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HomeMy WebLinkAbout08-34450 ,k COMMONWEALTH OF PENNSYLVANIA ?C4'NTY OF: CDM$? q` Mag. Dist. No.. 09-1-01 MDJ Name: Hon. CHARLES A. CLEMENT, Address: 400 BRIDGE ST OLDS TOWNE COMMONS NEW CUMBERLAND, PA Telephone: (717 ) 774-5989 UNIFUND CCR PARTNERS 1729 PITTSTON AVE ABRAHAMSEN & ASSOC PC SCRANTON, PA 18505 E0 -SUITS 3 17070 THIS IS TO NOTIFY YOU THAT: Judgment: DBFAULT_ JDDMMT PLTF ® Judgment was entered for: (Name) ® Judgment was entered against: (Name) in the amount of $ 2,674.11 68 - Mqs (2sv11 -grin NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME: and ADDRESS FUNIFDND CCR PARTNERS 1729 PITTSTON AVE ABRASAMSEN & ASSOC PC LSCRANTON, PA 18505 J VS. DEFENDANT: NAME and ADDRESS r-SHORT, JAMIE 503 MARKET STREET NEW CUMBERLAND, PA 17070 L J Docket No.: CV-0000086-08 Date Filed: 2/11/08 (Date of Judgment) 3_/11/08 UNIPUND CCR PARTNERS SHORT, JAMIE ? Defendants are jointly and severally liable. 1-1 Damages will be assessed on Date & Time ? This case 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 $ Amount of Judgment $ 2,064.93 Judgment Costs $_ 93.00 Interest on Judgment $ .0 Attorney Fees $ Total $ 2,674.16 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ 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 FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE 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. 3/11/2008 ? ? Date , Magisterial District Judge I certify that this is a true a correct opy a ord of r c edings containing the judgment. MAY 2 2 2008 Date Magisterial District Judge My commission expires first Monday of January, 2014 AOPC 315-07 DATE PRINTED: 3/13/08 10:20:00 AM SEAL UNIFUND CCR PARTNERS In the Court of Common Pleas of c/o Edwin A. Abrahamsen & Assoc. CUMBERLAND County, Pennsylvania 1729 Pittston Avenue Civil Division Scranton, PA 18505 Plaintiff NO: VS. JAMIE SHORT PRAECIPE FOR ENTRY OF JUDGMENT 603 MARKET ST NEW CUMBERLAND PA 17070 Defendant To the Prothonotary of CUMBERLAND County: 1) Enter Judgment on the attached Certified copy of Judgment from a District Justice. A) Date of instrument: 03/11/2008 B) Amount of Judgment: $2,674.16 C) Interest From: 03/11/2008 2) Enter the judgment in favor or the original holder, or (unless expressly forbidden in the instrument) in favor of the assignee or other transferee; 3) I hereby certify that the address of the plaintiff is: UNIFUND CCR PARTNERS c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 4) 1 hereby certify that the address of the defendant is: JAMIE SHORT 603 MARKET ST NEW CUMBERLAND PA 17070 Michael F. Ratchford, Esquire Edwin A. Abrahamsen & Associates, P.C. 1729 Pittston Ave, Scranton, PA 18505 570-558-5510 Ext. 101 Attorney ID 86285 UNIFUND CCR PARTNERS c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 Plaintiff : vs. JAMIE SHORT 603 MARKET ST NEW CUMBERLAND PA 17070 Defendant In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division NO: AFFIDAVIT UNDER SOLDIERS AND SAILORS RELIEF CIVIL RELIEF ACT OF 1940 AS AMENDED State of Pennsylvania County of CUMBERLAND SS: Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the above named defendant(s): JAMIE SHORT; is(are) not in the military service of the United States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended; That the defendant(s): JAMIE SHORT; is(are) older than eighteen years of age; That the employment status of the defendant(s): JAMIE SHORT; is(are) unknown. C? t 44- P, S)3 f? Sb C_- w j C_ C- _ -G d ? cao r? ,Ln m '"G UNIFUND CCR PARTNERS c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 vs. JAMIE SHORT 603 MARKET ST NEW CUMBERLAND PA 17070 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division Plaintiff NO: Defendant NOTICE OF FILING JUDGMENT Notice is herby given that a money judgment in the above-captioned matter has been entered -- _ against you in the amount of $ on &C ^0 /41. _4.0v. By: IL , If you have any questions regarding this notice, please contact the filing party: Edwin A. Abrahamsen & Associates 1729 Pittston Avenue Scranton, PA 18505 Telephone: (570)-558-5510 (Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS Plaintiff CIVIL DIVISION VS. JAMIE SHORT NO: 08-3445 Defendant PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S RESPONSES TO INTERROGATORIES IN AID OF EXECUTION Plaintiff, UNIFUND CCR PARTNERS, by and through its attorneys, Edwin A. Abrahamsen &Associates, P.C., files its Motion to Compel the Defendant's Responses to Interrogatories in Aid of Execution as follows: 1. Plaintiff, UNIFUND CCR PARTNERS,obtained a judgment against the Defendant in regard to an outstanding, past due and defaulted credit card account. 2. On June 13, 2008, Plaintiff served Defendant with Interrogatories in Aid of Execution on the subject judgment. (See, Interrogatories in Aid of Execution dated June 13, 2008, attached hereto and marked Exhibit "A ". ) 3. Defendant failed to respond to the Interrogatories in Aid of Execution within the time permitted by the Pennsylvania Rules of Civil Procedure. 4. On July 18, 2008, Plaintiff sent a letter to remind the Defendant of the past due responses and his duty to provide the same. (See, Correspondence to Defendant, attached hereto and marked Exhibit "B".) 5. Defendant still failed and refused to respond to the Interrogatories in Aid of Execution or respond to Plaintiffs counsel in any manner. 6. On August 08, 2008, Plaintiffs counsel notified Defendant that he intended to present to the court the within Motion to Compel Defendant's Response to Interrogatories in Aid of Execution if Defendant continued to fail to provide the responses. (See, Correspondence to Defendant, attached hereto and marked Exhibit "C'.) 7. Pursuant to the Pennsylvania Rules of Civil Procedure Defendant should have responded to the Interrogatories within 30 days. 8. More than 30 days have passed since Defendant was served with the Interrogatories in Aid of Execution. WHEREFORE, Plaintiff request this Honorable Court to grant the within Motion to Compel Defendant's Responses to Interrogatories in Aid of Execution and direct Defendant to provide full and complete response to the Interrogatories in Aid of Execution within 20 days upon penalty of sanctions, and that Plaintiff be awarded attorney's fees, costs and such other relief as the court deems just and appropriate. Respectfully submitted, Edwin A. Abr amsen & Associates, P.C. Michael F. tchfOrd, Esquire Heather oodruff, Esquire Attorne D. Nos: 862851207805 120 N h Keyser Ave Scranton, Pa 18504 Phone: 570-558-5510 Fax: 570-558-5511 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS CIVIL DIVISION Plaintiff VS. JAMIE SHORT Defendant NO: 08-3445 PLAINTIFF'S BRIEF IN SUPPORT OF ITS MOTION TO COMPEL DEFENDANT'S RESPONSES TO INTERROGATORIES IN AID OF EXECUTION Plaintiff, UNIFUND CCR PARTNERS, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., submits its Brief in Support of its Motion to Compel the Defendant's Responses to Interrogatories in Aid of Execution as follows: 1. STATEMENT OF FACTS Plaintiff, UNIFUND CCR PARTNERS, obtained a judgment against the Defendant in regard to an outstanding, past due and defaulted credit card account. On June 13, 2008, Plaintiff served Defendant with Interrogatories in Aid of Execution of the subject judgment. (See, Interrogatories in Aid of Execution, dated June 13, 2008, attached hereto and marked Exhibit "A.') Defendant failed to respond to the Interrogatories in Aid of Execution within the time permitted by the Pennsylvania Rules of Civil Procedure. On July 18, 2008, Plaintiff sent a letter to Defendant concerning the past due responses. (See, Correspondence attached hereto and marked Exhibit "B.') Plaintiff still failed and refused to respond to the Interrogatories in Aid of Execution or respond to Plaintiffs counsel in any manner. On August 08, 2008, Plaintiffs counsel notified Defendant that he intended to present to the court the within Motion to Compel Defendant's Response to Interrogatories in Aid of Execution if Defendant continued to fail to provide the responses.(See, Correspondence to Defendant, attached hereto and marked Exhibit "C.') Pursuant to the Pennsylvania Rules of Civil Procedure Defendant should have responded to the Interrogatories within 30 days. More than 30 days have passed since Defendant was served with the Interrogatories in Aid of Execution. II. QUESTION PRESENTED Whether Plaintiffs Motion to Compel Defendant's responses to discovery requests should be granted when the responses are more than 30 days past due. Suggested answers: Yes III. LEGAL ARGUMENT Pursuant to the Pennsylvania Rules of Civil Procedure Defendant should have responded to the Interrogatories in Aid of Execution within thirty (30) days after service thereof. More than thirty (30) days have passed since defendant was served with the Interrogatories in Aid of Execution, however, Defendant has not answered, objected or responded in any manner to the Interrogatories or to the notice sent by Plaintiffs counsel. IV. CONCLUSION Plaintiff requests this Honorable Court to grant the within Motion to Compel Defendant's Responses to Interrogatories in Aid of Execution and direct Defendant to provide full and complete response to the Interrogatories in Aid of Execution within twenty (20) days upon penalty of sanctions, and that Plaintiff be awarded attorney's fees, costs and such other relief as the court deems just and appropriate. Respectfully submitted, BY/,/f? Edwin A. sen & Associates, P.C. R Michael F. t hford, Esquire Attorney I. 86285 VERIFICATION I, Michael F. Ratchford, Esquire, attorney for Plaintiff, UNIFUND CCR PARTNERS am fully familiar with the facts set forth in the within Motion to Compel Defendent's Response to Interrogatories in Aid of Execution and am authorized to make this Verification on behalf of Plaintiff. I verify that the facts set forth in the within Motion are true and correct to the best of my knowledge, information and belief. I know that any false statements are punishable by law pursuant to 18 C.S.A. §4904. 1AA EDWIN A. ABRANAMSEN ANCNAEL F.IATCNFORD SCOrr 1 BEST' 'ALSO MEMBER OF NJ BAR JAMIE SHORT 603 MARKET ST NEW CUMBERLAND PA 17070 THE LAW OFFICE OF EDWIN A ABRAHAMSEN & ASSOCIATES, P.C. WWW.EAA-LAW.COM June 13, 2008 RE: Unifund CCR Partners/CITIBANK SOUTH DAKOTA NA vs. JAMIE SHORT File # U07-1163 Balance: 52,795.47 Dear Sir/Madam: Enclosed please find Interrogatories for Discovery of Assets in Aid of Execution, which have been propounded in accordance with the applicable Pennsylvania Rules of Civil Procedure. Full and complete instructions concerning your duty to Answer and the penalties for failure to Answer are contained in the Interrogatories. Please read the instructions carefully. You are to note your answers on the original and return it to this office after it is properly notarized. Please be aware that under the Rules of Court, we can and will, have our attorney's fees and expenses of all discovery Proceedings and Sanction Hearings charged against you as "additional costs" for which you will be responsible. In the alternative, you may make arrangements to pay the balance owed before the thirty (30) days to Answer the Interrogatories expire. Either the balance must be paid to us or the Interrogatories answered within thirty (30) days from the receipt of this letter. This is an attempt to collect a debt and any information obtained will be used for that purpose. This is a communication from a debt collector. Edwin A. Abrahamsen & Associates, P.C. Heather K. Chukinas, Esquire 1729 PITTSTON AVENUE SCRANTON, PA 18505 (P) 510.558.5510 (D 510.558.5511 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION Unifund CCR Partners, assignee of CITIBANK SOUTH DAKOTA NA Plaintiff -vs- JAMIE SHORT Defendant NO.08-3445 INTERROGATORIES FOR DISCOVERY OF ASSETS IN AID OF EXECUTION DIRECTED TO JUDGMENT DEBTOR Because you have failed to pay the full amount of the Judgment previously entered against you, the Judgment-Creditor, to who you are indebted, has a right to attempt to enforce that Judgment by a Judicial Sale (Sheriffs Sale) of your assets; and has a right to inquire concerning the existence and location of those assets. Therefore, pursuant to the applicable Rules of Court, you are required to make full and complete Answers to the questions set forth in the following pages. These Answers must be made in writing, under oath, within thirty (30) days after service upon you. You are warned that, should you fail to do so, the Court may make an Order imposing punishment for Contempt of Court. Please, if you do not understand your duty to answer these questions, you should consult a lawyer. If you do not have or know a lawyer, then you should find out where you can get legal help, such as your local County Bar Association or Lawyer Reference Service. PORTIONS OF THE APPLICABLE PENNSYLVANIA RULES OF CIVIL PROCEDURE CONCERNING DISCOVERY OF ASSETS IN AID OF EXECUTION " Rule 3117. Discovery in Aid of Execution. (a) Plaintiff, at any time after judgment, before or after the issuance of a writ of execution, may, for the purpose of discovery of assets of the defendant, take the testimony of any person, including a defendant or a gamishee, upon oral examination or written interrogatories as provided by the rules relating to Depositions and Discovery ...... (b) All reasonable expenses in connection with the discovery may be taxed against the defendant as costs if it is ascertained by the discovery proceedings that he has property liable to execution" (emphasis added) " Rule 4005. Written Interrogatories to a Party. (a) ......any party may serve upon any other party written interrogatories to by answered by the party served...... who shall furnish such information as is available......" " Rule 4006. Answers to Written Interrogatories by a Party. (a) (1) Answers to interrogatories shall be in writing and under oath. The answers shall be inserted in the spaces provided in the interrogatories. If there is insufficient space to answer an interrogatory, the remainder of the answer shall follow on a supplemental sheet. (b) (2) Each interrogatory shall be answered fully and completely unless objected to, in which event the reasons for the objection shall be stated in lieu of an answer.... The answering party shall file and serve a copy of the answers and objections, if any, within 30 days after the service of the interrogatories....... "Rule 4019. Sanctions. (a) (1) The court may, on motion, make an appropriate order if (i) a party fails to serve answers, sufficient answers, or objections to written interrogatories under Rule 4005.... (c) The Court, when acting under Subdivision (a) of this rule, may make...... (4) an order imposing punishment for contempt....." (emphasis added) INTERROGATORIES 1. Please state the following: (a) The full name, age and Social Security number of the person who is answering these Interrogatories. ANSWER: (b) Phone number, address and how long at this address. ANSWER: 2. REAL ESTATE: Do you have an ownership or interest in any real estate anywhere in the United States? If so, set forth a brief description thereof, included the structure and lot size and type of construction; the location, including the state, county and municipality; the volume and page number of the official record thereof; and state further whether you own is solely or together with any other person or persons and give their full names and addresses. ANSWER: (a) State the present Fair Market Value of the property, and what the Fair Market Valuation is based upon. ANSWER: (b) If any of the above properties are mortgaged, supply the names and addresses of lenders, the date and amount of the mortgage, where it is recorded, the monthly payments and the balance now due. ANSWER: 3. AGREEMENTS: State whether you have any agreements involving the purchase of any real estate anywhere in the United States. If so, state with whom this agreement is made, and state whether or not any persons are joined with you in the agreement. Supply full names and addresses of all parties concerned. If the said agreement is recorded, provide the state and county of recordation, volume and page numbers. ANSWER: 4. MORTGAGES: State whether you own any mortgages against any real estate owned by any other person in the United States. If so state whether or not you own this mortgage with any other person or persons and, if so, supply their full name and address. State further the names and addresses of all borrowers and the state and county where said mortgage is recorded together with the number of the volume and the page number. ANSWER: 5. DEBTS. NOTES AND JUDGMENTS: State the names and addresses of any and all persons whom you believe owe you money and set forth in detail the amount of money owed, the terms of payment and whether or not you have written evidence of this indebtedness, and if so, the location thereof. Also state if the matter is in litigation, and if so give full details. If you hold a Judgment or Judgments as security for any of these debts, state where and when the Judgment was recorded; and the County, number and term where the Judgment is recorded. If you hold this Judgment or Judgments jointly with any other person or persons, give their name and address. ANSWER: b. INSURANCE: State whether or not you are the owner of any life insurance contracts. If so state the serial or policy number or numbers of said contract, the face amount, the exact name and address of the insurance company, the named beneficiary or beneficiaries and their present address. State also the Present Cash Value of the policy. If you own this insurance jointly with any other person or persons, give their name and address. ANSWER: 7. GOVERNMENT, MUNICIPAL or CORPORATE BONDS: State whether or not you own individually or jointly any corporate or government bonds. If so, include the face amount, serial numbers and maturity date and state the present location thereof. If you own any of these Bonds jointly with any other person or persons, give their name and address. ANSWER: 8. STOCKS. SHARES or INTEREST: State whether or not you own any stocks, shares or interest in any corporation, or unincorporated association or partnership interest, limited or general and state the location thereof. Include the names and addresses of the organizations and the serial numbers of the shares or stocks. If you own any of the Stocks, Shares or Interest jointly with any other person or persons, give their name and address. ANSWER: 9. ACCOUNTS: State whether or not you maintain any checking or savings accounts. If so, state the name and location of the banks or savings and loan association or building and loan association or credit union and the branch or branches thereof, the identification numbers of those accounts, and the amount or amounts you have in each account. If you maintain any of these jointly with another person, give their name and address. ANSWER: 14. SAFETY DEPOSIT BOXES: State whether or not you maintain any safety deposit box or boxes. If so, include the name of the bank or banks, branch or branches, and 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 you maintain any of these jointly with another person, give their full name and address. ANSWER: 11. TRANSFERRED ASSETS AND GIFTS: If, since the date upon which the debt herein was first incurred to the Plaintiff herein, you have transferred any assets (real property, personal property, chose in action) to any person, and/or, if you have given any gift or any asset, including money, to any person; set forth, in detail, a description of the property, the type of transaction, and the name and address of the transferee or recipient. ANSWER: 12. INHERITANCES: State whether or not, to your knowledge, you are now or will be a beneficiary of or will inherit any money from any decedent in the United States, and state the place and date of death, the legal representative of the estate, and the location of the Court where the said estate is administered or to be administered. ANSWER: 13. ANNUITIES: State whether you are the beneficiary of any trust fund, and if so, state the names and addresses of the trustees and the amount of the payment and when the payment is received. ANSWER: 14. PERSONAL PROPERTY: State whether or not you own any personal property. Include a full description of all furnishings and any other items of personal property (including jewelry) with full description, value and present location. State also whether or not there are any encumbrances on that property and if so, the name and address of the encumbrance holder, the date of the encumbrances, the original amount of that encumbrance, the present balance of that encumbrance and the transaction which gave rise to the existence of the encumbrance. If you own a personal property jointly with any other person or persons, give their name and address. ANSWER: 15. MOTOR VEHICLES: State whether or not you own motor vehicles. Include a full description of such motor vehicles including color, model, title number, serial number and registration plate number. Also show the exact name or names in which the motor vehicles are registered, the present value of those motor vehicles and their present location and place of regular storage, garaging or parking. State also whether or not there are any encumbrances on those motor vehicles and if so, the name and address of the encumbrance holder, the date of the encumbrance, the original amount of that encumbrance, the present balance of the encumbrance and the transaction which gave rise to the existence of the encumbrance. ANSWER: 16. PENSION: State whether you are a participant in or the recipient of any pension or annuity fund, and if so, state specifically the source of payment, the person to whom such payments are made, the amount of the payments and date when those payments are received. ANSWER: 17. RENTAL INCOMES: State whether you are the recipient, directly or indirectly, of any income for the rental of any real or personal property; and if so, state specifically the source of payment, the person to whom such payments are made and the amount and date when those payments are received. ANSWER: 18. OTHER ASSETS: If you have any asset or assets which are not disclosed in the preceding Interrogatories, please set forth all detail concerning those assets. ANSWER: Edwin A. Abrahamsen & Associates, P.C. DATED: BY: Attorneys for Plaintiff (s) AFFIDAVIT COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA SS Before me, the undersigned authority personally appeared who, being duly sworn according to law, deposes and says that the foregoing Answers to Interrogatories For Discovery of Assets in Aid of Execution are true and correct to the best of the affiant's knowledge, information and belief. SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF ,20 NOTARY PUBLIC AFFIANTS SIGNATURE AFFIANTS ADDRESS TITLE OF OFFICIAL COWIN A. ABRANAMMEN MICNACL F. RATCHFORO HEATHER K. W000RUFF- •ALOO MEMBER OF FL OAR 911 THE LAW OFFICE OF EDWIN A. ABRAHAMISEN & ASSOCIATES, RC, WWW. EAA-LAW. COM JAMIE SHORT 603 MARKET ST NEW CUMBERLAND PA 17070 July 18, 2008 RE: Creditor: Unifund CCR Partners Original Creditor: CITIBANK SOUTH DAKOTA NA Original Account Number: 5424180329310590 Balance Due: 52,875.27 Our File #: U07-1163 Dear JAMIE SHORT: You recently received a series of Interrogatories in Aid of Execution from Edwin A. Abrahamsen & Associates, P.C. regarding a judgment that has been obtained against you by UNIFUND CCR PARTNERS . According to the Pennsylvania Rules of Civil Procedure, you had thirty days to provide this office with your reply to the interrogatories. To date, my office has not received a reply. Please provide an answer to these Interrogatories, or contact our office within the next 15 days, or appropriate steps may be taken with the court to compel you to answer them. This is an important matter that requires your attention. Very truly yours, ?-O.ww W00ar Heather K. Woodruff, Esq. Edwin A. Abrahamsen & Associates, P.C. This is a communication from a debt collector in an attempt to collect a debt. Any information obtained will be used for that purpose. 1 729 PITTSTON AVE. 0 SCRANTON, PA 1 8505 • (P) 570.558.55 10 • (F) 570.558.551 1 EDWIN A. ABRAHAMSEN MICHAEL F. RATCHFORD HEATHER K. WOODRUFF- •ALSO MEMBER OF FL BAR UIR THE LAW OFFICE OF EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C. WWW.EAA-LAW.COM August 8, 2008 JAMIE SHORT 420 N MARKET ST DUNCANNON PA 170201547 Re: UNIFUND CCR PARTNERS v. JAMIE SHORT CUMBERLAND County Civil Action No.: CV-0000086-08 Our File #: U07-1163 Dear JAMIE SHORT: As you know, on June 13, 2008, you were served with Interrogatories in Aid of Execution in regard to the above-noted matter, to which you have failed to respond. As a result, please be advised that if I do not receive your responses within ten (10) days of the date of this letter, I intend to file a Motion to Compel your Responses to Interrogatories in Aid of Execution in the CUMBERLAND Court of Common Pleas. If you wish to discuss this issue or a reasonable resolution of this matter, please contact me at 570-558-5510. Thank you. Edwin A. Abrahamsen Associates, P.C. Michael F. Ratchford, E This is a communication from a debt collector in an attempt ollect a debt. Any information obtained will be used for that purpose. 1 729 PITTSTON AVE. 0 SCRANTON, PA 1 85135 • (P) 570.558.551 0 0 (F) 570.558.551 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA UNIFUND CCR PARTNERS Plaintiff VS. , JAMIE SHORT , Defendant CIVIL DIVISION NO: 08-3445 CERTIFICATE OF SERVICE I, Michael F. Ratchford, Esquire, hereby certify that I caused a true and correct copy of the within Motion to Compel Defendant's Responses to Interrogatories in Aid of Execution, Brief in Support thereof, Notice of Presentation and Proposed Order via first class United States Mail, postage prepaid on the date set forth below upon the following: JAMIE SHORT 812 BELMONT ST Mechanicsburg PA 17055-4311 Date: r FILED-nF-rr,E OF THE PROTHONOTARY 2009 OCT -2 PH 12: 48 CUB'}i. -. a tY pt I_dl?s ?f/1 UNIFUND CCR PARTNERS, Plaintiff V. JAMIE SHORT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-3445 CIVIL TERM ORDER OF COURT AND NOW, this 8 h day of October, 2009, upon consideration of Plaintiff's Motion To Compel Defendant's Responses to Interrogatories in Aid of Execution, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 21 days of the date of this order. BY THE COURT, J ? Michael F. Ratchford Esq. Heather K. Woodruff, Esq. Edwin A. Abrahamsen & Associates, P.C. 120 North Keyser Avenue Scranton, PA 18504 Attorneys for Plaintiff ? Jamie Short 812 Belmont Street Mechanicsburg, PA 17055-4311 Defendant, pro Se :rc (20P(Es ,JCL l??alo? i I ? esley Oli Jr., THE P""! 7ARY 2099 OCT --8 Ph 3: ` t C L? ?_^ 1 fYl \.