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HomeMy WebLinkAbout04-6503IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA S & L RESIDENTAL PROPERTIES, vs Plaintiff ASHLEY M. WEIDNER 103 N. East Street, Apt. 2 Carlisle, PA 17013, Defendant CIVIL ACTION - LAW NO.: ?? ?oS43 (3 .L `?L! PRAECIPE FOR TRANSFER OF JUDGMENT To the Prothonotary: Kindly enter judgment for Plaintiff and against Defendant Ashley M. Weidner and assess damages certified to be calculable as a sum certain from the Judgment entered in Dauphin County, Pennsylvania under Docket Number 2004-NT-3377, of which a Certification of Docket Entries and Judgment is attached as Exhibit "A". Principal due $1,517.00 Total due $1,517.00 THIS 2R?DAY OF JUDGMENT IS ENTERED IN FAVOR OF PLAINTIFF AND AGAINST DEFENDANT ASHLEY M. WEIDNER BY ORDER OF COURT AND DAMAGES ASSESSED AT THE SUM OF $1,517.00 1i Lti Michael B. Volk, Esquire Attorney ID #88553 Capozzi & Associates, P.C. 2933 N. Front Street Harrisburg, PA 17110 Attorney for Plaintiff PROTHONOTARY Date: / 6 t1jq? 3)n The Court of (Common PCea.5 of ?Daupbin Countp, Venn5plbauia S & L Residential Properties vs. No. 2004-NT-3377 Ashley Weidner J 103 N. East Street Apt. 2 Carlisle, PA 17013 CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT I, the undersigned Prothonotary of the Court of common Pleas of Dauphin County, Pennsylvania, do hereby certify that the attached is a full, true and correct copy of the docket entries in the above captioned case. I further certify that judgment was entered in favor of Plaintiff, S & L Residential Properties and against Defendant, Ashley Weidner on November, 22, 2004 in said case in the amount of 1,517.00 3n Seotimonp 30bereot, I have hereunto s)my and and affixed the se the Court, on Wednesday, December 15, 2004. lionotary By. ?Iwljt_ Deputy JUDGMENT $1517.00 Interest from Commission Attorney Due $3.00 Plaintiff Paid $21_00 Defendant Paid Prothy. Due $8.75 This record $17_50 Date: 12/16/2004 Time: 10:05 AM Page 1 of 2 Filed: 11/22/2004 Dauphin County Complete Case History 2004-NT-3377- S & L Residential Properties vs. Ashley Weidner Physical File: Y Appealed: N Comment: Judge History Date Judge 11/2212004 No Judge, Reason for Removal Current Payments Receipt Date Type Capozzi & Associates 69556 1112212004 Civil Filing Plaintiff Name: S & L Residential Properties Address: Phone: Home: Employer: Party Type: Comment: Attorneys Reavey, Donald R Defendant Name: Address: Work: (Primary attorney) Weidner, Ashley 103 N East Street Apartment 2 Carlisle PA 17013 Phone: Home: Work: Employer: Party Type: Comment: Register of Actions 11122/2004 New Civil Case Filed This Date. Filing: Judgment- DJ Paid by: Capozzi & Associates Receipt number: 0069556 Dated: 11/2212004 Amount: $21.00 (Check) Transcript of Judgment from the Docket of James Pianka, District Justice 8125104. Judgment for $1,517.00 Entered At 4:08 p.m. Stephen E. Farina, Prothonotary District Justice Costs $87.00 Plaintiff: S & L Residential Properties Attorney of Record: Donald R Reavey Total SSN: DOB: Sex: Send notices: Y Send Notices SSN: DOB: Sex: Send notices: Y No Judge, No Judge, No Judge, No Judge, User: VMARTINEZ Amount 21.00 21.00 Date: 12/15/2004 Dauphin County User: VMARTINEZ Time: 10:05 AM Complete Case History Page 2 of 2 2004-NT-3377- S & L Residential Properties vs. Ashley Weidner Judgment Order date in Favor Of Disposition 11/22/2004 Plaintiff 11/22/2004 Open Plaintiff: S & L Residential Properties Defendant: Weidner, Ashley gnnL I erel rt fy that the fore oii is a d orrect op" f the or' nail filed. Prot notary/Clerk of Cou Judgment DJ Judgment Amount .00 41, Does ma,-6? ? -fo l -t IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA S & L RESIDENTIAL PROPERTIES 2933 North Front Street Harrisburg, PA 17110 Plaintiff, V. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant CIVIL ACTION - LAW No. c cxD ivT .33 7 -7 0 J NOTICE OF THE ENTRY OF JUDGMENT AGAINST DEFENDANT ASHLEY WEIDNER To: Ashley Weidner, Defendant: u 711 ? 220041 You are hereby notified that on the following Judgment has been entered against you in the above-captioned case. Judgment in the amount of $1,517.00 plus interest at the legal rate of 6% from August 25, 2004 and the cost of this proceeding. Date: ifail? 6. f Protho otary eFj I hereby certify that the name and address of the proper person(s) to receive this notice is: Ashley Weidner 103 N. East Street, Apartment 2 Carlisle, PA 17013 ?S ' Zl DEC ? ? 2004 hereby cerfiN kite'the forte rw true and c0? cOPY fi{ed. ?e J) . 2? d_ Prothonotary Y, Ashley Weidner, Defendido Por este medio se le esta notificando que el r de del 2004, el siguiente Faloo ha lido anotado en contra suya en el grafe. "1 FECHA f q Certifico qua la siquiente direccion es la del defendido/a segun indicada en el certificado de residencia. Ashley Weidner 103 N. East Street, Apartment 2 Carlisle, PA 17013 Abogado del Demandante Date: - e?- -By: onald R. Reavey, Esquire Attorney ID No. 82498 Michael B. Volk, Esquire Attorney I.D. No.: 88553 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA S & L RESIDENTIAL PROPERTIES 2933 North Front Street Harrisburg, PA 17110 Plaintiff, V. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant § CIVIL ACTION -LAW §NO. '-?R oo{ NT 33-7? § ?a 0 co PRAECIPE FOR THE ENTRY OF JUDGMENT AGAINST DEFENDANT ASHLEY WEIDNER To the Prothonotary: In accordance with the attached judgment taken on August 25, 2004 in District Justice Court 12-1-02, Please enter Judgment in favor of Plaintiff and against Defendant in the amount of $1,517.00 plus interest at the legal rate of 6% from August 25, 2004 and the cost of this proceeding. More than thirty days have elapsed since the date of judgment and no appeal has been filed. Date: Respectfully Submitted: By: 1 Do rod R. Reavey, Esquire Attorney ID No. 82498 Michael B. Volk, Esquire Attorney I.D. No.: 88553 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 'COMMONWEALTH OF PENNSYLVANIA CnIfNTV oF- DAUPHIN 1a-1-02 DJ Nana: Hon. JAME$ PIANRA Addmsa; 2967-A NORTH 7TH HARRISBURG, PA Teav on,: (717) 238-3388 STREET 17110-0000 ATTORNEY FOR PLAINTIFF ATTTN: MICHAEL VOLK LOUIS J. CAPOZZI JR ESQ 2933 N FRONT STREET HARRISBURG, PA 17110 NOTICE OF JUDGMENT/TRANSCRIPT PLAINTFF: RESIDENTIALFLEASE NAM R rS 4 L RESIDENTIAL P 2933 N FRONT STREET HARRISBURG, PA 17110 L vs. DEFENDANT: NAME and ADDRESS rWEIDNER, ASHLEY 239 WOODBINE STREET APT/STS 1 HARRISBURG, PA 17110 L o? ooq A, r 33 - 7 Docket No.: LT-0000453-04 Date Filed: 7/16/04 1 J -1 J THIS IS TO NOTIFY YOU THAT: r -, Judgment: FOR PUATMTIFF ;i- ® Judgment was entered for: (Name) 8 & L RESIDENTIAL PROP13RTIES Judgment was entered against WEIDNER, ASHLEY= i- Q Landlord/Tenant action in the amount of $ 1.517.00 on 8/25/04 (Date of JUdgm ent) The amount of rent per month, as established by the District Justice, is $ 465.00 Co The total amount of the Security Deposit is $ 465.00 Total Amount Establish id tb? J Less • Security Deposit Ap BI' R = Adjudica d ouptt Rent in Arrears $ ?,4y3 •00-$ BIR $ ? •00 Physical Damages Leasehold Property g g$ g .00 Damages/UnjustDetention $ -00-$ -00 - $ .00 Less Amt Due Defendant from Cross Complaint - $ -00 Interest (if provided by lease) $ _nn UT Judgment Amount $ iF410 _ n0 ? Attachment Prohibited/ Judgment Costs $ 87.00 42 Pa. C.S. § 8127 Attorney Fees $ -04) ? This case dismissed without prejudice. Total Judgment $ 1,517.00 ? Possession granted. ® Possession granted if money judgment ? Possession not granted. Post Judgment Credits Post Judgment Costs Certified Judgment Total Defendants are jointly and severally liable. IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE -RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITWTHE_PROTHONOTARYICLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APP.EAL'OF THE MONEY JUDGMENT, IF-ANY:. IN. ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. - IF A PARTY WISHES TO APPEAL ONLY THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS 30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARYICLERK OF COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. """ " _. THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH, THE NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE.FOR DISTRICT JUSTICES, IF THE. JUDGMENT HOLDER ELECTS. TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST: COME FRCilkT IE,COyRT OF COMMON PLEAS-.AND NO FURTHER PROCESS MAY SE ISSUED BY THE DISTRICT JUSTICE. - ' • 1 t ' s'r UNLESS THE JUDGMENT IS ENTERED- IN THE COURT OFICOMMON .PLEAS ?ANYONE•INTERESTEDINTHEJIUbGMENT_MA'Y' F0 A REgUE3T FOR ENTRY. OF $ATISFAGTION WITH THE DISTRIGT.JUST.ICE IF THE.JWOGMENT DEBTOR PAY5IN FULL; SETTLES,.', ; -. OR OTHERWISE COMPLIES WITH THE JUDGMENT. ' fi'a? o Date , DlstrictJustlge,. certl y 1ha I Is a rue an rect copy o t e recd ee In ng a fu gmen): • _ - ? IIT Q Date ,District Justice M commission expires first Monday of January , 6 • SEAL IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA S & L RESIDENTIAL PROPERTIES 2933 North Front Street Harrisburg, PA 17110 Plaintiff, V. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant CIVIL ACTION- LAW NO. r.9oy y v/ 3 3 7 7 CERTIFICATE OF SERVICE I, Michael B. Volk, hereby certify that I did on this day of ra o 200_, serve a true and correct copy of the Praecipe for Entry of Judgment upon the person(s), and/or their counsel, and in the manner indicated below: VIA CERTIFIED MAIL: 7003-1680-0005-4463-0647 VIA FIRST CLASS MAIL Ashley Weidner 103 N. East Street, Apartment 2 Carlisle, PA 17013 Date: r1vnJ By: / Donald R. Reavey, Esquire Attorney ID No. 82498 Michael B. Volk, Esquire Attorney I.D. No.: 88553 2933 North Front Street Harrisburg, PA 17110 (717)233-4101 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA S & L RESIDENTAL PROPERTIES, CIVIL ACTION - LAW Plaintiff vs NO.: ASHLEY M. WEIDNER 103 N. East Street, Apt. 2 Carlisle, PA 17013, Defendant CERTIFICATE OF SERVICE 0 I, Michael B. Volk, Esquire, hereby certify that I am serving this r6 day of , 2004 a copy of the Praecipe to Transfer of Judgment upon the persons and in the manner indicated: Service by Certified Mail Return Receipt Requested and via Regular First Class U.S. Mail, postage paid, addressed as follows; VIA CERTIFIED MAIL: 7003 2260 0000 9890 4808 VIA FIRST CLASS MAIL Ashley Weidner 103 North East Street Carlisle, PA 17013 Respectfully Submitte , 7 _It-'Michael B. Volk, Esquire Attorney I.D. #88553 Capozzi & Associates, P.C. 2933 North Front Street Harrisburg, PA 17101 Attorney for Plaintiff T? 0 ?. CID f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA S & L RESIDENTIAL PROPERTIES 2933 North Front Street Harrisburg, PA 17110 Plaintiff, V. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant § CIVIL ACTION -LAW § NO. (?a S76 1'v, '_-7 l § Writ No.: § Principal: $1,517.00 § Interest to date: $26.55 § Clerk's Cost § Sheriff's Cost § TOTAL PRAECIPE FOR WRIT OF EXECUTION FOR ATTACHMENT AND GARNISHMENT OF BANK ACCOUNT To the Prothonotary: Issue a Writ of Execution in the above matter, (1) directed to the Sheriff of Cumberland County, (2) against Ashley Weidner, Defendant; and (3) against the Pennsylvania State Employees Credit Union, commonly known as PSECU, located at 1 Credit Union Place, Harrisburg, PA 17110 as garnishee. (4) Exemption has not been waived. Dated: 6 ? -If L ?, ? A ? CL P-,- Mi hael 13. Volk, Esq 're Attorney for Plaintiff 2 --t=- l'b n J? C G o p ? `? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA S & L RESIDENTIAL PROPERTIES 2933 North Front Street Harrisburg, PA 17110 Plaintiff, v. ASHLEY WEIDNER 103 M East Street, Apartment 2 Carlisle, PA 17013 Defendant CIVIL ACTION - LAW NO. Writ No.: _ Principal: Interest to date: Clerk's Cost Sheriff s Cost TOTAL § CERTIFICATE OF SERVICE $1,517.00 $26.55 I, Michael B. Volk, attorney for Plaintiff in this cause of action, hereby certify that on this day of LO-Le M?-u---- , 2004, I placed in the United States Mail, via first class and via certified delivery, a true and correct copy of the Praecipe for Writ of Execution, addressed to the following: VIA CERTIFIED MAIL: 7003-1680-0005-4463-0933 AND VIA FIRST CLASS MAIL Ashley Weidner 103 N. East Street, Apartment 2 Carlisle, PA 17013 Respectfully submitted, M1 ?i? j i ?W- Date: ?\S?( By: MichaJB. Volk, Esquire ; f Attorney ID No. 82498 V 2933 North Front Street Harrisburg, PA 17110 (717)233-4101 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-6503 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due S & L RESIDENTIAL PROPERTIES, Plaintiff (s) From ASHLEY WEIDNER, 103 N. EAST STREET, APARTMENT 2, CARLISLE, PA 17013 (1) 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 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, COMMONLY KNOWN AS PSECU, LOCATED AT 1 CREDIT UNION PLACE, HARRISBURG, PA 17110 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 $1,517.00 Interest TO DATE - $26.55 Any's Comm % Any Paid $38.00 Plaintiff Paid Date: FEBRUARY 23, 2005 (Seal) L.L. $,50 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary C `By. C. L Deputy REQUESTING PARTY: Name MICHAEL B. VOLK, ESQUIRE Address: 2933 NORTH FRONT STREET HARRISBURG, PA 17110 Attorney for: PLAINTIFF Telephone: 717-233-4101 Supreme Court ID No. 82498 0 OQ5-NT--0709 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA S & L RESIDENTIAL PROPERTIES 2933 North Front Street Harrisburg, PA 17110 Plaintiff, V. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant CIVIL ACTION - LAW NO. ?- SQL C??1:` \ Prr`? a C' s Writ No.: ?. -Yi Principal: $1,517.00 Interest to date: $26.55 Clerk's Cost c Sheriff's Cost TOTAL 10 Q n t -n r- Z O You are hereby notified to plead to the enclosed interrogatories within 30 days from service hereof or a default judgment may be entered against you. By: ichael B. Volk pozzi & Associates, PC ID No. 88553 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 Attorney for Plaintiff ?JsLJe-2S lb INTERROGATORIES IN ATTACHMENT TO: the Pennsylvania State Employees State Credit Union, commonly known as PSECU, Garnishee You must file with the court verified answers to the following interrogatories in attachment within thirty (30) days after service upon you. Failure to do so may result in a default judgment being entered against you. A copy of the answers must be served on the undersigned. your answer to any of the interrogatories is affirmative, specify the amount and value and/or completely describe the nature of the subject property. If your answer depends upon the review of any documents, account records, or other papers or electronic data, completely describe the same in exact detail (or attach a copy of the same). I . a. At the time you were served or at any subsequent time, did you owe the defendant[s] any money or were you liable to defendant[s] on any negotiable or other written instrument, or did defendant[s] claim that you owed any money or were liable to defendant[s] for any reason? No. b. To the extent that your above answer depends in whole or part on documents, account records, other papers, or electronic data, describe each in exact detail (or attach a copy of the same). N/A -2. a. 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 or one or more other persons property of any nature owned solely or in part by the defendant[s]? Yes. b. To the extent that your above answer depends in whole or part on documents, account records, or other papers or electronic data, describe each in exact detail (or attach a copy of the same). S1 Regular Shares $ 9.02* S9 Checking $887.28 *$5.00 Membership Fee held in Regular Shares. 3. a. At the time you were served or at any subsequent time, did you hold legal title to property of any nature owned solely or in part by the defendant[s] or in which defendant[s] held or claimed any interest? No. b. To the extent that your above answer depends in whole or part on documents, account records, or other papers or electronic data, describe each in exact detail (or attach a conv of the same). N/A 4. a. At the time you were served or at any subsequent time, did you hold as a fiduciary property in which the defendant[s] had an interest? No. b. To the extent that your above answer depends in whole or part on documents, account records, or other papers or electronic data, describe each in exact detail (or attach a copy of the same). N/A 5. a. At any time before or after you were served, did the defendant[s] transfer or deliver property of any nature to you or to any person or place pursuant to your direction or consent and, if so, what was the consideration therefor? No. b. To the extent that your above answer depends in whole or part on documents, account records, or other papers or electronic data, describe each in exact detail (or attach a copy of the same). N/A 6. a. At the time you were served or at any subsequent time did you pay, transfer, or deliver any money or property of any nature to the defendant[s]? No. b. To the extent that your above answer depends in whole or part on documents, account records, or other papers or electronic data, describe each in exact detail (or attach a copy of the same). N/A 7. a. At the time you were served or at any subsequent time did you pay, transfer, or deliver any money or property of any nature, to any person, entity, or place pursuant to the direction of or undertaking for, the defendant[s], e.g., lease payments, loan payments? No. b. To the extent that your above answer depends in whole or part on documents, account records, or other papers or electronic data, describe each in exact detail (or attach a copy of the same). N/A 8. a. At the time you were served or at any subsequent time, did you have, share, or utilize any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivable, license, or collateral in which there was an interest claimed by defendant[s]? No. b. To the extent that your above answer depends in whole or part on documents, account records, or other papers or electronic data, describe each in exact detail (or attach a copy of the same). N/A 9. a. Identify every account (not previously noted) titled in the name of defendant[s] in which you believe defendant[s] have an interest in whole or part, whether or not styled as a payroll account, individual retirement account, tax account, lottery account, partnership account, joint or tenants by entirety account, insurance account, trust or escrow account, attorney's account, or otherwise. None. b. To the extent that your above answer depends in whole or part on documents, account records, or other papers or electronic data, describe each in exact detail (or attach a copy of the same). N/A MI hael B. o c r r PCL? Atto ey for plaintiff -- 10 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA S & L RESIDENTIAL PROPERTIES 2933 North Front Street Harrisburg, PA 17110 Plaintiff, ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant CIVIL ACTION - LAW NO. Writ No.: _ Principal: Interest to date: Clerk's Cost Sheriffs Cost TOTAL $1,517.00 $26.55 I hereby certify that I am this day serving Interrogatories in Attachment on the person and in the manner indicated below, which service satisfies the requirements of Pa. R.C.P. 440: Service by first class mail, addressed as follows: Pennsylvania State Employees Credit Union 1 Credit Union Place Harrisburg, PA 17110 Ashley Weidner 103 N. East Street, Apartment 2 Carlisle, PA 17013 Respectfully Submitted, Date: By: is ael B. Volk CAP?ZZI & ASSOCIATES, P.C. ID# 88553 2933 North Front Street Harrisburg, PA 17110 Phone 717-233-4101 Fax 717-233-4103 Attorney for Plaintiff 11 C> ? ? ?- ?„ ? T_ -n .. -S iJ _r,; , n ? ?' : ?n .___ ? ?..?} { ? .< Donald R. Reavey, Esq. Attorney I.D. No. 82498 Michael B. Volk, Esq. Attorney I.D. No.: 88553 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 Attorneys for S & L Residential Properties IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA S & L RESIDENTIAL PROPERTIES 2933 North Front Street Harrisburg, PA 17110 Plaintiff, CIVIL ACTION - LAW NO. 04-6503 CIVIL TERM V. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant PRAECIPE TO WITHDRAW WRIT OF GARNISHMENT AGAINST PENNSYLVANIA STATE EMPLOYEES CREDIT UNION TO THE PROTHONOTARY: Please withdraw Plaintiff s Writ of Garnishment previously filed in this matter against the Pennsylvania State Employees Credit Union. "onaw tc. rwavey, nsq. Attorney I.D. No.: 82498 Michael B. Volk, Esq. Attorney I.D. No.: 88553 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA S & L RESIDENTIAL PROPERTIES 2933 North Front Street Harrisburg, PA 17110 Plaintiff, CIVIL ACTION - LAW NO. 04-6503 CIVIL TERM V. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant CERTIFICATE OF SERVICE I, Michael B. Volk, do hereby certify that on this I day of 2005,1 placed in the United States Mail, first class and via certified, a true and correct copy of Plaintiff's Praecipe to Withdraw Writ of Garnishment against the Pennsylvania State Employees Credit Union, addressed to the following: VIA FIRST CLASS MAIL: Ashley Weidner 103 N. East Street, Apartment 2 Carlisle, PA 17013 VIA FIRST CLASS MAIL: Pennsylvania State Employees Credit Union ATTN: Ms. Kathleen Weinstein, Account Supervisor 1 Credit Union Place Harrisburg, PA 17110 & AssoZatks,,P.C. Donald R. Reavey, Esq. Attorney I.D. No.: 82498 Michael B. Volk, Esq. Attorney I.D. No.: 88553 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 Attorneys for Plaintiff (_} ?.> r'} ^-' `il u1t -- -r_ _. ??,-. -'SC; «i ??'? ;; > ::- _. '- rn cn :' _, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA S & L RESIDENTIAL PROPERTIES 2933 North Front Street Harrisburg, PA 17110 Plaintiff, CIVIL ACTION - LAW NO. 04-6503 CIVIL TERM V. ASHLEY WEIDNER 114 North Bedford Street Carlisle, PA 17013 Defendant NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 S & L Residential Properties, Plaintiff, intends to serve a subpoena identical to the ones that are attached to this notice. You have 20 days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoenas may be served. Michael B. Volk, Esquire Supreme Court I.D. No.: 88553 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA S & L RESIDENTIAL PROPERTIES 2933 North Front Street Harrisburg, PA 17110 Plaintiff, CIVIL ACTION - LAW NO. 04-6503 CIVIL TERM V. ASHLEY WEIDNER 114 North Bedford Street Carlisle, PA 17013 Defendant CERTIFICATE OF SERVICE I, Michael B. Volk, Esquire do hereby certify that on this the/ day of 2005, I served a true and correct copy of the Notice of Intent to Serve Subpoenas to Produce Documents and Things for Discovery Pursuant to Rule 4009.2 1, via first class mail, with Certificate of Mailing, addressed to the following: Ashley Weidner 114 North Bedford Street Carlisle, PA 17013 Date: /? 1?1,?A,,,1--- /"- Michael B. Volk, Esquire Supreme Court I.D. No.: 88553 2933 North Front Street Harrisburg, PA 171 10 (717) 233-4101 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA S & L RESIDENTIAL PROPERTIES 2933 North Front Street Harrisburg, PA 17110 Plaintiff, CIVIL ACTION - LAW NO. 04-6503 CIVIL TERM V. ASHLEY WEIDNER 114 North Bedford Street Carlisle, PA 17013 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THNI FOR DISCOVERY PURSUANT OT RULE 4009.22 TO: Ronald C. Holby 29011 SW 194`" Avenue Homestead, FL 33030 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all information related to Tracy M. McNeal, current resident at 139 North 13`h Street, Harrisburg, PA 17103, including, but not limited to rental or lease agreements, employment, asset and/or bank account information and copies of cancelled checks. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the service of compliance, to the party making this address at the address shown above. You have (lie right to seek, in advance, the reasonable cost of preparing copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Michael B. Volk 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 Supreme Court I.D. 88553 Attorney for G & C .Associates, L.LC. Date: Prothonotary sent of the Cow I hJ (? ?? C_l .,> 'Ij ?:s '-{ C_i r._ !_.'" ?I]? . ni : ?' '^ --j i; m_t 1???. (\) ? ??? -1 r `;J U. -< IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA S&L Residential Properties 2933 North Front Street Harrisburg, PA 17110 Plaintiff V. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant. § CIVIL ACTION - LAW § CAUSE NO.: 04-6503 CIVIL TERM § § § P R A E C I P E TO RECORD TRANSMITTAL OF PROPOSED MOTION AND ORDER PURSUANT TO CUMBERLAND COUNTY LOCAL RULE 208.2 To the Prothonotary: Kindly file the attached letter of transmittal for a proposed motion and order in this matter, pursuant to Cumberland county Local Rule 208.2. RESPECTFULLY SUBMITTED: By: C?1) 111 Michael B. Volk, Esquire Attorney I.D. # 88553 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 Attorney for Plaintiff Lquis J. Capozzi. Jr.. Esquire* Daniel K. Natirboff. Esquire Donald R. Reavev. Esquire Doreena C. Sloan, Esquire Michael B. Volk. Esquire Joseph F. Murphy, Esquire Kirk S. Sohonage, Esquire Bruce G. Baron, Research Coordinator Robert G. Sobanski, Reimb. Analyst Raymond Schuenemann, Law Clerk Karen L. Fisher, Paralegal Susan Courchesne, Paralegal Amanda Howard, Paralegal Amy Reavev, Paralegal Lmcmed in Pk NJ, ND 2933 North Front Street Harrisbum. PA 171 10 Ca o I & Associates, P.C. Telephone: (71') 233--1101 ttorn aw Fax: (717)233-4103 www. capozziassoc iates. co m y"' = Victor J. Bierman', III Esq. 3 Dennis A. Roth', Esq. t t Vincent E. Fisher , Esq. A Of Counsel I L n d O m ,,, , ]LicensedIn OK H. Pk FL January 25, 2006 Ashley Weidner 103 North East Street, Apartment 2 Carlisle, PA 17013 Re: Filing of Motion; S& L v. Ashley Weidner Dear Ms. Weidner, Enclosed please find a Motion that I intend to file with the Court regarding this matter. Please contact me so that I may know whether or not you concur with the filing of this Motion. If I do not hear from you within 7 days from the date of this letter, I will assume that you do not concur with the filing of the Motion. Please feel free to contact me if you have any questions. Until then, I remain, Respectfully yours, J cif u j `16 UA- Michael B. Volk IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA S&L Residential Properties 2933 North Front Street Harrisburg, PA 17110 Plaintiff V. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant. § CIVIL ACTION - LAW § CAUSE NO.: 04-6503 CIVIL TERM § § MOTION FOR DISCLOSURE OF INFORMATION TO THE HONORABLE JUDGE OF SAID COURT: AND NOW, comes the Plaintiff, S&L Residential Properties, by and through its attorneys, Capozzi & Associates, P.C., hereby files this Motion for the Turnover of Information upon Defendant and in support thereof avers as follows: I. Pursuant to Cumberland County Local Rule 208.2(d), attorney for Movant hereby certifies that the full text of this motion and proposed order was transmitted to all parties, seeking their concurrence or nonconcurrance in this matter. No party has responded to the inquiry regarding concurrence. A copy of the correspondence is attached as Exhibit 1' 2. This matter arises out of a collections action for moneys owed pursuant to a residential lease agreement. 3. Judgment was entered against Defendant by District Justice James Pianka, District 12-1-02 on August 25, 2004, in the amount of S 1,517.00. 4. The District Justice Judgment was filed with this Court on or about October, 2005 under docket number 04-6503 CIVIL TERM. 5. Pursuant to 42 Pa.C.S.A. § 8127, the Plaintiff is entitled to garnish 10% of the net wages per pay period of the Defendant, the judgment debtor-tenant. 6. At this time, Defendant's employer is unknown. The Plaintiff requests that this Court issue an order directing the Pennsylvania Department of Labor and the Pennsylvania Department of Revenue to disclose to Plaintiff the name and address of Defendant's current employer and subsequently, any future employers. WHEREFORE, Plaintiff respectfully requests that this Honorable Court issue a rule ordering Defendant to show cause why Plaintiffs request should not be granted. Respectfully Submitted: Date: Michael B. Volk, Esq. Attorney I.D. No.: 88553 2933 North Front Street Harrisburg, PA 17110 Phone 717-233-4101 Fax 717-233-4103 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA S&L Residential Properties 2933 North Front Street Harrisburg, PA 17110 Plaintiff v. CIVIL ACTION - LAW CAUSE NO.: 04-6503 CIVIL TERM ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant. AND NOW, this day of RULE 2006, upon consideration of Plaintiff's Motion for Disclosure of Information , a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. Rule returnable fourteen (14) days from the date of service via regular mail. In the event Defendant fails to respond to this rule, Plaintiff shall file a Petition to Make Rule Absolute, at which point an Order granting Plaintiff's Motion will be issued. BY THE COURT: J. Distribution: Michael B. Volk, Esq., 2933 North Front Street, Harrisburg, PA 17110 ASHLEY WEIDNER,103 N. East Street, Apartment 2,Carlisle, PA 17013 IN THE COURT OF COMNION PLEAS FOR CUMBERLAND COUNTY PENNSYLVANIA S&L Residential Properties 2933 North Front Street Harrisburg, PA 171 10 Plaintiff V. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant. § CIVIL ACTION - LAW § CAUSE NO.: 04-6503 CIVIL TERM CERTIFICATE OF SERVICE 1 hereby certify that I am this day serving Motion for the disclosure of Information upon the person and in the manner indicated below, which service satisfies the requirements of Pa. R.C.P. 440: Service by first class mail, addressed as follows: ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Respectfully Submitted, Date: Michael B. Volk, Esq. Attorney I.D. No.. 88553 2933 North Front Street Harrisburg, PA 171 10 Phone 717-233-4101 Fax 717-233-4103 Attorney for Plaintiff 6 ? J 11.?,? Xr L -n ; f r i Fq N _ I Cl ?--? fi ? N = 1 I IN THE COURT OF COMMON PLEAS FOR CUMBERLA! PENNSYLVANIA S&L Residential Properties 2933 North Front Street Harrisburg, PA 17110 Plaintiff V. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle. PA 17013 Defendant. § CIVIL ACTION - LAW § CAUSE NO.: 04-6503 CIVIL TERM 4 ti § 1 MOTION FOR DISCLOSURE OF INFORMATION TO THE HONORABLE JUDGE OF SAID COUR"1 : AND NOW, comes the Plaintiff, S&L Residential Properties, by and through its L-: attorneys, Capozzi & Associates, V.C., hereby files this Motion for the Turnover of Information upon Defendant and in support thereof avers as follows: 1. Pursuant to Cumberland County Local Rule 208.2(d), attorney for Movant hereby certifies that the full text of this motion and proposed order was transmitted to all parties, seeking their concurrence or nonconcurrance in this matter. No party has responded to the inquiry regarding concurrence. A copy of the correspondence is attached as Exhibit 1' 2. This matter arises out of a collections action for moneys owed pursuant to a residential lease agreement. 3. Judgment was entered against Defendant by District Justice James Pianka, District 12-1-02 on August 25, 2004, in the amount of $1,517.00. 4. The District Justice Judgment was filed with this Court on or about October.. 2005 under docket number 04-6503 CIVIL TERM. 5. Pursuant to 42 Pa.C.S.A. § 8127, the Plaintiff is entitled to garnish 10% of the net wages per pay period of the Defendant, the judgment debtor-tenant. 6. At this time, Defendant's employer is unknown. The Plaintiff requests that this Cows issue an order directing the Pennsylvania Department of Labor and the `Ti F Pennsylvania Department of Revenue to disclose to Plaintiff the name and address of Defendant's current employer and subsequently, any future employers. WHEREFORE. Plaintiff respectfully requests that this Ilonorabte Court issue a rule ordering Defendant to show cause why Plaintift's request should not be granted. Date: Respectfully Submitted: Michael B. Volk, Esq. Attorney LD. No.: 88553 2933 North Front Street Harrisburg, PA 17110 Phone 717-233-4101 Fax 717-233-4103 Attorney for Plaintiff IN THE COURT OFCOMMON PLEAS FOR CUMBERLAND COUNTY PENNSYLVANIA S&L Residential Properties 2933 North Front Street Harrisburg. PA 17110 Plaintiff v. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant § CIVIL ACTION- LAW § CAUSE NO.: 04-6503 CIVIL TERM ti i ti CERTIFICATE OF SERVICE I hereby certify that I am this day serving Motion for the disclosure of Information upon the person and in the manner indicated below, which service satisfies the requirements of Pa. R.C.P. 440: Service by first class mail, addressed as follows: ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Respectfully Submitted, Date: Michael B. Volk, Esq. Attorney I.D. No.: 88553 2933 North Front Street Harrisburg, PA 17110 Phone 717-233-4101 Fax 717-233-4103 Attorney for Plaintiff IN THE COURT OF COMNION PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA _ . 1 I S&L Residential Properties § CIVIL ACTION - LAW_- 2933 North Front Street § Harrisburg, PA 171 10 § CAUSE NO.: 04-6503 CIVIL TERM Plaintiff 3 ASHLEY WEIDNER § 103 N. East Street, Apartment 2 § Carlisle, PA 170L3 § Defendant. § P R A E C I P E TO RECORD TRANSMITTAL OF PROPOSED MOTION AND ORDER PURSUANT TO CUMB To the Prothonotary: AND COUNTY LOCAL RULE 208.2 Kindly file the attached letter of transmittal for a proposed motion and order in this matter, pursuant to Cumberland county Local Rule 208.2. RESPECTFULLY SUBMITTED: By: lc'-60'Q Z)>Y?L Michael B. Volk, Esquire Attorney I.D. 9 88553 2933 North Front Street Harrisburg, PA 17110 (717)233-4101 Attorney for Plaintiff a.?M r> o Z - ro cv c -- z J N W Louis J. Capozzi. Jr.. Esquire' Daniel K. Natirboff. Esquire Donald R. Reavev. Esquire Doreena C. Sloan. Esquire Michael B Volk. Esquire Joseph F. Murphy. Esquire Kirk S. Sohona2e. Esquire Bruce G. Baron, Research Coordinator Robert G. Sobanski. Reimb. Analyst Racmond Schuer,emann. Law Clerk Karen L. Fisher. Parale_al Susan Courcheme. Paralegal Amanda Howard, Parale_al Amy Reavey, Paralegal Lmentta In 2a, V. SID Ashley Weidner 103 North East Street, Apartment 2 Carlisle. PA 17013 1933 Sorh Fror.t Harrisburg. PA 17 i i0 sociates, P.C. Telephone: (717) 31 a &'? w Fax (-1-) 333-a; u3 www capozziassociates cam January 25, 2006 Victor J. Bierman. HI Esq. Dennis A. Roth'. Esq. r. t 3 Vincent E. Fisher', Esc. Of Counsel ?k„ ez. - - L IZ15,1 .i OR Re: Filing of Motion: S& L v. Ashley Weidner Dear Iris. Weidner, Enclosed please find a Motion that I intend to file with the Court regarding this matter. Please contact me so that I may know whether or not you concur «ith the filing of this Motion. If I do not hear from you within 7 days from the date of this letter, I will assume that you do not concur with the filing of the Motion. Please feel free to contact me if you have any questions. ]Until then, I remain, Respectfully yours, Caoo- & Y t t,;- r. ,. Michael B. Volk IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA S&L Residential Properties 2933 North Front Street Hamsbure. PA 17110 Plaintiff v. CIVIL ACTION- LAW CAUSE NO.: 04-6503 CIVIL TERM ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle. PA 17013 Defendant. iyIOTION FOR DISCLOSURE OF INFORMATION TO THE HONORABLE JUDGE OF SAID COURT: AND NOW, comes the Plaintiff, S&L Residential Properties, by and through its attorneys, Capozzi & Associates, P.C., hereby files this Motion for the Turnover of Information upon Defendant and in support thereof avers as follows: Pursuant to Cumberland County Local Rule 208.2(d), attorney for Movant hereby certifies that the full text of this motion and proposed order was transmitted to all parties, seeking their concurrence or nonconcurrance in this matter. No party- has responded to the inquiry regarding concurrence. A copy of the correspondence is attached as Exhibit I„ 1 This matter arises out of a collections action for moneys owed pursuant to a residential tease agreement. 3. Judgment was entered against Defendant by District Justice James Pianka, District 12-1-02 on August 25. 2004, in the amount of S t,517.00. 4. The District Justice Judgment «as tiled with this Court on or about October, 2005 under docket number 04-6503 CIVIL TERM. 5. Pursuant to 42 Pa.C.S.A. 3 8127, the Plaintiff is entitled to garnish 10% of the net wages per pay period of the Defendant, the judgment debtor-tenant. 6. At this time, Defendant's employer is unknown. The Plaintiff requests that this Court issue an order directing the Pennsylvania Department of Labor and the Pennsylvania Department of Revenue to disclose to Plaintiff the ::a-:e and address of Defendant's current employer and subsequently, any funtre emolo?ers. WHEREFORE, Plaintiff respectfully requests that this Honorable Court issue a rule ordering Defendant to show cause why Plaintiff s request should not be granted. Respectfully Submitted: Date: Michael B. Volk, Esq. Attorney I.D. No.: 88553 2933 North Front Street Harrisburg. PA 17110 Phone 717-233-4101 Fax 717-233-4103 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA S&L Residential Properties 2933 North Front Street Harrisburg, PA 17110 Plaintiff v. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant. § CIVIL ACTION -LAW § § CAUSE NO.: 04-6603 CIVIL TERM RULE AND NOW, this day of 2006, upon consideration of Plaintiffs Motion for Disclosure of Information , a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. Rule returnable fourteen (14) days from the date of service via regular mail. In the event Defendant fails to respond to this rule, Plaintiff shall file a Petition to Make Rule Absolute, at which point an Order granting Plaintiffs Motion will be issued. BY THE COURT: J. Distribution: Michael B. Volk, Esq., 293, North Front Street, Harrisburg. PA 17110 ASHLEY WEIDNER ,103 N. East Street, Apartment 2,Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY PENNSYLVANIA S&L Residential Properties 2933 North Front Street Harrisburg. PA 171 10 Plaintiff V. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant. § CIVIL ACTION - LAW 3 § CAUSE NO.: 04-6=03 CIVIL TERM § § § CERTIFICATE OF SERVICE I hereby certify that I am this day serving Motion for the disclosure of Information upon the person and in the manner indicated below, which service satisfies the requirements of Pa. R.C.P. 440: Service by first class mail, addressed as follows: ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle. PA 17013 Respectfully Submitted, Date: Michael B. Volk, Esq. Attorney I.D. No.: 88553 2933 North Front Street Harrisburg, PA 17110 Phone 717-233-4101 Far 717-233-1103 Attorney for Plaintiff 5 IN TIIE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA S&L Residential Properties 2933 North Front Street Harrisburg, PA 17110 Plaintiff v. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle. PA 17013 Defendant. § CIVIL ACTION - LAW § CAUSE NO.: 04-6503 CIVIL TERM RULE AND NOW, this day of 7006, upon consideration of Plaintiffs Motion for Disclosure of Information , a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. Rule returnable fourteen (14) days from the date of service via regular mail. In the event Defendant fails to respond to this rule, Plaintiff shall file a Petition to Make Rule Absolute, at which point an Order granting Plaintiffs Motion will be issued. BY THE COURT: Distribution: Michael B. Volk, Esq., 2933 North Front Street, Harrisburg, PA 1711() ASHLEY WEIDNER ,103 N. East Street, Apartment 2 ,Carlisle, PA 17013 J" ' _. ? 'i r?_? ? ???1? ?: ,.. i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA S & L RESIDENTIAL PROPERTIES 2933 North Front Street Harrisburg, PA 17110 Plaintiff, CIVIL ACTION - LAW NO. 04-6503 CIVIL TERM V. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant CERTIFICATE OF SERVICE I, Karen L. Fisher, an employee of Capozzi and Associates, P.C., do hereby certify that on this 2- day of 2006, I placed in the United States Mail first class and via certified, a true and correct copy of the Rule issued February 23, 2006, addressed as follows: VIA FIRST CLASS U.S. MAIL: Ashley Weidner 103 N. East Street, Apartment 2 Carlisle, PA 17013 Ashley Weidner 167 East Penn Street Carlisle, PA 17013 Ashley Weidner 114 North Bedford Street Carlisle, PA 17013 Date: slk? Respectfully submitted, CAPOZZI & ASSOS?. Ka n L. Fisher, Paralegal BYe?d 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 Attorney for Plaintiff M IN THE COURT OF COMMON PLEAS FOR CL\MBERLAND COUNT), PENNSYLVANIA S&L Residential Properties 2933 North Front Street Harrisburg, PA 17110 Plaintiff v. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle. PA 17013 Defendant § CIVIL ACTION - LA W § CAUSE NO.:04-6503 CIVIL TERM `i F RULE AND NOW, this d 3,,?4t day of -. 2006. upon consideration of' Plaintiffs Motion for Disclosure of Information , a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. Rule returnable fourteen (14) days from the date of service via regular mail. In the event Defendant fails to respond to this rule, Plaintiff shall file a Petition to Make Rule Absolute, at which point an Order granting Plaintiff's Motion will be issued. BY THE COURT f/rj /'l I Distribution: Michael B. Volk, Esq \SHI FY WTID'\' P 2933 North Front Street, Haiiisbur ,, PA 171 10 1 W N. East Street, Apartmcnt ?,Carhi lc, PA 17013 % Tr :. y 0( ? ? ?auk -- ProtP?4nrst6fd IN THE COURT OF CWIMON PLEAS FOR CUMBERLAND COUNTY, ? PENNSYLVANIA S&L Residential Properties 2933 North Front Street ilamsburg, PA 17110 Plaintiff ASHLEY WEIDNER 10, N. East Sweet, Apartment 2 Carlisle. PA 17013 Defendant CIVIL ACTION - LAW CAUSE NO.: 04-6503 CIVIL TERM TION FOR DISCLOSURE OF INFORMATION TO THE HONORABLE JUDGE OF SAID COURT _ r c- j AND NOW, comes the Plaintiff, S&L Residential Properties, by and through its attorneys, Capozzi & Associates, P.C., hereby files this Motion for the Turno% cr of Information upon Defendant and in support thereof avers as follows: Pursuant to Cumberland County Local Rule 208.2(d), attorney for Movant hereby certifies that the full text of this motion and proposed order was transmitted to all parties, seeking their concurrence or nonconcunance in this matter. No party, has responded to the inquiry regarding concurrence. A copy of the correspondence is attached as Exhibit ,1, 2. I-his matter arises out of a collections action for moneys owed pursuant to a residential lease agreement. 3 Judgment was entered against Defendant by District Justice James Pianka, District 12-1-02 on August 25, 2004. in the amount of$1,51 Z00. 4 The District Justice Judgment ?k?as tiled with this Court on or about October, 2003 under docket number 04-6503 CIV11_ TERM. 5. Pursuant to 42 Pa.C.S-A. § 8127, the Plaintiff is entitled to garnish 10'/0 of the net wages per pay period of the Defendant, the judgment debtor-tenant. b. At this trine, Defendant's employer is unknown. t he Plaintiff requests that this Cott „uc an Cudel Directing tTt? r'ci;ns}l? aMILL Deb Li 111crnt t l_ahor a11d the Pennsylvania Department of Revenue to disclose to Plaintiff the name and address of Defendant's cunent employer and suhsequently, anv future cmptoyer; WHEREFORE, Plaintiff respectfully rcyuests that this Honorabte Court issue a ule ordering Defendant to show cause why Plaintiff's request should not he granted Respectfully Submitted 7 1 ts' [)are: j Michael B. Volk, Esq. Attorney I.D. No.: 88553 2933 North Front Street Harrisburg, PA 171 10 Phone 717-233-4101 Fax 7 17-233-4 103 Attorney for Plainti If IN THE COURT OF COMNION PLEAS FOR CUMBERLAND COUNTY PENNSYLVANIA S&L Residential Properties 293', North Front Strect Harisburg, PA 17110 Plaintiff v. ASHLEY Wl"IDNER 10") N. East Street, Apartment 2 Carlisle, PA 17013 Defendant. CIVIL ACTION - LAyV 3 CAUSE NO.: 04-6503 CJVIL I-ERM S ti i CERTIFICATE OF SERVICE 1 hereby certify that 1 am this day serving Motion for the disclosure of Information upon the person and in the manner indicated below, which service satisfies the requirements of Pa. R.C-P. 440'. Service by first class mail, addressed as follows: ASHLEY WEIDNER t 03 N. East Street, Apartment 2 Carlisle, PA 17013 Respectfully Submitted, Date r t ? r ? 7_ Michael H. Volk, Esq. Attomey I.D. No.: 88553 2933 North Front Street Harrisburg, PA 171 10 Phone 717-233-4101 Fax 717-233-4103 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COL\TY,? PENNSYLA'ANIA _ ._- S&L Residential Properties 2933 North Front Street Harrisburg, PA 1 7110 Plaintiff ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant. CIVIL ACTION - LAW_-= J CAUSE NO.: 04-6503 CIVIL TERM ?Vl P R A E C I P E TO RECORD TRANSMITTAL OF PROPOSED MOTION .AND ORDER PURSUANT TO CUMBERLAND COUNTY LOCAL RULE 208.2 To the Prothonotary: Kindly file the attached letter of transmittal for a proposed motion and order in this matter, pursuant to Cumberland county Local Rule 20S.2. RESPECTFULLY SUBMITTED: By: Michael B. Volk, Esquire Attorney LD. # 88553 2933 North Front Street Harrsburg, PA 17110 (717)2;3-4101 Attorney for Plaintiff t I?M C7 o O c , r ri'. r :nom _ rQ ;-. c, i N _? Louis 1. Calr=:. ;r.. Esquire' Daniel K. Vatirboff. Esquire Donald R- Reavev. Esquire Doreena C Sloan. Esquire Michael B Volk. Esquire Joseph F, Nturphc. Esquire KrkS Sohona2e.Esquire Bruce G. Baron. R.searc Coordinator Robert G. Sobansk,. Reirro Analyst Raymond Sch_enennarm Law Clerk Karen L. Fisher. Paralegal Susan Courehesne. Paralegal Amanda Howard. Parale_al .Amy Reavev, Paralegal L? -c mP,.'l'0 Ashley Weidner 103 North East Street, Apartment 2 Carlisle. PA 17013 Telephone av) Fax (71 www capozziasocia2scnm i? a' _ c'or1 Bie-ma r Dennis A Roth E?a L ncent E. Furor-. Esc. Cif Counsel L¢nstl , ONa January 25, 2006 Re: Filing of Motion: S& L v. Ashley Weidner Dear NIs. Weidner. Enclosed please find a Motion that I intend to file with the Court regarding this matter. Please contact me so that I may know whether or not you concur,Aith the filing of this Motion. If I do not hear from you within 7 days from the date of this leaer, I will assume that you do not concur with the filing of the Motion. Please feel free to contact me if you ha%e any questions. Until then, I remain, Respectfully yours, Ca o &. horn ?9;_ Dorf. Fmn; =.:._. Harri>bur_e. PA 1- !0 ociates, P.C. fix. ? ?a Michael B. Volk IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA S&L Residential Properties 2933 Nosh Front Street Hamsburg. PA 1-110 Plaintiff ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle. PA 17013 Defendant. y CIVIL ACTION - LAW s 7 CAUSE NO.: 04-6503 CIVIL TERM Y Y J 3 5 3 MOTION FOR DISCLOSURE OF INFOR-NIATION TO THE HONORABLE JUDGE OF SAID COURT: AND NOW, comes the Plaintiff, S&L Residential Properties, by and through its attorneys, Capozzi & Associates, P.C., hereby files this Motion for the Turnover of Information upon Defendant and in support thereof avers as follows: Pursuant to Cumberland County Local Rule 208.2(4), attorney for Movant hereby certifies that the fall text of this motion and proposed order was transmitted to all parties, seeking their concurrence or nonconcurrance in this matter. No party has responded to the inquiry regarding concurrence. A copy of the correspondence is attached as Exhibit ..1., 2. This matter anses out of a collections action for moneys o%? ed Pursuant to a residential lease agreement. 3. Judgment was entered against Defendant by District Just:ce James Pianka, District 12-1-02 on August 25. 2004, in the amount of S 1,51700- 4. Tne District Justice Judarnent,a as tiled with this Court o?: or about October, 2005 under docket number 04-6503 CIVIL TERM. 5 Pursuant to 43 Pa.CS._A. S I17, the Plaintiff is entitled t.> >anish 104'0 of the r,et wages per pay period of the Defendant, the judgment dcbtot ten-a. G. At _.,.? t]..ic, L?l tl.?a. _;'.I .1Yp10? U1'?i?l. T1: P1. -J.tt t i1e`. t:i ?h St tb'.5 ?OUrt iSille an Urd Cr lllrc'C:me Inc PCn1:?_`1I`v ar7la lir111I 1i1Clli JI 1 a0l`f ':lQ InC Pennsylvania Department of Revenue to disclose to Plaintiff the .a-.e and address of Defendant's current employer and subsequently, arts' future emplo} ers. NN'HEREFORE, Plaintiff respectfully requests that this Honorable Court issue a rule ordering Defendant to show cause why Plaintiffs request should not be granted. Respectfully Submitted: Date: Michael B. Volk, Esq. Attomey I.D. \o.: 88553 2933 North Front Street Harrisburg. PA 17110 Phone 717-233-4101 Fax 717-23-4103 Attorney for Plaintiff IN TAE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA S&L Residential Properties 2933 North Front Street Har-,sbu,-2, PA 17110 Plaintiff c. CIVIL ACTION - LAW CAUSE NO.: 04-650 CIVIL TERM ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle. PA 17013 Defendant. AND NOW, this day of RULE 2006, upon consideration of Plaintiff's %lotion for Disclosure of Information , a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. Rule returnable fourteen (14) days from the date of service via regular mail. In the event Defendant fails to respond to this rule, Plaintiff shall file a Petition to ,lake Rule.-\bsolute, at which point an Order granting Plaintiffs Motion will be issued. BY THE COURT: J. Distribution: 1! !,se1 B >Ik. Es?l ?y> N(,rth Front Street. Namsburv. P.'1 171 10 :ASHLEY WEIDNER ,10, N. East Street, Apartment 2,Carlisle. P.A 17013 IN THE COLRT OF CONIN'ION PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA S&L Residential Properties 2933 North Front Street Hamsbur<=. PA 17110 Plaintiff V. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant. 3 CIVIL ACTION - LAW J CAUSE NO 04-6403 CIVIL TERM § § § § CERTIFICATE OF SERVICE I hereby certify that I am this day serving Motion for the disclosure of Information upon the person and in the manner indicated below, which service satisfies the requirements of Pa. R.C.P. 440: Service by first class mail, addressed as follows: ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle. PA 17013 Respectfully Submitted, Date: Michael B. Volk, Esq. Attorney LD. No.: 35553 2933 North Front Street Harrisburg, PA 17110 Phone 717-233-4101 Fax 717-'_33-4103 Attorney for Plaintiff ( l ?? i? . j ' ? > a c_,., WRIT OF EXECUTION and/or ATTACH NT W5- t-4-r- o709 COMMONWEALTH OF PENNSYLVANIA) NO 04-6503 Civil V? COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF bAU.Pg i W )COUNTY: To satisfy the debt, interest and costs due S & L RESIDENTIAL PROPERTIES, Plaintiff (s) From ASHLEY WEIDNER, 103 N. EAST STREET, APARTMENT 2, CARLISLE, PA 17013 (1) 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 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, COMMONLY KNOWN AS PSECU, LOCATED AT 1 CREDIT UNION PLACE, HARRISBURG, PA 17110 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 $1,517.00 L.L. $.50 Interest TO DATE - $26.55 Na ca Atty's Comm % Due Prothy $1.00 C Atty Paid $38.00 Other Costs M _.- ,. , Pl t ff P id y t. ?a?. oo Dxv4w n Co UY. ' crn ain i a • c- , Z- (° -+v Date: FEBRUARY 23, 2005 C : =C CURTIS R. LONG - r ., Prothonotary (Seal) REQUESTING PARTY: Name MICHAEL B. VOLK, ESQUIRE Address: 2933 NORTH FRONT STREET HARRISBURG, PA 17110 Attorney for: PLAINTIFF Telephone: 717-233-4101 Supreme Court ID No. 82498 Deputy -.Q CD C> 7:0 3, C1 r r, x.. f _.j L 4 % SHERIFF'S RETURN 0708-NT - - -2005 PERSONAL PROPERTY WRIT OF EXECUTION & INTERROGATORIES S&L RESIDENTIAL PROPERTIES vs WEIDNER ASHLEY And Now: March 17, 2005 at 11:51 A.M. RECEIVED FROM PROTHONOTARY - PP And Now: March 23, 2005 at 9:13 A.M. INITIAL SERVICE And Now: March 23, 2005 at 9:14 A.M. PAYMENT RECEIVED Receipt # 205156 And Now: March 24, 2005 at 10:04 A.M. SERVED GARNISHEE(S) And Now: March 24, 2005 at 10:04 A.M. AS COMMANDED DID ATTACH ALL MONIES DEBTS, CREDITS, RIGHTS, INTEREST, REAL & PERSONAL PROPERTY OF ASHLEY WEIDNER DEFT IN HANDS OF PSECU GAR BY HANDING TO HARRY SMITH COLL MGR A TRUE COPY OF WRIT/INTERROGATORIES AND MAKING KNOWN TO HIM CONTENTS THEREOF AT ONE CREDIT UNION PLACE HBG PA. ALSO LEFT WITH GARNISHEE A LIKE COPY OF WITHIN WRIT FOR WITHIN NAMED DEFT. And Now: April 15, 2005 at 9:08 A.M. PP - REQUEST LETTER TO STAY And Now: November 22, 2006 at 7:31 A.M. PP - EXPIRED Sheriff's Costs $56.00 State/Prothonotary Fee $20.00 Poundage $76.00 n. /I- °1;.- 6 b RH So Answers, M J. R. Lotwick, Sheriff 11/22/2006 PAGE 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA S & L RESIDENTIAL PROPERTIES 2933 North Front Street Harrisburg, PA 17110 Plaintiff, V. ASHLEY WEIDNER 103 N. East Street, Apartment 2 Carlisle, PA 17013 Defendant Principal: Interest to date: Clerk's Cost Sheriff's Cost TOTAL WRIT OF EXECUTION NOTICE 517.00 $1 , $26.55 C-_ C:) C:? r 0 This paper is a Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. The law provides that certain property cannot be taken. Such property is said to be exempt. There is a debtor's exemption of $300.00. There are other exemptions, which may be applicable to you. Attached is a summary of some of the major exemptions. You may have other exemptions or other rights. If you have an exemption, you should do the following promptly: (1) Fill out the attached claim form and demand for a prompt hearing. (2) Deliver the form or mail it to the Sheriff s Office at the address noted. You should come to court ready to explain your exemption. If you do not come and prove your exemptions, you may lose some of your property. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 CIVIL ACTION - LAW NO. Writ No.. Pd 3 w n r N O O Ul rD r r r NxNx xord W w tO H• w : v? 1-1 LA) 0 C fD I n w w r• C? C CA Z (D En r O '(D ?0 G O v fti C v bn O ?t1::1 w0r H. • ?:s x O rt ? F' F-? rd vEn tri yr rrt U) rA? Nrt? Nn Om C> (D (D rr n d o o 0 '' R ri rt W "? t' O r r 00 r• ? Z m En O O ?e cu r• K ( y (D rr N ' ? a N ? cn m ?-d M 4+ c n ? p w w 0 v, • co M ?• ?* M w r r v ?n O rt b pi W (D O (D b rt n rt H. m co