HomeMy WebLinkAbout14-0700 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Cavalry SPV I, LLC
Plaintiff NO.
V. CIVIL ACTION -LAW b=
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MARY HARVEY
Defendant(s) CD CD {
PRAECIPE TO ENTER JUDGMENT ON
MAGISTERIAL DISTRICT JUDGE'S TRANSCRIPT OF JUDGMENT
In accordance with the transcript of the Magisterial District Judge which is attached hereto, enter
judgment in favor of Plaintiff and against Defendant, in the sum of $ 2655.02 , which consists of
$ 2538.66 as principal, $0.00 as interest and $ 116.36 as costs less payments of $ 0.00 , plus interest
thereon from the date of that judgment, as provided bylaw.
Respectfully S m' d,
By:
Michael B. Volk, Esq. #885530
Fulton, Friedman & Gullace LLP
Counsel for Plaintiff
6 Kacey Court, Suite 203
Mechanicsburg, PA 17055
Tel: (866) 563 -0809 Fax: (585) 546 -4241
AFFIRMATION OF NO APPEAL
As of the date of this filing a District Justice appeal has not been e 1- the Court of Common Pleas
of CUMBERLAND County.
Michael B. Volk, Esq. #885530
FFG file #: 380795
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Cavalry SPV I, LLC
111
Plaintiff NO. )q-
V. CIVIL ACTION - LAW
i
MARY HARVEY
Defendant(s)
NOTICE OF JUDGMENT
In accordance with the transcript of the Magisterial District Judge which is attached hereto, enter
judgment in favor of Plaintiff and against Defendant, in the sum of $ 2655.02 , which consists of
$ 2538.66 as principal, $0.00 as interest and $ 116.36 as costs less payments of $ 0.00 , plus interest
thereon from the date of that judgment, as provided by law.
NOW, 10—,20—ffl JUDGMENT I NTEh - D7 BOVE.
Protho Clerk, Civil Division
By:
Deputy
I hereby certify that the name and address of the proper person to receive this notice under
Pa. R. Civ. P. 236 is:
MARY HARVEY
115 W MAIN ST
CAMP HILL PA 17011 -6329
Defendant(s)
Michael B. Volk, Esq. #885530
FFG file #: 380795
IIIIIIIVIIIIIIIIIIIIIIIIIIVIIIVIIIIIIIIIIIIIIIIIIIVIIIIII IIII
PAPA TRANSJ
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Cavalry SPV 1, LLC
Plaintiff NO. J - lob CC
V. CIVIL ACTION - LAW
MARY HARVEY
Defendants)
CERTIFICATE OF LAST KNOWN ADDRESS
I hereby certify that the last known address of Defendant and the Plaintiff are as follows:
MARY HARVEY Cavalry SPV 1,
115 W MAIN ST 500 SUMMIT DRIVE
CAMP HILL PA 17011 -6329 VALHALL 0595 -1340
Michael B. Volk, Esq. #885530
CERTIFICATE OF SERVICE
I, Michael B. Volk, an authorized agent for Fulton, Friedman & Gullace, LLP, hereby certify that a
copy of the foregoing Praecipe to Enter Judgment on the Magisterial District Judge's Transcript of
Judgment was served this date by mailing same via first class mail, postage prepaid, addressed as
follows:
MARY HARVEY
115 W MAIN ST
CAMP HILL PA 17011 -6329 1
Defendant(s)
Date: 2014 l
Michael B. Volk, Esq. 4885530
FF file#: 380795 `
l IIIIIi I'll) (IIII Illil Illii IIII) VIII IIIIIII II IIIIIII VIII III IIII
PA1PA_TRANS3
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COMMONWEALTH OF PENNSYLVANIA Notice Of Judgment/Transcript Civil
COUNTY OF CUMBERLAND Case
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Mag. Dist. No: MDJ- 09 -1 -01 Cavalry, SPV I, LLC C/o Fulton Friedman &
MDJ Name: Honorable Charles A. Clement Jr. Gullace, LLP
Address: 920 Linda Lane V.
Camp Hill, PA 17011 Mary Harvey
l'e l e p h o n e: 717- 737 -3434
Michael B. Volk, Esq. Docket No: MJ- 09101 -CV- 0000423 -2013
Fulton Friedman & Gullace, LLP Case Filed: 10/28/2013
6 Kacey Court, Suite 203 c. =
Mechanicsburg, PA 17055
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Disposition Summary (cc - Cross complaint)
Docket No Plaintiff Defendant Disposition p = Disc sitiofi Date
MJ-091 01 -CV-0000423-2013 Cavalry, SPV I, LLC c/o Fulton Mary Harvey Default Judgment for Plaintiff< 12120/2013
Friedman & Gullace, LLP
Judgment Summary
Participant Joint/Several Liability Individual Liability Amount
Cavalry, SPV I, LLC c/o Fulton Friedman & $0.00 $0.00 $0.00
Gullace, LLP
Mary Harvey $0.00 $2,655.02 $2,655.02
Judgment Finding ('Post Judgment)
In the matter of Cavalry, SPV I, LLC c/o Fulton Friedman & Gullace, LLP vs. Mary Harvey on MJ- 09101 -CV- 0000423 -2013, on
12/20/2013 the judgment was awarded as follows:
Judgment Component JoinVSeveral Liability Individual Liability Deposit Applied Amount
'i Civil Judgment $0.00 $2,538.66 $2,538.66
q Interest $0.00 $105.50 $105.50
" Costs $0.00 $10.86 $10.86
Grand Total: $2,655.02
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 C';VIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDG ". ENT.
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. (�
DEC 2 0 2013 `
Date Magisterial District Judge
I certify that this is a true and correct copy of the record // o the proceedings containin t e Iu gment.
!� T / "C
Date Magisterial District Judge
MDJS 315 Page 1 of 2 Printed: 12/20/2013 11:11:55AM
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Cavalry SPV I, LLC
assignee of HSBC Bank Nevada, N.A.
v
MARY HARVEY
115 W MAIN ST
CAMP HILL PA 17011-6329
: ❑
:g
: Docket No.
: Judgment Amount
: Less Payments
: Interest:
: Total:
Comm:
: Costs:
Confessed Judgment
Other
14-700
PRAECIPE FOR ATTACHMEN i LAVA, u
TO THE PROTHONOTARY:
$2655.02
$(0.00)
$58.48
$2713.50: Atty's
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract or
account based on a confession of judgment, but if it does , it is based on the appropriate original proceeding filed
pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Wa0.0mp L-Fi II °Sheppi nq cn'et , awnp H -i !I , PA 170 tl
Issue writ of attachment in the above/latter to the Sheriff of -Cumberland County, for debt, interest and
costs, directing attachment against PNC BANK , as Garnishee, for the following prope the defendant(s):
All accounts, including but not limited to, all savings, checking . , d r e . ecounts, certificates of
deposit, notes receivables, collateral, pledges, documents of title, securities, �supo s and all other property of
the defendant(s) in the possession, custody or control of Garnishee.
Date
FFG File # 380795
Signature:
Print name:
Address:
Attorney for:
Michael B. Volk, Esq.
6 Kacey Court, Suite 203
Mechanicsburg, PA 17055
Cavalry SPV I, LLC
Telephone: (866) 563-0809
Supreme Court ID No:#88553
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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
Cavalry SPV I, LLC
assignee of HSBC BANK NEVADA, N.A.
Vs.
Term
MARY HARVEY
WRIT OF EXECUTION
(Pa R.C.P. 3252)
NO 2014-700 Civil
CIVIL ACTION — LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs against MARY HARVEY, 115 W Main St, Camp Hill, PA
17011-6329, 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
PNC BANK, 140 Camp Hill Shopping Center, Camp Hill, PA 17011, GARNISHEE(S), as garnishee, All
accounts, including but not limited to, all savings, checking and other accounts, certificates of deposit, notes
receivables, collateral, pledges, documents of title, securities, coupons and all other property of the defendant
in the possession, custody or control of Garnishee. (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.
1
(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.
(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 $2,655.02
Interest -- $58.48
Attorney's Comm. %
Attorney Paid $60.25
Date:'/2/3 4
Plaintiff Paid
Law Library $.50
Due Prothonotary $2.25
Other Costs
David D. Buell, Prothonotary
may:
Deputy
REQUESTING PARTY:-
Name : MICHAEL B. VOLK, ESQUIRE
Address: FULTON, FRIEDMAN & GULLACE, LLP
6 KACEY COURT, SUITE 203
MECHANICSBURG, PA 17055
Attorney for: PLAINTIFF
Telephone: 866-563-0809
Supreme Court ID No. 88553
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
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson
Sheriff THE PROTON() Y,
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
it
OEC FTKE C Eh'IFF
2C1iiJUL 11F Ail !0.2
CUMBERLAND COUNT
PENNSYLVANIA
Cavalry SPV I, LLC, Assignee of HSBC Bank Nevada N.A.
vs.
Mary Harvey
Case Number
2014-700
SHERIFF'S RETURN OF SERVICE
07/09/2014 10:00 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded
all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control
of the within named garnishee, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013,
Cumberland County, by handing to Susan Casale, Consultant, 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 July 11, 2014 to Mary Harvey at 115 W Main
Street, Camp Hill, PA 17011-6329.
July 11, 2014
fcf CountySu!to Sheriff, Teleasoft, Inc.
SO ANSWERS,
RONN R ANDERSON, SHERIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Cavalry SPV I, LLC
assignee of HSBC Bank Nevada, N.A.
Plaintiff NO. 14-700
v. CIVIL ACTION - LAW
MARY HARVEY
Defendant(s)
PRAECIPE TO DISCONTINUE ATTACHMENT
TO THE PROTHONOTARY:
Please discontinue the Writ of Execution filed against Garnishee PNC BANK in the referenced matter without
prejudice.
Respectfully Submitted
By:
Michael B. Volk, Esq. #::553
Fulton, Friedman & Gullace, LLP
Counsel for Plaintiff
6 Kacey Court, Suite 203
Mechanicsburg, PA 17055
(866)563-0809
CERTIFICATE OF SERVICE
_4.
I hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office,
first class mail, postage prepaid, addressed as follows:
MARY HARVEY
115 W MAIN ST
CAMP HILL PA 17011-6329
PNC BANK
140 CAMP HILL SHOPPING MALL
CAMP HILL PA 17011
FFG file #: 380795
PA/PA_PRAEDISATT
Michael B. Volk, Esq.
Attorney ID #88553
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