The URL can be used to link to this page

Home My WebLink About08-1603IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING, LLC Plaintiff VS KEITH R MARTIN Defendant(s) No. 08 - 1(003 CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT 01 V i I I-ar n Please enter Judgment in favor of Plaintiff and against Defendant(s), KEITH R MARTIN , for want of pursuant to the District Justice Transcript. (X) Amount due $4,276.49 TOTAL $4,276.49, plus interest and costs (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( X ) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. ( ) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occured and at least ten days prior to the date of the filing of this pram?ipe and a copy of the notice is attached. Date: Amy F. Doyle #87 2 / Daniel F. Wn] Philip C. Warholi #863 D vid R. Gall vay #87: Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff NOW, MQrrh fl , 20-a-, JUDGME 71S ELATE ABOVE. Protho tary/Clerk, Ci rvisi By: Deputy W&A File No. 179333203 COMMONWEALTH OF PENNW,LVANIA fft [ INTY nP:- CUMBERLAND Mag. Dist. No.: 09-2-01 MDJ Name: Hon. PAULA P. CORREAT, Address .2260 SPRING:°RD :SUITE #3 CARLISLE, . PA Telephone (717 218-5250 17013-0000 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rLVNV FUNDING LLC 4660 TRINDLE ROAD APT/STE 300 CAMP HILL, PA 17 011 L v8. DEFENDANT: ; NAME and ADDRESS 'f MARTIN,.' ARTIN,.' KEITH R 16 2 MOHAWK RD C/O WOLPOFF A ABRAMSON LLP 4660 TRINDLE ROAD APT/STE 300 CAMP HILL, PA 17011 THIS IS TO NOTIFY YOU THAT: FOR PLAINTIFF 1/14/08 Judgment (Date of Judgment) _, . ,.. - Judgment was entered for: (Name) LVNV FUNDING LLC Judgment was entered against: (Name) MARTIN, KEITH R in the amount of $ 4, 276.4 Defendants are jointly and severally liable. Damages will be assessed on Date & Time ? This Lase dismissed without prejudice. Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease J ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST -COME FR01d,T1iEtGWRT pIL 0",LEAS AND- -F_URTHER PRgCf-S%kIIIAY._[3E.tUggP.RY, TN_E MAGI FzR'AL DISTRICT JUDG_.E UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAV FILE T A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. ? _ t Lf -09 Date - certify that this isa true corr copy oft (=A rocee Date My commission expires first Monday of January, 2012 NE",ILLE, PA 17241 L J, Docket No.: CV-0000188-07 Date Filed: 12/03/07 s Magisterial: District Judge f ntaining the judgment. Magisterial District Judge SEAL AOPC 315-07 DATE PRINTED: 1/14/08 10:16:00 AN . t ? ?? ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING, LLC Plaintiff No. VS CIVIL ACTION - LAW KEITH R MARTIN Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLAND The undersigned counsel, being duly sworn according to law, depose and say that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief Defendant, Keith R Martin, above-named, is over 21 years of age; is last known to reside at 162 Mohawk Rd Newville, County of Cumberland, Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act and its Amendments. Date: S' Amy F. Doyle #87 2 / Daniel F. Wo Philip C. Warholic 8634 R. Ga ay #8732 Tonilyn M. Chippie # 52 Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff SWORN and SUBSCRIBED to before me this day of ??.U20 C. SYLV IA E Notarial Seal Cortney M. Fantom, Notary Public Hampden Twp., Cumberland County Commission ires Nov. 23 2009 Member, Permsyt ania Association Or No<ar!es Notary Pub l4 W & A File No. 179333203 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING. LLC Plaintiff VS KEITH R MARTIN Defendant(s) No. CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I hereby certify that the precise address of Plaintiff is: Lvnv Funding, Llc 15 South Main Street Greenville SC 29601 and certify that the last known address of the within Defendant(s) is: Keith R Martin 162 Mohawk Rd Newville PA 17241 G C Date: l L Amy F. Doyle #8 062 / Daniel F. Wolfson #20617 Philip C. Warholi 1#8634 David loway #873 Tonilyn M. Chippie #87852 ar asz 6469 Robert N. Polas, Jr. #201259 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 179333203 J F-j Cro Co ( I -t J ?- _r, E3 :5 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING. LLC Plaintiff No. VS CIVIL ACTION - LAW KEITH R MARTIN Defendant(s) TO: KEITH R MARTIN 162 MOIL V'VTK RD NEWVILLE, PA 17241 NOTICE OF ORDER, DECREE OR JUDGMENT You are h reby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on Ir?o$ in accordance with the provisions of Pa. R.C.P. 236. ( ) Decree Nisi in Equity ( ) Final Decree in Equity ( ) Judgment of ( ) Confession ( ) Verdict ( ) Default ( ) Non-suit ( ) Non-pros ( ) Arbitration Award (X) Judgment is in the amount of $4,276.49, plus costs. (X) District Justice transcript of judgment in civil action in the amount of $3,553.51, attorney's fees in the amount of $0.00, interest in the amount of $596.98, plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Pennsylvania Department of Transportation. By: othonotary If you have any questions regarding ' otice, please contact the filing party. .? o Date: Amy F. Doyle #8t62 / Daniel F Philip C. Warholic 4 /David . G oway #873 Tonilyn M. Chippie #87852 ar . Ehasz #86469 Robert N. Polas, Jr. #201259 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 179333203 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 LVNV FUNDING, LLC ASSIGNEE OF SHERMAN ACQUISITION ASSIGNEE OF SEARS vs. KEITH R MARTIN Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JUDGMENT NO. 08-1603-CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $4,276.49. (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against,KEITH R MARTIN located at 162 MOHAWK RD, NEWVILLE, PA 17241, Defendant(s) (3) and against, M & T BANK located at 1 W HIGH ST, CARLISLE, PA, Garnishee(s); (4)- and index this writ =?,• - - (a) against, KEITH R MARTIN , Defendant(s) and (b) against, M & T BANK, Garnishee(s), as a lis pendens against the real property of the Defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property) ***GARNISH ONLY*** You are directed to attach the property of the Defendant(s) not levied upon in the possession of M & T BANK located at 1 W HIGH ST, CARLISLE, PA , Garnishee(s). All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes. Amount due $4,276.49 Interest from 03/11/2008 To Be Determined At an interest rate of 6% per year Total ,276.49 Plus costs & interest Date: o? Amy F. Doyle #81062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / David R. Galloway #87326 Tonilyn M. Chippie #87832 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 179333203 XXX-XX-4887 ct Sty P-) IF ? -o ? v O rann b' W -6? A.i ? .mac d al O b C J PV C3 z MIM -17 M, of f.a C WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-1603 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LVNV FUNDING, LLC, assignee of SHERMAN ACQUISITION, assignee of SEARS, Plaintiff (s) From KEITH R. MARTIN, 162 Mohawk Rd., Newville, PA 17241 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: M & T BANK, 1 W. High St., Carlisle, PA 17013 All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securites, coupons and safe deposit boxes. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,276.49 L.L. $.50 Interest from 3/11/08 at an interest rate of 6% per year - To be Determined Atty's Comm % Atty Paid $54.25 Plaintiff Paid Date: 3/24/08 (Seal) REQUESTING PARTY: Name AMY F. DOYLE, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone : 717-303-6700 Supreme Court ID No. 87062 Due Prothy $2.00 Other Costs Curti ong, Pr otary By: Deputy SHERIFF'S RETURN - GARNISHEE CASE NO: 2008-01603 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND LVNV FUNDING LLC VS MARTIN KEITH R And now NOAH CLINE ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0013:20 Hours, on the 28th day of March , 2008, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT MARTIN KEITH R hands, possession, or control of the within named Garnishee M & T BANK 1 WEST HIGH ST , in the CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to JESSICA C. REESE (TELLER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscribed to before me this true and made So ans .00 .00 .00 R. Thomas Kline .00 Sheriff of Cumberland County .00 0 0 V, ylb 316 8 03/31/2008 day of By Deputy Sheriff A.D 06'623-' 08, 13 ; 33 FROM- T-269 P015/021 F-299 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING, LLC ASSIGNEE OF SHERMAN ACQUISITION ASSIGNEE OF SPARS Plaintiff VS KEITH R MARTIN Defendant(s) No. 08-1603-CIVIL TERM CIVIL ACTION - LAW ?Ks INTERROGATORIES TO GARNISHEE TO: M & T BANK 1 W HIGH ST CARLISLE, PA ` PURSUANT 'TO RL-LE 332.3.) OF t'flE RULES OF CIVZ PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. issued. B. The term "Defendant(s)" means the individual(s) or entity against whom the. Writ of Execution was C. "You" means the main office and all branch offices, representatives, employees, and agents of your organization. D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment which is in your possession, custody or control is attached, including all property of the Defendant(s) which comes into your possession thereafter. E. These Interrogatories are considered to be continuing and therefore should be modified,or supplemented as you receive further or additional information. F. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate is to be used, it should be identified as such, and an explanation should be given as to the basis on which the estimate is made, and the reason the exact information cannot be furnished. G. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys. W&A File No. 179333203 XXX-XX-4887 O3 ;23-'03 13;33 FROM- T-269 P026/021 F-299 THTS IS A JOINT ACCd?ANT(S)T KEITH R GSH E MARTIN M & T Bank roquires written APR 1.8 2003 Authorization of both ow l a'9EPft1T 3RY1A=- At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any checking, savings, lines of credit, certificate of deposit's or other depository accounts with your institution. If so, state the identification numbers of those accounts, and the amount or amotmts the Defendant(s) has in each account. If the Defendant(s) maintains any of these jointly with any other person, or persons. give their name and address. ?S dalancE'as Provided .May not PcflQCt Unposted Tr,,3, ., t"10,1; Dor or Legal I A. DIREM5106MACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. aa.-- 2. If you are a bank or other financial institution, at the time you were served or at any subsequent time. did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the mason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. tAo 3. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. 8123? If -so, identify each account. 4. TRANSFER OF PROPERTY: At any time after you were served did you pay, transfer or deliver any money. or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? 5. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, include the identification number or other designation of the box or boxes. Include a full description of the contents and also the amount of cash among those contents. If the Defendant(s) maintains any of these jointly with any other person or persons give their full name and address. No W&A File No. 179333203 XXX-XX-4887 03-0-'02) 13:33 FROM- T-269 P017/021 F-299 6. REAP, OR PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or not Defendant(s) owns any personal property that was in your possession and/or control. If so, include a full description of all personal property giving full value and present location. State also whether or not there are any encumbrances or liens holders, the present balance of the encumbrance. State where and when the encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. 7. OTHER ASSETS: At the time you were served or at any subsequent time, did you know of the existence of any other asset(s) of the Defendant(s) which are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset. 8. PROPERTY HELD AS A RDUCIARX:. __. -At-the titne'you wetr sc ved cu- At Siny subx .-imriz tiriae, dial you hold as a fiduciary any property in which any Defendant(s) had an interest? If so, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s). 9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees charged by you against the Defendant(s) or account(s) of the Defendant(s) for the completion of this Answer. If yes, outline the exact amount of any fees due, and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer. 1?1 Date. I!? Amy F. Doyl #87062 / Daniel P. Wolfson #20617 Philip C. Warholic #86341 / David R. Galloway #87326 Tonilyn M. Chippie #87852 / Sarah E. Ehasx #86469 Robert N. Polas, Jr. #201259 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff BANK W&A File No. 179333203 XXX-XX-4887 r? ? i C ` . .5?? ?? l ? ° ? . 1?, ?' 4? Ik ? .S r' 5T' _ ? ?1 C?; r '.:.C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING, LLC No. 08-1603-CIVIL TERM ASSIGNEE OF SHERMAN ACQUISITION ASSIGNEE OF SEARS Plaintiff VS KEITH R MARTIN Defendant(s) CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, M & T BANK, discontinued, upon payment of your costs only Respectfully Submitted, fL a Date: Amy F. Doyle #87062 i ip C. Warholic #86341-7- David R. Galloway #8732 ar asz#? Robert N. Polas, Jr. #201259 Mann Bracken LLC The Successor by Merger to Wolpoff & Abramson, L.L.P. and Eskanos & Adler, P.C. 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff File No. 179333203 00 ; 4 1 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Advance Costs: 150.00 86.19 Docketing 18.00 63.81 Poundage 1.69 Advertising Refunded on 11/07/08 Law Library .50 Prothonotary 2.00 Milage 5.00 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee 9.00 So Answers, 86.19 ? ? a.? o ?i/ p 8 ? , r - .100 R. Thomas Kline, Sheriff By Z ? :E ci S Z UN 8001 Vd 'Alrtiii 4 331213HS 3H + ,2 5 . l Uz.4 G ?'' ? .2l Qd ?. g Q L)i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-1603 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LVNV FUNDING, LLC, assignee of SHERMAN ACQUISITION, assignee of SEARS, Plaintiff (s) From KEITH R. MARTIN, 162 Mohawk Rd., Newville, PA 17241 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: M & T BANK, 1 W. High St., Carlisle, PA 17013 All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securites, coupons and safe deposit boxes. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,276.49 L.L. $.50 Interest from 3/11/08 at an interest rate of 6% per year - To be Determined Atty's Comm % Arty Paid $54.25 Plaintiff Paid Date: 3/24/08 (Seal) Due Prothy $2.00 Other Costs Curtis R. Long, Proth By: Deputy REQUESTING PARTY: Name AMY F. DOYLE, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87062