HomeMy WebLinkAbout09-2610Burton Neil & Associates, P.C.
By: Brit J. Suttell, Esquire ID. NO. 204140
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
Midland Funding LLC
Plaintiff
V.
MICHELLE L O'BRIEN
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. oq-,%I o CiV1? term
CIVIL ACTION - LAW
Praecipe for Entry of Judgment Pursuant to Pa. R.C.P.M.D.J. No 402 D(1) and (2)
To the Prothonotary:
Pursuant to the attached District Justice Judgment Transcript, enter judgment on behalf of
the plaintiff, Midland Funding LLC, and against the defendant, Michelle L O'Brien, and assess
damages as follows:
Judgment Transcript
Interest from
Less Payments
Judgment Amount
$3,029.91
$.00
-$.00
$3,029.91
Burton Neil & Associates, P.C.
B )Y
Bri J. Suttell, Esquire
Attorney for the Plaintiff
a
And now on this alt day of r+1 judgment is entered in favor of
the total s f $3,029.91.
Midland Funding LLC and against Michelle L O'B4Prothonot
t'q
ary'
By
B
urton Neil & Associates, P.C. is a debt collector.
COMVONWF-ALTH OF PENNSYLVANIA
,CCU U NTY OF: COJIBERZ AND
Mag. Dist. No.:
09-1-02
t
r
MDJTiame: Hon.
r Address: .];PMT V. MANLOVE
1g01 '
Burt "ST
CAM HILL, 'PA
9J;.
Telephone 1,4
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE 108909
PLAINTIFF' NAME and ADDRESS
rilDLAND FUNDING LLC
1060 ANDREW DR APT/STE 170
WEST CHESTER, PA 19381-0356
L
DEFENDANT: NAME and ADDRESS
_39N4THnor,
L=OYNZ, Ply 17043 a
C/O BURTON NEIL i? ASSOCIATES, PC L J
1060 ANDREW DR APT/STE 170 Docket No.: CST-0000264-08
WEST CHESTER, PA 19381-0356 Date Filed: 9/09/08
THIS IS TO NOTIFY YOU THAT:
DH F ?IILT J MT PLTF 10/31/08
-Judgment: , (Date of AWgaxW Judgment was entered for: (Name) NIDIJ= FUNDING LLC'
® Judgment was entered against. (Name) OBRIEN, MICHELLE L
in the amount of $ 3, 029.9
Defendants are jointly and severally liable.
Damages will be assessed on Date & ,Time
'ThtS case dismissed with out prej4q]F%,
F] 'Amount of Judgment Subject to AttachmeiWO Pa C.S.' § 8127,
Portion of Judgment for physical damages arising out of
L, residential lease $
Amount of Judgment $ 2,936.41
Judgment Costs $ 93•
Interest on Judgment $ .00
Attorney Fees $
Total, $ 3 x; g29.91
Bost Judgrtlent 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
u JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON,PLEAS, ALL FURTHER PROCESS MUST
_-COM& PF" #FIE 6A ART OF410MMON PEAS"ANB t-WfURTiR-:R-Pft=ESS -MAY-SE ISSUEB-SY THE4&di L 091RId-T 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.
12/1/08 IS. IS TRUE AND C
"r
OW " a
r
COPY.
abate
Zap
'>tcertif "thatta?s,s.a,true, ?co et' - rd ,
Q Date ?
My commission expires first Monday of January, 2012
, Magisterial District Judge
SEAL
AOPC 315-07
DATE PRINTED: 10/31/08 10:39:00 AN
S? 1
Burton Neil & Associates, P.C.
By: Brit J. Suttell, Esquire ID. NO. 204140
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
Midland Funding LLC
8875 Aero Drive Suite 200
San Diego CA 92123
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
MICHELLE L O'BRIEN
39 North 4th Street
Lemoyne PA 17043
Defendant
: NO.
:CIVIL ACTION - LAW
Certification of Address and
Affidavit of Non-Military
Understanding that false statements herein are subject to penalty under 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities, I verify that:
1. The above are the precise last-known addresses of the judgment creditor and debtor.
2. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003
(SCRA) the defendant is not in the military service of the United States based on information
received from the defendant and/or the Department of Defense website.
Burton Neil & Associates, P.C.
By)I-
Brit J Suttell, Esquire
Atto ey for Plaintiff
Burton Neil & Associates, P.C. is a debt collector.
FUL) '
2009 APR 27 pi 1`. Q3
4 al . as PD ATW
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axe- aaAalI
• .
Burton Neil & Associates, P.C.
By: Brit J. Suttell, Esquire ID. NO. 204140
1060 Andrew Drive, Suite 170
West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
Midland Funding LLC IN THE COURT OF COMMON PLEAS
Plaintiff
v.
: CUMBERLAND COUNTY, PENNSYLVANIA
. NO.
MICHELLE L O'BRIEN
Defendant : CIVIL ACTION - LAW
Rule of Civil Procedure No. 236 (Revised)
Notice is given that a JUDGMENT in the above captioned matter has been entered
against you on
P othonot
By:
Deputy
If you have any questions concerning the above, please contact:
Brit J. Suttell, Esquire
Attorney for Party Filing
1060 Andrew Drive, Suite 170
West Chester, PA 19380
Phone: 610-696-2120
Burton Neil & Associates, P.C. is a debt collector.
108248 / 232
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
Pa.R.C.P. § 3103 to 3149
Midland Funding LLC
8875 Aero Drive Suite 200, San Diego CA 92123
Plaintiff
v.
MICHELLE L O'BRIEN
39 North 4th Street, Lemoyne PA 17043
Defendant(s)
METRO BANK
1130 Carlisle Road, Camp Hill, PA 17011
Garnishee(s)
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 09 2610 CV
: CIVIL ACTION - LAW
To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER r t
1. Directed to the Sheriff of Cumberland County, Pennsylvania
2. against MICHELLE L O'BRIEN , Defendant(s)'
3. and against METRO BANK , Garnishee())
4. and index this writ
(a) against Defendant(s)
(b) against Garnishee(s)
as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows:
(specifically describe property)
NO LEVY - GARNISHMENT ONLY
Serve interrogatories on garnishee at: 1130 Carlisle Road, Camp Hill, PA 17011
5. Amount Due
Interest from 10/31/2008
Total
*Plus writ costs
Dated: December 11, 2014
$3,029.91
$1,111.68
$4,141.59*
Ed d J. l rien, Esquire
Attorney for Plaintiff
NOTE: Under paragraph 1 when the writ is directed to sheriff of another county as authorized by Rule 3103(b), the county should be
indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued.
Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule
3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should
be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c).
This is an attempt to collect a debt, and any information obtained will be used for that purpose. This
communication is from a debt collector.
tts99 °c) ait)
.7) .as ect
$a. as
# .31H(»
l a(a Th°d
THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite100 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
MIDLAND FUNDING, LLC
Vs.
MICHELLE L. O'BRIEN
WRIT OF EXECUTION
(Pa R.C.P. 3252)
NO 09-2610 Civil Term
CIVIL ACTION — LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs against MICHELLE L. O'BRIEN, 39 NORTH 4TH STREET,
LEMOYNE, PA 17043 Defendant (s)
(1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein;
(2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of
METRO BANK, 1130 CARLISLE ROAD, CAMP HILL, PA 17011 GARNISHEE(S), as garnishee,
(Specifically describe property) and to notify the garnishee that
(a) an attachment has been issued;
(b) except as provided inparagraph (c), the garnishee is 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;
(c) the attachment shall not include
(i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any
funds whichare deposited electronically on a recurring basis and are identified as being funds that upon deposit
are exempt from execution, levy or attachment under Pennsylvania or federal law.
(ii) each account of the defendant (s)'with a bank or other financial institution in which funds on deposit exceed
$10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being
funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law.
(iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If
multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as
determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general
exemption provided in 42 Pa.C.S. § 8123.
(3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession
1
of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added
as a garnishee and is enjoined as above stated.
Amount Due $3,029.91
Interest FROM 10/31/2008 - $1,111.68
Attorney's Comm. %
Attorney Paid $56.25
Date: 12/15/14
Plaintiff Paid
Law Library $.50
Due Prothonotary $2.25
Other Costs
David i. Buel , Prothonotary
By:
Deputy
REQUESTING PARTY:
Name : EDWARD J. O'BRIEN, ESQUIRE
Address: LAW OFFICES BURTON NEIL & ASSOCIATES, P.C.
1060 ANDREW DRIVE, SUITE 170
WEST CHESTER, PA 19380
Attorney for: PLAINTIFF
Telephone: 610-696-2120
Supreme Court ID No. 32985
MAJOR EXEMPTIONS UNDER PENNSYLVANIA
AND FEDERAL LAW
1. $300 statutory exemption
2. Bibles, school books, sewing machines, uniforms and equipment
3. Most wages and unemployment compensation
4. Social Security benefits
5. Certain retirement funds and accounts
6. Certain veteran and armed forces benefits
7. Certain insurance proceeds
8. Such other exemptions as may be provided by law
2
Burton Neil & Associates. P.C.
By: Edward J. O'Brien, Esquire ID. NO. 32985
1060 Andrew Drive Suite 170
• West Chester, PA 19380
610-696-2120
Attorney for Plaintiff
fit
25 I 4 DEC 29 Pti I: 5 I
CUMBERLAND COUNT'
PENNSYLVANIA
Midland Funding LLC : IN THE COURT OF COMMON PLEAS
Plaintiff
v. : CUMBERLAND COUNTY, PENNSYLVANIA
MICHELLE L O'BRIEN
39 North 4th Street, Lemoyne PA 17043 : NO. 09 2610 CV
Defendant(s)
METRO BANK
Garnishee
: CIVIL ACTION -LAW
To: METRO BANK
1130 Carlisle Road. Camp Hill. PA 17011
nAnt JEi r )d
Interrogatories to Garnishee
You are required to file answers to the following interrogatories within twenty (20) days
after service upon you. Failure to do so may result in judgment against you:
L' s 1.- At the time you were served or at any subsequent time did you owe the defendantany
money or were you liable to the defendant.or any negotiable or other written instrument, or did
the defendant claim that you owed the defendant any money or were liable to the defendant for
any reason? Defendant has account with a balance of $109.95
which is less than $300 exemption
2. At the time you were served or at any subsequent time was there in your possession,
custody or control or in the joint possession, custody or control of yourself and one or more other
persons any property of any nature owed solely or in part by the defendant?
no
3. If the answer to 1 and/or 2 is yes, please specify the nature of the property and, if
money, the amount?
no
4. At the time'.you were served.or at anysubsequent time, did you. hold, legal, title to any
property of any nature "owned solely or in part by the -defendant or in which,de_ fendantheld or,
claimed any interest? n e
5. At the time you were served or at any subsequent time did you hold as fiduciary any
property in which defendant had an interest?
no
6. At any time before you were served did the defendant transfer or deliver any property
to you or any person or place pursuant to your direction or consent and if so what was the
consideration therefor?
no
7. At any time after you were served did you pay, transfer or deliver any money or
property to the defendant or to any person or place pursuant to the defendant's direction or
otherwise discharge any claim of the defendant against you?
no
8. If you are a bank or other financial institution, at the time you were served or at any
subsequent time did the defendant have funds on deposit in an account in which funds are
deposited electronically on a recurring basis and which are identified as being funds that upon
deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so,
identify each account and state the reason for the exemption, the amount being withheld under
each exemption and the entity electronically depositing those funds on a recurring basis.
see answer to question 1
9. If you are a bank or other financial institution, at the time you were served or at any
subsequent time did the defendant have funds on deposit in an account in which funds on
deposit, not including any otherwise exempt finds, did not exceed the amount of the general
monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account.
Burton Neil : Associates, P.C.
d 4. O'Brien, Esquire
This is an attempt to collect a debt, and any information obtained will be used for that purpose.
This communication is from a debt collector.
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating
to unsworn falsifications to authorities, that he/she is Jennifer Hilbish
(Name)
Levy Specialist
(Title)
of Metro Bank, . garnishee herein,
(Company)
that he/she duly authorized to make this verification, and that the facts set forth in the foregoing
Answers to Interrogatories are true and correct to the best of his/her knowledge, information and
belief.