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HomeMy WebLinkAbout14-4992 1 • ECJyy -10 Nok t,,,ry fuF L4_ LAW OFFICES OF AUG 25 PH 1: 4 � HAYT, HAYT & LANDAU, LLC BY: ARTHUR LASHIN 11%ERL A 1AJ[) INDENTIFICATION NO. 23425 PEMNSY + COU NTY 123 S . BROAD STREET ATTORNEY FOR PLAINTIFF ANIA SUITE 1600 PHILADELPHIA, PA 19109-1003 (215) 928-1400 OUR FILE NO: 480840 MIDLAND FUNDING LLC CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION VS - iTERM, No. 01 'U' KAROLYN SHAMBAUGH PRAECIPE TO ENTER JUDGMENT TO THE COURT: Kindly enter judgment in favor of Plaintiff, MIDLAND FUNDING LLC; .and against Defendant (s) : KAROLYN SHAMBAUGH in the amount of $1,772.56 By: ARTHUR LASHIN, Esquire Law Offices of Hayt, Hayt & Landau, LLC Attorney ID 423425 -a Q,SP& cCD DL t 310 aa.a rr Vv comp161\IWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND ; Case Mag. Dist. No: MDJ-09-1-01 Midland Funding LLC MDJ Name: Honorable Charles A. Clement Jr. V Address: 920 Linda Lane Karolyn Shambaugh Camp Hill, PA 17011 Telephone: 717-737-3434 Arthur Lashin, Esq. Docket No: MJ-09101-CV-0000238-2013 c/o Law Offices of Hayt, Hayt& Landau, LLC Case Filed: 7/15/2013 123 South Broad Street, Suite 1660 Philadelphia, PA 19109-1003 Disposition Summary (cc-Cross complaint) - Docket No Plaintiff Defendant Disposition Disposition Date MJ-09101-CV-0000238-2013 Midland Funding LLC Karolyn Shambaugh Default Judgment for Plaintiff 08/23/2013 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Karolyn Shambaugh $0.00 $1,772.56 $1,772.56 Midland Funding LLC $0.00 $0.00 $0.00 Judgment Finding (*Post Judgment) - - In the matter of Midland Funding LLC vs. Karolyn Shambaugh on MJ-09101-CV-0000238-2013, on 8/23/2013 the judgment was awarded as follows: Judament Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $1,672.70 $1,672.70 Costs $0.00 $99.86 $99.86 Grand Total: $1,772.56 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES,IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. ` 8/23/2013 Date Magisterial District Judge Charles A.Clement Jr. certify that this is a true and correct copy of the record of the proceedings containing the judgment. 6/30/2014 06��, Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed:06/30/2014 1:41:59PM Midland Funding LLC Docket No.: MJ-09101-CV-0000238-2013 V. Karolyn Shambaugh Participant List Plaintiff(s) Midland Funding LLC Go Hayt, Hayt& Landau LLC 123 S Broad St Suite 1660 Philadelphia, PA 19109 Defendant(s) Karolyn Shambaugh 1736 Main St Mechanicsburg, PA 17055 Complainant's Attorney(s) Arthur Lashin, Esq. c/o Law Offices of Hayt, Hayt&Landau, LLC c > 123 South Broad Street, Suite 1660 C Philadelphia, PA 19109-1003 rY„I E+7 -C Cq n CD CD C:) MDJS 315 Page 2 of 2 Printed:06/30/2014 1:38:26PM COMMONWEALTH OF PENNSYLVANIA CIVIL COMPLAINT COUNTY OF CUMBERLAND t [ddress; gister al District Number:09-1-01 PLAINTIFF, NAME and ADDRESS J Name:Hon.CHARLES CLEMENTJR ('MIDLAND FUNDING LLC c/o Hayt,Hayt&Landau,LLC 920 LINDA LN. 123 S.BROAD STREET SUITE 1660 MP HILL,PA 17011 PHILADELPHIA,PA 19109 215-928-1400 elephone: 7177745989 VS. DEFENDANT- NAME and ADDRESS F "ROLYN SHAMBAUGH 1736 MAIN ST �MEOHANICSBURG,PA 170555945 EcketNo: CV-0000238-13 ate Filed: 7/15/2013 P. 1N AMOUNT DATE PAID FILING COSTS $ 89.00 7 / 18' 13 Social security numbers and financial information POSTAGE $ 10.86 7 ' 19 13 (e.g. PINS)should not be listed. If the identity of an SERVICE COSTS $ i i account number must be established, list only the CONSTABLE ED. $ i i last four digits.204 Pa.Code§§213.1 -213.7. TOTAL $ 99.86 7 181 13 Pa.R.C.P.D.J. No.206 sets forth those costs recoverable by the prevailing party. TO THE DEFENDANT: The above named plaintiff(s)asks judgment against you for 1672.70 together with costs upon the following claim(Civil fines must include citation of the statute or ordinance violated): Plaintiff is the owner of a certain credit account (hereafter, 'the Account*) by virtue of the assignment of the Account, as set forth in the records maintained on Plaintiff's behalf. As a result of the assignment, Plaintiff now holds all rights, title and interest in and to the Account. Records further reflect that defendant entered into a credit agreement with WEBBANX, for the Account bearing number XXXXXXXXXXXXXXX3292 and used or authorized the use of the Account to obtain goods and/or services and/or cash advances. Based upon review of records kept on behalf of Plaintiff, the last payment posted to the account on 2011-11-02. The account shows that-the defendant owes a balance of 1672.70. I,Paula Fruth verify that the facts set forth in this complaint are true and correct.This statement is made subject to the penalties of Section 4904 of the Crimes Code(18 PA.C.S.§4904)related to unswor, falsificati It authorities. (Signature of Plaintiff ol Authorized Agent) The plaintiff's attorney shall file an entry of appearance with the magisterial district court pursuant to Pa.R.C.P.M.D.J.207.1. IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD TRY TO NOTIFY.THIS OFFICE IMMEDIATELY AT THE ABOVE TELEPHONE NUMBER.YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE.UNLESS YOU DO,JUDGMENT MAY BE ENTERED AGAINST YOU BY DEFAULT. If you have a claim against the plaintiff which is within magisterial district judge jurisdiction and which you intend to assert at the hearing,you must file it on a complaint form at this office at least five(5)days before the date set for the hearing. If you are disabled and require a reasonable accomodation to gain access to the Magisterial District Court and its services,please contact the Magisterial District Court at the above address or telephone number.We are unable to provide transportation. AO jj�� r r:;- PA10 . 8553772942 DICOMPLAINT 480840001 COURT OF COMMON PLEAS VERIFICATION OF NON-MILITARY SERVICE MIDLAND FUNDING LLC COMMONWEALTH OF PENNSYLVANIA - VS - COUNTY OF PHILADELPHIA KAROLYN SHAMBAUGH I represent the Plaintiff in the above entitled case and am authorized to make this verification. I make this verification on behalf of the Plaintiff upon information and belief: the above named Defendant (s) is/are 18+ years of age; the address of the Defendant (s) is/are KAROLYN SHAMBAUGH 1736 MAIN ST MECHANICSBURG, PA 17055 the occupation of Defendant (s) is unknown; and the Defendant (s) is/are not in the Military Service of the United States, nor any State of Territory thereof and its Allies as defined by the Servicemembers Civil Relief Act, 50 U.S .C. section 521 . By: ARTHUR LASHIN, Esquire, *23425 Attorney for Plaintiff I verify that the statements made in this verification are true and correct upon information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C section 4904 relating to unsworn falsification to authorities . By: ARTHUR LASHIN, Esquire, #23425 Attorney for Plaintiff i; LAW OFFICES OF HAYT, HAYT & LANDAU, LLC BY: ARTHUR LASHIN INDENTIFICATION NO. 23425 ATTORNEY FOR PLAINTIFF 123 S . BROAD STREET SUITE 1660 PHILADELPHIA, PA 19109-1003 (215) 928-1400 OUR FILE NO. 480840 MIDLAND FUNDING LLC STATE OF PENNSYLVANIA - VS - SS KAROLYN SHAMBAUGH COUNTY OF CERTIFICATION OF ADDRESSES I hereby certify that the address for the Defendant (s) is, 1736 MAIN ST MECHANICSBURG, PA 17055 I hereby certify that the address for Plaintiff is, P.O. BOX 939019 SAN DIEGO, CA 92123 By: ARTHUR LASHIN, ESQUIRE, 423425 ATTORNEY FOR PLAINTIFF h f- T'40 r1�rxair LAW OFFICES OF Aug 25 P1.f !: HAYT, HAYT & LANDAU, LLC 40 BY: ARTHUR LASHIN U'0`18 ERLt NDr IDENTIFICATION NO. 23425 a �QUN j,1 123 S . BROAD STREET � ' 1& IAFOR PLAINTIFF SUITE 1660 PHILADELPHIA, PA 19109-1003 (215) 928-1400 CUMBERLAND COUNTY COURT OF COMMON PLEAS MIDLAND FUNDING LLC CIVIL DIVISION P.O. BOX 939019 SAN DIEGO, CA 92123 - VS - TERM, KAROLYN SHAMBAUGH 1736 MAIN ST MECHANICSBURG, PA .17055 ENTRY OF APPEARANCE TO THE COURT: Kindly enter my appearance on behalf of Plaintiff, MIDLAND FUNDING LLC as to the above indicated matter. By: ARTHUR LASHIN, Esquire Law Offices of Hayt, Hayt & Landau, LLC Attorney ID #23425