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HomeMy WebLinkAbout12-2024 >` d ? P'd1i nF ?i ;. L1iJVf,?G ;r'l tL ? ;? 12xi 2 9 Pt! : 1 U C'(, M"ERLAJ,'D COU;gT" PEW Q`fLVANfA Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff Midland Funding LLC IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. ld- aXRI-f Civil7GM ALICE P QUINNONEZ Defendant : CIVIL ACTION - LAW Praecipe for Assessment of Damages To the Prothonotary: Kindly assess damages in the above matter as follows: District Justice Judgment $5,467.09 Less Post-Judgment Payments 675.00 Balance Due $4,792.09 Burton Neil WABociates. P.C. By: Wei in, Esquire i for Plaintiff In making this communication, we advise that our firm is ayebt collector. 431. as P6 ATT`1 a* -134 q ewn)yg? ?666 "ailed v y-7? COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ-09-3-02 MDJ Name: Honorable Vivian Cohick Address: 55 Penn Drive Newville, PA 17241 Telephone: 717-776-3187 Midland Funding Llc C/O Burton Neil Assoc. Pc 1060 Andrew Drive Suite #170 West Chester, PA 19380 Disposition Summary Docket No Plaintiff Defendant MJ-09302-CV-0000210-2008 Midland Funding Lie Alice P Quinnonez Judgment Summary Participant Joint/Several Liability Individual Liability Alice P Quinnonez $0.00 $5,467.09 Midland Funding Lie $0.00 $0.00 Midland Funding Llc V. Alice P Quinnonez Docket No: MJ-09302-CV-0000210-2008 Case Filed: 11/17/2008 Disposition Disposition Date Default Judgment for Plaintiff 01/22/2009 Amount $5,467.09 $0.00 Judgment Detail (`Post Judgment) In the matter of Midland Funding Lie vs. Alice P Quinnonez on 1/22/2009 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 $5,300.09 $5,300.09 Costs $0.00 $167.00 $167.00 Grand Total: $5,467.09 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 JUDGMENTITRANSCRIPT 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. tJ Date Magisterial District Judge Vivian Cohick certify that this is a true an correct copy o the record o the proceedings containing the judgment. Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed: 03/19/2012 1:20:10PM COMMONWEALTH OF PENNSYLVANIA COUNTY OF: Cumberland CIVIL COMPLAINT Mao. Dist. No.: 093-02 DJ Name: Hon. Vivian J. Cohick Adams: 27 W. Big Springs Rd, Box 155 Newville, PA 17241 T«eown.: 7171776-3187 PLAINTIFF: NAME and ADDRESS r Midland Funding LLC c/o Burton Neil & Associates, P.C. 1060 Andrew Drive, Ste. 170 tWest Chester, PA 19380 VS. DEFENDANT: NAME and ADDRESS rALICE P QUINNONEZ 3234 Ritner Highway LNewville PA 17241 Docket No.: " -A 110-ezq " Date Filed: 11 1 f-71 U Y A cow AMOUNT DATE PAID FILING COSTS $ ! / 7f 6 POSTAGE $ SERVING COSTS $ ! 1 CONSTABLE ED. $ ! I TOTAL $ ! ! Pa.R.C.P.D.J. No. 206 set s forth those Costs recoverable by the prevailing party. TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for $5.300.09 together with costs upon the following claim (Civil fines must include citation of the statute or ordinance violated): For past due credit card account balance on a Citibank USA credit card $5,300.09 Principal which account was acquired by Plaintiff. $.00 Interest 00 Credit $5,300.09 Balance I, Yale D. Weinstein. Esquire, Attorney for Plaintiff, verify that the facts set forth In this complaint are true and correct to the best of my knowledge, information and belief. This statement Is made subject to the penalties of Section 4904 of the Crimes Code (18 PA. C. S. § 4904) related to unworn falsification t 7*7/ Pursuant to Pa.R.C.P.M.D.J. Rule 207.1 (A) signature of counsel below acknowledg that h pla[ntiff in this proceeding. or Authorised ASeot) Plaintiff's Attorney: Yale D. Weinstein Attorney ID. NO. 89678 Address: 1060 An rew Drive, Suite 170 Telephone: 610-696-2120 West C ester, PA 19380 IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO, JUDGMENT MAY BE ENTERED AGAINST YOU BY DEFAULT. If you have a claim against the plaintiff which is within magisterial district judge jurisdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office at least five days before the date set for the hearing. If you are disabled and require reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. AOPC 30BA-05 Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff Midland Funding LLC Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 1 `a- ?a ?f LIA] ALICE P QUINNONEZ Defendant : CIVIL ACTION - LAW Rule of Civil Procedure No. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on '00 Prothono By: .? Deputy If you have any questions concerning the above, please contact: Yale D. Weinstein, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 Burton Neil & Associates, P.C. is a debt collector. Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff Midland Funding LLC 8875 Aero Drive Suite 200 San Diego CA 92123 Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. ALICE P QUINNONEZ 3234 Ritner Highway Newville PA 17241 : NO. Defendant :CIVIL ACTION - LAW Certification of Address and Affidavit of Non-Military Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment creditor and debtor. 2. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA) the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. Burton Neil & Associates, P.C. is a debt collector. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COt'NTY OF CUMBERLAND) NO 2012-2024 Civil CIVIL ACTION - LAW TO 1'HE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDLAND FUNDING LLC Plaintiff (s) From ALICE P. QUINNONEZ, 3234 RITNER HIGHWAY, NEWVILLE, PA 17241 (I )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 GARNISHEE(S) as follows: METRO BANK, 1130 CARLISLE ROAD, CAMP HILL, PA 17011 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paling any debt to or for the account of the defendant (s) and fi-om 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 DueS4,792.09 Interest FROM 1/22/09 - $1,044.31 Am's Comm Attu Paid Plaintiff Paid $62.75 Date: July 31, 2012 (Seal) I_.. L. S.50 Due Prothy 52.25 Other Costs i2v k 1 -- - David D. Buell, Prothonotary Deputy R1:QUESTING PARTY: Name : YALE D. WEINSTEIN, ESQUIRE Address: BURTON NEIL & ASSOCIATIONS, P.C. 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 Attorney for: PLAINTIFF "felephonc: 610-696-2120 Supreme Court 11) No. PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.C.P. § 3103 to 3149 MIDLAND FUNDING LLC 8875 Aero Drive Suite 200.. San Diego CA 92123 Plaintiff v. ALICE P OUINNONEZ 3234 Ritner Highway, Newville PA 17241 Defendant(s) METRO BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-2024 1 130 Carlisle, Road, Camp Hill, PA 17011 3 Garnishee(s) CIVIL ACTION -LAW C? rs.? rx; To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER 1. Directed to the Sheriff of Cumberland County, Pennsylvania 2. against- ALICE P QUINNONEZ Defendant(o 3. and against METRO BANK , Garnishee(s) 4. and index this writ (a) against (b) against Defendant(s) Garnishee(s) r ca C0 f o -; CD as a hs pendens against the real property of the defendant(s) in the name of the Garnishee(s) as folldws: (specifically describe property) NO LEVY - GARNISHMENT ONLY Serve interrogatories on garnishee at: 1130 Carlisle Road, Camp Hill, PA 17011 5. Amount Due $4,792.09 Interest from 01/22/2009 $1,044.31 Total $5,836.40* *Plus writ costs Dated: Jul,,24, 2012 Yale . ,Wein-sein, Esquire Atto o? for Plaintiff No'lF. Undcr paragraph t when the writ is directed to sheriff of another unty as authorized by Rule 3103(b). the county should be The firm of Burton Neil & Associates, P.C. is attempting to collect a debt. 10474" Q 31. aS U5 a "" a? ?. ?. s 16 C( .0 3Co V)a 0t' -- indicated. Under Rule 3103(c) a writ issued on a transferredjudgment ma ? be directed only to the sheriff of the county in which issdied. Paragraph 3 above should he completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 3104(x). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should be complete?,l onl} ii real property in the name of the garnishee is attached and indexing as a ]is pendens is desired. See Rule 3104(c11. Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO.89678 1060 Andrew Drive, Suite l 70 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff MIDLAND FUNDING LLC Plaintiff v. ALICE P QUINNONEZ 3234 Ritner Highway, Newville PA 17241 Defendant(s) METRO BANK Garnishee To: METRO BANK f il~~G-L1F~It;. .'~~ ~-~~ ~'~OT~QN~TA~;`~' ~~i2 Ql~G ! 3 PF4 3~ ! 3 i;.U~S~~N~.A~tD COUNTY P~NNSYLYAN'IA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV NO. 12-2024 CIVIL ACTION -LAW 1130 Carlisle Road, Camp Hill, PA 17011 ~ ~`-;~e+~ Interrogatories to Garnishee You are required to file answers to the following interrogatories within twenty (20) days service upon you. Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the defendant an~ money or were you liable to the defendant or any negotiable or other written instrument, or did ~ defendant claim that you owed the defendant any money or were liable to the defendant for any reason? No Accounts 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more otl~ persons any property of any nature owed solely or in part by the defendant? 3. If the answer to 1 and/or 2 is yes, please specify the nature of the property and, if the amount? 4. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or c: any interest? s ~ ~. At the time you were served or at any subsequent time did you hold as fiduciary any property in which defendant had an interest? 6. At any time before you were served did the defendant transfer or deliver any property to you or any person or place pursuant to your direction or consent and if so what was the consideratio therefor? I i i 7. At any time after you were served did you pay, transfer or deliver any money or prop rty to the defendant or to any person or place pursuant to the defendant's direction or otherwise disch rge any claim of the defendant against you? 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are depos'ted electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify ea h account and state the reason for the exemption, the amount being withheld under each exemptio and the entity electronically depositing those funds on a recurring basis. 9. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds on deposi ,not including any otherwise exempt funds, did not exceed the amount of the general monetary exem tion under 42 Pa.C.S. § 8123? If so, identify each account. ~ Burton~Veil Br,~AssgEiates, P.C. By' r~a~te i~. Weinstein, Bsquire The firm of Burton Neil & Associates, P.C. is attempting to ollect a debt. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Jennifer Hilbish (Name) Levy~ecialist of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. ~- SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~Q«pty of ~turr~~ f~f,A ~I~EC:r. `~E 8" ERIFF Jody S Smith Chief Deputy Richard W Stewart Solicitor `_ ~ 2 AI~C 13 P~ ~ ~ ~ Midland Funding, LLC Case Number vs. Alice P Quinnonez 2012-2024 SHERIFF'S RETURN OF SERVICE 08/08/2012 09:50 AM -John Hanner, Deputy Sheriff, who being duly sworn according to law, states that on Augus 8, 2012 at 0950 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and mo ies of the within named defendant, to wit: Alice P. Quinnonez, in the hands, possession, or control of the ithin named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 1701 , by handing to Taryn L. Walters, Store Manager, personally three copies of interrogatories together wit three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on 08-13-12 to Alice P. Quinnonez at 3234 Highway, Newville, PA 17241. SO ANSWERS, August 13, 2012 R ANDERSON, SHERIFF o~~, Deputy C) CeuntySuite Sheriff, Tpleosoft, Inc:. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Anderson I S Smith clef Deputy -1 kriffttttr1}144 FF kF f !? AUG 22 PM Ir?:.- PENNSr 1 b,,ANj Richard W Stewart Solicitor Midland Funding, LLC vs. Alice P Quinnonez Case Number 2012-2024 SHERIFF'S RETURN OF SERVICE 08/08/2012 09:50 AM - John Hanner, Deputy Sheriff, who being duly sworn according to law, states that on August 8, 2012 at 0950 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Alice P. Quinnonez, in the hands, possession, or control of the within named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Taryn L. Walters, Store Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on 08-13-12 to Alice P. Quinnonez at 3234 Ritner Highway, Newville, PA 17241. 08/22/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per request of plaintiffs attorney. SHERIFF COST: $88.38 SO ANSWERS, August 22, 2012 RON R ANDERSON, SHERIFF sPd . 00. 5 L L ;' ;Ufl i, n.-; Qf?ery 1_ iP19C6Q (t. 7M. t;} _ "riff-OF?f=??OrA[ 2012 AUG 23 AM 8: 05 CUMBERLAND COUNTY PENNSYLVANIA Burton Neil & Associates, P.C. By: Yale D. Weinstein, Esquire ID. NO. 89678 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff Midland Funding LLC Plaintiff V. ALICE P QUINNONEZ Defendant and METRO BANK Garnishee To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-2024 CIVIL ACTION - LAW Praecipe to Dissolve Attachment Dissolve the attachment against METRO BANK, garnishee. Burton Neil,& AW/ ialfes, P.C. By: Yale Weinstein, Esquire Atto v for Plaintiff The law firm of Burton Neil & Associates is a debt co 104574 o Pd a ck? ?o?aCo a9 9