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Home My WebLink About13-6886 N0. /3 .--to COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND � � - � ,�,, Case Ji Mag. Dist. No: MDJ-09-2-01 Janet L Breiner MDJ Name: Honorable Paul M Fegley V. Address: 2260 Spring Road, Suite 3 Cassandra Barilla Carlisle, PA 17013 Telephone: 717-218-5250 Janet L Breiner Docket No: MJ-09201-CV-0000026-2013 967 W Trindle Rd Lot 9 Case Filed: 3/14/2013 Mechanicsburg, PA 17055 Disposition Summary Docket No Plaintiff Defendant Disposition Disposition Date MJ-09201-CV-0000026-2013 Janet L Breiner Cassandra Barilla Default Judgment for Plaintiff 05/21/2013 Judgment Summary Particioant Joint/Several Liability Individual Liability Amount Cassandra Barilla $0.00 $1,528.98 $1,528.98 Janet L Breiner $0.00 $0.00 $0.00 Judgment Detail (*Post Judgment) In the matter of Janet L Breiner vs. Cassandra Barilla on 5/21/2013 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $1,400.00 $1,400.00 Costs $0.00 $128.98 $128.98 Grand Total: $1,528.98 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 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. a■ 113 Date Magisterial District Judge Paul M Fegley b C� 514, I certify that this is a true and correct copy of the record of the proceedin• • •ing the judgment. \ 8 Z '7 /3 , e. r •Date Magist> ial District udge BM MDJS 315 Page 1 of 2 Printed:05/21/2013 11:31:20AM Janet L Breiner Docket No.: MJ-09201-CV-0000026-2013 v. Cassandra Barilla Participant List Plaintiff(s) ,-. Janet L Breiner 967 W Trindle Rd Lot 9 = ` Mechanicsburg, PA 17055 -{7> p cn <C3 Defendant(s) Ts[, Cassandra Barilla 84 Tip Top Circle Carlisle, PA 17015 $ 3(, ;- P ' C4L 9 W N071) t µ` ;'e MDJS 315 Page 2 of 2 Printed: 11/20/2013 10:47:52AM r' I i L s i 1... J. Palmer Lockard i `` 11` ''' '' 3605 Vartan Way 'i P ' n, Harrisburg, PA 17110 Tel. (717) 541-0320 CUM?E;LAND NUN r PENNSYLVANIA lawclinichb @mail.widener.edu JANET L BREINER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 2013 CV 06886 • CASSANDRA BARILLA Defendant : CIVIL ACTION—LAW MOTION TO COMPEL ANSWERS TO DISCOVERY NOW COMES Janet L. Breiner,the Plaintiff in the above-captioned matter, and Moves this Honorable Court for an Order Compelling the Defendant, Barilla Cassandra, to respond to Interrogatories in Aid of Execution and states as grounds therefore, 1. On May 21, 2013,the Honorable Paul M. Fegley, Magisterial District Judge awarded Judgment in favor of Plaintiff, Janet L. Breiner, and against Barilla Cassandra in the amount of$1,528.98. 2. On or about November 20, 2013, Plaintiff caused the aforementioned judgment to be docketed with the Court of Common Pleas of Cumberland County. 3. On or about January 16, 2014, 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, answers to the Interrogatories were due on or before February 15, 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. Plaintiff believes and avers that defendant will not answer plaintiffs interrogatories absent a court order pursuant to Pa. R.C.P. 4019(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 be subject to sanctions. Date: 3/ ,3 y �/ .��.... J. Palmer Lockard Atty. ID No. 33681 Counsel for Plaintiff 3605 Vartan Way Harrisburg, PA 17110 (717) 541-0320 Fax: (717) 909-0442 Lawclinichb@mail.widener.edu JANET BREINER , : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF . : NO. 2013-CV-6886-NT • • vs. . • CASSANDRA BARILLA . DEFENDANT : CIVIL ACTION INTERROGATORIES TO DEFENDANT IN AID OF EXECUTION Please take notice that demand is hereby made upon you for answers under oath or certification to the following interrogatories. 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 J. Palmer Lockard, 3605 Vartan Way, 2nd Floor, Harrisburg, PA 17110. If additional sheets are necessary to completely answer your questions,please feel free to attach them. Should you fail to answer these interrogatories,the court may enter an Order imposing sanctions against you. 1. State your full name, address, age, telephone number and Social Security Number. 2. Do you own or maintain any savings or checking accounts, certificates of deposit,money market accounts, mutual fund accounts, or IRA or Keogh accounts, either individually or jointly with another individual or entity or in the name of any entity in which you have any ownership or other involvement? If so,please provide the following information for each account or certificate. a. The identity of the institution in which you have such an account or certificate; [1] b. The title and number or identifying reference of the account or certificate; c. The identify of any joint owner of the account or certificate and the nature of your joint ownership; d. The nature of the account or certificate; e. The dates and amounts of your deposits or contributions for the last twelve months; f. The current balance of account or value of the certificate. 3. If you are self-employed, state the nature of your self-employment, the address of your office of place of business,the name under which you trade, your average gross annual earning, and your average net annual earnings. [2] 4. State your gross taxable income as shown by your Federal Income Tax returns for years 2001 through 2011. 5. Do you own real property or a home in which you live now?Please state the following. a. Address of any such real property; b. The county in which the real property is located; c. The current market value of real property or home. d. Whether there is a mortgage, lien, or other encumbrance on the aforementioned property, the amount of the mortgage, lien, or other encumbrance, and the address of the creditor holding the mortgage, lien, or other encumbrance. If the property has been mortgaged, provide the current balance of the mortgage and the monthly mortgage payment amount. 6. Do you own a motor vehicle or any interest in a motor vehicle either individually or jointly with another person or entity? If so, state the following as to each such vehicle. [3] a. The make, model, year, color, and VIN number of the motor vehicle; b. Whose name appears on the registration or title certificate; c. The location and current custodian of the motor vehicle; d. The purchase price of the motor vehicle; e. The balance due on any outstanding purchase money security interest in the motor vehicle, and the name and addressed of the secured party; f. Each person who paid any part of the purchase price or who has repaid or is repaying any part of the purchase money loan, and the amount and source of the funds paid; g. The market value of the motor vehicle; [4} h. The identity of all documents relating to the purchase of the motor vehicle, along with evidence of title or registration; i. The nature and value of an interest in the motor vehicle. 7. Identify all items of tangible personal property having a value of$100 or more which you own either individually or jointly with another person or entity including, but not limited to,jewelry, furs, furniture, office equipment,television sets, audio equipment, electrical appliances,power tools,photographic equipment,works of art, musical instruments,coin or stamp collections, silver or china, or any other unmentioned personal property of value. Please state the purchase price and date of purchase. Additionally, specify any encumbrances that may be on any aforementioned personal property and any individual or entity that holds such an interest in the property, including the amount of the interest and the address of the individual or entity. [5] 8. Do you own or have any interest in any other assets not already disclosed? If so, please identify the asset and its current location. a. Date: V/G `/ '( / J. Palmer Lockard Attorney ID#33681 Supervising Attorney Harrisburg Civil Law Clinic 3605 Vartan Way,2"d Floor Harrisburg, PA 17110 (717) 541-0320 lawclinichb@mail.widener.edu [6] • VERIFICATION I, Cassandra Barilla, Defendant herein,verify that the answers to the aforegoing interrogatories are true, correct, and complete, 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: Cassandra Barilla, Defendant [7] JANET BREINER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF : NO. 2013 CV 6886 NT vs. CASSANDRA BARILLA DEFENDANT : CIVIL ACTION CERIFICATE OF SERVICE I, J. Palmer Lockard, certify that I served a true and correct copy of the Interrogatories in Aid of Execution,upon the following persons at the following address: CASSANDRA BARILLA 127 E. Simpson St. Mechanicsburg, PA 17055 DATE: 1//0// y U . Palmer Lockard JANET L BREINER •• IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. •• No. 2013 CV 06886 CASSANDRA BARILLA • Defendant : CIVIL ACTION—LAW CERTIFICATE OF SERVICE I, J. Palmer Lockard 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 first class mail, postage prepaid, addressed as follows: CASSANDRA BARILLA 127 E. Simpson St. Mechanicsburg, PA 17055 DATE: _3 4 / J. Palmer Lockard JANET L. BREINER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION — LAW CASSANDRA BARILLA, : Defendant : NO. 13-6886 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO COMPEL ANSWERS TO DISCOVERY ORDER OF COURT AND NOW, this 7th day of March, 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. BY THE COURT, Lt4- Christyl e L. Peck, J. Lockard, Esq. 3605 Vartan Way Harrisburg, PA 17110 Attorney for Plaintiff Cassandra Barilla 127 E. Simpson Street Mechanicsburg, PA 17055 Defendant, pro Se :rc Ce-Y-Ji.C.S 1,•,)