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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 '-M rn CIVIL ACTION n!" rv : a 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 0,*$1cf,c6pa a C.k- I6 14110 z*a ?6 yQ $? 1'Ace w6 led 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.) *`i, ??y? ??y t "sM' t. 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 :rlm i -• DEC - 5 2011 111NVAT iNM ON _£ Wd I ,...- '. ! 0NOU \/1NVA1ASNN3d A1000 ONVIb39WAO LZ :£ Wd I - 330 I IDl A1Vi0N01Ai0dd 3HJI. 30 301330-0311? %I A 1, - 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{=-= z :?o ma r c-s o -vrn CD = ,, CIVIL ACTION )>° -0 C:j o ?' c=s 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 =-?D W 9 N vs. CIVIL ACTION < Q za = x °? HENRY MUSSER, n rv x ``', 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 ,ell e L'? N i rnw M M;= " C ?b v r-M -?C7 *C-1 Q