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HomeMy WebLinkAbout05-4820564 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., NO. Q j -- 1/A.20 ?? 'C' ? yy\ P.O. BOX 1651 ROCKVILLE, ND 20849-1651 Plaintiff Vs. DARLEE ANSEL Defendant(s) PRAECIPE FOR JUDGMENT Mr./Ms. Clerk: Please enter Judgment in favor of Plaintiff and against Defendant(s), DARLEE ANSEL and , pursuant to the District Justice Transcript. ( X ) Amount due $ 4643.97 Less credits $ TOTAL $ 4643.97 , plus interest and costs ( X ) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( X ) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. DATE: 9/uhf- Signature: AA ? //U/Zl 4 e". Amy F. Doyle # 0 2 Daniel F. Wol son /20617 Bruce H. Cher is #18837 Philip C. Warholic /86341 Ronald M. Abramson #94266 Ronald S. Canter #94000 Donald P. Shiffer x/89451 Andrew C. Spears #87737 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 NOW, 200S , JUDGMENT IS rERED AS AB Prothonotary .j CiV 1 Division Deputy PRAEDJ/PANOJ W&A FILE NO. 129134300 ,-OMMONWEALTH OF PENNSYLVANIA COUNTY OF: Mao. Dist. No.: 09-3-04 MDJ Name. Ron. THOMAS A. PLACEY Add,ees> 104 8 SPORTING HILL RD MECHANICSBURG, PA Telephone (717) 761-8230„, 17050 GREAT SENECA FINANCIAL CORP. 267 EAST MARKET ST. C/O WOLPOFF do ABRAMSON YORK, PA 17403 x 7-/mil-mss' NOTICE OFCJIVICL CASE /TRANSCRIPT PLAINTIFF: NAMEand ADDRESS FGREAT SENECA FINANCIAL CORP. 267 EAST MARKET ST. C/O WOLPOFF & ABRAMSON LYORK, PA 17403 J VS. DEFENDANT NAME and ADDRESS 5ANSEL, DARLEE C 65 SILVER CROWN DR MECHANICSBURG, PA 17050 L J Docket No.: CV-0000126-05 Date Filed: 3/14/05 THIS IS TO NOTIFY YOU THAT: __ T441fiT_T .7TR1aYl[AATP D 'L'F ® Judgment was entered for: (Name) aRRST -gymmeem 1rrv'vnrar, nORP ® Judgment was entered against: (Name) Msgr. __DARLRK r in the amount of $ A - 6sa _ 07 on: (Date of Judgment) 6/DQJn5 ? Defendants are jointly and severally liable. (Date & Time) ?' Damages will be assessed on: This case dismissed without prejudice. Amount of Judgment Subject to ? Attachment/42 Pa.C.S. § 8127 $ Portion of Judgment for physical damages arising out of residential lease $ ANY PARTY - PPEAL'gV' A. NOTICE MUST INCLUDE ACOPY bF THIS NOTICE OF JUDGMENTfMANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE. PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT 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. k x dj.. Date Magisterial District Judge, ` I certify that this is a true a` - orrect copy of t e cord of ceedmgs containing the fudgment: b 06 Date Magisterial District Judge My commission expires first Monday of January, 2010 . AOPC 315-05 DATE PRINTED: 6109105 9:55:38 AM 7 Amount of Judgment $ 4,503.4 Judgment Costs $ 140.50 Interest on Judgment $ ;00 0 Attorney Fees $ .0 7 Total $ 4,643.9 Post Judgment Credits $ Post Judgment CostsF $ Certified Judgment Total $ SEAL CAq 3U 300 7' t- d o c a 562 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., No. DD -4IQ V t. P.O. Box 1651 ROCKVILLE, MD 20849-1651 Plaintiff VS. CIVIL ACTION - LAW DARLEE ANSEL Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OFiXOM n t yY1, ?/jaY"L' ,The undersigned counsel, being duly sworn according to law, depose and say that'am_ he Attorney for the Plaintiff in the above-captioned matter, and that to _ &he burst of'my knowledge, information and belief Defendant, ^I%RLFZ ANSEL- above-named, is over 21 years of age; is last Aknown;to reside at 65 SILVER CROWN DR MECHANICSBURG PA 17050-1638 MF (ount°y of CUMBERLAND Pennsylvania; is not in the military service of tie U)ited-States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act and its Amendments. Amy . Doyle r#87062Doyl r#87062 Daniel F. Wo son #20617 Bruce H. Che is #18837 Philip C. Warholic #86341 Ronald M. Abramson #94266 COMMONWEALTH OF PENNSYLVAMA Ronald S. Canter #94000 Notarial Seal Donald P. Shif.fer #89451 Dina A. Sweitzer, Notary Public Hampden Twp., Cumberland County Andrew C. Spears #87737 My Commission Expires Apr. 16, 2008 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 ( 17) 303-67 (1 SWORN and SUBSCRIBED to before me this day ot? j? 20 J DNo ry Public PNMAFF/PAN07 W&A FILE NO. 129134300 a ? K ETI[tS "Q G% ( ? -i 563 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., No. (?S -??2-0 (tUL???L?y? P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff Vs. CIVIL ACTION - LAW DARLEE ANSEL Defendant(s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: GREAT SENECA FINANCIAL CORP., A:. MARYLAND CORPORATION, ASSIGNEE OF COLLINS FINANCIAL r, SERVICES, ASSIGNEE OF DIRECT MERCHANTS BANK, N.A. P.O. BOX 1651 ROCKVILLE, MD 20849-1651 and certify that the last known address of the within Defendant(s) is: DARLEE ANSEL 65 SILVER CROWN DR MECHANICSBURG PA 17050-1638 Cheis #18837 Philip C. Warholic #86341 Ronald M. Abramson #94266 Ronald S. Canter #94000 Donald P. Shiffer #89451 Andrew C. Spears #87737 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Pr actice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 L'? Amy #87062 Doyler Dan i eF.l F. Wo son //20617 Bruce H. f PCRES/PANOS W&A FILE NO. 129134300 o cra f ?S cn l nC_ co O ?m T O?` 561 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., NO. UU S -Tab P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff VS. DARLEE ANSEL 65 SILVER CROWN DR MECHANICSBURG PA 17050-1638 Defendant(s) • CIVIL ACTION - LAW NOTICE OF ORDER, DECREE OR JUDGMENT TO: DARLEE ANSEL 65 SILVER CROWN DR MECHANICSBURG PA 17050-1638 You are hereby notified to it the following ORDER, DECREE or JUDGMENT has been entered against you on -Izv) in accordance with the provisions of Pa. R.C.P. 236. ( ) Decree Nisi in Equity ( ) Final Decree in Equity ( ) Judgment of ( ) Confession ( ) Verdict ( ) Default ( ) Non-suit ( ) Non-pros ( ) Arbitration Award ( ) Judgment is in the amount of $ plus costs. ( X ) District Justice transcript of judgment in civil action in the amount of $ 4643.97 , plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Pennsylvania De artment of Transportation. , By: Pr hon If you have any questions regarding this Notice, please contact the filing party. P Amy F. DSyle 11 x/87062 / Daniel F.'Wolfson x/20617 Bruce H. Cherkis #18837 / Philip C. Warholic x/86341 Ronald S. Canter #94000 / Ronald M. Abramson #94266 Donald P. Shiffer /89451 / Andrew C. Spears /87737 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 / (717) 303-6700 (This Notice is given in accordance with Pa. R.C.P. 236.) DJNTC/PANOJ W&A FILE NO. 129134300 3253 ` PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF COLLINS FINANCIAL SERVICES, ASSIGNEE OF DIRECT MERCHANTS BANK, N.A. P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. JUDGMENT NO. 054820 DARLEE ANSEL 65 SILVER CROWN DR MECHANICSBURG PA 17050-1638 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Defendant (s) To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, (1) Directed to the Sheriff of CUMBERLAND COUNTY, Pennsylvania; (2) against, DARLEE ANSEL 65 SILVER CROWN DR MECHANICSBURG PA 17050-1638 , Defendant(s); (3) and against, FULTON BANK 360 CUMBERLAND PKWY MECHANICSBURG PA 17055-567 Garnishee(s); (4) and index this writ (a) against, DARLEE ANSEL Defendant(s) and (b) against, FULTON BANK Garnishee(s), as a lis pendens against the real property of the Defendant(s) in the name of the Garnishe`e(s) as follows: (Specifically describe property) 65 SILVER CROWN DR MECHANICSBURG PA 17050-1638 All personal property of any nature located within the household or immediate vicinity of the Defendant(s) address and all other personal property within the dominion and control of the Defendant(s) wherever it is located shall be subject to the levy. ALSO: You are directed to attach the property of the Defendant(s) not levied upon in the possession of FULTON BANK 360 CUMBERLAND PKWY MECHANICSBURG PA 17055-567 , Garnishee (s) All accounts including all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes. Amount due $ 4643.97 Interest from 06/09/2005 To Be Determined At an interest rate of 6% per year Total $ 4643.97 Plus costs & interest Dated: 12bd C-1- Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / David R. Galloway #87326 / Tonilyn M. Chippi!e8W2 Ronald M. Abramson #94266 / Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 / (717) 303-6700 t C 1 ? Y -7?? 1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF COLLINS FINANCIAL SERVICES, ASSIGNEE OF DIRECT MERCHANTS BANK, N.A., Plaintiff (s) From DARLEE ANSEL, 65 SILVER CROWN DR., MECHANICSBURG, PA 17050-1638 (1) You are directed to levy upon the property of the defendant (s)and to sell 65 SILVER CROWN NO 05-4820 Civil CIVIL ACTION - LAW DR., MECHANICSBURG, PA 17050-1638, ALL PERSONAL PROPERTY OF ANY NATURE LOCATED WITHIN THE HOUSEHOLD OR IMMEDIATE VICINITY OF THE DEFENDANT(S) ADDRESS AND ALL OTHER PERSONAL PROPERTY WITHIN THE DOMINION AND CONTROL OF THE DEFENDANT(S) WHEREVER IT IS LOCATED SHALL BE SUBJECT TO THE LEVY . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of FULTON BANK, 360 CUMBERLAND PKWY, MECHANICSBURG, PA 17055-567 -- ALL ACCOUNTS INCLUDING ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. 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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4643.97 L.L. $.50 Interest FROM 6/9/05 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Atty Paid $37.25 Plaintiff Paid Date: AUGUST 1, 2006 (Seal) REQUESTING PARTY: Name ANDREW C. SPEARS, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonot By: Deputy 4660 TRINDLE ROAD, 3" FLOOR CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87737 DARLEE C. ANSEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW TED W. ANSEL, Defendant NO. 95-6520 CIVIL TERM GREAT SENECA IN THE COURT OF COMMON PLEAS OF FINANCIAL CORP., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION - LAW DARLEE ANSEL, / Defendant NO. 05-4820 CIVIL TERM ORDER OF COURT AND NOW, this 17th day of October, 2006, upon consideration of the attached "petition," and the contents thereof being unintelligible, the petition is denied to the extent that it seeks action by the court. BY THE COURT, Darlee C. Ansel 65 Silver Crown Drive Mechanicsburg, PA 17050 Plaintiff, pro Se i V,NYAIASN;N3d ? Z :1 l wv 81 130 9coz K J.o,N? ; ; 03 3Hl AO f Ted W. Ansel 139 Sample Bridge Road Mechanicsburg, PA 17050 Defendant, pro Se Andrew Spears, Esq. 4660 Trindle Road Third Floor Camp Hill, PA 17050 Attorney for Great Seneca Financial Corp. :rc IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP Plaintiff NO. 054820 VS. DARLEE ANSEL Defendant CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, Fulton Bank, discontinued, upon payment of your costs only. Respectfully Submitted, Dated: Amy F. Doyle #87062 Daniel F. Wolfson #20617 Philip C. Warholic #86341 Andrew C. Spears #87737 David R. Galloway #87326 Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 Ronald M. Abramson #94266 Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., Suite 300 Camp Hill, PA 17011 (717) 303-6700 W&A File No. 129134300 W -a \).) J CZ) SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-04820 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GREAT SENECA FINANCIAL CORP VS ANSEL DARLEE And now DOUGLAS RUZANSKI ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0013:24 Hours, on the 16th day of August , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT ANSEL DARLEE hands, possession, or control of the within named Garnishee FULTON BANK 360 CUMBERLAND PARKWAY MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to LESLIE GAUS (HEAD TELLER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her in the true and made Sheriff's Costs: So Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 L 00 V, jo/10joG 10/05/2006 Sworn and Subscribed to before me this day of A.D By j Z, TDeputy Sheriff PC 440 ti, R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Advance Costs: .150.00 Sheriff's Costs 130.22 Docketing 18.00 19.78 Poundage 2.56 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 07/17/07 Mileage 17.60 Misc. Surcharge 40.00 Levy 40.00 Post Pone Sale Certified Mail Postage 1.56 Garnishee 9.00 TOTAL 130.22 7)14 lp-7 CI So Answers;? r2! as K?li`n?e_, S eriff By Lt,t.(.?-v?Z'l -)0 0 U\ s a Ck 5 9ye, If PL, /1-5 16 9 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4820 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF COLLINS FINANCIAL SERVICES, ASSIGNEE OF DIRECT MERCHANTS BANK, N.A., Plaintiff (s) From DARLEE ANSEL, 65 SILVER CROWN DR., MECHANICSBURG, PA 17050-1638 (1) You are directed to levy upon the property of the defendant (s)and to sell 65 SILVER CROWN DR., MECHANICSBURG, PA 17050-1638, ALL PERSONAL PROPERTY OF ANY NATURE LOCATED WITHIN THE HOUSEHOLD OR IMMEDIATE VICINITY OF THE DEFENDANT(S) ADDRESS AND ALL OTHER PERSONAL PROPERTY WITHIN THE DOMINION AND CONTROL OF THE DEFENDANT(S) WHEREVER IT IS LOCATED SHALL BE SUBJECT TO THE LEVY . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of FULTON BANK, 360 CUMBERLAND PKWY, MECHANICSBURG, PA 17055-567 - ALL ACCOUNTS INCLUDING ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. 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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4643.97 L.L. $.50 Interest FROM 6/9/05 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Due Prothy $1.00 Atty Paid $37.25 Other Costs Plaintiff Paid Date: AUGUST 1, 2006 CURTIS R. LONG Prothonotar (Seal) Deputy REQUESTING PARTY: Name ANDREW C. SPEARS, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, 3RD FLOOR COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., • = say Plaintiff : No. 2005-04820 rm ° fu'1 =xt -4 X43 • ,r' I VS. -a.: -�r `1- •. CIVIL ACTION 'ems' c:�rt DARLEE ANSEL, : v :' Defendant : ; -< PRAECIPE FOR ENTRY OF APPEARANCE TO THE CLERK OF SAID COURT: Kindly enter my appearance on behalf of the Plaintiff in the above captioned matter. Date: October 7, 2013 By: Al. . ' . ege, Esquire V Atty. I.D. #81288 Attorney for Plaint'' P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C") GREAT SENECA FINANCIAL CORP., : Plaintiff : No. 2005-04820 rn m rn _ � A © off; vs. • �--%�., —4 C: CIVIL ACTION A cam ' DARLEE ANSEL, ° Defendant • PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO INTERROGATORIES IN AID OF EXECUTION And now comes Plaintiff and submits the instant Motion to Compel, and in support thereof avers as follows: 1. Judgment for Plaintiff and against Defendant in the sum of$4,643.97 plus costs was entered in Cumberland County on September 16, 2005. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on October 7, 2013. 3. Pursuant to Pa.R.C.P. 4006 (a) (2), Defendant's responses to the Interrogatories were due within thirty days after they had been served, but none has been received as of the date of giving notice herein. 4. Counsel for Plaintiff has made a good faith effort to confer with Defendant, but Defendant has still failed to reply. 5. A copy of this Motion and proposed Order were mailed to Defendant, via first class mail on February 7, 2014. A certificate of Service is attached hereto. 6. As of February 7, 2014, Plaintiff has not received answers to the Interrogatories. 7. Plaintiff requires an Order pursuant to Pa.R.C.P. 4019 (a) (1) (I), compelling the Defendants to answer the Interrogatories. 8. No Judge has ruled upon other issues in this matter. 9. Concurrence with the Pro Se Defendant has been sought and no response received. A copy of our January 9, 2014 letter to Defendant is attached hereto as Exhibit"A". WHEREFORE, Plaintiff, requests that this Honorable Court grant its motion and enter an Order directing the Defendant to answer Plaintiff's Interrogatories within twenty(20) days or risk sanctions, pay fees in the amount of$100.00, as well as such other and further relief as the Court may deem just and appropriate. ' . Mege, Esq. Attorney ID No. : 288 Attorney for P .intiffs P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 -2- LAW OFFICES OF ALAN R. MEGE, ESQ. P.O. BOX 1426 70 EAST BROAD STREET BETHLEHEM, PA 18016-1426 Licensed in PA and NJ (610) 954-5393 Todd A. Johns, Esq. Of Counsel (610) 954-5395 FAX AlanM_Esq @juno.com January 9, 2014 Darlee Ansel 65 Silver Crown Dr. Mechanicsburg. PA 17050 RE: Great Seneca Financial Corp v. Ansel #2005-04820 Dear Ms. Ansel: Our office intends to file a Motion to Compel Defendant's answers to Plaintiff's Discovery In Aid of Execution. Please notify our office of your disposition concerning same by January 24, 2014. If we do not hear from you by this time we will assume your concurrance. I appreciate your assistance in bringing this matter to an amicable conclusion. Should you have any questions or comments, please feel free to contact my office. Very truly yours, Alan R. Mege ARM/llp LE COPY This message is from a debt collector, this is an attempt to collect a debt, and any information obtained will be used for that purpose. � X1^-' b` --f- c• � � t COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : Plaintiff : No. 2005-04820 • vs. : CIVIL ACTION DARLEE ANSEL, • Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on February 7, 2014, I served a true correct copy of Plaintiffs Motion to Compel Defendant's Answers to Interrogatories in Aid of Execution and proposed Order by mailing same, first class, postage prepaid to: Darlee Ansel, 65 Silver Crown Dr., Mechanicsburg. PA 17050. By: . R. Mege, Esquire Atty. I.D. #81288 Attorney for Plai 'ff P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 GREAT SENECA FINANCIAL CORP. : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSXLVANIA-_:. -aa � t V. • (c -.1 .. t n� _ DARLEE ANSEL, -.0> co c DEFENDANT : NO. 05-4820 CIVIL ORDER OF COURT AND NOW, this 0.-day of February, 2014, upon consideration of the Plainti 's —.. Motion to Compel Defendant's Answers to Interrogatories In Aid of Execution; IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule shall issue upon Darlee Ansel to show cause why the relief requested by the Plaintiff should not be granted; 2. Darlee Ansel shall file an Answer to the Petition on or before February 28, 2014; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. 4. Should the Defendant file an Answer, the Court will determine the necessity for hearing and/or oral argument. By the Court, 41\j‘i\\. M. L. Ebert, Jr., J. ✓ ■lan R. Mege, Esquire Attorney for Plaintiff 'rlee Ansel Defendant bas ef.S ila1i, , ape/pi �. � -77 cm -� CD GREAT SENECA FINANCIAL CORP. IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSIRVAr�IA Car DARLEE ANSEL, DEFENDANT NO. 05-4820 CIVIL �c-7 -C c)-rt ORDER OF COURT AND NOW, this W ay of February, 2014, upon consideration of the Plaintiff's Motion to Compel Defendant's Answers to Interrogatories In Aid of Execution; IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule shall issue upon Darlee Ansel to show cause why the relief requested by the Plaintiff should not be granted; 2. Darlee Ansel shall file an Answer to the Petition on or before February 28, 2014, 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Petitioner shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. 4. Should the Defendant file an Answer, the Court will determine the necessity for hearing and/or oral argument. By the Court, I 4k M. L. Ebert, Jr., J. Alan R. Mege, Esquire Attorney for Plaintiff Darlee Ansel Defendant bas COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION S • Defendant GREAT SENECA FINANCIAL CORP., : Plaintiff : No. 2005 -04820 vs. DARLEE ANSEL, PLAINTIFF'S MOTION FOR NEW RULE RETURNABLE DATE And now comes Plaintiff and submits the instant Motion for New Rule Returnable Date, and in support thereof avers as follows:: 1. Plaintiff is a judgment creditor of the Defendant in the above matter. 2. On February 11, 2014, Plaintiff filed a Motion to Compel. 3. An Order dated February 18, 2014, issuing a Rule Returnable date of February 28, 2014, was to be served on Defendant. 4. Plaintiff has not been able make timely service upon Defendant due to a fire in Attorney for Plaintiff's office February 9, 2014 which displaced same for three (3) weeks. 5. Plaintiff is respectfully requesting a new rule returnable date to allow timely service upon Defendant. 6. A copy of this Motion and proposed Order was mailed to Defendant, via first class mail on March 7, 2014. A certificate of service is attached hereto. WHEREFORE, Plaintiff respectfully request that the Court issue a new Rule Returnable Date with regard to Plaintiff's Motion to Compel. Alan R. Mege, Esq. Attorney ID No. 288 Attorney for Plaintiff PO Box 1426 Bethlehem, PA 18016 -1426 (610) 954 -5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA c GREAT SENECA FINANCIAL CORP.,: Plaintiff : No. 2005-04820 VS. DARLEE ANSEL, Defendant : CIVIL ACTION IN RE: PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO INTERROGATORIES IN AID OF EXECUTION ORDER AND NOW, this I '1 day of M , 2014, upon consideration of Plaintiff s Motion for New Rule Return Date, a RULE is issued upon Defendant to show cause why an order compelling Defendant to respond to the Interrogatories in Aid of Execution should not be issued. PLAINTIFF shall effectuate service of this Order upon Defendant. A motion to make this Rule absolute will not be entertained until proof of service is filed. RULE RETURNABLE twenty (20) days from the date of service by Plaintiff. BY THE COURT, Distribution: R. Mege, P.O. Box 1426, Bethlehem, PA 18016 „....--flarlee Ansel, 65 Silver Crown Dr., Mechanicsburg, PA 17050 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : Plaintiff : No. 2005 -04820 Vs. DARLEE ANSEL, : CIVIL ACTION Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on March 17, 2014, I served a true correct copy of this Court's March 14 Order stating a Rule Return date by mailing same, first class, postage prepaid to: Darlee Ansel, 65 Silver Crown Dr., Mechanicsburg, PA 17050 . By: Alan R. Mege, Es. • ire Atty. I.D. #8128. Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 181016 -1426 (610) 954 -5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., Plaintiff : No. 2005 -04820 rr :1a VS. CN i",.. : CIVIL ACTION ANSEL, W' Defendant • C7▪ . PLAINTIFF'S MOTION TO MAKE THE RULE ABSOLUTE And now comes Plaintiff and submits the instant Motion to Make The Rule Absolute, and in support thereof, avers as follows: 1. On March 14, 2014, a Rule was issued upon the Defendant, Darlee Ansel, to show cause why Plaintiff's Motion to Compel should not be granted. A copy of the Order is attach hereto as Exhibit "A ". 2. The March 14, 2014, Rule was served upon Defendant on March 17, 2014. A Certificate of Service is attached hereto as Exhibit "B ". 3.. The Rule Returnable was to be answered by April 6, 2014 in the Office of the Cumberland County Prothonotary. As of April 14, 2014, no answer has been filed. 4. A copy of this Motion and proposed Order were mailed to Defendant, via first class mail on April 14, 2014. A certificate of Service is attached hereto. 5. Plaintiff requests that the Rule be made Absolute. WHEREFORE, Plaintiff, requests that this Honorable Court grant its motion and enter an Order directing the Defendants to answer Plaintiff's Interrogatories within twenty (20) days or risk sanctions, pay fees in the amount of $100, as well as such other and further relief as the Court may deem just and appropriate. Alan R. Mege, Esq. Attorney ID No. 8) 88 Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C) C. L.,-r; 1 7 r -<> .r. C vS. {e ^- ^,, : CIVIL ACTION v -, c. 1 GREAT SENECA FINANCIAL CORP., : Plaintiff : No. 2005 -04820 DARLEE ANSEL, Defendant IN RE: PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO INTERROGATORIES IN AID OF EXECUTION ORDER INA a e , 2014, upon consideration of Plaintiffs to AND NOW, this 11'1 day of Motion for New Rule Return Date, a RULE is issued upon Defendant to show cause why an order compelling Defendant to respond to the Interrogatories in Aid of Execution should not be issued. PLAINTIFF shall effectuate service of this Order upon Defendant. A motion to make this Rule absolute will not be entertained until proof of service is filed. RULE RETURNABLE twenty (20) days from the date of service by Plaintiff. BY THE COURT, Distribution: Alan R. Mege, P.O. Box 1426, Bethlehem.8(��6--'"Yr Darlee Ansel, 65 Silver Crown Dr., Mechanicsburg, PAR1r:700V 1-.t) 1AR 1 7 2014 L a Afar N1e ^ -e n Oir ,ce. ei.,Itibt+ It COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 47) N-3 C: 5 CO GREAT SENECA FINANCIAL CORP., — 1 Plaintiff : No. 2005-04820 7:0 (- tf) o CIVIL ACTION DARLEE ANSEL, r:9 Defendant cft, CERTIFICATE, OF SERVICE 1, Alan R. Mege, Esquire, hereby certify that on March 17, 2014, 1 served a true correct copy of this Court's March 14 Order stating a Rule Return date by mailing same, first class, postage prepaid to: Darlee Ansel, 65 Silver Crown Dr., Mechanicsburg, PA I 7050 . -Th TC1 4 • By: Alan R. Mege, Esql:tire Atty. I.D. #81288' Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 1810161426 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : Plaintiff : No. 2005 -04820 vs. DARLEE ANSEL, Defendant : CIVIL ACTION CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on April 14, 2014, I served Plaintiff's Motion to Make the Rule Absolute mailing same, first class, post prepaid to: Darlee Ansel, 65 Silver Crown Dr., Mechanicsburg, PA 17050. By: . Mege, Esquire Atty. I.D. #81288 Attorney for Plainti P.O. Box 1426 Bethlehem, PA 18016 (610) 954 -5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : Plaintiff : No. 2005 -04820 cZ) VS. = = -r:- : CIVIL ACTION -<v r Defendant r° AE` ORDER --< AND NOW, this A 9ity of A090.4 L , 2014, upon consideration of DARLEE ANSEL, Plaintiff's Motion to Compel, and Defendant's response thereto, if any, it is hereby ORDERED that the Rule issued on March 14, 2014, is hereby made absolute and Plaintiff's Motion is GRANTED; IT IS FURTHER ORDERED that Defendant must make full and complete answers to the Interrogatories and Production of Documents, without objection or motion for protective order, within twenty (20) days of the date of this Order or appropriate sanctions will be imposed upon Defendant following application to this Court. se ees o it 0'. 6 G" . ., ; = c on _ _ - pose. upon 1 e en ant o owing app ication to t is Court. , Judge Distribution: �A�lan R. Mege, Esquire, PO Box 1426, Bethlehem, PA 18016 -1426 Darlee Ansel, 65 Silver Croym Dr., Mechanicsburg, PA 17050 Cop .fs /n.t •Y%