The URL can be used to link to this page

Home My WebLink About01-1402IN THE COURT OF COMMON PLEAS OF MONTGOMERY COUNTY, PENNSYLVANIA CIVIL DIVISION J.G. WENTWORTH S.S.C. LIMITED PARTNERSHIP Plaintiff VS. MATTHEW LUKOSAVICH Defendant(s) NO. 01-847 WRIT OF EXECUTION COMMONWEALTH OF PENNSYLVANIA, COUNTY OF MONTGOMERY TO THE SHERIFF OF CUMBERLAND COUNTY, PA To satisfy the judgment, interest and costs against MATTHEW LUKOSAVICH, Defendant(s); (1) You are directed to levy upon the property of the defendant(s) and to sell his, her (or their) interest therein: (2) You are also directed to attach the property of the defendant not levied upon in the possession of CGU LIFE INSURANCE COMPANY OF AMERICA F/Ir, UA COMMERCIAL UNION LIFE INSURANCE COMPANY OF AMERICA as Garnishee(s) per property description attached: and to notify the Garnishee(s) that (a) an attachrnem has been issued; (b) the garnishee(s) is enjoined from paying any debt or for the account of the defendant(s) or otherwise disposing thereof. (3) If the property of the defendant not levied upon and subject to attachment is found in the possession of anyone other than the named garnishee(s), you are directed to notify him that he has been added as a garnishee and is enjoined as above stated. COSTS: Prothonotary: Sheriff: (SEAL) Amount due: $1167850~00 Interest from: $23.42 TOTAL: $116,873.42 Plus co~ts as per endorsement hereon. ...I,,,IIIJ3HS StH.L JO ~,')l:J.',lO IN THE COURT OF COMMON PLEAS OF MONTGOMERY COUNTY, PENNSYLVANIA J.G. WENTWORTH S.S.C. LIMITED PARTNERSHIP CIVIL ACTION - LAW vs. NO. 01-847 MATTHEW LUKOSAVICH PRAECIPE FOR WRIT OF EXECUTION UPON A CONFESSED JUDGMENT To the Prothonotary: Issue a writ of execution upon ajudgment entered by confession in the above matter, (1) directed to the Sheriff of Cumberland County; (2) against Matthew Lukosavich, defendant; (3) against CGU LIFE iNSURANCE COMPANY OF AMERICA F/K/A COMMERCIAL [iNION LIFE iNSURANCE COMPANY OF AMERICA, garnishee; (4) mad index this writ (a) against Matthew Lukosavich, defendant (b) against CGU LIFE INSURANCE COMPANY OF AMERICA F/K/A COMMERCIAL UNION LIFE INSURANCE COMPANY OF AMERICA, garnishee, as a lis pendens against real property of the defendant in name of garnishee as follows: (See attached) (Spec.ifically describe property) (5) Amount due $116,850.00 Interest from $ 23.42 Attorneys' fees** $ 0.00 [~osts to be added] $116,873.42 **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. CERTIFICATION I certify that: (a) This praecipe is based upon ajudgment entered by confession, and Notice has been served pursuant to Rule 2958.1 at least thirty days prior to the filing of this praecipe as evidenced by a return of service filed of record. (e-) Notice will be served at least thirty days prior to the date of the sherif£s sale of real property pursuant to Rule 2958.2. (d) Notice will be served with the writ of execution pursuant to Rule 2958.3. Notice was served in connection with a prior execution on this judgment and pursuant to Rule 2958.4(b), no further notice is required. (-t:) Notice is not required under Rule 2956. l(c) b.ecg~ise a petition to/bpen or strike the judgment was previously filed. · '~ ~ i ,Richard M. Co ~n~elly ...... G¢~f~i for J:G. Wentworth 30 South 15th St. 10th FL Philadelphia, PA 'I'9102 (215) 567-7660 RICHARD M CONNELLY, ESQUIRE Attorney ID No. 32837 1 Penn Square West, 30 South 15th Street, l0th Floor Philadelphia, PA 19102 (215) 567-7660 J.G. WENTWORTH S.S.C. LIMITED PARTNERSHIP 222 Delaware Avenue, Suite 1449 Wilmington, DE 19801 Plaintiff, V. MATTHEW LUKOSAVICH 751 N. Salina Street Syracuse, NY 13208 Defendant. CGU LIFE INSURANCE COMPANY OF AMERICA F/K/A COMMERCIAL UNION: LIFE INSURANCE COMPANY OF : AMERICA : 5010 Ritter Road : Mechanicsburg, PA 17055~4828 Gamishee. MONTGOMERY COUNTY COURT OF COMMON PLEAS CIVIL ACTION - LAW NO. 01-847 TO: INTERROGATORIES IN ATTACHMENT CGU LIFE INSURANCE COMPANY OF AMERICA F/K/A COMMERCIAL UNION LIFE INSURANCE COMPANY OF AMERICA 5010 Ritter Road Mechanicsburg, PA 17055-4828 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. DEFINITIONS AND INSTRUCTIONS Unless negated by the context of the Interrogatory, the following definitions are to be considered to be applicable to all Interrogatories contained herein: (A) "Document(s)" is an all inclusive term referring to any writing and/or recorded or graphic matter, however produced or reproduced. The term document(s) includes without limitation, correspondence, memoranda, interoffice communications, minutes, reports, notes, schedules, analysis, books of account, ledgers, invoices, pleadings, questionnaires, contracts, bills, checks, diaries, logs, recordings, telegrams, letters, and all other such documents, tangible or retrievable ofm~y kind. Documents also include any preliminary notes and drafts of all the foregoing, in whatever form, for example: printed, typed, longhand, shorthand, on paper, paper tape, tabulating cards, ribbon blueprints, magnetic tape, microfilm, film, photographic records, or other form. (B) and addressee; identify with respect to documents further means: (i) To describe a document sufficiently well enough to enable the interrogator to know what such document is and to retrieve it from a file or wherever it may be located; (ii) To-~describe irwin a manner suitable ~br use as a description in a subpoena; (iii) To give the name, address, position or title of the person(s) who has custody of the document and/or copies thereof. With respect to documents, the term "identify" means to give the date, title, author (C) "Identify" when used in reference to an individual means: (il) To state his/her full name: (ii) Present residence address or last known residence; (i/i) Present or last known business address; (iv) Present employer or last known employer; (v) Whether ever employed by any party to this action and, if so, the dates he (she) was employed by such party, the name of such party and the last position held as an employee of such party. (D) "Describe" when used in connection with, or with respect to, an agreement or event, means to state the place and time thereof, to identify all documents relating or referring thereto, to identify all persons present or having knowledge thereof, to state the subject matter and substance of the agreement or event, and to state the acts by each person who participated in any way. (E) "Person" when used as a term herein shall mean any natural person, firm, association, partnership, corporation or other form of legal entity or governmental body, unless the context of the question indicates otherwise. (F) "You" and "Your" apply and refer to the responding party or the person or persons who is/are responding on behalf of the responding party, and encompasses each and every person employed or working under the supervision, direction, or control of the responding party, to attorneys and agents, and to all other persons acting or purporting to act with actual or apparent authority on behalf of the party to whom these Interrogatories are addressed. (G) "Defendant", "He" and "Him" or "She" and "Her" apply and refer to the Defendant, Matthew Lukosavich. (H) "Occurrence" shall mean the precipitating event, incident, act or manner of defendant(s) actions, defendant(s) conduct and/or the series or combined events, incidents, acts Who is the owner of said annuity policy? Please provide the address of the owner. 5. Has the owner, to date, instructed the provider to make payment to any party other than the defendant? YES or NO If yes, please state who. A. Have any payments been made under the annuity policy #9254448 party other than the defendant? YES or NO If yes, please state who. 6. Is the schedule of payments in exhibit A consistent with the stream of payments to be paid to the defendant? YES or NO If no, please set forth the correct stream of payment. February 7, 2001 RICH3RD M. CONNEL~¥ ESQ. /BY' t ...... [_..R_!s~ ~a~3Conne lly, Esquire General Counsel for J.G. Wentworth UC-7~28 REV, ~ IN THE COURT OF COMMON PLEAS OF C~V[BERLA~D COUN'rY, PENNSYLVANIA CERTIFIED COPY OF LIEN TO THE PROTHONOTARY OF SAID COURT: Pursuant to Section 308.1 of the Pennsylvania Unemployment Compensation Law, 43 P.S. § 788.1, this is a Certified Copy of Lien for unpaid unemployment compensation contributions, interest and penalties to be entered of record by you and indexed as judgments are indexed. COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF LABOR AND INDUSTRY TO THE USE OF THE UNEMPLOYMENT COMPENSATION FUND VS. ~ohn M. Lucidon Sr. Individually & T/A Paradise Landscaping & Construction 1910 Spring Road · Carlisle, PA 17013 PENNSYLVANIA EMPLOYER ACCOUNT NUMBER: 21-19795-5 AD Number: QTR/YR, DUE CONTRIBUTION INTEREST ~3UE ON UNPAID PENALTY olJ PAID/CREDIT BALANCE CONTRtBUTION pAI~3 LATE.DISHONORED ' 4/99AS 266.22 266.22 25.51 26.6 1/00AS 271,15 271.15 20.56 27.1 2/00AS 108.46 108.46 6.06 25.0 sub-total 645.83 52.13 78.' Additional interest is to be computed on the above balance of unpaid unemployment oompeneation oontribution$ at the rate determined by the Seoretary of Revenue under Section 806 of the Fisoal Code, 72 P.S. § 806, per month, or fraction of a month, from 3/31/01 Additional Interest R. SCOT MIEDRICH Aealstlnt Director, ~ureau of Employsr Tex Qper~tlona TO BE RETAINED BY RECORDING OFFICE 3/2/01 DATE Z I- Z m~ ~Z ~ mz Z~ ~ ~Z 0. w ~ ~ ~ o uO ~ m 0~ ~w--=~ O--Z ,,,~ ~> ~ ~ =Z ~ 0 ~ IN THE COURT OF COMMON PLEAS OF MONTGOMERY COUNTY. PENNSYLVANIA CIVIL DIVISION J.G. WENTWORTH S.S.C. LIMITED PARTNERSHIP Plaintiff VS. MATTHEW LUKOSAVICH Defendant(s) NO. 01-847 WRIT OF EXECUTION COMMONWEALTH OF PENNSYLVANIA, COUNTY OF MONTGOMERY TO THE SHERIFF OF CUMBERLAND COUNTY, PA To satisfy the judgment, interest and costs against MATTHEW LUKOSAVICH, Defendant(s); (1) You are directed to levy upon the property of the defendant(s) and to sell his, her (or their) interest therein: (2) You are also directed to attach the property of the defendant not levied upon in the possession of CGU LIFE INSURANCE COMPANY OF AMERICA F/K/A COMMERCIAL UNION LIFE iNSURANCE COMPANY OF AMERICA as Garnishee(s) per property description attached: and to notify the Garnishee(s) that (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt or for the accoUnt of the defendant(s) or otherwise disposing thereof. (3) If the property of the defendant not levied upon and subject to attachment is found in the possession of anyone other than the named garnishee(s), you are directed to notify him that he has been added as a gm-nikhee and is bnjdined as above stated. COSTS: Prothonotaw: Sheriff: (SEAL) Amount due: $116}850.00 Interest from: $23.42 TOTAL: $116,873.42 Plus coCs as per endorsement hereon. ,, ,¢ ,,// :.. WILLIAM E. DO~ELLY Pro~onotaw ~&~ ~'~'~ R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing 18.00 Poundage 1.72 Advertising Law Library Prothonotary I~, 50 Mileage 8.68 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee 9.00 8~.90 Advance Costs: 150.00 Sheriff's Costs: 82 · 90 [~,. lO Refunded to Atty on 7/15/02 Sworn and Subscribed to before me this' ' dayof 2002 A.D. proth~ta~y So Answers; R. Thomas Kline, Sheriff