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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 c--) rn 0:1 —off V) Es () y� 7 —"3 CD —rte N 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- °C37 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. ---( GREAT SENECA FINANCIAL CORP., : -0 C— A MARYLAND CORPORATION;. xm c•-_-_ r— r- ---0 rn ...th 1— ----,; r--1 ASSIGNEE OF FORWARD c) -<?''' PROPERTIES; ASSIGNEE OF DIRECT : < --1:3 MERCHANTS BANK, 3:- c) a: z •-: = c) c) ( • Plaintiff : No. 2004-3623 CIVIL TERM -- -.• r? ---i rN) - -<‹ -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..) ac i€ sry c� C.P.J.1 r co = rn Z CD S> 9