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
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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