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HomeMy WebLinkAbout09-6500 J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 UNIVERSITY OF PENNSYLVANIA 3451 Walnut Street Philadelphia, PA 19104 V. DICK ALBERT KIRCHNER 206 West Pine Street Mount Holly Springs, PA 17065 PRAECIPE Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS dq - (or a"'kr P.m Kindly docket the attached Judgment in the amount of $24,597.82 in favor of Plaintiff, University of Pennsylvania, and against the Defendant, Dick Albert Kirchner, for execution purposes only. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 UNIVERSITY OF PENNSYLVANIA 3451 Walnut Street Philadelphia, PA 19104 V. DICK ALBERT KIRCHNER 206 West Pine Street Mount Holly Springs, PA 17065 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND The undersigned, being duly sworn according to law, deposes and says that the Defendant is 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 Defendant, Dick Albert Kirchner, is over eighteen (18) years of age, and resides at 206 West Pine Street, Mount Holly Springs, Pennsylvania 17065. SWORN TO AND SUBSCRIBED BEFORE ME THISc?5'DAY OF 2009. c2f-?? 9 NOTARY' COMMONWEALTH OF PENNSYLVANIA LAURA ANN MALONEYE Notary Concord T Notary ty wp., Delaware County My Commission Expires April 29, 2010 J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 UNIVERSITY OF PENNSYLVANIA 3451 Walnut Street Philadelphia, PA 19104 V. DICK ALBERT KIRCHNER 206 West Pine Street Mount Holly Springs, PA 17065 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT I, J. Scott Watson, Esquire, hereby certifies that the debt in the above matter is valid, enforceable and unsatisfied to date. i? J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIScX* DAY OF 2009. NOTARY COMMONWEALTH OF pENNSYLVANiq NOTARIAL AURA ANN SEAL MALONEY NOt MY cord T" Delre Co C? Public mrnission awa Expires April 29ounty , 2010 J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 UNIVERSITY OF PENNSYLVANIA 3451 Walnut Street Philadelphia, PA 19104 V. DICK ALBERT KIRCHNER 206 West Pine Street Mount Holly Springs, PA 17065 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT I, J. Scott Watson, Esquire hereby certifies that the name and the last known address lof Plaintiff and Defendant are as stated below: Plaintiff: University of Pennsylvania 3451 Walnut Street Philadelphia, PA 19104 Defendant: Dick Albert Kirchner 206 West Pine Street Mount Holly Springs, PA 17065 SWORN TO AND SUBSCRIBED BEFORE ME THIS025'?'- DAY O 2009. s `J NOTARY' COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL LAURA ANN MALONEY Notary Public Concord Twp., Delaware County My Commission Expires April 29, 2010 J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 UNIVERSITY OF PENNSYLVANIA 3451 Walnut Street Philadelphia, PA 19104 V. DICK ALBERT KIRCHNER 206 West Pine Street Mount Holly Springs, PA 17065 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT OF NO APPEAL I, J. Scott Watson, Esquire, hereby certifies that the Municipal Court judgement in the above matter was not appealed into a higher court to date. J. SCO WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS. DAY OF? 2009. NOTARY COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL ELAU:RRA ANN MALONEY Notary Public cord Twp., Delaware County mmissionExpires April 29, 200 PAGE 1 REPORT ZDRDOCT First Judicial District RUN DATE 09/09/09 USER ID: PJV CIVIL DOCKET REPORT RUN TIME 12:27 PM CASE ID 081200634 -------------------------------------------------------------------------------- CASE NUMBER CASE CAPTION 081200634 UNIVERSITY OF PA VS KIRCHNER FILING DATE COURT LOCATION JURY 03-DEC-2008 AR AC N CASE TYPE: CONTRACTS (GOODS), ENFORCE STATUS: JUDGMENT ENTERED BY AGREEMNT Seg # Assoc Expn Date Type ID Party Name / Address & Phone No. 1 APLF A41060 WATSON, J. SCOTT 24 REGENCY PLAZA GLEN MILLS PA 19342 (610)358-9600 2 1 PLF 112474 UNIVERSITY OF PA 3451 WALNUT ST PHILADELPHIA PA 19104 3 DFT @6178860 KIRCHNER, DICK ALBERT 206 WEST PINE STREET MT HOLLY SPGS PA 17065 Filing Date / Time Docket Entry Date Entered 03-DEC-08 11:18:56 ACTIVE CASE 03-DEC-08 03-DEC-08 11:20:00 COMMENCEMENT OF CIVIL ACTION 09-DEC-08 WATSON, J. SCOTT 03-DEC-08 11:20:00 COMPLAINT FILED NOTICE GIVEN 09-DEC-08 WATSON, J. SCOTT COMPLAINT WITH NOTICE TO DEFEND WITHIN TWENTY (20) DAYS AFTER SERVICE IN ACCORDANCE WITH RULE 1018.1 FILED. 03-DEC-08 11:20:00 SHERIFF'S SURCHARGE 1 DEFT 09-DEC-08 WATSON, J. SCOTT 08-DEC-08 15:37:23 ARBITRATION HEARING SCHEDULED 08-DEC-08 15-JAN-09 09:39:02 SHERIFF'S SERVICE 15-JAN-09 DEPUTIZED SERVICE OF COMPLAINT UPON DICK ALBERT KIRCHNER BY SHERIFF OF CUMBRLAND COUNTY ON 12/18/2008. 02-APR-09 15:35:47 JUDGMENT ENTERED BY AGREEMNT 24,597.82 02-APR-09 WATSON, J. SCOTT JUDGMENT IS HEREBY ENTERED IN FAVOR OF UNIVERSITY OF PA REPORT : ZDRDOCT First Judicial District USER ID: PJV CIVIL DOCKET REPORT CASE ID 081200634 Filing Date / Time Docket Entry PAGA' ' ' ' 2 RUN DATE 09/09/09 RUN TIME 12:27 PM Date Entered AND AGAINST DICK ALBERT KIRCHNER IN THE AMOUNT OF $24,597.82 PURSUANT TO INTERESTED PARTIES' CONSENT - A TRUE AND CORRECT COPY OF WHICH IS ATTACHED HERETO. NOTICE GIVEN UNDER RULE 236 JUDGMENT IS HEREBY ENTERED..... * * * End of Docket ***Judgement certified in the amount of $24,597.82.*** SEP 0 2009 PHF -..COURT nSGir.R F Pti: EY FILED T THE 2u09 8 p? in: 5 ?. a UQ. oo Po ATE`{ ce 5Iµ85 AT,, .231133 No?he?. I?(.c?oP OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY TO: Dick Albert Kirchner 206 West Pine Street Mount Holly Springs, PA 17065 UNIVERSITY OF PENNSYLVANIA 3451 Walnut Street Philadelphia, PA 19104 CUMBERLAND COUNTY COURT OF COMMON PLEAS V. DICK ALBERT KIRCHNER 206 West Pine Street Mount Holly Springs, PA 17065 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. j4L OTHONOT JUDGMENT BY DEFAULTID q X MONEY JUDGMENT JUDGMENT IN REPLEVIN JUDGMENT FOR POSSESSION If you have any questions concerning this Judgment, please call J. Scott Watson, Esquire at 610-358-9600. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION University of Pennsylvania 3451 Walnut Street Philadelphia, PA 19104 VS. Dick Albert Kirchner 206 West Pine Street Mount Holly Springs, PA 17065 and Members First F.C.U. 1166 Walnut Bottom Road Carlisle, PA 17013 (Garnishee) ( )Confessed Judgment (X) Other ~~ . File No. 09-6500 ~_~'~' ~. ~~ -T` Amount Due $24,597.82 _ "`^'-'- ~ r/ .F1 Interest to 4/2/10 - $1,475.8' _ Atty's Comm r' _~ - - Costs :.~ '~ ,~ ~ ..r. TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. O Issue Writ of execution in the above matter to the Sheriff of Cumberland ,County, for debt, interest and costs, upon the following described property of the defendant(s) a,~4.6o PA A1T a4 . oo ~' d.Sp ~~ 5(0 . oo - PA t~Yfy PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) All checking accounts savings accounts monies on d~osit safety deposit boxes and any other realty or personalty which may be subject to lew in the possession of the Garnishee, Members First F.C.U., at 1166 Walnut Bottom Road Carlisle PA 17013 and belon ig_ng to the Defendant. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ( ) (indicate) Index the writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date ~ ~ ~ D Signature: Print Name: Address: Attorney for: Telephone: Supreme Ct ID ._~ J. Scott Watson, Esquire 24 Regency Plaza Glen Mills. PA 19342 Plaintiff 610-359-9600 041060 ~a.oo~UeCo • 50 t.C, ~,~ ~so9 ~.~a~ o3-~f I~ ri-toQ ~G~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-6500 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIVERSITY OF PENNSYLVANIA, Plaintiff (s) From DICK ALBERT KIRCHNER, 206 West Pine Street, Mount Holly Springs, PA 17065 (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 GARNISHEE(S) as follows: MEMBERS FIRST F.C.U., 1166 Walnut Bottom Road, Carlisle, PA 17013 All checking accounts, savings accounts, monies on deposit, safety depposit boxes and any other realty or personalty which may be subject to levy in the possession of the Garnishee and belonging to the Defendant. 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 $24,597.82 L.L. $.50 Interest to 4/2/10 -- $1,475.86 Atty's Comm Atty Paid $56.00 Plaintiff Paid Due Prothy $2.00 Other Costs Date: 4/12'10 (Seal) D uel , othonota By: Deputy R.EQUESTRdG PARTY: Name J. SCOTT WATSON, ESQUIRE Address: J. SCOTT WATSON PC 24 REGENCY PLAZA GLEN MILLS, PA 19342 Attorney for: PLAINTIFF Telephone: 610-359-9600 Supreme Court ID No. 041060 t OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY TO: Member's 1St Federal Credit Union Tania Young 5000 Louise Drive Mechanicsburg, PA 17055 UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS v. DICK ALBERT KIRCHNER NUMBER 09-6500 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. PROTHONOTARY JUDGMENT BY DEFAULT ~/171~ o X MONEY JUDGMENT _ JUDGMENT IN REPLEVIN JUDGMENT FOR POSSESSION If you have any questions concerning this Judgment, please call J. Scott Watson, Es uire at (610) 358-9600. J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610)358-9600 '-L_f - - - ,rJ ~ `... ~ _,.~~ r ~; 7~i0 ~~y.~~' i 7 i`r 2~ C~~,~_ _ a ~_;v1Y i''~'~.i`~'i ~Ur' : ~i'i~. Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA v. DICK ALBERT KIRCHNER CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 09-6500 PRAECIPE TO ENTER JUDGMENT IN ACCORDANCE WITH ANSWERS TO INTERROGATORIES IN ATTACHMENT TO THE PROTHONOTARY: Kindly enter Judgment on the attached Answers to Interrogatories in favor of Plaintiff, University of Pennsylvania, and against Garnishee, Member's First F.C.U., in the above-captioned matter and assess damages as follows: PRINCIPAL SUM $ 126.83 __- /.. ~J__ -,~~ ~_. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff ~ID.00 Pp q~rY e~.~' Ss-~s ~~ a~ a ado st MEMBERS 1St FEDERAL CREDIT UNION May 4, 2010 J. Scott Watson, Esq. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 RE: Writ of Execution for Dick A. Kirchner Dear Mr. Watson: A search of our records has revealed one (1) checking account and two (2) savings accounts bearing the name Dick A. Kirchner with an address of 206 W. Pine Street, Mt. Holly Springs, PA 17065. The checking account reflects an available balance of $426.85. The savings account reflects a balance of $0.02. Pursuant to the writ, all funds in the aforementioned accounts have been frozen and the accounts have been restricted from any further activity. Pursuant to Rule 3111.1 of Title 231 as promulgated and made effective on April 1, 2007, the total balance of both accounts exceeds the general monetary exemption under 42 Pa. C.S. § 8123 and are therefore attachable. The full amount of the attachable funds is contained in the interrogatories as filed with the Cumberland County Prothonotary. Since the funds contained in these accounts are attachable, and the accounts have been frozen and restricted from any further activity, no additional funds will be available for attachment. Should you have any questions or need any additional information, feel free to contact me at (800) 283-2328, ext. 5125. Sincerely, ~~~~ ~~ Tania S Young Deposit Operations Analyst 5000 Louise Drive P.O. Box 40 Mechanicsburg, Pennsylvania 17055 (800) 283-2328 www.memberslst.org ." v • ~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor x~~"~~ at ~a~~r+Lr~f~~~~ ~, University of Pennsylvania vs. Dick Albert Kirchner ' ~~~:~ ~ r~#.i :,~ ~~~1~~~'~~' -i,3 ~,; ~ ~L,~,~,1~ C,GUr~ . 'f~7 ~~c J JFfr ase Number I 12009-6500 SHERIFF'S RETURN OF SERVICE 04/26/2010 02:16 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states 2010 at 1416 hours, attached as herein commanded all goods, chattels, rights, debts, cr. of the within named defendant, to wit: Dick Albert Kirchner, in the hands, possession, or within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Cumberland County, Pennsylvania 17013, by handing to Brian peters, Branch Manager, copies of interrogatories together with three true and attested copies of the writ of execu contents there of known to him. The writ of execution and notice to defendant was mailed on May 3, 2010 to Dick Albert West Pine Street, Mt. Holly Springs, PA 17065. 11/02/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of e returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.50 November 02, 2010 SO ANSWERS, RON R ANDE B Sharon on April 26, >, and monies :rol of the •lisle, sonally three and made the ner at 206 is RS N, SHERIFF ~. ~antz ~i ~I ~ o ~. ~_ s ~~. !d) GOUnii Siaikr Sheriff, 'fear,^,SOft. 1;+;;. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-6500 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIVERSITY OF PENNSYLVANIA Plaintiff (s) From DICK ALBERT KIRCHNER, 206 West Pine Street, Mount Holly Springs, PA 17065 (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 GARNISHEE(S) as follows: MEMBERS FIRST F.C.U., 1166 WALNUT BOTTOM ROAD, CARLISLE, PA 17013 - - ALL CHECKING ACCOUNTS, SAVINGS ACCOUNTS, MONIES ON DEPOSIT, SAFETY DEPOSIT BOXES AND OTHER REALTY OR PERSONALTY WHICH MAY BE SUBJECT TO LEVY IN THE POSSESSION OF THE GARNISHEE. 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 $24,470.99 L.L. Interest to 2/28/11 - - $2,090.81 Atty's Comm % Due Prothy $2.00 Atty Paid $100.00 Other Costs Plaintiff Paid Date: 3/28/11 r David D. Buell, Prothonotary (Sea)) By: Deputy REQUESTING PARTY: Name J. SCOTT WATSON, ESQUIRE Address: LAW OFFICE OF J. SCOTT WATSON P.C. 24 REGENCY PLAZA GLEN MILLS, PA 19342 Attorney for: PLAINTIFF Telephone: 610-359-9600 Supreme Court ID No. 41060 C-) r. a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNS LV_NIA CIVIL DIVISION -" PRAE CIPE FOR WRIT OF EXECUTION University of Pennsylvania ) Confessed Judgm ent ' q ?r 3451 Walnut Street : (X) Other C Philadelphia, PA 19104 0 Z _. vs. : File No. 09-6500 co } Dick Albert Kirchner : Amount Due $24,597.82 206 West Pine Street : Interest to 2/28/11 - $2,090.81 Mount Holly Springs, PA 17065 : Atty's Comm SSN XXX-XX-0205 : Less Monies Rec'd ($126.83) and : Costs Members First F.C.U. 1166 Walnut Bottom Road Carlisle, PA 17013 (Garnishee) TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue Writ of execution in the above matter to the Sheriff of Cumberland , County, for debt, interest and costs, upon the following described property of the defendant(s) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) All checkine accounts. savings accounts monies on deposit safety deposit boxes and any other realty or personalty which may be subiect to levy in the possession of the Garnishee Members First F C U at 1166 Walnut Bottom Road Carlisle PA 17013 and belonging to the Defendant. and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). ( ) (indicate) Index the writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date h ?/1 S ay. so N ate aq.oo Coo ?l u r? ay.s t y. 60 00 D( 0- 4) ?c a4_? Signature: ?f 771 Print Name: J. Scott Watson Esquire Address: 24 Regency Plaza Glen Mills, PA 19342 Attorney for: Plaintiff Telephone: 610-359-9600 Supreme Ct ID 041060 qd' 60 'Ne &. CL* 110 '510 e?as7135 r ?r J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff RMWO APR @ 1201 UNIVERSITY OF PENNSYLVANIA 3451 Walnut Street Philadelphia, PA 19104 V. DICK ALBERT KIRCHNER 206 West Pine Street Mount Holly Springs, PA 17065 S.S.N. XXX-XX-0205 and MEMBERS FIRST F.C.U. 1166 Walnut Bottom Road Carlisle, PA 17013 CUMBERLAND COUNTY COURT OF COMMON PLEAS pnsw-?YS:lo NO. 09-6500 INTERROGATORIES IN ATTACHMENT "TO: Members First F.C.U. 1166 Walnut Bottom Road Carlisle, PA 17013 C'7 G -tam rnco 2rn Z? r ?= i;c= 0 ?v -v ?c sv N =C-n rnr- p 40 :r---n c->-n :?r, C)Pl x> :"0 -G 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. 1. At the time you were served or at any subsequent time, did you owe the Defendant any money or were you liable to the Defendant on 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 ? nc accwot 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 ? n v 3cCouot ' 3. 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 Defendant held or claimed any interest ? Vic) CtCCCurlt 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 ? h(? wcofl- 5. At the time before or after you were served did Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? m CkCCDo'lt 6. 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? 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 any 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. V1? GCM ?,??? t 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. Section 8123? If so, identify each account and the amount available in each account. alt; GCCcvi I t 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 the funds on deposit, not including any otherwise exempt funds, exceeded the amount of the general monetary exemption under 42 Pa. U. Section 8123? If so, identify each account and the amount available in each account. I?? acCcL?ir?. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff 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 Tania S. Young (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (Uompany) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. J1 ?.? (SIGNAT RE) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILED-OFFICE Jody S Smith oll ?t 444 OF THE PROTHONOTARY Chief Deputy z ; 20I I APR -8 AM 9: 15 Richard W Stewart Solicitor OFFICE ? ;hERIFF CUMBERLAND COUNTY PENNSYLVANIA University of Pennsylvania Case Number vs. Dick Albert Kirchner 2009-6500 SHERIFF'S RETURN OF SERVICE 04/01/2011 10:00 AM - Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on April 1, 2011 a 1000 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Dick Albert Kirchner, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Marisol Barber, Manager, 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 April 7, 2011 to Dick Albert Kirchner at 206 W Pine Street, Mount Holly Springs, PA 17065. SO ANSWERS, April 07, 2011 RON R ANDERSON, SHERIFF Tim 1 ck, Deputy c) Courn6uito Sheet Teieosott. Inc. J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. DICK ALBERT KIRCHNER NUMBER 09-6500 ORDER TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, Members First F.C.U., discontinued upon payment of your costs only. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff w :Zrr I =? r-M J /?? 1T .#? &) fi*/ wdjfm 4141#01 (V g PH ED—OFFICE J. SCOTT WATSON, P.C. lei 4 'f ( Tt;OOTAF's' BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 29#3 MA Y 2 0 PM 1: 55 24 Regency Plaza CUMBERLAND COUNTY Glen Mills, Pennsylvania 19342 P Eli N S Y LVA N f A (610)358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. DICK ALBERT KIRCHNER NUMBER 09-6500 PLAINTIFF'S MOTION TO REASSESS THE DAMAGES Plaintiff,by and through their attorneys, J. Scott Watson, P.C., hereby requests that this Court reassess the damages in this matter, and avers as follows: 1. On or about April 2, 2009, Plaintiff obtained a judgment against the Defendant in the amount of$24,597.82 in the Philadelphia County Court of Common Pleas. 2. On or about September 28, 2009, Plaintiff docketed said judgment in the Cumberland County Court of Common Pleas. - 3. Plaintiff wishes to reassess the damages in this matter to reflect the following: Judgment Amount $ 24,597.82 Post Judgment Interest $ 7,145.39 Costs $ 442.58 Payments ( 376.83) Current Balance $ 31,808.96 WHEREFORE, Plaintiff respectfully requests that this Honorable Court reassess the damages in this matter to reflect the current judgment balance against the Defendant in the amount of$31,808.96. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff J. SCOTT WATSON,P.C. BY: J. SCOTT WATSON,ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills,Pennsylvania 19342 (610)358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. DICK ALBERT KIRCHNER NUMBER 09-6500 PLAINTIFF'S MEMORANDUM OF LAW IN SUPPORT OF MOTION TO REASSESS THE DAMAGES I. FACTS On or about April 2, 2009, Plaintiff obtained a judgment against the Defendant in the amount of$24,597.82 in the Philadelphia County Court of Common Pleas.On or about September 28, 2009, Plaintiff docketed said judgment in the Cumberland County Court of Common Pleas. Plaintiff now wishes to reassess the damages in this matter. II. ISSUE Should Plaintiff's Motion be granted? Suggested Answer: YES III. ARGUMENT Plaintiff wishes to reassess the damages in this matter to reflect the following: Judgment Amount $ 24,597.82 Post Judgment Interest $ 7,145.39 Costs $ 442.58 Payments ( 376.83) Current Balance $ 31,808.96 Pursuant to Pa. R.C.P. 3118, the Court, may, before or after the issuance of a writ of execution,enter an order granting such other relief as may be deemed necessary and appropriate. Plaintiff wishes to reassess the damages to reflect the proper judgment amount before filing a writ of execution in this matter. IV. CONCLUSION For the reasons set forth above, Plaintiff respectfully requests that this Honorable Court reassess the damages in this matter to reflect the current judgment balance against the Defendant in the amount of$31,808.96. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff VERIFICATION The undersigned, J. SCOTT WATSON,hereby certifies that he is Plaintiffs counsel in the within action and that he is authorized to make this verification on behalf of Plaintiff and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements contained herein are made subject to the penalties of 17 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. J. SCOTT WATSON, ESQUIRE J. SCOTT WATSON,P.C. BY: J. SCOTT WATSON,ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610)358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. DICK ALBERT KIRCHNER NUMBER 09-6500 CERTIFICATION OF SERVICE I do hereby certify that service of a true and correct copy of the within Motion to Reassess the Damages was made on the 17`h day of May, 2013, to the below-named by United States Mail, postage pre-paid. Dick Albert Kirchner 206 West Pine Street Mount Holly Springs, PA 17065 J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. DICK ALBERT KIRCHNER NUMBER 09-6500 RULE TO SHOW CAUSE AND NOW,this 30-day of " , 2013, Rule is hereby GRANTED upon Defendant,Dick Albert Kirchner,to show good cause if any why Plaintiffs Motion to Reassess the Damages should not be granted. RULE RETURNABLE,tki&------—41Y of BY THE COURT: J. CD 04,t --qc� =-VA > r D T1 c ) - Fil-FO-OFFIVE * J. SCOTT WATSON, P.C. 1 E� THE F ROTHONOTARY BY: J. SCOTT WATSON,ESQUIRE 2013 JUN 14 PH 2: 0 6 Identification Number 41060 24 Regency Plaza CUMBERLAND COUNTY Glen Mills, Pennsylvania 19342 PENNSYLVANIA (610) 358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. DICK ALBERT KIRCHNER NUMBER 09-6500 AFFIDAVIT OF SERVICE J. SCOTT WATSON, ESQUIRE, being duly sworn according to law, deposes and says that a time-stamped copy of Plaintiff's Motion to Reassess Damages, as well as the Rule to Show Cause dated May 30, 2013, has been served upon the following person: Dick Albert Kirchner 206 West Pine Street Mount Holly Springs, PA 17065 Via: Regular Mail on June 10, 2013 . J. SCOTT WATSON,ESQUIRE Attorney for Plaintiff LAW OFFICES J. SCOTT WATSON, P.C. 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Fax: (610) 358-9601 J.Scott Watson,Esquire Gregory J.Allard,Esquire Mary K.Jacono,Esquire June 10, 2013 Dick Albert Kirchner 206 West Pine Street Mount Holly Springs, PA 17065 Re: University of Pennsylvania v. Dick Albert Kirchner Cumberland County C.C.P.; Number 09-6500 Dear Mr. Kirchner: Enclosed please find a time-stamped copy of Plaintiff's Motion to Reassess Damages relative to the above-captioned matter. We are also enclosing a Rule to Show Cause dated May 30, 2013. The purpose of this communication is to collect a debt and any information obtained will be used for that purpose. This communication is from a debt collector. If you have any questions or comments, please do not hesitate to contact me. Thank you for your attention to this matter. Very truly yours, J. SCOTT WATSON JSW/co Enclosures J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE 13 1„9 Identification Number 41060 24 Regency Plaza Glen Mills,Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA • CUMBERLAND COUNTY • COURT OF COMMON PLEAS • v. • DICK ALBERT KIRCHNER • NUMBER 09-6500 MOTION TO MAKE RULE TO SHOW CAUSE ABSOLUTE AND NOW comes Plaintiff, University of Pennsylvania, by and through their attorney, J. Scott Watson, P.C., hereby move this Court to Reassess The Damages in this matter, and aver as follows: 1 On or about April 2, 2009, Plaintiff obtained a judgment against the Defendant in the amount of$24,597.82 in the Philadelphia County Court of Common Pleas. 2. On or about September 28, 2009, Plaintiff docketed said judgment in the Cumberland County Court of Common Pleas. 3. Pursuant to Pa. R.C.P. 3118, it is appropriate to reassess the damages in this matter to reflect the current judgment balance against the Defendant in the amount of$31,808.96. 4. Petitioner filed a Motion to Reassess Damages on or about May 20, 2013. See copy of Motion attached hereto as Exhibit"A". 5. On or about May 30, 2013, this Court issued a rule on all parties to show cause why the Motion to Reassess Damages should not be granted, returnable twenty (20) days after service which was the 19`" day of June 2013. See Exhibit `B". 6. The Petitioner caused a copy of the rule to be served upon the parties by regular mail. See correspondence dated May 30, 2013 attached hereto as Exhibit "C". WHEREFORE, Plaintiff respectfully requests this Honorable Court make the rule to show cause absolute and reassess the damages in this matter to reflect the current judgment balance against the Defendant in the amount of$31,808.96. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff VERIFICATION The undersigned, J. SCOTT WATSON,hereby certifies that he is Plaintiffs counsel in the within action and that he is authorized to make this verification on behalf of Plaintiff and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements contained herein are made subject to the penalties of 17 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. J. SCOTT WATSON,ESQUIRE J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA • CUMBERLAND COUNTY COURT OF COMMON PLEAS v. • • DICK ALBERT KIRCHNER • NUMBER 09-6500 CERTIFICATE OF SERVICE I do hereby certify that service of a true and correct copy of the within Motion to Make Rule to Show Cause Absolute was made on the 14th day of August, 2013, to the below-named by United States Mail, postage pre-paid. Dick Albert Kirchner 206 West Pine Street Mount Holly Springs, PA 17065 J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS v. DICK ALBERT KIRCHNER : NUMBER 09-6500 ORDER AND NOW, this day of ,2013, upon consideration of Plaintiff's Motion to Reassess the Damages, and any response thereto, it is hereby ORDERED and DECREED that Plaintiff's motion is GRANTED. Damages shall be reassessed to reflect the current judgment balance against the Defendant in the amount of$31,808.96.Post-Judgment Interest will continue to accrue at the rate of six percent(6%)per year pursuant to 41 P.S. §202 and 42 Pa.C.S. §8101. BY THE COURT: J. EXHOWT A J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills,Pennsylvania 19342 c CD (610)358-9600 Attorney for Plaintiff T - r- UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNT * ° ° COURT OF COMMON PI z� DICK ALBERT KIRCHNER : NUMBER 09-6500 PLAINTIFF'S MOTION TO REASSESS THE DAMAGES Plaintiff', by and through their attorneys, J. Scott Watson,P.C.,hereby requests that this Court reassess the damages in this matter, and avers as follows: 1. On or about April 2, 2009, Plaintiff obtained a judgment against the Defendant in the amount of$24,597.82 in the Philadelphia County Court of Common Pleas. 2. On or about September 28, 2009, Plaintiff docketed said judgment in the Cumberland County Court of Common Pleas. 3. Plaintiff wishes to reassess the damages in this matter to reflect the following: Judgment Amount $ 24,597.82 Post Judgment Interest $ 7,145.39 Costs $ 442.58 Payments ( 376.83) Current Balance $ 31,808.96 WHEREFORE, Plaintiff respectfully requests that this Honorable Court reassess the damages in this matter to reflect the current judgment balance against the Defendant in the amount of$31,808.96. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills,Pennsylvania 19342 (610)358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA : CUMBERLAND COUNTY . COURT OF COMMON PLEAS v. DICK ALBERT KIRCHNER NUMBER 09-6500 PLAINTIFF'S MEMORANDUM OF LAW IN SUPPORT OF MOTION TO REASSESS THE DAMAGES I. FACTS On or about April 2, 2009, Plaintiff obtained a judgment against the Defendant in the amount of$24,597.82 in the Philadelphia County Court of Common Pleas.On or about September 28, 2009, Plaintiff docketed said judgment in the Cumberland County Court of Common Pleas. Plaintiff now wishes to reassess the damages in this matter. II. ISSUE Should Plaintiff's Motion be granted? Suggested Answer: YES III. ARGUMENT Plaintiff wishes to reassess the damages in this matter to reflect the following: Judgment Amount $ 24,597.82 Post Judgment Interest • $ 7,145.39 Costs $ 442.58 Payments ( 376.83) Current Balance $ 31,808.96 Pursuant to Pa. R.C.P. 3118, the Court, may, before or after the issuance of a writ of execution, enter an order granting such other relief as may be deemed necessary and appropriate. Plaintiff wishes to reassess the damages to reflect the proper judgment amount before filing a writ of execution in this matter. IV. CONCLUSION For the reasons set forth above, Plaintiff respectfully requests that this Honorable Court reassess the damages in this matter to reflect the current judgment balance against the Defendant in the amount of$31,808.96. J. SCOTT WATSON, ESQUIRE Attorney for PIaintiff VERIFICATION The undersigned,J. SCOTT WATSON, hereby certifies that he is Plaintiffs counsel in the within action and that he is authorized to make this verification on behalf of Plaintiff and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements contained herein are made subject to the penalties of 17 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. J. SCOTT WATSON,ESQUIRE . J. SCOTT W.ATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610)358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA : CUMBERLAND COUNTY . COURT OF COMMON PLEAS v. DICK ALBERT KIRCHNER : NUMBER 09-6500 CERTIFICATION OF SERVICE I do hereby certify that service of a true and correct copy of the within Motion to Reassess the Damages was made on the 17th day of May, 2013, to the below-named by United States Mail, postage pre-paid. Dick Albert Kirchner 206 West Pine Street Mount Holly Springs, PA 17065 J.SCOTT WATSON, ESQUIRE Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA UNIVERSITY OF PENNSYLVANIA • CUMBERLAND COUNTY • COURT OF COMMON PLEAS • v. • DICK ALBERT KIRCHNER NUMBER 09-6500 RULE TO SHOW CAUSE AND NOW, this 30'day of Avg , 2013,Rule is hereby GRANTED upon Defendant,Dick Albert Kirchner, to show good cause if any why Plaintiffs Motion to Reassess the Damages should not be granted. -- A-4 2W RULE RETURNABLE,this day-o , L3. BY THE COURT: r914 J. -D 3 L.? rn I'}r rn - :3 co rn co 2J • Ca C) r--z - 'o C � _ t C I\] fir, EXHIBfF B LAW OFFICES J. SCOTT WATSON, P.C. 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610)358-9600 Fax: (610)358-9601 J.Scott Watson,Esquire Gregory J.Allard,Esquire Mary K Jacono,Esquire June 10, 2013 Prothonatary's Office Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013-3387 Re: University of Pennsylvania v. Dick Albert Kirchner Cumberland County C.C.P.; Number 09-6500 Dear Sir or Madam: Enclosed please find an original and one (1)copy of an Affidavit of Service relative to the above-captioned matter. Kindly file the original of record with the Court and return a time- stamped copy of same to our attention in the stamped, self-addressed envelope provided. If you have any questions or comments,please do not hesitate to contact me. Thank you for your attention to this matter. Very truly yours, J. SCOTT WATSON JSW/co Enclosures J. SCOTT WATSON,P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24-Regency PIaza Glen Mills,Pennsylvania 19342 (610)358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA : CUMBERLAND COUNTY • COURT OF COMMON PLEAS • v. DICK ALBERT KIRCHNER : NUMBER 09-6500 AFFIDAVIT OF SERVICE J. SCOTT WATSON, ESQUIRE, being duly sworn according to law, deposes and says that a time-stamped copy of Plaintiff's Motion to Reassess Damages, as well as the Rule to Show Cause dated May 30, 2013,has been served upon the following person: Dick Albert Kirchner 206 West Pine Street n CZ+ C 6 Mount Holly Springs, PA 17065 - � w --+ _ rnaD c.. x'71 to r' c Via: Regular Mail on June 10, 2013 . Cra x-n; (--) o-r, v '^ D c Fv °)1r; z n > J.SCOTT WATSON,ESQUIRE-< I Attorney for Plaintiff • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. DICK ALBERT KIRCHNER NUMBER 09-6500 ORDER AND NOW,this day of #441"w 2013, upon consideration of Plaintiff's Motion to Make Rule Absolute, and any response thereto, it is hereby ORDERED and DECREED that the rule issued on May 30, 2013,to show cause, is made absolute. Damages shall be reassessed to reflect the current judgment balance against the Defendant in the amount of $31,808.96. Post-Judgment Interest will continue to accrue at the rate of six percent(6%)per year pursuant to 41 P.S. §202 and 42 Pa.C.S. §8101 BY THE COURT: J. ZZ, C= -<> C:)-n ac-1 7b. 4 1,441 ty J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON,ESQUIRE ';' j .' 'r r Identification Number 41060 24 Regency Plaza `JM D E �L""N) C 0 UN T'( Glen Mills, Pennsylvania 19342 ` �'�$Y i VAN 1 A (610)358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. DICK ALBERT KIRCHNER NUMBER 09-6500 PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment in the above-captioned matter in favor of Plaintiff, University of Pennsylvania, and against Defendant, Dick Albert Kirchner, in the amount of$31,808.96 pursuant to the attached Court Order dated August 28, 2013. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff Our ��( low c?00 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. DICK ALBERT KIRCHNER NUMBER 09-6500 ORDER o�L AND NOW,this %day of R4Gtrt- ,2013,upon consideration of Plaintiffs Motion to Make Rule Absolute,and any response thereto, it is hereby ORDERED and DECREED that the rule issued on May 30,2013,to show cause,is made absolute. Damages shall be reassessed to reflect the current judgment balance against the Defendant in the amount of $31,808.96. Post-Judgment Interest will continue to accrue at the rate of six percent(6%)per year pursuant to 41 P.S. §202 and 42 Pa.C.S. §8101 BY THE COURT: . J. C') C -r zrn rnr r ';UV -NCD Q �o � ao 20 in �C Hrm J. SCOTT WATSON,P.C. BY: J. SCOTT WATSON,ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills,Pennsylvania 19342 (610)358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. DICK ALBERT KIRCHNER NUMBER 09-6500 CERTIFICATION OF SERVICE I do hereby certify that service of a true and correct copy of the within Praecipe to Enter Judgment was made on the 15'day of November, 2013,to the below-named by United States Mail,postage pre-paid. Dick Albert Kirchner 206 West Pine Street Mount Holly Springs, PA 17065-1122 J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY TO: Dick Albert Kirchner 206 West Pine Street Mount Holly Springs, PA 17065-1122 UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. DICK ALBERT KIRCHNER NUMBER 09-6500 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. PROTHONOTARY JUDGMENT BY DEFAULT X MONEY JUDGMENT JUDGMENT IN REPLEVIN JUDGMENT FOR POSSESSION If you have any questions concerning this Judgment, please call J. Scott Watson, Esquire at 610-358-9600 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION ; University of Pennsylvania : ( )Confessed Judgment . 3451 Walnut Street : (X)Other Philadelphia,PA 19104 f, VS. : File No. 09-6500 Dick Albert Kirchner : Amount Due $31,808.96 _77117 C:D 206 W. Pine Street : Interest ` Mount Holly Springs, PA 17065 : Atty's Comm Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract,or account based on a confession of judgment,but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue Writ of execution in the above matter to the Sheriff of Cumberland , County, for debt, interest and costs,upon the following described property of the defendant(s) All contents of Defendant's residence including but not limited to all furniture,clothing,jewelry, electronic equipment, electrical appliances, kitchen utensils, silverware,televisions,tools, and any other propeM which may be subject to levy. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above,directing attachment against the above-named garnishee(s) for the following property(if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s). ( )(indicate)Index the writ against the garnishee(s)as a lis pendens against real estate of the defendant(s)described in the attached exhibit. Date / /3 Signature: ......__....._.> -.... _.. Print Name: J. Scott Watson, Esquire Address: 24 Regency Plaza �� �p C� Glen Mills, PA 19342 Attorney for: Plaintiff •lJ� Telephone: 610-359-9600 Supreme Ct ID 041060 ov Ike. s Og � �a o 0' U� WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-6500 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIVERSITY OF PENNSYLVANIA Plaintiff(s) From DIRK ALBERT KIRCHNER,206 W.PINE STREET,MOUNT HOLLY SPRINGS,PA 17065 (1) You are directed to levy upon the property of the defendant(s)and to sell ALL CONTENTS OF DEFENDANT'S RESIDENCE INCLUDING BUT NOT LIMITED TO ALL FURNITURE, CLOTHING,JEWELRY, ELECTRONIC EQUIPMENT,ELECTRICAL APPLIANCES, KITCHEN UTENSILS,SILVERWARE,TELEVISIONS,TOOLS,AND ANY OTHER PROPERTY WHICH MAY BE SUBJECT TO LEVY. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of 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$31,808.96 Plaintiff Paid$ Interest Attorney's Comm. % Law Library$ Attorney Paid$214.08 Due Prothonotary$2.25 Other Costs$ Date: 11/25/13 i(7 ):Bue David D. Buell, Prothonotary By: t"A. Deputy REQUESTING PARTY: Name : J. SCOTT WATSON,ESQUIRE Address: 24 REGENCY PLAZA GLEN MILLS,PA 19342 Attorney for: PLAINTIFF Telephone: 610-359-9600 Supreme Court ID No. 041060 SHERIFF'S OFFICE OF CI;MBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith 'Wtr 0i comb,", f i Chief Deputy t f V Oj Richard W Stewart Solicitor a, � RR;F University of Pennsylvania vs. Case Number Dick Albert Kirchner 2009-6500 SHERIFF'S RETURN OF SERVICE 12/09/2013 01:41 PM - Brian Grzyboski, Deputy , being duly sworn according to law, states that on December 09, 2013 at 1:41 PM hours, served the requested Writ of Execution and Claim for Exemption Form by "personally"handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Dick Albert Kirchner at 206 W Pine Street, South Middleton Township, Mt Holly Springs, PA 17065, informed Defendant of contents of same and levied upon personal property as directed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on December 10, 2013. 01/15/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiff's attorney. SHERIFF COST: $70.46 SO ANSWERS, January 15, 2014 4RONANDERSON, SHERIFF c*4 m4 t J. SCOTT WATSON,P.C. THE f'/ rj 11—;°p �"5` r BY: J. SCOTT WATSON,ESQUIRE 28/4 1AR Identification Number 41060 JAN 31 24 Regency Plaza CUiistiitq Pk/ -1.s 54 Glen Mills,Pennsylvania 19342 PENNs iO COON. (610) 358-9600 Attorney for Mbliff UNIVERSITY OF PENNSYLVANIA : CUMBERLAND COUNTY . COURT OF COMMON PLEAS v. • DICK ALBERT KIRCHNER : NUMBER 09-6500 Civil Term ORDER TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the Money Judgment in the above matter as satisfied upon payment of your costs only. J. SCOTT WATSON,ESQUIRE Attorney for Plaintiff