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HomeMy WebLinkAbout01-4688HAYT, HAYT & LANDAU BY: ARTHUR LASHIN, ESQUIRE IDENTIF)CATION NO. 23425 SIXTH FLOOR 400 MARKET STREET PHILADELPHIA, PA 19106-2509 (215) 928-1400 ATTORNEY FOR PLAINTIFF FORD MOTOR CREDIT COMPANY VS. ISREAL ZAMBRANA AND JOAN ZAMBRANA (EXECUTING AGAINST ISREAL ONLY) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION TERM, PRAECIPE TO ENTER JUDGMENT TO THE COURT: Kindly enter judgment in favor of FORD MOTOR CREDIT COMPANY ~ISREAL ZAMBtlANA , in the amount of $ 5365..7i , , and against By: YT/&~ HAYT, AU Attorney for Plaintiff ARTHUR~LASHIN, ESQUIRE HAYT, HAYT & LANDAU BY: ARTHUR LASHIN, ESQUIRE IDENTIFICATION NO. 23425 SIXTH FLOOR 400 MARKET STREET PHILADELPHIA, PA 19106-2509 (215) 928-1400 OHIGINAI~ ATFORNEY FOR PLAINTIFF FORD MOTOR CREW)IT COMPANY VS. ISREAL ZAMBRANA AND JOAN ZAMBRANA (EXECTUTING AGAINST ISREAL ONLY) CUMBERLAND COUNTY COURT OF COMMON PLEAS C IV IL DI VISION TERM, PRAECIPE TO ASSESS DAMAGES TO THE PROTHONOTARY: Please assess damages as follows with regard to the above captioned matter: JUDGMENT AMOUNT: $ 5365.75 INTEREST: $ 3541.39 7-21-89 TOTAL: $ 8907.14 By: Attorney for Plaintiff ARTHUR LASHIN, ESQUIRE DATE: ' 9/10/2001 OFFICE OF PROTHONOTARY BUCKS COI/NTY, PA. PAGE 1 TIME: 12:18 CIVIL CASE DOCKET INFORMATION JUDGE RUFE III. PLAINTIFF FORD MOTOR CREDIT COMPANY ONE AMERICAN ROAD DEARBORN MI 48122 CLASS ASSUMPSIT VS STATUS X DEFENDANT ZAMBRANA ISRAEL 1446 GIBSON ROAD, LOT # C-15 BENSALEM PA 19020 LASHIN ARTHUR ATTYS NONE VS ZB=MBP, A/{A 15 OVERBROOK LJtNE LEVITTOWN PA 19054 ATTYS NONE 05241989 06071989 06091989 06131989 06201989 06271989 07181989 07241989 08011989 08021989 COMPLAINT IN ASSUMPSIT FILED. PD. $50.50. APPEARANCE OF ARTHUR LASHIN, ESQ., ENTERED FOR PLAINTIFF. DEMAND FOR DAMAGES IS LESS THAN $20,000.00. RECEIVED IN SHERIFF'S OFFICE FOR SERVICE. TRANSACTION #89 1 06494. AMOUNT PAID $42.00. SHERIFF' RETURN, UNDER OATH, NOT FOUND BY DEPUTY RINK_ER AS TO DEFENDANT JOAN ZAMBPJkNA. DEFT MOVED, CHECKED POST OFFICE, NO FORWARDING. SHERIFF'S RETURN, UNDER OATH, FILED. DEPUTY MACKNICK AT 9:00 AM. SERVED DEFENDANT(S) PURSUANT TO PA.R.C.P. #402(A) (I) SERVED. CHERYL A PELLEGRINO PERSONALLY. SHERIFF'S RETURN, UNDER OATH, FILED. DEPUTY HAVERSTOCK AT 2:40 PM. SERVED DEFENDANT(S) PURSUANT TO PA.R.C.P. #402(A) (I) SERVED. ISRAEL ZAMBANA PERSONALLY. PAPERS RETURNED TO PROTHONOTARY. INVOICE MAILED TO ARTHUR LASHIN ESQ. (89 1 06494). PRAECIPE TO REINSTATE COMPLAINT FILED. EO DIE COMPLAINT REINSTATED. 9.00 PD CERTIFICATION OF SERVICE OF NOTICE OF INTENTION TO TAKE JUDGMENT BY DEFAULT FILED. AFFIDAVIT OF NON-MILITARY SERVICE FILED. NOTICE MAILED IN ACCORDANCE WITH PA. R.C.P. 236 AS AMENDED. SEE FILE FOR NAMES AND ADDRESSES. RECEIVED IN SHERIFF'S OFFICE FOR SERVICE. TPJtNSACTION #89 1 08346. AMOUNT PAID $36.80. SHERIFF' RETURN, UNDER OATH, NOT FOUND BY DEPUTY RINKER AS TO DEFENDANT JOAN ZAMBRANA A/K/A JOAN MATARAZZO. DEFT MOVED, P.O. NO FORWARDING. PAPERS RETURNED TO PROTHONOTARY. INAfOICE MAILED TO ARTHUR LASHIN ESQ. (89 1 08346). LM LM LM DR DR DR DR DR DR DR DR CL SA SA SA SA DR DR DR DR DATE:- 7/10/2001 PAGE 2 TI~E: 12:18 DOCKET # 1989 04191 08161989 08171989 08241989 08251989 09191989 10131989 11141989 11241989 12181989 03141990 03201990 03261991 PP~AECIPE FOR WRIT OF EXECUTION FILED AND WRIT EXIT. SM GARNISHEE: FIDELITY BAiqK PAID 15.00 RECEIVED IN SHERIFF'S OFFICE FOR SERVICE. TRANSACTION #89 1 09654 RE AMOUNT PAID $100.00. REAL DEBT FIXED IN THE AMOUNT OF $5,365.75. RE FORMER COSTS IN THE SUM OF $161.80. RE WRIT OF EXECUTION AND INTERROGATORIES TO GARNISHEE FILED. RE FIDELITY BANK, 90 NORTH MAIN STREET, DOYLESTOWN PA 18901. PAPERS NOT SERVED BECAUSE (GARNISHMENT GIVEN TO DEPUTY). SL SERVED WRIT AND INTERROGATORIES, WITH COPY FOR DEFENDANT, ON SL FIDELITY BANK, GARNISHEE ON 8 /25/ 89,AT 10:00 AM BY DEPUTY BROWN BY HANDING TO JANICE BRUEHL, PERSON IN CHARGE. SL PAPERS NOT SERVED BECAUSE (LEVY GIVEN TO DEPUTY). SL PP~AECIPE TO DISSOLVE ATTACHMENT AGAINST GARNISHEE FILED BY PLTF. PA PAPERS NOT SERVED BECAUSE DEFENDANT MOVED. SL LETTER SENT TO ATTORNEY FOR MORE INFORMATION FOR SERVICE. SL PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE FILED. SA EO DIE CASE MARKED DISCONTINUED. PAID $5.00 NO LEVY MADE WITHIN 90 DAYS BECAUSE DEFENDANT HAS MOVED TO BRADFORD SL CO. SHERIFF COSTS $85.40. SHERIFF REFUND $14.60 , INVOICE #35178 GE CHECK #10469 MAILED TO ARTHUR LASHIN, ESQ. IR RETURN MADE TO PROTHONOTARY. GE FILE REMOVED TO REMOTE STORAGE. CONTACT RECORDS MANAGER. DP END OF CASE JULY 10, 2001 certified in th~ ~mant of $5,365.75+(X~PS against Deft Is~-ael Z~mbra~a. County of Bucks. S.S. I, do hereby certify that the W~tNn and f~regoi~g Is a 1]'ue and at.ecl GDI:)Y of * me within entttklcl case as ~ saree re- FORD MOTOR CREDIT COMPANY VS. ISREAL ZAMBRANA AND JOAN ZAMBRANA (EXECUTING AGAINST ISREAL ONLY) CUMBERLAND COUNTY COUMT OF COMMON PLEAS COUNTY OF CUMBERLAND CERTIFICATION OF ADDRESSES I hereby certify that the address for the Defendant(s), 1 BUTTON LANE CARLISLE PA 17013 I hereby certify that the address for Plaintiff, 1335 S. CLEARVIEW AVENUE MESA AZ 85208 / Attorney for Plaintiff ARTHUR LASHIN, ESQUIRE 23425 (215)928-1400 COURT OF COMMON PLEAS AFFIDAVIT OF NON-MILITARY SERVICE FORD MOTOR CREDIT COMPANY : VS. SS ISREAL ZAMBRANA AND JOAN ZAMBRANA (EXECUTING AGAINST ISREAL ONLY) : STATE OF PENNSYLVANIA COUNTY OF ~H'ILA~.LPHiA Arthur Lashin. · being duly sworn according to Law, deposesand says~tha~he represents the Plaintiff in the above entitled case; that he is authorized to make this Affidavit on behalf of the Plaintiff; and that the above named Defendant(s) is (are) 18+ years of age; the address of Defendant(s) is 1 BUTTON LANE CARLISLE PA 17013 Occupation of Defendant(s) is unknown; and the Defendant(s) is (are) not in the Military Service of the United States, nor any State or Territory thereof or its Allies as defined in the Soldiers' and the Sailors' Civil Rmlief Act of 1940 and amendments thereto. HAYT, HAYT AND LANDAU ATTORNEY FOR PLAINTIFF ARTHUR LASHIN, ESQUIRE 23425 Prothonotary Sworn to and subscribed before me this 17TH day of JULY Not~f~'i~ub lic My commission expires: Nofaria~ HAYT, HAYT & LANDAU BY: ~ ~ IDENTIFICATION NO. 23425 SIXTH FLOOR 400 MARKET STREET PHILADELPHIA, PA 19106-2509 (215) 928-1400 ATTORNEY FOR PLAINTIFF FORD MOTOR CREDIT COMPANY VS. ISREAL ZAMBRANA AND JOAN ZAMBRANA (EXECUTING AGAINST ISREAL ONLY) CUMBERLAND C0~NTY COURT OF COMMON PLEAS CIVIL DIVISION TERM, ENTRY OF APPEARANCE TO THE COURT: .-7 Kindly enter my appearance on behalf of Plaintiff, F~MOTOR CREDIT COMPANY as to the above indicated matter. By: Arthur Lashir~, Esquire Hayt, Hayt & Landau Attorney ID #23425 "~'~' ' N '~ =v JUDGMENTS) pKALCii'E FOR WKIT CF E.XZ~,..'TIO --w'ION'-~ P.R.C.P. 3101 to 3149 Etc. FORD MOTOR CREDIT COMPANY ISREAL ZAMBRANA AND JOAN ZAMBRANA (EXECUTING AGAINST ISREAL ONLY) ..... IN THE COURT OF CO~,IMON PLF. A$ OF CUMBERLAND COUNTY, PENNSYLVANIA w~ No..-- ................... r~m, 19 ...... ......- ...... A,,..,[ d~, ............ $ .>_~.5... 7_~ ....... Int,r~,t ~mm 7--'2'~--"8~' ...... ..3.~5_&.l.~J ....... Att'y's Corn. ................................ Costs ................ $ ........................ To Lhe Prethono~ary of sa~d Court: ISSUE ~,','P, IT OF EXECIf'rlON IN THE ABOVE MA (2} ~n~ ..... EX~G~~-~ ~AL '~ ......................................... ........................................................................... ~cfenda~ (s) ; (3) znd ~a~t .... ~FR~I~-~C~%~'~ ............... Garnishee (s) ; (4) ~nd index this writ .................................................................. D.-~en~nt (s) and (b) aE~nst ................................................................................... ...................................................................... ~ ~.rn~shee (,), · s · i~s p~-nd~ns against ~he reml property ci lhe defendant [ s) in die nam~ of the Garnishee (s) as follows: ~Sp.ciflcall¥ describ~ property) PERSONAL PROPERTY LEVY AT: BANK ATTACHMENT AT: 1 BUTTON LANE AMERICHOICE ~EDERAL CREDIT UNION CARLISLE, PA 17013 20 SPORTING GREEN DRIVE MECHANICSBURG PA 17055 KINDLY SERVE INTERROGATORIES UPON GARNISHEE LISTED. (5) Exemption h~s (not) been wmvcd. D,,~d ...... 7_=1.7:-.R1 ....... ARTHUR L~SHIN, ESQUIRE 23425 NOTZ (215)928-1400 PERSONAL PROPERTY LEVY AT: 1 BUTTON LANE CARLISLE PA 17013 BANK ATTACHMENT AT: AMERICHOICE FEDERAL CREDIT UNION 20 SPORTING GREEN DRIVE MECHANICSBURG PA 17055 LEVY AND BANK ATTACHMENT Wrk,No ...................... Term, 19 ...... No ......................... Term, 19_ ..... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY -'7 [i~; 8:25 COUNTY PENNSYLVANIA ISREAL ZAMBRANA AND JOAN ZAMBRANA (EXECIjTING AGAINST ISREAL ONLY) PRAECIPE FOR WILIT OF EXECUTION {Moncy Judg~ncnts) P. K. C. P. 3101 to 3149 etc. ARTHUR LASHIN, ESQUIRE 23425 Address: (215)928-1400 HAYT, HAYT & LAND~i~fc papers may be ,erred. BUTTON LANE 6T~-I FLOOR 400 MARKET..STRE:E"T CARLISLE PA 17013 PHI~ 'PA fg:lO~ 2of4/7 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. DEFENDANT NOW RESIDES IN YORK HAVEN, YORK CO. PA. Sheriff's Costs: Docketing $ 18.00 Poundage 1.76 Advertising Law Library .50 Prothonotary 1.00 Mileage 9.60 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Garnishee 9.00 89.86 Advance Costs: $ 150.00 Sheriffs Costs: 89.86 60.14 Refundedto Arty on 9/17/01 Sworn and Subscribed to before me this /f~day of~ 200 A.D. prot~o~{otary So Answers; R. Thomas Ktine, Sheriff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cumberland To satisfy the debt interest and costs due NO. COUNTY: Ford Motor Credit Cux~any 01-4688 CIVIL 17~X TE~ CIVIL ACTION - LAW PLAINTIFF(S) from Isreal Zambrana and Joan Zambrana (executing against Isreal only), 1 Buttc~ Lane, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the properly of the defendant(s) and to sell ];;~r~ona.1- property (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of __ Bank Attachment At: Americhoice Federal Credit Union, 20 Spo~cJ3zg Green Drive, ~han~h]t~3. PA 17055 - Kindly Serve Interroqatories upon Garnishee Listed. GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are 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 propertyof 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 $5367.75 L.L. $. 50 Interest ¢-,-~-n 7/21/Rg - S3541.39 Due Prothy $1.00' Atty's Corem % Other Costs Atty Paid $429.50 Plaintiff Paid Date: Auqust 7, 2001 Curtis R. Long REQUESTING PARTY: Name 'A_--"thu~ T~hin, Esq. Address: ' 6th Floor~ 400 Market Street .Philadelphia, PA 19106 Afforney for: Plaintiff Telephone: ~15-928-1400 Supreme Couff ID No. 23425 b~ Prothonotary, Civil Division ~. Deputy SHERIFF'S RETURN - CASE NO: 2001-04688 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GARNISHEE FORD MOTOR CREDIT COMPANY VS ZAMBRANA ISREAL ET AL And now JASON VIORAL Cumberland County of to law, at 0013:28 Hours, on the 28th day of August , as herein commanded all goods, chattels, rights, debts, moneys of the within named DEFENDANT , ZAMBR3LNA ISREAL hands, possession, or control of the within named Garnishee AMERICHOICE FEDERAL CREDIT UNION ,Sheriff or Deputy Sheriff of Pennsylvania, who being duly sworn according 2001, attached credits, and , in the 20 SPORTING GREEN DR MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to DIANE MARKLEY (DIR. OF OPERATIONS) , personally three copies of interogatories together with 3 true and attested copies of the within EXEMPLIFIED RECORD and made the contents there of known to Her . Sheriff,s Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and subscribed to before me this /~ day of ~--~,~ ~ A.D. Pr6thonotary · R. Thomas Kline Sheriff. of CumberLa. nd.-County oo/oo/oooo // eputy Sheriff RECEIPT FOR DISTRIBUTION OF ADVANCE PAYMENTS HELD In ESCROW Cumberland County Pennsylvania Hanover and High Street Carlisle, PA 17013 Receipt Date 09/17/2001 Receipt Time 09:20:55 Receipt No. 271010 FORD MOTOR CREDIT COMPANY Case Number Service Info Remarks (VS) ZAMBRANA ISREAL ET AL 2001-04688 P Escrow Transfer Out 102.00 41.86 Advance Payment Balance Total Amount Distributed 60.14 Balance Remaining HAYT HAYT D. ND LANDAU 400 MARKET STREET, 6TH FLOOR PHILADELPHIA, PA 19106 ............................ Distribution Transaction Description Amount POUNDAGE 1.76 PROTHONOTARY 1.50 MILEAGE 9.60 GARNISHEE 9.00 LEVY 20.00 Payee CUMBERLAND CO TREASURER CUMBERLAND CO PROTHONOTARY CUMBERLAND CO TREASURER CUMBERLAND CO TREASURER CUMBERLAND CO TREASURER Total Amount Distributed 41.86 HAY'F, HAYT & LANDAU BY: ARTHUR LASHIN IDENTIFICATION NO. 23425 SIXTH FLOOR 400 MARKET STREET PHILADELPHIA, PA 19106-2509 (215) g~-14oo ~ FORD MOTOR CREDIT COMPANY ATTORNEY FOR PLAINTIFF ISREAL ZAMBRANA and JOAN ZAMBRANA CUMBERLAND COUNTY COURT OF COMMON PLEAS C:~. DIVISION TERM, No. 01-4688 CIVIL PRAEcIPE TO DISCONTINUE wITHouT 'PI~LHYDIC:e; TO THE PROTHONTARy: Kindly discontinue the above captioned matter _Without Rrejudice. Attorney for' Plaintiff HAYT, HAYT & LANDAU BY: ARTHUR LASHIN, ESQUIRE IDENTIFICATION NO. 23425 SIXTH FLOOR 40O MARKET STREET PHILADELPHIA, PA 19106-2509 (215) 9~-1400 FORD MOTOR CREDIT COMPANY vs. ISREAL ZAMBRANA and JOAN ZAMBRANA and ANERCHOICE FEDERAL CREDIT UNION Garnishee ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS Civil DIVISION TERM. No. 01-4688 CIVIL ORDERTO DISCONTINUE ~ DISSOLVE ATTAC~NT TO THE PROTHONOTARY: Kindly mark the attachment against the Darnishee, AMERCHOICE FEDERAL CREDIT UNION , made under the Writ of E~ecutiou issued on August 7, 2001 in the above captioned matter Discontinued and Dissolved. HAYT, HAYT~ By: Attorney for Plaintiff