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HomeMy WebLinkAbout08-5113Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff No.j? s 3 C 7 J 'r uM VS. ROBYN HICKEY Defendant CIVIL ACTION PRAECIPE FOR TRANSFER OF JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: Kindly enter judgment in favor of Plaintiff and against the above-named defendant(s), pursuant to Pa.R.C.P.D.J. No.402(D), for failure of defendant(s) to appeal, within 30 days, a judgement entered November 16, 2007 against the above-named defendant(s) before District Justice Charles A. Clement, Jr., as set forth in the transcript of judgment, which is attached hereto. Assess damages as follows: Judgment Amount 6,102.78 Post Judgment Interest (from November 16, 2007 to August 19, 2008 at 6% per annum) 283.67 Payments 75.00 Total $6,311.45 Dated: August 19, 2008 AMATO AND ASSOCIATES, P.C. BY: R na Amato, Esq., Atty ID #32323 ael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM 2062645 • COMMONWEALTH OF PENNSYLVANIA C01INTY nF• CUMBERLAND Mag. Dist. No.: 09-1-01 MDJ Name: Hon. CNARLES A. CLEMENT, JR Address: 400 BRIDGE ST OLDS TONNE COMONS -SUITE 3 NEW CUMBZU AND, PA Telephone: (717 ) 774-5989 17070 MMSON & i[EYSE LLC 107 N COMKZRCE NAY C/O AMATO A ASSOC PC BETBLEHEI[, PA 18017 THIS IS TO NOTIFY YOU THAT: Judgment: FOR PLAINTIFF 71 Judgment was entered for: (Name) NOTICE OF JUDGMENTAANS RIP T CIVIL CASE PLAINTIFF: NAME and ADDRESS ri=SON & =EYSE LLC 107 N C011111KZRCE NAY C/O AKATO i ASSOC PC LBETBLENEII[, PA 18017 J VS. DEFENDANT: NAME and ADDRESS rSICSEY, ROBYN 4600 OLD GETTYSBDRG RD L1[ECSANICSBURG, PA 17055 J Docket No.: CV-0000490-07 Date Filed: 10/16/07 _ (Date of Judgment) 11/16/07 NODSON A EEYSE LLC ® Judgment was entered against: (Name) HICZZY, ROBYN in the amount of $ 6,102.7 ? Defendants are jointly and severally liable. Damages will be assessed on Date & Time This case dismissed without prejudice. Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 F] Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 5,975.78 Judgment Costs $ 127.00 Interest on Judgment $ .0 a Attorney Fees $ .00 Total $ 6,102.78 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 JUDGMENT/TRANSCRIPT 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. 11/16/07 Date I certify that this is a true 8/13/08 Date My commission expires first Monday of January, 2014 Magisterial District Judge containing the judgment. , Magisterial District Judge SEAL AOPC 315-07 DATE PRINTED: 8/13/08 2:15:00 PM ?T vvv___ ..C ro? G ? c q n { Q C-S r- n 4 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff No. 0 7J VS. ROBYN HICKEY CIVIL ACTION Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHAMPTON The undersigned, being duly sworn, according to law, deposes and says that he is unable to determine whether or not the above Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of The Servicemembers Civil Relief Act; That Robyn Hickey is over 18 years of age, resides at 4600 Old Gettysburg Rd, D, Mechanicsburg PA 17055 and is employed; Sworn to and subscribed before me this?(. day of A-/ Z20 08 A. NOTAR UBLIC NOTARIAL SEAL GWFFREY G SCHOEK=X Nalwy NM0M ,N?ORTbHAYPwm c Nry OF off" I ;-? 11 rote 29,2M2 Q • ' ? ' F f1F i. G7 t ? , £,X C11 - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff No. - ,- H 3 VS. ROBYN HICKEY CIVIL ACTION Defendant CERTIFICATION OF ADDRESSES I do certify that the precise last known address of the within named plaintiff is: 382 Blackbrook Road PAINESVILLE OH 44077 do certify that the precise last known address of the within named defendant is: 4600 Old Gettysburg Rd, D Mechanicsburg PA 17055 AMATO AND ASSOCIATES, P.C. By: ald Amato, Esq., Atty ID #32323 Z?rMichael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM n Q Cm C= ..-l to -t7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff No. VS. ROBYN HICKEY CIVIL ACTION Defendant NOTICE OF JUDGMENT (XX) NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST THE ABOVE-NAMED DEFENDANT(s) IN THE AMOUNT OF $ ?j 101,7PON P'Ia-s` , 2008. ( ? A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN JUDGMENT IS/ARE ENCLOSED. PROTHONOTARY - CUMBERLAND COUNTY Per: I Sl C??v k c If you have any questions concerning the above, please contact the undersigned. AMATO AND ASSOCIATES, P.C. By: ald Amato, Esq., Atty ID #32323 ichael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM ;..:? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff vs. '4WO oid 4e*fs6w3 EA, D ROBYN HICKEY Mech, pa r7055 Defendant(s) MEMBERS 1ST FEDERAL CREDIT UNION .Garnishee c$ louse Dr Meth, PA 17055 CIVIL ACTION NO. 08-51 13 Civil Amount Due $ 6,102.78 Interest $2.13 Payments $ 0.00 Costs $ Poundage $ : Total $ 6,104.92 To the Prothonotary - Cumberland County: ISSUE A WRIT OF EXECUTION AND ATTACHMENT IN THE ABOVE MATTER. PRAECIPE WRIT OF EXECUTION Issue a writ of execution in the above matter to the Sheriff of CUMBERLAND County, for debt, interest and costs upon the following described property of the defendant(s) All cash on PRAECIPE FOR WRIT OF ATTACHMENT EXECUTION AMATO AND SOCI S, P.C. By: Rona d Amato, -tty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Attorney File#: 2062645 Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above named garnishee(s) for the following P?a C C= ?? ~?, ? rTi 0 -o Fn ?-1 Cb' Ap- -1) , '+} `?' ? $ (Jt 0 tJt Ct' rte-- c_ ? - SLR 9a o t t"" r-n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff No. 08-51 13 Civil VS. ROBYN HICKEY CIVIL ACTION Defendant(s) CERTIFICATION OF DEFENDANT'S ADDRESS FOR SERVICE do certify that the precise last known address of the within named defendant(s) is the address provided below, and request that the Sheriff serve the above named defendant(s) at: Dated: August 27, 2008 4600 Old Gettysburg Rd, D Mechanicsburg PA 17055 AMATO AND ASSOCIATES, P.C. By: Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Attorney File #: 2062645 cn 1 ^ t ;, C'n WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HUDSON & KEYSE, LLC, Plaintiff (s) From ROBYN HICKEY, 4600 Old Gettysburg Road D, Mechanicsburg, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell all cash on hand or in the NO 08-5113 Civil CIVIL ACTION - LAW possession of the defendant, accounts receivables, furniture, furnishings, equpment, inventory, tools, electronic equipment, vehicles, any and all other personal property belonging to the above-named defendant. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS 1sT FEDERAL CREDIT UNION, 5000 Louise Drive, Mechanicsburg, PA 17055 All property of the above-named defendant, including, without limitation, all savings and checking accounts, certificates of deposit, money market accounts, deposits and all debts and other property and/or obligations owing from the above-named garnishee to the above named defendant, including but not limited to account #3183090527, and any account owned solely or in part by the above-named defendant, which are in the possession, custody and/or control of said garnishee 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 $6,102.78 Interest - $2.13 Atty's Comm % Atty Paid $54.25 Plaintiff' Paid Date: 9/23/08 L.L. $.50 Due Prothy $2.00 Other Costs (Seal) REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: AMATO AND ASSOCIATES, PC _,, 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone: 610-866-0400 Supreme Court ID No. 32323 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC R?- LEI V t L Plaintiff No. 08-51 13 Civil SEP 2 9 1008 VS. ROBYN HICKEY , CIVIL ACTION Defendant(s) MEMBERS 1ST FEDERAL CREDIT UNION Garnishee INTERROGATORIES TO GARNISHEE To: MEMBERS 1 ST FEDERAL CREDIT UNION, Garnishee 5000 LOUISE DRIVE, MECHANICSBURG PA 17055 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: 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? D 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? no 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? n(D 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? no 5. At any time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? Y-)o 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? fA 0 7. 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 reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. Y-) 0 8. 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.A. § 8123? If so, identify each account. V 9. At any time before or after you were served, did the defendant, either solely or in part, have any account (savings, checking, certificate of deposit, money market, deposits or any other debt and/or property) [including but not limited to 31830905271 with your office? UXA 51atu tb r e f fim 10. If your answer to interrogatory #9 is in the affirmative, state: T A) the account number of each account; B) the amount of money in each account. (dab In WC-11N AMATO AND ASSOCIATES, P.C. 30°, 65a By: jq ____ ? , ?, Q row Attorney File#: 2062645 318q (b - ch?[??-o her N. Lar (?o n her LarlS ? Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Jd; nt 2AV I1)9 - 3, 5-7 0, 0 0 C,4 P racesst ?? ?e? 3, S4?(o (O C1in? 54.0 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities that he/she is ao k rl- S ' ?W rY) (Name) of #1t bersistFedwal Credit UMM Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. Loo (SIGNATU ) r- I t : CM) -n 7.1 S. - ... ?,.,y ......t `QT`S a 3? ?_ „ ?r r F I ?S --3 Y „r COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff No. 08-5113 Civil vs. ROBYN HICKEY CIVIL ACTION Defendant(s) MEMBERS 1ST FEDERAL CREDIT UNION Garnishee PRAECIPE TO DISCONTINUEAGAINST GARNISHEE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please discontinue the above-captioned matter against MEMBERS 1 ST FEDERAL CREDIT UNION, Garnishee, ONLY, without prejudice. AMATO AND ASSO S, P.C. By: Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM 4o- n_ t ?m 3 '' 00 attl R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Advance Costs: 150.00 Sheriffs Costs: 150.00 Docketing 18.00 000.00 Poundage 50.00 Advertising Law Library .50 Prothonotary . 2.00 Refunded to Atty on 10/06/08 Mileage 10.00 Surcharge 40.00 Levy 20.00 Certified Mail Post Pone Sale Garnishee 9.00 Postage ? {.. TOTAL $ 150.00 ? 1 ?/? So Answers; o R. Thomas Kline, Sheriff By laudia A. Brewbaker pUS" C'L ? G /P) U&' .7i5 Pio WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-5113 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HUDSON & KEYSE, LLC, Plaintiff (s) From ROBYN HICKEY, 4600 Old Gettysburg Road D, Mechanicsburg, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell all cash on hand or in the possession of the defendant, accounts receivables, furniture, furnishings, equpment, inventory, tools, electronic equipment, vehicles, any and all other personal property belonging to the above-named defendant. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS 1sT FEDERAL CREDIT UNION, 5000 Louise Drive, Mechanicsburg, PA 17055 All property of the above-named defendant, including, without limitation, all savings and checking accounts, certificates of deposit, money market accounts, deposits and all debts and other property and/or obligations owing from the above-named garnishee to the above named defendant, including but not limited to account #3183090527, and any account owned solely or in part by the above-named defendant, which are in the possession, custody and/or control of said garnishee 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 $6,102.78 L.L. $.50 Interest -- $2.13 Atty's Comm % Atty Paid $54.25 Plaintiff Paid Due Prothy $2.00 Other Costs Date: 9/23/08 (Seal) Deputy REQUESTING PARTY: Name RONALD AMATO, ESQUIRE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff No. 08-5113 Civil VS. ROBYN HICKEY CIVIL ACTION Defendant(s) PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please satisfy the judgment entered in the above-captioned case. AMATO AND ASSOC ES, P.C. By: Rd(ald Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM OT/Ty OF TH 2009 JUN 30 A? 1 5; 0 6 'T 1