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HomeMy WebLinkAbout13-6205 2156853 j - 0F F C GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE 2013 OCT 21 PH 3: 15 Identification No.: 41360 JOEL M. FLINK, ESQUIRE CUMBERLAND COUNTY Identification No.: 41200 PENNSYLVANIA 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351 -0500 UNIFUND CCR, LLC COURT OF COMMON PLEAS 10625 Techwoods Circle CUMBERLAND COUNTY Cincinnati OH 45242 VS. DOCKET NO. - b0lu CELESTE G HEDGES 45 COLGATE DR CAMP HILL PA 17011 PRAECIPE FOR ENTRY OF APPEARANCE TRANSFER OF JUDGMENT ASSESSMENT OF DAMAGES AND VERIFICATION OF ADDRESS(ES), VALIDITY AND NON MILITARY SERVICE TO THE PROTHONOTARY: Enter my appearance for the Plaintiff in the above matter; enter judgments in favor of Plaintiffs) against Defendant(s) on the duly authenticated copy of the magisterial district justice judgment hereto -- attached, entered in the jurisdiction noted therein, and assess damages as follows: $11,650.31 Judgment $229.81 Post Judgment Interest $.00 Post Judgment Costs $.00 Post Judgment Payments $11,880.12 Total Pursuant to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, I verify that: (1) the precise last known address(es) of the Plaintiff ; (s) and Defendant(s) are as above.; (2) that said judgments were entered by the Magisterial Court in the said jurisdiction in said amount with costs and interest due as noted, no part of which has been paid (except as noted) and which is valid, enforceable and unsatisfied; find a copy of which is attached hereto; (3) and that the Defendant(s) is (are) over 18 years of age and not in the military service of the United States or its allies or otherwise within coverage of the Soldier's and Sailors Relief Act of C�18g� Notice Au hi r F&q ��1 1940, as amended, and had (have civilian occupation(s). Date: �L A � FREDERIC I WE; ESQUIRE JOEL M. FLI , ESQUIRE DAMAGES ASSESSED AND JUDGMENT(S) ENTERED NS ABOVE NOTICES) GI "N UNDER PA. CIV.- 2 e " r� ". ' r f r= Pro 51roitl on 2156853 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351 -0500 UNIFUND CCR, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. ' vs. CELESTE G HEDGES 45 COLGATE DR CAMP HILL PA 17011 NOTICE Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above proceeding as indicated below. " Judgment by Default $11,880.12 /x / Money Judgment $$11,880.12 �L Judgment on Award of Arbitrators$ LL Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351 -0500 tm—j PROTHONOTARY Department of Defense Manpower Data Center Results as of: Oct -07 -2013 10:19:59 SCRA 3.0 r f' Status Deport •� ..� pursuant to Servicernembers Civil belief Act Last Name: HEDGES First Name: CELESTE Middle Name: G Active Duty Status As Of: Oct -07 -2013 On Active Duty On Active Duty Status Date Active Duty Start Dale Active Duty End Dale Status Service Component NA NA No NA This response reflects the Individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Dale Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HislHer Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Dale Order Notification Start Date Order Notification End Date Status Service Component NA NA I No I NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. 4 1131 )4. , Mary M. Snavely- Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http: / /www.defenselink .mil /faq /pis /PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his /her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds, All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN /date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: X455L99EDOABS10 5c��sS COMMONWEALTH. OF PENNSYLVANIA CA _ Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ- 09 -1 -01 Unifurld CCR. LLC._ MDJ Name: Honorable Charles A. Clement Jr. V Address: 920 Linda Lane Celeste G Hedges Camp Hill, PA 17011 Telephone: 717- 737 -3434 Joel Marc Flink, Esq. Docket No: MJ- 09101 -CV- 0000071 -2013 Gordon & Weinberg, PC Case Filed: 1/31/2013 1001 E. Hector Street Suite 220 Conshohocken, PA 19428 Disposition Summary Docket No Plaintiff Defendant Disposition Disposition Date MJ-091 01 -CV-0000071-2013 Unifund CCR. LLC Celeste G Hedges Default Judgment for Plaintiff 06/06/2013 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Celeste G Hedges $0.00 $11,650.31 $11,650.31 Unifund CCR. LLC $0.00 $0.00 $0.00 Judgment Detail ( "PostJudgment) In the matter of Unifund CCR. LLC vs. Celeste G Hedges on 6/06/2013 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $11,478.81 $11,478.81 Costs $0.00 $171.50 $171.50 Grand Total: $11,650.31 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. 6/6/2013 Date Magisterial District Judge Charles A. Clement Jr. certify that this is a true and correct copy of the record of the proceedings c tainmg the judgment. 9/4/2013 I q Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed: 06/06/2013 3:26:32PM Unifund CCR. LLC Docket No.: MJ-091 01 -CV-0000071-2013 v. - Celeste G Hedges CrT 21 K 3 Participant List Private(s) Frederic Ivan Weinberg, Esq. Gordon & Weinberg, P.C. 1001 E Hector Street, Suite 220 Conshohocken, PA 19428 Plaintiff(s) Unifand CCR. LLC 10625 Techwoods Circle Cincinnati, OH 45242 Defendant(s) Celeste G Hedges 45 Colgate Drive Camp Hill, PA 17011 Complainant's Attorneys) Joel Marc Flink, Esq. Gordon & Weinberg, PC 1001 E. Hector Street Suite 220 Conshohocken, PA 19428 IUUJ I i : I SEP 0 9 2013 101 By _... MDJS 315 Page 2 of 2 Printed: 06/06/2013 3:26:32PM COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND ? T, Case Mag. Dist. No: MDJ- 09 -1 -01 Unifund CCR. LLC MDJ Name: Honorable Charles A. Clement Jr. V. Address: 920 Linda Lane Celeste G Hedges Camp Hill, PA 17011 Telephone: 717-737-3434 Frederic Ivan Weinberg, Esq. Docket No: MJ- 09101 -CV- 0000071 -2013 Gordon & Weinberg, P.C. Case Filed: 1/31/2013 1001 E Hector Street, Suite 220 Conshohocken, PA 19428 Disposition Summary Docket No Plaintiff Defendant Disposition Disposition Date MJ-091 01 -CV-0000071-2013 Unifund CCR. LLC Celeste G Hedges Default Judgment for Plaintiff 06/06/2013 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Celeste G Hedges $0.00 $11,650.31 $11,650.31 Unifund CCR. LLC $0.00 $0.00 $0,00 Judgment Detail (*Post Judgment) In the matter of Unifund CCR. LLC vs. Celeste G Hedges on 6/06/2013 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00. $11,478.81 $11,478.81 Costs $0.00 $171.50 $171.50 Grand Total: $11,650.31 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. 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 !SSUED 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. 6/6/2013 .' Date Magisterial District Judge Charles A. Clement Jr. certify that this is a true and correct copy of the record of the proceedings containing the judgment. 9/4/2013 N 1 0A Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed: 06106/2013 3:26:32PM S Unifund CCR. LLC Docket No.: MJ- 09101 -CV- 0000071 -2013 V . Celeste G Hedges Participant List Private(s) Frederic Ivan Weinberg, Esq. Gordon & Weinberg, P.C. 1001 E Hector Street, Suite 220 Conshohocken, PA 19428 Plaintiff(s) Unlfund CCR. LLC 10625 Techwoods Circle Cincinnati,, OF+ 45242 iDetendant(s) Celeste G Hedges 45 Colgate Drive Camp Hill, PA 17011 Complainant's Attorney(s) Joel Marc Flink, Esq. Gordon & Weinberg, PC 1001 E. Hector Street Suite 220 Conshohocken, PA 19428 MDJS 315 Page 2 of 2 Printed: 06/06/2013 3:26:32PM 2156853 GORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE L Identification No. : 41360 JOEL M. FLINK, ESQUIRES s ' 4 Identification No. : 41200 _ 1001 E. Hector Street, Ste 220L `i ;�Ff�o,� ' �}l� �t=` Conshohocken, PA 19428 PENNSYLVANIA 484/351-0500 UNIFUND CCR, LLC COURT OF COMMON PLEAS —10625 Techwoods Circle CUMBERLAND COUNTY Cincinnati OH 45242 VS . DOCKET NO. 13-6205-CIVIL CELESTE G HEDGES 45 COLGATE DR CAMP HILL PA 17011 and Fulton Bank =1423 S. Market Street Mechanicsburg, PA 17055 GARNISHEE PRAECIPE FOR WRIT OF EXECUTION —TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against CELESTE G HEDGES defendant (s) and (2) against Fulton Bank garnishee (s) (3) Amount Due $11, 650 . 31 Interest from October 21, 2013 $35.39 Costs Prothonotary fee Sheriff fee (4) Less : Payments on Account $ . 00 OQ TOTAL °O � SI � Spy FREDERIC I . WEINB G, SQUIRE U! JOEL M. FLINK, ESQ Attorney for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 2013-6205 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIFUND CCR, LLC Plaintiff(s) From CELESTE G. HEDGES,45 COLGATE DRIVE,CAMP HILL,PA 17011 (1) You are directed to levy upon the properly 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: FULTON BANK, 1423 S. MARKET STREET,MECHANICSBURG,PA 17055 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$11,650.31 Plaintiff Paid$ Interest FROM OCTOBER 21,2013-$35.39 Attorney's Comm. % Law Library$.50 Attorney Paid$60.25 Due Prothonotary$2.25 Other Costs$ Date: 11/14/2013 169� David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : FREDERICK I. WEINBERG,ESQUIRE Address: GORDON& WEINBERG,P.C. 1001 E. HECTOR STREET,SUITE 220 CONSHOHOCKEN,PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41360 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff A tr' (' Ci �Lt +y Jody S Smith Chief Deputy 2N13NGV21 FH 2: 4 Richard W Stewart .CUMBERLAND Lt %1! r"r Solicitor #:M EOFTm S�ERIFF PENNSYLVANIA Unifund CCR, LLC vs. Case Number Celeste G Hedges 2013-6205 SHERIFF'S RETURN OF SERVICE 11/19/2013 12:13 PM - Dawn Kell, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Fulton Bank, 1423 S Market Street, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County, by handing to Audrey Whary, Bank Teller, 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 November 20, 2013 to Celeste G. Hedges at 45 Colgate Drive, Camp Hill, PA 17011. 1 DAWN KELL, DEPUTY SO ANSWERS, November 20, 2013 RbNW R ANDERSON, SHERIFF (G)CounhrSw..Sherff, ',e'.„o^ft 'nr. { 2156853 ""- 1.02H, r, C GORDON & WEINBERG, P.C. 2 Pfd ,f, 3 BY: FREDERIC I . WEINBERG, ESQUIRE ft� El( �'U JOEL M. Identification ESQUIRE � SYLV;P�lj: Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 IMIMM UNIFUND CCR, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY vs . DOCKET NO. : 13-6205-CIVIL CELESTE G HEDGES and Fulton Bank Garnishee ° PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Kindly dissolve the attachment of the defendant' s bank MINNIMM account with Fulton Bank, as Garnishee in the above entitled MINIM MIMEO matter. GORDON & WEINBERG, P. . BY: FREDERIC I . WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P011 - ( a M.1 ekJf /19D ?7s;), p_ wo?98gss Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY nt of Enoribttf0/d 0. oF.FICE of THE $HERIFF OF THE PROTHOHLI TAR`I` C s4 JUN 16 PM 2: 31 CUPS HLAYL°VAN� A T` Unifund CCR, LLC vs. Case Number Celeste G Hedges 2013-6205 SHERIFF'S RETURN OF SERVICE 11/19/2013 12:13 PM - Dawn Kell, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Fulton Bank, 1423 S Market Street, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County, by handing to Audrey Whary, Bank Teller, 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 November 20, 2013 to Celeste G. Hedges at 45 Colgate Drive, Camp Hill, PA 17011. 06/13/2014 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: $93.87 SO ANSWERS, June 13, 2014 (c) CountySuito Sheriff, Toleosoft. Inc. a--9, 36-23k/