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HomeMy WebLinkAbout12-4183Andrew Sklar, Esquire (ID#65332) Sklar - Markind 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 FILE NO.: F1100091 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Ford Motor Credit Company Plaintiff(s) V. TARA E LYTER Defendant(s) I No. )),q1D? I I Term I I I CIVIL ACTION I I I I I bVi-I (Applicable to real estate and personal property) 236 NOTICE OF FILING JUDGMENT () Notice is given that a judgment in the above captioned matter has been entered against you in the amount of on I , 201,,' (?) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. Clerk of Cou rotho ry Date: June 26, 2012 By: LAAoe'. eputy If you have any questions regarding this Notice, please contact the filing party: Andrew Sklar, Esquire (ID#65332) 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 (This Notice is given in accordance with Pa.R.C.P. No. 236) Andrew Sklar, Esquire (ID#65332) Sklar - Markind 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 FILE NO.: F1100091 Attorneys for Plaintiff wUMBERLAND COUNTY IN THE COURT OF COMMON PLEAS &?YNY COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FILED-OFFICE 1j": pROTHONOTAR t 2 t2 im -5 Pm 2' 31 Ford Motor Credit Company I No. )?-4) I I Term I I CIVIL ACTION I I I I I I e(vil Plaintiff(s) V. TARA E LYTER Defendant(s) PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Please issue judgment in the above matter against TARA E LYTER , Defendant(s) and in favor of Ford Motor Credit Company , Plaintiff, in the amount of $6,851.41 plus interest from February 23, 2012. Date: June 26, 2012 Andrew Sklar, Esquire (ID#65332) 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 ark ? 3? ?? ac ?.a to C9 -1 1-7 s73 Nlk? lei Andrew Sklar, Esquire (ID#65332) Sklar - Markind 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 FILE NO.: F1100091 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Ford Motor Credit Company I I No. Plaintiff(s) I I Term I V. TARA E LYTER Defendant(s) CIVIL ACTION CERTIFICATION OF JUDGMENT/ADDRESSES Andrew Sklar, hereby certifies: 1. That he is the attorney for the Plaintiff in the above matter. 2. That the Defendant(s) is/are TARA E LYTER . 3. That the last known address of the Defendant(s) is/are 124 WOODS DR LOT #28 MECHANICSBURG PA 17050. 4. The Plaintiff is Ford Motor Credit Company and their address is 1335 S. Clearview Avenue Mesa, AZ 85209. 5. That the foreign judgment entered by the Plaintiff, Ford Motor Credit Company , and against the Defendant(s), TARA E LYTER , in DISTRICT COURT, County of CUMBERLAND in the sum of $6,851.41 is valid, enforceable and unsatisfied. I hereby certify that the above statements are true. I am aware i any f the above statements are willful] false, I am subject to punishment. Date: June 26, 2012 Andrew Sklar, Esquire F llCOMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Notice of Judgment/Transcript Civil Case 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 Ford Motor Credit Company c/o Andrew Sklar, Esquire 102 Browning Lane Building B, Suite 1 Cherry Hill, NJ 08003 Disposition Summary Docket No MJ-09304-CV-0000014-2012 Judgment Summary Participant Ford Motor Credit Company Tara E. Lyter Plaintiff Defendant Ford Motor Credit Company Tara E. Lyter Joint/Several Liability Individual Liability $0.00 $0.00 50.00 $6,851.41 Ford Motor Credit Company V. Tara E. Lyter Docket No: MJ-09304-CV-000004-2012 Case Filed: 1/23/2012 Disposition Default Judgment for Plaintiff 02/23/2012 $6,851.11 Judgment Detail (*PostJudgment) In the matter of Ford Motor Credit Company vs. Tara E. Lyter on 2/23/2012 the disposition is Default Judgment for judgment was awarded f-11 s ows. Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amou Civil Judgment $0.00 $6,671.54 $6,671. Filing Fees $0.00 $143.00 $143. Costs $0.00 $5.00 $5 Server Fees $0.00 $31.87 $31. and Grand Total: $6,851. 1 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF A PEAL WITH THE PROTHONOTARY/CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS OTICE OF JUDGMENT/TRANSCRIPT 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 AY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FUL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. Senior Magisterial DistLict Judge PaAla P. Correa) Date / Aviagisterial District MDJS 315 Page 1 of 2 Printed: 04/05/2012 5:40:16PM _:.. ?. J b Ford Motor Credit Com an p Y Docket No.: MJ-09304-CV-0000014-2012 V. Tara E. Lyter L Participant List Plaintiff(s) Ford Motor Credit Company c/o Andrew Sklar, Esquire 102 Browning Lane Building B, Suite 1 Cherry Hill, NJ 08003 Defendant(s) Tara E. Lyter 124 Woods Drive Lot #28 Mechanicsburg, PA 17050 Complainant's Attorney(s) Andrew Sklar, Esq. C/O Andrew Sklar, Esquire 102 Browning In, Bldg B, Ste 1 Cherry Hill, NJ 08003 . W. M Ln =p L, MDJS 315 Page 2 of 2 Printed: 04/05/2012 5:40:16PM APR 1 1 20 2 { ,d IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Ford Motor Credit Company 1335 S. Clearview Avenue Mesa, AZ, 85209 Plaintiff(s) V. TARA E LYTER 124 WOODS DR LOT 928 MECHANICSBURG PA 17050 Defendant(s) I I No. 12-4183 CIVIL I I I CIVIL ACTION I PRAECIPE FOR WRIT OF EXECUTION (Money Judgment) I I I TO THE PROTHONATORY: (1) Issue writ of execution in the above matter, directed to the Sheriff of CUMBERLAND County, against TARA E LYTER , defendant(s) (2) and against, METRO BANK, 65 ASHLAND AVE, CARLISLE, PA 17013 garnishee. AMOUNT DUE INTEREST from: February 23, 2012 PLUS COSTS $6,851.41 $157.93 G Zrn C g70 r-- -V r ,-> n? _, ?4. Gb 1?cL 3 r.?s G?31-? . . s. - i111 r a.?S e.o Dated: July 16, 2012 FILE NO.: F1100091 ex--O M39 Andrew Sklar, Esquire (ID #65332) Lloyd S. Markind, Esquire (ID #52507) Daniel J. Santucci, Esquire (ID #92800) Attorneys for Plaintiff Sklar - Markind 102 Browning Lane, Building B, Suite 1 Cherry Hill, New Jersey 08003 (856) 616-8710 R `4 -2:;?,9-2?7 C,t.u4 o-1-` evccwdtW ?sruscl y WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 12-4183 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FORD MOTOR CREDIT COMPANY, Plaintiff (s) From TARA E. LYTER, 124 WOODS DR. LOT #28, MECHANICSBURG, PA 17050 (] )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 METRO BANK, 65 ASHLAND AVE., CARLISLE, PA 17013 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 $6,851.41 Interest FROM 2/23/12 - $157.93 Atty's Comm % Atty Paid $62.75 Plaintiff Paid Date: JULY 20, 2012 (Seal) L.L. $ .50 Due Prothy $2.25 Other Costs David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : ANDREW SKLAR, ESQ. Address: SKLAR - MARKIND 102 BROWNING LANE BUILDING B, SUITE 1 CHERRY HILL, NJ 08003 Attorney for: Plaintiff Telephone: 856-616-8710 Supreme Court ID No. 08003 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Jody S Smith Ronny R Anderson Sheriff Chief Deputy Richard W Stewart Solicitor SHERIFF'S RETURN OF SERVICE Ford Motor Credit Company vs. Case Number Tara Ernestine Lyter 2012-4183 07/26/2012 03:25 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on July 2Q3, 2012 at 1519 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Tara E. Lyter in the hands, possession, or control of the within named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 1701'3, by handing to Evie Birtch, 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 an July 27, 2012 to Tara E. Lyter at 124Woods Drive, Lot # 28, Mechanicsburg, PA 17050. SO ANSWERS, July 27, 2012 LZ RONW R ANDERSON, SHERIFF Ryan Burgett, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV. CIVIL ACTION - LAW Ford Motor Credit Company :No. 12-4183 CIVIL Plaintiff vs. : CIVIL ACTION TARA E LYTER Defendant INTERROGATORIES IN ATTACHMENT TO: METRO BANK , Garnishee: zrM 'ern cnr mac' C n -O -?r of Ion ^L Q ? C) r* A? 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. 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 him (her/them) on any negotiable or other written instrumen or did he (she/they) claim that you owed him (her/them) any money or were liable to him (her/them) for any reason? Defendant has less than $300 exemptic 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 persons any property of any nature owned solely or in part by the defendant? 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 or in which the defer held or claimed any interest? 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had any interest? 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 what was the consideration thereof? 6. At any time after you were served did you pay, transfer or deliver any money or property tot he defendant(s) or to any person or place pursuant to his (her/their) direction or otherwise discharge 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 any subsequent time did the defendant have funds on deposit in an account in which funds are n deposited electronically on a recurring basis and which are identified as being funds upon deposit are exempt from execution, levy or attachment under Pennsylvania or i law? If so, identify each account and state the reason for the exemption, the amount withheld under each exemption, the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. 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 fun on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 41 Pa.C.S § 8123? If so, identify each account. 9. How much is the value of any property in your possession belonging to the defendants; Date: July 16, 2012 Andrew Sklar, Esquire (ID 465332) Lloyd S. Markind, Esquire (ID#52507) Daniel J. Santucci, Esquire (ID #92800) Sklar - Markind 102 Browning Lane, Building B, Suite 1 Cherry Hill, NJ 08003 (856) 616-8710 Disclosure You are hereby advised, pursuant to the Fair Debt Collection Practices Act, that this firm is deemed to be a debt collector attempting to collect a debt and any information obtained will be used for that purpose. 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. Specialist 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. Daniel Santucci, Esquire (ID#92800) SKLAR ~ MARKIND 102 BROWNING LANE, BLDG B, STE 1 CHERRY HILL, NJ 08003 (856) 616-8710 Attorney for Plaintiff(s) .tom iY11~ ~(l~ / ~V'io ~~t~ ,.,; 2fl12 At1G 13 P~9 3: ~~ Our File Number: F1100091 ~~M~ERtA~t~ COUNTY pENNS YP~i~~'~LVANIA IN THE COURT OF COMMON PLEDS OF CUMBERLAND COUNTY, CIVIL ACTION -LAW Ford Motor Credit Company Plaintiff No. 12-4183 CIVIL TERM vs. CIVIL ACTION TARA E LYTER Defendant PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: PIeDSe dissolve the attachment DS to garnishee, METRO BANK, in the above captioned Date: August 3, 2012 a~ 2 ~~, So ~ a ~ aagb ~a~9~r? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Ford Motor Credit Company :No. 12-4183 CIVIL Plaintiff a =» r w i vs. rri CIVIL ACTION N TARA E LYTER c> Defendant -ra t , ?m)ey< C-) ca C-- 77 M' " (v INTERROGATORIES IN ATTACHMENT TO: METRO BANK , 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. At the time you were served or at any subsequent time did you owe the defendant(s) any money or were you liable to him (her/them) on any negotiable or other written instrument, or did he (she/they) claim that you owed him (her/them) any money or were liable to him (her/them) 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 persons any property of any nature owned solely or in part by the defendant? 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 the defendant held or claimed any interest? At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had any interest? 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 what was the consideration thereof? At any time after you were served did you pay, transfer or deliver any money or property tot he defendant(s) or to any person or place pursuant to his (her/their) direction or otherwise discharge any claim of the defendant(s) against you? If you are a bank or other financial institution, at the time you were served or any subsequent time did the defendant have funds on deposit in an account in which funds are 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 and state the reason for the exemption, the amount being withheld under each exemption, the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. 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 on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 41 Pa.C.S § 8123? If so, identify each account. How much is the value of any property in your possession belonging to the defendant(s)? Date: January 16, 2013 Andrew Sklar, Esquire (ID #65332) Lloyd S. Markind, Esquire (ID#52507) Jordan W. Felzer, Esquire (ID #38670) Sklar .., Markind 102 Browning Lane, Building B, Suite 1 Cherry Hill, NJ 08003 FILE NQ.: F1100091 (856) 616-8710 Disclosure You are hereby advised, pursuant to the Fair Debt Collection Practices Act, that this firm is deemed to be a debt collector attempting to collect a debt and any information obtained will be used for that purpose. 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 Specialist 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. (IGN URE) Lloyd S. Markind, Esquire (ID#52507) Jordan W. Felzer, Esquire (ID 438670) FILED-OFFICE SKLAR—MARKIND OF THE PROTHONOTARY 102 Browning Lane, Building B, Suite 1 2013 APR —8 PM 3'- 52 Cherry Hill,New Jersey 08003 (856) 616-8710 CUMBERLAND COUNTY Attorney for Plaintiff(s) PENNSYLVANIA Our File Number: F1100091 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Ford Motor Credit Company : No. 12-4183 CIVIL Plaintiff TERM vs. CIVIL ACTION TARA E LYTER Defendant PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Please dissolve the attachment as to garnishee, Metro Bank, in the above captioned action. Date: Andrew Sklar, Esquire (ID 465332) Lloyd S. Markind, Esquire (ID#52507) Jordan W. Felzer, Esquire (ID #38670) Attorneys for Plaintiff Sklar—Markind 102 Browning Lane, Bldg B, Suite 1 Cherry Hill, NJ 08003 (856) 616-8710 phone (856) 616-8716 fax a�� ti SHERIFF'S OFFICE OF CUMBERLAND COUNTY y R Anderson riff t �+ N i t H 0t w/�. �rtdtaPr�s^t�.t�} 2U1��l�f I ,ody S Smith Chief Deputy �_ p : Richard W Stewart CUMBERLAND COUNTY Solicitor w, �CE O _ PENNSYLVANIA Ford Motor Credit Company vs Case Number Tara Ernestine Lyter 2012-4183 SHERIFF'S RETURN OF SERVICE 01/31/2013 11:15 AM-William Cline, Deputy Sheriff,who being duly sworn according to law, states that on January 31, 2013 at 1114 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Tara E. Lyter, in the hands, possession, or control of the within named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania, by handing to Taryn 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 February 1, 2013 to Tara E. Lyter at 124 Woods Drive, Lot#28, Mechanicsburg, PA 17050. 09/04/2013 ,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 04, 2013 RON R ANDERSON, SHERIFF c} C011;tyS trite Sher:Y,7e eosof* nr„ a SHERIFF'S OFFICE OF CUMBERLAND COUNTY RAnderson dy S Smith �ku��r zit atr��ir � ,hief Deputy p.° 2013 SE'P -5 PM 2: 53 Richard W Stewart CUMBERLAND COUNTY Solicitor OFFICE OF TPE SPERIF= PENNSYLVANIA Ford Motor Credit Company vs. Case Number Tara Ernestine Lyter 2012-4183 SHERIFF'S RETURN OF SERVICE 07/26/2012 03:25 PM - Ryan Burgett, Deputy Sheriff,who being duly sworn according to law, states that on July 26, 2012 at 1519 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Tara E. Lyter in the hands, possession, or control of the within named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Evie Birtch, 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 July 27, 2012 to Tara E. Lyter at 124Woods Drive, Lot#28, Mechanicsburg, PA 17050. 09/04/2013 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: $88.40 SO ANSWERS, September 04, 2013 RbNW R ANDERSON, SHERIFF '2. 5- p C o e),;)S:ei 2 C!xintySui e Shenff,','e,oscft inc. 'e 1