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HomeMy WebLinkAbout04-4239COMMONWEALTH OF PENNSYLVANIA Oq - ?a3? _' ?tL (?/j?^??'??s? a3?? COUNTY OF: CUMBERLAND NOTICE OFJUDGMENt/TRANSCRIPT FM-9 DistNOPLAINTIFF: CIVIL CASE 09 3-03 I NAME antl ADDRESS Name: Hon GREAT SENECA FINANCIAL CORP SUSAN K. DAY 267 E MARKET ST Add,oss: 229 MILL STREET, BOX 167 YORK, PA 17403 MT. HOLLY SPRINGS, PA Telephone (717 486-7672 17065 GREAT SENECA C/O WOLPOFF&ABRAMSON 267 E MARKET ST YORK, PA 17403 L VS. J DEFENDANT: NAMEentl ADDRESS rRUMFORD, MICHELLE A 20 EAST ST APT/STE 11 MT HOLLY SPRINGS, PA 17065 L J DocketNo.: CV-0 000116-04 Date Filed: 4/23/04 I- THIS IS TO NO IFY YOU THAT: j Judgment,: -DEFA7r'.T TrmGMRNm prgF X? Judgment was entered for: (Name) r.RFAm 1 --Sxr,4 .srA FTNAAWTAr MRP X? Judgment was entered against: (Name) R13MFr7Rn MTC'HRT T R A i in the amount of $ 11 S1 on: (Date of Judgment) 9/0711114 Defendants are jointly and severally liable. i (Date & Time) ?P 11 Damages will be assessed on: D This case dismissed without prejudice. lease $ Amount of Judgment ? Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 $ Portion of Judgment for physical damages arising out of residential Judgment Costs Interest on Judgment Attorney Fees Total Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ 1, 1311.51 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 THE 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 DISTRICT JUSTICES, 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 DISTRICT JUSTICE. 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 DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. A- Date District Justice I certify that this is a tr a nd corre copy of the rec proceedin s co taining the judgment, 715?`?D District Justice My commission expires first Monday of January, 2010 . SEAL AoPC ais-os DATE PRINTED: 6/08/04 9:38:31 AM 54 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ? NO. ?+)l1 l?II?I?r GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF FORWARD PROPERTIES, ASSIGNEE OF ORCHARD BANK P.O. BOX 1651 ROCKVILLE, MD 20849 Plaintiff VS. CIVIL ACTION - LAW MICHELLE A RUMFORD 20 EAST ST APT 11 MT HOLLY SPGS PA 17065-1731 Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT TO: MICHELLE A RUMFORD 20 EAST ST APT 11 MT HOLLY SPGS PA 17065-1731 You are hereby notified tJiat the following ORDER, DECREE or JUDGMENT has been entered against you on A a a Kta 0U) in accordance with the provisions of Pa. R.C.P. 236. ??- ( ) Decree Nisi in Equity ( ) Final Decree in Equity ( ) Judgment of ( ) Confession ( ) Verdict ( ) Default ( ) Non-suit ( ) Non-pros ( ) Arbitration Award ( ) Judgment is in the amount of $ plus costs. ( X ) District Justice transcript of judgment in civil action in the amount of $ 1311.51 , plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Pennsyl vania Department of Transportation. By: Prothono tary If you have any questions rggarding this Notice, please contact the filing party. .1 11 Amy F. Doyl #871*2 / Daniel F. Wolfson #20617 Bruce H. Ch rkis #18637 / Philip C. Warholic #86341 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 267 East Market Street, York, PA 17403 (717) 846-1252 (This Notice is given in accordance with Pa. R.C.P. 236.) DJNTC/PANOJ W&A FILE NO. 116823737 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. C)14 -)qa? GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF FORWARD PROPERTIES, ASSIGNEE OF ORCHARD BANK P.O. BOX 1651 ROCKVILLE, MD 20849 Plaintiff VS. MICHELLE A RUMFORD Defendant(s) CIVIL ACTION - LAW AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND 1, Amy F. Doyle, Esquire, being duly sworn according to law, depose and say that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief Defendant, MICHELLE A RUMFORD , above-named, is over 21 years of age; is last known to reside at MO HEAST OLLY S SP S T P11 A 17065-1731 County of York, Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act and its Amendments. 1/1 :.. ?. NIA b'4c ( Y ? y ?3, 2007 r;y? Amy F. Doy1 - tr„•...... Daniel F. lfson #20617 Bruce H. Cherkis #18837 Philip C. Warholic #86341 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 267 East Market Street York, PA 17403 (717) 846-1252 Counsel for Plaintiff ?J 20 0 SWORN and SUBSCRIBED to before me this day of tr, Notary Public PNMAFF/PANOJ W&A FILE NO. 116823737 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF FORWARD PROPERTIES, ASSIGNEE OF ORCHARD BANK P.O. BOX 1651 ROCKVILLE, MD 20849 Plaintiff Vs. MICHELLE A RUMFORD Defendant(s) I, hereby certify that GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF FORWARD PROPERTIES, ASSIGNEE OF ORCHARD BANK P.O. BOX 1651 ROCKVILLE, MD 20849 and certify that the last known address of the within Defendant(s) is: MICHELLE A RUMFORD 20 EAST ST APT 11 MT HOLLY SPGS PA 17065-1731 Amy F. Doyle 7062 Daniel F. Wol son x{20617 Bruce H. Cher is #18837 Philip C. Warholic #86341 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 267 East Market Street York, PA 17403 (717) 846-1252 Counsel for Plaintiff No OV - , 'Uj CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE PA. R.C.P. 236 the precise residence of Plaintiff is: PCRES/PANOJ W&A FILE NO. 116823737 ell 112.1 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF FORWARD PROPERTIES, ASSIGNEE OF ORCHARD BANK 'P.O. BOX 1651 ROCKVILLE, MD 20849 Plaintiff VS. MICHELLE A RUMFORD 20 EAST ST APT 11 MT HOLLY SPGS PA 17065-1731 ` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JUDGMENT NO. 044239 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Defendant (s) I To the Prothonotary: PLEASE ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of CUMBERLAND COUNTY, Pennsylvania; (2) against, MICHELLE A RUMFORD 20 EAST ST APT 11 MT HOLLY SPGS PA 1706 -1731 Defendant (s) ; (3) and against, WACHOVIA BANK ` 604 E HIGH ST I CARLISLE PA 17013-2661 Garnishee(s); (4) and index this writ (a) against, MICHELLE A RUMFORD Defendant (s) and (b) against, WACHOVIA BANK , 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) *** GARNISH ONLY *** You are directed to attach the property of the Defendant(s) not levied upon in the possession of WACHOVIA BANK 604 E HIGH ST CARLISLE PA 17013-2661 Garnishee (s) All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons,and safe deposit boxes. Amount due $ 1311.51 Interest from 06/07/2004 To Be Determined At an interest rate of 6% per year Total $ 1311.51 Plus costs & interest Dated: f Amy F. Doyl / IIA 62 / Daniel F. Wolfson #20617 Philip C. W rholic #86341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Ronald M. Abramson #94266 / Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection ILAAn Tr;ndla Road. 3rd Floor_ rzin- W i l VA t'7n" ?-71 70 2, Q t wv ` ?T W7 V 41A M vi c? r-zs .rw a WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 04-4239 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF FORWARD PROPERTIES, ASSIGNEE OF ORCHARD BANK, Plaintiff (s) From MICHELLE A. RUMFORD, 20 EAST ST APT 11, MT HOLLY SPGS, PA 17065-1731 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of WACHOVIA BANK, 604 E HIGH ST., CARLISLE, PA 17013-2661 -- ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. 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 $1311.51 L.L. $.50 Interest FROM 6/07/04 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Atty Paid $37.25 Plaintiff Paid Date: SEPTEMBER 28, 2006 (Seal) Due Prothy $1.00 Other Costs E!az?' Curti R. ong, Pro tary By: Deputy REQUESTING PARTY: Name AMY F. DOYLE, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, 312D FLOOR CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87062 SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION COURT OF COMMON PLEAS COUNTY OF CUMBERLAND vs. MICHELLE A. RUMFORD and : NO. 04-4239 WACHOVIA BANK, N.A., GARNISHEE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Wachovia Bank, N.A., Garnishee, in the above-captioned matter. JON C. SIN Attorney # Garnishee Date: Cy"? C:3 - :if r C ) MM Fn co It l ? 3 ? _ "L7 iri ,.==? P s ?? q( SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION COURT OF COMMON PLEAS COUNTY OF CUMBERLAND vs. MICHELLE A. RUMFORD and NO. 04-4239 WACHOVIA BAND, N.A., GTARNESHF.F. TO: GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, Plaintiff 1. No. 2. Yes, an account titled Michelle A. Rumford-Carranza with a zero balance. This account has been restricted pursuant to this writ. 3. - 6. No. 7. See answer to number two above. Dated: WACHOVIA Wachovia Bank. N.A. P.O. Box 8667 Philadvilihia. Pennsylvania 19101-866, Verification r Kathleen Gormley, being duly sworn according to law, deposes and says that she is the Writ of Execution Administrator of Wachovia Bank, N.A. Garnishee herein, and verifies that the statements made in the foregoing Answers to Interrogatories are true and correct to the best of her knowledge. Said Garnishee understands that false statements herein are made subiect to penalties of 18 Pa. C.S. Section 4904, relating to sworn falsification to :authorities. Kathleen Go Wiley Manager Dated: ?-4 _ ` T - [j. ) f ?. rn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, Plaintiff : No. 2004 - 4239 CIVIL TERM V. : Garnishment and Michelle A. Rumford, Execution of Judgment Defendant and Wachovia Bank, N.A., Garnishee PRAECIPE for ENTRY of APPEARANCE To the Prothonotary: Kindly enter my appearance on behalf of Michelle Rumford, Defendant. Papers may be served at the address set forth below: Suzanne Spencer Abel, Esq. Attorney ID # 202443 22 East Street, #6 Mt. Holly Springs, PA 17065 (717) 829-3206 n 1)71 Date: /U - 1 '0 '- uza ne Spencer Abel, Esq. r? C°) ? ? ? `? ? ?, ._;: ° gY , } f,` ? ? C. - C ? ? t '- ? :fit _.r -? ? ?C C„?"; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, Plaintiff V. Michelle A. Rumford, Defendant and Wachovia Bank, N.A., Garnishee No. 2004 - 4239 CIVIL TERM Garnishment and Execution of Judgment PETITION TO SET ASIDE EXECUTION PURSUANT TO Pa. R.C.P. 3121 v AND NOW, this R day of October, 2006, comes Defendant, Michelle Rumford-Carranza, by and through her attorney, Suzanne Spencer Abel, Esq., and who avers as follows: 1. 2. 3. 4. The Petitioner is Michelle Rumford-Carranza, defendant in the above captioned matter. She is represented by legal counsel, Suzanne Spencer Abel, Esq.. The Respondent is Great Seneca Financial Corp, A Maryland Corporation, Plaintiff in the above captioned matter. Respondent is represented by legal counsel, Amy Doyle, Esq.. Pursuant to a default judgment entered on June 7, 2004, by District Justice Susan Day, Respondent entered a Notice of Order, Decree, or Judgment in the Court of Common Pleas of Cumberland County on September 28, 2006. On or about September 30, 2006, Petitioner received a copy of the Notice of Order, Decree, or Judgment via regular mail. 5. After investigation by both Petitioner and her counsel, Petitioner believes and, therefore, specifically avers that: a. Petitioner received neither notice nor service of the initial complaint filed with District Justice Susan Day, and therefore, was precluded from defending the underlying claim; b. Petitioner received neither notice nor service of the hearing before District Justice Susan Day held on June 7, 2004, and therefore, was precluded from attending the hearing and defending the underlying claim; c. Petitioner received neither notice nor service of the subsequent default judgment before District Justice Susan Day ordered on June 7, 2004, and therefore, was precluded from filing a timely appeal; d. Petitioner has never been contacted by anyone, including any of the successor Plaintiffs or their counsel, regarding any attempt to collect the default judgment; e. Petitioner has never had an account with any of the named successor Plaintiffs. WHEREFORE, Plaintiff respectfully requests this Honorable Court to issue a Rule to Show Cause and enter a temporary Order Staying Execution of the Judgment pending a hearing on the matter. Respectfully submitted, Suzanne Spencer Abel, Attorney at Law Page 2 mot )io )mffw;;;;& Suza a Spe r Abel, Esq. Attor y ID #202443 22 East Street, #6 Mt Holly Springs, PA 17065 (717) 829-3206 spencer abel esQ _fastmail.fm Counsel for Petitioner, Michelle Rumford-Carranza Page 3 VERIFICATION I VERIFY that I have personal knowledge of all facts not of record set forth in the foregoing pleading, and that such statements are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: M) ?1 UZ? Ll? AJJJXZM1 _tr])?d Mich Rumford-C rranza CERTIFICATE OF SERVICE I certify that, concurrent with filing the foregoing Petition to Set Aside Execution Pursuant to Pa.R.C.P. 3121, 1 am this day serving a copy of same by First Class Mail, to the following: Counsel for Respondent: Amy Doyle, Esq. Wolpoff & Abramson, LLP 267 East Market Street York, PA 17403 Counsel for Garnishee: Jon Sirlin, Esq. Sirlin, Gallogly & Lesser, PC 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 Date: OL il'e i' Suz ne Sp cer Abe 22 East Street, #6 Mt. Holly Springs, PA 17065 (717) 829-3206 spencer abet esq a@fastmail.fm - tt Q -- F TP, iuN ; M OCT 31 2006,0f/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, Plaintiff No. 2004 - 4239 CIVIL TERM Garnishment and Execution of Judgment ORDER 22 CE ULE TO SHOW CAUSE AND NOW, this J day ofQetaber, 2006, upon consideration of the v. Michelle A. Rumford, Defendant and Wachovia Bank, N.A., Garnishee foregoing Petition, it is hereby ordered that 1. A Rule is used upon the Respondent to show why the Petitioner is not entitled to the relief requested; twenty e PLA4 4. "Ovi d® the day of /V gNt•,?N1.?-'?„ 2006, at -Y-0GO o'clock 40orpm, in Courtroom # 3 4th Floor of the Cumberland County Courthouse. 5. The Notice of Order, Decree, or Judgment Executing Judgment is temporarily stayed pending the hearing on this mattp-°`---, THE COURT: J. sac :c ?' l c- 1,oll9G5Z ' `'9 ?' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. Plaintiff VS. MICHELLE A. RUMFORD Defendant And WACHOVIA BANK Garnishee NO. 044239 CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, Wachovia Bank, discontinued, upon payment of your costs only. Dated: q ) a Amy F. Doyle #8 62 - Daniel F. Wolfso 20617 Philip C. Warholi #86341 Andrew C. Spears #87737 David R. Galloway #87326 Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 Ronald M. Abramson #94266 Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., Suite 300 Camp Hill, PA 17011 (717) 303-6700 W&A File No. 116823737 Respectfully Submitted, 2Z) F7 SHERIFF'S RETURN - GARNISHEE CASE NO: 2004-04239 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GREAT SENECA FINANCIAL CORP VS RUMFORD MICHELLE A And now SHARON LANTZ ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:40 Hours, on the 4th day of October , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT RUMFORD MICHELLE A hands, possession, or control of the within named Garnishee WACHOVIA BANK 604 E. HIGH ST CARLISLE, PA 17013 .00 .00 Cumberland County, Pennsylvania, by handing to JILL MANLEY (MANAGER) , personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION , in the and made the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscribed to So an s .00 R. Thomas Kline .00 Sheriff of Cumberland County 00 oo V1, Job (3/6 00/00/0000 before me this day of By L Deputy Sher A.D GREAT SENECA FINANCIAL CORP., : IN THE COURT OF COMMON PLEAS OF A MARYLAND CORPORATION, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. 04-4239 VS MICHELLE A. RUMFORD, Defendant and WACHOVIA BANK, N.A., Garnishee . ORDER OF COURT AND NOW, this 20th day of November, 2006, it appearing unclear whether or not the issue has been resolved or whether counsel for Plaintiff is even aware of today's hearing, the hearing scheduled in this matter on Defendant's Petition to Set Aside Execution Pursuant to Pennsylvania Rule of Civil Procedure 3121 is rescheduled for January 22, 2007, at 9:00 a.m. In the meantime, our prior order dated November 3, 2006, staying the Notice of Order, Decree or Judgement Executing Judgment shall remain in full force and effect. By t e Court, Edward E. Guido, J. ?-My F. Doyle, Esquire For the Plaintiff ?Suzanne Spencer Abel, Esquire For the Defendant /_0 n C. Sirlin, Esquire or the Garnishee :mlc N+! 14 Vf? L`?:??f BE R01 WV 8Z AON 90OZ AdVIONOv DW 3Hi dO 901A_?311J' r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, Plaintiff V. Michelle A. Rumford, Defendant and Wachovia Bank, N.A., Garnishee No. 2004 - 4239 CIVIL TERM Garnishment and Execution of Judgment PRAECIPE for WITHDRAWAL of PETITION TO SET ASIDE EXECUTION Kindly withdraw the Petition to Set Aside Execution filed by Defendant, Michelle Rumford-Carranza in the above referenced matter. Respectfully submitted, Spencer Abel Law Office b Su a ne Spe cer Abel, Esq. Atto ey ID #202443 22 East Street, #6 Mt Holly Springs, PA 17065 (717) 323-0046 spencer abel esg(c_fastmail.fm Counsel for Petitioner, Michelle Rumford-Carranza CERTIFICATE OF SERVICE I certify that, concurrent with filing the foregoing Praecipe to Withdraw the Petition to Set Aside Execution Pursuant to Pa.R.C.P. 3121, 1 am this day serving a copy of same by First Class Mail, to the following: Counsel for Respondent: Andrew Spears, Esq. Wolpoff & Abramson, LLP 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Counsel for Garnishee: Jon Sirlin, Esq. Sirlin, Gallogly & Lesser, PC 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 Date: Suz4jne Spender Abel ' 22 E st Street, #6 Mt. Holly Springs, PA 17065 (717) 323-0046 spencer abel_esq@fastmail.fm Z7 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing 18.00 Poundage 1.68 Advertising Law Library .50 Prothonotary 1.00 Mileage 4.40 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage .78 Garnishee TOT 9.00 ? iJl0-710.7 AL 85.36 Advance Costs: 150.00 Sheriff s Costs 85.36 64.64 Refunded to Atty on 10/24/07 So Answers, BY 1° Q? Cv? ,, fi..b --?Q? 9QQl .r ?3i i.0. e? Ge.Go9? 3?-- a Ult WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-4239 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF FORWARD PROPERTIES, ASSIGNEE OF ORCHARD BANK, Plaintiff (s) From MICHELLE A. RUMFORD, 20 EAST ST APT 11, MT HOLLY SPGS, PA 17065-1731 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of WACHOVIA BANK, 604 E HIGH ST., CARLISLE, PA 17013-2661-- ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. 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 $1311.51 L.L. $.50 Interest FROM 6/07/04 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Atty Paid $37.25 Plaintiff Paid Due Prothy $1.00 Other Costs Date: SEPTEMBER 28, 2006 (Seal) Curtis R. ong, Pro ry By: Deputy REQUESTING PARTY: Name AMY F. DOYLE, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, 3R" FLOOR CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87062 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORPORATION Plaintiff v. NO. 04-4239 CIVIL ACTION -LAW MICHELLE A RUMFORD .,°~ ~ '° ~ c -vim ° z Defendant(s) ~~~,.1 ~ --t ~~--,, -o ~ ~y ~ F rn ~ C? ENTRY OF APPEARANCE ~-~ ~~ z„ ~ ~ .._. ~ TO THE PROTHONOTARY: ~ = ~ --~ .c- ~~ ~, Kindly enter the undersigned as counsel for Plaintiff in the captioned matter. `` _~ Respectfully Submitted, By: } David R. Gall ay #87326 Fulton Friedm n & Gullace, LLP Counsel for Pl intiff Attorneys in the Practice of Debt Collection 130B Gettysburg Pike Mechanicsburg, PA 17055 Tel: (866) 563-0809 Fax: (585) 546-4241 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Entry of Appearance was served this date by depositing same in the Post Office, first class mail, postage prepaid, addressed as follows: MICHELLE A RUMFORD 20 EAST ST APT 11 MT HOLLY SPGS PA 17065-1731 ~O•~-1 FFG File #: 210103 David R. Ga Attorney ID Date I ill~i III III Iilll fl~l IIli IINI IINII Ilil INI IIIII Iln illl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORPORATION Plaintiff NO. 04-4239 ~, CIVII. ACTION -LAW ~ d .°,~, .~., -~ -`° -~ ~. o --~ © ~-~ MICHELLE A RUMFORD ~ ~ ! ~ Defendant(s) ~ ° -D z ° NOTICE OF ASSIGNMENT ~' ~ ~' ° ° --~ m "+ - b "~ N ~ The Judgment entered in this action was assigned for value from the above referenced Plaintiff to Palisades Acquisition XVI, LLC (hereinafter "Palisades"), 210 Sylvan Avenue, Englewood Cliffs, NJ 07632, for its use and at its risk, costs and charges in all respects. A copy of Palisades' Bill of Sale from the original Plaintiff to Palisades is attached hereto. Respectfully submitted, FULTON FRIEDMAN & GULLACE, LLP David R. Gallow y Attorney I.D. N 87326 130B Gettysbur Pike Mechanicsburg, 17055 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Notice was served this date by depositing same in the Post Office, first class mail, postage prepaid, addressed as follows: MICHELLE A RUMFORD 20 EAST ST APT 11 MT HOLLY SPGS PA 17065-1731 ,~ 10-51c~ David R. Ga oway Date Attorney ID #87326 ~~~o1a- R~ ~socv48 BII.L OF SALE THIS BILL OF SALE is dated as of March ~, 2007 between GREAT SENECA FINANCIAL CORPORATION organized under the laws of the State of Maryland, located at 700 King Farm Blvd, Rockville, MD 20850 ("Seller") and PALISADES ACQUISITION XV, LLC, a Delawaze limited liability company organized under the laws of the State of Delaware with its headquarters/principal place of business at 210 Sylvan Avenue, Englewood Cliffs, New Jersey 07632 ("Buyer"). For value received and subject to the terms and conditions of the Purchase and Sale Agreement (the "Agreement") dated February 5, 2007, between Buyer and the Sellers (as defined in the Agreement), Seller does hereby transfer, sell, assign, convey, grant, bargain, set over and deliver to Buyer, and to Buyer's successors and assigns, all of the accounts of Seller included in the Accounts described in Section 1.2 of the Agreement, attached hereto as Schedule I. This Bill of Sale is executed without recourse and without representations or warranties including, without limitation, any warranties as to collectibility, except as set forth in the Agreement. GREAT SENECA FWANCIAL CORPORATION, PALISADES ACQUISITION XV, LLC Seller Buyer ;~ By; n ,---~ (Signature) Name: Daniel Varner Title: President By: Name: Title: (Signature) iom-nisi o3rov2~~ zi ~ ~am.o2 Bna,, of sAil,i~ 'INlS BILL OF SALE is dated as of March ~^, 2U0? betwcea GRFA"f S;E~IF~CA FINANCIAL CURPURATIUN anganired under tfie lams of ttre State of Maryland, located at 70Q King Farm B}vd, RoCkrilk, MD .t085t~ (''Salter") and PAI.ISAC~S ACQ~ISI'I7ON XV, LLC, s f~lacaare limited liability company orgacuaed tmdor the lava of the State of Ddew~r: w~ its hcadquartets~'ltt'incipal placa of business at 210 Sylvan Avetnue. Englewood CLf.6, New Jersey it?632 t"Riryef For valve received and s-rbleLi to Iho tenn9 and cotldihOR1R OR' ttuC Purchase and Sale moment (the ",A~gt+ocrncnt") dated February 5, 2607. betvweetr Bayer acid the Seller3 (as defined in the Agnxmtnt), Setter does hamby trar~sfet, sell, aseiga, convey 1?~~ bargain, set o~ror and dditiZr to Hrryer, and to F3ryeCs suceesmrs eod assigns, ail of the accounts of Seller iatcluAed in the Acaou-xts described in Sectian L2 of the Agr+semem, attached hereto as Schedule 1. 'labs !Bill of Sala is ewecuted without tecourye and w~ihoul xepreseniations or warranties including, andkc+ut linnutation, any asarisnti~ as to collectibility, e~rcept as set forQa m the A,greenvrrt, GREA,7 Sk~IFC.A k7NANCIAL CORPORATION, PALISADfi5 ,A,CQUlSI7lO!v XY, l.I,C Seller Royer ~~ ~ ~' (Sig~ture) >v~: ,.isle: ~' - (Si Varna: ~ ~ iii ~~~ a'~~c: ~t4„a~, r r ,~~~~ car~x~zoo~iur~o+.aa BILL OF SALE Subject to the terms and conditions of that certain Sale Agreement, dated as of March ~, 2047 (the "Agreement"), between PALISADES ACQUISITION XV, LLC ("Seller"), a Delaware limited liability company organized under the Iaws of the State of Delaware with its headquarters/principal place of business at 210 Sylvan Avenue, Englewood Cliffs, New Jersey 07632 and PALISADES ACQUISITION XVI, LLC {"Buyer', a Delaware limited liability company organized under the laws of the State of Delaware with its headquarterslprincipal place of business at 210 Sylvan Avenue, Englewood Cliffs, New Jersey 07b32, and for the consideration set forth in the Agreement and for other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, Seller does hereby sail, convey, assign, transfer, set over and deliver to Buyer alI of Seller's right, title and interest in all of the Receivable Assets, which such Receivable Assets are more fully described in the Agreement: This Bill of Salc is being delivered pursuant to the Agreement and is subject to each of the terms set forth therein. This Bill of Sale shall be .binding upon, and shall inure to the benefit of, the parties hereto and their respective successors and assigns. Capitalized terms not otherwise defined herein shall have the meanings ascribed to such terms in the Agreement. [signature page follows) 10024+'81 03/01/2007 2112999.Oi IN WITNESS WHEREOF, Seller has caused this Bill of Sale to be executed on its behalf by its duly authorized officer as of this ~ day of March, 2007. PALIS~DE5 ACQUISITIC31v XV, LLC By: Name: .~ ; ~~. +~c /f . ~-.,.. Title: ,,+~?<r., ~./ r-.~ -z- COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A : ,, Maryland Corporation, • w .3 Plaintiff No. 2004-4239 Civil Term " ' rte'' co vs. ? °C: : CIVIL ACTION yr, � Michelle A. Rumford, : 2s c i Defendant : '" PRAECIPE FOR ENTRY OF APPEARANCE TO THE CLERK OF SAID COURT: Kindly enter my appearance on behalf of the Plaintiff in the above captioned matter. By: :1 ' . Mege, Esquire Atty. I.D. #81288 Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A • Maryland Corporation, • (4-,4 Plaintiff : No. 2004-4239 Civil Term r3 a r.' vs. : r.- , : CIVIL ACTION Michelle A. Rumford, : < -° ' Defendant c--; , n› CERTIFICATE OF SERVICE cr% I, Alan R. Mege, Esquire, hereby certify that on, October 30, 2013, I served Plaintiff s Discovery In Aid Of Execution by mailing same, first class,post prepaid to: Michelle A. Rumford, 15 Trine Ave., Mount Holly Springs, PA 17065. By: Mege, Esquir- Atty.. LD. #81288 Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, . Plaintiff • No. 2004-4239 Civil Term vs. • r CIVIL ACTION ..<> ry Michelle A. Rumsford, : <a -_, , Defendant • =c) CERTIFICATE OF SERVICE ..< C.11 - I,Alan R.Mege,Esquire,hereby certify that on December 30,2013,I served a letter of Intent to file a Motion to Compel Defendant's Answers to Interrogatories in Aid of Execution and request for Concurrence by mailing same,first class,postage prepaid to: Michelle A. Rumford, 15 Trine Ave., Mount Holly Springs, PA 17065. By: Al ' . Mege, Esquire Atty. I.D. #81288 Attorney for Plainti P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, Plaintiff No. 2004-4239 Civil Term c � vs. rri CIVIL ACTION , '- m r Michelle A. Rumsford, Defendant ° .° `-�C-,) cs PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS T(Y © T: INTERROGATORIES IN AID OF EXECUTION Y And now comes Plaintiff and submits the instant Motion to Compel, and in support thereof avers as follows: 1. Judgment for Plaintiff and against Defendant in the sum of$1,311.51 plus costs was entered in Cumberland County on August 25, 2004. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on October 30, 2013. 3. Pursuant to Pa.R.C.P. 4006 (a) (2), Defendant's responses to the Interrogatories were due within thirty days after they had been served, but none has been received as of the date of giving notice herein. 4. Counsel for Plaintiff has made a good faith effort to confer with Defendant, but Defendant has still failed to reply. 5. A copy of this Motion and proposed Order were mailed to Defendant, via first class mail on January 13, 2014. A certificate of Service is attached hereto. 6. As of January 13, 2014, Plaintiff has not received answers to the Interrogatories. 7. Plaintiff requires an Order pursuant to Pa.R.C.P. 4019 (a) (1) (I), compelling the Defendants to answer the Interrogatories. 8. No Judge has ruled upon other issues in this matter. 9. Concurrence with the Defendant has been sought and no response received. A copy of our letter of Intent and a Certificate of Service evidencing same is attached hereto as Exhibit"A". WHEREFORE, Plaintiff, requests that this Honorable Court grant its motion and enter an Order directing the Defendant to answer Plaintiff's Interrogatories within twenty(20) days or risk sanctions, pay fees in the amount of$100.00, as well as such other and further relief as the Court may deem just and appropriate. an R. Mege, E Attorney ID N . 81288 Attorney for Plaintiffs P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 -2- LAW OFFICES OF ALAN R. MEGE, ESQ. P.O. BOX 1426 70 EAST BROAD STREET BETHLEHEM, PA 18016-1426 Licensed in PA and NJ (610) 954-5393 Todd A. Johns, Esq. Of Counsel (610) 954-5395 FAX AlanM_Esq @juno.com December 30, 2013 Michelle A. Rumford 15 Trine Ave Mount Holly Springs, PA 17065 RE: Great Seneca Financial Corp v. Rumsford #2004-4239 Civil Term Dear Ms. Abel: Our office intends to file a Motion to Compel Defendant's Answers to Interrogatories In Aid of Execution. If you are opposed to this filing, you must contact our office by January 10, 2014. Please be advised that if we are not contacted by you, we will assume that you are in concurrance. I would appreciate your assistance in bringing this matter to an amicable conclusion. Should you have any questions or comments, please feel free to contact my office. Very truly-yours, Alan R.Mege ARM/llp Enc. FLE COPY This message is from a debt collector, this is an attempt to collect a debt, and any information obtained will be used for that purpose. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, Plaintiff No. 2004-4239 Civil Term • �r71 � ''�i= vs. r~ CIVIL ACTION cv o Michelle A. Rumsford, D° =° Defendant o CERTIFICATE OF SERVICE n I,Alan R.Mege,Esquire,hereby certify that on December 30,2013,I served a letter of Intent to file a Motion to Compel Defendant's Answers to Interrogatories in Aid of Execution and request for Concurrence by mailing same,first class,postage prepaid to: Michelle A. Rumford, 15 Trine Ave., Mount Holly Springs, PA 17065. By: f- AlarrR. M6ge, Esquire Atty. I.D. #81288 Attorney for Plainti P.O. Box 1426 70 East Broad St. d Bethlehem, PA 18016-1426 e�e�ve 6 TO �,e9e Pao SO.s P va ECJI I i COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, Plaintiff No. 2004-4239 Civil Term vs. CIVIL ACTION Michelle A. Rumsford, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on January 13, 2014, I served a true correct copy of Plaintiffs Motion to Compel Defendant's Answers to Interrogatories in Aid of Execution and proposed Order by mailing same, first class, postage prepaid to: Michelle A. Rumford, 15 Trine Ave., Mount Holly Springs, PA 17065. By: n R. Mege, Esquire Atty. I.D. #81288 Attorney for Plai iff P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 T _ 3 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A • Maryland Corporation, -' Plaintiff : No. 2004-4239 Civil Term „a3 rntr C-- rn} =rn yo. j x 7 x -•tr rr» vs. we : CIVIL ACTIONc, Michelle A. Rumsford, : z Defendant • y , ORDER AND NOW, this 4ay of , 2014, upon consideration of a3 �� ,��u�►2 Plaintiff's Motion to Compel, and Defendant's response thereto, if any, it is hereby ORDERED that Plaintiff's Motion is GRANTED; and 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 the date of this Order or appropriate sanctions will be imposed upon Defendant following application to this Court. I RTHER • ; P ; I • - -- - la la • ' tiff and • ! 4 . . . .- -sa ion or e prepara ion, service, an. presen a ion e . •en, !same-tm•- i• _• wenty 20) days of the date of this Order or appropria ion. , J. Distribution: Alan R. Mege, Esq., 70 E Broad St., Bethlehem, PA 18016 ✓ Michelle A. Rumford, 15 Trine Ave., Mount Holly Springs, PA 17065 t-ES / 1.€cL /A13// — �� COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • Great Seneca Financial Corp., A • Maryland Corporation, Plaintiff : No. 2004-4239 Civil Term • CIVIL ACTION ) Michelle A. Rumsford, Defendant • <p 4`= t C CERTIFICATE OF SERVICE . cn v I, Alan R. Mege, Esquire, hereby certify that on January 28, 2014, I served a true correct copy of this Court's January 23,2014 Order by mailing same,first class,postage prepaid to: Michelle A. Rumford, 15 Trine Ave., Mount Holly Springs, PA 17065. By: '-.. / n R. Mege, Esqu' - Atty. I.D. #81288 Attorney for Pia' tiff P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, Plaintiff VS. Michelle A. Rumford, Defendant : No. 2004-4239 Civil Term : CIVIL ACTION CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on March 5, 2014, I served upon Defendant, a true and correct copy of Plaintiff s Motion for Sanction, proposed Order, and a request for concurrance by mailing same, first class, postage prepaid to: Michelle A. Rumford, 15 Trine Ave., Mount Holly Springs, PA 17065. By: Mege, Esq Atty. I.D. #81288 Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, Plaintiff VS. : No. 2004 -4239 Civil Term : CIVIL ACTION Michelle A. Rumford, Defendant PLAINTIFF'S MOTION FOR SANCTIONS And now comes Plaintiff and submits the instant Motion for Sanctions, and in support thereof avers as follows: 1. Judgment for Plaintiff and against Defendant in the sum of $1,311.51 plus costs was entered in Cumberland County on August 25, 2004. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on October 30, 2013. 3. Pursuant to Pa.R.C.P. 4006 (a) (2), Defendant's responses to the Interrogatories were due within thirty days after they had been served, but none has been received as of the date of giving notice herein. 4. After notice, a Motion to Compel was filed and an Order entered on January 23, 2014 requiring Defendant, within twenty(20) days, to make full and complete answers to Interrogatories. A true and correct copy of the January 23, 2014 Order is attached as Exhibit »A» 5. As of March 5, 2014, Plaintiff has not received Defendant's answers to Interrogatories. 6. A copy of this Motion and proposed Order was sent to Defendant on March 5, 2014. A Certificate of Service is attached hereto. 7. Counsel for Plaintiff sent correspondence to Defendant on March 5, 2014, seeking concurrence, to which no reply was received, therefore Defendant is unopposed. A true and correct copy of the correspondence is attached hereto as Exhibit "B ". WHEREFORE, Plaintiff, requests that this Honorable Court grant its motion and Order that the Defendant shall pay a daily fine of $25.00 to the use of Plaintiff until Defendant complies with this Court's Order of January 23, 2014 and Defendant shall also pay $100.00 attorney's fees to Plaintiff within twenty (20) days of the date of this Order or appropriate sanctions will be imposed upon Defendant following application to this Court. an R. Mege, Es Attorney ID No. 288 Attorney for Plaintiff PO Box 1426 Bethlehem, PA 18016 -1426 (610) 954 -5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, Plaintiff VS. Michelle A. Rumsford, Defendant AND NOW, this A344ay of : No. 2004 -4239 Civil Term : CIVIL ACTION ORDER k /1LGC1s1 /7i 2014, upon consideration of -o C.i Plaintiff's Motion to Compel, and Defendant's response thereto, if any, it is hereby ORDERED that Plaintiff's Motion is GRANTED; and 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 the date of this Order or appropriate sanctions will be imposed upon Defendant following application to this Court. I RTHER agait}st-4 Gfenda • a. iff and a ton or e prepara ion, s - r t e, an presen a ion t to wenty ays o the date of this Order or approprta ton. Distribution: Alan R. Mege, Esq.,,70 E Broad St., Bethlehem, PA 18016 Michelle A. Rumford, 15 Trine Ave., Mount Holly Springs, PA 17065 , J. Received JAN 272014 . .Law Offices of Alan Mege LAW OFFICES OF ALAN R. MEGE, ESQ. P.O. BOX 1426 70 EAST BROAD STREET BETHLEHEM, PA 18016 -1426 Licensed in PA and NJ Todd A. Johns, Esq. Of Counsel Michelle A. Rumford 15 Trine Ave. Mount Holly Springs, PA 17065 (610) 954 -5393 (610) 954 -5395 FAX AIanM_Esq @juno.com March 5, 2014 RE: Great Seneca Financial Corp. v. Rumford #2004 -4239 Civil Term Dear Ms. Rumford: You are in violation of the Court's Order of January 23, 2014, directing you to provide answers to the interrogatories. Because of this, our office intends to file a Motion for Sanctions, a copy of which is enclosed. Please notify our office of your concurrance of same by March 19, 2014. If we do not hear from you by this time we will assume your concurrance. I appreciate your assistance in bringing this matter to an amicable conclusion. Should you have any questions or comments, please feel free to contact my office. ARM /11p Very truly yours, 11LE PIO C SPY This message is from a debt collector, this is an attempt to collect a debt, and any information obtained will be used for that purpose. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, Plaintiff vs. Michelle A. Rumford, Defendant : No. 2004 -4239 Civil Term : CIVIL ACTION ORDER AND NOW, this 3/ 'day of 4'7,112,C.A , 2014, upon consideration of Plaintiff's Motion for Sanctions, and Defendant's response thereto, if any, it is hereby ORDERED that Plaintiff's Motion is GRANTED; ainti un i l e en an comp ies wi is ou s u an. corn c� --n se of 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 and same shall be paid by Defendant within twenty (20) days of the date of this Ordei err --4. Alan R. Mege, Esq., 70 E. Broad St., Bethlehem, PA 18018 Michelle A. Rumford, 15 Trine Ave., Mount Holly Springs, PA 17065 is' i l 3 /.?/ //y =-11'1 , Judge 3 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, Plaintiff : No. 2004-4239 Civil Term VS. : CIVIL ACTION Michelle A. Rumford, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on April 2, 2014, I served upon Defendant, a true and correct copy of this Court's March 31,2014 Order by mailing same, first class, postage prepaid to: Michelle A. Rumford, 15 Trine Ave., Mount Holly Springs, PA 17065. By: Alan,R-:14ege, Esquire ./‘7. LD. #81288 Attorney for Plaint f P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 ;,` COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, Plaintiff VS. Michelle A. Rumford, Defendant : No. 2004-4239 Civil Term : CIVIL ACTION CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on May 8, 2014, I served a trt oma;) N.) correct copy of Plaintiffs Motion for Contempt and proposed Order by mailing same, first class, postage prepaid to: Michelle A. Rumford, 15 Trine Ave., Mount Holly Springs, PA 17065. By: lan R. Mege, Esquire Atty. I.D. #81288 Attorney for Plain ' f P.O. Box 1426 Bethlehem, PA 181016-1426 (610) 954-5393 c CD Y' COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, Plaintiff vs. Michelle A. Rumford, Defendant : No. 2004-4239 Civil Term : CIVIL ACTION ORDER OF COURT AND NOW, this 21ST day of NOVEMBER, 2014, a hearing on Plaintiff's Motion for Contempt is scheduled for TUESDAY, JANUARY 13, 2015, at 1:30 p.m. in Courtroom # 3 of the Cumberland County Courthouse, Carlisle, Pa. 17013. Plaintiff shall serve this notice of said hearing on Defendant by certified mail, restricted delivery, return receipt, or by personal service. Defendant's failure to appear at said hearing may result in the issuance of a bench warrant for her arrest. Distribution: , Judge 'Alan R. Mege, Esquire, 70 E. Broad St., PO Box 1426, Bethlehem, PA 18016-1426 Michelle A. Rumford, 15 Trine Ave., Mount Holly Springs, PA 17065 C p, e3 bvw., Ca ��G COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A : MARYLAND CORPORATION, Plaintiff : No. 2004-4239 Civil Term vs. MICHELLE A. RUMFORD, Defendant : CIVIL ACTION STIPULATION AND NOW, this 12th day of December, 2014, it is hereby stipulated and agreed by and between the parties: 1.. The parties agree that Defendant shall pay the judgment amount and costs 4 ' to Plaintiff by making three (3) monthly payments of a minimum of $15.00 per month, thereafter $25.00 per month, paid by Defendant and mailed to Plaintiff, with the first such monthly payment due by the end of December, 2014 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 Mege - EEC", and mailed, to Law Offices of Alan Mege, 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 the Court for filing, a fully executed Praecipe to Satisfy. 6. Defendant need not comply with outstanding discovery or sanctions Orders, where applicable, as long as Defendant is not in default of the payment arrangement. 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. Michelle A. Rumford (J Defendant 1,,11/7,1-0f+/ Alan R. Mege, Esq. Attorney for Plaintiff r COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A : MARYLAND CORPORATION, Plaintiff : No. 2004-4239 Civil Term vs.. MICHELLE A. RUMFORD, Defendant : CIVIL ACTION ORDER AND NOW, to wit, this G D1 day off/A A 2015, the Stipulation of the parties dated December 12, 2014, is hereby approved and made an Order of Court in the above -captioned matter. IT IS FURTHER ORDERED that the hearing set for January 13, 2015 is cancelled as moot. , J. Distribution: Alan R. Mege, Esquire, PO Box 1426, 70 E. Broad St., Bethlehem, PA 18016-1426 . Michelle A. Rumford, 15 Trine Ave., Mount Holly Springs, PA 17065 etop%es mai lei' I jC7//s' 3 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Great Seneca Financial Corp., A Maryland Corporation, Plaintiff vs. Michelle A. Rumsford, Defendant : No. 2004-4239 Civil Term : CIVIL ACTION C. r� PRAECIPE TO WITHDRAW PLAINTIFF'S MOTION FOR CONTEMPT TO THE CLERK OF SAID COURT: Please withdraw Plaintiff's Motion for Contempt and cancel the hearing set for January 13, 2015 at 1:30 p.m. with regard to the above -referenced matter. Date: January 13, 2015 Alin R. Mege, Es Attorney ID .. 81288 Attorney fPlaintiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393