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Home My WebLink About11-4168BINGAMAN, HESS, COBLENTZ & BELL, P.C. By: Mark G. Yoder, Esquire Attorney Identification No. 32493 Treeview Corporate Center Attorneys for Plaintiff 2 Meridian Boulevard, Suite 100 Wyomissing, PA 19610 (610) 374-8377 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA UTILITIES EMPLOYEES CREDIT UNION successor by assignment from Land Akkquisitions, LLC f/k/a James Delaplaine Family, LLC, Plaintiff vs. RICHARD J. SNYDER, t/a Snyder Developers, CAROLE B. SNYDER and RICHARD J. SNYDER AND CAROLE B. SNYDER LIMITED PARTNERSHIP t/a R&C Developers Defendants NO. //- CfJll? e'lp/ :CIVIL ACTION -LAW' C - : g. l?-j ms PRAECIPE TO TRANSFER JUDGMENT IN FAVOR OF PLAINTIFF AND AGAINST DEFENDANTS, RICHARD J. SNYDER, T/A SNYDER DEVELOPERS, CAROLE B. SNYDER, AND RICHARD J. SNYDER AND CAROLE B. SNYDER LIMITED PARTNERSHIP T/A R&C DEVELOPERS TO THE OFFICE OF THE PROTHONOTARY: Kindly enter judgment in favor of Plaintiff and against Defendants, Richard J. Snyder, t/a Snyder Developers, Carole B. Snyder and Richard J. Snyder and Carole B. Snyder Limited Partnership t/a R&C Developers, jointly and severally, in the amount of $264,587.20, plus interest at the per diem rate of $61.54 from April 15, 2010 forward and costs of this action. Judgment is based on a Judgment already filed in Berks County, Pennsylvania, docketed to number 10-7123, against the Defendants listed in the caption of this case in the amount of $264,587.20, plus interest at the per diem rate of $61.54 from April 15, 2010 forward and costs of this action. Certified copies of the Judgment and docket entries are attached hereto as Exhibit "A." 0 #1 V°lur BINGAMAN, HESS, COBLENTZ & BELL, P.C. Mark G. Yoder, Esquire Attorneys for Plaintiff By: 342786 UTILITIES EMPLOYEES CREDIT UNION Successor by Assignment from LAND AKKQUISITIONS, LLC f/k/a JAMES DELAPLAINE FAMILY, LLC VS. RICHARD J. SNYDER, t/a SNYDER DEVELOPERS, CAROLE B. SNYDER, and RICHARD J. SNYDER AND CAROLE B. SNYDER LIMITED PARTNERSHIP t/a R&C DEVELOPERS No. 10-7123 I, Marianne R. Sutton Prothonotary of the Court of Common Pleas of Berks County, Pennsylvania, do hereby certify that the above and foregoing pages contain a true copy and correct transcript of the docket entries, which form the whole record. Judgment has been entered and certified in favor of the Plaintiff, & against the Defendants, Richard J. Snyder t/a Snyder Developers, Carole B. Snyder, and Richard J. Snyder and Carole B. Snyder Limited Partnership t/a R&C Developers in the amount of $264,587.20 + interest @ $61.64 per diem & court costs. In Testimony Whereof, I have hereunto set my hand and affixed the seal of said Court at Reading, PA, this 27th day of April 2011. Marianne R. Sutton, Prothonotary 4/27/2011 Berks County Civil Court Information System 10 07123 COMPLETE DOCKET SUMMARY UTILITIES EMPLOYEES CREDIT UNION, Succ/Assig LAND AKKQUISITIONS LLC F/K/A, JAMES DELAPLAINE FAMILY LLC, SNYDER, JENNIFER S, Petitioner *** VS *** SNYDER, RICHARD J, T/A, SNYDER DEVELOPERS, SNYDER, CAROLE B, RICHARD J SNYDER AND CAROLE B SNYDER R&C DEVELOPERS, SNYDER, RICHARD J, RICHARD J SNYDER AND CAROLE B SNYDER SNYDER, RICHARD J, I/T/A, Lim.Ptrshp SNYDER, CAROLE B, I/T/A, Lim.Ptrshp R&C DEVELOPERS, Lim.Ptrshp LIMITED PARTNERSHIP T/A, LIMITED PARTNERSHIP, UTILITIES EMPLOYEES CREDIT UNION, Garnishee DOCKET NUMBER: 10 07123 INITIAL ACTION TYPE: Judgment / Cmpl & Con INITIAL ASSIGNED JUDGE: Albert A. Stallone, S.J. OLD SYSTEM CASE#: ***** ** ** ** ** PAGE: 1 PTR350 PTDWROBE DATE DOCKET SUMMARY 4/15/2010 10:58AM Complaint and Confession of Judgment against Richard J Snyder t/a Snyder Developers, Carole B Snyder, and Richard J Snyder and Carole B Snyder Limited Partnership t/a R&C Developers in the amount of $264,587.20 plus... Copies and notice sent 4/19/10 4/15/2010 Certification of Addresses 4/15/2010 Affidavit of Non Military Service as to Defendant 4/15/2010 Appearance of Charles T Young Jr, Esq for Pltf 4/15/2010 Notices in Connection with Judgments by Confession required by 42 PA C S A 2737.1 (Act 105 of 2000) 4/15/2010 5/03/2010 Notice Under PA RCP 2958.1 of Judgment and Execution thereon R t e urn of Svc pursuant to PA RCP 2958.1(c) of Notice of Judgment and Execution required by Rule 2958.1 by Cert Mail on 4/26/10 and rec'd on 4/27/10 for Snyders' and 4/29/10 b Alfred Crump, Esq 6/11/2010 02:57PM Attachment UPON A CONFESSED JUDGMENT against Richard J Snyder, Carole B Snyder, Richard J Snyder and Carole B Snyder Limited Partnership and Utilities Employees Credit 6/11/2010 Union, Garnishee - $264,587.20 plus ...with Certification I t n errogatories in Attachment addressed to: Utilities Employees Credit Union 6/23/2010 Sheriff served Attachment/Interrogatories upon Utilities Employees Cred. Un. on 6/22/10 by handing to Services Rep PIC; upon Richard J Snyder and Snyder Developers and R&C Developers on 6/23/10 by Mail 6/23/2010 Sheriff served Attachment/Interrogatories upon Utilities Employees Cred Un on 6/22/10 by handing to Service Rep PIC; upon Richard J Snyder and Snyder Developers and R&C Developers on 6/23/10 by Mail 6/23/2010 Sheriff served Attachment/Interrogatories upon Utilities Employees Cred Un on 6/22/10 by handing to Services Rep/ PIC; upon Richard J Snyder and Snyder Developers and 4/27/2011 Berks County Civil Court Information Systgm PAGE: 2 10 07123 COMPLETE DOCKET SUMMARY PTR350 PTDWROBE DATE DOCKET SUMMARY R&C Developers on 6/23/10 by Mail 7/12/2010 Garnishee's Answers to Interrogs 7/20/2010 Writ Stayed on 7/20/10. Attached served upon Deft. Sheriff costs paid in full 7/26/2010 Pet of Jennifer S Snyder for Stay of Execution and for Dissolution of Attachment w/ prop. Order and Cert of Svc 8/02/2010 Order of 8/2/10 issuing Rule upon Pltfs and Defts to Show Cause in 30 days - Re: Pet of Jennifer S Snyder to Stay of Execution and for Dissolution of Attachment 8/27/2010 Answer of Pltf to Jennifer S Snyder's Petition for Stay of Execution & for Dissolution of Attachment w/Cert of Srvc 8/31/2010 Defts'Answer to the Petition of Jennifer S Snyder Petitioner & Order of Judge Stallone to Show Cause Why the Petition- 9/13/2010 er is not Entitled to the Relief Requested w/Cert of Srvc M ovant Jennifer S Snyder's Emergency Mtn for Protective 9/15/2010 Order and Sanctions w/ prop. Order and Cert of Service O d r er of 9/15/10 Emergency Motion of Third-Party Deponet Jennifer S Snyder for Protective Order and Sanctions DENIED. Copies and notice sent 9/16/10 10/05/2010 Exemplified Judgment to Adams County 10/05/2010 Pltf's Motion for Summary Judgment against Garnishee Utilities Employees Credit Union w/Proposed Order & Svc 10/28/2010 Appearance of Mark G Yoder Esq for Garnishee Utilities Employees Credit Union w/Cert of Srvc 10/28/2010 Appearance of Mark G Yoder Esq for Garnishee Utilities Employees Credit Union w/Cert of Srvc 11/01/2010 Stipulation to Extend Time to Answer Motion for Summary Judgment w/Proposed Order & Cert.of Service 11/03/2010 Order of 11/3/10 Approving Stip to Extend Time to Answer Mtn 11/15/2010 for Summary Judgment. Copies & Notice sent 11/5/10 Pltf's Praecipe to Withdraw its Motio f 11/15/2010 n or Summary Judgment Assignment of Judgment to Utilities Employees Credit Union 11/15/2010 Voluntary Substitution of Successor Party, Utilities 11/15/2010 Employees Credit Union, pursuant to PA RCP 2352(a) Voluntary Substitution of Successor Party, Utilities 11/15/2010 Employees Credit Union, pursuant to PA RCP 2352(a) A ppearance of Thomas A Rothermel, Esq for Pltf 11/15/2010 Appearance of Thomas A Rothermel, Esq for Pltf 11/15/2010 Exemplified Judgment to Schuylkill County PA 11/15/2010 , Exemplified Judgment to New Jersey 11/16/2010 Cert of Srvc of the Assignment of Judgment & Voluntary Substitution of Successor Party, Utilities Employees Credit Union 4/19/2011 Exemplified Judgment to Dauphin County PA 4/19/2011 , Exemplified Judgment to Mifflin County PA 4/19/2011 , Exemplified Judgment to York County, PA 4/19/2011 Exemplified Judgment to Cumberland County, PA PLAINTIFF(S): ATTORNEY: UTILITIES EMPLOYEES CREDIT UNION *Successor by Assignment Yoder, Mark G 01 02 4/27/2011 Berks County Civil Court Information System 10 07123 COMPLETE DOCKET SUMMARY PLAINTIFF(S): ATTORNEY: Rothermel, Thomas A 01 02 LAND AKKQUISITIONS LLC F/K/A Young, Charles T Jr 01 02 Yoder, Mark G 01 Rothermel, Thomas A 01 02 JAMES DELAPLAINE FAMILY LLC Young, Charles T Jr 01 02 Yoder, Mark G 01 Rothermel, Thomas A 01 02 DEFENDANT(S): ATTORNEY: SNYDER, RICHARD J, T/A Crump, Alfred W Jr 01 SNYDER DEVELOPERS Crump, Alfred W Jr 01 SNYDER, CAROLE B Crump, Alfred W Jr 02 01 RICHARD J SNYDER AND CAROLE B SNYDER LIM ******** R&C DEVELOPERS Crump, Alfred W Jr SNYDER, RICHARD J 01 Crump, Alfred W Jr 02 01 RICHARD J SNYDER AND CAROLE B SNYDER LIM Crump, Alfred W Jr 02 01 SNYDER, RICHARD J, I/T/A *Limited Partnership *Spelling Error/Name Typed Incorrectly Crump, Alfred W Jr 01 SNYDER, CAROLE B, I/T/A *Limited Partnership *Spelling Error/Name Typed Incorrectly Crump, Alfred W Jr 01 R&C DEVELOPERS *Limited Partnership *Party Sub-Type Amended PAGE: 3 PTR350 PTDWROBE Crump, Alfred W Jr 01 4/27/2011 Berks County Civil Court Information System 10 07123 COMPLETE DOCKET SUMMARY DEFENDANT(S): ATTORNEY: OTHER (S) : UTILITIES EMPLOYEES CREDIT UNION *Garnishee ATTORNEY: Crump, Alfred W Jr 01 Yoder, Mark G 01 02 SNYDER, JENNIFER S *Petitioner Smith, James M 01 02 PAGE: 4 PTR350 PTDWROBE 4/27/11 Berks County Civil Court Information System 10 07123 CASE COSTS SUMMARY REPORT UTILITIES EMPLOYEES CREDIT UNION, Succ/Assig LAND AKKQUISITIONS LLC F/K/A JAMES DELAPLAINE FAMILY LLC *** VS *** SNYDER, RICHARD J, T/A SNYDER DEVELOPERS SNYDER, CAROLE B RICHARD J SNYDER AND CAROLE B SNYDER LIMITED PARTNERSHIP T/A R&C DEVELOPERS SNYDER, RICHARD J, I/T/A, Lim.Ptrshp SNYDER, CAROLE B, I/T/A, Lim.Ptrshp R&C DEVELOPERS, Lim.Ptrshp DOCKET NUMBER: 10 07123 INITIAL ACTION TYPE: Judgment / Cmpl & Con INITIAL ASSIGNED JUDGE: Albert A. Stallone, S.J. OLD SYSTEM CASE#: ***** ** ** ** ** DATE AMOUNT P/D/R COMMENTS 4/15/2010 193.40 PAID CONFESSION OF JUDGMENT 10/05/2010 25.25 PAID EXEMPLIFICATION OF RECORD 11/15/2010 12.45 PAID OTHER: ASSIGNMENTS 11/15/2010 25.25 PAID EXEMPLIFICATION OF RECORD 11/15/2010 25.25 PAID EXEMPLIFICATION OF RECORD 4/19/2011 25.25 PAID EXEMPLIFICATION OF RECORD 4/19/2011 25.25 PAID EXEMPLIFICATION OF RECORD 4/19/2011 25.25 PAID EXEMPLIFICATION OF RECORD 4/19/2011 25.25 PAID EXEMPLIFICATION OF RECORD 6/11/2010 51.85 PAID WRIT OF ATTACHMENT 6/23/2010 85.00 PAID SHERIFF 6/23/2010 60.00 PAID STATE SURCHARGE 7/20/2010 390.25 PAID TOTAL COSTS TO DATE PAGE: PTR353 SHEET BOOK PAGE BINGAMAN, HESS, COBLENTZ & BELL, P.C. By: Mark G. Yoder, Esquire Attorney Identification No. 32493 Treeview Corporate Center Attorneys for Plaintiff 2 Meridian Boulevard, Suite 100 Wyomissing, PA 19610 (610) 374-8377 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW UTILITIES EMPLOYEES CREDIT UNION NO. successor by assignment from Land Akkquisitions, LLC f/k/a James Delaplaine Family, LLC, ; Plaintiff vs. RICHARD J. SNYDER, t/a Snyder Developers, CAROLE B. SNYDER and RICHARD J. SNYDER AND CAROLE B. SNYDER LIMITED PARTNERSHIP t/a R&C Developers Defendants CERTIFICATION OF ADDRESSES I do hereby certify that the following are the names and current addresses of each party's attorney of record and/or the names and current addresses of each unrepresented party in this foregoing action: Counsel for Plaintiff: Mark G. Yoder, Esquire Bingaman Hess Treeview Corporate Center 2 Meridian Boulevard, Ste. 100 Wyomissing, PA 19610 Defendants: Richard J. Snyder, t/a Snyder Developers, Carole B. Snyder and Richard J. Snyder and Carole B. Snyder Limited Partnership t/a R&C Developers 119 W. Lancaster Avenue Shillington, PA 19607 BINGAMAN, HESS, COBLENTZ & BELL, P.C. ';"? 3. // G.?--- L By: Mark G. Yoder, Esquire Attorneys for Plaintiff 342786 BINGAMAN, HESS, COBLENTZ & BELL, P.C. By: Mark G. Yoder, Esquire Attorney Identification No. 32493 Treeview Corporate Center 2 Meridian Boulevard, Suite 100 Wyomissing, PA 19610 (610) 374-8377 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND CIVIL ACTION - LAW UTILITIES EMPLOYEES CREDIT UNION NO. successor by assignment from Land Akkquisitions, LLC f/k/a James Delaplaine Family, LLC, ; Plaintiff vs. RICHARD J. SNYDER, t/a Snyder Developers, CAROLE B. SNYDER and RICHARD J. SNYDER AND CAROLE B. SNYDER LIMITED PARTNERSHIP t/a R&C Developers Defendants AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF BERKS ss. LINTY, PA Mark G. Yoder, Esquire, being duly sworn according to law, deposes and says that he is counsel for Utilities Employees Credit Union, Plaintiff herein, and as such states the following: 1. The Defendants, Richard J. Snyder and Carole B. Snyder, are not, to his knowledge, 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 1940, as amended. 2. The Defendants, Richard J. Snyder and Carole B. Snyder, are more than 21 years of age and have a last known address of 119 W. Lancaster Avenue, Shillington, PA 19607 3. He makes this affidavit with due authority based upon information provided to him by the Plaintiff. /, I ?z M &k G. Yoder, Esquire Sworn to and subscribed before me this 11:2 day of Mme,, , 2011. Notarial seal Notary Public Donna L. Witman, Notary Public Spring TWp•, Berks County Commission Expires Sept. 12, 2014 342786 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW Dated: 2011 Richard J. Snyder t/a Snyder Developers 119 W. Lancaster Avenue Shillington, PA 19607 RE: Utilities Employees Credit Union, successor by assignment from Land Akkquisitions, LLC f/k/a James Delaplaine Family, LLC vs. Richard J. Snyder, t/a Snyder Developers, Carole B. Snyder, and Richard J. Snyder and Carole B. Snyder Limited Partnership t/a R&C Developers No. /I- 61011 Cumberland County Court of Common Pleas Dear Mr. Snyder: Utilities Employees Credit Union, successor by assignment from Land Akkquisitions, LLC f/k/a James Delaplaine Family, LLC, this date has entered judgment against you individually and trading as Snyder Developers in the Court of Common Pleas of Cumberland County, Pennsylvania, in the amount of $264,587.20, together with interest at the per diem rate of $61.64 from April 15, 2010 forward and costs of this action. Prothonotary Court of Common Pleas Cumberland County, Pennsylvania By: Deputy Prothonotary 342786 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW Dated: fia S , 2011 Carole B. Snyder 119 W. Lancaster Avenue Shillington, PA 19607 RE: Utilities Employees Credit Union, successor by assignment from Land Akkquisitions, LLC f/k/a James Delaplaine Family, LLC vs. Richard J. Snyder, t/a Snyder Developers, Carole B. Snyder, and Richard J. Snyder and Carole B. Snyder Limited Partnership t/a R&C Developers No. I/- ho l , Cumberland County Court of Common Pleas Dear Mrs. Snyder: Utilities Employees Credit Union, successor by assignment from Land Akkquisitions, LLC f/k/a James Delaplaine Family, LLC, this date has entered judgment against you in the Court of Common Pleas of Cumberland County, Pennsylvania, in the amount of $264,587.20, together with interest at the per diem rate of $61.64 from April 15, 2010 forward and costs of this action. Prothonotary Court of Common Pleas Cumberland County, Pennsylvania By: lla?- _ U Deputy Prothonotary 342786 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW Dated: ISM S , 2011 Richard J. Snyder and Carole B. Snyder Limited Partnership t/a R&C Developers 119 W. Lancaster Avenue Shillington, PA 19607 RE: Utilities Employees Credit Union, successor by assignment from Land Akkquisitions, LLC f/k/a James Delaplaine Family, LLC vs. Richard J. Snyder, t/a Snyder Developers, Carole B. Snyder, and Richard J. Snyder and Carole B. Snyder Limited Partnership t/a R&C Developers No. 1 r'-(Vf I , Cumberland County Court of Common Pleas Dear Sir or Madam: Utilities Employees Credit Union, successor by assignment from Land Akkquisitions, LLC f/k/a James Delaplaine Family, LLC, this date has entered judgment against the limited partnership in the Court of Common Pleas of Cumberland County, Pennsylvania, in the amount of $264,587.20, together with interest at the per diem rate of $61.64 from April 15, 2010 forward and costs of this action. Prothonotary Court of Common Pleas Cumberland County, Pennsylvania By: , Deputy Prothonotary 342786 BINGAMAN, HESS, COBLENTZ & BELL, P.C. BY: Mark G. Yoder, Esquire Identification No. 32493 Treeview Corporate Center 2 Meridian Boulevard, Suite 100 Wyomissing, PA 19610 (610) 374-8377 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, UTILITIES EMPLOYEES CREDIT UNION :NO. 11-4168 Successor by assignment from LAND AKKQUISITIONS, LLC, f/k/a JAMES DELAPLAINE FAMILY, LLC, . Plaintiff VS. RICHARD J. SNYDER, t/a SNYDER DEVELOPERS, CAROLE B. SNYDER, and RICHARD J. SNYDER AND CAROLE B. SNYDER LIMITED PARTNERSHIP t/a R&C DEVELOPERS, Defendants iNSYLVANI G r'rtvn t ,-r ZO ,,,fl or :CONFESSION OF JUDGMENT PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly satisfy the judgment entered against Defendant g, Richard J. Snyder, t/a Snyder Developers, Carole B. Snyder, a ad Richard J. Snyder and Carole B. Snyder Limited Partnership, t /a R&C Developers in the above-captioned matter. BINGAMAN, HESS, COBLENTZ & BELL, P.C. B Jim .??ti Y: Mark G. Yoder, Esquire Attorneys for Plaintiff Date: August 2012 362009