Ross, 148 E.North St., Carlisle, PA 17013. By: Alan-If. Mege, Esqui Atty. I.D. #81288 Attorney for Plai tiff P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., : Plaintiff No. 07-6998-CV vs. CIVIL ACTION DENISE ROSS, I Defendant Cn c ; PRAECIPE FOR ENTRY OF APPEARANCE "z TO THE CLERK OF SAID COURT Kindly enter my appearance on behalf of the Plaintiff in the above captioned matter. By: ge Esquir R. W , Atty. I.D. #81288 Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 CACH, LLC, � Plaintiff V. IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT DENISE ROSS, Defendant 2007-06998 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO INTERROGATORIES IN AID OF EXECUTION ORDER OF COURT AND NOW, this W'day of June 2013, upon review of Plaintiffs Motion to Compel Defendant's Answers to Interrogatories in Aid of Execution, a Rule is issued upon Defendant to show cause, if any, why the relief requested should not be granted. PLAINTIFF shalt effectuate service of this Rule upon Defendant. Proof of service must be filed prior to the court entertaining a motion to make rule absolute. RULE RETURNABLE twenty (20) days from the date of service by Plaintiff. BY THE COURT, Thomas A. Placey C.P.J. Distribution., ✓Alan R. Mege, Esq. �enise Ross ,n r. 4 fo�t3 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., Plaintiff No. 07-6998-CV Cam;:. vs. mcu CIVIL ACTION ''' ~ �- DENISE ROSS, ; 05.r- r5T-1 -<> , Defendant Cn CERTIFICATE OF SERVICE » > Cn I,Alan R.Mege,Esquire,hereby certify that on June 12,2013,I served a true correct copy of the Court's June 10, 2013 Compel Order by mailing same, first class, postage prepaid to: Denise Ross, 148 E. North St., Carlisle, PA 17013. BranR. Mege, Esqui I.D. #81288 Attorney for Plaintiff P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • CACH, LLC., Plaintiff : No. 07-6998-CV vs. m m r;_ : CIVIL ACTION DENISE ROSS, : <>. co Defendant • �° -17 CD >c r,T -s LI PLAINTIFF'S MOTION FOR NEW RULE RETURNABLE DATE And now comes Plaintiff and submits the instant Motion for New Rule Returnable Date, and in support thereof avers as follows:: 1. Plaintiff is a judgment creditor of the Defendant in the above matter. 2. On May 31, 2013, Plaintiff filed a Motion to Compel. 3. An Order dated June 10, 2013, issuing a Rule Returnable date of July 3, 2013. 4. Plaintiff has not been able serve the Rule upon Defendant. 5. Plaintiff is respectfully requesting a new rule returnable date. 6. A copy of this Motion and proposed Order was mailed to Defendant, via first class mail on September 20, 2013. A certificate of service is attached hereto. WHEREFORE, Plaintiff respectfully request that the Court issue a new Rule Returnable Date with regard to Plaintiff's Motion to Compel. lan R. Mege, Esq. Attorney ID No. 812:8 Attorney for Plainti f PO Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • CACH, LLC., Plaintiff : No. 07-6998-CV • vs. : CIVIL ACTION DENISE ROSS, • Defendant CERTIFICATE OF SERVICE I,Alan R. Mege, Esquire, hereby certify that on September 20,2013,I served a true correct copy of Plaintiffs Motion for New Rule Returnable Date and proposed Order by mailing same, first class, postage prepaid to: Denise Ross, 148 E. North St., Carlisle, PA 17013. By: � ■ • .n R. Mege, Esquir- e Atty. I.D. #81288 Attorney for Plain 'ff P.O. Box 1426 Bethlehem, P• 18016-1426 (610) 954-53' CACH, LLC, J1 t'II ti►c tl ,z z� Plaintiff „ , ilia V. IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT DENISE ROSS, Defendant 2007-06998 CIVIL TERM IN RE: PLAINTIFF'S MOTION FOR NEW RULE RETURNABLE DATE ORDER OF COURT AND NOW, this 1 day of October 2013, upon consideration of Plaintiff's Motion for New Rule Returnable Date, a new RULE is issued upon Defendant to show cause, if any, why the relief requested should not be granted. PLAINTIFF shall effectuate service of this Rule upon Defendant. Proof of service must be filed prior to the court entertaining a motion to make rule absolute. RULE RETURNABLE twenty (20) days from the date of service by Plaintiff. BY THE COURT, Thomas A. Placey C.P.J. Distribution: Alan R. Mege, Esq. . 717:00 Denise Ross -1 0 .,; ter- t DCS rrlilleick -‹- — Crs COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC•, • Plaintiff •▪ No. 07-6998-CV • vs. • •▪ CIVIL ACTION DENISE ROSS, Defendant • CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on October 4, 2013, I served a true correct copy of the Court's October 1, 2013 Order by mailing same, first class,postage prepaid to: Denise Ross, 148 E. North St., Carlisle, PA 17013. By: • . R. Mege, Esquire Atty. I.D. #81288 Attorney for Plainti P.O. Box 1426 Bethlehem, PA 18016-1426 c, r ` ' (610) 954-5393 _,z rn co -`r r COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA' C) CACH, LLC., • Plaintiff : No. 07-6998-CV r rn ` r` (-111, cx r vs. : -..cp r. : CIVIL ACTION - DENISE ROSS, : - > cr Defendant • t.„3 PLAINTIFF'S MOTION TO MAKE THE RULE ABSOLUTE And now comes Plaintiff and submits the instant Motion to Make The Rule Absolute, and in support thereof avers as follows: 1. On October 1, 2013, a Rule was issued upon the Defendant, Denise Ross,to show cause why Plaintiffs Motion to Compel should not be granted. A copy of the Order is attach hereto as Exhibit"A". 2. The October 1, 2013, Rule was served upon Defendant on October 4, 2013. 3.. The Rule Returnable was to be answered by October 21, 2013 in the Office of the Monroe County Prothonotary. As of November 13, 2013, no answer has been filed. 4. A copy of this Motion and proposed Order were mailed to Defendant, via first class mail on November 14, 2013.A certificate of Service is attached hereto. 5. Plaintiff requests that the Rule be made Absolute. WHEREFORE, Plaintiff, requests that this Honorable Court grant its motion and enter an Order directing the Defendants to answer Plaintiffs Interrogatories within twenty(20) days or risk sanctions, pay fees in the amount of$100, as well as such other and further relief as the Court may deem just and appropriate. A - - • . Mege, Esq. Attorney ID No. : 288 Attorney for Plaintiff CACH LLC Plaintiff rtij •� u? °us ai1in� ,'1�,, 111116,, V, s�_ IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT DENISE ROSS, Defendant 2007-06998 CIVIL TERM IN RE: PLAINTIFF'S MOTION FOR NEW RULE RETURNABLE DATE ORDER OF COURT AND NOW, this 1 day of October 2013, upon consideration of Plaintiffs Motion for New Rule Returnable Date, a new RULE is issued upon Defendant to show cause, if any, why the relief requested should not be granted. PLAINTIFF shall effectuate service of this Rule upon Defendant. Proof of service must be filed prior to the court entertaining a motion to make rule absolute. RULE RETURNABLE twenty (20)days from the date of service by Plaintiff. BY THE COURT, Thomas A. Placey C.P.J. Distribution: Alan R. Mege, Esq. r,r- Denise Ross , . / L.' r' �v <=1 ..Z_ >c, -- L. 0 - 4 2013 " L L.;64+ p ' • COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., : Plaintiff : No. 07-6998-CV vs. :. CIVIL ACTION DENISE ROSS, Defendant • CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire,hereby certify that on November 14, 2013, I served a true correct copy of the Plaintiff's Motion to Make Rule Absolute and proposed Order by mailing same, first class, postage prepaid to: Denise Ross, 148 E. North St., Carlisle, PA 17013. By: lan R. Mege, Esq ' e Atty. I.D. #81288 Attorney for Pla' tiff P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 w CACH, LLC, Plaintiff 00*1W*df!MAN44 V. ot" IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT DENISE ROSS, Defendant 2007-06998 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO MAKE THE RULE ABSOLUTE ORDER OF COURT AND NOW, thise day of November 2013, upon consideration of Plaintiff's Motion to Make the Rule Absolute, it is hereby ORDERED that the Rule issued on 1 October 2013 is hereby made absolute and Plaintiff's Motion to Compel Answers to Interrogatories in Aid of Execution is GRANTED. It is further ORDERED that Defendant must make full and complete answers to the interrogatories, without objection or motion for protective order, within twenty (20) days of service of this Order or appropriate sanctions and attorneys' fees may be imposed upon Defendant following application to this Court. PLAINTIFF shall effectuate service of this Order upon Defendant. TT Thor s A. Placey C.P.J. Distribution: ,"Alan R. Mege, Esq. � � � 1�171OW l'i .1�4n 1,6 ON . ✓ Denise Ross °> .g WV SZ AON EIT' 4;es w,a, led �t/,;?3/� / Al � COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • CACH, LLC., � , Plaintiff : No. 07-6998-CV ' "' Cf) N vs. • sc : CIVIL ACTION DENISE ROSS, : Defendant • CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire,hereby certify that on November 27,2013,I served a true correct copy of this Court's November 25,2013 Order by mailing same,first class,postage prepaid to: Denise Ross, 148 E. North St., Carlisle, PA 17013. By: ' . ege, Esquire ty. I.D. #81288 Attorney for Plaintiff P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC•, : r. Plaintiff No. 07-6998-CV = -- Z -,` ^°co t.. • =r" (-6,: VS. : z..- ..... -I,,r unr- s rJ,-,- CIVIL ACTION co -4C-: DENISE ROSS, : <cp xx* c_r Defendant : `' CERTIFICATE OF SERVICE - I, Alan R. Mege, Esquire, hereby certify that on January 6, 2014, I served upon Defendant,a Letter of Intent seeking concurrance and a true and correct copy of Plaintiff's Motion for Sanctions and proposed Order by mailing same,first class,postage prepaid to: Denise Ross, 148 E. North St. Carlisle, PA 17013. By: ■ -i . R. Mege, Esquir- Atty. I.D. #81288 Attorney for Plain iff P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYbVANIA > CACH, LLC., --- Plaintiff : No. 07-6998-CV ry J' • : CIVIL ACTION cz) DENISE ROSS, cr; cfN • Defendant PLAINTIFF'S MOTION FOR SANCTIONS And now comes Plaintiff and submits the instant Motion for Sanctions, and in support thereof avers as follows: 1. Judgment for Plaintiff and against Defendant in the sum of$2,548.32 plus costs was entered in Cumberland County on January 16, 2008. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on April, 3, 2013. 3. Pursuant to Pa.R.C.P. 4006 (a) (2), Defendant's responses to the Interrogatories were due within thirty days after they had been served, but none has been received as of the date of giving notice herein. 4. After notice, a Motion to Compel was filed and an Order entered on November 25, 2013 requiring Defendant, within twenty(20) days, to make full and complete answers to Interrogatories. A true and correct copy of the November 25, 2013 Order is attached as Exhibit »A„ 5. As of January 17, 2014, Plaintiff has not received Defendant's answers to Interrogatories. 6. A copy of this Motion and proposed Order was sent to Defendant on January 6, 2014. A Certificate of Service is attached hereto as exhibit"B". 7. Counsel for Plaintiff sent correspondence to Defendant on January 6, 2014, seeking concurrence, and Defendant is unopposed. A true and correct copy of the correspondence is attached hereto as Exhibit"C". WHEREFORE, Plaintiff, requests that this Honorable Court grant its motion and Order that the Defendant shall pay a daily fine of$25.00 to the use of Plaintiff until Defendant complies with this Court's Order of November 25, 2013 and Defendant shall also pay$100.00 attorney's fees to Plaintiff within twenty(20) days of the date of this Order or appropriate sanctions will be imposed upon Defendant following application to this Court. lan R. Mege, Esq. Attorney ID No. 81 :8 Attorney for Plain 'ff PO Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 -2- CACH,Plaintiff ;�u� gu yea ri,, I ; ,. (. " i44. v. IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT DENISE ROSS, Defendant 2007-06998 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO MAKE THE RULE ABSOLUTE ORDER OF COURT AND NOW, this* day of November 2013, upon consideration of Plaintiffs Motion to Make the Rule Absolute, it is hereby ORDERED that the Rule issued on 1 October 2013 is hereby made absolute and Plaintiff's Motion to Compel Answers to Interrogatories in Aid of Execution is GRANTED. It is further ORDERED that Defendant must make full and complete answers to the interrogatories, without objection or motion for protective order, within twenty (20) days of service of this Order or appropriate sanctions and attorneys' fees may be • imposed upon Defendant following application to this Court. PLAINTIFF shall effectuate service of this Order upon Defendant. 1 NOV 2 7 2013 Tho s • . Placey C.P.J. Distribution: tl ytl n o dAlan R. Meg e� Es q. Denise Ross ,lj1£ Q0 0Q lSZ A0ti Wt(1m0 t ;.T7J.T3ICA1A04.481-17i:,H,1 .:t0 ‘11.,191--f COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., • Plaintiff : No, 07-6998-CV vs. CIVIL ACTION DENISE ROSS, Defendant CERTIFICATE OF SERVICE 1, Alan R. Mege, Esquire, hereby certify that on January 6, 2014, I served upon Defendant,a Letter of Intent seeking concurrance and a true and correct copy of Plaintiff's Motion for Sanctions and proposed Order by mailing same,first class,postage prepaid to:Denise Ross, 148 E. North St. Carlisle, PA 17013. By: ∎01111r�r �R. Mege, Esquir- Atty. I.D. #81288 Attorney for Plain iff P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 P . - r' r rO Co O� Received w JAN 1 0 2014 _• Law Offices of Alan Mege LAW OFFICES OF ALAN R. MEGE, ESQ. P.O. BOX 1426 70 EAST BROAD STREET BETHLEHEM, PA 18016-1426 Licensed in PA and NJ (610) 954-5393 Todd A. Johns, Esq. Of Counsel (610) 954-5395 FAX AlanM_Esq @juno.com January 6, 2014 Denise Ross 148 E. North St. Carlisle, PA 17013 RE: CACH, LLC v. Ross #07-6998-CV Dear Ms. Ross: You are in violation of the Court's Order of November 25, 2013, directing you to provide answers to the interrogatories. Because of this, our office intends to file a Motion for Sanctions, a copy of which is enclosed. Please notify our office of your concurrance with same by January 17, 2014. If we do not hear from you by this time we will assume your concurrance. I appreciate your assistance in bringing this matter to an amicable conclusion. Should you have any questions or comments,please feel free to contact my office. Very truly yours, Alan R. Mege ARM/IIp Enc. FILE COPY This message is from a debt collector, this is an attempt to collect a debt, and any information obtained will be used for that purpose. t5M)t '. , , C , CACH, LLC., l�h Plaintiff U" ;( 1)h i I a +� I V. Countp of Cumberlanb IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT DENISE ROSS, Defendant 2007-06998 CIVIL TERM IN RE: PLAINTIFF'S MOTION FOR SANCTIONS ORDER OF COURT AND NOW, this. day of January 2014, upon consideration of Plaintiff's Motion for Sanctions, it is hereby ORDERED that Plaintiff's Motion is GRANTED. It is FURTHER ORDERED that $100.00 in counsel fees are awarded to Plaintiff and against Defendant as compensation for the preparation, service, and presentation of the Motion. The $100.00 in counsel fees shall be paid by Defendant within twenty (20) days of service of this Order. It is FURTHER ORDERED that Defendant shall pay a daily fine of $25.00 per day to the use of Plaintiff until Defendant complies with this Court's Order of 25 October 2013, requiring Defendant to make full and complete answers to the Interrogatories in Aid of Execution. If Defendant provides said answers to Plaintiff within 30 days of the filing of proof of service with this Court, the daily fines will be purged. However, if Defendant has failed to provide the answers after 60 days from the filing of proof of service, the daily fine will thereafter increase to $50.00 per day. If Defendant has failed to provide the answers after 90 days from the filing of proof of service, the daily fine will thereafter increase to $75.00 per day. If Defendant has failed to provide the answers after 120 days from the filing of proof of service, the daily fine will thereafter increase to $100.00 per day. It is this Court's intention to encourage Defendant to provide full and complete answers to the interrogatories and should be noted that Defendant has 30 days to do so before any fines, other than the $100.00 counsel fees, will be imposed. PLAINTIFF shall effectuate service of this Order upon Defendant. Proof of service must be filed with this Order to begin the calculation of daily fines. BY THE COURT, Thomas A. lacey C.P.J. Distribution: Ia'n R. Mege, Esq. Denise Ross Cori.e.c Tr&I'LL //3v/iY C) Iy cYr. - COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., Plaintiff No. 07-6998-CV VS. CIVIL ACTION DENISE ROSS, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on February 6, 2014, I served upon Defendant a true and correct copy of this Court's January 30, 2014 Order by mailing same, first class, postage prepaid to: Denise Ross, 148 E. North St. Carlisle, PA 17013. By: an R. Mege, Esqui Atty. I.D. #81288 Attorney for Pla' tiff P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 moo -n M rn C" --3 t Dc)-I PO 'COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., Plaintiff No. 07-6998-CV '17.1i 7.1 vs. DENISE ROSS, r c..-) CIVIL ACTION Defendant PLAINTIFF'S MOTION FOR CONTEMPT And now comes Plaintiff and submits the instant Motion for Contempt, and in support thereof avers as follows: 1. Judgment for Plaintiff and against Defendant in the sum of $2,548.32 plus costs was entered in Cumberland County on January 16, 2008. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on April, 3, 2013. 3. Pursuant to Pa.R.C.P. 4006 (a) (2), Defendant's responses to the Interrogatories were due within thirty days after they had been served, but none has been received as of the date of giving notice herein. 4. After notice, a Motion to Compel was filed and an Order entered on November 25, 2013 requiring Defendant, within twenty(20) days, to make full and complete answers to Interrogatories. A true and correct copy of the November 25, 2013 Order is attached as Exhibit 5. After notice, a Motion for Sanctions was presented to the Court and an Order entered on January 30, 2014, requiring Defendant to pay an escalating fine of up to $100.00 to the use of the Plaintiff until Defendant complies with the Court's Order of January 30, 2014, requiring Defendant to make full and complete answers to the interrogatories. A true and correct copy of the January 30, 2014, Order is attached as Exhibit "B". 6. As of March 7, 2014, the Plaintiff has yet to receive the answers to interrogatories, court awarded fees, or court imposed fines. 7. A copy of this Motion and proposed Order were mailed to Defendant on March 7, 2014. A Certificate Of Service is attached hereto. WHEREFORE, Plaintiff, requests that this Honorable Court grant its motion and direct the Prothonotary to issue a bench warrant for Denise Ross, 148 E. North St., Carlisle, PA 17013, and deliver the warrant to the Sheriff and Defendant shall also pay $100.00 attorney's fees to Plaintiff within fourteen (14) days of the date of this Order or appropriate sanctions may be imposed upon Defendant following application to this Court. R. Mege, Esq. Attorney ID No. 288 Attorney for P :intiff CACH, LLC, Plaintiff v. DENISE ROSS, Defendant IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 2007-06998 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO MAKE THE RULE ABSOLUTE ORDER OF COURT AND NOW, this/. day of November 2013, upon consideration of Plaintiff's Motion to Make the Rule Absolute, it is hereby ORDERED that the Rule issued on 1 October 2013 is hereby made absolute and Plaintiff's Motion to Compel Answers to Interrogatories in Aid of Execution is GRANTED. It is further ORDERED that Defendant must make full and complete answers to the interrogatories, without objection or motion for protective order, within twenty (20) days of service of this Order or appropriate sanctions and attorneys' fees may be imposed upon Defendant following application to this Court. PLAINTIFF shall effectuate service of this Order upon Defendant. Distribution: Alan R. Mege, Esq. . Denise Ross NOV 2 7 2013 Tho . Ptacey VINWCIASHN3d xitanoo (11011839I403 6C SZ fQNUZ 10t401-11,08311 d 34-11 .) T31.-1:i0-0:3 CACH, LLC., Plaintiff v. DENISE ROSS, Defendant 2007-06998 CIVIL TERM IN RE: PLAINTIFF'S MOTION FOR SANCTIONS ORDER OF COURT AND NOW, thi day of January 2014, upon consideration of Plaintiff's Motion for Sanctions, it is hereby ORDERED that Plaintiff's Motion is GRANTED. It is FURTHER ORDERED that $100.00 in counsel fees are awarded to Plaintiff and against Defendant. as compensation for the preparation; service, and presentation of the Motion. The $100.00 in counsel fees shall be paid by Defendant within twenty Comp ot (nide tianb IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT • (20) days of service of this Order. It is FURTHER ORDERED that Defendant shall pay a daily fine of $25.00 per day to the use of Plaintiff until Defendant complies with this Court's Order of 25 October 2013, requiring Defendant to make full and complete answers to the Interrogatories in Aid of Execution. If Defendant provides said answers to Plaintiff within 30 days of the filing of proof of service with this Court, the daily fines will be purged. However, if Defendant has failed to provide the answers after 60 days from the filing of proof of service, the daily fine will thereafter increase to $50.00 per day. If Defendant has failed to provide the answers after 90 days from.the filing of proof of service, the daily fine 'II thereafter increase to $75.00 per day. If Defendant has f- iled to PAGetilkeEgswer FEB - 4 2014 Law Offices of Alan Mede after 120 days from the filing of proof of service, the daily fine will thereafter increase to $100.00 per day. It is this Court's intention to encourage Defendant to provide full and complete answers to the interrogatories and should be noted that Defendant has 30 days to do so before any fines, other than the $100.00 counsel fees, will be imposed. PLAINTIFF shall effectuate service of this Order upon Defendant. Proof of service must be filed with this Order to begin the calculation of daily fines. BY THE COURT, Thomas A. lacey C.P.J. Distribution: Alan R. Mege, Esq. Denise Ross COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., Plaintiff : No. 07-6998-CV VS. : CIVIL ACTION DENISE ROSS, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on March 7, 2014, I served a true correct copy of Plaintiffs Motion for Contempt and proposed Order by mailing same, first class, postage prepaid to: Denise Ross, 148 E. North St., Carlisle, PA 17013. By: 'ge, Esqu Atty. T.D. #81288 Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 181016-1426 (610) 954-5393 CACH, LLC., Plaintiff Ig €j ' (` G r I`9 i� i`' i� tJ � $ i � i 20 it; VAR 8 PH 1:s. 6 CUMBERLAND D COO ' Y PENNSYLVANIA v. eouutp of QCumberlanb IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT DENISE ROSS, Defendant 2007 -06998 CIVIL TERM IN RE: PLAINTIFF'S MOTION FOR CONTEMPT ORDER OF COURT AND NOW, this 18th day of March 2014, upon consideration of Plaintiff's Motion for Contempt, it is hereby ORDERED that a Contempt hearing is scheduled for 11 April 2014 at 9:00 a.m., in Courtroom Number Six of the Cumberland County Courthouse, Carlisle, Pennsylvania. Plaintiff's request for counsel fees will be addressed at the above - scheduled contempt hearing. It is specifically noted that Defendant is DIRECTED to appear at the above - scheduled hearing. Failure to appear MAY result in the issuance of a bench warrant for Defendant's arrest. Thomas A. placey C.P.J. 2istribution: Alan R. Mege, Esq. Denise Ross 3 !E // COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., VS. DENISE ROSS, Plaintiff : No. 07-6998-CV Defendant CIVIL ACTION CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on March 21, 2014 I served upon Defendant, a letter seeking concurrance, Plaintiff s Motion for Continuance and proposed Order by mailing same, regular mail, postage prepaid to: Denise Ross, 148 E. North St., Carlisle, PA 17013. By: A . ege, Esqu Atty. I.D. #81288 Attorney for Plaintif P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., Plaintiff : No. 07-6998-CV vs. c? DENISE ROSS, -r\ Defendant -0 y MOTION FOR CONTINUANCE CACH,LLC. by and through its counsel, Alan R. Mege, Esquire, hereby moves this Honorable Court for a continuance and in support thereof states as follows: 1. A hearing is currently scheduled with regard to Plaintiff's Motion for Contempt in the above - captioned matter on April 11, 2014 at 9:00 am. A copy of the Cumberland County Order is attached as Exhibit "A ". 2. A continuance is required because Counsel for Plaintiff was previously scheduled to appear in Northampton County Court of Common Pleas at the same time and date. 3. Counsel for Plaintiff sent correspondence to Defendant on March 21, 2014 seeking concurrence, and Defendant is unopposed. A true and correct copy of the correspondence is attached hereto as Exhibit "B ". 4. Notice of this Motion and proposed Order were mailed to Defendant, via first class mail on March 21, 2014. A certificate of Service is attached hereto. WHEREFORE, Plaintiff, requests that this Honorable Court grant their motion and enter an Order continuing the April 11, 2014 hearing to a later date. : CIVIL ACTION an R. Mege, Esquir Atty. I.D. #81288 Attorney for P1a' tiff CACH, LLC., Plaintiff v. :_L . !v_. .. , i,.•. � ill: l i,���a., :. �.�. 2 101AR 18 FI1 I: Sri ?.1JM3ERLAN1U CGUNTY PENNSYLVANIA Conntp of Cainberlanb IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT DENISE ROSS, Defendant 2007 -06998 CIVIL TERM IN RE: PLAINTIFF'S MOTION FOR CONTEMPT ORDER OF COURT AND NOW, this 18th day of March 2014, upon consideration of Plaintiffs Motion for Contempt, it is hereby ORDERED that a Contempt hearing is scheduled for 11 April 2014 at 9:00 a.m., in Courtroom Number Six of the Cumberland County Courthouse, Carlisle, Pennsylvania. Plaintiff's request for counsel fees will be addressed at the above - scheduled contempt hearing. It is specifically noted that Defendant is DIRECTED to appear at the above - scheduled hearing. Failure to appear MAY result in the issuance of a bench warrant for Defendant's arrest. Distribution: Alan R. Mege, Esq. Denise Ross MAR 2.0 2014 Law Offices of Alan N1ege LAW OFFICES OF ALAN R. MEGE, ESQ. P.O. BOX 1426 70 EAST BROAD STREET BETHLEHEM, PA 18016 -1426 Licensed in PA and NJ Todd A. Johns, Esq. Of Counsel Denise Ross 148 E. North St. Carlisle, PA 17013 (610) 954 -5393 (610) 954 -5395 FAX AlanM_Esq @juno.com March 21, 2014 RE: CACH, LLC v. Ross Cumberland County # 2007 - 06998 -Civil Term Dear Ms. Ross: A hearing is currently scheduled for April 11, 2014 at 9:00 am with regard to Plaintiff's Motion for Contempt. Our office intends to request a continuance due to a scheduling conflict. If you are opposed to this Continuance, you must contact our office by March 31, 2014. Please be advised that if we are not contacted by you, we will assume that you are unopposed. I would appreciate your assistance in bringing this matter to an amicable conclusion. Should you have any questions or comments, please feel free to contact my office. ARM /llp Enc. Very truly yours, This message is from a debt collector, this is an attempt to collect a debt, and any information obtained will be used for that purpose, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., VS. DENISE ROSS, Plaintiff : No, 07-6998-CV Defendant : CIVIL ACTION CERTIFICATE OF SERVICE 1, Alan R. Mege, Esquire, hereby certify that 011 March 21, 2014 1 served upon Defendant, a letter seeking concurrance, Plaintiff's Motion for Continuance and proposed Order hy mailing same, regular mail, postage prepaid to: Denise Ross, 148 E. North St., Carlisle, PA 170 I 3. RECEIVED MAR 2 6 2014 u,k. Offices of Alan Nlege By: Alan R. Mege, Esquire Atty. I.D. #81288 Attorney for Plain P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 -.0 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., VS. DENISE ROSS, Plaintiff : No. 07-6998-CV Defendant : CIVIL ACTION ORDER cb N.) AND NOW, this 5 day of AVO4 t-- , 2014, it is hereby ordered and decreed that the Plaintiffs Motion for Continuance is Granted and the hearing originally scheduled for April 11, 2014 at 9:00 a.m. shall be continued until 1 b 20t1-, 2014 at • OD m . Courtroom # of the Cumberland County Courthouse, Carlisle, PA 17013-3387. _.„. • - Distribution: Alan R. Mege, Esquire, 70 E. Broad St., PO Box 1426, Bethlehem, PA 18016-1426 (V1<lise Ross, 148 E. North St., Carlisle, PA 17013 'QS PZI COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., VS. DENISE ROSS, Plaintiff : No. 07-6998-CV Defendant : CIVIL ACTION CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on April 11, 2014 I served upon Defendant, this Court's April 8, 2014 Order setting a Hearing date of May 16, 2014 by mailing same, regular mail, postage prepaid to: Denise Ross, 148 E. North St., Carlisle, PA 17013. By: Al . ege, Esqui tty. I.D. #81288 Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., VS. DENISE ROSS, Plaintiff : No. 07-6998-CV : CIVIL ACTION Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on April 14, 2014 I 141 ' -tr, 171 tzl erved upon Defendant, a letter seeking concurrance, Plaintiff's Motion for Continuance and proposed Order by mailing same, regular mail, postage prepaid to: Denise Ross, 148 E. North St., Carlisle, PA 17013. By: Alan ege, Esquire tty. I.D. #81288 Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., Plaintiff : No. 07 -6998 -CV vs. : CIVIL ACTION 0 a cn Defendant MOTION FOR CONTINUANCE c CACH,LLC. by and through its counsel, Alan R. Mege, Esquire, hereby moves this DENISE ROSS, Cfl Honorable Court for a continuance and in support thereof states as follows: 1. A hearing is currently scheduled with regard to Plaintiff's Motion for Contempt in the above -captioned matter on May 16, 2014 at 9:00 am. A copy of the Cumberland County Order is attached as Exhibit "A". 2. A continuance is required because Counsel for Plaintiff was previously scheduled to appear in Bucks County Court of Common Pleas at the same time and date. 3. Counsel for Plaintiff sent correspondence to Defendant on April 14, 2014 seeking concurrence, and Defendant is unopposed. A true and correct copy of the correspondence is attached hereto as Exhibit "B". 4. Notice of this Motion and proposed Order were mailed to Defendant, via first class mail on April 14, 2014. A certificate of Service is attached hereto. WHEREFORE, Plaintiff, requests that this Honorable Court grant their motion and enter an Order continuing the May 16, 2014 hearing to May 30, 2014 at 9:00 AM. Bv: an R. Mege, Esquir Atty. I.D. #81288 Attorney for Plaintiff --- 1 1. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., vs. DENISE ROSS, Plaintiff : No. 07 -6998 -CV Defendant : CIVIL ACTION ORDER -< AND NOW, this day of i 'Q-& — , 2014, it is hereby ordered and decreed that the Plaintiff's Motion for Continuance is Granted and the hearing��originally V" scheduled for April 11, 2014 at 9:00 a.m. shall be continued until (b 4 . 2014- 2014 at q 00tr m . Courtroom # of the Cumberland County Courthouse, Carlisle, PA 17013-3387. Distribution: --CODG % A - Y LAG -e Alan R. Mege, Esquire, 70 E. Broad St., PO Box 1426, Bethlehem, PA 18016-1426 Denise Ross, 148 E. North St., Carlisle, PA 17013 ► (4" RECEIVED APR 1 1 2014 Law Offices of Alert Mege LAW OFFICES OF ALAN R. MEGE, ESQ. P.O. BOX 1426 70 EAST BROAD STREET BETHLEHEM, PA 18016-1426 Licensed in PA and NJ Todd A. Johns, Esq. Of Counsel Denise Ross 148 E. North St. Carlisle, PA 17013 (610) 954-5393 (610) 954-5395 FAX A1anM_Esq@juno.com April 14, 2014 RE: CACH, LLC v. Ross Cumberland County # 2007 -06998 -Civil Term Dear Ms. Ross: A hearing is currently scheduled for May 16, 2014 at 9:00 am with regard to Plaintiff's Motion for Contempt. Our office intends to request a continuance due to a scheduling conflict. If you are opposed to this Continuance, you must contact our office by April 30, 2014. Please be advised that if we are not contacted by you, we will assume that you are unopposed. I would appreciate your assistance in bringing this matter to an amicable conclusion. Should you have any questions or comments, please feel free to contact my office. ARM/Ilp Enc. Very truly yours, Alan R Me copY This message is from a debt collector, this is an attempt to collect a debt, and any information obtained will be used for that purpose. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., vs. DENISE ROSS, Plaintiff : No. 07 -6998 -CV Defendant Uti : CIVIL ACTION O DER AND NOW, this day of , 2014, it is hereby ordered and decreed that the Plaintiff's Motion for Continuance is Granted and the hearing originally • scheduled for May 16, 2014 at 9:00 a.m. shall be continued until May 30, 2014 at eco -0 A.. Courtroom # (%� of the Cumberland County Courthouse, Carlisle, PA 17013- 3387. BY THE COURT: Thomas A. Placey Common Pleas Judge Distribution: Alan R. Mege, Esquire, 70 E. Broad St., PO Box 1426, Bethlehem, PA 18016-1426 Denise Ross, 148 E. North St., Carlisle, PA 17013 OR GI AL COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., vs. DENISE ROSS, Plaintiff : No. 07 -6998 -CV : CIVIL ACTION Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on May 12, 2014 I served upon Defendant, this Court's May 7, 2014 Order setting a Hearing date of May 30, 2014 by mailing same, regular mail, postage prepaid to: Denise Ross, 148 E. North St., Carlisle, PA 17013. By: . Mege, Esquire Atty. I.D. #81288 Attorney for Plaint'ff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., vs. DENISE ROSS, Plaintiff : No. 07 -6998 -CV c-: : CIVIL ACTION me Defendant PRAECIPE TO WITHDRAW PLAINTIFF'S MOTION FOR SANCTIO1Si ; TO THE CLERK OF SAID COURT: Please withdraw the Motion for Contempt filed in the above -captioned matter. Date: May 23, 2014 Alan R. Mege, Esq. Attorney ID No 1288 Attorney for ' laintiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 : c3 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC., Plaintiff : No. 07 -6998 -CV vs. : CIVIL ACTION DENISE ROSS, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on May 23, 2014, I served upon Defendant, a true and correct copy of Plaintiff's Praecipe to Withdraw Plaintiff's Motion for Sanctions by mailing same, first class, postage prepaid to: Denise Ross, 148 E. North St., Carlisle, PA 17013. By: Ian R. Mege, Esq Atty. I.D. #8128 Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393