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