HomeMy WebLinkAbout04-3623 ", ' COI~IMONWEA4-TH'~)~'PENNSYLVAN A
COUNTY OF: ~'OHBERLAND.~¢ .. NOTICE OF JODGIdENT/TRANSCRIP I
CIVIL CASE
Ua~ D,~I No PLAINTIFF:
09-3- 0'4 ~T ~
~,J~,~ ~o, 267 ~ST ~T ST.
~O~S A. P~ C/O WOFLSON & ASS~. P.C.
~u,~,~ 104 S. S~RTING HILL ~. ~ORK, PA ~7403
~ICSB~G, PA ~ . I
VS.
DEFENDANT:
T.~n. J17) 761-8230 17050 FGLI~TSIS, LITSA, ~T ~. - I
915 A~I
~ICSB~, PA 17050
G~T S~ ~ ~p AS~ ~R~S L _1
267 ~ST ~ ST. 0ocketNo.: ~-0000045-04~
C/O WOFL8~ & ASS~. P.C. Date Filed: 1/26/04
YO~K, PA 17403
THIS IS TO NOTIFY YOUTHAT:
--' .............. 4~at: ....... -- ................ D~ ..,.~.. ~.m~ ........
~ Judgment was entered for: (Name) ~a~ ~a ~. ~D a~
~ Judgment was entered against: (Name) ~T.T~T~
in the amount of $ 4:~4 _ ~ on: (Date of Judgment)
~ Defendants are jointly and severally liabl~:~, ~.,~ ~ .- ; .(Date & Time)
~. .. .~ .~,.....'.~ ·
~ Damages will be assessed on: ;:~' ~.[ ~ ~' ','~'
~ ' ' ~ Am
~ r~=?'..:~" ] ount of Judgment $ 4.536.0{
~[.;];.; .]Judgment Costs $ 118.0
~ This case dismissed without prejudice. ~ ~;'..~ Interest on Judgment $ .0
~ i[~.'~A.orney Fees $ .0
~ ~,~,:Total $ 4 654.0
~ Amount of Judgment Subject to ~
' ~ A~achmenF42 Pa.C.S. { 8127 $ ~~ ~ ~?~.~Post Judgment Credits $_
~ Potion of Judgment for physical ~ ~ ~ '''~
~:~[~..: ~ Post Judgment Costs $
~ damages arising out of residential ~ ============
lease $ ~ ' '" "' '" '; Ce~lfied Judgment Total
... ANY PARTY HAS TH~T TO ~AL WITHIN 30 DAYS A~ER THE ENTRY OF JUDGMENT BY FILING. A NOTICE
' ' ~' ~'~L ~'~'~ PROT~AR ~}~'~R~"OF T~ ~ ~U ~ ~ c0~MON'PLEA~, C~L 'DiViSiON. YOU
-- MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT~RANSCRI~ FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER
ELECTS TO E~ER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCE~ MAY BE ISSUED BY THE DISTRICT JUSTICE,
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGME~ MAY FILE
A REQUEST FOR E~RY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SE~LES,
OR OTHERWISE COMPLIES WITH THE JUDGME~.
4' ~ ~ I 04 Date
___,_, District Justice
~hat this is a true; correct containing the judgment. ].,
My commission expires first Monday of January. 2010 . SEAL'
AOPC 315-o3
DATR PRINTED: 4/05/04 10:39:48 AM
. '~COMMONWEALTH' 01~ PENNSYLVANIA ~ "': "
COUNTY OF:~UI'IBZRI.~,.ND ~ NOTICE OF JUDGMENT/TRANSCRIP'i-
""' °'" CIVIL CASE
09 - 3 - O~ · PLAINTIFF:
· HO~8 A. p~ B
~'~'~ 104 8. SPOR~ZNG HZ~ ~. C/O ~F~O~ & ASBOC. P.C.
~ZCSB~G, PA ~ORK, PA ~7403
DEFENDANT: VS.
~,~o,. (717) 761-8230 17050 ~GLZ~TSZs, LZTSA, ~
915 A~Z RO~
~ZCSB~G, PA 17050
267 ~ST ~T
YORR, PA ~7403 ~Date ~[e~: ~/26/04
T~S IS TO NOTIFY YOU THAT: GLZ~TSIs, p~
· ' ....... '-' .Jueg~ ......... , ........ Dg~
............ : .=.:. ..... =. ~T.~R~ .~/O.
~ Judgment was entered for: (Name)
~ Judgment was entered against: (Name).
i~ the amount of $ on: (Date of Judgment)
~ Defendants are jointly and severally liable.
(Date & Time)
~ Damages will be assessed on:
Amount of Judgment $
Judgment Costs $ .
~This case dismissed without prejudice. Interest on Judgment $ .
Attorney Fees $ .
Amount of Judgment Subject to Total $ .
~ AEachmenF42 Pa.C.S. ~ 8127 $
Post Judgment Credits $
~ Potion of Judgment for physical Post Judgment Costs
' ' damages arising out of residential
lease $ ============
Ce~ified Judgment Total $
ANY PA~TY HAS THE ;l~T TO A~PEA~~ W~TH N 30 ~AYS A~E; THE ENT '
OF APPEAL WiTH THE PnOTHONO~y~6['E;~ ~ ~'= ~-..-=-: ' '" ~? JUDGMFNTBY F;LINa A NOTICE
MUST INCLUDE A COPy OF TH S NnT ~= ~= ~',~', .... UU~ UF COMMON PLEAS, CIVIL DIVISION. YOU '
......... ~u~MENT~RANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER
ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PR~ESS MUST COME FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCE~ MAY BE ISSUED BY THE DISTRICT JUSTICE.
UNLESS THE JUDGMENT 18 ENTERED IN THE COURT OF COMMON PLEAS. ANYONE I~ERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SE~LES,
OR OTHERWISE COMPLIES WITH THE JUDGME~.
'~~ District Justice
j ......... ~x ~, ,,~ ,~uro o~ me p~ceedi~gs containing the ~
Date ~_ ~_, District Justice
My commission expires first M '
onday of January. 2010 .
AOPC 3~5-o3 SEAL
D~ ~Z~= 4/05/04 10:~0=59 ~..
hereby certify that the precise residence of Plaintiff
GHEAT SENECA F~NANCTAL
A MARYLAND CONPORAT=ON.
Bruce N. Cherkis ~18837
COMMONWEALTH OF PENNSYLVANIA Philip C. Warholic #86341
=[ Not~mlSeal [ wonPo~s ~ ~s~.so~. ~.n.P.
J DinnA. SweJl~Notnry Publ~ [ A~torneys in the Practice o~ Deb~ Collection
| Ci~M'Yor~YoA~oue~ ~e~ 267 East Markec Street
] My Commissi~ Expires A~. so, ~uuo ] Y o r k, P A 1 7 0 4 3
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., :
A MARYLAND CORPORATION;
ASSIGNEE OF FORWARD
PROPERTIES; ASSIGNEE OF DIRECT :
MERCHANTS BANK,
Plaintiff : No. 2004-3623 CIVIL TERM
VS.
LITSA GLINATSIS,
Defendant
: CIVIL ACTION
PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWER0b.
INTERROGATORIES IN AID OF EXECUTION r\.)
And now comes Plaintiff and submits the instant Motion to Compel, and in support
thereof avers as follows:
1. Judgment for Plaintiff and against Defendant in the sum of $4,654.00 plus costs was
entered in Cumberland County on July 26, 2004.
2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class
mail on October 22, 2013.
3. Pursuant to Pa.R.C.P. 4006 (a) (2), Defendant's responses to the Interrogatories were
due within thirty days after they had been served, but none has been received as of the date of
giving notice herein.
4. Counsel for Plaintiff has made a good faith effort to confer with Defendant, but
Defendant has still failed to reply.
5. A copy of this Motion and proposed Order were mailed to Defendant, via first class
mail on November 26, 2013. A certificate of Service is attached hereto as Exhibit "A".
6. As of March 12, 2014, Plaintiff has not received answers to the Interrogatories.
7. Plaintiff requires an Order pursuant to Pa.R.C.P. 4019 (a) (1) (I), compelling the
Defendants to answer the Interrogatories.
8. No Judge has ruled upon other issues in this matter.
9. Concurrence with the Pro Se Defendant has been sought and denied.
WHEREFORE, Plaintiff, requests that this Honorable Court grant its motion and
enter an Order directing the Defendant to answer Plaintiff's Interrogatories within twenty (20)
days or risk sanctions, pay fees in the amount of $100.00, as well as such other and further relief
as the Court may deem just and appropriate.
an R. Mege, Esq.
Attorney ID No. 81 88
Attorney for Plai iffs
P.O. Box 1426
Bethlehem, PA 180
(610) 954-5393
6-1426
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., :
A MARYLAND CORPORATION;
ASSIGNEE OF FORWARD
PROPERTIES; ASSIGNEE OF DIRECT :
MERCHANTS BANK,
Plaintiff : No. 2004-3623 CIVIL TERM
VS.
: CIVIL ACTION
LITSA GLINATSIS,
Defendant
CERTIFICATE OF SERVICE
I, Alan R. Mege, Esquire, hereby certify that on November 26, 2013, I served a
true correct copy of Plaintiffs Motion to Compel Defendant's Answers to Interrogatories in Aid
of Execution and proposed Order by mailing same, first class, postage prepaid to: Litsa
Glinatsis, 915 Acri Road, Mechanicsburg, PA 17050.
By:
. ege, Esquire
Atty. I.D. #81288
Attorney for Plaintif
P.O. Box 1426
70 East Broad St.
Bethlehem, PA 18016-1426
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., :
A MARYLAND CORPORATION;
ASSIGNEE OF FORWARD
PROPERTIES; ASSIGNEE OF DIRECT :
MERCHANTS BANK,
Plaintiff : No. 2004 -3623 CIVIL TERM
VS.
LITSA GLINATSIS,
Defendant
: CIVIL ACTION
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PRAECIPE FOR ENTRY OF APPEARANCE
TO THE CLERK OF SAID COURT:
Kindly enter my appearance on behalf of the Plaintiff in the above captioned matter.
Date:
/ /7/
By:
n R. Mege, Esquir
Atty. I.D. #81288
Attorney for Plain iff
P.O. Box 1426
Bethlehem, PA 18016
(610) 954 -5393
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., :
A MARYLAND CORPORATION;
ASSIGNEE OF FORWARD •
PROPERTIES; ASSIGNEE OF DIRECT :
MERCHANTS BANK,
Plaintiff : No. 2004-3623 CIVIL TERM
vs. •
: CIVIL ACTION
LITSA GLINATSIS,
Defendant •
IN RE: PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO
INTERROGATORIES IN AID OF EXECUTION
// ORDER
AND NOW, this p�/C 7`'day of / a , 2014, upon consideration of
Plaintiff's Motion to Compel, a RULE is issued upon Defendant to show cause why an order
compelling Defendant to respond to the Interrogatories in Aid of Execution should not be issued.
PLAINTIFF shall effectuate service of this Order upon Defendant. A motion to make
this Rule absolute will not be entertained until proof of service is filed.
RULE RETURNABLE twenty (20) days from the date of service by Plaintiff.
E COU ,
J
Di ibution:
Al R. Mege r7i u-?
itsa Glinatsis -- '
na
es traiLitt_ t-
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., :
A MARYLAND CORPORATION; : (.-)
ASSIGNEE OF FORWARD
--..
PROPERTIES; ASSIGNEE OF DIRECT :
MERCHANTS BANK,
Plaintiff : No. 2004-3623 CIVIL TERM
VS.
: CIVIL ACTION
LITSA GLINATSIS,
1-4)
..c""
Defendant
CERTIFICATE OF SERVICE
I, Alan R. Mege, Esquire, hereby certify that on March 31, 2014, I served a true
correct copy of the Court's March 27, 2014, Order by mailing same, first class, postage prepaid
to: Litsa Glinatsis, 915 Acri Road, Mechanicsburg, PA 17050.
By:
n R. Mege, Esqu
Atty. I.D. #81288
Attorney for Plain
P.O. Box 1426
70 East Broad St.
Bethlehem, PA 18016-1426
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANI
c--) -n.
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GREAT SENECA FINANCIAL CORP., : -0
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A MARYLAND CORPORATION;.
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ASSIGNEE OF FORWARD c)
-<?'''
PROPERTIES; ASSIGNEE OF DIRECT :
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MERCHANTS BANK, 3:- c) a: z •-:
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Plaintiff : No. 2004-3623 CIVIL TERM -- -.• r?
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-
-<‹ -I
vs.
: CIVIL ACTION
LITSA GLINATSIS,
Defendant
PLAINTIFF'S MOTION TO MAKE THE RULE ABSOLUTE
And now comes Plaintiff and submits the instant Motion to Make The Rule Absolute, and
in support thereof avers as follows:
1. On March 27, 2014, a Rule was issued upon the Defendant, Litsa Glinatsis, to show
cause why Plaintiff's Motion to Compel should not be granted. A copy of the Order is attach
hereto as Exhibit "A".
2. The March 27, 2014, Rule was served upon Defendant on March 31, 2014.
3.. The Rule Returnable was to be answered by April 20, 2014 in the Office of the
Cumberland County Prothonotary. As of July 17, 2014, no answer has been filed.
4. A copy of this Motion and proposed Order were mailed to Defendant, via first class
mail on July 17, 2014. A certificate of Service is attached hereto.
5. Plaintiff requests that the Rule be made Absolute.
WHEREFORE, Plaintiff, requests that this Honorable Court grant its motion and
enter an Order directing the Defendants to answer Plaintiff's Interrogatories within twenty (20)
days or risk sanctions, pay fees in the amount of $250.00, as well as such other and further relief
as the Court may deem just and appropriate.
Alan R. Mege, Es
Attorney ID No. 81288
Attorney for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., :
A MARYLAND CORPORATION;
ASSIGNEE OF FORWARD
PROPERTIES; ASSIGNEE OF DIRECT :
MERCHANTS BANK,
Plaintiff : No. 2004-3623 CIVIL TERM
vs.
LITSA GLINATSIS,
Defendant
: CIVIL ACTION
.L
.:1
r•)
IN RE: PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO
INTERROGATORIES IN AID OF EXECUTION
ORDER
AND NOW, this a2/•day of ri , 2014, upon consideration of
Plaintiff's Motion to Compel, a RULE is issued upon Defendant to show cause why an order
compelling Defendant to respond to the Interrogatories in Aid of Execution should not be issued.
PLAIN'T'IFF shall effectuate service of this Order upon Defendant. A motion to make
this Rule absolute will not be entertained until proof of service is filed.
RULE RETURNABLE twenty (20) days from the date of service by Plaintiff
13Y THE COURT,
Distribution:
Alan R. Mege
Litsa Glinatsis
ocov
2014
Law Officts of flan Ideg
rJ COPy
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., :
A MARYLAND CORPORATION;
ASSIGNEE OF FORWARD
PROPERTIES; ASSIGNEE OF DIRECT :
MERCHANTS BANK,
Plaintiff : No. 2004-3623 CIVIL TERM
vs.
LITSA GLINATSIS,
Defendant
: CIVIL ACTION
CERTIFICATE OF SERVICE
I, Alan R. Mege, Esquire, hereby certify that on July 17, 2014, I served Plaintiff's Motion to
Make the Rule Absolute mailing same, first class, post prepaid to: Litsa Glinatsis, 915 Acri Road,
Mechanicsburg, PA 17050.
By:
Mege, Esquire
Atty. LD. #81288
Attorney for Plaintiff
P.O. Box 1426
Bethlehem, PA 18016
(610) 954-5393
GREAT SENECA FINANCIAL CORP. A
MARYLAND CORPORATION;
ASSIGNEE OF FORWARD
PROPERTIES; ASSIGNEE OF DIRECT
MERCHANTS BANK
Plaintiff
v.
LITSA GLINATSIS,
Defendant
Countp of Oturnbertapb
IN THE COURT OF COMMON PLEAS
OF THE NINTH JUDICIAL DISTRICT
2004-03623 CIVIL TERM
IN RE: PLAINTIFF'S MOTION TO MAKE RULE ABSOLUTE
ORDER OF COURT
day of July 2014, upon consideration of Plaintiff's Motion to
AND NOW, this
Make Rule Absolute, it is hereby ORDERED that the Rule issued on 27 March 2014 is
hereby made absolute and Plaintiff's Motion is GRANTED.
It is further ORDERED that Defendant must make full and complete answers to
the interrogatories, without objection or motion for protective order, within twenty (20)
days of service of this Order or appropriate sanctions and attorneys' fees may be
imposed upon Defendant following application to this Court.
PLAINTIFF shall effectuate service of this Order upon Defendant.
BY THE COURT
Thomas A. ' acey
pi.sfribution:
G�P,1a�R. Mege, Esq.
itsa Glinatsis Loc..)
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