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HomeMy WebLinkAbout11-8935SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy .,, of ?irtr?Ger/i?t FILED-OFFICE (IF THP POTHf1OTAPY c?l? Pte- P? I A? JD', OB I`„ 1) ,i`.. Richard W Stewart Solicitor €f r ? _ ,:c!,t?€ Commonwealth Financial Systems, Inc. Number vs I 201Case1-8935 Robert S. Martens SHERIFF'S RETURN OF SERVICE 12/14/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Robert S. Martens, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Robert S. Martens. Request for service at 120 Second Street, Boiling Springs, Pennsylvania 17007 is vacant. However, The Carlisle Postmaster is still delivering the Defendants mail to this address. SHERIFF COST: $39.00 SO ANSWERS, December 14, 2011 RON R ANDERSON, SHERIFF r,c) Coun±ySuito jherft. Teioosoft. h:c. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff No. 11-8935 Civil Term VS. ROBERT S. MARTENS, Defendant CIVIL ACTION <'7 ? .. , o N e --z-F rn co -- v rte- ? ? ? -fib r- ? v .? ca c? TO THE CLERK OF SAID COURT: Please reinstate the complaint filed in the above-captioned matter. Date: December 27, 2011 Attorney ID No. 8 88 Attorney for Pla' tiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 ???1. ? Spa COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff VS. ROBERT S. MARTENS, Defendant TO THE CLERK OF SAID COURT: : No. 11-8935 Civil Term CIVIL ACTION PRAECIPE = c= M ... r c? -O r , ,. , C) zo ?? r- .. ? CO Please enter judgment in favor of Plaintiff Commonwealth Financial Systems, Inc. and against Defendant Robert S. Martens in the amount of $3,539.52 plus costs and interest at the rate of 18% per annum from May 25, 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 February 8, 2012. an R. ege, Esq. Attorney ID No. 288 Attorney for aintiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5.93 r,?} 14.50 P4 At ? a -71 '1\Ace N xck1 leck COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA. COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff No. 11-8935 Civil Term vs. ROBERT S. MARTENS, Defendant : CIVIL ACTION TEN DAY NOTICE TO: Robert S. Martens, 120 2nd St., Boiling Springs, PA 17007 DATE OF NOTICE: February 8, 2012 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 lan R. Mege, Es . Attorney ID .81288 Attorney for Plaintiff Law Offices of Alan R. Mege, Esq. P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 ECOPY IN THE COURT OF COMMON PLEAS OF BERKS Commonwealth Financial Systems, Inc. Plaintiff VS. Robert S. Martens COUNTY, PENNSYLVANIA NO. 11-8935 Civil Term 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 Robert S. Martens is over 18 years of age, resides at 120 2nd St., Boiling Springs, PA 17007 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 years of age, resides at and is employed is I, Alan R. Mtge, Esquire, do hereby verify that I am the attorney for Plaintiff, that 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 fled documents. The verifier understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, Signed: Dated: 2/7c,-/ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff No. 11-8935 Civil Term VS. ROBERT S. MARTENS, Defendant : CIVIL ACTION ( ) Notice is hereby given that a Judgment in the above captioned matter has been entered against you in the amount of $3,539.52 plus costs and interest on 2012. ( ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. Prothonotary By: If you have questions regarding this Notice, please contact the filing party: NAME: Alan R. Mege, 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.) COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff V. IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT CIVIL TERM ROBERT S. MARTENS, Defendant DOCKET NO: 2011-8935 IN RE: PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO INTERROGATORIES IN AID OF EXECUTION RULE TO SHOW CAUSE AND NOW, this 3RD day of May, 2012, upon consideration of Plaintiff's Motion to Compel Defendant's Answers to Interrogatories in Aid of Execution a rule to show cause is issued upon defendant to show cause, if any, why the relief requested by Plaintiff should not be granted. RULE RETURNABLE within 20 days from the service of this order. Distribution List: Alan R. Mege, Esq. 70 E. Broad Street Bethlehem, PA 18016 For Plaintiff By the Court, Thomas A. lacey M°° rn i;:= r-n -c -o rr! G -0 C-> Robert S. Martens 645 N. Mount Joy Street Elizabethtown, PA 17022 For Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff vs. ROBERT S. MARTENS, Defendant 11-8935 Civil Term' No °. . -cam ? T- CIVIL ACTION' -- CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on May 7, 2012, 1 served upon Defendant a true correct copy of this Court's May 3, 2012, Rule to Show Cause by mailing same, first class, postage prepaid to: Robert S. Martens, 645 N. Mount Joy St., Elizabethtown, PA 17022. By: an R. Mege, Esquire Atty. I.D. #812Vintiff Attorney for PI P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 COMMONWEALTH FINANCIAL SYSTEMS, INC., Plaintiff V. ROBERT S. MARTENS, Defendant IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT No. 2011-8935 CIVIL TERM IN RE: MOTION TO MAKE RULE ABSOLUTE ORDER OF COURT AND NOW, this day of June, 2012, upon consideration of Plaintiff's Motion To Compel Defendant's Answers to Interrogatories in Aid of Execution, and Plaintiff's Motion To Make Rule Absolute, and it appearing that Defendant has not filed a response of record, despite a Rule dated May 3, 2012 that directed Defendant to file a response on or before May 23, 2012, Plaintiff's Motion To Make Rule Absolute is hereby GRANTED to the extent that Defendant shall cause responses to any of Plaintiff's discovery requests still outstanding be produced within 30 days from the date of this Order. No further relief is granted at this time. 14- Ca. Thomas A. Placey C.P.J. Distribution List: ' ? Alan R. Mege, Esq. 70 E. Broad St. ` Bethlehem, PA 18016 N ?vr For Plaintiff A m <o ? Robert S. Mertens 645 N. Mount Joy St. Elizabethtown, PA 17022 ? Defendant, pro se Rfi?_u COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff : No. 11-8935 Civil Term vs. N CIVIL ACTION f ? r = ROBERT S. MARTENS, Ze Defendant -CJW ? C) s CERTIFICATE OF SERVICE - C4 I, Alan R. Mege, Esquire, hereby certify that on June 28, 2012, I sErve3 upen Defendant a true correct copy of this Court's June 26, 2012, Order by mailing same, first class, postage prepaid to: Robert S. Martens, 645 N. Mount Joy St., Elizabethtown, PA 17022. By: Ala ege`;T- squire tty. I.D. #81288 Attorney for Plaintiff P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV COMMONWE.~ILTH FINANCIAL SYSTEMS, INS. Plaintiff vs. ROBERT S. MARTENS, Defendant No. 11-8935 Civil Term CIVIL ACTION PLAINTIFF'S MOTION FOR SANCTIONS C"? ~ r~ ~ ...., r*ti1°~ ~ ' rat' Z~ r- c w ~~ ~ ~t~s G C7 -t~ p ZGa y 2 tV ar;': ~„ --i -t .~ . 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 $3,539.52 plus costs was entered in Cumberland County on February 22, 2012. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on Mazch 26, 2012. 3. Pursuant to Pa.R.C.P. 4006 (a) (2), Defendant's responses to the Interrogatories 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 June 26, 2012 requiring Defendant, within twenty(20) days, to make full and complete answers to Interrogatories. A true and correct copy of the June 26, 2012 Order is attached as Exhibit "A". 5. As of'August 28, 2012, Plaintiff has not received Defendant's answers to Interrogatories. 6. A copy of this Motion and proposed Order was sent to Defendant on August 28, 20 ~ 2. A Certificate of Service is attached hereto. 7. Counsel for Plaintiff sent correspondence to Defendant on August 6, 2012, seeking concurrence, and 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 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 June 26, 2012 and Defendant shall also pay $100.00 attorney's fees to~Plaintiff within twenty (20) days of the date of this Order or appropriate sanctions will be imposed upon Defendant following application to this Court. 2~1an R. Mege, Esq. Attorney ID No. Attorney for P nti: PO Box 14 Bethlehem, PA 18016-1426 (610) 954-5393 -2- i~ , COMMONWEALTH FINANCIAL SYSTEMS, INC., Plaintiff v, ROBERT S. MARTENS, Defendant ~~~$ IN THE COURT OF COMMON PLEAS 0 THE NINTH JUDICIAL DISTRICT No. 2011-8935 CNIL TERM IN RE: MOTION TO MAKE RULE ABSOLUTE RDER OF COURT AMD NOW, phis ~~,,? da of June 2012, upon consideration of PlaintifYs Motion . `iv Y ~ Compel Defendant's Answers to Interrogatories in Aid of Execution, and Plaintiff Motion To Make Rule Absolute, and it appearing that Defendant has not filed response of record, despite a Rule dated May 3, 2012 that directed Defendant to Fle response on or before May 23, 2012, Plaintiffs Motion Ta Make Ruie Absolute is herel GRANTED to the extent that Defendant shall cause responses to any of Plaintiff discovery requests still outstanding be produced within 30 days from the date of tr Order. No further relief is granted at this time. Distribution Lift: Alan R.Mege, Esq. 70 E. Broad St. Bethlehem, PA i$016 i~or Plaintiff Robert S. Mertens 645 N. Mount Joy St. Eiizabe~~town, PA 17022 Defendant, pro se Thomas A. Placey ~ C.~. N ~ rn z r N "~ o Z ~ .a i ~ cv . - bx ~ w ~; -i cn ~ ~ w ~ ?~ • .'. „~ 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 Robert S. Martens 645 N. Mount Joy St. Elizabethtown, PA 17022 RE: CFSI v. Martens Cumberland County # 11-8935 Civil Term Dear Mr. Martens: (610)954-5393 (610) 954-5395 F. AlanM_Esq@jun August 6, 2012 Enclosed please find a copy of Plaintiff's Motion for Sanctions, which we intend to file with the Court. Please provide your concurrence or non-concurrence with regard to said Moti by August 27, 2012. 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, ~1 :J ~+ lan R. Me ARM/clc Enc. 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. ~ ~c/` T r_ , , COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV. COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff vs. ROBERT S. MARTENS, Defendant No. 11-8935 Civil Term CIVIL ACTION CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on August 28, 2012, I served Defendant, a true and correct copy of Plaintiffl s Motion for Sanctions and proposed Order by maili same, first class, postage prepaid to: Robert S. Martens, 645 N. Mount Joy St., Elizabethtown, ~A 17022. ~_ By: Al ~ squir tty.I.D.#81288 Attorney for Plai tiff P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff No. 11-8935 Civil Terns t vs. rn CIVIL ACTION ROBERT S. MARTENS, Defendant ss CD-" Zc3, =-, r ORDER >psi AND NOW, this f j day of 2012, 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; IT IS FURTHER ORDERED that Defendant shall pay a daily fine of $25.00 to the use of Plaintiff until De:5endant complies with this Court's Order of June 26, 2012, requiring Defendant to make full and complete answers to the interrogatories; and 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 Order or appropriate sanctions will be imposed upon Defendant following application to this Court. BY THE COURT: Thomas A. Phdi ? Alan R. Mege, Es'q., 70 E. Broad St., Bethlehem, PA l nmon Pleas Judge ? Robert S. Martens, 645 N. Mount Joy St., Elizabethtown, PA 17022 0zp.es ma, l-ed g1&11 PY COUR_7~ OF COMMON PLEAS OF CiJMBER,LAND COUNTY, PENNSYLVANIA COMMONWEALTH FINANCIAL SYSTEMS, INC. `~-~~ Plaintiff No. I 1-8935 Civil ~f~erm ~ ~ --- ` ~-i _. w VS. : :. ~ ) ^"~ ~ ` CIVIL .ACTION .~ ~ : "= _ -: ; ROBERT S. MARTENS, - ~`. , -_ Defendant PLAINTIFF'S MOTION FOR CONTEMPT A~~d now conies Plaintiff and submits the instant Motion for Contempt, and in support thereof avers as follows: 1. .ludgment 1For Plaintiff and. against Defendant in the sum of $3,539.52 plus costs was entered in Cumberland County on February 22, 2012. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on March 26, 2012. 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 anal an Order entered on June 26, 2012 requiring :Defendant, within twenty(20) days, to make full and complete answers to Interrogatories. A true and correct copy of the June 26, 2012 Order is attached as Exhibit "A". 5. After notice, a Motion for Sanctions was presented to the Court and an Order entered on September 6, 2012, requiring Defendant to pay a fine of $100.00 to the use of the Plaintiff until Defendant compaies with the Court's Order of June 26, 2012, requiring Defendant to make full and complete answers to the interrogatories. Atrue and correct copy of the September 6, 2012, Order is attached as Exhibit `B". 6. As of October 18, 2012, the Plaintiff has yet to receive the answers to interrogatories, court awarded fees, or court imposed fines. 7. .A copy of this Motion and proposed Order were mailed to Defendant on October 18, 2012. A Certificate Of Service is attached hereto. WHEREFORE, Plaintiff, requests that this Honorable Court grant its motion and direct the Prothonotary to issue a bench warrant for Robert S. Martens, 645 N. Mount ,boy St., Elizabethtown, PA 1'7022, and deliver the warrant to the Sheriff and Defendant shall also pay $100.00 attorney's fees to Plaintiff within fourteen (l 4) days of the date of this Order or appropriate sanctions will be imposed upon Defendant following application to this Court. ,- ..._. ,_ _ _~ _- ;, _- ~ --elan R. Mege, Esq. Attorney ID No. 8128 Attorney for Pla~ltiff -2- COMMONWEALTH FINANCIAL sv~MS, Ilvc., . Plaintiff v. ROBERT S. MARTENS, Defendant ~~ ~ ~~ IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL. DISTRICT Na. 2011-8935 CiNIL TERM IN RE: MOTION TO MAKE RULE AeSplUTE ORDER OF COURT AND MOW, thls`~l day of June, 2012, upon consideration of Plaintiff's Motion To Compel Defendant's Answers to Interrogatories in Aid of F.xecu~an, and Plaintiff s Motion To Make Rule Absolute, and it appearing that Defendant has not filed a response of record, despite a Rule dated May 3, 2012 that directed Defendant to fife a response on or before May 23, 2012, Plaintiffs Motion To Make Rufe Absolute is hereby GRANTED to the extent that Defendant shaft cause responses to any of Plaintiff's discovery requests still outstanding be produced within 30 days from the date of this Order. No furt~er relief is granted at this time. c ~~-_ Distribution List: Alan R..Mege, Esq. 70 E. Broad St. Bethlehem, PA 18416 For Plaintiff Robert S. Mertens 645 N. Mount ]oy St. Elizabethtown, PA 17022 Defendant, pro se Thomas A. Placey C,~]. rn ~ w ~. ' x ~,-. ter' r ~ ~~ ~ ~ .v, o , ~v an ~ .~. ° d' 7 , b~ ~ ~~ --~ cn ~ w ri ~ ----- __- - ~~ .7 COLTIZ"I' OF CC-MMON PLEAS OF CUMBERLAND COUN°I~Y, PENNSYLVANIA b OMMONWEAI~TH FINANCIAL ~'~ a ^' ~ SYSTEMS, INC. a=~ ~ r'' `a _ .~ '-''"7 , Plaintiff No. 11-8935 Civi17'erm ~~ ~ ' ~~ A ~L =`~ :CIVIL ACTION D~ ° ~; ROBERT S. MARTENS, ~--, ~~ ~ _ ~-:> =.~ Defendant ~` ORDER '~L. AND NOW, this Cj day of 2012, 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; 1T IS FURTHER ORDERED that Defendant sh~t11 pay a daily fine of $25.00 to the use of PlaintifL until Defendant complies with this Court's Order of June 26, 2012, requiring Defendant to make full and complete answers to the interrogatories; and 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 Order or t appropriate sanctions will be imposed upon Defendz.t-.t following application to this Court. 13Y THE CO[.!RT: ~ ~ /~ Thomas A. P1'~L'~r AIan R. Mege, Esq., 70 E. Broad S#., Bethlehem, PA 1~'1'1f71UC1 P~edS .JUf~C~~' Robert S. Marten~~, 645 N. Mount Joy St., Elizabethtown, PA 17022 ~: TRUE.COPY FROM RECORD . • to Testimony whereof, 1 here unto set my hand and the seal of said Cou at Carlisle, i'a. This ~~ day of ~~ 20 la y;~~ ~APtrothonota COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYI_ VANIA COMMONWEALr]['H FINANCIAL SYSTEMS, INC. Plaintiff No. 11-8935 Civil Term vs. : CIVIL .ACTION ROBERT S. MAR~'ENS, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on October 18, 2012, I served a true correct copy of Plaintiff s Motion for Contempt and proposed Order by mailing same, first class, postage prepaid to: Robert S. Martens, 645 N. Mount Jo;y St., Elizabethtown, PA 17022. ___ y; - ~.. - -__~- ~ Alan R. Mege, Esquire Atty. LD. #81288 ,- Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 181016-1426 (610) 954-593 COMMONWEALTH FINANCIAL SYSTEMS, INC., Plaintiff v. ROBERT S. MARTENS, Defendant bae~ nu~~~~ IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT ~-, G r,.a ...~ ~ N 11-8935 CIVIL T1 0 "'v ' ~ ~ r IN RE: PLAINTIFF'S MOTION FOR CONTEMPT ~~' ORDER OF COURT v c-, Zp ~y C. -~ '-v 3 .~' cr AND NOW, this 1St day of November 2012, upon consideration of Defendants failure to Comply with this Court's Order of 26 June 2012 and 6 September 2012, a contempt sanction hearing is scheduled for 30 November 2012 at 9:30 a.m. in Courtroom No. 6 of the Cumberland County Courthouse, Carlisle, Pennsylvania. At that time the court will listen to argument as to what the appropriate sanctions for this disobedience shall be, to include but not limited to, consideration of judgment for Plaintiff. T Tho s . Placey C.P.J. Distribution List: ~/ Alan R. Mege, Esq. 70 E. Broad Street Bethlehem, PA 18016 / Robert S. Martens 645 N. Mount Joy Street Elizabethtown, PA 17022 ~. .-{ fTl -L3 rte; ~~ ~° c~ -r, -.. ~.. -'. ~~~•i ~~ C~~1 ~° ray COURT OF COMMON PLEAS OF CUMBERLAND COUN7['Y, PENNSY"LVANIA COMMONWEALTH FINANCIAL SYSTEMS, INC. Plaintiff No. ll-8935 Civil Term vs. ROBF,RT S. MARTENS, Defendant CIVIL AC"TION PRAECIPE TO WI'CHDRAW MOTION FOR CONTEMPT TO TTIE CLERK OF SAID COURT: Please withdraw the Motion for Contempt filed in the above captioned matter. Date: November 1.2012 ~_---= -~~, ,.~ ~ lA an R. Mege, Esq. Attorney ID No. &Y1,88 Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 18016 (:610) 954-5393 ' `~"\ In COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH FINANCIAL ~ .~~, SYSTEMS, INC. rn~w. ~ ~ ~' Plaintiff No. 11-8935 Civil Term ~~ ~ ~? • -~ o --sc~ ?~ - VS. .e;~' ~' C~-'s-; CIVIL ACTION ;~ ~, ~=~ c~ ~: ROBERT S. MARTENS, ~ ~' ~ ~ _ ` Defendant -<. . `-" ORDER AND NOW, to wit, this 3 p~ day of , 2012, the Stipulation of the parties dated November 5, 2012 is hereby approved and made an Order of Court in the above-captioned matter. Thomas A. Placed J' Common Pieas ]edge Distribution: ~a~ ~e Alan R. Mege, Esq., 70 E Broad St., Bethlehem, PA 18016 1e,, -"` ~ ~, I o21~ 1 ~~ Robert S. Martens, 645 N. Mount Joy St., Elizabethtown, PA 17022 /