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Home My WebLink About13-6439 F "LE0 0i l - 10L OF l��E PRO TI-$l�ldO i0AF' Harrisburg Civil Law Clinic 3605 Vartan Way 2013 NOY 4 I Pik 2: 19 Harrisburg, PA 17110 CUM COU N T Y Tel. (717) 541 -0320 PENNSYLVANIA lawcli.nichbmail.widener.edu NANCY L. MORRIS IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA J �r V. No. ` � � ll/ v 9 NEW KINGSTOWN AUTO SALES Defendant CIVIL ACTION — LAW PRAECIPE TO INDEX JUDGMENT To the Prothonotary: Kindly index the attached judgment docketed at MJ- 090304 -CV- 0000251 -2013 in the amount of $5,014.24 against the above -named defendant. �T t _ ep tlen I. McLendon, Certified Legal Intern DATE: _ ^ Z�/;7 Monica Cliatt, tsquire Supervising Attorney ID #84848 Harrisburg Civil Law Clinic Widener University School of Law 3605 Vartan Way, 2 nd Floor Harrisburg, PA 17110 COMMONWEALTH OF PENNSYLVANIA Notice o Civil COUNTY OF CUMBERLAND .` r� Case Mag. Dist. No: MDJ- 09 -3 -04 Nancy L Morris. MDJ Name: Honorable Paula P. Correal v. Address: 5275 East Trindle Road New Kingstown Auto Sales Suite 110 Mechanicsburg, PA 17050 Telephone: 717-697-2201 J. Palmer Lockard, Esq. Docket No: MJ- 09304 -CV- 0000251 -2013 3605 Vartan Way Case Filed: 7/2/2013 Harrisburg, PA 17110 Disposition Summary Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09304 -CV- 0000251 -2013 Nancy L Morris New Kingstown Auto Sales Default Judgment for Plaintiff 08/12/2013 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Nancy L Morris $0.00 $0.00 $0.00 New Kingstown Auto Sales $0.00 $5,014.24 $5,014.24 Judgment Detail ('Post Judgment) In the matter of Nancy L Morris vs. New Kingstown Auto Sales on 8/12/2013 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $5,007.24 $5,007.24 Costs $0.00 $7.00 $7.00 Grand Total: $5,014.24 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 WAY 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. Date Senior Magisterial District Judge ala P. Correala certify that this is a true and correct copy of the record of the proceedings ( containing the lu gme .t Date M K enal District Judge MDJS 315 Page 1 of 2 Printed: 08/12/2013 1:39:27PM ." • -. Nancy L Morris ' hoc �'et No. MJ- 09304 -CV- 0000251 -2013 " : y v. New Kingstown Auto Sales Participant List Plaintiff(s) {Nancy L Morris 1931 Fulton Street Harrisburg, PA 17102 Defendant(s) C cz; New Kingstown Auto Sales PO Box 413 73.E. Main St. o New Kingstown, PA 17072 Vic^ Complainant's Attorneys) v� o J. Palmer Lockard, Esq. 3605 Vartan Way Harrisburg, PA 17110 } � R MDJS 315 Page 2 of 2 Printed: 08 /12/2013 1:39:27PM 1 H'LED 1" 10E Harrisburg Civil Law Clinic EE ti4lOTO 3605 Vartan Way 2013 NOV - I PI 2 18 Harrisburg, PA 17110 CUMERLAND COUNTY Tel. (717) 541 -0320 P ENNSYLVANIA lawclinichb (a-)mai.l.wi.dener.edu NANCY L. MORRIS IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, P V. No. NNSYLVANIA � Y" � 1 (� NEW KINGSTOWN AUTO SALES Defendant CIVIL ACTION - LAW PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Nancy L. Morris, Plaintiff, to proceed in forma pauperis. I, Stephen I. McLendon, Certified Legal Intern and Monica Cliatt, Attorney for the party proceeding in forma pauperis, certify that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Stephen 1. McLendon, ertified Legal Intern DATE: Monica Cliatt, Esq., #84848 ORDER AND NOW, this day of "0 • , 2013, pursuant to Pa. R. Civ. P. 240(d), upon presentation and consideration of the within Praecipe to Proceed In Forma Pauperis, said Application is hereby granted. David D. Buell, Prothonotary NANCY L. MORRIS IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 13-6439 CIVIL NEW KINGSTOWN AUTO SALES Defendant CIVIL ACTION—LAW CERTIFICATE OF SERVICE I, Stephen I. McLendon, certify that I served a true and correct copy of the Praecipe to Index Judgment on this date, upon the following persons by certified, return receipt mail at the following address: NEW KINGSTOWN AUTO SALES PO BOX 413 73 E. MAIN STREET NEW KINGSTOWN, PA 17072 DATE: Stephen I. McLendon :5-- F ., �, �. COMPLETE • ON DELIVERY ■ Complete items 1,2,and 3.Also complete A. Signature item 4 if Restricted Delivery is desired. t ❑Agent ■ Print your name and address on the reverse X \ �"— ❑Addressee so that we can return the card to you. B. Received by ted Name) C. ate of Delivery ■ Attach this card to the back of the mailpiece, or on the front if space permits. D. is delivery address different from item ii ❑Yes 1. Article Addressed to: If YES,enter delivery address below: ❑No PUew e4 QS16W() AJ6 Sas (ne, „ NOV 1 , 7 �- ( 1aA 5 e�` 3 REC D 1n / 3. Service Type CJ-)n ?/k )§Certified Mail ❑Express Mail ❑Registered JO Retum Receipt for Merchandise ❑Insured Mail ❑C.O.D. 4. Restricted Delivery?(Extra Fee) ❑Yes 2. Article Number 7012 3050 0001 3819 2677 (Transfer from service label) PS Form 3811,February,2994: Domestic Return Receipt 102595-02-M-1540 Harrisburg Civil Law Clinic 3605 Vartan Way Harrisburg, PA 17110 Tel. (717) 541 -0320 lawclinichb@mail.widener.edu NANCY L. MORRIS Plaintiff v. NEW KINGSTOWN AUTO SALES Defendant • FILED-OFFICE OF THE PROTHONOTARY Zak APR 21 PM 2O CUMBERLAND COUNTY PENNSYLVANIA- : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 13 -6439 CIVIL : CIVIL ACTION — LAW MOTION TO COMPEL ANSWERS TO DISCOVERY NOW COMES Nancy L. Morris, the Plaintiff in the above - captioned matter, and Moves this Honorable Court for an Order Compelling the Defendant, New Kingstown Auto Sales, to respond to Interrogatories in Aid of Execution and states as grounds therefore: 1. On August 12, 2013, the Honorable Paula P. Correal, Magisterial District Judge awarded Judgment in favor of Plaintiff, Nancy L. Morris, and against New Kingstown Auto Sales in the amount of $5,014.24. 2. On November 1, 2013, the Plaintiff caused the aforementioned judgment to be docketed with the Court of Common Pleas of Cumberland County. 3. On or about March 11, 2014, the Plaintiff served Defendant with Interrogatories in Aid of Execution by First Class Mail, postage prepaid. A true and correct copy of those Interrogatories is attached hereto as Exhibit "A ". 4. Pursuant to Pa. R. Civ. P. 4006(2), answers to the Interrogatories were due on or before April 10, 2014. 5. The aforementioned Interrogatories were not returned as undeliverable. 6. The Defendant has not responded to the Interrogatories or requested an extension of time. 7. The Plaintiff believes and avers that Defendant will not answer the Plaintiffs Interrogatories absent a court order pursuant to Pa. R. Civ. P. 4019(a)(1)(i). WHEREFORE, Defendant prays that this Honorable Court issue an ORDER compelling the Defendant to respond to Plaintiff's Interrogatories in Aid of Execution within thirty (30) days or subject to sanctions. Date: Don Gual Certified Legal Intern J. Palmer Loc Attorney ID #33681 Supervising Attorney Harrisburg Civil Law Clinic 3605 Vartan Way, 2nd Floor Harrisburg, PA 17110 (717) 541 -0320 lawclinichb@mail.widener.edu Harrisburg Civil Law Clinic 3605 Vartan Way Harrisburg, PA 17110 Tel. (717) 541 -0320 lawclinichb@mail.widener.edu NANCY L. MORRIS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 13 -6439 CIVIL NEW KINGSTOWN AUTO SALES Defendant : CIVIL ACTION — LAW INTERROGATORIES TO DEFENDANT IN AID OF EXECUTION Pursuant to Pennsylvania Rules of Civil Procedure No. 3117 and 4006, you are required to make full and complete answers to the questions made in writing, under oath, within thirty (30) days after service upon you. Please return answers to Widener University School of Law, Harrisburg Civil Law Clinic, 3605 Vartan Way, 2nd Floor, Harrisburg, PA 17110. If additional sheets are necessary to completely answer your questions, please feel to attach them. If a precise value, amount or date cannot be supplied in responses to an Interrogatory, an approximate value, amount or date should be provided. Should you fail to answer these interrogatories, the court may enter an Order imposing sanctions against you. 1. State the full name of each person answering these Interrogatories, each person's work address, home address, work telephone number and home telephone number, title and relationship with the business on whom these Interrogatories were served. [1] e. 2. Describe the business on whom these were served, including without limitation, the name, address, telephone number, other business name(s) under which it operates, legal status (i.e., corporation, limited partnership, limited liability company, partnership, sole proprietorship, etc.), date of formation, addresses of all business locations, and federal tax identification number. 3. Identify each partner, agent, shareholder, director and officer of the business by name, work and home addresses and telephone number, title, relationship with the business, and value of interest. 4. Give the address, nature of interest, date of acquisition cost, assessed value, fair market value, appraised value, balance of all existing liens, names of lien holders, legal description, and the income derived from any real estate or interest therein owned in whole or in part by the business, whether in the business's name or that of another wherever located, and state who paid for it. [2] 5. State whether the business has filed federal and /or state business tax returns in the last 3 years, specifying as to each return; date filed; name, address and telephone number of the signor of each return; and gross income reported. 6. Identify inventory, materials, work -in- progress owned by the business, specifying as to each the description, amount, value and location. 7. Give listing of all property owned by the business, including but not limited to: (i) all checking and savings accounts (provide bank names, account numbers and present balances); (ii) stocks, bonds and other securities, identifying each by type, fair market value and location where held; [3] (iii) all property owned by the business, including without limitation, fixtures, equipment, tools, trucks, automobiles, trailers, boats, tractor, planes (specifying as to each the location where kept, serial/VIN number, license number, state of registration, value, and any debts secured thereby); (iv) accounts receivable (specifying as to each the name of account, address and amount); (v) judgments held by the business against third parties (specifying as to each the court, case number, case name and amount); [4] (vi) rents receivable (specifying as to each property address, lessee and amount); and (vii) intellectual property (specifying as to each the type, interest and value). 8. Describe each place of business where the business operates, specifying as to each the address, square footage, inventory and fixtures, equipment and number of cash registers. 9. As to each safe or safe deposit box of the business, identify the location and contents. [5] r 10. Identify all property of the business held by third parties, specifying as to each such item of property the holder, location, description and value. 11. Identify all loans and/or mortgages owed to the business, including any loans made to officers / directors /shareholders /employees /etc., specifying as to each the borrower's name, borrower's address and amount owing. 12. Identify any related parent and subsidiary business(es), specifying as to each the name and location(s). 13. Identify any transfers over $1,000 in the last 12 months by name of transferee, amount, date and reason. [6] 14. Identify all other sources of income or property of the business, actual or potential, which you have not disclosed in answers to previous questions, specifying as to each the type, value or potential value thereof, and the holder. 15. Attach your answers to these Interrogatories and copies of your corporate ledgers for the last 12 months. Date: Vit fiy [7] Certified Legal Intern J ' almer Lockard Attorney ID #33681 Supervising Attorney Harrisburg Civil Law Clinic 3605 Vartan Way, 2nd Floor Harrisburg, PA 17110 (717) 541 -0320 lawclinichb @mail.widener.edu 4' VERIFICATION I, New Kingstown Auto Sales, Defendant herein, verify that the statements made in this affidavit are true and correct, to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: [8] Authorized Signatory New Kingston Auto Sales, Defendant NANCY L. MORRIS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 13 -6439 CIVIL NEW KINGSTOWN AUTO SALES Defendant : CIVIL ACTION — LAW CERTIFICATE OF SERVICE I, Don Gual, certify that I served a true and correct copy of the Interrogatories on this date, upon the following persons by certified, return receipt mail at the following address: NEW KINGSTOWN AUTO SALES PO BOX 413 73 E. MAIN STREET NEW KINGSTOWN, PA 17072 DATE: 3/u //y NANCY L. MORRIS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 13 -6439 CIVIL NEW KINGSTOWN AUTO SALES Defendant : CIVIL ACTION — LAW CERTIFICATE OF SERVICE I, Don Gual, hereby certify that I have this day served a true and correct copy of the foregoing Motion to Compel Answers to Discovery on the Defendant by certified, return receipt, first class mail at the following address: NEW KINGSTOWN AUTO SALES PO BOX 413 73 E. MAIN STREET NEW KINGSTOWN, PA 17072 DATE: 4/ / / / /`% Don Gual NANCY L. MORRIS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 13-6439 CIVIL NEW KINGSTOWN AUTO SALES Defendant : CIVIL ACTION — LAW IN RE: PLAINTIFF'S MOTION TO COMPEL ANSWERS TO DISCOVERY ORDER OF COURT AND NOW, thiso?Sitday of April, 2014, upon consideration of Plaintiff s Motion To Compel Answers to Discovery, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. .7.r.;almer Lockard, Esq. 3605 Vartan Way, 2nd Floor Harrisburg, PA 17110 Attorney for Plaintiff Kingstown Auto Sales, Inc. 73 E. Main Street New Kingstown, PA 17072 Defendant CCe-I'E4 ini .4/1 py BY THE COURT. NANCY L. MORRIS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 13-6439 CIVIL C) r-., NEW KINGSTOWN AUTO SALES : ' ar- --,..t Defendant : CIVIL ACTION—LAW mco °' =1"1"1 Cn tv C tom... <E >C) C Z.'C.) _ cn r MOTION FOR RULE ABSOLUTE NOW COMES the Plaintiff in the above-captioned matter,Nancy L. Morris, and moves this Honorable Court for a Rule Absolute and states as grounds therefore: 1. The Plaintiff holds a judgment in this matter against the Defendant in the amount of $5,014.24. 2. On or about March 11, 2014, the Plaintiff served the Defendant with Interrogatories in Aid of Execution by first class mail, postage prepaid. A true and correct copy of those Interrogatories is attached hereto as Exhibit"A". 3. The Defendant has not responded to the Interrogatories, either by answer or objection. 4. On or about April 21, 2014, Plaintiff filed a Motion to Compel Answers to Discovery seeking an Order compelling the Defendant to respond to Plaintiff's Interrogatories. A copy of that Motion is attached hereto as Exhibit"B". 5. On or about April 25, this Honorable Court issued a Rule on the Defendant to show cause within twenty(20) days of service why the relief requested in Plaintiff's Motion to Compel Answers to Discovery should not be granted. A copy of that Rule is attached hereto as Exhibit "C”. 6. The Defendant has not responded to the Rule and more than twenty (20) days have elapsed since service of that Rule. WHEREFORE, Plaintiff prays that this Honorable Court issue an Order compelling the Defendant to respond to the Interrogatories or suffer sanctions. DATE: J. Palmer Lockard Attorney for Plaintiff Widener University School of Law Harrisburg Civil Law Clinic 3605 Vartan Way Harrisburg, PA 17110 (717) 541-0320 I awe]inichb @mail.widener.edu EXHIBIT "A" • Harrisburg Civil Law Clinic 3605 Vartan Way Harrisburg,PA 17110 Tel. (717)541-0320 lawclinichb( mai1.widener.edu NANCY L. MORRIS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 13-6439 CIVIL NEW KINGSTOWN AUTO SALES • Defendant : CIVIL ACTION—LAW INTERROGATORIES TO DEFENDANT IN AID OF EXECUTION Pursuant to Pennsylvania Rules of Civil Procedure No. 3117 and 4006,you are required to make full and complete answers to the questions made in writing,under oath,within thirty • (30)days after service upon you. Please return answers to Widener University School of Law, Harrisburg Civil Law Clinic, 3605 Vartan Way,2"d Floor, Harrisburg, PA 17110. If additional sheets are necessary to completely answer your questions,please feel to attach them. If a precise value, amount or date cannot be supplied in responses to an Interrogatory, an approximate value, amount or date should be provided. Should you fail to answer these interrogatories,the court may enter an Order imposing sanctions against you. 1. State the full name of each person answering these Interrogatories, each person's work address,home address,work telephone number and home telephone number,title and relationship with the business on whom these Interrogatories were served. [1] • 2. Describe the business on whom these were served,including without limitation,the name,address,telephone number,other business name(s)under which it operates,legal status(i.e.,corporation, limited partnership, limited liability company,partnership, sole proprietorship,etc.), date of formation,addresses of all business locations, and federal tax identification number. 3. Identify each partner, agent, shareholder,director and officer of the business by name, work and home addresses and telephone number,title,relationship with the business,and value of interest. 4. Give the address,nature of interest, date of acquisition cost,assessed value,fair market value,appraised value,balance of all existing liens,names of lien holders, legal description,and the income derived from any real estate or interest therein owned in whole or in part by the business,whether in the business's name or that of another wherever located,and state who paid for it. [2] 5. State whether the business has filed federal and/or state business tax returns in the last 3 years, specifying as to each return; date filed;name, address and telephone number of the signor of each return;and gross income reported. 6. Identify inventory, materials, work-in-progress owned by the business,specifying as to each the description,amount,value and location. • 7. Give listing of all property owned by the business, including but not limited to: (i) all checking and savings accounts (provide bank names,account numbers and present balances); (ii) stocks,bonds and other securities, identifying each by type,fair market value and location where held; [3] (iii) all property owned by the business, including without limitation, fixtures, equipment,tools,trucks, automobiles,trailers,boats,tractor, planes (specifying as to each the location where kept, serialNIN number, license number, state of registration,value,and any debts secured thereby); (iv) accounts receivable(specifying as to each the name of account,address and amount); (v) judgments held by the business against third parties (specifying as to each the court,case number,case name and amount); [4] (vi) rents receivable(specifying as to each property address, lessee and amount);and (vii) intellectual property(specifying as to each the type,interest and value). 8. Describe each place of business where the business operates, specifying as to each the address, square footage, inventory and fixtures,equipment and number of cash registers. 9. As to each safe or safe deposit box of the business,identify the location and contents. [5] 10. Identify all property of the business held by third parties,specifying as to each such item of property the holder, location,description and value. 11. Identify all loans and/or mortgages owed to the business, including any loans made to officers/directors/shareholders/employees/etc., specifying as to each the borrower's name,borrower's address and amount owing. 12. Identify any related parent and subsidiary business(es), specifying as to each the name and location(s). 13. Identify any transfers over$1,000 in the last 12 months by name of transferee,amount, date and reason. [6] • 14. Identify all other sources of income or property of the business, actual or potential, which you have not disclosed in answers to previous questions, specifying as to each the type, value or potential value thereof, and the holder. 15. Attach your answers to these Interrogatories and copies of your corporate ledgers for the last 12 months. Date: 31/1/4/ / 44^, (1,,,_..e Don Gual Certified Legal Intern 77/ ,,_:_:_ ---...-. 1 `J 3almer Lockard /Attorney ID #33681 / Supervising Attorney Harrisburg Civil Law Clinic 3605 Vartan Way, 2"`'Floor Harrisburg, PA 17110 (717) 541-0320 lawclinichb@mail.widener.edu [,7] VERIFICATION I,New Kingstown Auto Sales,Defendant herein,verify that the statements made in this affidavit are true and correct,to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: Authorized Signatory New Kingston Auto Sales,Defendant [8] EXHIBIT "B " Harrisburg Civil Law Clinic 3605 Vartan Way Harrisburg,PA 17110 Tel. (717) 541-0320 lawclinichb@mail.widener.edu NANCY L. MORRIS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 13-6439 CIVIL NEW KINGSTOWN AUTO SALES Defendant : CIVIL ACTION—LAW MOTION TO COMPEL ANSWERS TO DISCOVERY NOW COMES Nancy L. Morris, the Plaintiff in the above-captioned matter, and Moves this Honorable Court for an Order Compelling the Defendant,New Kingstown Auto Sales,to respond to Interrogatories in Aid of Execution and states as grounds therefore: 1. On August 12,2013,the Honorable Paula P. Corral,Magisterial District Judge awarded Judgment in favor of Plaintiff,Nancy L. Morris,and against New Kingstown Auto Sales in the amount of$5,014.24. 2. On November 1,2013,the Plaintiff caused the aforementioned judgment to be docketed with the Court of Common Pleas of Cumberland County. 3. On or about March 11, 2014, the Plaintiff served Defendant with Interrogatories in Aid of Execution by First Class Mail, postage prepaid. A true and correct copy of those Interrogatories is attached hereto as Exhibit"A". 4. Pursuant to Pa. R. Civ. P. 4006(2), answers-to the Interrogatories were due on or before April 10, 2014. 5. The aforementioned interrogatories were not returned as undeliverable. 6. The Defendant has not responded to the Interrogatories or requested an.extension of time. 7. The Plaintiff believes and avers that Defendant will not answer the Plaintiffs Interrogatories absent a court order pursuant to Pa. R. Civ, P. 40.19(a)(1)(i). WHEREFORE, Defendant prays that this Honorable Court issue an ORDER compelling the Defendant to respond to Plaintiffs Interrogatories in Aid of Execution within thirty (30) days or subject to sanctions. (--\\ P . Date: (4//Li ft.,_,,4,,,, .,,.7_,,,,,ir...."•k Don Gual Certified Legal Intern ' H J. Palmer Loc(al: - Attorney ID #33681 . Supervising Attorney Harrisburg Civil Law Clinic 3605 Vartan Way, 2nd Floor Harrisburg, PA 1711.0 (717) 541-0320 lawelinichb antail.widener,edu EXHIBIT "C" NANCY L. MORRIS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 13-6439 CIVIL NEW KINGSTOWN AUTO SALES Defendant : CIVIL ACTION -LAW IN RE: PLAINTIFF'S MOTION TO COMPEL eitatiANSWER S TO DISCOVERY ORDER OF COURT AND NOW, thismyof April, 2014, upon consideration of Plaintiffs Motion To Compel Answers to Discovery, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT. L . i , JO 1 J. J. Palmer Lockard, Esq. C) ,--, c c.. 3605 Varian Way, 2nd Floor Harrisburg, PA 17110 rri m-- --t, =1-T1 7a -7 .1 H Attorney for Plaintiff —7a tn.r- tc•il L,---.2 t; New Kingstown Auto Sales, Inc. 73 E. Main Street New Kingstown, PA 17072 Defendant - 4- _. NANCY L. MORRIS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 13-6439 CIVIL NEW KINGSTOWN AUTO SALES Defendant : CIVIL ACTION—LAW CERTIFICATE OF SERVICE I, J.Palmer Lockard, certify that I served a true and correct copy of the Plaintiff's Motion for Rule Absolute on this date, upon the following persons by first class mail, postage prepaid, at the following address: NEW KINGSTOWN AUTO SALES PO BOX 413 73 E. MAIN STREET NEW KINGSTOWN, PA 17072 DATE: A , . Palmer Lockard / i NANCY L. MORRIS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 13-6439 CIVIL NEW KINGSTOWN AUTO SALES Defendant : CIVIL ACTION — LAW ORDER AND NOW, this 3C) day of94-u"-.2---, 2014 upon consideration of Plaintiff's Motion for Rule Absolute, it is hereby ORDERED: 1. The Motion is granted. 2. Defendant is Ordered to respond to Plaintiff's Interrogatories within 30 days of service of this Order or sanctions shall be imposed. ktsc.624, i61 S400 Ad() Data 40f/op ?' By the Court: J. s