HomeMy WebLinkAbout08-7308ASSET ACCEPTANCE LLC 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: 08- 7308 CiVil ferVV4
VS.
CHRIS J WORTHINGTON PRAECIPE FOR ENTRY OF JUDGMENT
500 E MARBLE ST
MECHANICSBURG PA 17055
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:
B) Amount of Judgment: $1,152-09
C) Interest From:
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
ASSET ACCEPTANCE LLC
c/o Edwin A. Abrahamsen & Assoc.
1729 Pittston Avenue
Scranton, PA 18505
4) I hereby certify that the address of the defendant is:
CHRIS J WORTHINGTON
500 E MARBLE ST
MECHANICSBURG PA 17055
Michael F. Ratchford, Esquire
Edwin A. Abrahamsen & Associates, P.C.
1729 Pittston Ave,
Scranton, PA 18505
570-558-5510 Ext. 101
Attorney ID 86285
ASSET ACCEPTANCE LLC
c/o Edwin A. Abrahamsen & Assoc.
1729 Pittston Avenue
Scranton, PA 18505
Plaintiff :
VS.
CHRIS J WORTHINGTON
500 E MARBLE ST
MECHANICSBURG PA 17055
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): CHRIS J WORTHINGTON 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): CHRIS J WORTHINGTON is(are) older than eighteen years of age;
That the employment status of the defendant(s): CHRIS J WORTHINGTON is(are) unknown.
COMMONWEALTH OF PENNSYLVANIA
r.nl INTY OF: CU MZRLAND
Mag. Dist. No.:
09-3-05
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
(ASSET ACCEPTANCE LLC
1729 PITTSTON AVE
C/O EDWIN A ABRAEA1IIIZlIN
LSCRANTON, PA 18505 J
VS.
DEFENDANT: NAME and ADDRESS
51ORTHINGTON, CHRIS J
500 8 NARZLE ST
NZC8ANICSBURG, PA 17055
L J
Docket No.: CV-0000287-08
Date Filed: 8/26/08
MDJ Name: Hon.
311 ARE XARTIN
Address: 507 N YORK ST
MCNANICSBURG, PA
Telephone: (717 ) 766-4575 17055
ATTORNEY FOR PLAINTIFF :
1NICHAEL F. R&TCEFOBD
1729 PITTSTON AVE
SCRANTON, PA 18505
THIS IS TO NOTIFY YOU THAT:
Judgment: DEFAULT JDDT PLTF
® Judgment was entered for:
(Date of Judgment)
(Name) ASSET ACCEPTANCE LLC
Judgment was entered against: (Name) WORTHINGTON, CRRXS J
in the amount of $ 1,152.0
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 $
Amount of Judgment $ 1,075.59
Judgment Costs $ 76•
Interest on Judgment $ .00
Attorney Fees $ • U0
Total $ 1,152.09
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.
,-Magisterial District J
4K,Xru - Z
•'17-61F Date
I certify that this is a true and correct copy of the record of the proceedings containing the judgment.
zz Date ?- jr? , Magisterial District Judge
My commission expires first Monday of January, ` ". -
AOPC 315-07
9/19/08
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ASSET ACCEPTANCE LLC ; 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.
CHRIS J WORTHINGTON NOTICE OF FILING JUDGMENT
500 E MARBLE ST
MECHANICSBURG PA 17055
Defendant
Notice is herby given that a money judgment in the above-captioned matter has been entered
against you in the amount of $_ r , pq on _ /T /gyp
By:
If you have any questions regarding this notice, please contact the filing party:
Edwin A. Abrahamsen & Associates
1729 P ttston 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
ASSET ACCEPTANCE LLC
CIVIL DIVISION
Plaintiff
VS.
CHRIS J WORTHINGTON
Defendant
NO: 08-7308
PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S RESPONSES TO
INTERROGATORIES IN AID OF EXECUTION
Plaintiff, ASSET ACCEPTANCE LLC, 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, ASSET ACCEPTANCE LLC,obtained a judgment against the
Defendant in regard to an outstanding, past due and defaulted credit card account.
2. On December 26, 2008, Plaintiff served Defendant with Interrogatories in
Aid of Execution on the subject judgment. (See Interrogatories in Aid of Execution dated
December 26, 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 January 30, 2009, 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 February 20, 2009, 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,
lkwin A. Abr msen & Associates, P.C.
Michael F. R hford, Esquire
Heather K. oodruff, Esquire
Attorney . Nos: 86285/207805
120 No Keyser Ave
Scranton, Pa 18504
Phone: 570-558-5510
Fax: 570-558-5511
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ASSET ACCEPTANCE LLC
CIVIL DIVISION
Plaintiff
VS.
CHRIS J WORTHINGTON
Defendant
NO: 08-7308
PLAINTIFF'S BRIEF IN SUPPORT OF ITS MOTION TO COMPEL
DEFENDANT'S RESPONSES TO INTERROGATORIES IN AID OF
EXECUTION
Plaintiff, ASSET ACCEPTANCE LLC, 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, ASSET ACCEPTANCE LLC, obtained a judgment against the
Defendant in regard to an outstanding, past due and defaulted credit card account. On
December 26, 2008, Plaintiff served Defendant with Interrogatories in Aid of Execution
of the subject judgment. (See, Interrogatories in Aid of Execution, dated December 26,
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 January 30, 2009, 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 February 20, 2009, 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,
Edwin A. Ab amsen & Associates, P.C.
hford, Esquire
Michael F. ff
Attorney o
.: 86285
VERIFICATION
I, Michael F. Ratchford, Esquire, attorney for Plaintiff, ASSET
ACCEPTANCE LLC 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.
Mhlt1 A. ABRAHAMSEN
MICHAEL F, RATCHFORD
HEATHER K. WOODRUFF'
• ALSO A MEMBER OF FL BAR
•
THE LAW OFFICE OF
WAIN A. AB&ML01SEN & A SOCL-kT ES. PC
W W W.EAA-I.AW.COM
CHRIS J WORTHINGTON
500 E MARBLE ST
MECHANICSBURG PA 17055
December 26, 2008
RE: ASSET ACCEPTANCE LLC/CAPITAL ONE BANK vs. CHRIS J
WORTHINGTON
File # AA8-0708 Balance: $1,050.24
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.
. ?af?ar ?C ffm"d, 4 wsio
Heather K. Woodruff, Esquire
1729 PITTSTON AVENUE SCRANTON, PA 18505 (P) 570.558.5510 (F) 570.558.5511
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
ASSET ACCEPTANCE LLC, assignee of
CAPITAL ONE BANK
Plaintiff
-vs- NO.08-7308
CHRIS J WORTHINGTON
Defendant
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 wamed 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 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 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:
(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. 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:
4.-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:
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 safety 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 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:
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 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
encurnbrance, 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:
8. 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. Abrahamson & Associates, P.C.
DATED: V BY: v g?jDb(j)
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
3120
NOTARY PUBLIC
AFFIANTS SIGNATURE
AFFIANTS ADDRESS
TITLE OF OFFICIAL
EDWIN A. AGRAHAMSEN
MICHAEL F. RATCHFORD
HEATHER K. WOODRUFF-
`ALSO MEMBER OF FL BAR
WWW.EAA-LAW.COM
CHRIS J WORTHINGTON
500 E MARBLE ST
MECHANICSBURG PA 17055 January 30, 2009
RE: Creditor: ASSET ACCEPTANCE LLC
Original Creditor: CAPITAL ONE BANK
Original Account Number: 5178052447063468
Balance Due: $1,056.27
Our File #: AA8-0708
Dear CHRIS J WORTHINGTON:
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 ASSET
ACCEPTANCE LLC . 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
Edwin A. Abrahamsen & Associ
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.
94
THE LAW OFFICE OF
EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C.
1 729 PITTSTON AVE. • SCRANTON, RA 1 8505 • (P) 570.558.551 0 • (F) 570.558.55 1 1
EDWIN A. AORAHAMSEN
MICHAEL F. RATCHFORD
HEATHER K. WOODRUFF'
'ALSO MEMBER OF FL OAR
1AR
THE LAW OFFICE OF
EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C.
WWW.EAA-LAW.COM
February 20, 2009
CHRIS J WORTHINGTON
500 E MARBLE ST
MECHANICSBURG PA 17055
Re: ASSET ACCEPTANCE LLC v, CHRIS J WORTHINGTON
CUMBERLAND County Civil Action No.: CV 287-08
Our File #: AA8-0708
Dear CHRIS J WORTHINGTON:
As you know, on December 26, 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.
Ed%-v,ir A. Abrahamsen & Associates. P
ec
t a debt. Any
This is a communication from a debt collector in an attem7??
information obtained will be used for that purpose. /
1 729 PITTSTON AVE. 0 SCRANTON, PA 1 8505 • (P) 570.558.551 0 • (F) 570.558.551 1
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
ASSET ACCEPTANCE LLC
Plaintiff
VS.
CHRIS J WORTHINGTON
Defendant
CIVIL DIVISION
NO: 08-7308
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:
CHRIS J WORTHINGTON
500 E MARBLE ST
MECHANICSBURG PA 17055
Date:
W, I
Michael F tchford, Esquire
Att A,
orne No.: 86285
FILED-ORF CE
OF THE PRCTHMARY
2009 OCT -2 PM 12: 5 j4
CUM _,; .
ASSET ACCEPTANCE LLC IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
CHRIS J. WORTHINGTON,
DEFENDANT NO. 08-7308 CIVIL
ORDER OF COURT
AND NOW, this 20th day of October, 2009, upon consideration of Plaintiff's
Motion to Compel Defendant's Responses to Interrogatories in Aid of Execution,
IT IS HEREBY ORDERED AND DIRECTED that Defendant shall serve
full and complete answers, without objection to the Plaintiffs Interrogatories in
Aid of Execution within 20 days of personal service or service by certified mail
return receipt requested of this Order upon the Defendant.
IT IS FURTHER ORDERED AND DIRECTED that if the Defendant fails to
provide the requested discovery, the Plaintiff shall file a Motion for Sanctions
which sets forth compliance with said proof of service, at which time a hearing
will be scheduled.
By the Court,
M. L. Ebert, Jr., J.
I- Michael F. Ratchford, Esquire
Attorney for Plaintiff
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C)P THE PRTH NOTARY
2009 ESC T 21 Ai 1 9- €3 3
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