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HomeMy WebLinkAbout08-5885 , COMMONWEALTH OF PENNSYLVANIA COUNTY OR CUllMZRLAND Mag. Dist. No.: 09-3-03 -yLo- : ") k- f5' i P -< 7Z- NOTICE OF JUDGMENT BAN SCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rC01IMONKRALTH FINANCIAL SYSTEMS ? 120 NORTH KEYSER AVENUE SCRANTON, PA 18504 L J VS. DEFENDANT: NAME and ADDRESS rNEOYER,, LINDA D 104 F tL STREET BOILING SPRINGS, PA 17007 L J Docket No.: CV-0000151-08 Date Filed: 5/07/08 MDJ Name: Hon. SUSAN S. DAY Add,ess: 229 KILL ST, BOX 167 MT. HOLLY SPRINGS, PA Telephone: (717 ) 486-7672 17065 C010L NwzALTH FINANCIAL SYSTE@S 120 MOATS SEYSER AVENUE SCRANTON, PA 18504 THIS IS TO NOTIFY YOU THAT: Judgment: ' DEFAULT JUDQXZNT PLTF (Date of Judgment) 7/17/08 © Judgment was entered for: (Name) CO3=NWZALTH FINANCI, AL SYSTE ® Judgment was entered against: (Name) MOYER, LINDA D in the amount of $ 6,101.0 F1 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 Portion of Judgment for physical damages arising out of residential lease S Amount of Judgment Judgment Costs interest on Judgment Attorney Fees Total $ 5,971.00 $ 130.00 $ .00 $ U0 $ 6,101.001 Certified Judgment Total $ 6,101.00 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. Date Magisterial District Judge I certify that this is a true d corr c copy of the r f th pr ce dings containing the judgment. Date d .(J , Magisterial District Judge My commission expires first Monday of January, 20 0 SEAL AOPC 315-07 DATE PRINTED: 9/16/08 1:01:00 PS C Q W 1 C C "0a) p C- 1 Fn ?`_ N 57 J , N m 9 Commonwealth Financial Systems, Inc. 120 North Keyser Avenue Scranton, PA 18504 vs. LINDA D MOYER 104 EARL ST BOILING SPRINGS, PA 17007 Plaintiff Defendant(s) To the Prothonotary of CUMBERLAND County: In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division No Utw-4 PRAECIPE FOR ENTRY OF JUDGMENT 1) Enter Judgment on the attached Certified copy of Judgment from a District Justice. A) Date of Instrument: 07/17/2008 B) Amount of Judgment: 6,101.00 C) Interest From: 07/17/2008 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: Commonwealth Financial Systems, Incorporated 120 North Keyser Avenue Scranton, PA 18504 4) I hereby certify that the address of the defendant is: LINDA D MOYER 104 EARL ST BOILING SPRINGS, PA 17007 Patricia A Cobb, Esquire 120 North Keyser Avenue Scranton, PA 18504 570-342-1600 Ext. 202 Attorney ID 39688 V icia A. Cobb, Esquire, Attorney for Plaintiff 120 North Keyser Avenue CUMBERLAND County, Pennsylvania Scranton, PA 18504 Civil Division Plaintiff vs. No. 0 7- 5 F FS cl;.-L, ?? LINDA D MOYER 104 EARL ST Affidavit under Soldiers and Sailors Relief BOILING SPRINGS, PA 17007 Civil Relief Act of 1940 as amended. Defendant(s) State of Pennsylvania County of CUMBERLAND ) SS: Patricia A. Cobb, Esquire being duly sworn according to law deposes and says that the above named defendant(s): LINDA D MOYER; 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): LINDA D MOYER; is(are) older than eighteen years of age; That the employment status of the defendant(s): LIND OVER; is(are) unknown. Patricia A. Cobb, Esquire Subscribed before me this day o 20 Kelly L Lance- Notary Publi NOTARIAL SEAL KELLY L LANCE Notary PubIIC SCRANTON CITY, LACKAWANNA C]2011 My Commission Expires Fetb 21, c? D c- fT. -r_ o. Commonwealth Financial Systems, Inc 120 North Keyser Avenue Scranton, PA 18504 Plaintiff(s) vs. LINDA D MOYER 104 EARL ST BOILING SPRINGS, PA 17007 In the Court of Common Pleas of CUMBERLAND, Pennsylvania Civil Division File / Index No. 8' S Q SAS__T^ : NOTICE OF FILING JUDGMENT Defendant(s) Notice is herby given that a money judgment in the above-captioned matter has been entered against you in the Amount of $ 6. / 64 dV on Sri.-P?- a ",r By: 4! $ If you have any questions regarding this notice, please contact the filing party: Commonwealth Financial Systems, Inc. 120 North Keyser Avenue Scranton, PA 18504 Telephone: 570-347-1115 (Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236) COURT OF COMMON PLEAS OF CUMMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff No. 08-5886 Civil VS. SVETLANA PATLATYUK CIVIL ACTION Defendant(s) PLAINTIFF'S ANSWER TO DEFENDANT'S PRELIMINARY OBJECTIONS TO PLAINTIFF'S AMENDED COMPLAINT The above Plaintiff files the within Answer to Defendant's Preliminary Objections to Plaintiff's Amended Complaint and states the following: 1. DEMURRER PURSUANT TO PA.R.C.P. 1028(a)(4) 1. It is admitted that Plaintiff filed the Amended Complaint at issue. The Amended Complaint is a written document which speaks for itself. Plaintiff has filed an Amended Complaint which meets the requirements of the Pennsylvania Rules of Civil Procedure. Defendant has been provided sufficient information such that she can plead to Plaintiff's Amended Complaint. 2. Denied. Plaintiff has attached to the Amended Complaint monthly statements sent to the Defendant by the original credit grantor and the Bills of Sale assigning the account to the Plaintiff. Wherefore, Plaintiff respectfully requests that Defendant's Preliminary Objections be overruled. II. DEMURRER PURSUANT TO PA.R.C.P. 1028(a)(4) 3. Denied. The benefit is the extension of credit so that Defendant could purchase certain goods and merchandise. Plaintiff has sufficiently stated a cause of action. The items for which the Defendant has objected are subject to discovery. Wherefore, Plaintiff respectfully requests that Defendant's Preliminary Objections be overruled. III. MOTION FOR A MORE SPECIFIC PLEADING PURSUANT TO PA.R.C.P.1028(a)(3) 4. Admitted that Defendant has plead in the alternative. Denied that Defendant is entitled to the relief requested. 5. Denied. Plaintiff has attached the invoices which specify the balance, provide Defendant with the date of said invoices, provide the original creditor name, address, interest charges and other information. Certainly, Defendant can admit of deny whether she had the charge card in question and state whether the charges therein are accurate or not. Secondly, the items Defendant is requesting are all items that she has or had in her possession. There is no need for Plaintiff to attach documents to a pleading when the Defendant has those documents. Wherefore, Plaintiff respectfully requests that Defendant's Preliminary Objections be overruled. AMATO AN A SOCI ES, P.C. By: Ron hld Am to, 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 (D - _ ca -q'E cp C") m Fi7 OD G,J -"C