HomeMy WebLinkAbout11-6326SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
FILED-OFFIr
9?1tt,,0t c„„b"?,f1n4 Gil- THE PROTHON I ,? ,
2011 SEP -2 AM 8: 23
Orr F .. ,. CUMBERLAND COUNTY
PENNSYLVANIA
Commonwealth Financial Systems, Inc.
vs. Case Number
Henry Musser 2011-6326
SHERIFF'S RETURN OF SERVICE
08/19/2011 11:10 AM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on August
19, 2011 at 1110 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Henry Musser, by making known unto himself personally, at 35 Mountain View Terrace,
Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to him
personally the said true and correct copy of the same.
C/?Q ? i??r}riJ
RONALD HOOVER, DEPUTY
SHERIFF COST: $40.00
August 22, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH FINANCIAL
SYSTEMS, INC.
Plaintiff
vs.
HENRY MUSSER,
Defendant
TO THE CLERK OF SAID COURT:
No. 11-6326-Civil Term
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CIVIL ACTION n!" rv
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PRAECIPE
Please enter judgment in favor of Plaintiff Commonwealth Financial Systems, Inc. and
against Defendant Henry Musser in the amount of $2,498.44 plus costs and interest at the rate of
11.99% per annum from April 26, 2011, for want of filing an Answer. I certify that a 10-day
notice, a copy of which is attached hereto, was served on Defendant via first class mail on
September 9, 2011.
Alarf-K. Mege, Es .
Attorney ID No 1288
Attorney for aintiff
P.O. Box 1426
Bethlehem, PA 18016
(610) 954-5.93
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH FINANCIAL
SYSTEMS, INC.
Plaintiff No. 11-6326-Civil Term
vs.
CIVIL ACTION
HENRY MUSSER,
Defendant
( ) Notice is hereby given that a Judgment in the above captioned matter has been
entered against you in the amount of $2,498.44 plus costs and interest on
a \ , 2011.
( ) A copy of all documents filed with the Prothonotary in support of the within
judgment is/are enclosed.
Prothonotary
2
By:
--
If you have questions regarding this Notice, please contact the filing party:
NAME: Alan R. Me e, Esq.
ADDRESS: P.O. Box 1426
Bethlehem, PA 18016
TELEPHONE NO. 610-954-5393
(This Notice is given in accordance with Pa.R.C.P.§236.)
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH FINANCIAL
SYSTEMS, INC.
Plaintiff No. 11-6326-Civil Term
vs.
: CIVIL ACTION
HENRY MUSSER,
Defendant
TEN DAY NNOTICE
TO: Heruy Musser 35 Mountain View Terrace, Newville, PA 17241
DATE OF NOTICE: September 9, 2011
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 OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
TELEPHONE (717) 249-3166
?Alan R. Mege, Es
Attorney ID No. 1288
Attorney for P
aintiff
Law Office of Alan R. ]\*ge, Esq.
P.O. Box 1426
Bethlehem, PA 18016-1426
(610) 954-5393
IN THE COURT OF COMMON PLEAS OF BERKS COUNTY, PENNSYLVANIA
Commonwealth Financial Systems, Inc.
Plaintiff
VS. NO. 11-6326-Civil Term
Henry Musser
Defendant
AFFIDAVIT OF NON-MILITARY SERVICE
The undersigned, being duly sworn, according to law, deposes and says that the Defendant(s)
is/are not 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 Congress of 1940 as amended;
That Henry Musser is over 18
years of age, resides at 35 Mountain View Terrace, Newville RA 17241
and is employed
That Defendant
Is
years of age, resides at
and is employed
That Defendant is
years of age, resides at
and is employed
That Defendant is
years of age, resides at
and is employed
I, Alan R. M6ge, Esquire, do hereby verify that I am the attorney for Plaintiff, that I
am fully authorized to make this Verification on their behalf, that the Defendants are unavailable to
make this Verification, that the facts contained in the foregoing pleading are true and correct to the best
of my knowledge, information and belief, and the source of my information are interviews with my
client and the Plaintiff's filed documents.
The verifier understands that false statements herein are made subject to the penalties
of 18 Pa. C.S. Section 4904 r In u or alsification to authorities.
Signed: 1 Dated: 9120/1
COURT OF COMMON'IPLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH
SYSTEMS, INC.
VS.
HENRY MUSSER,
And now comes P
UNCIAL
FILED-OFFICE
of J HE PROTHONOTARY
ff No. 11-6326-Civi erm
M DEC 22 AM f t = OS
CIVIL ACTION "? NSY MIUMLAND COUNTY
cant
and submits the instant Motion to Make The Rule Absolute, and
in support thereof avers as
1. On November * 2011, a Rule was issued upon the Defendant, Henry Musser 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 Rule Returnable was to be answered by December 20, 2011 in the Office of
the Cumberland County Prothonotary. As of December 21, 2011, no answer has been filed.
3. A copy of this M?tion and proposed Order were mailed to Defendant, via first class
mail on December 21, 2011 A certificate of Service is attached hereto.
4. Plaintiff requests ? that the Rule be made Absolute.
WHEREFORE, PWntiff, 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 *es ees in the amount of $100, as well as such other and further relief as
the Court may deem just and appropriate.
R. ege, Esq.
Attorrey ID No. 288
Attorney for Pla ntiff
V
COMMONWEALTH FINANCIAL IN THE COURT OF COMMON PLEAS OF
SYSTEMS, INC., CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
VS. NO. 11-6326 CIVIL
HENRY MUSSER
IN aE: PLAINTIFF'S MOTION TO COMPEL
ORDER
AND NOW, this ?o` day of November, 2011, a rule is issued on the defendant to
show cause why the relief requested in the within motion to compel ought not to be granted.
This rule returnable twenty ($0) days after service.
BY THE COURT,
Alan R. Mege, Esquire
For the Plaintiff
Henry Musser, Pro Se
Defendant
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DEC - 5 2011
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH FINANCIAL
SYSTEMS, INC.
No. 11-6326-Civil Term
VS.
HENRY MUSSER,
De
I, Alan R. Mege, Es
Motion to Make the Rule A
Mountain View Terrace, Ni
CIVIL ACTION
CERTIFICATE OF SERVICE
hereby certify that on December 21, 2011, I served Plaintiff's
ute mailing same, first class, post prepaid to: Henry Musser 35
Ile. PA 17241.
By:
Mege, Esquir
Atty. I.D. #81288
Attorney for Pl ntiff
P.O. Box 1426
Bethlehem, PA 18016
(610) 954-5393
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH FINANCIAL
SYSTEMS, INC.
Plaintiff
VS.
HENRY MUSSER,
Defendant
No. 11-6326-Civil Term x°r° ° M{=-=
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CIVIL ACTION )>°
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ORDER
AND NOW, this jp'' day of 7,k,&%Av , 2011, upon consideration of Plaintiffs
Motion to Make the Rule Absolute, it is hereby
ORDERED that the Rule issued on November r30, 2011, 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
suvt"..
the date ofKthis Order or appropriate sanctions will be imposed upon Defendant following
application to this Court;
IT IS FURTHER ORDERED that counsel fees of $100.00 are awarded to Plaintiff and
against Defendant as compensation for the preparation, service, and presentation of this motion,
to be paid within twenty (20) days of this Order.
, Judge
Distribution:
? Alan R. Mege, Esquire, 70 East Broad Street, Bethlehem, PA 18016 /? ies ?, Piet
/Henry Musser 35 Mountain View Terrace, Newville, PA 17241. &P t
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH FINANCIAL h., C:;
SYSTEMS, INC.
Plaintiff No. 11-6326-Civil Term
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vs.
CIVIL ACTION < Q
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HENRY MUSSER, n rv x
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Defendant
STIPULATION
AND NOW, this 13`x' day of February, 2012, it is hereby stipulated and agreed by
and between the parties:
1. The parties agree that Defendant shall pay the judgment amount and costs
to Plaintiff by making monthly payments of a minimum of $50 per month paid by Defendant and
mailed to Plaintiff, with the first such monthly payment due by the end of February, 2012, and
each following monthly payment due by the end of each month thereafter.
2. The parties agree that payments shall be made payable to "Alan M6ge,
Attorney for CFSI", and mailed, to Law Offices of Alan M6ge, P.O. Box 1426, Bethlehem, PA,
18016-1426.
3. The parties agree that this Stipulation be made into an Order of Court.
4. The parties agree that his account will be reviewed every six months to see
if the minimum payment can be increased.
5. Upon completion of the above-referenced payments, barring an uncured
default, Plaintiff shall forward to Defendant for filing, a fully executed Praecipe to Satisfy.
IN WITNESS WHEREOF and intending to be legally bound, the parties hereto have set
their hands and seals the day and year first above written.
1
He Musser R. Mege, Esq.
Defendant Attorney for CFSI
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COMMONWEALTH FINANCIAL
SYSTEMS, INC.
Plaintiff No. 11-6326-Civil Term
VS.
HENRY MUSSER,
Defendant
CIVIL ACTION
ORDER
AND NOW, to wit, this 2l * xday of "waA..4 , 2011, the
Stipulation of the parties dated February 13, 2012 is hereby approved and made an Order of
Court in the above-captioned matter.
BY THE COURT:
, J.
Distribution:
Alan R. Mege, Esq., 70 E Broad St., Bethlehem, PA 18016
? Henry Musser 35 Mountain View Terrace, Newville, PA 17241
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