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HomeMy WebLinkAbout08-5997COMMONWEALTH OF PENNSYLVANIA ' rnl INTv nF• CMME8L11ND Mag. Dist. No.: 09-3-01 MDJ Name: Hon. BABOLD E. BENDER Address: 35 N 0871160E ST SBIPPEIxSBVRQ' PA Telephone: (717 ) 532-7676 17257-0361 ATTORNEY FOR PLAINTIFF : SCOTT J. BEST 1729 PITTSTON AVE SCRANTON, PA 18504 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JUDGMENT PLTF © Judgment was entered for: (Name) NOTICE - sQQ ??? CE OF JUDGMENT/TRANSCRI T CIVIL CASE PLAINTIFF: NAME and ADDRESS rCITIFINMCIAL INC 1729 PITTSTON AVE C/O AB8ARANSE6I & ASSOCS LSCBANTON, PA 18504 J VS. DEFENDANT: NAME and ADDRESS rCLEAB Y -1 . , WILLIAM[ F 45 FOX HILL 8D SEIPPENSBURG, PA 17257 L J Docket No.: CV-0000117-08 Date Filed: 5106108 _ (Date of Judgment) 5/28/08 CITIFINMMIAL INC © Judgment was entered against: (Name) CLZARY, WILLIAM F in the amount of it 2, 669.6 Defendants are jointly and severally liable. Damages will be assessed on Date & Time This case dismissed without prejudice. F] 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 $ 2,576.12 Judgment Costs $ 93. Interest on Judgment $ - 00 Attomey Fees $ Total $ 2,669.62 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. Date , Magisterial District Judge I Ify that this is?a true and correct copy of the recd f the proceedings containing the judgment. ' U ° Date Magisterial District Judge My commission expires first Monday of January, 2012 SEAL AOPC 315-07 DATE PRINTED: 5/28/08 9:57:00 AN 10411 6?7 6-5 ^ / Cr, i CITIFINANCIAL INC. c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division Plaintiff . VS. WILLIAM F CLEARY 49 FOX HILL RD SHIPPENSBURG PA 17257 NO: PRAECIPE FOR ENTRY OF JUDGMENT 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: 052808 B) Amount of Judgment: $2,669.62 C) Interest From: 052808 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: CITIFINANCIAL INC. c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 4) I hereby certify that the address of the defendant is: WILLIAM F CLEARY 49 FOX HILL RD SHIPPENSBURG PA 17257 Michael F. Ratchford, Esquire Edwin A. Abrahamsen & Associates, P.C. 1729 Pittston Ave, Scranton, PA 18505 570-558-5510 Ext. 101 Attorney ID 86285 CITIFINANCIAL INC. c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division Plaintiff NO: vs. WILLIAM F CLEARY 49 FOX HILL RD SHIPPENSBURG PA 17257 AFFIDAVIT UNDER SOLDIERS AND SAILORS RELIEF CIVIL RELIEF ACT OF 1940 AS AMENDED Defendant 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): WILLIAM F CLEARY 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): WILLIAM F CLEARY is(are) older than eighteen years of age; That the employment status of the defendant(s): WILLIAM F CLEARY is(are) unknown. ichael F of W- 20 Esquire CITIFINANCIAL INC. c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 VS. WILLIAM F CLEARY 49 FOX HILL RD SHIPPENSBURG PA 17257 Plaintiff : NO: ne s99,7 Ou ,, L In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division NOTICE OF FILING JUDGMENT Defendant Notice is herby given that a money judgment in the above-captioned matter has been entered against you in the amount of $ J. 1.!?. 1. 2on ! O?? ?a By: 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 CITIFINANCIAL INC. CIVIL DIVISION Plaintiff VS. WILLIAM F CLEARY Defendant NO: 08-5997 PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S RESPONSES TO INTERROGATORIES IN AID OF EXECUTION Plaintiff, CITIFINANCIAL INC., 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, CITIFINANCIAL INC.,obtained a judgment against the Defendant in regard to an outstanding, past due and defaulted credit card account. 2. On October 20, 2008, Plaintiff served Defendant with Interrogatories in Aid of Execution on the subject judgment. (See, Interrogatories in Aid of Execution dated October 20, 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 November 26, 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 December 17, 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, ahamsen & Associates, P.C. Micatchford, Esquire Heaoodruff, Esquire Ed/n AttNos: 86285/207805 120 yser Ave Scr 18504 Phone: 570-558-5510 Fax: 570-558-5511 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIFINANCIAL INC. VS. WILLIAM F CLEARY Plaintiff Defendant CIVIL DIVISION NO: 08-5997 PLAINTIFF'S BRIEF IN SUPPORT OF ITS MOTION TO COMPEL DEFENDANT'S RESPONSES TO INTERROGATORIES IN AID OF EXECUTION Plaintiff, CITIFINANCIAL INC., 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, CITIFINANCIAL INC., obtained a judgment against the Defendant in regard to an outstanding, past due and defaulted credit card account. On October 20, 2008, Plaintiff served Defendant with Interrogatories in Aid of Execution of the subject judgment. (See Interrogatories in Aid of Execution, dated October 20, 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 November 26, 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 December 17, 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 ,' V - Edwin A. Abrah sen & Associates, P.C. Michael F. Rat ord, Esquire Attorney I.D , o.: 86285 VERIFICATION I, Michael F. Ratchford, Esquire, attorney for Plaintiff, CITIFINANCIAL INC. 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. E[?.1]t1 A. ABR.AHAWIE1I 101CHAE1 F. RAT_HP. RC, HEATHER K. `; :' _ir iG'R! iFF 14US0 A MEF.4BER OF F1 BAR iftt THE LAW OFFICE OF EDMN A.AEF k1L- W:EN .1; A'-`,*C ,UTE?. PC: October 20, 2008 WILLIAM F CLEARY 49 FOX HILL. RD SIAIPPENSBURG PA 17257 RE: NCO FINANCIAL SYSTEMS, INC/CITIFINANCIAL vs. WILLIAM F CLEARY File # N07-6726 Balance: $2,637.53 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 arc 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 fi-orn a debt collector. Edwin A. Abrahamsen & Associates, P.C. -/V,/ , ,( !///," //, ?fusre (-leather K. Woodruff Esquire 1729 PITTSTON AVENUE SCRANTON, PA 18505 (P) 570.558.5510 (F) 510.558.5511 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION NCO FINANCIAL SYSTEMS, INC, assignee of CITIFINANCIAL Plaintiff, -vs- NO.08-5997 WILLIAM F CLEARY Defendant INTERROGATORIES FOR DISCOVERY OF ASSE'T'S IN AID OF EXECUTION DIRECTED TO JUDGMENT DEBTOR Because you have failed to pay the full amount ofthc Judgment previously entered against you, the Judgment-Creditor, to who you are indebted, has a right to attempt to enforce that Judgment by a .ludicial Sale (Sheriffs Salc) 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 firth in the following pages. These Answers must be made in writing, under oath, within thirty (30) clays after set vice upon you. You are warned that, should you fail to do so, the Court may make an Order imposing punishinent 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 TILE APPLICABLE PENNSYLVANIA RULES OF CIVIL PROCEDURE CONCERNING DISCOVERY OF ASSETS IN AID OF EXECUTION " Rule 3117. Discovery in Aid 01' Execution. (a) Plaintiff, at any time after judgmctit, 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 garnishee, 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 adde(l) " 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 it Party. (a) (1) Answer to interrogatories shall he 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 complcteiy 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 (lays after the service of the imen,ogatories....." "Rule 4019. Sanctions. (a) (1) The court may, oil motion, make an appropriate order if' (1) 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 construclion; 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: (b) If any ofthe 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. GOVERNMENT MUNICIPAL or CORPORATE BONUS: State whether or not you own individually or jointly any corporate or government bonds. lfso, 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: 4. STOCKS SHARES or INTEREST: State whether or not VOL) own any stocks, shares or interest in any corporation, or unincorporated association or partnership interest, limited or general and state the location thereof. Include Ilic names and addresses ofthe 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: 5. 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. State whether satiety deposit. ANSWER: 6. 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 ifso, the name and address of-'the encumbrance holder, the date ofthe 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: 7. 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 ot'thosc 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: S. 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: Edwin A. Abrahamsen & Associates, P.C. DATED: BY: L-I 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 hest of the aftiant's knowledge, information and belief: SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF AFFIANTS SIGNATURE ,20 AFFIANTS ADDRESS NOTARY PUBLIC TITLE OF OFFICIAL EDWIN A. ABRAHAMSEN MICHAEL F. RATCHFORD HEATHER K. WOODRUFF' 'ALSO MEMBER OF FL BAR WILLIAM F CLEARY 49 FOX HILL RD SHIPPENSBURG PA 17257 RE: Creditor: NCO FINANCIAL SYSTEMS, INC Original Creditor: CITIFINANCIAL Original ACCOLInt Number: 330658031.7534 Balance Due: $2,653.20 Our File #: N07-6726 Dear WILLIAM F CLEARY: November 26, 2008 You recently received a series ol'Interrogatories in Aid of Execution [1-0111 Edwin A. Abrahamsen & Associates, P.C. regarding a judgment that has been obtained against you by C1T11-"1,1 ANCIAL INC. . According to the Pennsylvania Rules ol'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, d Heather K. Woodruff. Edwin A. Abrahamsen THE LAW OFFICE OF EDWIN A. ABRAHAMSEN & AssoCIATES, P.C. WWW.EAA-LAW.GOM ociates. P.C. This is a communication Irom 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 0 (P) 570.556.551 0 0 (F) 5'70.558,551 1 EDWIN A. ABRAHAMSEN MICHAEL I. RATCHIORD HEATHER K. WOODRUFF- •ALMO MEMWER OF FL MAR THE LAW OFFICE OF EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C. WWW. EAA-LAW. COM December 17, 2008 WILLIAM F CLEARY 49 FOX HILL RD SHIPPENSBURG PA 17257 Re: CITIFINANCIAL INC. v. WILLIAM F CLEARY CUMBERLAND Countv Civil Action No..-CV-1 17-08 Our File #: N07-6726 Dear WILLIAM F CLEARY: As you know, on October 20, 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. /4miel Ratchford, Es This is a communication from a debt collector in an attempt to cgl1?t a debt. Any information obtained will be used for that purpose. G? 1729 PmrNTON AVE. -SCRANTON, PA 18505 - (P) 570.559.5510 - (F) 570.558.551 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIFINANCIAL INC. Plaintiff VS. WILLIAM F CLEARY Defendant CIVIL DIVISION NO: 08-5997 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: WILLIAM F CLEARY 49 FOX HILL RD SHIPPENSBURG PA 17257 Date: BY/v 1 Michael F. Attorney I. Ford, Esquire : 86285 nLED--o OF THE PPOT?MTARY 2009 OCT -2 PM 12: 48 CUPS j? S.' °?' 'My 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CITIFINANCIAL INC. CIVIL DIVISION Plaintiff vs. NO: 08-5997 WILLIAM F CLEARY Defendant ORDER AND NOW, this day of OeA-, 2009, Plaintiff CITIFINANCIAL INC. 's Motion to Compel Defendant's Responses to Interrogatories in Aid of Execution is hereby GRANTED. Defendant shall serve full and complete Answers, without objection, to Plaintiffs Interrogatories in Aid of Execution within twenty (20) days of the date of this Order upon penalty of sanctions. B HE COUR J. FILEU-0t- ICE OF THEI?CTHONOTARY 2009 OCT -6 PM 4: 18 PENNSYLVANA /p/?JOt - l.o?tES m???Ec?.. ?n1 w . el.? C> t-- G? C= CJ cv IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW ATTORNEY CERTIFICATION OF GOOD FAITH Pursuant to CUMBERLAND County Local R.C.P.208.2(e) The undersigned counsel for movant hereby certifies and attests that: A. He or she has had the contacts described below with opposing counsel or unrepresented party regarding discover matter contained in the foregoing discover motion in an effort to resolve the specific discover dispute(s) at issue, and further, that despite counsel's good faith attempts to resolve the dispute(s), counsel have been unable to do so without Court intervention. Description of effort to resolve discover motion: B. He or she was unsuccessful in actually contacting opposing counsel or unrepresented part in an attempt to resolve the discovery dispute(s) despite his or her good faith efforts to do so. Description of effort to reslove discovery motion: CERTIF TO T At 4 ey for the Movant( n of party) Date