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