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Home My WebLink About12-3520IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA ASSET ACCEPTANCE, LLC No: 1 o1. ? !Sc)D r A? Plaintiff 77 4 r, e? vs. CIVIL ACTION - LAW , ROBERT LEONARD Defendant(s) ?.r irv, c:: -a . PRAECIPE TO ENTER JUDGMENT ON MAGISTERIAL DISTRICT JUDGE'S TRANSCRIPT OF JUDGMENT In accordance with the transcript of the Magisterial District Judge which is attached hereto, enter judgment in favor of Plaintiff and against Defendant(s), in the sum of $4,380.86, which consists of $4,231.86 as principal and $149.00 as costs less payments of $0.00, plus interest thereon from the date of that judgment, as provided by law. DAVID R. GALLOWAY 87326 FULTON, FRIE N & GULLACE, LLP 130B GETTYSrRG, PIKE MECHANICSB PA 17055 (877) 386-5383 Attorneys for Plaint AFFIRMATION OF NO APPEAL As of the date of this filing a District Justice appeal has not been filed in the Court of Common Pleas of CUMBERLAND County. \ '? C DAVID R. G) Attorney ID # PA_0412 File No.: 11-32775 AY 6 If LL DD SW/ e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA ASSET ACCEPTANCE, LLC No: Plaintiff vs. CIVIL ACTION - LAW ROBERT LEONARD Defendant(s) CERTIFICATE OF SERVICE & LAST KNOW ADDRESS I, DAVID R. GALLOWAY, an authorized agent for FULTON, FRIEDMAN & GULLACE, LLP, hereby certify that a copy of the foregoing Praecipe to Enter Judgment on Magisterial District Judge's Transcript of Judgment was served this date by mailing same via first class mail, postage prepaid, addressed as follows to Defendant's last known address: ROBERT LEONARD 436 SPRING HOUSE RD CAMP HILL PA 170111452 Dated: PA 0412 File No.: 11-32775 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA ASSET ACCEPTANCE, LLC Plaintiff vs. ROBERT LEONARD Defendant(s) No: 1 a - 3S a0 ? v `' CIVIL ACTION - LAW NOTICE OF JUDGMENT Notice is hereby given that a Judgment in the above-captioned matter has been entered against you as follows: in the sum of $4,380.86, which consists of $4,231.86 as principal and $149.00 as costs less payments of $0.00, plus interest thereon from the date of that judgment, as provided by law. NOW, 2012, JUDGMENT I NT A OVE. Ob_ Prothonotary/Clerk, Civil Division By: Deputy I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: ROBERT LEONARD 436 SPRING HOUSE RD CAMP HILL PA 170111452 DAVID R. GAL OWAY Attorney ID #87126 PA 0412 File No.: 11-32775 t .4 4 COMIV`ON ALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IWO, Mag. Dist. No: MDJ-09-3-04 MDJ Name: Honorable Paula P. Correal Address: 5275 East Trindle Road Suite 110 Mechanicsburg, PA 17050 Telephone: 717-697-2201 Asset Acceptance, LLC 87326 c/o Fulton, Friedman & Gullace, LLP 130B Gettysburg Pike Mechanicsburg, PA 17055 Disposition Summary Docket No MJ-09304-CV-0000073-2012 Judgment Summary Participant Asset Acceptance, LLC 87326 Robert A Leonard Notice of Judgment/Transcript Civil Case Plaintiff Defendant Asset Acceptance, LLC 87326 Robert A Leonard Joint/Several Liability Individual Liability $0.00 $0.00 $0.00 $4,380.86 Asset Acceptance, LLC 87326 V. Robert A Leonard Docket No: MJ-09304-CV-0000073-2012 Case Filed: 3/1/2012 Disposition Disposition Date Default Judgment for Plaintiff 04/09/2012 Amount $0.00 $4,380.86 Judgment Detail (*Post Judgment) In the matter of Asset Acceptance, LLC 87326 vs. Robert A Leonard on 4/09/2012 the judgment was awarded as follows: Judament Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $4,231.86 $4,231.86 Filing Fees $0.00 $143.00 $143.00 Costs $0.00 $6.00 $6.00 Grand Total: $4,380.86 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. a. XCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOL ER 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 QQTHERWISE COMPLIES WITH THE JUDGMENT. d. LILA I M UaLe ....... $? Senior Magisterial District Judge P a P. Correa[ certi y t at t is is a true an correct copy o the record o the procee ing nt ning the e ?? WJ Date Magisterial District udge MDJS 315 Page 1 of 2 Printed: 05/16/2012 10:21:5 9A M /I/ vii i f\S.r1tRU C0U{'1 ? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson c!L;.0-0j=F I Sheriff Jody S Smith Lovllltr �t 114* t q OR T CNQZ��E Chief Deputy 2013 MAR 20 AM 9: 4 4 Richard W Stewart ' Solicitor 0 cEOFTHE$f~ERIFa CUMBERLAND COUNT' PENNSYLVANIA Asset Acceptance LLC vs. Case Number Robert Alan Leonard 2012-3520 SHERIFF'S RETURN OF SERVICE 03/14/2013 01:12 PM-Stephen Bender, Deputy Sheriff,who being duly sworn according to law, states that on March 14, 2013 at 1310 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Robert Alan Leonard, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania, by handing to Laurie Shultz, Customer Service Representative, 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 March 15, 2013 to Robert Leonard at 436 Springhouse Road, Camp Hill, PA 17011. STEPH N BENDER, DEPUTY SO ANSWERS, March 15, 2013 RbNW R ANDERSON, SHERIFF (C)Cour ty iuitc Sheriff.Te,:OSC` I', ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND,COUNTY,PENNSYLVANIA i ASSET ACCEPTANCE,LLC No: 12-3520 CIVIL Plaintiff `l�-Mf VS. CIVIL ACTION-LAW �,=' A X - 't ROBERT LEONARD � � Defendant(s) and < - ' MEMBERS 1 ST FEDERAL CU =' Garnishee. S INTERROGATORIES TO GARNISHEE To: MEMBERS I ST FEDERAL CU 5000 LOUISE DR ATTN: LEGAL DEPT MECHANICSBURG PA 17055 PURSUANT TO RULE 3253 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE YOU ARE REQUIRED TO FILE ANSWERS TO THE FOLLOWING INTERROGATORIES WITHIN TWENTY(20)DAYS AFTER SERVICE UPON YOU. FAILURE TO DO SO MAY RESULT IN JUDGMENT AGAINST YOU. A.The term"Defendant(s)"means the individual(s)or entity against whom the Writ of Execution was issued. B. "You" means the main office and all branch offices,representatives,employes and agents of your organization. r C.By service of the Writ of Execution upon you,all property of the Defendant(s)subject to attachment which is in your possession,custody or control is attached, including all property of the Defendant(s)which comes into your possession thereafter. D.These Interrogatories are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. E.Where exact information cannot be furnished,estimated information is to be supplied.When an estimate is to be used, it should be identified as such,an explanation should be given as to the basis on which the estimate is made,and the reason the exact information cannot be furnished. F.Where knowledge or information is possession of a party is requested,such request includes knowledge of the party's agents,representatives,and attorneys. PA_0511GE File No.:11-32775 INTERROGATORIES TO GARNISHEE RAR 15 2013 DEFENDANT(S)-ROBERT LEONARD SS#-209584276 1. At the time you were served or at any subsequent time did you owe the defendant(s)any money or were you liable to the defendant(s)on any negotiable or other written instrument,or did the defendant(s)claim that you owed the defendant(s)any money or were liable to the defendant(s)for any reason? NO 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 other persons any property of any nature owned solely or in part by the defendant(s)? N0 3. 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(s)or in which the defendant(s)held or claimed any interest? fi 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant(s)had an interest? No 5. At any time before or after you were served did the defendant(s)transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? 6. At any time after you were served did you pay,transfer or deliver any money or property to the defendant(s)or to any person or place pursuant to the defendant's direction or otherwise discharged any claim of the defendant(s)against you? 7. If you are a bank or other financial institution,at the time you were served or at any subsequent time did the defendant(s)have funds on deposit in an account in which funds were deposited 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 each account number and state the amount of funds in each account,and the entity electronically depositing those funds on a recurring basis. So UJq tt/) PA_0511GE File No.:11-32775 M f DEFENDANT(S)-ROBERT LEONARD NAR 2013 SS#- 209584276 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 the funds in deposit,not including any otherwise exempt funds,did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123?If so,identify each account. �I i 9. Please identify all accounts not listed in your answer to interrogatory No. 7,the amount of funds in each account,whether the funds are deposited electronically on a recurring basis and the entity electronically depositing those funds.If the defendant(s)maintains any of those accounts jointly with any other person,or persons,give their name,address and relationship to the defendant. N10 10. Are there any attorney's fees or processing fees charged by you against the defendant(s)or account(s)of the defendant(s)for the completion of this answer?If yes,outline the exact amount of any fees due and owing to the garnishee or the attorney for the garnishee for the preparation to the Answer. ND 11. Please provide the name,business address and business telephone of the person answering these interrogatories. "J 6,6— N�LA (i eC F'l nc cs ,l-S , �RA 1 -70515 LK1-- �eo z z- 12. Please provide the address and telephone number where future co documents pertaining to this case can be served on Garnishee. 50 00 LOu 'k 01- "\k, fC hCl�l1'rS iota 1 R4 !-7 0`J5 Ist MICHAEL B. VOLK#88553 RACHEL A.CLARK#311484 FULTON,FRIEDMAN&GULLACE,LLP 130E GETTYSBURG PIKE MECHANICSBURG,PA 17055 (877)386-5396 Attorneys for Plaintiff Please return your Answer to Interrogatories to counsel for Plaintiff at PO BOX 2123 WARREN MI 48090-2123. i PA_0511GE File No.:11-32775 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PQr, ASSET ACCEPTANCE,LLC No: 12-3520 m CD 3; � z rorn Plaintiff Z rte.. .�. Vs. CIVIL ACTION-LAW V-:D" ROBERT LEONARD ' ' .... Defendant(s) � PRAECIl'E TO DISCONTINi M ATTACHMENT TO THE PROTHONOTARY: Please discontinue the Writ of Execution filed against Garnishee,ME RS 1ST FEDERAL CU 5000 LOUISE DR ATM:LEGAL DEPT MECHANICSBURG P 7 5 n the referenced matter without prejudice. MICHAEL B. VOLK#88553 RACHEL A.CLARK#311484 FULTON,FRIEDMAN&GULLACE,LLP 6 KACEY COURT SUITE 203 MECHANICSBURG,PA 17055 (877)386-5396 Attorneys for Plaintiff CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Praecipe was served this da by epositing same in the Post Office,first class mail,postage prepaid,addressed as follows: ROBERT LEONARD 436 SPRING HOUSE RD CAMP HILL PA 170111452 MICHAEL B.VOLK Attorney ID#88553 RACHEL A.CLARK Attorney ID#311484 PA-0508G File No.:11-32775 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson f: z s.; —G s I'. _. Sheriff t+ rr�� >r, t" {;�r i �i�:~Pfrf 0"ff�it f:J Jody S Smith Chief Deputy SE � Richard W Stewart ""` Solicitor 0HCEOFTHES.VERWa 0UMBEiRLAND COUNTY PENNSYLVANIA Asset Acceptance LLC Case Number vs. 2012-3520 Robert Alan Leonard SHERIFF'S RETURN OF SERVICE 03/14/2013 01:12 PM -Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on March 14, 2013 at 1310 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Robert Alan Leonard, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania, by handing to Laurie Shultz, Customer Service Representative, 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 March 15, 2013 to Robert Leonard at 436 Springhouse Road, Camp Hill, PA 17011. 09/26/2013 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.46 SO ANSWERS, September 26, 2013 RON R ANDERSON, SHERIFF s c2 (c)CountySuite Sheriff,Te!eosoft,Inc. ASSET ACCEPTANCE, LLC VS. ROBERT LEONARD Plaintiff, Defendant TO THE PROTHONOTARY: IN THE MAGISTRATE COURT CUMBERLAND COUNTY, PA CIVIL ACTION No: 12-3520 PRAECIPE TO SUBSTITUTE COUNSEL Kindly WITHDRAW my appearance in the above. apto ed matter on behalf of PLAINTIFF, ASSET ACCEPTANCE, LLC. Date: FEB 1 9 2014 By: Michael Volk, Esq. Fulton, Friedman & Gullace, LLP Kindly ENTER my appearance in the above captioned matter on behalf of PLAINTIFF,ASSET ACCEPTANCE, LLC. Papers may be served at the address set forth below: Daniel J. Santucci, Esquire P.O. BOX 517 Essington, PA 19029 Telephone Number: (866) 300-8750 FEB 19 2014 Date: By: FFG 11-32775 / AA 11-2422350 EX_0012 Daniel J. Santucci Attorney for Plaintiff In-House Counsel Asset Acceptance, LLC Midland Funding, LLC