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HomeMy WebLinkAbout05-5825 ~V./~.J~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CuJ lULYVL GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF FORWARD PROPERTIES ASSIGNEE OF METRIS P.O. BOX 1651 ROCKVILLE, MD 20849-1651 NO. () ~ - S'P 02..5 Plaintiff VS. CIVIL ACTION - LAW BRENDA YOHE 802 RITNER HWY SHIPPENSBURG PA 17257-9550 Defendant (5) NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. NOTICIA Le han demandado a used en la corte. 5i used quarere defensas de esas demandas expuestas en 1as paginas, siguientes, used tiene viente (20) dias de plazo a1 partir de 1a fecha de 1ademanda y 1a notifiation. Used debe presentar una apariencia escrita 0 en persona opor abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones a last demandas en carta de su persona. Sea avisado que si used no se defienda, la corte tomara medidas y psedido entrar una orden contra used sin previa aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en 1a peticion de demanda. Used puede perder diner 0 0 sus propledades 0 otros derechos importantes para used. LLEVE ESTA DEMANDA A UN ABODOAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSITANCIA LEGAL. Lawyer Referral Service Cumberland County Bar Assn. 32 S. Bedford St. Carlisle 800-990-9108 PA 17013 CVRNOT/PARET W&A FILE NO. 124335619 ......./.....JV IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF FORWARD PROPERTIES ASSIGNEE OF METRIS P.O. BOX 1651 ROCKVILLE, MD 20849-1651 ... NO. t).y'- S r:l.., Plaintiff VS. CIVIL ACTION - LAW BRENDA YOHE 802 RITNER HWY SHIPPENSBURG PA 17257-9550 Defendant (s) COMPLAINT Now comes the Plaintiff, GREAT SENECA FINANCIAL CORP., , by and through its attorneys, and the law firm of Wo1poff & Abramson, L.L.P., and files this Complaint and in support avers as follows: 1. Plaintiff, GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF FORWARD PROPERTIES ASSIGNEE OF METRIS P.O. BOX 1651 ROCKVILLE, MD 20849-1651 is a business entity doing business within the Commonwealth of Pennsylvania and the other states of the United States. 2. Defendant, BRENDA YOHE a last known address of , is an adult individual with 802 RITNER HWY SHIPPENSBURG PA 17257-9550 COUNTY OF CUMBERLAND 3. It is averred that Defendant(s) was/were issued an open end credit card account. 4. At all relevant times material hereto, Defendant(s) has/have used said charge card for the purchase of products, goods and/or for obtaining services. CCPNRI/PARET W&A FILE NO. 124335619 .LU7L.'"tV 5. Plaintiff provided Defendant(s) with copies of the Statements of Account showing all debits and credits for transactions on the aforementioned credit card account to which there was no bona fide objection by Defendant(s). A true and correct copy of the Statement of Account is attached hereto, incorporated herein, and marked as Exhibit "A". 6. As of the date of this Complaint, the remaining balance due, ow,ng and unpaid on Defendant's credit card account as a result of the charges made by said Defendant(s) and/or any authorized users is the sum of $ 8745.48. 7. Pursuant to the applicable Pennsylvania law, any unpaid or delinquent balances on said account shall continue to bear interest at the rate of 18%. 8. As of the date of the filing of this Complaint, the amount of interest which has accrued is the sum of $ 1940.78. 9. refused account Despite reasonable and repeated demands for payment, Defendant(s) has/have and continue to refuse to pay all sums due and owing on the aforementioned balance, all to the damage and detriment of the Plaintiff. 10. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment ,n favor of the Plaintiff and against Defendant(s) in the amount of $ 8745.48, plus interest in the amount of $ 1940.78, plus costs of this action and any other relief as this Court deems just and reasonable. Respectfully submitted, >-.. ------- 1187062 / {/86341 / 1187326 / 1194266 / 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 Y F. Doy Philip C. Warholic David R. Galloway Ronald M. Abramson Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter /120617 {187737 1187852 1194000 CPNRI2/PARET W&A FILE NO. 124335619 ......./Lo" ATTORNEY VERIFICATION I hereby state that I am the attorney for the Plaintiff, who is located outside of this jurisdiction and in order to file the within document in an expedient and timely manner, am authorized to take this verification on behalf of said Plaintiff in this action and verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date:fC/;..,tloo :!~c;lt Philip C. Warholic #86341 / David R. Galloway #87326 1 Ronald M. Abramson #94266 / 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 (71 7) 303-6700 ~ ~ Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1120617 1187737 1187852 1194000 PAVERF/PARET W&A FILE NO. 124335619 189236 . EXHIBIT "A" J...J..J71 l11!bl ACCOUNT NUMBER GREAT SENECA 5123003035087795 FINANCIAL CORPORATION BRENDA YOHE I NEW BALANCE I 802 RITNER HWY $ 8745.48 SHIPPENSBURG PA 17257-9550 IF ADDRESS AS SHOWN ABOVE IS INCORRECT, PLEASE INDICATE CHANGE BELOW: PAYMENT DUE DATE MINIMUM PAYMENT NAME DUE NOW $ 8745.48 ADDRESS PLEASE WRITE IN AMOUNT OF PAYMENT ENCLOSED $ --- ---- ---- -- ---- --------- --- -------- _u -- u_ -- u u u --- --- --- ----- ---- ------ ---- ----- u_ I PLEASE DEl ACH AND RETURN TOP PORTION WITH YOUR PAYMENT I ACCOUNT NUMBER CREDIT LIMIT CREDIT AVAILABLE PAST DUE STATEMENT CLOSING DATE 5123003035087795 0 0 $ 8745.48 07/20/05 DATE REFERENCE NUMBER NEW TRANSACTIONS AMOUNT 07/20/05 BALANCE DUE 06/30/04 $ 8745.48 GREAT SENECA FINANCIAL CORPORATION A MARYLAND CORPORATION ASSIGNEE OF METRIS COMPANY INCORPORATE P.O. BOX 1651 ROCKVILLE MD 20849-1651 PREVIOUS BALANCE PAYMENTS AND CREDITS NEW BALANCE SUMMARY OF TRANSACTIONS $ 8745.48 PROMPT CREDITING OF PA'i'MENT$: TO RECEIVE CREDIT FOR PAYMENTS AS OF THE DATE PAYMENT DUE DATE MINIMUM PAYMENT OF RECEIPT, WE MUST RECEIVE THE TOP PORTION OF THE STATEMENT AND YOUR CHECK OR $ 8745.48 MONEY ORDER BY 3:00 P,M_ AT: DUE NOW GREAT SENECA FINANCIAL CORPORATION P.O. BOX 1651 SEND INQUIRIES TO: ROCKVlLLE, MD 20849 PAYMENTS RECEIVED AT THE ABOVE AOORESS IN T\-IE MANNER SPECIFIED AFTER THAT TIME GREAT SENECA FINANCIAL CORPORATION Will BE CREDITED TO YOUR ACCOUNT AS OF OUR NEXT BUSINESS DAY. THE CREDITING TO P.O. BOX 1651 YOUR ACCOUNT OF PAYMENTS RECEIVED AT ANY LOCATION OTHER THAN THE ABOVE ROCKVlLLE, MD 20849 ADDRESS MAY BE DElAYED UP TO 5 DAYS FROM DATE OF RECEIPT. GSENBL(03!l8/<Xlj GSENBL/BILLS2 124335619 N ~ ........ ~ 0. ~ -- --....j 0-IA. r- V( \\trt tI1 -l;J\)' f~ ~~ +- ~ (~? r-' zg J' -.;."'; .(,::.:~ ~~',- 1 CO ,) R, --' -C-n. f~..~} s:; ~., C,__ .:~ ,-) y:-.;:., Q -t"'! -~ i =- ',--~~ (-~~) ~--)cn '--\ -7~ C> ~'1 .-..-',- SHERIFF'S RETURN - REGULAR CASE NO: 2005-05825 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GREAT SENECA FINANCIAL CORP VS YOHE BRENDA MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon YOHE BRENDA the DEFENDANT , at 1952:00 HOURS, on the 18th day of November, 2005 at 375 NEFF STREET SHIPPENSBURG, PA 17257-9550 by handing to BRENDA YOHE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 20.16 .00 10.00 .00 48.16 ?"'~~~~< <~ " R. Thomas Kline me this }Af day of 11/21/2005 WOLPOFF & ABRAMS.oN ~ BY~?~/'" Deputy Sheriff , Sworn and Subscribed to before A.D. 1217 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF FORWARD PROPERTIES ASSIGNEE OF METRIS P.O. BOX 1651 ROCKVILLE, MD 20849-1651 NO. 200505825 Plaintiff vs. BRENDA YOHE Defendant (s) PRAECIPE FOR JUDGMENT Mr./Ms. Clerk: Please BRENDA YOHE for want of enter Judgment in favor of Plaintiff and against Defendant(s), and ANSWER TO COMPLAINT. ( X ) Amount due $ Interest $ Attorney's Commission $ Filing costs $ TOTAL $ 10686.26 , plus interest ( X) I certify that the foregoing assessment of damages amounts alleged to be due in the complaint and is calculable as 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. ( X) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. 8745.48 1940.78 and costs is for specified a sum certain from 1187062 / 86341 / 118732 ~/ 266 / 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 2!? Phili aVId R. Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1120617 #87737 1187852 1194000 DATE: liB /c " ( Signature: NOW~~, ) :J ') , 2CV')(~ , JUDGMENT IS , TERED AS ABOV Protho . 11 ivision By: De ut 121 MAIN OFFICE TW'1IRVINGTON CENTRE 7ol'klNG FARM BLVD., ROCKVllLE, MD 20850 REGIONAL OFRCES 10605 JUDICIAL DR" BLDG., A-5, FAIRFAX, VA 22030 1108 E. MAIN ST,I, STE. 1003, RICHMOND, VA 23216 5122 GREENWICH RD., VIRGINIA BEACH, VA 23462 9.19 N. MARKET ST., ST~. 1300, WILMINGTON, DE i9SQ9 1 VALLEY BANK BLDG., BOX 1226, CLAAKS~URG, \IN 26302 4660 TAINDLE ROAD, 3AD FLOOR, CAMP HILL. PA 17011 26632 ROADSIDE DRIVE. STE. 265. AGOUAA HILlS. CA 91301 .. 39500 HIGH POINTE BLVD"STE. 250. NOVI. M148375 ~OO CANAL'vIEW BLVD" ROCHESTER. NY 14623 5216 NORTH O'CONNOR BLVD.. lAVING, TX 75039" 180 GLASTONBUAY BLVO" GLASTONBURY, CT 06033 210 INTERSTATE NORTH PKWY., ATLANTA, GA 30339 301 CARLSON PKWY.. STE. 303, MINNETONKA, MN 55305 LAW OFFICES W 0 L P 0 F F lit A BRA M SON, L. L. P. Attorna ys in the Practice of Debt Collection (A National Collection Attorney Network Firm) 4660 TRINDLE ROAD ' 3RD FLOOR CAMP HILL. PA 17011 717-303-6700 OUTSIDE CAMP HILL METROPOLITAN AREA (TOLL FREE) 1-8()(}'321.8467 FACSIMILE (717) 737-9051 PLEASE DIRECT ALL INQUIRIES TO CAMP HILL OFFICE DECEMBER 12, 2005 124335619 BRENDA YOHE 802 RITNER HWY SHI/,PENSBURG PA 17257-9550 NATIONAL COLLECTION ATTORNEY NElWORK AFFILIATED ARM LOCATIONS [NOT REGIO~ OFFICES OF WOLPOFI''' ABRAMSO~ LLP.~ BIRMINGlAM. ALABAMA CEDAA 0llS. eN J~EV ANCHORAGE, ALASKA RALEIGH. NOR1li CAROUNA PHOENIX. ARIZONA FAAOC. NORTH DAKOTA CABOT, AAKANSAS a..EV'EI.ANO. GiIO ENGLEWOOJ. COl.ORAOO CJKI..AHCMA CITY, OKLAHOMA FT. LAUDERDALE. Fl..OAIOA EUGENE. OFIEGON HONOLULU, HAWAII PROVIDENCE, AHOOE IsLAND BOISE. IDAHO COlUMBIA, SOUTH CAROUNA CHICAGO, IWNOIS I<NOXVIUE, TENNESSEE MERAILLVILLE.1NOIAHA SANOY, UTAH KANSAS CITY,ICANSAS MILWAUKEE, WISCONSI~ LEXINGTON. KENTUCKY RAWUNS, WYOMING METAIRIE, LOUISIANA ST. lOUIS, M1SSOJAI * 11Ie Ndona1 CoItectton GREAT FALLS,MQNTANA AtlDmeyNetwortl; lean OMAHA. NEBRASKA . efllllatlon oI...........w..... LAS VEGAS, NEVADA WSA How!! of Operation: MANCHESTER, NEW HAMPSHIRE 8 ..m. -11 p.m. E.S.T. M-F I W&A F;le No. 124335619 Re: GREAT SENECA FINANCIAL CORP., ASSIGNEE OF METRIS VS. BRENDA YOHE Docket No. 200505825 Dear BRENDA YOHE Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, Amy F. Doyle 87062 I Daniel F. Wolfson 1/2061: ~hi '. Warhol;" #86341 I Andrew C. Spears 1/87737 . a' R. Galloway 1/873U"-'" Tonilyn M. Chippie 1/87852 onald M. Abramson #94266 I Ronald S. Canter #9400 Bruce H. Cherkis # 18837 WOLPOFF & ABRAMSON, L.L.P. I Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle ,Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 Enclosure CC: BRENDA YOHE This is an attempt by a debt collector to collect a debt and any information obtained wi II be used for that purpose. NOT 1 OD/P ANOTC I TI'lHD111D1:>{U".~1 122 , . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL GORP" A MARYLAND CORPORATION, ASSIGNEE OF FORWARD PROPERTIES ASSIGNEE OF METRIS P.O. BOX 1651 ROCKVILLE, MD 20849-1651 NO. 200505825 . ' Plaintiff vs. I BRENDA YOHE Defendant (s) TO: BRENDA YOHE 802 RITNER HWY SHIPPENSBURG PA 17257-9550 DATE OF NOTICE: 1z{IZ!c5 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU FAILED TO TAKE THE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. .IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Assn. 32 S. Bedf~rd St. Carlisle 800-990-9108 PA 17013 By: Amy F. Doyle #87062 / Philip r W~rholic #86341 / ~vid R. Galloway 1187321>) / Ronald M. Abramson #94266 / Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt ~ollection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1120617 1187737 1187852 #94000 Tun"Tf"T'/D"a.u'\'rr I.JI.A 'EO'TTI<" MO l?LL'\~'\;;,lQ 1216 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF FORWARD PROPERTIES ASSIGNEE OF METRIS P.O. BOX 1651 ROCKVILLE, MD 20849-1651 No. 200505825 : Plaintiff vs. CIVIL ACTION - LAW BRENDA YOHE 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 FORWARD PROPERTIES ASSIGNEE OF METRIS P.O. BOX 1651 ROCKVILLE, MD 20849-1651 and certify that the last known address of the within Defendant(s) is: BRENDA YOHE 802 RITNER HWY SHIPPENSBURG PA 17257-9550 AmY~ ff87062 / Daniel F. Wolfson P 'lin r Warhelie IIRI\~ / Andrew C. Spears DIaV1d R. Galloway ff8732 / Tonilyn M. Chippie onald M. Abramson ~94266 / Ronald S. Canter Bruce H. Cherkis ff18837 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 1120617 1187737 1187852 1194000 PCRES/PANOJ W&A FILE NO. 124335619 1215 . IN THE COURT OF COMMON PLEAS OF CUKBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A KARYLAND CORPORATION, ASSIGNEE OF FORWARD PROPERTIES ASSIGNEE OF METRIS P.O. BOX 1651 ROCKVILLE, MD 20849-1651 No. 200505825 : Plaintiff vs. CIVIL ACTION - LAW BRENDA YOHE Defendant (s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUKBERLAND : The undersigned counsel, being duly sworn according to law, depose and say that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief Defendant, BRENDA YOHE , above-named, is over 21 years of age; is last known to reside at 802 RITNER HWY SHIPPENSBURG PA 17257-9550 County of CUMBERLAND , Pennsylvania: is not in the military service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act and its Amendments. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Kimberly l. E:is~nhauer, Notary Public Hampden Twp., Cumberland County My Commission Expires Nov. 17,2009 Member, Pennsylvania Association of Notaries ~ .""", I Philip C. W 86341 / av R. Galloway #873~1 Konald M. Abramson U94266 / 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 Daniel F. Wolfson Andrew C. Spears Toni1yn K. Chippie Ronald S. Canter 1120617 1187737 1187852 1194000 SWORN and SUBSCRIBED to before me this ~ day o~, 20~. tJu IV) /, Ii: ' ~[.l-lc0> u-''-- Qli'otiry PUbl~ PNMAFF/PANOT W&A FTIF. NO 124~~~~1_ '0 -;:.) () -1.9- :-:"> ...c ~ \\- ;< \\- \) -, 0 ~ ,'"j ~ c, - - ~ 0 , , , 1 VJ ..c , " ~ ' " 7-> 1j. " - >-> " . - ~- -------- 1218 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, NO. 200505825 Plaintiff vs. CIVIL ACTION - LAW BRENDA YOHE Defendant (s) NOTICE OF JUDGMENT ( x) Notice is hereby given that a in the above-captioned matter has been entered $ 10686.26 , plus interest, on -.J';J~ 'I ..:2...2 against you in the amount of , 20~. ( x) A copy of all documents filed with the Prothonotary in support of the within judgment is/are attached. Prot By: If you have any questions regarding this Notice, please contact the filing party. QJ-0 Amy F. Doyle #87062 / Phili 341 / "d R. Galloway #873 / a ramson 94266 / Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trind1e Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1120617 #87737 1187852 1194000 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: BRENDA YOHE 802 RITNER HWY SHIPPENSBURG PA 17257-9550 STNTC/PANOJ W&A FILE NO. 124335619 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : A MARYLAND CORPORATION; ASSIGNEE OF FORWARD • ,-, PROPERTIES; ASSIGNEE OF METRIS, : s , Plaintiff : No. 2005-05825 rn ° vs. : CIVIL ACTION `' BRENDA YOHE, - Defendant • r,> 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$10,686.26 plus costs was entered in Cumberland County on January 23, 2006. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on August 16, 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 September 18, 2013. A certificate of Service is attached hereto as Exhibit"A". 6. As of October 2, 2013, 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 denied. 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. - an R. Mege, Esq. Attorney ID No. 8 88 Attorney for P1.'ntiffs P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 -2- COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : A MARYLAND CORPORATION; ASSIGNEE OF FORWARD PROPERTIES; ASSIGNEE OF METRIS, : Plaintiff : No. 2005-05825 • vs. : CIVIL ACTION BRENDA YOHE, • Defendant CERTIFICATE OF SERVICE I,Alan R. Mege, Esquire, hereby certify that on September 18,2013, 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: Brenda Yohe, 802 Ritner Highway, Apt. 1, Shippensburg, PA 17257. By: • . ' . Mege, Esquire Atty. I.D. #81288 Attorney for Plaintif P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : A MARYLAND CORPORATION; ASSIGNEE OF FORWARD • PROPERTIES; ASSIGNEE OF METRIS, : Plaintiff : No. 2005-05825 vs. • : CIVIL ACTION BRENDA YOHE, 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 2, 2013 By: • ' . Mege, Esquire Atty. I.D. #81288 � -r* Attorney for P tiff t5 P.O. Box 1426 xa_.,. - rya Bethlehem, PA 18016 -< (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., c::) r' A MARYLAND CORPORATION; ASSIGNEE OF FORWARD zp PROPERTIES; ASSIGNEE OF METRIS, : Plaintiff : No. 2005-05825 <` ` `. v cst vs. : CIVIL ACTION BRENDA YOHE, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on October 15, 2013, I served a true correct copy of the Court's October 9, 2013, Compel Order by mailing same, first class, postage prepaid to: Brenda Yohe, 802 Ritner Highway, Apt. 1, Shippensburg, PA 17257. By: lan R. Mege, Esq ' e Atty. I.D. #8128: Attorney for Pl.mtiff P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION; ASSIGNEE OF FORWARD • PROPERTIES; ASSIGNEE OF METRIS, Plaintiff : No. 2005-05825 •© J" CIVIL ACTION �' `kc} BRENDA YOHE, : � -r� ;-' Defendant • © = . "7-p • - PLAINTIFF'S MOTION TO MAKE THE RULE ABSOLUTE cn And now comes Plaintiff and submits the instant Motion to Make The.Rule Absolute, and in support thereof avers as follows: 1. On October 9, 2013, a Rule was issued upon the Defendant, Brenda Yohe, to show cause why Plaintiffs Motion to Compel should not be granted. A copy of the Order is attach hereto as Exhibit"A". 2. The October 9, 2013, Rule, was served upon Defendant on October 15, 2013. 3. The Rule Returnable was to,be answered within thirty (30) days of service, in the Office of the Cumberland County Prothonotary. As of November 19, 2013, no answer has been filed. 4. A copy of this Motion and proposed Order were mailed to Defendants, via first class mail on November 19, 2013. 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 Defendant to answer Plaintiffs 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, Es. Attorney ID N•. 81288 Attorney for Plaintiff GREAT SENECA : IN THE COURT OF COMMON PLEAS OF FINANCIAL CORP., : CUMBERLAND COUNTY, PENNSYLVANIA ASSIGNEE OF FORWARD : PROPERTIES; ASSIGNEE : OF METRIS, Plaintiff • • v. : CIVIL ACTION—LAW BRENDA YOHE, Defendant : NO. 05-5825 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO INTERROGATORIES IN AID OF EXECUTION ORDER OF COURT AND NOW, this 9th day of October, 2013, upon consideration of Plaintiffs • Motion To Compel Defendant's Answers to Interrogatories in Aid of Execution, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 30 days of service. BY THE COURT, Christylee L. Peck, J. Ala . Mege, Esq. 7 . Broad Street ethlehem,PA 18016 Attorney for Plaintiff Brenda Yohe, • c7 • 802 Ritner Highway OCT 1 r; 2013 -o Apt. 1 z m Shippensburg, PA 17257 c.n'` r ter'• Defendant, pro Se 4 `o Vic.ED :rc 7, c w qk COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : A MARYLAND CORPORATION; • ASSIGNEE OF FORWARD PROPERTIES; ASSIGNEE OF METRIS, : Plaintiff : No. 2005-05825 • vs. : CIVIL ACTION BRENDA YOHE, • Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on November 19, 2013, I served Plaintiff's Motion to Make the Rule Absolute mailing same, first class, post prepaid to: Brenda Yohe, 802 Ritner Highway, Apt. 1, Shippensburg, PA 17257. By: an R. Mege, Esqu''- Atty. I.D. #81288 Attorney for Pl, ntiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 GREAT SENECA IN THE COURT OF COMMON PLEAS OF FINANCIAL CORP., : CUMBERLAND COUNTY, PENNSYLVANIA ASSIGNEE OF FORWARD PROPERTIES; ASSIGNEE • OF METRI S, • Plaintiff • • v. : CIVIL ACTION—LAW BRENDA YOHE, • Defendant : NO. 05-5825 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO MAKE THE RULE ABSOLUTE ORDER OF COURT AND NOW, this 2nd day of December, 2013, upon consideration of Plaintiff's Motion To Compel and a Rule To Show Cause having been issued on October 9, 2013, and the Defendant having failed to respond to the Rule, the Motion To Make the Rule Absolute is hereby granted, and Defendant has 30 days to answer Plaintiff's interrogatories. BY THE COURT, Christ ee L. Peck, J. Alan R. Mege, Esq. 70 E. Broad Street Bethlehem, PA 18016 Attorney for Plaintiff rn renda Yohe, o F ;._ 802 Ritner Highway "' w Apt. 1 .� Shippensburg, PA 17257 w f 7' Defendant, pro Se :rc Cdt \,., /a, 3f13 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : A MARYLAND CORPORATION; ASSIGNEE OF FORWARD • PROPERTIES; ASSIGNEE OF METRIS, : Plaintiff : No. 2005-05825 z rn `i car— vs. : -<> Ixt : CIVIL ACTION 'C BRENDA YOHE, xY Defendant • ,,n CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on December 5, 2013, I served a true correct copy of the Court's December 2, 2013, Compel Order by mailing same, first class, postage prepaid to: Brenda Yohe, 802 Ritner Highway, Apt. 1, Shippensburg, PA 17257. By: i R. Mege, Esquire Atty. I.D. #81288 Attorney for Plain; f P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : �, A A MARYLAND CORPORATION; : .. -.- ASSIGNEE OF FORWARD '``� . PROPERTIES; ASSIGNEE OF METRIS, : ' = Plaintiff : No. 2005-05825 o C3 vs. p • �T, C r■ CD : CIVIL ACTION crt BRENDA YOHE, • Defendant PLAINTIFF'S MOTION FOR SANCTIONS And now comes Plaintiff and submits the instant Motion for Sanctions, and in support thereof avers as follows: 1. Judgment for Plaintiff and against Defendant in the sum of$10,686.26 plus costs was entered in Cumberland County on January 23, 2006. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on August 16, 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. After notice, a Motion to Compel was filed and an Order entered on December 2, 2013, requiring Defendant, within thirty(30) days, to make full and complete answers to Interrogatories. A true and correct copy of the December 2, 2013, Order is attached as Exhibit 5. As of January 28, 2014, Plaintiff has not received Defendant's answers to Interrogatories. 6. A copy of this Motion and proposed Order was sent to Defendant on January 10, 2014. A Certificate of Service is attached hereto. 7. Counsel for Plaintiff sent correspondence to Defendant on January 10, 2014, seeking concurrence, and Defendant has not responded. A true and correct copy of the correspondence is attached hereto as Exhibit "B". WHEREFORE, Plaintiff, requests that this Honorable Court grant its motion and Order that the Defendant shall pay a daily fine of$25.00 to the use of Plaintiff until Defendant complies with this Court's Order of December 2, 2013, and Defendant shall also pay$100.00 attorney's fees to Plaintiff within twenty(20) days of the date of this Order or appropriate sanctions may be imposed upon Defendant following application to this Court. ■11111111111111101111 lan R. Mege, Est Attorney ID No. : 1288 Attorney for Pl. ntiff PO Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 -2- GREAT SENECA : IN THE COURT OF COMMON PLEAS OF FINANCIAL CORP., : CUMBERLAND COUNTY, PENNSYLVANIA ASSIGNEE OF FORWARD PROPERTIES; ASSIGNEE OF METRIS, Plaintiff v. : CIVIL ACTION—LAW BRENDA YOHE, : Defendant : NO. 05-5825 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO MAKE THE RULE ABSOLUTE ORDER OF COURT AND NOW, this 2nd day of December, 2013, upon consideration of Plaintiff's Motion To Compel and a Rule To Show Cause having been issued on October 9, 2013, and the Defendant having failed to respond to the Rule, the Motion To Make the Rule Absolute is hereby granted, and Defendant has 30 days to answer Plaintiff's interrogatories. BY THE COURT, % Lz/ %/ <- Christ ee L. Peck, J. Ala94. Mege, Esq. Z6"E. Broad Street Bethlehem, PA 18016 Attorney for Plaintiff n Brenda Yohe, x z 802 Ritner Highway (pr.' Apt. 1 ' <p o �_�- Shippensburg, PA 17257 >c.) -,- Defendant, pro Se 2 =c = ` «i tt 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 10, 2014 Brenda Yohe 802 Ritner Highway, Apt. 1 Shippensburg, PA 17257 RE: Great Seneca Financial Corp. v. Yohe No. 2005-05825 Dear Ms. Yohe: You are in violation of the Court's Order of December 2, 2013, directing you to provide answers to the interrogatories. Because we have not received your answers to the interrogatories, our office intends to file a Motion for Sanctions, a copy of which is enclosed. Please notify our office of your concurrence or non-concurrence with regard to said Motion by January 24, 2014. If we do not hear from you by this time we will assume your concurrence. 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. Meg ARM/cms 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. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : A MARYLAND CORPORATION; • ASSIGNEE OF FORWARD PROPERTIES; ASSIGNEE OF METRIS, : Plaintiff : No. 2005-05825 • vs. : CIVIL ACTION BRENDA YOHE, • Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on January 10, 2014, I served upon Defendant,a true and correct copy of Plaintiffs Motion for Sanctions and proposed Order by mailing same, first class, postage prepaid to: Brenda Yohe, 802 Ritner Highway, Apt. 1, Shippensburg, PA 17257. By: Alan ' ege, Esquire - y. I.D. #81288 Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 GREAT SENECA FINANCIAL CORP., ASSIGNEE OF FORWARD PROPERTIES; ASSIGNEE OF METRIS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION — LAW BRENDA YOHE, Defendant : NO. 05-5825 CIVIL TERM IN RE: PLAINTIFF'S MOTION FOR SANCTIONS ORDER OF COURT AND NOW, this 23rd day of September, 2014, upon consideration of Plaintiffs Motion for Sanctions for Defendant's failure to answer interrogatories pertaining to a judgment issued against the Defendant on January 23, 2006, the motion for sanctions is denied. BY THE COURT, Christylee L. Peck, ,..VA'1.ran R. Mdge, Esq. 70 E. Broad Street Bethlehem, PA 18016 Attorney for Plaintiff Brenda Yohe, 802 Ritner Highway Apt. 1 Shippensburg, PA 17257 Defendant, pro Se :rc etiopCES 1-5-eL Ci rntX 1-> -77 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION; ASSIGNEE,OF FORWARD PROPERTIES; ASSIGNEE OF METRIS, Plaintiff • vs. BRENDA YOHE, Defendant • : No. 2005-05825 : CIVIL ACTION STIPULATION AND NOW, this 17`h day of October, it is hereby stipulated and agreed by and between the parties: 1. The parties agree that Defendant shall pay the judgment amount and costs to Plaintiff by making monthly payments of a minimum of $400.00 per month paid by Defendant and mailed to,Plaintiff, with the first such monthly payment due by the end of October, 2014 and each following monthly payment due by the end of each month thereafter. 2. The parties agree that payments shall be made payable to "Alan Mege - EEC", and mailed, to Law Offices of Alan Mege, P.O. Box 1426, Bethlehem, PA, 18016-1426. 3. The parties agree that this Stipulation be made into an Order of Court. 5. Upon completion of the above -referenced payments, barring an uncured default, Plaintiff shall forward to the Court for filing, a fully executed Praecipe to Satisfy. 6. Defendant need not comply with outstanding discovery or sanctions Orders, where applicable, as long as Defendant is not in default of the payment arrangement. IN WITNESS WHEREOF and intending to be legally bound, the parties hereto have set their hands and seals the day and year first above written. Brenda Yohe : Alan R. iviege, Esq. Defendant Attorney for Plaintif SHERIFF'S OFFICE OF CUMBERLAND COUNTY 2 Ronny R Anderson rnW Sheriff n t z Jody S Smith '' Chief Deputy $ r-" Richard W Stewart - 01. Solicitor 4 � THE SKE. (F cri Great Seneca Financial Corp Assignee of Forward Properties; Assignee o vs. Brenda Yohe Case Number 2005-5825 SHERIFF'S RETURN OF SERVICE 10/16/2014 06:19 PM - William Cline, Deputy , being duly sworn according to law, states that on October 16, 2014 at 6:19 PM hours, served the requested Writ of Execution and Claim for Exemption Form by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Brenda Yohe at 802 Ritner Hwy, Apt. 1, Shippensburg Township, Shippensburg, PA 17257, informed Defendant of contents of same and levied upon personal property as directed. Copy of levy mailed to attorney and letter mailed to defendant on October 17, 2014. 10/29/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ is returned STAYED at request of plaintiffs attorney. SHERIFF COST: $87.01 SO ANSWERS, October 29, 2014 (c) CountySuite Sheriff, Te!eosoft, enc. RONZ' R ANDERSON, SHERIFF COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION; ASSIGNEE OF FORWARD PROPERTIES; ASSIGNEE OF METRIS, Plaintiff vs. BRENDA YOHE, Defendant AND NOW, to wit, this 3. • : No. 2005-05825 : CIVIL ACTION ORDER c mW r� <d day of , 2014, the Stipulation of the parties dated October 17, 2014 is hereby approved and made an Order of Court in the above -captioned matter. BY THE COURT: ee,14- , J. Distribution: Alan R. Mege, Esq., 70 E Broad St., Bethlehem, PA 18016 Brenda Yohe, 802 Ritner Highway, Apt 1 Shippensburg, PA 17257 CO? l'ES /')ai///10 '%� COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION; ASSIGNEE OF FORWARD PROPERTIES; ASSIGNEE OF METRIS, Plaintiff vs. BRENDA YOHE, Defendant • : No. 2005-05825 : CIVIL ACTION STIPULATION AND NOW, this 17`h day of October, it is hereby stipulated and agreed by and between the parties: 1. The parties agree that Defendant shall pay the judgment amount and costs to Plaintiff by making monthly payments of a minimum of $400.00 per month paid by Defendant and mailed to Plaintiff, with the first such monthly payment due by the end of October, 2014 and each following monthly payment due by the end of each month thereafter. 2. The parties agree that payments shall be made payable to "Alan Mege - EEC", and mailed, to Law Offices of Alan Mege, P.O. Box 1426, Bethlehem, PA, 18016-1426. 3. The parties agree that this Stipulation be made into an Order of Court. 5. Upon completion of the above -referenced payments, barring an uncured default, Plaintiff shall forward to the Court for filing, a fully executed Praecipe to Satisfy. 6. Defendant need not comply with outstanding discovery or sanctions Orders, where applicable, as long as Defendant is not in default of the payment arrangement. IN WITNESS WHEREOF and intending to be legally bound, the parties hereto have set their hands and seals the day and year first above written. Brenda Yohe U Alan R. ;viege, Esq. Defendant Attorney for Plaintif