HomeMy WebLinkAbout14-5104 2139552F ILI E1)-0 EICE'
The Law Offices of Frederic I . Weinberg '' 1#-!E PR `H0til0 T'' Y
& Associates, P.C. 2014' SEP _2 PM 12: u 1
BY: FREDERIC I . WEINBERG, ESQUIRE
Identification No. : 41360 CU'IMBERLAND COUNTY
JOEL M. FLINK, ESQUIRE PENNSYLVANIA
Identification No. : 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
CAPITAL ONE BANK (USA) , N.A. COURT OF COMMON PLEAS
4851 Cox Road CUMBERLAND COUNTY
_. Glen Allen, VA 23060
VS . DOCKET NO.
_ JANET LEACH
4341 CARLISLE PIKE6-�-yLC
CAMP HILL PA 17011
= PRAECIPE FOR ENTRY OF APPEARANCE, TRANSFER OF JUDGMENT, ASSESSMENT OF
DAMAGES AND VERIFICATION OF ADDRESSES) VALIDITY AND NON MILITARY
SERVICE
TO THE PROTHONOTARY:
Enter my appearance for the Plaintiff in the above matter; enter
judgments in favor of Plaintiffs) against Defendants) on the duly
authenticated copy of the magisterial district justice judgment hereto
attached, entered in the jurisdiction noted therein, and assess damages
as follows :
$6, 116. 74 Judgment
$682 . 33 Post Judgment Interest
$ . 00 Post Judgment Costs
( $155 . 00 Post Judgment Payments
$6, 644 . 07 Total
Pursuant to the penalties of 18 Pa-C. S . Section 4904 relating to
unsworn falsification to authorities, I verify that : (1) the precise
last known address (es) of the Plaintiff (s) and Defendant (s) are as
above. ; (2) that said judgments were entered by the Magisterial Court
in the said jurisdiction in said amount with costs and interest due as
noted, no part of which has been paid (except as noted) and which is
valid, enforceable and unsatisfied; find a copy of which is attached
hereto; (3) and that the Defendant (s) is (are) over 18 years of age and
7r 7
77�
not in the military service of the United States or its allies or
otherwise within coverage of the Soldiers and Sailors Relief Act of
1940, as amended, and had (have civilian occupation (s) .
Date: Z
FREDERIC I . WEINBERG, ESQUIRE
JOEL M. FLINK, ESQUIRE
DAMAGES ASSESSED AND JUDGMENT (S)
ENTERED AS ABOVE NOTICE (S) IVEN
UNDER P' . R. V. <. 6
IO
Pro. Pr A
2139552
The Law Offices of Frederic I . Weinberg
& Associates, P.C.
BY: FREDERIC I . WEINBERG, ESQUIRE
Identification No. : 41360
JOEL M. FLINK, ESQUIRE
Identification No. : 41200
1001 E. Hector Street, Ste 220
Conshohocken, PA 19428
484/351-0500
CAPITAL ONE BANK (USA) , N.A. COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. �'` �� !� �
v s . `j
JANET LEACH
4341 CARLISLE PIKE
CAMP HILL PA 17011
NOTICE
Pursuant to Pa. R.Civ. P. 236 of the Supreme Court of Pennsylvania, you
are hereby notified that a judgment has been entered against you in the
above proceeding as indicated below.
" Judgment by Default $6,644.07
/x / Money Judgment $$6,644.07
�L Judgment on Award of Arbitrators$
LL Judgment on Verdict$
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS:
FREDERIC I . WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELE HONE NUMBER:
484/351-0500
PROTHON. ' -
Department of Defense Manpower Data Center Results as of:Aug-20.201406:53:45 AM
SCRA 3.0
r:f� Stags Report
.�� Pursuant to Servicernemben Civil Relief Act
Last Name: LEACH
First Name: JANET
Middle Name:
Active Duty Status As Of: Aug-29-2014
On Active Duty On AUive DutyStatusDate
Active Duty Start Dale Active Duty End Date Status Service Component
NA NA No NA
This response reflects the individuals'active duty status based on the Active Duty Status Dale
Lett Active Duty Within 367 Days of AUive Dut Status Date
Active Duty Start Date Active Duty End Dale Status T Service Component
NA NA No I NA
This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notfied of a Future Call-Up to Active Duty on Active Duty Status Date
Order Notification Start Date Order Notification End Date Status Service Com nent
NA NA N0 NA
This response reflects whether the individual or hislher unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
41121 )4. , W
of
44_�
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
File#2139552
The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility
Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as
the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the
individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family
member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the
protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status
date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c).
This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1), Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard,this Includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve
Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1).
Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: OCP6OB2DT001 H40
,COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND Notice of Judgment/Transcript Civil
Case
Mag. Dist. No: MDJ-09-1-02 Capital One Bank (USA) NA
MDJ Name: Honorable Elizabeth S. Beckley v
Address: 1901 State Street Janet Leach
Camp Hill, PA 17011
Telephone: 717-761-0583
Frederic Ivan Weinberg, Esq. Docket No: MJ-09102-CV-0000190-2012
1001 E Hector Street Suite 220 Case Filed: 8/31/2012
Conshohocken, PA 19428
Disposition Summary (cc-Cross complaint)
Docket No Plaintiff Defendant Disposition Disposition Date
MJ-09102-CV-0000190-2012 Capital One Bank(USA)NA Janet Leach Default Judgment for Plaintiff 10/02/2012
Judgment Summary
Participant Joint/Several Liability Individual Liability Amount
Capital One Bank(USA)NA $0.00 $0.00 $0.00
Janet Leach $0.00 $6,116.74 $6,116.74
Judgment Finding (*Post Judgment)
In the matter of Capital One Bank (USA) NA vs. Janet Leach on MJ-09102-CV-0000190-2012, on 10/02/2012 the judgment was
awarded as follows:
The amount of rent per month,as established by the Magisterial District Judge,is$0.00
Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount
Civil Judgment $0.00 $5,939.92 $5,939.92
Filing Fees $0.00 $176.82 $176.82
Grand Total: $6,116.74
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.
Date Elizabeth S.BeckleyN"'4�J �`
certify that this is a true and correct copy of the record o t e proceedings contai a the lug ent`
Date eri istbi t udg
MDJS 315 Page 1 of 2 Printed:07/14/2014 1:49:41 PM
° Capital One Bank (USA) NA Docket No.: MJ-09102-CV-0000190-2012
V.
Janet Leach
Participant List
Private(s)
Frederic Ivan Weinberg, Esq. 3 -
1001 E Hector Street Suite 220
Conshohocken, PA 19428 7u - W
Plaintiff(s) '�
r-LD
c,
-a
C
Capital One Bank(USA) NA ��-a :
4851 Cox Road y t
Glen Allen,VA 23060
k -
Defendant(s)
Janet Leach
4341 Carlisle Pike C8
Mechanicsburg, PA 17055
D �
MDJS 315""r Page 2 of 2 Printed:07/14/2014 1:49:41 PM
,COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil
COUNTY OF CUMBERLAND
Case
Mag. Dist. No: MDJ-09-1-02 Capital One Bank (USA) NA
MDJ Name: Honorable Elizabeth S. Beckley V
Address: 1901 State Street Janet Leach
Camp Hill, PA 17011
Telephone: 717-761-0583
Capital One Bank(USA) NA Docket No: MJ-09102-CV-0000190-2012
4851 Cox Road
Glen Allen, VA 23060 Case Filed: 8/31/2012
Disposition Summary (cc-Cross complaint)
Docket No Plaintiff Defendant Disposition Disposition Date
MJ-09102-CV-0000190-2012 Capital One Bank(USA)NA Janet Leach Default Judgment for Plaintiff 10/02/2012
Judgment Summary
Participant Joint/Several Liability Individual Liability Amount
Capital One Bank(USA)NA $0.00 $0.00
$0.00
Janet Leach $0.00 $6,116.74 $6,116.74
Judgment Finding (*PostJudgment)
In the matter of Capital One Bank (USA) NA vs. Janet Leach on MJ-09102-CV-0000190-2012, on 10/02/2012 the judgment was
awarded as follows:
The amount of rent per month,as established by the Magisterial District Judge,is$0.00
Judament Component Joint/Several Liability Individual Liability Deposit Applied Amount
Civil Judgment $0.00 $5,939.92 $5,939.92
Filing Fees $0.00 $176.82 $176.82
Grand Total: $6,116.74
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.
eils�''
D�
Date Elizabeth S.Beckley
certify that this is a true and correct copy of the recor of
he procee Ings conta t e lu ment.
Date a s eri i IXJ64e
MDJS 315 Page 1 of 2 Printed:07/14/2014 1:49:41 PM
Capital One Bank (USA) NA Docket No.: MJ-09102-CV-0000190-2012
V.
Janet Leach
Participant List
Private(s)
t:
Frederic Ivan Weinberg, Esq. c -
1001 E Hector Street Suite 220 ='- -
-.
Conshohocken, PA 19428
Plaintiffs
Capital One Bank(USA) NA
4851 Cox Road p C-) c-�
Glen Allen,VA 23060
Defendant(s) -i
M
Janet Leach
4341 Carlisle Pike C8
Mechanicsburg, PA 17055
MDJS 315 Page 2 of 2
9 Printed:07/14/2014 1:49:41 PM
2139552
The Law Offices of Frederic I. Weinberg
& Associates, P.C.
BY: Frederic I. Weinberg, Esquire
Identification No.: 41360
Joel M. Flink, Esquire
Identification No.: 41200
375 E. Elm Street, Suite 210
Conshohocken, PA 19428
484/351-0500
CAPITAL ONE BANK (USA), N.A.
4851 Cox Road
Glen Allen, VA 23060
vs.
JANET LEACH
4341 CARLISLE PIKE
CAMP HILL PA 17011
and
PNC Bank
..7.7.105 Noble Blvd.
=Carlisle, PA 17013
GARNISHEE(S)
=TO THE PROTHONOTARY:
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO. : 14-5104
PRAECIPE FOR WRIT OF EXECUTION
Issue writ of execution in the above matter,
directed to the Sheriff of Cumberland County;
(1) against
JANET LEACH
(2) against
PNC Bank
defendant(s)and
garnishee(s)
(3) Amount Due
Interest from September 2, 2014
Costs
Prothonotary fee
Sheriff fee
(4) Less: Payments on Account
TOTAL
20q,oc� a
�"� r3L a s CAT
'as 4a.aS�Lc�
$6,116.74
$75.73
$0.00
FREDERIC I. WEINBERG, SQUIRE
JOEL M. FLINK, ESQUIRE
Attorney for Plaintiff
2� 31yisuz
`C-13'sti4
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
CAPITAL ONE BANK (USA), N.A.
Vs.
JANET LEACH
WRIT OF EXECUTION
(Pa R.C.P. 3252)
NO 14-5104 Civil Term
CIVIL ACTION — LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs against JANET LEACH, 4341 CARLISLE PIKE, CAMP HILL,
PA 17011 Defendant (s)
(1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein;
(2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of
PNC BANK, 105 NOBLE BLVD., CARLISLE, PA 17013 GARNISHEE(S), as 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.
(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
1
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 $6,116.74 Plaintiff Paid
Interest FROM SEPTEMBER 2, 2014 - $75.73 Law Library $.50
Attorney's Comm. %
Attorney Paid $60.25
Date: 12/22/14
(Somal)
Due Prothonotary $2.25
Other Costs
David D. Buell, Prothonotary
REQUESTING PARTY:
Name : FREDERIC I. WEINBERG, ESQUIRE
Address: LAW OFFICES OF FREDERIC I. WEINBERG & ASSOCIATES, P.0
375 E. ELM STREET
SUITE 210
CONSHOHOCKEN, PA 19428
Attorney for: PLAINTIFF
Telephone: 484-351-0500
Supreme Court ID No. 41360
MAJOR EXEMPTIONS UNDER PENNSYLVANIA
AND FEDERAL LAW
1. $300 statutory exemption
2. Bibles, school books, sewing machines, uniforms and equipment
3. Most wages and unemployment compensation
4. Social Security benefits
5. Certain retirement funds and accounts
6. Certain veteran and armed forces benefits
7. Certain insurance proceeds
8. Such other exemptions as may be provided by law
2
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
2U5J[; *]' -2 (�' { ( 3: 0 ,
r. tiMBERLAND C,CU,41
PENNSYLVANIA
Capital One Bank (USA) N.A. Case Number
vs.
Janet Mae Leach 2014-5104
SHERIFF'S RETURN OF SERVICE
12/29/2014 09:41 AM - Jamie DiMartile, 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 Wendy Whistler, Teller Banking Specialist,
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 December 30, 2014 to Janet Leach at 4341
Carlisle Pike, Apartment C8, Camp Hill, PA 17011.
4IE DIMARTILE, DEPUTY
SO ANSWERS,
December 30, 2014 R NFP' R ANDERSON, SHERIFF
(c) CountySuito Sheriff, Toteosoft, ��.c.