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HomeMy WebLinkAbout04-0841,,,~ , ~ . 'COMMONWEALTH OF PENNSYLVANIA COUNTY OF: 09-1'02 ROBERT V. A~dre~s: 1901 STATE STREET CAMP HILL, PA (717) 761-0583 C/O WOLFSON & ASSOCIATES, 267 E MARKET ST YORK, PA 17403 17011-0000 PC NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF~ NAM~ and A~)DR£SS UPLATINUM FINANCL SRVCS CORP 267 E MARKET ST YOKK, PA 17403 VS. DEFENDANT: NAME and ADDRESS ~-SEBASTIAN, VITTORIO, ET ii.L. 242 S ENOLA DR ENOLA, PA 17025 L_ Docket No.: C'V'- 0000366 - 03 Date F led: 8/07/03 J THIS IS TO NOTIFY YOU THAT: 'dudgmenE ~ [X~ Judgment was entered for: (Name) ~'~ Judgment was entered against: (Name) DEFAULT JU~G~f~'NT~PLTF p?,A~TN~M FTNAN~T, SRV~ C. OWP S~RARTTAN, VTr~PORTO in the amount of $ (Date of Judgment) -'-]Defendants are jointly and severally liable. ~ Damages will be assessed on: ~jThis case dismissed without prejudice· Amount of Judgment Subject to ~ Attachment/42 Pa.C.S. § 8127 $ [~ Portion of Judgment for physical damages arising out/of ¢esid/ential lease $ (Date & Time) Amount of Judgment $ 2,216. O1 Judgment Costs $ 112.82 interest on Judgment $ .00 Attorney Fees $ .00 Total $ 2,328.83 Post Judgment Credits $ Post Judgment Costs $ ,,' Certified 46dgment Total '$ ANY PARTY HA~ 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 JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES. IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST DOME FROM THE COURT OF COMMON PLEAS ANO NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE. UNLESS THE ,JueGM~NT iS FNTEF~EO IN THE COUR'r OF CO~OH ~LEAS, A['!YON-~ !HTE~ESTE9 IN THE JUPG~ENT ~AY F!LE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DESTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. I ce~ffYthatt~isisatr~lt///~.or~heprDceeding$cont'iningthejudgment,I /,q Oete , Distriol 'ust,coI My commission expires first Monday of January, :2006 . SEAL AOPC315-03 DATE PRIN~ED: 10/29/03 4:09:47 P~ .,. ,'~.'> r'COMMONWEALTH OF PENNSYLVAN A COUNTY OF: CUMBERLAND 09-1-02 ROBERT V. MAN-LOVE ,~,~,~s~: 1901 STATE STREET CAMP HILL, PA (717) 761-0583 17011'0000 C/O WOLFSON & ASSOCIATES, PC 267 E MARKET ST YORK, PA 17403 NOTICE OF JUDGMENT/TRANSCI IPT CIVIL CASE PLAINTIFF: NA~E and ADORES$ FpLATIN1]M FINANCL SRVCS ~RP 267 E ~T ST YO~, PA 17~03 DEFENDANT: NAM~ and AOOR~SS FBE~BT~, VI~RIO, ET ~. 242 S ~O~ DR ~O~, PA 17025 L Docket No.: CV-0000366-03 I ~L-~ Date Fi ed: 8/07/03 THIS IS TO NOTIFY YOU THAT: SEBASTIA~T, HOLLY 'Judgment: ? '= " DISNTSSWD W/O PR;~dODICE '--}Judgment was entered for: (Name) [~] Judgment was entered against: (Name) in the amount of $ on: (Date of Judgment) ~] Defendants are iointly and severally liable. Damages will be assessed on: }~'] This case prejudice. dismissed without Amount of Judgment Subject to ~] Attachment/42 Pa.C,S. § 8127 $ [~] Portion of Judgment for physical damages arising out of residential lease $ fDate & Time) DEF 002 Amount of Judgment $ . O0 Judgment Costs $ . O0 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ .0 0 Post Judgment Credits Post Judgment Costs Certified Judgment Total $ $ ANY PARTY. HAS~ THE ,~IGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF,:JUDGMENT, BY FILING A NOTI~,E i OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WiTH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY SE ISSUED BY THE OISTRICT JUSTICE. UNLESS THE JUDGMENT iS ENTERED !N THE COURT OF CO,%".~.",O.%~ PLEAS, ANYC,~tE ~NTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SE~LES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. 'y , isia ue~~.f....~th, proceedings containing the judgment. My commission expires first Monday of January, 2006 . ' SEAL AOPC315-03 DATE 10/29/03 :11:59 PM IN Till! C()I ~RT ()F COMMC)N P[,E/\S OF (1 ~MBERLAND COUNTY. PI~NNSYIJV/XNLA PI,AT1NUM FINANCIAL SERVICES : CORP.. A MARYI,AND CORPORAFION No. ASSIGNEE OF Ff)RWAI~,D : PROPERTIISS. INC., ASSIGNEE OF BANKFIRS I' C()RI~ORATION. INC. : Phtintiff VITTOI'[I() Dcl~ndant AFFIDAVIT OF NON-MILITARY SERVICE ('()MM()N\VI':\I,1II ()F PI£NNSYLV/\NIA : COUNI'Y ()l, Y()RK : 1, Amy F. Wolfson, Esquire, being duly sworn according to law, depose and say that I am thc Attorney ~br thc Plaintiff in the above-captioned matter, and that to the best of my know)edge. }n/brmation and belief DetCndant. VITTORIO SEBASTIAN. above named, is mcr 21 years ol'agc: is hist knowto reside at 242 S ENOLA DR. ENOLA PA 17025-2812. CU'MBERLANI) County. I)ennsylvania: is not in thc military service of thc [ inited States or its Allies. or otherwise within the provisions of the SoldierC and Sail~ws Congress of 1040 and its Amendments. Attorney tbr the Plaintif[/ Atlorncy ID~ 87062 Wol polT ~ Abramson. LLP 267 East Market Street York, PA 17403 SWORN and Si ;BSCRIBI~;D [o bclbrc mc this ~ day Notar5 Public My Commissiol Exp~s Jut;, 23 2007 IN 'FILE COURT OF COMMON PLEAS OF CI IMBERI,AND COUN'I Y. PENNSYLVANIA PLATINUM FINANCIAI~ SERVICES No. ~ ~ /~'/'t// CORP., A MARYLAND CORPORATION ASSIGNEE OF FORWARD PROPERTII~S. INC.. ASSIGNEE OF I~ANKFIRST CORPORATION. INC. Plainlil'f VITTORIO SEBASTIAN Det'cndant CERTIFICATE OF RESIDENCE I. Am3 I:. Wolf son. Esquire. duc hereby certify' that the last known address of thc above referenced l)el'cndant is as tbllox~s: VITTORIO SEBASTIAN _4_ S ENOI,A DR F. NOI,A PA 17025-2812 Date: Respcctlhlly submitted. WO'LPOFF'& ABRAM/~)N, LLP 267 East Market ~qtree~ York. I'A 17403 (717) 846-1252 ID No. 87062 Attorney lbr Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLATINUM FINANCIAL • SERVICES CORP., • = �' -0 3 s..., Plaintiff : No. 2004-841 CIVIL TERM rrico co rrt ri vs. "r—z rn ,, : CIVIL ACTION 'c-Q VITTORIO SEBASTIAN, Defendant • - "' PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO INTERROGATORIES IN AID OF EXECUTION And now comes 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$2,328.83 plus costs was entered in Cumberland County on February 26, 2004. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on July 25, 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 August 29, 2013. A certificate of Service is attached hereto as Exhibit"A". 6. As of September 13, 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 matter. 9. Concurrence with the Pro Se Defendant 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. lan R. Mege, Esq. Attorney ID No. : 288 Attorney for P1- ntiffs P.O. Box 14 Bethlehem, PA 18016-1426 (610) 954-5393 -2- COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLATINUM FINANCIAL • SERVICES CORP., • Plaintiff : No. 2004-841 CIVIL TERM vs. • : CIVIL ACTION VITTORIO SEBASTIAN, Defendant • CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on August 29, 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: Vittorio Sebastian, 1438 3rd Street, Enola, PA 17025. By: /1111111111116111111111111Irr an R. Mege, Esquire Atty. I.D. #81288 Attorney for Plainti f P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 PLATINUM FINANCIAL SERVICES r CORP. Plaintiff IN THE COURT OF COMMON PLEAS V. OF THE NINTH JUDICIAL DISTRICT VITTORIO SEBASTIAN, Defendant 2004-00841 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO INTERROGATORIES IN AID OF EXECUTION ORDER OF COURT AND NOW this da Y p of September 2013, upon consideration of Plaintiff's Motion to Compel, a RULE is issued upon Defendant to show cause why an order compelling Defendant to respond to the Interrogatories in Aid of Execution.should not be issued. PLAINTIFF shall effectuate service of this Order upon Defendant. A motion to make this Rule absolute will not be entertained until proof of service is filed. RULE RETURNABLE twenty (20) days from the date of service by Plaintiff. BY THE COURT, Thomas A. Placey C.P.J. Distribution,' n R. Mege, Esq. � cz!D _ ittorio Sebastian MC `' ' CO �yV] •• --..;r-1 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLATINUM FINANCIAL • 2 ` SERVICES CORP., • - rrt n _ Plaintiff : No. 2004-841 CIVIL TERM rrl rri rm ,� -v • ��, » vs. : CIVIL ACTION 3>c�z VITTORIO SEBASTIAN, : c r'.9 ter;3 Defendant • �—`� CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire,hereby certify that on September 23, 2013, I served a true correct copy of the Court's September 19, 2013 Rule, by mailing same, first class,postage prepaid to: Vittorio Sebastian, 1438 3`d Street, Enola, PA 17025. By: -411111111Cliir'' - an R. Mege, Esquir- Atty. 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 PLATINUM FINANCIAL • SERVICES CORP., ? Plaintiff : No 2004-841 CIVIL TERM ' ‘rn c24 vs. • cf); N c .t t : CIVIL ACTION -o -1'; VITTORIO SEBASTIAN, : v -Defendant • 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 September 19, 2013, a Rule was issued upon the Defendant, Vittorio Sebastian, to show cause why Plaintiff's Motion to Compel should not be granted. A copy of the Order is attach hereto as Exhibit"A". 2. The Rule Returnable was to be answered within twenty(20) days of service of the September 19, 2013, Order in the Office of the Cumberland County Prothonotary. As of October 18, 2013, no answer has been filed. 3. A copy of this Motion and proposed Order were mailed to Defendant, via first class mail on October 18, 2013. A certificate of Service is attached hereto. 4. Plaintiff requests that the Rule be made Absolute. 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, as well as such other and further relief as the Court may deem just and appropriate. Alan R. Mege, Esq. Attorney ID No. 8 88 Attorney for Plai iff PLATINUM FINANCIAL SERVICES ,ioi .�ii1 rn. CORP., ; ;1u '",,,u' y.; Rit.tat Plaintiff ' ='`''`' IN THE COURT OF COMMON PLEAS v. OF THE NINTH JUDICIAL DISTRICT • VITTORIO SEBASTIAN, Defendant 2004-00841 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO INTERROGATORIES IN AID OF EXECUTION p ORDER OF COURT AND NOW, this -� da y P p of September 2013, upon consideration of Plaintiff's Motion to Compel, a RULE is issued upon Defendant to show cause why an order compelling Defendant to respond to the Interrogatories in Aid of Execution should not be issued. • PLAINTIFF shall effectuate service of this Order upon Defendant. A motion to make this Rule absolute will not be entertained until proof of service is filed. RULE RETURNABLE twenty (20) days from the date of service by Plaintiff. BY THE COURT, Thomas A. Placey -um Distribution: : `. �`: z wr Alan R. Mege, Esq. -- -�-r r �F.... .w w Vittorio SebastianEQ 2 3 2013 < • ) 2c-) 3 .�?r o -- ik).( rat • COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • PLATINUM FINANCIAL • SERVICES CORP., Plaintiff : No. 2004-841 CIVIL TERM • vs. : CIVIL ACTION VITTORIO SEBASTIAN, • Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on October 18, 2013, I served Plaintiff's Motion to Make the Rule Absolute mailing same, first class, post prepaid to: Vittorio Sebastian, 1438 3`d Street, Enola, PA 17025. By: Al..- ' . Mege, Esquire • tty. I.D. #81288 Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 PLATINUM FINANCIAL SERVICES 1 ' ��� ,�i�t tit; ' a ''�� CORP., Plaintiff .i tr . IN THE COURT OF COMMON PLEAS v. OF THE NINTH JUDICIAL DISTRICT /0011 - S41 VITTORIO SEBASTIAN, 2000--00 CIVIL TERM Defendant IN RE: PLAINTIFF'S MOTION TO MAKE RULE ABSOLUTE ORDER OF COURT AND NOW, this Z44A. day of October 2013, upon consideration of Plaintiff's Motion to Make Rule Absolute, it is hereby ORDERED that the Rule issued on 19 September 2013 is hereby made absolute and Plaintiff's Motion 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. BY THE COURT, Thomas A. Placey C.P.J. Distribution: I"v � 1 A S,U: d Ian R. Mege, Esq. 0' 1 r iyk-i,a?4al Jr /ittorio Sebastian J , COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • PLATINUM FINANCIAL • SERVICES CORP., Plaintiff : No. 2004-841 CIVIL TERM vs. • : CIVIL ACTION VITTORIO SEBASTIAN, ` w Defendant • W . ° '' CERTIFICATE OF SERVICE v o I, Alan R. Mege, Esquire, hereby certify that on November 1, 2013, I servet,a txf correct copy of the Court's October 25, 2013, Order by mailing same, first class, postage prepaid to: Vittorio Sebastian, 1438 3' Street, Enola, PA 17025. By: A - • . Mege, Esquire Atty. I.D. #81288 Attorney for Plaintiff P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 w I ' COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLATINUM FINANCIAL • SERVICES CORP., • rTi Plaintiff : No. 2004-841 CIVIL TERM ii co ;r:;� vs. • : CIVIL ACTION - VITTORIO SEBASTIAN, : >` "' 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$2,328.83 plus costs was entered in Cumberland County on February 26, 2004. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on July 25, 2013. 3. Pursuant to Pa.R.C.P. 4006 (a) (2), Defendant's responses to the Llterrogatories 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 tiled and an Order entered on October 25, 2013, requiring Defendant, within twenty(20) days, to make full and complete answers to Interrogatories. A true and correct copy of the October 25, 2013, Order is attached as Exhibit 5. As of December 20, 2013, Plaintiff has not received Defendant's answers to Interrogatories. 6. A copy of this Motion and proposed Order was sent to Defendant on December 5, 2013. A Certificate of Service is attached hereto. 7. Counsel for Plaintiff sent correspondence to Defendant on December 5, 2013, seeking concurrence, and Defendant has not responded. A true and correct copy of the correspondence is attached hereto as Exhibit"B". 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 October 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 may be imposed upon Defendant following application to this Court. Alan R. Mege, Es . Attorney I o. 81288 Attorney for Plaintiff PO Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 -2- PLATINUM FINANCIAL SERVICES '''`ifill orn CORP., �Qri� fir, Di- Plaintiff Y+S�f IN THE COURT OF COMMON PLEAS v. OF THE NINTH JUDICIAL DISTRICT /0011 ' 241 VITTORIO SEBASTIAN, 2 00-00 CIVIL TERM Defendant IN RE: PLAINTIFF'S MOTION TO MAKE RULE ABSOLUTE ORDER OF COURT AND NOW, this 14.11\ day of October 2013, upon consideration of Plaintiffs Motion to Make Rule Absolute, it is hereby ORDERED that the Rule issued on 19 September 2013 is hereby made absolute and Plaintiffs Motion 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. BY THE COURT, Thomas A. Placey C.P.J. Dtribution: :IF.IV/t iA S {'I Alan R. Mege, Esq. '1„7'1 r.i,,vT:3p111':' /ittorio Sebastian • ','` :4 Isi 1;?7 AO f s._'. L ij�, ,t • P" lAy , 111111•... 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 December 5, 2013 Vittorio Sebastian 1438 3rd Street Enola, PA 17025 RE: Platinum Financial Services Corp. v. Sebastian No. 2004-841 Dear Mr. Sebastian: Enclosed please find a copy of Plaintiff's Motion for Sanctions, which we intend to file with the Court. Please provide your concurrence or non-concurrence with regard to said Motion by December 19, 2013. I would appreciate your assistance in bringing this matter to an amicable conclusion. Should you have any questions or comments, please reel tree to contact my office. Very truly yours, Alan R. Mege ARM/cms Enc. 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 PLATINUM FINANCIAL • SERVICES CORP., Plaintiff : No. 2004-841 CIVIL TERM • vs. : CIVIL ACTION VITTORIO SEBASTIAN, • Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on December 5, 2013, I served upon Defendant,a true and correct copy of Plaintiff s Motion for Sanctions and proposed Order by mailing same, first class, postage prepaid to: Vittorio Sebastian, 1438 3`d Street, Enola, PA 17025. By: an R. Mege, Esquire Atty. I.D. #81288 Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 PLATINUM FINANCIAL SERVICES dpi ;�4111 I« aripennsotzt CORP. < z . Plaintiff IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT v. 2004-00841 CIVIL TERM VITTORIO SEBASTIAN, Defendant - rri r-0 IN RE: PLAINTIFF'S MOTION FOR SANCTIONS Cri ORDER OF COURT 4J` AND NOW, this day of January 2014, upon consideration of Plaintiff's r.M; 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 $100.00 counsel fees, will be imposed. PLAINTIFF shall effectuate service of this Order upon Defendant. Proof of service must be filed with this Order to begin the calculation of daily fines. BY THE COURT, Thomas A. Placey C.P.J. Distribution: ✓Alan Mege, Esq. Vittorio Sebastian i£$' 022,1.04., /PPil (") COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSY-0 I TASIA --t rn L.. PLATINUM FINANCIAL • = i n SERVICES CORP. • -(3' ' r Plaintiff No. 2004-841 CIVIL TERM ::r =CD - r3 C r•= vs. Yom . •• CIVIL ACTION VITTORIO SEBASTIAN, Defendant • CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on January 6, 2014, I served a true correct copy of the Court's January 3, 2014, Order,by mailing same, first class,postage prepaid to: Vittorio Sebastian, 1438 3`d Street, Enola, PA 17025. By: an R. Mege, Esquire Atty. I.D. #81288 Attorney for Plainti P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLATINUM FINANCIAL SERVICES CORP., Plaintiff VS. VITTORIO SEBASTIAN, Defendant : No. 2004 -841 CIVIL TERM : CIVIL ACTION 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 $2,328.83 plus costs was entered in Cumberland County on February 26, 2004. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on July 25, 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 October 25, 2013, requiring Defendant, within twenty(20) days, to make full and complete answers to Interrogatories. A true and correct copy of the October 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 3, 2014, requiring Defendant to pay a fine of $100.00 to the use of the Plaintiff until Defendant complies with the Court's Order of October 25, 2013, requiring Defendant to make full and complete answers to the interrogatories. A true and correct copy of the January 3, 2014, Order is attached as Exhibit "B ". 6. A true and correct copy of the January 3, 2014, Order was served upon Defendant on January 6, 2014. A copy of the Certificate of Service is attached as Exhibit "C ". 7. As of April 7, 2014, the Plaintiff has yet to receive the answers to interrogatories, court awarded fees, or court imposed fines. 8. A copy of this Motion and proposed Order were mailed to Defendant on April 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 Vittorio Sebastian, 1438 3`d Street, Enola, PA 17025 and 123 Westmoreland Ave., Enola, PA 17025, 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 will be imposed upon Defendant following application to this Court. n R. Mege, Esq. Attorney ID No. 8 Attorney for Plai tiff PLATINUM FINANCIAL SERVICES CORP., Plaintiff v. VITTORIO SEBASTIAN, Defendant IN RE: PLAINTIFF'S MOTION TO MAKE RULE ABSOLUTE ORDER OF COURT AND NOW, this day of October 2013, upon consideration of Plaintiff's Motion to Make Rule Absolute, it is hereby ORDERED that the Rule issued on 19 September 2013 is hereby made absolute and Plaintiff's Motion 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. IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 200q.sql 2003fre0491 CIVIL TERM Detribution: Alan R. Mege, Esq. /Mono Sebastian BY THE COURT, Thomas A. Placey f INVAIASMI2c1 Wd eZ 130 E;',7, C.P.J. PLATINUM FINANCIAL SE CORP. Plaintiff v. VITTORIO SEBASTIAN, Defendant Ina IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT (`') -C7 -;. .4-- 2004 -00841 CIVIL TES IN RE: PLAINTIFF'S MOTION FOR SANCTIONS ORDER OF COURT AND NOW, this day of January 2014, upon consideration of Plaintiffs 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 4- (23, 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 -� r', 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. Distribution: Alan R. Mege, Esq. Vittorio Sebastian Thomas A. Placey C.P.J. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLATINUM FINANCIAL SERVICES CORP., Plaintiff vs. : No. 2004 -841 CIVIL TERM : CIVIL ACTION VITTORIO SEBASTIAN, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on January 6, 2014, I served a true correct copy of the Court's January 3, 2014, Order, by mailing same, first class, postage prepaid to: Vittorio Sebastian, 1438 3`d Street, Enola, PA 17025. By: R. Mege, Esqui Atty. 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 PLATINUM FINANCIAL SERVICES CORP., Plaintiff vs. : No. 2004 -841 CIVIL TERM : CIVIL ACTION VITTORIO SEBASTIAN, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on April 7, 2014, I served a true correct copy of Plaintiffs Motion for Contempt and proposed Order by mailing same, first class, postage prepaid to: Vittorio Sebastian, 1438 3`d Street, Enola, PA 17025 and 123 Westmoreland Ave., Enola, PA 17025. By: an R. Mege, Esquir- Atty. I.D. #81288 Attorney for Plai tiff P.O. Box 1426 Bethlehem, PA 18016 -1426 (610) 954 -5393 PLATINUM FINANCIAL SERVICES CORP., Plaintiff v. VITTORIO SEBASTIAN, Defendant Catnap of Cunrberianb IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 2004 - 000841 CIVIL TERM IN RE: PLAINTIFF'S MOTION FOR CONTEMPT ORDER OF COURT AND NOW, this 16th day of April 2014, upon consideration of Plaintiff's Motion for Contempt, it is hereby ORDERED that a Contempt hearing is scheduled for 28 May 2014 at 3:00 p.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: /4an R. Mege, Esq. y /c/ittorio Sebastian homas A. Placey C.P.J. VINVAlASNN3d AINfQ3 ONV11130W110 £S ?E Nd 91 2IdV't1Oi A 4! # 0t 0HIO8d 3H . c COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA "6:3 .70 ro s■-) cn CD PLATINUM FINANCIAL SERVICES CORP., Plaintiff VS. No. 2004-841 CIVIL TERM : CIVIL ACTION VITTORIO SEBASTIAN, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on April 21, 2014, I served a true correct copy of this Court's April 16, 2014, Order by mailing same, first class, postage prepaid to: Vittorio Sebastian, 1438 3' Street, Enola, PA 17025 and 123 Westmoreland Ave., Enola, PA N) 17025. By: Ala ege, Esquire 1.D. #81288 Attorney for Plaintif P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLATINUM FINANCIAL SERVICES CORP., Plaintiff vs. VITTORIO SEBASTIAN, Defendant : No. 2004 -841 CIVIL TERM : CIVIL ACTION PRAECIPE TO WITHDRAW PLAINTIFF'S MOTION FOR SANCTIONS TO THE CLERK OF SAID COURT: Please withdraw the Motion for Contempt filed in the above - captioned matter. Date: May 28, 2014 an R. Mege, Esq. Attorney ID No. 8 :8 Attorney for Plai tiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954 -5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLATINUM FINANCIAL SERVICES CORP., Plaintiff VS. : No. 2004-841 CIVIL TERM : CIVIL ACTION VITTORIO SEBASTIAN, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on May 28, 2014, I served upon Defendant, a true and correct copy of Plaintiffs Praecipe to Withdraw Plaintiffs Motion for Sanctions by mailing same, first class, postage prepaid to: Vittorio Sebastian, 1438 3rd St., Enola, PA 17025. By: an R. Mege, Esqu Atty. I.D. #81288 Attorney for Pla tiff P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 PLATINUM FINANCIAL SERVICES, CORP., Plaintiff v VITTORIO SEBASTIAN, Defendant . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA . THE NINTH JUDICIAL DISTRICT . CIVIL ACTION - LAW . 2004-0841 CIVIL TERM IN RE: MOTION DISMISSED ORDER OF COURT AND NOW, this 28th day of May, 2014, the Court waiting 15 minutes for either party to Motion for Contempt, and neither party motion is dismissed without prejudice. appear on Plaintiff's having appeared, the Alan R. Mege, Esquire P.O. Box 1426 70 East Broad Street Bethlehem, PA 18016-1426 For Plaintiff Vittorio Sebestian. 1438 3rd Street Enola, PA 17025 :mae ea/Discs in„l�.L. a/v��y Thomas A. Placey C.P.J. C1 r-.. m co r Cn 1 C CD nD AC, 2.C) 5 N -J