HomeMy WebLinkAbout11-7432COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil
COUNTY OF CUMBERLAND Case
Mag. Dist. No: MDJ-09-1-02
MDJ Name: Honorable Barbara A. Clare
Address: 1901 State Street
Camp Hill, PA 17011
Telephone: 717-761-0583
Seligman, Friedman & Company PC
235 St Charles Way Ste 250
York, PA 17402
Disposition Summary
Docket No
MJ-09102-CV-0000096-2011
Judgment Summary
Participant
Tonya Williams dba Rejoice inc
Seligman, Friedman & Company PC
V.
Tonya Williams dba Rejoice inc
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Llr-r'1is" PA I_? (O3
Docket No: MJ-09102-CV-0000096-2011
Case Filed: 4/7/2011
Plaintiff Defendant Disposition Disposition Date
Seligman, Friedman & Company Tonya Williams dba Rejoice inc Default Judgment for Plaintiff 05/19/2011
PC
Joint/Several Liability Individual Liability Amount
$0.00 $11,625.67
$11,625.67
Judgment Detail (*PostJudgment)
In the matter of Seligman, Friedman & Company PC vs. Tonya Williams dba Rejoice inc on 5/19/2011 the disposition is Default
Judgment for Plaintiff and judgment was awarded as follows:
Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount
Civil Judgment $0.00 $11,473.67 $11,473.67
Filing Fees $0.00 $152.00 $152.00
Grand Total: $11,625.67
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH
THE PROTHONOTARY/CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF
JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT
HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE
COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A
REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
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Date Magisterial District Judge Barbara A. Clare
/
certify that this is a true an correct copy o the record o the proceedings co ping the judgment.
Date Magisterial District Judge Barb a A. are
MDJS 315 Page 1 of 2 Printed: 06/28/2011 9:59:17AM
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2113 JUL 24 ,°i 10: 0j,
CUMBERLAND COUNTY
Pl``NNsYLVANIA
COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENNSYLVANIA
SELIGMAN, FRIEDMAN &
COMPANY, P.C.,
Plaintiff,
V. Docket No.:11-7432
TONYA WILLIAMS d/b/a CIVIL TERM
REJOICE,INC.,
Defendant.
For Plaintiff: Glenn J. Smith, Esquire
PA#206767
135 North George Street
York, PA 17401
Tel: (717) 848-4900
Fax: (717) 843-9039
gsmith @cgalaw.com
For Defendant: Tonya Williams
1820 Linglestown Road
Harrisburg, PA 17110-3339
MOTION TO COMPEL FULL AND COMPLETE ANSWERS TO
INTERROGATORIES IN AID OF EXECUTION
Submitted by Attorney Glenn J. Smith, Counsel for Seligman, Friedman& Company, P.C.
(00715223/3)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
SELIGMAN, FRIEDMAN &
COMPANY, P.C., .
Plaintiff,
V. Docket No.:11-7432
TONYA WILLIAMS d/b/a CIVIL TERM
REJOICE, INC., .
Defendant.
MOTION TO COMPEL FULL AND COMPLETE ANSWERS TO
INTERROGATORIES IN AID OF EXECUTION
AND NOW, TO WIT, this 23`d day of July, 2013, comes Plaintiff, Seligman, Friedman
& Company,P.C., by and through their undersigned counsel, CGA Law Firm, files the within
Motion to Compel Discovery and states in support thereof:
1. Plaintiff, Seligman, Friedman& Company, P.C., is a Pennsylvania professional
corporation located at 235 St. Charles Way, Ste. 250, York, PA 17402.
2. Defendant, Tonya Williams is an individual with an address of 1820 Linglestown
Road, Harrisburg, Pennsylvania 17110.
(00715223/3) .
3. On or about March 8, 2013, Plaintiff served on Defendant its First Set of
Interrogatories in Aid of Execution Addressed to Defendant.
5. Pursuant to Pa.R.C.P. 4006(a)(2) and 4009.12(a)(1), Defendant's responses and
objections, if any,to said discovery were due on or about April 7, 2013.
6. Defendant failed to respond to the First Set of Interrogatories by April 7, 2013.
7. On April 12, 2013, Plaintiff notified Defendant of her failure to comply with the
Pennsylvania Rules regarding discovery and requested that Defendant respond to the Plaintiff's
Interrogatories without the Court's intervention. A true and correct copy of the aforementioned
demand is attached,hereto, made a part hereof and marked as Exhibit "A".
8. To date, Defendant has never responded to the Plaintiff's First Set of
Interrogatories or Plaintiff's related correspondence.
9. Plaintiff avers that Defendant will not answer Plaintiff s Interrogatories in Aid of
Execution absent a Court Order pursuant to Pa. R.C.P.§ 4019(a)(1)(i).
10. The Court'may, on motion, compel Defendant to respond to Plaintiff's written
discovery requests upon Defendant's failure to serve answers or objections to written
interrogatories, or failure to respond to a request for production of documents pursuant to Pa.
R.C.P. § 4019(c)(5).
(0071522313)
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order
directing Defendant to provide full and complete answers to Plaintiff's Interrogatories in Aid of
Execution within ten(10) days or suffer sanctions as this Honorable Court sees fit, including
counsel fees in the amount of$25.00 per day for every day that the completed Interrogatories in
Aid of Execution are not received following the Court's order and award $750.00 to Plaintiff for
the cost of preparing and presenting the instant Motion.
Respectfully submitted,
CG 7
By:
tl le , Esquire
PA#206767
135 North George Street
York, PA 17401
Tel: (717) 848-4900
Fax: (717) 843-9039
gsmith @cgalaw.com
Counsel for Plaintiff
(00715223/3)
yT ��
WAI I
L A W F I R' M
Glenn J.Smith,Attorney
gsmfth@cgalaw.com
Ext. 135
April 12, 2013
Tonya Williams
1820 Linglestown Road
Harrisburg,PA 17110-3339
Re: Seligman, Friedman & Company, P.C.v. Tonya Williams d/b/a Rejoice, Inc.
Dear Ms. Williams:
On March 8, 2013 I directed to your attention Interrogatories in Aid of Execution on behalf of
my client Seligman,Friedman&Company, P.C. These Interrogatories pertain to a judgment my
client obtained against you in the amount of$11,625.67 on May 19, 2011. The Pennsylvania
Rules of Civil Procedure require full and complete responses from you within 30 days of service.
You have failed to do so. Should I not be in receipt of full and complete responses to said
Interrogatories, by the close of business Friday, April 19, 2013, I will be forced to file a Motion
to Compel in which I will request attorney's fees and costs related thereto.
Enclosed herein are a duplicate set of those Interrogatories should the original set not be handy.
You are welcome to contact my office should you wish to discuss this further.
V er tly yours,
. Smith
GJS/kml
Enclosure
EXHIBIT
(00695789/1)
CGA Law Firm,CGA Professional Center, 135 N. George Street,York,PA 17401,717.848.4900, Fax 717.843,9039.www.coalaw.cnm
COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENNSYLVANIA
SELIGMAN, FRIEDMAN &
COMPANY,P.C., .
Plaintiff,
V. Docket No.:11-7432
TONYA WILLIAMS d/b/a CIVIL TERM
REJOICE, INC.,
Defendant.
CERTIFICATE OF SERVICE
I hereby certify that on this 23`d day of July, 2013, a true and correct copy of the
Plaintiff s Motion to Compel Full and Complete Answers to Interrogatories in Aid of Execution
was served, via first class mail, postage prepaid upon the following:
Tonya Williams
1820 Linglestown Road
Harrisburg, PA 17110-3339
21, .�
Shane M. Rohrbaugh, Paralegal for
Glenn J. Smith, Esquire
(00715223/3)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
SELIGMAN,FRIEDMAN &
COMPANY, P.C.,
Plaintiff,
V. Docket No.:11-7432
TONYA WILLIAMS d/b/a CIVIL TERM
REJOICE, INC.,
Defendant.
ORDER GRANTING PLAINTIFF'S MOTION TO COMPEL INTERROGATORIES IN
AID OF EXECUTION AND REIMBURSEMENT OF LEGAL COSTS
AND NOW, this V Say of V AL/I , 2013, upon consideration of Plaintiff's
Motion to Compel Interrogatories in Aid of Execution filed in the above-docketed matter, it is
hereby ORDERED and DECREED that:
(1) Defendant must serve upon Plaintiff full and complete responses to Plaintiff's
First Set of Interrogatories in Aid of Execution directed to Defendant within ten (10) days of the
date of this Order or suffer sanctions as this Honorable Court deems just and proper,irteft?ftrg-.
@e wtsei fees in the- d ay
(00715223/3)
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ref' r sanc ions as is o
IT IS FURTHER ORDERED that Defendant must provide the documents
electronically via electronic mail, regular mail, or facsimile.
BY THE COURT,
J.
DISTRIBUTION:
, Glenn J. Smith, Esq.
CGA Law Firm
13 5 N. George St.
York, PA 17401
Tonya Williams
d/b/a Rejoice, Inc.
1820 Linglestown Rd. �D
Harrisburg, PA 17110-3339 O
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(0071522313)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
SELIGMAN, FRIEDMAN &
�t
COMPANY, P.C., Docket No. 11-7432
Plaintiff, '
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TONYA WILLIAMS d/b/a �y� -
REJOICE, INC., °
Defendant. co
MOTION FOR DISCOVERY SANCTIONS FOR
FAILURE TO OBEY COURT ORDER TO ANSWER
AND NOW, this 19th day of August, 2013, comes Plaintiff, Seligman, Friedman &
Company, P.C., by and through its counsel, Glenn J. Smith, Esquire, and CGA Law Firm, and
files this Motion for Discovery Sanctions as a result of the failure of, Defendant, Tonya Williams
d/b/a Rejoice, Inc., to comply with this Honorable Court's July 31, 2013 Order Granting
Plaintiff s Motion to Compel Interrogatories in Aid of Execution and in support thereof avers as
follows:
1. Plaintiff, Seligman, Friedman& Company, P.C., is a Pennsylvania professional
corporation located at 235 St. Charles Way, Ste. 250, York, PA 17402.
2. Defendant,Tonya Williams is an individual with an address of 1820 Linglestown
Road, Harrisburg, Pennsylvania 17110.
3. On or about March 8, 2013, Plaintiff served on Defendant its First Set of
Interrogatories in.Aid of Execution Addressed to Defendant.
4. Pursuant to Pa.R.C.P. 4006(a)(2) and 4009.12(a)(1), Defendant's responses and
objections, if any, to said discovery were due on or about April 7, 2013.
5. Defendant failed to respond to the First Set of Interrogatories by April 7, 2013.
(00735925/1)
6. On April 12, 2013, Plaintiff notified Defendant of her failure to comply with the
Pennsylvania Rules regarding discovery and requested that Defendant respond to the Plaintiff s
Interrogatories without the Court's intervention.
7. Defendant failed and/or refused to respond to Plaintiff in any capacity.
8. On or about July 23, 2013, Plaintiff filed a motion to compel discovery to which
this Honorable Court issued an Order dated July 31, 2013 therein directing Defendant to provide
full and complete answers to said Interrogatories within 10 (10) days of the date of its Order or
suffer as this Honorable Court deems just and proper.
9. Defendant has neglected, failed and refused to supply answers to said
Interrogatories despite this Honorable Court ordering and directing her to do so.
10. Plaintiff respectfully requests that this Honorable Court approve the proposed
order annexed hereto.
11. Defendant has been unresponsive to Plaintiff and, therefore, has been unable to
confer with all interested parties in order to attempt a resolution of this matter.
12. Defendant has been unresponsive to Plaintiff and, therefore, has not concurred
with the filing of this Motion to Compel.
WHEREFORE, Plaintiff, Seligman, Friedman & Company, P.C., respectfully requests
that this Honorable Court approve the proposed order annexed hereto and enter any and all other
such relief as is deemed just and necessary.
(00735925/1)
Respectfully Submitted,
CGA Law Firm
By:
Glenn J. Smith ui
• urt I.D. 859
York, Pennsylvania" 7401
Telephone: (717) 848-4900
Facsimile: (717) 843-9039
GSmith @cgalaw.com
Counsel for Plaintiff
(00735925/1)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
SELIGMAN, FRIEDMAN &
COMPANY, P.C., Docket No. 11-7432
Plaintiff,
V. :
TONYA WILLIAMS d/b/a :
REJOICE, INC.,
Defendant.
CERTIFICATE OF SERVICE
I hereby certif y that on this
/qday of August, 2013, a copy of the Motion for Discovery
Sanctions for Failure to Obey Court Order to Answer Interrogatories in Aid of Execution was
served upon the following party by first class mail, and postage prepaid:
Tonya Williams
1820 Linglestown Road
Harrisburg, PA 17110-3339
This Certificate is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
CGA Law Firm
By:
Samantha N. Ewing, Paralegal to
Glenn J. Smith, Esquire
{00735925/1} _
COURT OF COMMON PLEAS C=
CUMBERLAND COUNTY, PENNSYLVANIA =rn rncu
�r -s SELIGMAN, FRIEDMAN&
COMPANY, P.C., Docket No. 11-7432 r-=
Plaintiff,
V. 511
cn
t'J
TONYA WILLIAMS d/b/a
REJOICE, INC.,
Defendant.
ORDER GRANTING PLAINTIFF'S MOTION FOR SANCTIONS
AND NOW, thisA70day o*U46 2013, upon consideration of Plaintiffs
Motion for Sanctions, it is hereby ORDERED that the motion is GRANTED.
Befendetit, +en!a Wiiiitm"s, shrr*rr 2r-fttty ftne Of$20.00 LO 171e 77 oT F!aintiff ntil
;;'44 4ho pr-iwr of-d— of this eetrt reetaiii..'r, fali I nupl-CR: 7115"S to
i @ffega4efi@s i-40 R_i_d_ @_f.@_4HW'*48ft6 C-ennsei feel of$;4Q.49-ffe W#Vftrde++" Pivifyti+��st
Dofen4attt as @@mpe"smian for 0ve mid rmeesning-4_ gotifts@i foo&.8
'i. 'i vvid'i.. ter tfo� da7"f-dic dute
4
Defendant is ordered to appear personally in Courtroom No. of the Cumberland
County Courthouse located at One North Courthouse Avenue, Carlisle, PA 17013 on the tl
day of 0azel—, 2013, at b.' A.m. to show cause why she should not be found in
contempt of the prior order and subject to further sanctions,which may be imposed at that time.
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BY THE..GQLURT:
L
4' fm J.
_77
(0073592511)
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SELIGMAN, FRIEDMAN & IN THE COURT OF COMMON PLEAS OF
COMPANY, P. C. , CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
•
V.
•
TONYA WILLIAMS d/b/a
•
REJOICE, INC. ,
Defendant NO. 11-7432 CIVIL TERM
IN RE: MOTION FOR SANCTIONS
ORDER OF COURT
AND NOW, this 4th day of October, 2013, at the
request of the Plaintiff, hearing on the Motion for
Sanctions is continued generally to be rescheduled at
Plaintiff' s request .
By the Court,
Edward E. Guido, J.
Glenn J. Smith, Esquire
CGA Professional Center
135 North George Street
York, PA 17401
For the Plaintiff
,/'lronya Williams
1820 Linglestown Road r•s
Harrisburg, PA 17110
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