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
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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
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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
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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
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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
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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:
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Attorney File#: 2062645
318q (b - ch?[??-o her N. Lar
(?o n her LarlS
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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
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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 )
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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
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