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HomeMy WebLinkAbout14-5666 p0 1 LAW OFFICES OF HAYT, HAYT & LANDAU, LLC i.���. BY: ARTHUR LASHINCr';'j;� ( lrp" H � � INDENTIFICATION NO. 23425 123 S . BROAD STREET ATTORNEY FOR PLAINTIFF SUITE 1600 PHILADELPHIA, PA 19109-1003 (215) 928-1400 OUR FILE NO: 477001 MIDLAND FUNDING LLC CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION - VS - TERM, , KIMBERLY MARQUART PRAECIPE TO ENTER JUDGMENT TO THE COURT: Kindly enter judgment in favor of Plaintiff, MIDLAND FUNDING LLC, and against Defendant (s) : KIMBERLY MARQUART in the amount of $2, 258. 80 By: ARTHUR LASHIN, Esquire Law Offices of Hayt, Hayt & Landau, LLC Attorney ID #23425 X31, as�d a� �1 PIT Pa30Loq CbMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND -1 ,. x, Case Mag. Dist. No: MDJ-09-1-02 Midland Funding LLC MDJ Name: Honorable Elizabeth S. Beckley V Address: 1901 State Street Kimberly Marquart Camp Hill, PA 17011 Telephone: 717-761-0583 Arthur Lashin, Esq. Docket No: MJ-09102-CV-0000100-2013 123 S Broad Street, Suite 1660 Case Filed: 6/11/2013 Philadelphia, PA 19109-1003 Disposition Summary (--cross complaint) Docket No Plaintiff Defendant Disposition Disposition Date MJ-09102-CV-0000100-2013 Midland Funding LLC Kimberly Marquart Default Judgment for Plaintiff 07/18/2013 Judgment Summary Participant Joint/Several Liability Individual Liability . Amount Kimberly Marquart $0.00 $2,258.80 $2,258.80 Midland Funding LLC $0.00 $0.00 $0.00 Judgment Finding g ('Post Judgment) - In the matter of Midland Funding LLC vs. Kimberly Marquart on MJ-09102-CV-0000100-2013, on 7/18/2013 the judgment was awarded as follows: Judament Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $2,153.30 $2,153.30 Filing Fees $0.00 $105.50 $105.50 Grand Total- $2,258.80 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. 1 13 Date Elizabeth S. Beckley 'l I certify that this is a true and correct copy of the record of the proceedings conta in t e lu g ent. Date gisteri Di ric Ju ge MDJS 315 Page 1 of 2 Printed:06/30/2014 3:10:51 PM Midland Funding LLC Docket No.: MJ-09102-CV-0000100-2013 Kimberly Marquart Participant List Private(s) Arthur Lashin, Esq. 123 S Broad Street, Suite 1660 Philadelphia, PA 19100,1003 Plaintiff(s) Midland Funding LLC C/o Law Offices of Hayt, Hayt&Landau, LLC 123 South Broad Street, Suite 1660 Philadelphia, PA 19109-1003 Defendant(s) Kimberly Marquart - 2110 Logan St ��--, � rn = Camp Hill, PA 17011 -i7 C7 ill: c� C: - { Au• Y..r MDJS 315 Page 2 of 2 Printed:06/30/2014 3:10:51 PM COMMONWEALTH OF PENNSYLVANIA CIVIL COMPLAINT COUN"i Y OF CUMBERLAND , giMerial District Number -1 2 PLAINTIFF: NAME and ADDRESS i DJ Name:Hon.ELIZABETH S BECKELY MIDLAND FUNDING LLC cto Hayt,Hayt&Landau,LLC ddress:1901 STATE ST. 123 S.BROAD STREET SUITE 1660 AMP HILL,PA 17011 PHILADELPHIA,PA 19109 Telephone: 7177610583 215-928-1400 Vs. DEFENDANT: NAME and ADDRESS F—KIMBERLY MARQUART 2110 LOGAN ST CAMP HILL,PA 17011 rate ket No:Filed:G.l I AMOUNT DATE PAID FILING COSTS $ Social security numbers and financial information POSTAGE $ 11 . (» l l (e.g. F lNS)should not be listed. N the identity of an SERVICE COSTS $ l l account number must be established, list only the CONSTABLE ED. $ l l last four digits.204 Pa.Code§§213.1 -213.7. TOTAL 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 2153.30 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 CITIBANK, N.A., for the Account bearing number XXXXXXXXXXXX8080 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 2011-10-12. The account shows that the defendant owes a balance of 2153.30. ' I,Paige Duncan verity 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)relat?dTo-0hawokn falsification t authorities. gnruant of a i or Authorized Agan The plaintiff's attorney shall file an entry of appearance with the magisterial district court p 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. H you are disabled and require 6-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. 8548590172 WCOMPLAINT 477001001 w COURT OF COMMON PLEAS VERIFICATION OF NON-MILITARY SERVICE MIDLAND FUNDING LLC COMMONWEALTH OF PENNSYLVANIA - VS - COUNTY OF PHILADELPHIA KIMBERLY MARQUART 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 KIMBERLY MARQUART 6389 CREEKBEND DR MECHANICSBURG, PA 17050 11 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. S . section 4904 relating to unsworn falsification to authoritie . By: ARTHUR LASHIN, Esquire, #23425 Attorney for Plaintiff a 7 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 (2 15) 928-1400 OUR FILE NO. 477001 MIDLAND FUNDING LLC STATE OF PENNSYLVANIA - VS - SS KIMBERLY MARQUART . COUNTY OF CERTIFICATION OF ADDRESSES I hereby certify that the address for the Defendant (s) is, 6389 CREEKBEND DR MECHANICSBURG, PA 17050 I hereby certify that the address for Plaintiff is, P.O. BOX 939019 SAN DIEGO, CA 92123 By: ARTHUR LASHIN, ESQUIRE, #23425 ATTORNEY FOR PLAINTIFF HE PPi0410 N R p LAW OFFICES of � � SEP 24 Pill 3: HAYT, HAYT & LANDAU, LLC CUMBtR(.,II,t BY: ARTHUR LASHIN � � arY cj coway' IDENTIFICATION NO. 23425 ATTORNEY FOR PLAINTIF 123 S . BROAD STREET SUITE 1660 PHILADELPHIA, PA 19109-1003 (215) 928-1400 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION MIDLAND FUNDING LLC P.O. BOX 939019 SAN DIEGO, CA 92123 TERM, - VS - No . KIMBERLY MARQUART 6389 CREEKBEND DR MECHANICSBURG, PA 17050 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