HomeMy WebLinkAbout05-1457MCSHANE & HITCHINGS, LLC
Plaintiff,
VS.
GEORGE, SEIDLE, JR.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 05- 1,1497
CIVIL ACTION
ENTRY OF APPEARANCE
PRAECIPE FOR ASSESSMENT OF DAMAGES
AND CONFESSION OF JUDGEMENT
TO THE PROTHONOTARY:
Kindly enter our appearance for and on behalf of the Defendant above named.
Pursuant to the authority in the Warrant of Attorney, the original or a copy of
which is attached to the Complaint filed in this action, I hereby appear for the Defendant
in this matter, George Seidle, Jr., and confess judgment authorized, in favor of the
Plaintiff and against the Defendant for Seven Hundred and Ninety Four Dollars and Fifty
Cents ($794.50), plus interest from March 7, 2005 add at a rate of 6% per annum.
submitted,
Date: ?l I N
McShane, Esquire
I.D.# 87919
481 ? Jonestown Road
Suit 125
Pennsylvania 17109
#717-657-3900
Attorney for Plaintiff
MCSHANE & HITCHINGS, LLC
Plaintiff,
vs.
GEORGE SEIDLE, Jr.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 05- P49`
CIVIL ACTION
CO. t C`T
COMPLAINT
AND NOW COMES, the Plaintiff, McShane & Hitchings, LLC, by and through
its undersigned Attorney, Justin J. McShane, Esquire and avers in support of this
Complaint against Defendant as follows:
1. The Defendant, George Seidle, Jr., is an adult individual residing at 813
Wertzville Road, Enola, Cumberland County, Pennsylvania 17025.
2. Plaintiff, McShane & Hitchings, is a Limited Liability Corporation with an
address of 4811 Jonestown Road, Suite 125, Harrisburg, Dauphin County,
Pennsylvania 17109.
3. A true and correct copy of the Warrant of Attorney is attached.
4. Judgment by confession is not being entered against a natural person in
connection with a consumer credit transaction.
5. The Warrant has not been assigned.
6. Judgment has not been entered on the instrument in any jurisdiction.
7. Defendant has defaulted on the agreement by failing to pay three hundred and
fifty dollars ($350.00) on December 3, 2004. Efforts to obtain payment have not
been fruitful.
8. This action is being filed in Cumberland County pursuant to the Warrant of
Attorney as that is the County in which the Defendant resides.
9. The Defendant now owes three hundred and fifty dollars ($350.00) in payments, a
ten percent (10%) penalty of thirty five dollars ($35.00), two hundred twenty five
dollars ($225.00) in collection fees and one hundred and eighty-four dollars and
fifty cents ($184.50) in filing fees as agreed upon in the Warrant of Attorney.
10. Wherefore, Plaintiff demands that judgment be entered against the Defendant in a
sum of seven hundred ninety four dollars and fifty cents ($794.50) as authorized
by the Warrant of Attorney.
WHEREFORE, Plaintiff, McShane & Hitchings, LLC, requests that this
Honorable Court, enter judgment in its favor and against the Defendant in an amount
of Seven Hundred and Ninety Four Dollars and Fifty Cents ($794.50), plus costs,
fees, interest at a rate of 6% per annum and other such relief as the Court deems
appropriate under the circumstances.
Respectfully submitted,
McShane & JlitchinLm LLC
Date: /
Atto ey I .D.# 87919
4811 nestown Road
S+it6125
Harrisburg, Pennsylvania 17109
#717-657-3900
Attorney for Plaintiff
MCSHANE & HITCHINGS, LLC
ATTORNEYS AT LAW
4807 Jonestown Road
Suite 242
Justin J. McShane Harrisburg, Pennsylvania 17109
Justin( 1866mcshane.com
(717) 657-3900
Joseph L. Hitchings Fax: (717) 657-2060
Jlh.la w(@,vet'i zon.n et
Erin M. Zimmerer
Zimmerer955( hotmaiLcom
November 22, 2004
Judy B. Cohen
Legal Assistant
Heather M. Maynard
Legal Assistant
Non-Refundable Retainer Agreement and Agreement on Fees-Time Payment Option
Dear Mr. Seidle:
You have asked my firm and I to act as Michael Sitzer's attorney in connection with the below
enumerated matter. I accept the representation on the terms set forth below:
1. I will represent you to the best of my ability in the matter, but can not guarantee that the matter
will be resolved to your satisfaction, I shall keep you fully informed as to the progress of your
case. I will be available to you by telephone or in person for consultation. If no one is available
when you telephone, your call will be returned promptly.
2. You agree to pay my firm an initial retainer fee of four hundred dollars ($400), which is paid to
me as consideration for my agreement to become your attorney and assuring my future
availability in your matter. This retainer fee is not refundable under any circumstances, is earned
by me upon receipt, and represents the minimum fee for the services to be rendered. It is retained
even upon your termination of my services.
3. You agree to pay a flat fee on an a la carte schedule for my services on a per event basis. This
means that all representation will cease at the end of representation for the event listed below.
You have agreed to pay a sum of three hundred ($300) for my representation in Michael Sizer's
preliminary hearing currently pending before DJ Shugars. The total fee in this matter would be
seven hundred and fifty dollars ($750). Some of the work on your case will be done at rates by
other attorneys or paralegal assistants or law students under my personal supervision. You will be
billed for their services at their standard rates if necessary. It is impossible to determine in
advance the amount of time that will be required to bring your case to a conclusion. I assure you
that I will proceed in an expeditious and efficient fashion and will consult with you in advance if
any exceptional activity is necessary. I expect and require prompt payment of these bills and
reserve the right to terminate my relationship with you should you fail to pay on time.
4. In the event that McShane and Hitchings, LLC is required to institute any legal action for
collection of our agreed upon fees or costs, you agree to pay additional reasonable fees, costs and
the value of my time in bringing such an action. McShane and Hitchings, LLC will charge one
1-866-MCSHANE
CENTRAL PENNSYLVANIA'S ONLY CRIMINAL DEFENSE ATTORNEY
AVAILABLE 24 HOURS A DAY SEVEN DAYS A WEEK
hundred and fifty dollars ($150) per hour in any attempt to recover fees. By signing this
document you agree to this fee. In the event, that we accept a credit card, debit card, draft or
check in your case and that credit card, debit card check or draft is returned for Non-sufficient
funds, a charge back instituted by the payor or other method of denial of payment for any reason
or no reason at all, you agree that your account will become immediately due in full and you will
be assessed a forty dollar ($40) returned item fee as well as a twenty dollar ($20) processing fee.
This money will be due by you regardless of whether or not a third party is paying this fee or co-
signs this instrument,
5. Costs will be incurred by me in my handling of this matter. Costs are out-of-pocket expenses,
and can include such items as filing fees, fees for subpoena servers, transcripts (including the
stenographer's appearance fee), investigators, appraisers and accountants, excessive
telecopying and photocopying, and excessive postage. They do not include charges for clerical or
secretarial time which are part of my flat fee. These costs are your responsibility and will be
itemized and billed on a bimonthly basis.
6. The payment of the non-refundable retainer will not include any other appearance in court.
You are required to pay an additional sum for additional appearances or actions. I also agree that
by signing this agreement that any subsequent agreements for services in the future are valid
regardless of whether or not I sign that subsequent agreement. In other words, once I pay on any
subsequent agreement regardless of whether or not I sign the agreement, I intend to be bound
according to the terms and conditions in this agreement except for the money. By paying any
amount I agree to the fee proposed even if no signature on a subsequent agreement is obtained.
7. The payment of any money does not include the filing of omnibus pretrial motions or bail
modification motions. This payment does not include appearances attendant to bail modification
hearing (e.g., bail forfeiture hearings, bail revocation hearings). This payment does not include
the filing of motions to reduce or reinstate bail. This payment does not include any sort of
appellate work including but not limited to direct appeals as of right, discretionary appeals,
interlocutory appeals, Petition for Allowance of Appeal and Post Conviction Relief Act (PCRA)
petitions.
8. Should you as the client fail to appear at a hearing or required court appearance, by your
absence, you will have agreed to forfeit the money paid for that appearance to McShane and
Hitchings, LLC and will be required to pay a new fee for further representation. Further, you will
be assessed a charge of five hundred dollars ($500) on top of the non-refundable retainer fee as
new legal fees if you miss a hearing and McShane and Hitchings, LLC attends it regardless of
whether or not a warrant is issued.
This agreement shall become effective and my representation will commence upon my receipt of
a signed copy of this letter and the specified fee below. With said endorsement and payment, you
signify that you agree to all the terms and conditions contained herein.
1-866-MCSIIANE
CENTRAL PENNSYLVANIA'S ONLY CRM4INAL DEFENSE ATTORNEY
AVAILABLE 24 HOURS A DAY SEVEN DAYS A WEEK
TIME PAYMENTS
McShane and Hitchings, LLC accepts your request for time payments at the following schedule:
Your first payment will be made on the November 22, 2004 in the amount of four hundred dollars
f ($400).
The second payment on the balance of the monies owed will be due on December 3, 2004 by no
later than three o'clock in the afternoon (3 p.m.). This would be a payment of three hundred
and fifty dollars ($350). In the event of non-payment or untimely payment, all efforts on your
behalf by this firm will cease and you will be charged a late payment fee of ten percent (10%). In
addition, the entire balance outstanding will come due immediately with a fee assessed at ten
percent (10%) as a penalty.
As mentioned previously, in the event McShane and Hitchings, LLC is required to institute any
legal action for collection of our agreed upon fees or costs, you agree to pay additional reasonable
fees, costs as well as the value of McShane and Hitchings, LLC's time in bringing such an action.
McShane and Hitchings, LLC will charge one hundred and fifty dollars ($150) per hour in any
attempt to recover fees. By signing this document you agree to this fee. Additionally, by signing
this agreement you agree that if you were to default for any reason you assert a dual recognition
that: (1) You acknowledge that you intentionally obtained services for yourself or for another
which you know is available only for compensation and (2) that you intend to permanently
deprive McShane and Hitchings, LLC of the balance of the monies accumulated and due.
Please execute a copy of this agreement where indicated below and return to McShane and
Hitchings, LLC with a check, money order, cash or credit card transaction for McShane and
Hitchings, LLC's fee outlined above.
Very truly yours,
McShane and Hitchings, LLC
Erin . Z mmerer, quire
Associate
By signing this document, I assert that I have read and fully understand all of the provisions and
conditions contained within. Further, I assert that I agree knowingly, intelligently, and
voluntarily to these terms and conditions outlined above. Finally, I acknowledge that this
1-866-MCSHANE
CENTRAL PENNSYLVANIA'S ONLY CRIMINAL DEFENSE ATTORNEY
AVAILABLE 24 HOURS A DAY SEVEN DAYS A WEEK
document contains the full and complete understanding between the parties and that no
amendments to this agreement will be permitted unless promulgated in writing and signed by the
parties.
// b
Date
Surety, Ck , or Co-signer o ebt
1-866-MCSHANE
CENTRAL PENNSYLVANIA'S ONLY CRIMINAL DEFENSE ATTORNEY
AVAILABLE 24 HOURS A DAY SEVEN DAYS A WEEK
WARRANT OF ATTORNEY:
In event of default which is measured by a failure to make a timely payment as
outlined above and to secure the payment of credit given and in
acknowledgement for the debt outlined above, I hereby empower the
Prothonotary of any court with proper jurisdiction and authorize irrevocably, any
attorney of any Court of Record to appear in any court with proper jurisdiction for
McShane and Hatchings, LLC at any time hereafter; and confess a judgment
without process, in favor of McShane and Hitchings, LLC for such amount as
may appear to be unpaid thereon, whether due or not together with reasonable
attorney's fees calculated at a rate of ten percent (10%) of the debt owed, court
costs, sheriff s fees and bond costs and to waive and release all errors which
may intervene in any such proceedings and to consent to immediate execution
upon such judgment hereby ratifying and confirming all that said attorney may do
by virtue hereof.
I also waive the right of inquisition of any real estate levied on, voluntarily
condemns the same, authorizes the Prothonotary or clerk to enter the writ of
execution on said voluntary condemnation, I agree that said real estate may be
sold on a writ of execution, and also waive and release all relief from any and all
appraisement, stay or exemption law of any state now in force or enacted in the
future. I acknowledge that the authority and power to appear for and enter
judgment against me will not be exhausted by any single exercise of the
authorized power, and the same may be exercised from time to time as often as
the holder deems necessary or desirable; and this instrument will be a sufficient
warrant.
I expressly waive presentment, demand, notice, protest and all other demands
and notices in connection with the delivery, acceptance, performance, default or
enforcement of this Acknowledgement of Debt, and an action for any amounts
due and unpaid shall therefore accrue immediately.
WARNING - BY SIGNING THIS PAPER YOU GIVE UP YOUR RIGHT TO
NOTICE AND COURT TRIAL. IF YOU DO NOT PAY ON TIME A COURT
JUDGMENT MAY BE TAKEN AGAINST YOU WITHOUT YOUR PRIOR
KNOWLEDGE AND THE POWERS OF A COURT CAN BE USED TO
COLLECT FROM YOU REGARDLESS OF ANY CLAIMS YOU HAVE
AGAINST THE CREDITOR WHETHER FOR FAILURE ON THEIR PART TO
COMPLY WITH THE AGREEMENT, OR FOR ANY OTHER CAUSE.
1 agree that this document constitutes the full and complete understanding of the
parties. No other provisions exist oral or otherwise. This Agreement may only
be amended or modified by a written instrument executed by the parties.
1-866-MCSIIANE
CENTRAL PENNSYLVANIA'S ONLY CRIMINAL DEFENSE ATroRNEY
AVAILABLE 24 HOURS A DAY SEVEN DAYS A WEEK
This Agreement will be construed in accordance with and governed by the laws
of the Commonwealth of Pennsylvania and be litigated before the Dauphin
County Court of Common Pleas.
The parties acknowledge that this Agreement is reasonable, valid and
enforceable. However, if a court of competent jurisdiction finds any of the
provisions of this Agreement to be too broad to be enforceable, it is the parties'
intent that such provision be reduced in scope by the court only to the extent
deemed necessary by that court to render the provision reasonable and
enforceable, bearing in mind that it is my intention to give McShane and
Hitchings, LLC the broadest possible enforcement possible to collect the debt
above outlined.
This Agreement will inure to the benefit of and be binding upon the respective
heirs, executors, administrators, successors and assigns, as the case may be, of
the parties.
Having fully read and understood the above and in full contemplation of the
consequences, I hereby knowingly, intelligently and voluntarily enter into this
agreement. I acknowledge that no threats, promises or other forms of coercion
have been used in securing my signature.
Executed this pS-day of 2004 at 4807 Jonestown Road,
Suite 242, Harrisburg, PA 17112
Signed: u\' _ • ) ) \A(V\A 100,
Witnessed: &ZAZ
1-866-MCStiANE,
CENTRAL PENNSYLVANIA'S ONLY CRIMINAL DEFENSE ATTORNEY
AVAILABLE 24 HOURS A DAY SEVEN DAYS A WEEK
IMPORTANT NOTICE
McShane & Hitchings, LLC utilizes the services of a Consumer Collection
Agency, otherwise known as a "Collection Agency," for accounts that are past
due. By signing this fee agreement you consent to having materials in the
possession of McShane & Hitchings, LLC necessary to collect on this debt be
released to the "Collection Agency" used by McShane & Hitchings, LLC. Such
information may include, but is not limited to any and all contact information (e.g.,
telephone numbers, addresses) as well as a copy of this fee agreement and
payment history. Furthermore, you agree to hold McShane & Hitchings, LLC
harmless for any actions taken by the Collection Agency while enforcing this
agreement. You further agree to a flat rate of one and one half hours (1 '/z) that
would be spent by McShane & Hitchings, LLC in forwarding this matter to the
Collection Agency. The specific Collection Agency employed by McShane &
Hitchings, LLC is subject for change with no prior notice given to you.
Having read all of the above, I knowingly, intelligently, and voluntarily
acknowledge and consent to the above listed terms.
I?I?Iwvx -
Signaffi
1-866-MCSI3ANE
CENTRAL PENNSYLVANIA'S ONLY CRu nNAL DEFENSE ATTORNEY
AVAILABLE 24 HOURS A DAY SEVEN DAYS A WEEK
MCSHANE & HITCHINGS, LLC,
Plaintiff,
vs.
GEORGE SEIDLE, JR,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 05-
CIVIL ACTION
VERIFICATION
I, Erin M. Zimmerer, an Associate for McShane & Hitchings, LLC, Plaintiff, in
the above-captioned matter, verify that the statements made in the Complaint are true and
correct. I understand that false statements herein are made subject to the penalties of 18
Pa. C. S. A. Section 4904 relating to unsworn falsification to authorities.
Y
vw?
Erin M. Zimm rer
MCSHANE & HITCHINGS, LLC
Plaintiff,
VS.
GEORGE, SEIDLE, JR.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 05-
CIVIL ACTION
TO THE HONORABLE JUDGES OF SAID COURT:
CERTIFICATE OF SERVICE
I, Justin J. McShane, Esquire, hereby certify that the following service has been
completed in compliance with the Rules of Civil Procedure:
Via first class mail:
George Seidle, Jr.
813 Wertzville Road
Enola, PA 17025
Atto ey IDS 87919
At rney for the Petitioner
I 1 Jonestown Road
Suite 125
Harrisburg, PA 17109-1739
Telephone: 717-657-3900
Facsimile: 717-657-2060
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PRAECIPE FOR WRIT OF EXECUTION
P. R. C. P. 3101 TO 3149
MCSHANE AND HITCHINGS, LLC
and Erin M. Zimmerer, Esq.
4811 Jonestown Road,
Suite 125
Harrisburg, PA 17109
Plaintiffs,
V.
George Seidle, Jr
813 Wertzville Road
Enola PA, 17025
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO. D S /q f 1 Ot. G 1?
CIVIL ACTION - EQUITY
TO THE PROTHONOTARY OF SAID COURT:
ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of Cumberland County, Pennsylvania;
(2) against George Seidle, Jr., 813 Wertzville Road, Enola, PA 17025.
(3) and against the following Gamishees: N/A
(4) AMOUNT DUE $610.00
INTEREST FROM FEBRUARY 25, 2005 $
COSTS TO BE ADDED 5184.50
(5) and index this writ
(a) George Seidle, Jr., 813 Wertzville Road, Enola, Cumberland
County, PA 17025
(b) against
Garnishee (s),
as a lis pendens against the real property of the Defendant in the name of the Gamishees
as follows: all that certain tract of land situate in Cumberland, known as 813
Wertzville Road, Enola, Cumberland County, PA 17025.
(6) Exemption has (not) been waived.
(7) Amount due: $794.50.
(8) Please have the Sheriff levy upon any and all personal property of George Seidle,
Jr., 813 Wertzville Road, Enola, Cumberland County, PA 17025, including any
automobiles or other vehicles.
Respectfully submitted,
MCSHANE & HITCHINGS, LLC
Justin J. p9hane, Esquire
Attorn fD, #87919
{Ltllmey for Plaintiffs
481'1 Jonestown Road, Suite 125
Harrisburg, Pennsylvania 17109
Telephone: (717) 657-3900
Fax: (717) 657-2060
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 05-1457 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION-LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MCSHANE AND HITCHINGS, LLC., Plaintiff (s)
From GEORGE SEIDLE, JR., 813 WERTZVILLE ROAD, ENOLA, PA 17025
(1) You are directed to levy upon the property of the defendant (s)and to sell AND LEVY UPON
ANY ALL PERSONAL PROPERTY OF GEORGE SEIDLE, JR., 813 WERTZVILLE ROAD,
ENOLA, PA 17025, INCLUDING ANY AUTOMOBILES OR OTHER VEHICLES.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) 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;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $610.00 L.L. $.50
Interest FROM 2/25/05
Atty's Comm % Due Prothy $1.00
Any Paid $37.00 Other Costs
Plaintiff Paid
Date: MARCH 18, 2005
CURTIS R. LONG
Prothonotaa
(Seal) /(j) 2. o lD/lit
Deputy
REQUESTING PARTY:
Name JUSTIN J. MCSHANE, ESQUIRE
Address: 4811 JONESTOWN ROAD, SUITE 125
HARRISBURG, PA 17109
Attorney for: PLAINTIFF
Telephone: 717-657-3900
Supreme Court ID No. 87919
R. Thomas Kline, Sheriff, who being duty sworn according to law, states
this writ is returned STAYED.
Sheriff's Costs:
Docketing 18.00
Poundage 12.20
Advertising
Law Library .50
Prothonotary 1.00
Mileage 10.36
Surcharge 20.00
Levy
Certified Mail
Post Pone Sale
Garnishee
Postage .74
TOTAL $ 62.80
Advance Costs: 150.00
Sheriffs Costs: 62.80
$ 87.20
Refunded to Atty on 05/18/05
Sworn and Subscribed to before me
This 21 "'dayof 'ht
2005 A.D.
0 onotary
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s? daw soaz
So Answers; 4
R. T omas Kline, Sheriff
ft N-3
y Claudia A. Brewbaker
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 05-1457 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due MCSHANE AND HITCHINGS, LLC., Plaintiff (s)
From GEORGE SEIDLE, JR., 813 WERTZVILLE ROAD, ENOLA, PA 17025
(1) You are directed to levy upon the property of the defendant (s)and to sell AND LEVY UPON
ANY ALL PERSONAL PROPERTY OF GEORGE SEIDLE, JR., 813 WERTZVILLE ROAD,
ENOLA, PA 17025, INCLUDING ANY AUTOMOBILES OR OTHER VEHICLES.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) 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;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify hirdber that hc'she has been added as a
garnishee and is enjoined as above stated.
Amount Due $610.00 L.L. $.50
Interest FROM 2/25/05
Any's Comm % Due Prothy $1.00
Arty Paid $37.00 Other Costs
Plaintiff Paid
Date: MARCH 18, 2005
(Seal)
CURTIS R. LONG
Prothonotary
Deputy
REQUESTING PARTY:
Name JUSTIN J. MCSHANE, ESQUIRE
Address: 4811 JONESTOWN ROAD, SUITE 125
HARRISBURG, PA 17109
Attorney for; PLAINTIFF
Telephone: 717-657-3900
Supreme Court ID No. 87919
MCSHANE & HITCHINGS, LLC
Plaintiff,
VS.
GEORGE SEIDLE, Jr.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 05-1457
CIVIL ACTION
SETTLEMENT AGREEMENT
AND NOW THIS 18`h day of May, 2005 comes, McShane & Hitchings, LLC
and George Seidle, Jr., individually (hereinafter "Seidle"), and enter into the following
Settlement Agreement.
WHEREAS, McShane & Hitchings, LLC did work and performed services for
Seidle in Michael Sizer's pending Criminal matter; and
WHEREAS, certain disputes have arisen between the parties regarding
compensation owed to McShane & Hitchings, LLC; and
WHEREAS, McShane & Hitchings, LLC filed suit against Seidle in the Court of
Common Pleas of Cumberland County, Pennsylvania, docketed to number 05-1457 and
WHEREAS, McShane & Hitchings, LLC entered a Warrant of Attorney against
Seidle in the Prothonotary's Office of the Court of Common Pleas of Cumberland
County, Pennsylvania docketed at number 05-1457 in the amount of seven hundred
ninety four dollars and fifty cents ($794.50), as well as costs; and
WHEREAS, the parties have reached an agreement to settle and discontinue the
above referenced litigation and to settle the claims either party may have against the
other.
NOW THEREFORE, the parties hereto with the intent of being legally bound
hereby have agreed as follows:
1. Upon payment of three hundred dollars and no cents ($300.00) in Money
Order on May 18, 2005, this lawsuit will be settled.
2. Upon receipt of the money outlined above in averment number one McShane
& Hitchings, LLC shall have the lawsuit filed by McShane & Hitchings, LLC against
Seidle docketed to number 05-1457 in the Court of Common Pleas Cumberland County,
Pennsylvania marked as satisfied, settled, and discontinued.
3. On May 18, 2005, Seidle issued a Money Order in the amount of three
hundred dollars and no cents ($300.00) sufficient to satisfy the amount of three hundred
dollars and no cents ($300.00).
4. McShane & Hitchings, LLC and Seidle agree that the terms and conditions
stated in this Settlement Agreement constitute the entire agreement between the parties
and no other agreements or representations have been made that are not stated herein.
AND NOW, the parties hereto have set their hand and seals the day and year first
above written.
? ? os
Witness ennif E. Cox D de
a{
Witness Geor i dle Date
Respectfully submitted,
McShane &Hkoin)?s, LLC
Date: 5 ?%105
Atto ey I.D.# 87919
481 Jonestown Road
_Sdite 125
Harrisburg, Pennsylvania 17109
#717-657-3900
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MCSHANE & HITCHINGS, LLC
Plaintiff,
vs.
GEORGE SEIDLE, Jr.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 05-1457
CIVIL ACTION
PRAECIPE TO SATISFY JUDGMENT
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please mark the Judgment entered in the above captioned case against George
Seidle as satisfied and please mark the Judgment Index accordingly.
Date: ,s
1 OS
Respectfully submitted,
McShane & Hitchings, LLC
Atto ey LD.# 87919
onestown Road
Suite 125
Harrisburg, Pennsylvania 17109
#717-657-3900
MCSHANE & HITCHINGS, LLC
Plaintiff,
VS.
GEORGE SEIDLE, Jr.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 05-1457
CIVIL ACTION
CERTIFICATE OF SERVICE
I, Erin M. Zimmerer of McShane & Hitchings, LLC, Attorney for Plaintiff,
McShane & Hitchings, LLC, do hereby certify that I served a true and correct copy of
the attached Praecipe to Satisfy Judgment by Hand Delivery:
George Seidle
813 Wertzville Road
Enola, PA 17025
Respectfully Submitted,
McShane & Hitchings, LLC
Harrisburg, Pennsylvania 17109
4717-657-3900
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES ACQUISITION XVI, LLC No. 06-1457
ASSIGNEE OF GREAT SENECA FINANCIAL CORP
ASSIGNEE OF FORWARD PROPERTIES
ASSIGNEE OF HOUSEHOLD
Plaintiff
VS CIVIL ACTION - LAW
WAYNE A MCDONOUGH
Defendant(s)
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
To the Prothonotary:
Kindly mark the attachment against the Garnishee, MEMBERS 1 ST FCU, discontinued, upon payment of your
costs only.
Respectfully Submitted,
Date:
Amy 'F`-Doyl 87062 / Daniel F. 1
Philip C. W holic 48 / D i R. allo&Ay #8732
Tonilyn M. Chippie 48 2 / Sarah E. Ehasz 486469
Robert N. Polas, Jr. #201259 / Bruce H. Cherkis #18837
Ronald S. Canter #94000 / Ronald M. Abramson #94266
Wolpoff & Abramson, L.L.P.
Attorneys in the Practice of Debt Collection
4660 Trindle Road, Suite 300
Camp Hill, PA 17011
Telephone: (717) 303-6700
Counsel for Plaintiff
W&A File No. 126431131
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