Loading...
HomeMy WebLinkAbout14-0856 'IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Cavalry SPV I, LLC Plaintiff NO. I q, V. CIVIL ACTION - LAW "s % frw CHRISTINE A HEDRICK Defendant(s) 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 $ 1757.40 , which consists of $ 1653.40 as principal, $0.00 as interest and $ 104.00 as costs less payments of $ 0.00 , plus interest thereon from the date of that judgment, as provided by law. Respectfully Su mi ed, By: 1 . 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 A PPE L As of the date of this filing a District Justice appeal has not been ed ' e Court of Common Pleas of CUMBERLAND County. Michael B. Volk, Esq. #885530 FFG file #: 380783 � IIIIIIIIIII VIII IIIII VIIIVIII IIIIIIIIIIIIIIIIIIIII IIIIII IIIIII CW [ �g '�* 301 LP ` o � � i�&bd PA/PA_TRANSJ '\ 'IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Cavalry SPV I, LLC C Plaintiff NO. L / V. CIVIL ACTION - LAW CHRISTINE A HEDRICK 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 $ 1757.40, which consists of $ 1653.40 as principal, $0.00 as interest and $ 104.00 as costs less payments of $ 0.00 , plus interest thereon from the date of that judgment, as provided by law. NOW, t`-'C, V) . ( , 20_) �, JUDGME IS E A Prot onotary /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: CHRISTINE A HEDRICK 3 FORGE RD BOILING SPRINGS PA 17007 -9746 Defendants) Michael B. Volk, Esq. #885530 FFG file #: 380783 I VIII) VIII VIII VIII I'I'I VIII VIII IIIIIII III IIIIII IIIIII II IIII PA/PA_TRANSJ 'IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Cavalry SPV I, LLC Plaintiff NO. V. CIVIL ACTION - LAW CHRISTINE A HEDRICK Defendant(s) CERTIFICATE OF LAST KNOWN ADDRESS I hereby certify that the last known address of Defendant and the Plaintiff are as follows: CHRISTINE A HEDRICK Cavalry SPV I, LLC 3 FORGE RD 500 SUMMIT A RIVE BOILING SPRINGS PA 17007 -9746 VALHALLA 1595 -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: CHRISTINE A HEDRICK 3 FORGE RD BOILING SPRINGS PA 17007 -9746 Defendant(s) Date: C ) 2. , 2014 Michael B. Volk, Esq. 4885530 FFG file #: 380783 IIIIII ��III IIII' VIII IIII IIII (IIIIII'lll� II' II�III IIIIII II I�') PAPA TRANSJ 'COMMONWEALTH OF PENNSYLVANIA Notice Of Judgment/Transcript Civil COLI.NTY CUMBERLAND Case Mag. Dist. No: MDJ- 09 -3 -03 Calvary SPV I LLC MDJ Name: Honorable Susan K. Day V. Address: 229 Mill Street Christine Ann Hedrick P.O. Box 167 Mount Holly Springs, PA 17065 Telephone: 717- 486 -7672 Calvary SPV I, LLC Docket No: MJ- 09303 -CV- 0000220 2013 c/o Fulton Friedman & Gullace, LLP Case Filed: 10/29/2013c �} 6 Kacey Court, Suite 203 -y Mechanicsburg, PA 17055 M M = M M c r 3� c — o 6 M C Nr. Disposition Summary (cc - Cross Complaint) Z: > Docket No Plaintiff Defendant Disposition Diiposi Date MJ- 09303 -CV- 0000220.2013 Calvary SPV I, LLC Christine Ann Hedrick Default Judgment for Plaintiff 12/09/2013 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Calvary SPV I, LLC $0.00 $0.00 $0.00 Christine Ann Hedrick $0.00 $1,757.40 $1,757.40 Judgment Finding ( 'Post Judgment) In the matter of Calvary SPV I, LLC vs. Christine Ann Hedrick on MJ- 09303 -CV- 0000220 -2013, on 12/09/2013 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $1,653.40 $1,653.40 Filing Fees $0.00 $104.00 $104.00 Grand Total: $1,757.40 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY /CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION.. YOU MUST INCLUDE A COPY OF THIS.NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE CO COM.MON`PLEAS'.AND'rIC FURTHER' PROCESS M?AY'$E tSSUEf) 3Y TH- -'R",AGISTERUAL DISTRICT JUDGE.-- --- = --- UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. Date" Ma sterial 'strict Judge Susan K. Day - certify that this is a true and correct copy of the record of the procee ings ntainmg t lu gment. 1 Date VMa Judge MDJS 315 Page 1 of 2 Printed: 12/13/2013 8:17:51 AM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Cavalry SPV I, LLC assignee of HSBC Bank Nevada, N.A. v CHRISTINE A HEDRICK 3 FORGE RD BOILING SPRINGS PA 17007-9746 : ❑ : : Docket No. : Judgment Amount : Less Payments : Interest: : Total: Comm: : Costs: Confessed Judgment Other 14-856 $1757.40 $(0.00) $36.40 $1793.80: PRAECIPE FOR ATTACHMEN i LAVA, U 1 it'll TO THE PROTHONOTARY: 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. / mal York:Rc , Carlisle PR 1/015 Issue writ of attachment in the above matter to the Shepiff of Cumberland County, for debt, interest and costs, directing attachment against Members First Federal Credit Union , as Garnishee, for the following property of the defendant(s): All accounts, including but not limited to, all savings, checking and ter cc . unts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupo sand all other property of the defendant(s) in the possession, custody or control of Garnishee. Date FFG File # 380783 Signature: Print name: Address: Attorney for: Telephone: Supreme Court 11111111111111111111111111111111111111111111111111111111111111111 PA_BANKPWRITC Michael B. Volk, Esq. 6 Kacey Court, Suite 203 Mechanicsburg, PA 17055 Cavalry SPV I, LLC (866) 563-0809 ID No:#88553 \IMVA1kSNN1d ..k ? f03 TOT -338144 :z1 Wd z- ��nr F�►4 .ONO} .1.O Jd ! __ $aq.00 PO/Cr-Pi 31.(95 C r (op.a5 Pt An/ fueeo •50 LL Cr aa48ca .3cllq 55 LtifoE J 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 CHRISTINE A. HEDRICK WRIT OF EXECUTION (Pa R.C.P. 3252) NO 2014-856 Civil CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against CHRISTIINE A. HEDRICK, 3 Forge Rd, Boiling Springs, PA 17007-9746, 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 MEMBERS 1sT FCU, 321 York Rd, Carlisle, PA 17013, 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 $1,757.40 Plaintiff Paid Interest -- $36.40 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Other Costs Attorney Paid $60.25 Date: 7/2/14 (S'sa[) .. David D. Buell, Prothonotary 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 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY THE F O 3 HOZ lt.:s 2LJUL 1 Ati IT 25 CUMBERLAND COUNTY PENNSYLVANIA Cavalry SPV I, LLC, Assignee of HSBC Bank Nevada N.A. Case Number vs. Christine A Hedrick 2014-856 SHERIFF'S RETURN OF SERVICE 07/09/2014 10:39 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, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Jan Finkle, Member Service Rep., 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. July 11, 2014 The writ of execution and notice to defendant was mailed on July 11, 2014 to Chris A. Hedrick, 3 Forge Road, Boiling Springs, PA 17007-9746. (c) CountySuite Sherif(, Te!eosoft. Inc. LLIAM CLINE, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Cavalry SPV I, LLC assignee of HSBC Bank Nevada, N.A. Plaintiff CIVIL ACTION - LAW vs. CHRISTINE A HEDRICK Defendant(s) No.14-856 ‘c\S toto INTERROGATORIES TO GARNISHEE To: Members First Federal Credit Union 321 York Road Carlisle PA 17013 RECEivED L (II -57 PURSUANT TO RULE 3253 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ Execution was issued. C. "You" means the main office and all branch offices, representatives, employees and agents of your organization. D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment which is in your possession, custody or control is attached, including all property of the Defendant(s) which comes into your possession thereafter. E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. F. Where exact infoiiiiation cannot be furnished, estimated information is to be supplied. When an estimate is to be used, it should be identified as such, an explanation should be given as to the basis on which the estimate is made, and the reason the exact information cannot be furnished. G. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys. FFG file #: 380783 1111111 11111 11111 11111 1111111111 111111111 1111111111 111111 11111111 PA/PA BANKINTERROGS INTERROGATORIES TO GARNISHEE DEFENDANT(S) - CHRISTINE A HEDRICK SS# - ***-**-2242 1. At the time you were served or at any subsequent time did you owe the defendant(s) any `fi mune' .� 20/4 or were you liable to the defendant(s) on any negotiable or other written instrument, or did the defendant(s) claim that you owed the defendant(s) any money or were liable to the defendant(s) for any reason? 2. 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 and one or more other persons any property of any nature owned solely or in part by the defendant(s)? (lo 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant(s) or in which the defendant(s) held or claimed any interest? no 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant(s) had an interest? no 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? no 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant(s) against you? no 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant(s) have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account number and state the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. no PA/PA_BANKINTERROGS DEFENDANT(S) - CHRISTINE A HEDRICK SS# - ***-**-2242 8. If you are a bank or other financial institution, at the time you were served or at any subseq time did the defendant have funds on deposit in an account in which the funds on deposit, not incluEIVEo any otherwise exempt funds, did not exceed the amount of the general monetary exemption unclfek42,0 Pa.C.S. § 8123? If so, identify each account. .1 21114 no 9. Please identify all accounts not listed in your answer to Interrogatory No. 7, the amount of funds in each account, whether the funds are deposited electronically on a recurring basis and the entity electronically depositing those funds. If the defendant(s) maintains any of these accounts jointly with any other person, or persons, give their name, address and relationship to defendant. n 10. Are there any attorney's fees or processing fees charged by you against the defendant(s) or account(s) of the defendant(s) for the completion of this answer? If yes, outline the exact amount of any fees due and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer. 11 . Please provide the name, business address and business telephone of the person answering these interrogatories. fridu x c7 X (- SCO- a8 3 - a3a8, et t�aa 5003 LCL, , 1-7055 12. Please provide the address and telephone number where future court documents pertaining to this case can be served on Garnishee. 5c oO 1_cu cc, lDr' p ; \-765S Fulton, Frieda a n; : ` Gullace, LLP (lam c� %C2 1_ _a33-a3a , x(oOaa Michael B. Volk, Esq. #88553 (866) 563-0809 Counsel for Plaintiff Attorneys in the Practice of Debt Collection Please return your Answer to Interrogatories to counsel for Plaintiff at: 28 E. Main Street, Suite 500 Rochester, New York 14614. FFG File #: 380783 PA/PA_BANKINTERROGS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Cavalry SPV I, LLC assignee of HSBC Bank Nevada, N.A. Plaintiff NO. 14-856 v. CHRISTINE A HEDRICK Defendant(s) TO THE PROTHONOTARY: CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT 4 -- ca CD -i7 CD jai Please discontinue the Writ of Execution filed against Garnishee Members First Federal Credit Union 5fhe re sten0 matter without prejudice. ,', Cn Respectfully S By: Michael B. Volk, #88553 Fulton, Friedman & Gullace, LLP Counsel for Plaintiff 6 Kacey Court, Suite 203 Mechanicsburg, PA 17055 (866) 563-0809 CERTIFICATE OF SERVICE 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: CHRISTINE A HEDRICK 3 FORGE RD BOILING SPRINGS PA 17007-9746 Members First Federal Credit Union 321 York Road Carlisle PA 17013 FFG file #: 380783 PAPA PRAEDISATT Michael B. Volk, Esq. Attorney ID #88553 11111111111 11111 11111 11111 11111 11111 IIII 11111 111111 IIII 11111 IIII o 56K)0+� e0-aaar.xD