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HomeMy WebLinkAbout09-4305 v COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Dist. No.: 09-1-03 MDJ Name: Hon. RICHARD S. DOUGHERTY Address: 98 S ENOLA DR STE 1 ENOLA, PA Telephone: 717 ) 728-2805 17025 ATTORNEY FOR PLAINTIFF : RICHARD H. YETTER III 4480 WILLIAM PENN HWY EASTON, PA 18042 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JODGIMENT PLTF ® Judgment was entered for: - (Name) ® Judgment was entered against: (Name) in the amount of $ 2, 631.2, 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 El Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 2,517.74 Judgment: Costs $ 113.50 Interest on Judgment $ .06 Attorney Fees $ • UD Total $ 2,631.24 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. J 2 2008 Date ft+ Wal'Di trict Judge I certify that this is a tr and co a th f t e edin p r>ta?nin 6 ment. Dat IVlagiteafiai District Judge My commission expires first Monday o January, 2012 SEAL AOPC 315-07 DATE PRINTED: ?9 - y3aS cN, I -I-«,?t NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rRANOVER INVESTMENT GROUP, LLC 5370 HANOVERVILLE RD BETHLEHEM, PA 18017 L VS. DEFENDANT: NAME and ADDRESS rFISHEL, RAETTA 95 2ND STREET APT/STE 1 ENOLA, PA 17025 J 7 L J Docket No.: CV-0000120-08 Date Filed: 5/02/08 (Date of Judgment) 6/12/08 HANOVER INVESTMENT GROUP, LLC FISHEL, BAETTA 6/13/08 9:14:00 AM FILED- 4Ql-F;fCE OF 'rr-Jr- 2009 JUH 25 PI 3: 47 V?IY I ?jNl i I $ 7 dt of alc??? /c#cr ?d-7a3( ?x e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW HANOVER INVESTMENT GROUP, LLC Plaintiff VS. NO. CV-120-08 RAETTA FISHEL . Defendant CIVIL ACTION NOTICE OF FILING JUDGMENT (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you, Raetta Fishel, in the amount of Two Thousand Six Hundred Thirty-one and Twenty- Four Cents ($2,631.24). (X) A copy of all documents filed with the Prothonotary in support of the within judgment are enclosed. CLERK OF COURT-CIVIL/PROTHONOTARY If you have any questions regarding this Notice, please contact the attorney of the filing party: Richard H. Yetter III, Esquire 4480 William Penn Highway Easton PA 18045 (610) 253-8948 (610) 923-8144 (fax) (This NOTICE is given in accordance with Pa.R.C.P. 236) RICHARD H. YETTER III, ESQUIRE I.D. NUMBER 90530 4480 William Penn Highway Easton, PA 18045 (610) 253-8948 (610) 923-8144 (fax) ATTORNEY FOR PLAINTIFF, HANOVER INVESTMENT GROUP, LLC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW HANOVER INVESTMENT GROUP, LLC Plaintiff VS. : NO. 094305 RAETTA FISHEL Defendant : CIVIL ACTION MOTION TO COMPEL DEFENDANT TO RESPOND TO PLAINTIFF'S DISCOVERY DIRECTED TO DEFENDANT Plaintiff, HANOVER INVESTMENT GROUP, LLC, by their undersigned counsel, hereby moves this Court to enter an order pursuant to Pa. R.C.P. No. 4019(a)(1)(i) directing defendant, RAETTA FISHEL, to serve full and complete answers to Plaintiffs First Set of Interrogatories propounded to defendant or suffer sanctions, and in support thereof avers as follows: 1. The action was instituted by complaint on or about April 30, 2008 in District Court 9-2-03. 2. Default Judgment was entered against the Defendant on or about June 12, 2008. 3. Said Default Judgment was filed with the Cumberland County Court of Common Pleas on or about June 25, 2009. A time-stamped copy of said Judgment is attached hereto as Exhibit "A". 4. On or about June 29, 2009, plaintiff served Plaintiffs First Set of Interrogatories upon defendant. A copy of Plaintiffs aforementioned discovery to Defendant is attached as Exhibit "B." 5. Pursuant to Pa. R.C.P. No. 4006(a)(2), defendant's answers and objections, if any, to the interrogatories were due on or before July 29, 2009. 6. A period of more than thirty days has elapsed since the aforementioned discovery was served upon defendant, and no response of any kind has been provided. 7. For the foregoing reasons, plaintiff believes and avers that defendant will not answer plaintiffs interrogatories absent a court order pursuant to Pa. R.C.P. 4019(a)(1)(i). WHEREFORE, plaintiff requests that the Court enter an order directing defendant to file full and complete answers to Plaintiffs First Set of Interrogatories within fifteen (15) days or suffer appropriate sanctions to be imposed upon further application to the Court. Respectfully Submitted: YETTER LAW OFFICE DATED: 5 09 Richard H. ener III, Esquire VERIFICATION I, RICHARD H. YETTER III, ESQUIRE, hereby verify that I am the attorney for the Plaintiff in the within action, and that the facts contained in the foregoing Motion are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 9 s 0 / Richard . etter III, Esquire COMMONWEALTH OF PENNSYLVANIA NOTICE OF JUDGMENT/TRANSCRIPT COUNTY OF: CU BSRT_AM CIVIL CASE Mag. Dist. No.: PLAINTIFF: NAME and ADDRESS 09-1-03 aA11OV1R INVSSTJKMT GROUP, LLC MW Name: Hon. 5370 H7ISOVSRVILLE RD RICHARD S. DOIIGH$RTY BSTHLMM, PA 18017 Address: 98 S KNOLA DR STS . 1 L. J ZNOLA, PA VS. DEFENDANT: NAME and ADDRESS Telephone: (717) 728-2805 170$5 fFISHEL, RARTTA -1 95 21® STRXZT APT/STS 1 ATTORNZY FOR PLAINTIFF s RNOLA, PA 17025 .RICHARD H. YSTTSR III L J 4480 WILLTJM PS= Hp1Y Docket No.: CV-0000120-08 SASTON, PA 18042 Date Filed: 5/02/08 THIS IS TO NOTIFY YOU THAT: - - Judgment: DEFAULT ?7QDGILI?IT PLTY (Date of Judgment) 6/12108 Judgment was entered for: (Name). VANOVRR INVESTMXNT . GROUP, LLC Judgment was entered against: Name) FISHSL, RABTTA in the amount of $ 2. 31.2 Amount of Judgment $ 2, 5.17. 74 Defendants are jointly and severally liable. Judgment Costs $ 113 . Damages will be assessed on.Date & Time Interest on Judgment $ • Attorney Fees $ This case dismissed without prejudice. $ 2, 631.4 •. Total Amount of Judgment Subject to Attachment/42 Pa C.S. § 8127 Post Judgment Credits $ $ Post Judgment Costs $ Portion of Judgment for physical damages arising out of residential lease 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 JUDGMENTI 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 THEAAGISTERIAL 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. r? rv .. - . , CD JUN' $ 20M, Date ?fiAgtteltl cfrct Judge J certify that this is a tr and co a th f t edin I?Xalhing t$-Iudghent Qat VaQ 0t ial" Di6trict. Judge 2012 My commission expires first Monday o anuary, SEAL AOPC 315-07 DATE PRINTED: 6/13/08 9:14:00 AX IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW HANOVER INVESTMENT GROUP, LLC Plaintiff VS. RAETTA FISHEL Defendant No. 0 9-LI30 5'- cN:i fees NO. CV-120-08 CIVIL ACTION NOTICE OF FILING JUDGMENT (X') Notice is hereby given that a judgment in the above-captioned matter has been entered against you, Raetta Fishel, in the amount of Two Thousand Six Hundred Thirty-one and Twenty- Four Cents ($2,631.24), (X) A copy of all documents filed with the Prothonotary in support of the within judgment are enclosed. CLERK OF COURT-CIVIL/PROTHONOTARY If you have any questions regarding this Notice, please contact the attorney of the filing party: Richard H. Yetter III, Esquire 4480 William Penn Highway Easton PA 18045 (610) 253-8948 (610) 923-8144 (fax) (This NOTICE is given in accordance with Pa.R.C.P. 236) RICHARD H. YETTER III, ESQUIRE I.D. NUMBER 90530 4480 Willlam Penn Highway Easton, PA 18045 (610) 253-8948 (610) 923-8144 (fax) ATTORNEY FOR PLAINTIFF, HANOVER INVESTMENT GROUP, LLC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW HANOVER INVESTMENT GROUP, LLC, Plaintiff VS. : NO. 094305 RAETTA FISHEL, Defendant : CIVIL ACTION INTERROGATORIES PROPOUNDED BY PLAINTIFF HANOVER INVESTMENT GROUP, LLC AND DIRECTED TO DEFENDANT IN AID OF EXECUTION TO: RAETTA FISHEL _ 95 tad Street APT 1 Enola, PA 17025-3202 Plaintiff, Hanover Investment Group, LLC, is seeking to collect on the judgment which it has secured against you in this case and needs information about your assets. In aid of execution you are requested to answer the following interrogatories pursuant to Pa. R.C.P. 3117. You are required under Pa. R.C.P. 4006 to file answers under oath or verification to the following interrogatories within thirty days after their service upon you: DEFINITIONS Unless negated by the context of the Interrogatory, the following definitions are to be considered applicable to all Interrogatories contained herein. 1. As used herein, the words "you" and "your" refer to defendant and defendant's agents, representatives, attorneys and all other persons acting or purporting to act on behalf of defendant. 2. As used herein, the word "document" shall mean that original and any copy, regardless of origin or location, or any book pamphlet, periodical, letter, memorandum, telegram, report, study, handwritten note, working paper, or any other written, recorded, punches, or taped matter, however produced, to which you have or have had access. (S) 3. As used herein, "corporation," "company" or "entity" shall mean any corporation, partnership, sole proprietorship, company, entity or business operation. 4. As used herein, "communication" shall mean all conversations, whether oral or written, all telephone calls, telegrams, letters, memoranda, documents, discussions or any other form of communication. 5. As used herein, "identify" or "identity" used in reference to an individual or person means to state his full name, present business and private addresses, his present or last known occupation, his employer, and employer's address. 6. As used herein, "identify" or "identity" when used in reference to a corporation, company, entity or institution means to state its full name and present address, any fictitious names under which it operates, and the present owners, officers and directors thereof with their current address. 7. As used herein, "identify" or "identity" when used in reference to a document or communication means to state the date, author, type of document or communication (e.g., letter, memorandum, telegram, chart, etc.) or any other means of identifying it, its present location, and the name and address of its custodian. If any such document of communication was, but is no longer, in your possession or subject to your control, state what disposition was made of it and who presently has it. 8. Whenever the expression "and/or" is used in these interrogatories, the information called for should a set out both ip the conjunctive and disjunctive, it should be given separately for each - and every element sought. 9. Whenever a date, amount, or other computation or figure is requested, the exact date, amount, or other and then, the approximated date, amount or other computation or figure is requested, the approximated date, amount or other computation or figure should be given of the best estimate thereof; and the answer shall state that the date, amount, or other computation or figure is an estimate or approximation. 10. No answer is to be left blank. If the answer to an interrogatory or subparagraph of an interrogatory is "none" or "unknown," such statement must be written in the answer. If the question is inapplicable, "N/A" must be written in the answer. If an answer is omitted because of the claim of privilege, the basis of privilege is to be stated. 11. These interrogatories are continuing, and any information secured subsequent to the filing of your answers which would have been includable in the answers had it been known or available, are to be supplied by supplemental answers. 12. If additional space is required for an answer, attach supplemental answer sheet which clearly identifies the interrogatory number. INTERROGATORIES OF THE INDIVIDUAL DEFENDANT RAETTA FISHEL 1. State your: (a) Full name (b) Address (c) Age (d) Social Security Number (e) Driver's License Number and expiration date (f) Telephone number 2. State other nbmes do you use, if any? 3. State the name(s), address(es) and age(s) of your present and/or former spouse and your children, if any. 4. With whom do you live? 5. Identify each of your dependents, if any. 6. State the full name and address of your employer (a) Your weekly salary: Gross Net (b) If not presently employed, name and address of last employer. 7. Is there currently a wage execution on your salary? Yes No 8. List the names and addresses of each bank and account numbers of all bank accounts on which your name appears. 9. If you receive money from any of the following sources, list the amount, how often, and the name and address of the source: Type Alimony Loan Payments Rental Income Pensions Bank Interest Stock Dividends 10. 11. Amount & Frequency Do you receive Social Security benefits? Yes No Name & Address of Source Do you own property where you reside? Yes No If Yes, state the following: (a) Name all of the owner or owners (b) Date property was purchased (c) Purchase price (d) Name and address of mortgage holder (e) Balance due on mortgage 12. Do you own any other real estate? Yes No (a) Address of property (b) Name all of the owner or owners (c) Date property was purchased (d) Purchase price (e) Name and address of mortgage holder (f) Balance due on mortgage If Yes, state the following for each property: (g) Name and address of all tenants and monthly rental paid by each tenant 13. Does the present value of your personal property which includes automobiles, furniture, appliances, stocks, bonds, and cash on hand, exceed $1,000? Yes No If the answer is "yes," you must itemize all personal property owned by you. Cash on hand: $ Other personal property: (Set forth make, model and serial number. If financed, give name and address of party to whom payments are made.) If Financed Date Purchase Balance Still Present Item Purchased Price Due Value 14 15. Do you own a motor vehicle? Yes No If yes, state the following for each vehicle owned: (a) Make, model and year of motor vehicle (b) If there is a lien on the vehicle, state the name and address of the lien holder and the amount due to the lien holder (c) License plate number (d) Vehicle Identification Number (VIN) Do you own a business? Yes No If yes, state the following for each business: (a) Name and address of the business(es) (b) Is the business a Corporation, sole propriet6rship, or partnership? (c) List the name and address of all stockholders, officers and/or partners (d) The amount of income received by you from the business during the last twelve months. 16. Set forth all other judgments that you are aware of that have been entered against you and include: Creditor's Creditor's Amount Name of Docket Name Attorney Due Court Number Respectfully Submitted: Dated: YETTER LAW OFFICE Richard H etter I, Esquire Attorney for tiff Attorney ID# 90530 4480 William Penn Highway Easton PA 18045 (610) 253-8948 (610) 923-8144 (fax) VERIFICATION I, RAETTA FISHEL, verify that the statements made in these Answers to Interrogatories are true and correct. Defendant understands that false statements herein are made subject to the penalties of 19 Pa.C.S. Section 4904, relating to unworn falsification to authorities. Dated: RAETTA FISHEL GI r T,?F: n_F Th'= E ^T y 2CQ9 AUG -7 Pli 2: 16 j, , HANOVER INVESTMENT GROUP, LLC, Plaintiff V. RAETTA FISHEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 09-4305 CIVIL TERM IN RE: MOTION TO COMPEL DEFENDANT TO RESPOND TO PLAINTIFF'S DISCOVERY DIRECTED TO DEFENDANT ORDER OF COURT AND NOW, this 10th day of August, 2009, upon consideration of Plaintiff's Motion To Compel Defendant To Respond to Plaintiff's Discovery Directed to Defendant, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 14 days of service. BY THE COURT, Richard H. etter, III, Esq. 4480 William Penn Highway Easton, PA 18045 Attorney for Plaintiff /aetta Fishel Second Street Apt./Ste. 1 Enola, PA 17025 Defendant, pro Se J esley Ole r., J. :rc TAP Y 2ry00 AU t 12 Ai I C : 01 4 RICHARD H. YETTER III, ESQUIRE I.D. NUMBER 90530 4480 William Penn Highway Easton, PA 18045 (610) 253-8948 (610) 923-8144 (fax) ATTORNEY FOR PLAINTIFF, HANOVER INVESTMENT GROUP, LLC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW HANOVER INVESTMENT GROUP, LLC Plaintiff VS. RAETTA FISHEL : NO. 09-4305 : CIVIL ACTION Defendant CERTIFICATE OF SERVICE I, RICHARD H. YETTER III9 ESQUIRE, certify that I served the Defendant with the INTERROGATORIES PROPOUNDED BY PLAINTIFF HANOVER INVESTMENT GROUP, LLC AND DIRECTED TO DEFENDANT IN AID OF EXECUTION by U.S. regular mail with delivery confirmation confirming delivery to the Defendant on August 17, 2009, at the address of 95 2nd Street APT/STE 1, Enola, PA 17025 (See Exhibit "A".) Dated: August 19, 2009 LISPS - Trac'c & Confirm Search Results Label/Receipt Number: 0308 2040 0002 4778 3958 Service(s): Delivery Confirmation" Status: Delivered Your item was delivered at 11:21 AM on August 17, 2009 in ENOLA, PA 17025. Page 1 of 1 Trick At Cotftm Enter Label/Receipt Number. Track & Confirm by email Get current event information or updates for your item sent to you or others by email. 1',-6> Site Map Customer Service Forms Gov't Services Careers Copyright© 2009 USPS. All Rights Reserved. No FEAR Act EEO Data FOiA Privacy Policy Terms of Use Business Customer Gateway ,.c A /, http://trkcnfrm l .smi.usps.com/PTSIntemetWeb/InterLabelInquiry. do 8/18/2009 Cr1 ?' N? a 9C9 pax mar rn a e =' M .G LTI z ?n co o o -.-_? N CUPJ O• v i FILED-OFFICE OF THE PROTHOfiN'OTARY 2609 AUG 20 AM 11: 17 ;1:t?l?? iP1 r (N