The URL can be used to link to this page

Home My WebLink About11-6309SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor "VAXtr of ??t+pbr??ih? OFFICE 7..E ^.! PdFF OF THELPROTHONOTArY 2011 AUG 23 PM 3-' 33 CUMBERLAND COUNTY PENNSYLVANIA Cach, LLC vs. Case Number Richard S. Roswog 2011-6309 SHERIFF'S RETURN OF SERVICE 08/18/2011 03:29 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on August 18, 2011 at 1529 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Richard S. Roswog, by making known unto himself personally, at 666 State Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the same. 7a??;7 ?_ - IC AEL BARRICK, DEPUTY SHERIFF COST: $44.00 August 19, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF i07 CounfySWte Sheriff, ieleoseft. Irc. Law Firm of Allan C. Smith, P.C..?Tj t Attorney I.D. 204756 1 h ?. 'hd a j : [+ 9 LU' 276 Veterans Highway, Suite E-1 190 Bristo 0 ?L s? 1 ., S''r IZ,i BEE??. AI'D // (215) 428-0666 888 1275 6 99 , , CACH, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff(s), ) NO: 11-6309-CIVIL TERM VS. ) RICHARD J ROSWOG ) PRAECIPE TO ENTER Defendant(s). ) JUDGMENT BY DEFAULT TO THE PROTHONOTARY: Please enter a Default Judgment in favor of plaintiff, CACH, LLC, and against the defendant(s), RICHARD J ROSWOG, for failure to answer or otherwise respond to the Complaint in Civil Action. The Complaint was served upon the defendant(s) on August 18, 2011. A copy of the proof of service is attached hereto as Exhibit "A". A copy of the Notice of Intention to take Default mailed to defendant(s) RICHARD J ROSWOG by regular United States mail, postage paid, on September 13, 2011, is attached hereto as Exhibit "B". Assess damages in the amount of $ 23,306.45 as follows: [a] $ 14661.41 principal being sought in the Complaint; [b] and $5712.76 interest being sought in the Complaint; [c] and reasonable attorney's fees of $2932.28, or $ 150.00 per hour, [d] and Court Costs of $ 0.00, [e] and Costs of Service of $0.00. Date: November 30, 2011 By- Allan C., mith sq. Attorney I.D. No. 204756 WX 3 I4. AD Pd Q (fi,? C,l: 4151&6 J je*0tpSYs/ VWcQ AeLiI4 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?$???, lot +Gumber?? Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE OF THE SHERIFF Cach, LLC Case Number vs. 2011-6309 Richard S. Roswog SHERIFF'S RETURN OF SERVICE 08/18/2011 03:29 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on August 18, 2011 at 1529 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Richard S. Roswog, by making known unto himself personally, at 666 State Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the same. C EL BARRICK, DEPUTY SHERIFF COST: $44.00 August 19, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (C) CountySuite Sheriff, Teleosoft, Inc. Law Firm of Allan C. Smith, P.C. Attorney I.D. 204756 1276 Veterans Highway, Suite E-1 Bristol, PA 19007 1-888-275-6399//(215)428-0666 Attorney for Plaintiff CACH,LLC Plaintiff, vs. RICHARD J ROSWOG Defendant(s). COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-6309-CIVIL TERM CERTIFICATE OF SERVICE OF NOTICE OF INTENT TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT I, ALLAN C. SMITH, ESQ., of full age, certify that I mailed a copy of the annexed NOTICE OF INTENT TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT upon defendant RICHARD J ROSWOG by United States mail, postage prepaid and certified mail, on September 13, 2011 at his/her last address of: 666 STATE ST LEMOYNE, PA 17043 Date: November 30, 2011 By _ Allan C Sm' sq. Attorney I.D. No. 204756 Harrison R. Byck, Esq., P.C. Attorney I.D. No. 61511 1276 Veterans Hwy-Suite E-1 Bristol, PA 19007 1-888-275-63" H (215) 428-0666 Attorney for the Plaintiff CACH, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, ) VS. ) No.: 11-6309-CIVIL TERM RICHARD J ROSWOG ) NOTICE OF INTENT TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT TO: RICHARD ROSWOG 666 STATE ST LEMOYNE, PA 17043 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CAN NOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service PENNSYLVANIA LAWYER REFERAL SERVICE 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013. (717) 240-6200 Dated: September 13, 2011 Law Firm of Allan C. Smith, P.C. Attorney I.D. 204756 Bucks County Office Center 1276 Veterans Highway, Suite E-1 Bristol, PA 19007 1-888-275-6399//(215)428-0666 Attorney for Plaintiff CACH,LLC ) Plaintiff, ) VS. ) RICHARD J ROSWOG ) Defendant(s). ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-6309-CIVIL TERM CERTIFICATION OF NON-MILITARY SERVICE I, ALLAN C. SMITH, ESQ. of full age, certifies as follows: 1. I am the plaintiff's attorney herein, and have sufficient knowledge of the facts and am fully authorized to make this Certification; 2. My information is that the defendant is RICHARD J ROSWOG. 3. Our latest information is that the defendant is employed at unknown. 4. To the best of my information and belief, the Defendant is not a member of the military services of the United States of its allies or otherwise within the provisions of the Soldiers' and Sailors' Relief Act of 1940, as amended, and as stated in the attached Department of Defense Manpower Data Center reports. 5. This certification is taken subject to the penalties of 18 PaCSA 4904 relating to unsworn falsification to authorities. Date: November 30, 2011. Allan . Smit Esq. Attorney I.D. No. 204756 Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page o 2 Sep-30-2011 11:04:25 4 Last First/Middle Begin Date Active Duty Status Active Duty End Date Service enc A Name y g Based on the information you have furnished, the DMDC does not possess ROSWOG RICHARD J any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Awt Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/pis/PC09SLDR.htm1. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.miVappj/scra/popreport.do 9/30/2011 Law Firm of Allan C. Smith, P.C. Attorney I.D. 204756 Bucks County Office Center 1276 Veterans Highway, Suite E-1 Bristol, PA 19007 1-888-275-6399 H (215) 428-0666 Attorney for Plaintiff CACH,LLC vs. RICHARD J ROSWOG Plaintiff, Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-6309-CIVIL TERM To: RICHARD J ROSWOG 666 STATE ST LEMOYNE, PA 17043 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below: N r B - Cler IaIka1ll X Judgment by Default Money Judgment - Judgment in Replevin - Judgment for Possession - Judgment on Award of Arbitration - Judgment on Verdict - Judgment on Court Verdict If you have any questions concerning the above, please contact: ATTORNEY: HARRISON ROSS BYCK, Esquire at 215-428-0666 or 1-888-275-6399 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-6309 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CACH, LLC., Plaintiff (s) From RICHARD J ROSWOG, 666 STATE STREET, LEMOYNE, PA 17043 (1) You are directed to levy upon the property of the defendant (s)and to sell ANY AND ALL PERSONAL PROPERTY OF THE DEFENDANT LOCATED AT 666 STATE STREET, LEMOYNE, PA 17043. (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 $23,306.45 L.L. $.50 Interest Atty's Comm % Due Prothy $2.25 Atty Paid $181.00 Other Costs Plaintiff Paid Date: 2%21/12 David D. Buell, Prothonotary (Seal) Deputy REQUESTING PARTY: Name ALLAN C. SMITH, ESQUIRE Address: LAW FIRM OF ALLAN C SMITH, ESQ, PC BRISTOL OFFICE CENTER 1276 VETERANS HIGHWAY, SUITE E-I BRISTOL, PA 19007 Attorney for: PLAINTIFF Telephone: 888-275-6399 Supreme Court ID No. 2047561 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 CACH, LLC 4340 S. Monaco Street, 2nd Floor Denver, Colorado 80237 Plaintiff(s), VS. RICHARD J ROSWOG 666 STATE ST LEMOYNE, PA 17043 Defendant(s). TO THE PROTHONOTARY: ISSUE and INDEX WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania, (2) against RICHARD J ROSWOG Defendant(s); (3) and against Garnishee(s); as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property to be levied upon by Sheriff) (4) Amount Due Interest from TOTAL February 02, 2012 Clz?) akk aS. sa d of 4 y. oo CBS 99-00((1 1(1.DOu k a. 5rJ u , 6° TC1 COURT OF COMMON PLEAS Q -' CUMBERLAND COUNTY, PENNSYLIA2 M r n ,-,-, .. =;u Co Docket No : 11-6309-CIVIL TERM --<> -- C . ?C $ 23,306.45 $ . Sv L L Plus costs. 1 4 1 ( (Alan C. SA Esq. torney for Plaintiff(s) 0..4 a( JL12k rid SHERIFF'S OFFICE OF CUMBERLAND COUNTY .< Anderson ,f w. "J ?v t ,ody S Smith Chief Deputy Richard W Stewart Solicitor '0112 t-IA 28 AN 09; PENNS YL A f p? Cach, LLC vs. Richard S. Roswog Case Number 2011-6309 SHERIFF'S RETURN OF SERVICE 02/23/2012 02:11 PM - Michael Barrick, Deputy , being duly sworn according to law, states that on February 23, 2012 at 2:11 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: Richarc S. Roswog at 666 State Street, Lemoyne Borough, Lemoyne, PA 17043, 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 02-27-12. 03/01/2012 On March 1, 2012, a property claim was filed by Christine M. Roswog. All parties notified by mail this date. 03/09/2012 Reference is made to Property Claim dated March 1, 2012, entered by Christine M. Roswog, Writ of Execution No. 2011-6309, CACH, LLC vs. Richard J. Roswog. Ronny R. Anderson, Sheriff, has determined that the claimant, Christine M. Roswog, in the above mentioned property claim, is the owner of the property set forth in the claim. 03/27/2012 No objections filed in this case. 03/27/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ of execution is returned STAYED per Pennsylvania Rules of Court 3206(c) (pertaining to property claims). SHERIFF COST: $112.00 SO ANSWERS, March 27, 2012 RON R ANDERSON, SHERIFF ' 73 i1.r