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Home My WebLink About13-7013 2115288 GORDON & WEINBERG, P.C. Af) HZf�`jJdi, BY: FREDERIC I. WEINBERG, ESQUIRE1 "a �, Identification No.: 41360 P 0 03 JOEL M. FLINK, ESQUIRE r`UMTEiiL AND Identification No.: 41200 PENN �� l 'd - Y ��.,� lq� t .S "rL 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351 -0500 Main Street Acquisition Corp. COURT OF COMMON PLEAS Assignee of HSBC Bank Nevada, CUMBERLAND COUNTY N.A. P.O. BOX 2529 °— SUWANEE,GA 30024 VS. DOCKET N0. j3 -7dr �i�cl�P RON HEDGES 45 COLGATE DR Camp Hill PA 17011 -7631 ° - -_ 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 Plaintiff (s) 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: $3,180.58 Judgment $.00 Post Judgment Interest $.00 Post Judgment Costs $.00 Post Judgment Payments $3,180.58 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 Plaintiffs) and Defendants) 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 �� mowed 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 Soldiers and Sailors Relief Act of 1940, as amended, and had (have civilian occupation(s). Date: 6 I � FREDERIC I. W J ERG, ESQUIRE JOEL M. FLINK, ESQUIRE DAMAGES ASSESSED AND JUDGMENT(S) ENTERED AS ABOVE NOTICE(S) GIVEN UN R P R. P.236 Pro th �` 100 , MMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ- 09 -1 -01 Main Street Acquisition Corp MDJ Name: Honorable Charles A. Clement Jr. V Address: 920 Linda Lane Ron Hedges Camp Hill, PA 17011 I Telephone: 717- 737 -3434 Main Street Acquisition Corp Docket No: MJ-091 01 -CV-0000656-201 0 429 Fourth Avenue Suite 1600 Case Filed: 12/6/2010 Assignee of HSBC Bank Nevada NA Pittsburgh, PA 15219 Disposition Summary .......... . Docket No Plaintiff Defendant Disposition Disposition Date MJ-091 01 -CV-0000656-201 0 Main Street Acquisition Corp Ron Hedges Default Judgment for Plaintiff 01/28/2011 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Main Street Acquisition Corp $0.00 $0.00 $0.00 Ron Hedges $0.00 $3,180.58 $3,180.58 Judgment Detail ( * Post Judgment) In the matter of Main Street Acquisition Corp vs. Ron Hedges on 1/28/2011 the judgment was awarded as-.follows: The amount of rent per month, as established by the Magisterial District Judge, is $0.00 Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $2,896.54 $2,896.54 Costs $0.00 $110.25 $110.25 Interest $0.00 $173.79 $173.79 Grand Total: $3,180.58 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. aim orr 1/28/2011 t Date Magisterial District Judge Charles A. Clement Jr. certify that this is a true and correct copy of the record of the proceedings containing t e 1u gment. 8/13/2013 Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed: 08/13/2013 9:10:26AM Main Street Acquisition Corp Docket No.: MJ- 09101 -CV- 0000656 -2010 V. Ron Hedges Participant List Plaintiff(s) Main Street Acquisition Corp 429 Fourth Avenue Suite 1600 Assignee of HSBC Bank Nevada NA Pittsburgh, PA 15219 Defendant(s) Ron Hedges 45 Colgate Drive Camp Hill, PA 17011 Complainant's Attorney(s) Joel Marc Flink, Esq. 1001 E Hector St Ste 220 Conshohocken, PA 19428-2395 MDJS 315 Page 2 of 2 Printed: 08/13/2013 9:12:48AM Department of Defense Manpower Data Center Results as of: Nov -13 -2013 07:27:36 SCRA 3.0 Status Deport Pursuant to Senficememben Civil Relief Act Last Name: HEDGES First Name: RON Middle Name: Active Duty Status As Of: Nov -13 -2013 On Active Duty On Active Duty Status Date Active Duty Start Dale Active Duty End Date 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 Date 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 Date Order Notification Start Dale Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or hisfher 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. hhkk 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: hftp: /Iwww.defenselink .mil /faq /pis/PC09SLDR.htmi. 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. Furthennore, 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: T5NAX729U078180 2115288 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 Main Street Acquisition Corp. COURT OF COMMON PLEAS Assignee of HSBC Bank Nevada, CUMBERLAND COUNTY N.A. DOCKET NO. VS. RON HEDGES 45 COLGATE DR Camp Hill PA 17011 -7631 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 $3,180.58 /x / Money Judgment $$3,180.58 LL Judgment on Award of Arbitrators$ 1� Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. LIN ESQUIRES AT THI TELEPHONE NUMBER: 484/351 -0500 PROTHONOTARY 1=•1•111= 2115288 The Offices of Frederic I. Weinberg HLED-OFFICR & Associates, P.C. Ut- THF PROTHONOD.P'f' BY: Frederic I. Weinberg, Esquire Identification No.: 41360 2014 OCT 1 PM 2: 141i Joel M. Flink, Esquire Identification No.: 41200 CUHBERLAND COUNTY 1001 E. Hector Street, Ste 220 PENNSYLVANIA Conshohocken, PA 19428 484/351-0500 ;-_-;Main Street Acquisition Corp. Assignee ETEof HSBC Bank Nevada, N.A. P.O. BOX 2529 -±liESUWANEE,GA 30024 111111111111 110111111=1•1 101111111 vs. ElEeRON HEDGES 45 COLGATE DR Camp Hill PA 17011-7631 and Citizens Bank of Pennsylvania ===665 North East Street ERECarlisle, PA 17013 GARNISHEE(S) 1111111111111 =7:= 111/1111 .11111.111.0111 WNW= =TO THE PROTHONOTARY: === •1111111=1 === MUM! Egg === COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 2013-7013 PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against RON HEDGES defendant (s) and (2) against Citizens Bank of Pennsylvania garnishee(s) (3) Amount Due Interest from November 25, 2013 Costs Prothonotary fee Sheriff fee (4) Less: Payments on Account TOTAL k")cicx,0 akj .gs 0‘1111 $3,180.58 $163.12 $.00 40.W3 Co.FREDERIC I. WEINBER , ESQUIRE •6° JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 199 gog bo- & tsed 2:* 2t '-'Noos THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net MAIN STREET ACQUISITION CORP. ASSIGNEE OF HSBC BANK NEVADA, N.A. Vs. NO 13-7013 Civil Term CIVIL ACTION — LAW RON HEDGES WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against RON HEDGES, 45 COLGATE DRIVE, CAMP HILL, PA 17011 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of CITIZENS BANK OF PENNSYLVANIAGARNISHEE(S), as garnishee, 665 NORTH EAST STREET, CARLISLE, PA 17013 (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. 1 (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $3,180.58 Plaintiff Paid Interest FROM NOVEMBER 25, 2013 - $163.12 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $60.25 Other Costs Date: 1014/2014 David D. Buell, Prothonotary By: REQUESTING PARTY: Name : FREDERIC I. WEINBERG, ESQUIRE Address: LAW OFFICES OF FREDERIC I. WEINBERG 1001 E. HECTOR STREET, SUITE 220 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No, 41360 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY vILED-OFFICL �cl*4 C.IFTHE pROTHONOTAR'/ OFF C.E OF THE ?0LOCT��T�< RI 10: ^"''"°'~' '-._ . CUMBERLAND COUN PENNSYLVANIA Main StreeAcquisition Corp. Assignee of HSHB Bank Nevada, N.A. vs. Ronnie Hedges Case Numbe 2013-7013 SHERIFF'S RETURN OF SERVICE 1017/2014 03:48 PM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defndant, in the hands, possession, or control of the within named garnishee, Citizen's Bank, 665 North East Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Tabitha Zarichansky, Banker, 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 October 20, 2014 to on Hedges at 45 Colgate Drive, Camp Hill, PA 17011-7631. October 2O.2014 (c) CountySuite Sheriff, Teleosoft, LLIACLINE, DEPUTY SO ANSWERS, R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION MAIN STREET ACQUISITION CORP Plaintiff(s), vs. RON HEDGES Defendant(s), and Citizens Bank of Pennsylvania, Garnishee. 137013 ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK CO The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS _1 to _12 ) At the time of service of above -captioned Writ of Execution and to the present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories: The Garnishee, Citizens Bank of Pennsylvania, states that it maintains no record of any deposit account in the name of the Defendant, Ron Hedges, accordingly no funds are being held subject to this Writ of Execution. COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Marjorie Morris who being duly sworn according to the law deposes and says that she is the Legal Clerk, Operations Services, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief. Sworn and subscribed before me thi �� day of , 2014. )(210 w titLe Notary Public COMMONWEALTH OF PENNSYLVANI NOTARIAL SEAL Dara Wilkerson, Notary Public City of Pittsburgh, Allegheny County My Commission Expires April 26, 2013 MEMBER, PENNSYLVANIA ASSOCIATION OP NOTARIES Certificate of Service I, Marjorie Morris, hereby ' -rtify that a true and correct copy of the Answers to Interrogatories has b en served upn the following by depositing it in the U. S. Mail, postage prepaid, this day of , 2014. FREDERIC I WEINBERG, ESQ THE LAW OFFICES OF FREDERIC I WEINBERG & ASSOCIAI'ES, PC 1001 E HECTOR ST CONSHOHOCKEN, PA 19428 RON HEDGES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION MAIN S1REET ACQUISITION CORP, Plaintiff(s), vs. RON HEDGES, Defendant(s), vs. Citizens Bank of Pennsylvania, Garnishee. 137013 Answers to Interrogatories Code: 200 Execution Filed on Behalf of Garnishee, Citizens Bank of Pennsylvania Counsel of Record for this Party: Nicholas Deenis, Esquire PA I.D. No. 62378 Stradley, Ronon, Stevens & Young 2005 Market Street, Suite 2600 Philadelphia PA 19103 (215) 564-8672 (215) 564-8120 fax ndeenis@stradley.com www.stradley.com The Law Offices of Frederic I Weinberg;° & Associates, P.C. BY: Frederic I. Weinberg, Esquire Identification No.: 41360 Joel M. Flink, Esquire Identification No.: 41200 375 E. Elm Street, Suite 210 Conshohocken, PA 19428 484/351-0500 2115288 Main Street Acquisition Corp. Assignee of HSBC Bank Nevada, N.A. RON HEDGES COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DOCKET NO. : 2013-7013 and Citizens Bank of Pennsylvania Garnishee PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Kindly dissolve the attachment against Citizens Bank of Pennsylvania, as Garnishee in the above entitled matter. The Law Offices of Frederic I. Weinberg & Associates, P.C. BY: P011 Frederic I. r, _, ' .erg, Esquire Joel M. Flink, Esquire Attorney for Plaintiff Ovid 6s9 sq,01044 CL- 06)9 d 2.u -31y3 608