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Home My WebLink About14-5698 it i'ESG7I�oNS 'Y Law Firm of Allan C. Smith, P.0 r� €' � 1 : Attorney ID: 204756 1276 Veterans Hwy- Suite E-1 r U,M GE RL "H C U NI T Y Bristol, Pa 19007 PENNSYLVANIA 1-888-275-6399 H(215) 428-0666 Attorney for Plaintiff CACH,LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiffs, ) NO: 14 -51098 -(v t' I-Fex P VS. ) DAVID GARRY ) Defendant ) Praecipe to Transfer Judgment To the Prothonotary: Kindly transfer the enclosed judgment from Magisterial District Court 09-1-03, Pennsylvania to CAMBRIA County Court of Common Pleas, Pennsylvania against DAVID GARRY, 808 ERFORD ROAD; CAMP HILL,PA 17011,and docket same. This judgment remains valid, enforceable and unsatisfied. The said judgment should read as follows: "Judgment in favor.of Plaintiff, CACH, LLC and against Defendant, DAVID GARRY , in the amount of$3,203.96 assessed as follows: [a] Civil Judgment Costs $2,417.09, [b] Filing r Fees $129.05 [c] Interest$174.40 [d] Attorney Fees $483.42. Date: September 24, 2014 By: Co n L. Kronnagel, Esqui Att ey I.D. No. 313173 CO PAO-10 e 311573 N0410'-L WAed �r y I 05 35b33 V —'0OMIAONWEALTH OF PENNSYLVANIA Notice Of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ-09-1-03 CACH, LLC MDJ Name: Honorable Richard S. Dougherty V. Address: 98 South Enola Drive, Suite 1 David Garry Enola, PA 17025 Telephone: 717-728-2805 Michael Francis X. McGuigan, Esq. Docket No: MJ-091030:*0044-26102' McGuiganCase Filed: 11/5/201 Law Office, LLC 2 Cn 311 Veterans Highway -<> , CD Levittown, PA 19056 r-J ----4E" r Disposition Summary Docket No Plaintiff Defendant Disposition Disposition Date MJ-09103-CV-0000304-2012 CACH, LLC David Garry Judgment for Plaintiff 02/20/2013 Judgment Summary Participant Joint/Several Liability Individual Liability Amount CACH, LLC $0.00 $0.00 $0.00 David Garry $0.00 $3,203.96 $3,203.96 Judgment In the matter of CACH, LLC vs. David Garry on 2/20/2013 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Costs $0.00 $2,417.09 _$2,417.09 Filing Fees $0.00 $129.05 $129.05 Interest $0.00 $174.40 $174.40 Attorney Fees $0.00 $483.42 $483.42 Grand Total: $3,203.96 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. FEB 2 0 201 ,,,; _°° Dategisterial Distri t J e Richard .Dougherty - certi y that this is a true and correct copy of the record of the proceedin containing t ment. MAR 2 g 201 Date kogis —nal District udge MDJS 315 Page 1 of 2 Printed:02/21/2013 8:48:25AM Law Firm of Allan C. Smith, P.C. Attorney I.D. 204756 Bucks County Office Center 1276 Veterans Hwy- Suite E-1 Bristol, PA 19007 1-888-275-6399 H(215)428-0666 Attorney for Plaintiff CACH,LLC CUMBERLAND COUNTY 4340 S. MONACO -- 2ND FLOOR DENVER, CO 80237 COURT OF COMMON PLEAS Plaintiff, vs. DAVID GARRY No. 808 ERFORD ROAD CAMP HILL,PA 17011 Defendant. CERTIFICATE OF SERVICE I, Corryn L. Kronnagel, Esq., of full age, certify that I mailed a copy of the Request to Transfer Judgment regarding the above-captioned matter upon Defendant,DAVID GARRY,by United States First Class Mail, postage prepaid, on September 24, 2014 at his/her last address of: DAVID GARRY 808 ERFORD ROAD CAMP HILL,PA 17011 Date: September 24, 2014 B4 n L. Kronnagel, Esq. ttomey I.D. No. 313173 Law Firm of Allan C. Smith,P.C. Attorney I.D. #204756 Bucks County Office Center 1276 Veterans Highway, Suite E-1 Bristol, PA 19007 1-888-275-6399 H(215) 428-0666 Attorney for Plaintiff CACH,LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, ) NO: vs. ) DAVID GARRY ) Defendant(s). ) To: DAVID GARRY 808 ERFORD ROAD CAMP HILL,PA 17011 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby no ied that a Judgment has been entered against you in the above pro eed' in i d below: By: X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Verdict If you have any questions concerning the above,please contact: ATTORNEY: ALLAN C. SMITH, Esquire at 215-428-0666 or 1-888-275-6399 Coyle Mule 230. Notice by Prothonotary ot'Elitry ot'Order or JuLl_uMIt. Pa-e i of 2 t�r Pru�urlvania Rule 236. Notice by Prothonotary of Entry of Order or Judgment. (a) The prothonotary shall immediately give written notice of the entry of (1) a judgment entered by confession to the defendant by ordinary mail together with a copy of all documents tiled with the prothonotary in support of the confession of judgment. The plaintiff shall provide the prothonotary with the required notice and documents for mailing and a properly stamped and addressed envelope: and (2) any other order or judgment to each party's attorney of record or. if unrepresented, to each party. The notice shall include a copy of the order or judgment. Official Note See Rules 1012 and 1025 as to the requirement of an address on an appearance and a pleading. (b)The prothonotary shall note in the docket the giving of the notice and, when a judgment by confession is entered, the mailing of the required notice and documents. (c) Failure to give the notice or when a judgment by confession is entered to mail the required documents. or both. shall not affect the lien of the judgment. (d) The prothonotary may give the notice required by subdivision(a) or notice of other matters by facsimile transmission or other electronic means if the party to whom the notice is to be given or the party's attorney has tiled a written request for such method of notification or has included a facsimile or other electronic address on a prior legal paper tiled in the action. Official Note Except as provided by subdivision(a)(1) relating to the entry of a judgment by confession. Rule 236 does not prescribe a particular method of giving notice. vlethods of notice properly used by the prothonotary include, but are not limited to, service via United States mail and courthouse mail. Subdivision(d) governs facsimile transmission and other electronic means if the prothonotary chooses to use such a method. A facsimile or other electronic address set forth on letterhead is not a sufficient basis under this rule to authorize the prothonotary to give notice electronically. Notice by facsimile transmission or other electronic means is applicable not only to orders and judgments under subdivision(a) but also to "other matters" such as the scheduling of a conference. hearing or trial or other administrative matters. Where the technology involved provides an acknowledgment for the mailing or the receipt of the notice. the prothonotary should retain that acknowledgment as part of his or her tile. Ilttn', %v%v-,v nicode co mkerimphi71 n0,t ttml i;1 1% �n i 1';l. Cele Mule '�G. Notice by Prothonotary of Entry t�f UCller ur Jug!`.merit. 1'a1e ? of 3 See Rule 305.4 _uvernin, tilling and service of legal papers by electronic means other than facsimile transmission. See Rule 440(d) <,oveming service of legal papers other than original process by facsimile transmission. Source The provisions of this Rule 336 adopted October 4, 1973. effective December 1, 1973, amended March 9, 1977, effective April 10. 1977, 7 Pa.B. 839: amended March 11, 1991, effective July 1, 1991.21 Pa.B. 1274: amended June 3, 1994, effective September 1, 1994. 24 Pa.B. 3017: amended November 28, 2000,effective January 1, 2001, 30 Pa.B. 6421: amended April 29, '_003. effective September 1, 2003, 33 Pa.B. 2356: amended December 16, 2003, effective July 1, 2004, 34 Pa.B. 9: amended June 12, 2006, effective July 1, 2006, 36 Pa.B. 3085: amended December 29, 2008, effective immediately. 39 Pa.B. 304. Immediately preceding text appears at serial pages(302-438)and(331697). No part of the information on this site may be reproduced for profit or sold for profit. I'his material has been drawn directly from the official Pennsylvania lode full text database.Due to the limitations of HTNIL or differences in display capabdiues of dttfarent browsers,this version may Jitter slightly from the official printed version. h tirl' 'ILI.L\.V I'1:1(`t1t�P,`t\tT!ca•nro l,-I•,tom/��1 �.•L,n.,►�.�nni..,�< 1,a..._t . . .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA n -a CACH, LLC : rn - • CIVIL TERMyr_' Plaintiff : V. • CASE NO.: 14-5698 cd - Y c-a • z c - David Garry : y_, Defendant : ry MOTION TO QUASH TRANSFER OF JUDGMENT, VACATE DEFAULT JUDGEMENT AND ENFORCE WRIT OF CERTIORARI 1. David Garry is an individual residing at 808 Erford Rd Camp Hill PA 17011, and is referred to as Defendant in this motion. 2. CACH, LLC is a corporation operating out of 4340, S. Monaco, Second Floor Denver, Colorado 80237 and is referred to as Plaintiff in this motion. 3. The Law Firm of Allan C. Smith, operating out of 1276 Veteran's Highway, Suite E-1 Bristol PA 19007 is the plaintiffs counsel. 4. On February 19, 2013 a hearing was held in MDJ-09-1-03 regarding plaintiffs allegations that the defendant owes them some alleged debt. 5. On February 20, 2013 a judgment was entered in favor of the plaintiff(Docket number MJ-09103-CV-0000304-2012). 6. On March 19, 2013, defendant entered a PRAECIPE FOR WRIT OF CERTIORARI (PA Code Title 246, Rule 1009) in Cumberland County Court of Common Pleas (Case 13- 1473), citing gross irregularity of procedure in obtaining the judgment against him. This Writ acts as a SUPERSEDEAS to the judgment in question (Title 246, Rule 1013). 1 7. The Prothonotary issued the Writ to the Magisterial District Justice; defendant properly served the district justice, who had 10 days to send a certified true copy of the record of the proceedings to the higher court for review (Title 246, Rules 1011 and 1012). 8. The Magisterial District Justice never complied with the Prothonotary's order. 9. On September 26th, 2014, the plaintiff, under a new attorney, entered a Praecipe to Transfer Judgment to Cambria County, PA. 10. It is unknown why a county out in Western PA was selected as the place requested to transfer the improperly obtained judgment. The plaintiffs counsel is located in Bucks County, Eastern PA, and the defendant lives in Cumberland County. 11. Also on September 26th, 2014,the Prothonotary issued a Judgment By Default. Conclusion The Cumberland County Court never reviewed the proceedings, all documents entered, as well as an audio recording of the hearing, to determine if the judgment in question was obtained in a valid manner according to the PA/local Rules of Civil/Magisterial Procedure. Furthermore, since a Writ of Certiorari is a perfectly legitimate legal challenge to an improperly obtained judgment, there can be no judgment by default. The judgment is not valid, nor enforceable, and cannot be until the defendant's Writ of Certiorari is addressed. Moreover, this is a matter that is pertinent only in the county of Cumberland, and should not be transferred to the Cambria county court. WHERFORE, the defendant respectfully requests this honorable court to grant this Motion, quash the plaintiffs Praecipe to Transfer Judgment, vacate the Prothonotary's Judgment by Default, and enforce defendant's Writ of Certiorari (13-1473). Respectfully Submitted, h 51/(/ David S. Garry 2 , . COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS WRIT OF CERTIORARI i JUDICIAL DISTRICT TO 1 . . !,,v i..:...,,-,•i.0,,,-- DISTRICT JUSTICE COMMON PLEAS No. /-3 - il?3 Cez,.A_,/• PRAECIPE FOR WRIT OF CERTIORARI NAME OF PARTY fiLING:l.litS PRAECIPE AND OBTAINING THIS WRIT CLAIM Na&II r-r-ei/01-- (V---/-7"6-5,-.4 cc.v iri (••• c,re, CV 4 2 c i Z LT 20 DATE JUDGMENT RENDERED 1 IN THE CASE OF(Plaineft) iDEFENDANT 1 f"..,117,1ria.‘"7' 2 c.:- . I) (A-(14/ 44 Vs. 1.),-1/4v 1 et ((corr." The party named ablve claims that with respect to the above proceedings there was: (Check app/cable box or boxes) 0 lack of jurisdiction over the subject matter 0 lack of jurisdiction over (Name of party) O improper venue la such gross irregularity of procedure as to make the judgment void PRAECIPE:To the Prothonotary . ic_14.24ej Issue Writ of Certiorari directing PC P1 g ..). D e .., hef 4 District Justice '' .,. , i to transmit to you a certified copy of the record of the proceedings named above. , .... (Signature I frparty filing Prabcipe or his attorney or agent) WRIT OF CERTIORARI To: Ri<kNkre_i 5- Do:),11.1.-1-1Distri• ct Justice 1. You are hereby directed by this writ to transmit to the Prothonotary of this Court of Common Pleas, within ten(10)days after you receive this writ, a certified true copy of the record of the proceedings named above. case. [0 2. This writ,when received by you,will operate as a SUPERSEDEAS to the judgment foi•possession in this This block will be checked ONLY when this notation is required under Pa. k C P.D.J. No. 10138. iI Date delivered for service /9 ,20 a_ • .. MIK - / .• ignature of Prothonotary or Deputy COURT FILE PROOF OF SERVICE OF WRIT OF CERTIORARI (This proof of service MUST BE FILED WITHIN TEN(10)DAYS AFTER deliver),of the writ for service) COMMONWEALTH OF PENNSYLVANIA (Check applicable boxes) COUNTY OF .ss AFFIDAVIT:I hereby swear or affirm that I served the Writ of Certiorari,Common Pleas No. upon the District Justice to whom it was directed on .20_—,0 by personal service,Oby(certified)(registered)mail,senders receipt attached hereto,and that I served a copy of the writ upon the opposite party(ies) (name or names): on 20.,___, 0 by personal service Oby(certified)(registered)mail,sender's receipt attached hereto. SWORN(AFFIRMED)AND SUBSCRIBED BEFORE ME THIS—DAY OF ,20—. (Signature of affiant) (Signature of official before whom affidavit was made) (Title of official) My Commission expires on 20 American LegalNet.Inc, (6/02) TO BE FILED IN TRIPLICATEwww.USCourtforms,com 10/15/2014 246 Pa.Code Rule 1009.Praecipe for Writ of Certiorari. PThe '!{lt? 1r's1: 1 ;Ill' 'l'I+ I l I: 1 2 ;( ., CERTIORARI Rule 1009. Praecipe for Writ of Certiorari. A. Unless he was the plaintiff in the action before the magisterial district judge, a party aggrieved by a judgment may file with the prothonotary of the court of common pleas a praecipe for a writ of certiorari claiming that the judgment should be set aside because of lack of jurisdiction over the parties or subject matter, improper venue or such gross irregularity of procedure as to make the judgment void. If the party aggrieved by the judgment was the plaintiff in the action before the magisterial district judge, he may file a praecipe for a writ of certiorari only on the last mentioned ground. B. If lack of jurisdiction over the parties or the subject matter is claimed, the praecipe may be filed at any time after judgment. Otherwise it shall be filed within thirty (30) days from the date of the judgment. C. The praecipe shall identify the judgment complained of and the magisterial district judge in whose office the record of the proceedings containing the judgment is filed. D. The praecipe and the writ shall be on a form which shall be prescribed by the State Court Administrator. Official Note Subdivision A sets forth the grounds for certiorari. See the comments concerning the limited nature of certiorari in the note to Rule 1001. The plaintiff in the action before the magisterial district judge, and the word "plaintiff" as used in this rule does not include a defendant who has sued on a cross-complaint, may file a praecipe for a writ of certiorari only on the ground of gross irregularity. Having instituted the proceedings before the magisterial district judge, the plaintiff should not be permitted to challenge jurisdiction or venue. Under subdivision B,the praecipe for the writ of certiorari must be filed within thirty days after the date of the judgment,except when a question of jurisdiction is raised.There is no time limit on raising a question of jurisdiction by certiorari.Flaherty v.Atkins, 189 Pa. Super. 550, 152 A.2d 280(1959).A party who files his praecipe after the thirty day period has run can be heard only on the question of jurisdiction(if permitted to raise that question under subdivision A)even though he claims improper venue or gross irregularity along with his claim of lack of jurisdiction. Source The provisions of this Rule 1009 amended through April 25, 1979, effective May 25, 1979, 9 Pa.B. 1499. Immediately preceding text appears at serial page (25119). http://www.pacode.conn/secure/data/246/chapter1000/s1009.html 1/2 10/15/2014 246 Pa.Code Rule 1011.Issuance and Service of Writ of Certiorari. The Pennsylvania I'I2I'i'U ("1("11.11,r I I'Ir Ili I:.()i ' I ' ;". I II. Rule 1011. Issuance and Service of Writ of Certiorari. A. Upon receipt of the praecipe for a writ of certiorari, the prothonotary shall issue the writ and direct it to the magisterial district judge in whose office the record of the proceedings containing the judgment is filed. The writ shall be delivered for service to the party who filed the praecipe. B. The party obtaining the writ shall serve it, by personal service or by certified or registered mail, upon the magisterial district judge to whom it was directed. In like manner, he shall also serve a copy of the writ upon the opposite party. The address of the opposite party for the purpose of service shall be his address as listed on the complaint form filed in the office of the magisterial district judge or as otherwise appearing in the records of that office. If the opposite party has an attorney of record named in the complaint form filed in the office of the magisterial district judge, the service upon the opposite party may be made upon the attorney of record instead of upon the opposite party personally. C. If proof of service of the writ upon the magisterial district judge and the opposite party is not filed with the prothonotary within five (5) days after delivery of the writ for service, the prothonotary shall, upon praecipe of the opposite party, mark the writ stricken from the record and the writ shall not be reinstated nor shall any new writ issue. D. Service and proof of service may be made by attorney or other agent. Official Note The provisions as to service of the writ parallel those for service of notices of appeal. Subdivision C contains sanctions for failing to comply with the prescribed time limits, and reinstatement of the writ or the issuance of a new one is not allowed. Source The provisions of this Rule 1011 amended November 21, 1975, 5 Pa.B. 3020. Immediately preceding text appears at serial page (21214). No part of the information on this site may be reproduced for profit or sold for profit. This material has been drawn directly from the official Pennsylvania Code full text database.Due to the limitations of HTML or differences in display capabilities of different browsers,this version may differ slightly from the official printed version. http://www.pacode.com/secure/data/246/chapter1000/s1011.html 1/1 10/15/2014 246 Pa.Code Rule 1012.Return by Magisterial District Judge. P' The : P1-1 '1 1 iS N€;\ I t t Lid'1 1 1 1, :. : 107 ) l 1'_ ,=.; ltai::: lot Rule 1012. Return by Magisterial District Judge. The magisterial district judge to whom the writ of certiorari is directed shall, within ten (10) days after its receipt by him, make return to the writ by transmitting to the prothonotary a certified true copy of the record of the proceedings containing the judgment. Official Note The certified true copy of the record of the proceedings containing the judgment will be a certified true copy of the filled out complaint form prescribed by the State Court Administrator. No part of the information on this site may be reproduced for profit or sold for profit. This material has been drawn directly from the official Pennsylvania Code full text database.Due to the limitations of HTML or differences in display capabilities of different browsers,this version may differ slightly from the official printed version. http://www.pacode.com/secure/data/246/chapter1000/s1012.html 1/1 10/15/2014 246 Pa.Code Rule 1013.Writ of Certiorari as Supersedeas. The rta Rule 1013. Writ of Certiorari as Supersedeas. A. Receipt of the writ of certiorari by the magisterial district judge to whom it was directed shall operate as a supersedeas, except as provided in subdivisions B and C of this rule. B. When the writ of certiorari involves a judgment for the possession of real property, receipt of the writ by the magisterial district judge shall operate as a supersedeas only if the party obtaining the writ at the time of filing the writ, deposits with the prothonotary a sum of money (or a bond, with surety approved by the prothonotary) equal to the lesser of three (3) months' rent or the rent actually in arrears on the date of the filing of the praecipe for writ of certiorari ("praecipe"), as determined by the magisterial district judge, and, thereafter, deposits cash or bond with the prothonotary in a sum equal to the monthly rent which becomes due during the period of time the proceedings upon writ are pending in the court of common pleas, such additional deposits to be made within thirty (30) days following the date of the filing of the praecipe, and each successive thirty (30) day period thereafter. Upon application by the landlord, the court shall release appropriate sums from the escrow account on a continuing basis while the writ is pending and while the ensuing proceeding is pending (in the event the writ is granted) to compensate the landlord for the tenant's actual possession and use of the premises during the pendency of the writ and during the pendency of the ensuing proceeding (in the event the writ is granted). In the event that the party filing the praecipe fails to deposit the sums of money, or bond, required by this rule when such deposits are due, the prothonotary, upon praecipe filed by the party that did not file the praecipe for writ of certiorari, shall terminate the supersedeas. Notice of the termination of the supersedeas shall be forwarded by first class mail to attorneys of record, or, if a party is unrepresented to the party's last known address of record. Where the deposit of money or bond is made pursuant to this Rule at the time of the filing of the praecipe, the prothonotary shall make upon the writ and its copies a notation that the writ will operate as a supersedeas when received by the magisterial district judge. C. Indigent Tenants (1) Residential tenants who seek to file a praecipe involving a magisterial district court judgment for possession and who do not have the ability to pay the lesser of three months' rent or the full amount of the magisterial district court judgment for rent shall file with the office of the prothonotary a tenant's affidavit, as set forth in subdivision (2). (2) The tenant's affidavit shall be substantially in one of the following two forms: [Caption] http://www.pacode.com/secure/data/246/chapter1000/s1013.html 1/7 LED 0FFi L OF T H E PROTHONOTARY 2014 OCT 17 PM J2: 4 3 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC. DAVID S. GARRY Plaintiff, CASE NO.: 14-5698 v. Defendant. • MOTION TO QUASH TRANSFER • • OF JUDGEMENT, VACATE DEFAULT JUDGEMENT_AND.,ENFORCE:WRIT OF CERTIORARI CERTIFICATE OF SERVICE David S. Garry, Defendant, hereby notifies this Court that proper service was completed by U.S. First Class Pre -paid mail to The Law Firm of Allan P Smith, counsel for the Plaintiff on October 15, 2014, at the following address: CACH, LLC. C/O Law Firm of Allan P. Smith 1276 Veteran's Highway, Suite E-1 Bristol PA 19007 David S. Garry /07/7AV 4 CAMP HILL POST OFFICE CAMP HILL, Pennsylvania 170119998 4134870011 -0095 10/15/2014 (717)737-1461 05:31:45 PM Sales Receipt Product Sale Unit `Description Oty Price Final Price (Forever) 1 $0.62 Folk Art Eagle WAG #10 Envelop BRISTOL PA II9007) Zone -2 First -Class Mail Large Env 1.60 oz. Expected Delivery: Sat 10/18/14 Customer Postage $0.62 $1.19 -$0.49 Issue Postage: $0.70 Total: $1.32 Paid by: Debit Card $1.32 Account #: XXXXXXXXXXXX7024 Approval #: 542982 Transaction #: 370 23 903110005 Receipt#: 001492 WXWWXWWWXWXWXXWWWWXXWWXWWXWWXWWWWXXWWXWW WWWWXWWXWWWWXWWWXXWXWWXWXXWXXXWXXWXXXXXW BRIGHTEN SOMEONE'S MAILBOX. Greeting cards available for purchase at select Post Offices. XXXWXXXXWXWWWWWWXWWXWXWWWXWWXWWWWXWWWXWW WWWWXWXXXWWWWWXWXWWWXWWWWWXWXWXXXXWXWXWW Order stamps at usps.com/shop or call 1-800-Stamp24. Go to usps.com/clicknship to print shipping labels with postage. For other information call 1 -800 -ASK -USPS. WWXWXXXWWWWXWWWWXWWXWWWWWWWWWWWXWXWX7CXXW WWWWWWWWWWXWWWWXWWWWWWWWWWXWWWWWWWXXWWWW Get your mail when and where you want it with a secure Post Office Box. Sign up for a box online at usps.com/poboxes. WWXWXXXXXXXWXXXXWWXWXXXWWWXWXWWWWWWXWXWX XWWXWWWWXWWWXWXWXXXXWWWXWWWWWWWXWWXWXWWW Bi1l#: 1000506235182 Clerk: 19 All sales final on stamps and postage Refunds for guaranteed servi-ces only Thank you:for your businesa' CACH, LLC., : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA v. DAVID S. GARRY, DEFENDANT : NO. 14-5698 CIVIL ORDER OF COURT AND NOW, this 20th day of October, 2014, upon consideration of Defendant's Pro Se Motion to Quash Transfer of Judgment, Vacate Default Judgment and Enforce Writ of Certiorari; IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule shall issue upon CACH, LLC to show cause why the relief requested by the Defendant should not be granted. 2. Plaintiff shall file an Answer to the Motion on or before November 14, 2014. 3. Hearing/argument on the motion will be heard Friday, January 23, 2015, at 2:00 p.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania. CH, LLC Plaintiff Zavid S. Garry Defendant bas //2,:// ef By the Court, C) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CACH, LLC. DAVID S. GARRY Plaintiff, CASE NO.: 14-5698 v. Defendant. MOTION TO DENY ORAL ARGU_ME [,T' AND DISMISS COMPLAINT moo rsi ^\Y W rC e+c ^Z3 c, cp ti CERTIFICATE OF SERVICE David S. Garry, Defendant, hereby notifies this Court that proper service was completed by U.S. First Class Pre -paid mail to Kodak Law Firm, counsel for the Plaintiff on November 3rd, 2014, at the following address: Lehigh University C/O Kodak Law Firm 407 N. Front St. Harrisburg PA 17101 4 CARLISLE MPO CARLISLE, Pennsylvania 170139998 4134870013 -0098 11/03/2014 (880)276'8777 12:47:49 PM Sales Receipt Product Sale Unit Final Description Qty Price Price (Forever) Bank Swallow WAG #10 Envelope 1 $0,62 $0.62 Total' $0.62 Paid by: VISA $0.62 Account #: xxxxxxxxxxxx/02* Approval #; 024720 Transaction #: 314 23 903110013 °^°°^**°°°°^*°°°°+^°° *^^^° BRIGHTEN SOMEONE'S MAILBOX. Greeting cards ' available for purchase at select Post Offices. ^^°^^++^^^^**°^^°°^°^^^++°^^^*^°°°*^^^°^ Order stamps at usps.com/shop or call 1'800'Stump24. Go to usps.com/clicknship to print shipping labels with postage. For other information call 1-800'ASK'U5PS. ^^°^°^°^^°°°^°°^*°^°°°^°^^^°°^~^^^^^°°^^ °°°~°^°°*°^°^°°°°°°°°°°°°^^°°°^°°°°~^°~° Get your mail when and where vnu want it with a secure Post Office Box. Sign up for a box online at usps.com/poboxes. ^°°°^^°^^^°°^*°°^°*°°°°^*^°°°°^°°°^°*°^° °°°°^^^^^°^^^°^^^^°°°^°^^^"^°^°°°^*^°~°° dill#: 1000206134579 Clerk: 13 All sales final on stamps and nostuye Refunds for guaranteed services only Thank you for your business HELP US SERVE YOU BETTER TELL US ABOUT YOUR RECENT POSTAL EXPERIENCE Go to: Or scan this code with your mobile device. Or.i � f- �