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Home My WebLink About09-5440COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CLAIMS RECOVERY SYSTEMS, INC. Plaintiff : No.OR - SM Civil Term VS. CIVIL ACTION ROBIN BARNHART, Defendant PRAECIPE TO THE CLERK OF SAID COURT: Please enter judgment in favor of Plaintiff Claims Recovery Systems, Inc. and against Defendant Robin Barnhart in the amount of $942.36 plus costs and interest. an R. M6ge, Es Attorney ID No. 1288 Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5.93 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CLAIMS RECOVERY SYSTEMS, INC. Plaintiff vs. ROBIN BARNHART, Defendant No.o4 - Civil Term CIVIL ACTION ( ) Notice is hereby given that a Judgment in the above captioned matter has been entered against you in the amount of $942.36 plus costs and interest on S , 2009. -,QL4-q ( ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. Prothonotary By: If you have questions regarding this Notice, please contact the filing party: NAME: Alan R. Wag, Esq. ADDRESS: P.O. Box 1426 Bethlehem, PA 18016 TELEPHONE NO. 610-954-5393 (This Notice is given in accordance with Pa.R.C.P.§236.) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA Claims Recovery Systems, Inc. Plaintiff VS. Robin Barnhart Defendant NO. AFFIDAVIT OF NON-MILITARY SERVICE The undersigned, being duly sworn, according to law, deposes and says that the Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; That Robin Barnhart is over 18 years of age, resides at 1483 Goodyear Rd., Gardners, PA 17324 . _ and is employed That Defendant is years of age, resides at and is employed That Defendant is years of age, resides at and is employed That Defendant is years of age, resides at and is employed I, Alan R. Mtge, Esquire, do hereby verify that I am the attorney for Plaintiff, that I am fully authorized to make this Verification on their behalf, that the Defendants are unavailable to make this verification, that the facts contained in the foregoing pleading are true and correct to the best of my knowledge, information and belief, and the source of my information are interviews with my client and the Plaintiff's filed documents. The verifier understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Signed: Dated: 7/30/09 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CIVIL COMPLAINT PLAINTIFF' NAME and ADORE .3 Maplsterial District NumOu?: 09-3-02 CLAIMS RECOVERY SYSTEMS District Justice Name: Non. 6 EAST MAIN PA STREET ? 0 6 VIVAN J CORICR CA.RNEGIE, y Addross: PO BOX 155 (412) 276-6980 ? NEINVILLE, PA. 3,7243. L_ vs. Te?ephona: ( 717 ) 776-3187 DEPENDANT: NAME and ADDRESS F-ROSIN BARNHART 1483 GOODYEAR RD GARDNERS, PA 17324 Dooket NO.: 1 b(o AMOUNT DATE PAID FILING COSTS $ J POSTAGE $?? J SERVICE COSTS $?`_ J I CONSTABLE ED. $?_, J J TOTAL $?? J I S ?'' 77 3 ' 3 6 TO THE DEFENDANT: The abovF_named„PW .' Iff(s) asks judgment against you for together with costs upon tho following claim (Civil tines must-include r:itatlon of the statute or ordinance violated): DEVE,,NDAGCO00NWTSNPAST DU5362 BALANCE85160 OF $ 1,773.36 FOR CAPITAL ONE CRAIG BARRETT verify that the facts set forth In this complaint are true and correct to the 4904 of the Crimes 1, best of my knowledge, Information, and belief. This statement is made subject to the penalties of on Code (I8 PA. C.S. § 4904) related to unswom falsification to authorities. ( i9natUM o MM or lit o Agent Plalntifra Address: Attomey: Telephone: ( ) IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD $O NOTIFY THIS OFFICE IMMEDIATELY AT THE ENTER F-13 AGAINST YOU BY DE AULTE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU 00, ABOVE TELEPHONE JUDGMENT MAY BE If you have a claim against the plaintiff which is within district justice jurisdiction and which you intend to assert at the hearing.; you must file it on a complaint form at this office at least five (5) days before the date set for ihe'hearing. If you are disabled and require a reasonable accommodation to gain access to the contact the Magisterial District Court at the above a District Court and its services, please address or telephone number. We are unable to provide transportation. AOPC 308A-03 COMMONWEALTH OF PENNSYLVANIA COtINTY nF• CUlIBERLARD Mag. Dist. No.: 09-3-02 MDJ Name: Hon. VIVIAN CORICE Address: PO BOX 155 27 N BIG SPRING AVE NENVILLE, PA Telephone: (717 ) 776-3187 17241 C . R. SYSTEMS 6 E KAIN STREET P.O. BOX 703 CARNEGIE, PA 15106 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JUDGMENT PLTF (Date of Judgment) 8/04/08 FX] Judgment was entered for: (Name) C. R. SYSTMS, ® Judgment was entered against: (Name) BARNH,RT, ROBIN in the amount of it 1,842.36- F-1 Defendants are jointly and severally liable. Damages will be assessed on Date & Time 1-1 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, 773.36 - Judgment Costs 69.05 $_ Interest on Judgment $ .00 Attorney Fees Total $ 1,842.36 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. S Date / Magisterial District Judge I certify that this is a true and correct copy of th re rd of the proceedings containing the judgment. -13-09 Date , Magisterial District Judge My commission expires first Monday of January, 2012 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF' NAME and ADDRESS F C.R. SYSTZKS 6 E KAIN STREET P.O. BOX 703 LCARNEGIE, PA 15106 J VS. DEFENDANT: NAME and ADDRESS FB,RNHA T ROBIN , 1483 GOODYEAR RD GARDNERS, PA 17324 L J Docket No.: CV-0000106-08 Date Filed: 6/30/08 SEAL AOPC 315-07 DATE PRINTED: 8/05/08 11:31:00 AN LL -? 2: 2 e. K-4 -R4- A)ol ?? ,?? CSC -1, 1 [N THE COURT OF COMMON PLEAS OFcuMBERUwoCOUNTY, PENNSYLVANIA CTYIL 12MSION Claims Recovery Systems, Inc. V. Robin Barnhart 1443 c-- 664d4>"S' A 1732-Y Sovereign Bank 1 ? Case No. Oq 8.i Amount Due $942.36 Interest from 8/4/08 @ 6916 ($51.81) Atty's Fee** Costs to be added Gamishee PRAEGLPE FOR WRIT OF EXECUTION To the Clerk of Courts: Issue a writ of execution in the above matter, (1) direct the Sheriff of CUMBERLAND county; (2) against Robin Barnhart , defendant(s) and upon the (Name of Defendant(s)) following described property of the defendant(s) Alllanglible persoy nall nrnpeM of the defendant located at GARNISHEMENT ONLY (Supply four copies of lengthy personalty list) (if real property supply six copies of the description) (3) against Sovereign Bank , garnishee(s) for the following property: (4) and enter this writ in the judgment index (a) against defendant(s) and (b) against , as garnishee(s) as a lis pendens against real property of the defendant in name of garnishee as follows: (Specifically described property) Date: 7/30109 Signature: Print Nam an R. Mee E Address: PO Box 1426, Be ehem, PA 18016-1426 Attorney for: Plaint Telephone: (610) 954_5393 Supreme Court 16 No: R12RR ** Where judgment has been entered under Rule 2951(a), attorneys' fees may be included if they are authorized in the instrument and there has been a record appearance of counsel at any stage of the proceedings. Pa.R.C.P. 3251 Ohiga", All- THE 'ARY 2099 AUG _5 PH 2: 2 I I.zq. SD ,4fi•;.s • Cam . .a. ro ` • r rr ?? tom C K4 ! 0183 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-5440 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CLAIMS RECOVERY SYSTEMS, INC., Plaintiff (s) From ROBIN BARNHART, 1483 GOODYEAR ROAD, GARDNERS, PA 17324 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of SOVEREIGN BANK, 17 WEST HIGH STREET, CARLISLE, PA 17013 -- ANY AND ALL ACCOUNTS, SAVINGS, CHECKING, CERTIFICATE OF DEPOSIT OR OTHERWISE, INCLUDING SAFE DEPOSIT BOXES. GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) 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; (3) If property of 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 $942.36 Interest FROM 8/4/08 @ 6% - ($51.81) Atty's Comm % Atty Paid $54.25 Plaintiff Paid Date: AUGUST 5, 2009 L.L. $.50 Due Prothy $2.00 Other Costs Curtis R. Long, Prothonotary (Seal) Deputy REQUESTING PARTY: Name ALAN R. MEGE, ESQ. Address: PO BOX 1426 BETHLEHEM, PA 18016-1426 Attorney for: PLAINTIFF Telephone: 610-954-5393 Supreme Court ID No. 81288 Sheriffs Office of Cumberland County R Thomas Kline ALE.D-^r'- 1t' Sheriff F THE - Ronny Ronny R Anderson tp 2+307 AUU. 17 A? Chief Deputy Jody S Smith Civil Process Sergeant f f't'v?t.?.L?? Edward L Schorpp Solicitor Claims Recovery Systems Inc. Case Number vs. Robin Barnhart 2009-5440 SHERIFF'S RETURN OF SERVICE 08/13/2009 10:12 AM - Timothy R. Black, Deputy Sheriff, who being duly sworn according to law, states that on August 13, 2009 at 1009 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Robin Barnhart, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 West High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Denise Beecher, Customer Service Representative, personally three copies of interrogatories together with three true and attested copies of the writ: of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on August 14, 2009 to Robin Barnhart, at 1483 Goodyear Road, Gardners, PA 17324. So Answers, R. Thomas Kline, Sheriff By De uty Sheriff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CLAIMS RECOVERY SYSTEMS, INC. Plaintiff VS. No.UR -PK0 Civil Term CIVIL ACTION ROBIN BARNHART, Defendant SOVEREIGN BANK, GARNISHEE JLSU*L +0 INTERROGATORIES TO THE ABOVE NAMED GARNISHEE TO: Sovereign Bank, 17 West High Street, Carlise, PA 17013 You are required to file an answer to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. 1. At the time you were served or at any subsequent time did you owe the Defendant, Robin Barnhart, SSN: 164-52-0794 any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? NO 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 owned solely or in part by the Defendant? YES At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the Defendant; or in which the Defendant held or claimed any interest? NO 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant had an interest? NO At any time before or after you were served, did the Defendant transfer or deliver any property to you or to any person, entity or place pursuant to your direction or consent and if so, what was the consideration therefor? NO 6. At any time after you were served, did you pay, transfer or deliver any money or property to the Defendant or any other person, entity or place pursuant to his direction or otherwise discharge any claim of the Defendant against you? NO 7. 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 amount of funds in each account, the reason for the exemption, the amount being withheld under each exemption, and the entity electronically depositing those funds on a recurring basis. 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 the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. §8123? If so, identify each account. YES - SEE ATTACHED 9. At any time before or after you were served, did Defendant, either solely or in part, have any account (savings, checking, certificate of deposit, money market, deposits, safe deposit box, and any other debt and/or property) with your office? SEE ATTACHED . 10. If your answer to Interrogatory #9 is in the affirmative, state: SEE ATTACHED VERIFICATION A. The account number of each account; B. The amount of money in each account. Mege, Attorney for P aintiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 ANSWERS TO INTERROGATORIES Account # 2891035968 Balance: $77.71 After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this account is $0.00 Account Holder: Robin L Barnhart or Timothy R Barnhart 1483 Goodyear Rd Gardners, PA 17324-8906 VERIFICATION I, Camille Neuwinger, C.O.P. Lead Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment 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 4094, relating to unsworn falsification to authorities. Sovereign Bank By: Camille Neuwinger C.O.P. Lead Specialist IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: Commonwealth Financial Systems, Inc. VS. Robin Barnhart CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Alan R Mege, Esquire P. O. Box 1426 Bethlehem, PA 18016-1426 Service by certified mail addressed as follows: Robin L Barnhart 1483 Goodyear Rd Gardners, PA 17324-8906 Camille Neuwinger C.O.P. Lead Specialist Sovereign Bank MA1 M133-02-10 2 Morrisey Boulevard Boston, MA 02125 August 25, 2009 FP p rAJRY 2009 iM'j 31 fl ! 4 l COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CLAIMS RECOVERY SYSTEMS, INC. Plaintiff No. 09-5440 vs. CIVIL ACTION ROBIN BARNHART, Defendant SOVEREIGN BANK, GARNISHEE PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Kindly dissolve the attachment against the garnishee, Sovereign Bank, with regard to the above-captioned matter. DATE: August 31, 2009 Alairf-R Wge, Esq/ Attorney for Pla tiff P.O. Boa 1426 Bethlehem, PA 18016 (610) 954-5393 F1LEt?--J); ? ICE f-, I, n i OF THE P7.11 2039 S£P 16 P 2: 23 CUiiV Ct; 1?; 1 da". d $%. co Pb A-rH M*"f6350 e0130&0% COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CLAIMS RECOVERY SYSTEMS, INC. Plaintiff vs. ROBIN BARNHART, Defendant No. 09-5440- Civil Term ~ r . ,.,,, ,~, CIVIL ACTION .~ .... o PRAECIPE AND POWER OF ATTORNEY FOR SATISFACTION AND/OR TERMINATION TO THE PROTHONOTARY OF CUMBERLAND COUNTY: You are hereby authorized, empowered, and directed to enter the following on the records thereof against Defendant Robin Barnhart: The within suit is Settled, Discontinued, Ended with costs paid. The within suit is Settled, Discontinued, Ended WITH Prejudice and costs paid. The within suit is Settled, Discontinued, Ended WITHOUT Prejudice and costs paid. Satisfaction of the Award in the within suit is acknowledged. XXX Satisfaction of Judgment, with interest and costs, in the within matter is acknowledged. Other: DATE: February 2, 2010 WITNESS (if signer is other than a registered attorney): Attorney or Notary ignature of Authori ' g Party Alan R. M~g so Type or print name of above signer COST PAYMENT VERIFICATION I UNDERSTAND THAT THE ABOVE ACTION CANNOT BE FILED AND DOCKETED UNTIL ALL COSTS HAVE BEEN PAID INCLUDING SHERIFF'S COSTS• AND HEREBY VERIFY THAT ALL COSTS HAVE BEEN PAID. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 78 PA C.S. 54904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. ignature = )* SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~�" .~~.�." " ~� ��n . ..=~~ =~" .=~�.°x~~~~xn=."�x��° ~~.=~°"° " . Ronny R Anderson • � 'VHF_ 'OT" ~^O TA/, ' Sheriff - Jody nSm»� 791iiNAR 27 pm 2^ co Chief Deputy ��N�"�`'""" Solicitor o��sur�smecp�p PENNSYLVANIA `~'~^~ Ck�maRecoverySys�mo|nu� vs. Robin Barnhart Case Number 2009-5440 SHERUFF'��0�� RETURN OF SERVICE 08/13/2009 10:12 AM - Timothy R. Black, Deputy Sheriff, who being duly sworn according to law, states that on August 13, 2009 at 1009 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Robin Barnhart, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 West High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Denise Beecher, Customer Service Representative, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on August 14, 2009 to Robin Barnhart, at 1483 Goodyear Road, Gardners, PA 17324. 03/27/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this wr of execution is returned SATISFIED. Attorneys office filed a praecipe to satisfy judgment on 02-04-10. SHERIFF COST: $123.52 SO ANSWERS, March 27, 2014 RON R ANDERSON, SHERIFF 'CO p^`.C~. b-t'md' Ay �/�� ~ �� -_' -~