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Home My WebLink About05-6283 -. COMMONWEALTH OF PENNSYLVANIA NOTICE OF APPEAL COURT OF COMMON PLEAS FROM DISTRICT JUSTICE JUDGMENT JUDICIAL DISTRICT CID1hEllLP.u"JD COUl\~TY COMMON PLEAS No. 0 S - ~J.P 3 (!Lu;(T~ NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Dis- trict Justice on the date and in the case mentioned below. NAME OF APPELLANT MAG. D1ST. NO. OR NAME OF D.J. DJ lIiANLOVE 09--1-02 GREAT SENECA FINANCIAL CORP. ADDRESS OF APPELLANT CITY STATE lIP CODE 11/7/05 ABiUU~SON LLP 4660 TRINDLE RD I IN THE CASE OF (PLAINTIFF) GREAT SENECA FIN,\KCIAL - SUITE 300 CAEP HILL PA 17011 (DEFENDANT) r./o wmnrm-.' & DATE OF JUDGMENT CORP. vs. RICHAPJ) & HILDA BYA~;UGISlil\. CV YEAR 454-05 SIGNATURE OF APPELLANT OR HIS ATTORNEY OR AGENT CLAIM NO. LT YEAR G.~~ This block will be signed ONLY when this notation is required under PA. R.C.P.J.P. No. 1008B. This notice of Appeal, when received by the District Justice, will operate as A SUPERSEDEAS to the Judgment for possession in this case_ If appellant was Claimanl (see PA RC.P.J.P. No. 1001(6)) in action before district Justice, he MUST FILE A COMPLAINT wlfhin twenty (20) days after filing his NOTICE of APPEAL. ~l!JnaWre oll-'rornonOlary or uepury PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see PA R.C.P.J,P. No. 1001(7) in action beiore District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rute upon , appellee(s), to file a complaint in this appeal Name of appel/ee(s) (Common Pleas No_ ) within twenty (20) days after service of rule or suffer entry of judgment of non pros_ Signature of appel/ant or his attorney or agent RULE: To , appellee(s) Name of appel/ee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty(20) days after the date of service of this ruie upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU UPON PRAECiPE (3) The date of service of this rule if service was by mail is the date of the mailing. Date: , Year Signature of Prothonotary or Deputy White Green Yellow Pink Gold Prothonotary Copy Court File Copy Appeiant's Copy Appellee Copy D. J. Copy Proth. - 76 PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUN1Y OF ; 55 AFFIDAVIT: I hereby swear or affirm that I served o a copy of the Notice of Appeal, Common Pleas No. , upon the District Justice designated therein on (date of service) . year . 0 by personal service Dby (certified) (registered) mail, sender's receipt attached hereto. and upon the appellee, (name _, on , year ~~, 0 by personal service 0 by (certified) (registered) mail, sender's receipt attached hereto. o and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee{s) to whom the Rule was addressed on , year , 0 by personal service Dby (certified) (registered) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF ,YEAR Signature of Alfkml Signature of official before whom affid.avit was ffl.ade My commission expires on _ , year H(":)~ t- 1. ~ ~ ~ tffl $ -{O f "il Tit1eofofficial c; '...) r-,~) cr", . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. Assignee of ASCENSION SERVICES Assignee of KEY BANK, N.A. Plaintiff NO. 05-6283 vs. RICHARD BY AMUGISHA HILDA BAY AMUGISHA Defendant(s) AFFIDAVIT OF SERVICE CIVIL ACTION - LAW Commonwealth of Pennsylvania ss. County of Cumberland AND NOW, TO WIT, comes the undersigned, who being duly sworn according to law, deposes and says that they are counsel for the Plaintiff in the above-caption action; that on 12/23/05, they caused a true copy of the Complaint in the above-captioned action to be sent by Regular Mail - Postage Prepaid and Certified Mail, Return Receipt Requested, to Defendant(s) 1 Defendant(s) Counsel, at their last known address. Said Certified Mail was returned marked "Unclaimed", as indicated on the envelope(s) addressed to the Defendant(s) 1 Defendant(s) Counsel attached hereto; however, the Regular Mail was never returned as undeliverable. Pursuant to Pa. R.C.P. ~403(l), effective service of the Complaint has been made upon Defendant(s)/Defendant(s) Counsel as a result of their failure to claim the Certified Mail and the fact that the Regular Mail was not returned as undeliverable. G~). Amy F. Doyle I Daniel F. Wolfson I Bruce H. Cherkis 1 Philip C. Warholic I Tonilyn M. Chippiel Andrew C. Spears I Ronald M. Abramson I Ronald S. Canter/David R. Galloway W olpoff & Abramson, LLPICounsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road-3" Floor, Camp Hill, PA 17011 (717) 303-6700 SWORN and SUBSCRIBED to before me this 2. "'i day ocbollo\u \_' 20.Q\.Q.... tC N V Notarial Seal Cortney M. Fantom, Notary Public Ha~ Twp" eu_'1and County IonEx' sNov 23 2 Member, PemsytYonla _ of Nolllrfea , -n li- c' . ~_/~ ~~.~ ':-J'A . o (J)Ol> DODD ~~:Z>- ( 'Z-fo::t~ --J 'I ~o~;c: JJ CJ r-l!!n-,;l~ () CJ \ "'1-::%:-1- IJ1 -1<z:ITl!2 :r: og;c::om .I ~>3:.z~ > ~ .".1 :%Il!:~S> JJ 0> =e",::a t:l 0 ru >>__~o CJ ::afl)~o::D OJ o>::D:e~ ~ Cl ..c g~z"" ~O~ Cl o . ".... 5: Cl . . m . ' ., --J ., C m 0 G) '" --J C '" (f) IJ1 :.2: .... Cl x :r: m ru 0 " > ~ IJ1 W 3: w IJ1 m 0 >- o o JJ m (f) (f) ~ Ii <: o m :n m o c m ~ m o ()-""-'<C' ;,.~o> ~:;t"'~ :I:?;1~O PZ'>j:g rO'>j- "C' () ~trJ~trJ .... ;,.'" ~?;1~ <3f?~ :::~~ c'" _0 ;;j .':2: wt"' o' or" ~ rn J a 7) 7) . ~~ . ,,' ~ ^'\......... ,:! ";i" ........ .Co 0') (.l'l C) CNffr ./') ,~ ~ f>~ if; .0 G 10 .,'" -{J ID ~ ~ .~ i ~ -s ~~ ~ DD {l o o ~ 0 ~;z DD ~. I> · "'i ~ ~ lOll ~:g ~ ~ i.~ :ij :. ~~ .~ (I) :ij~ 2l~ . o ~ ~ ID ::; \~ "i <$ ~ o ,- \ l z j c 6: Ji' -g .~ ~ )( cO " oi l!l \'! g $! 11) 0- c.'1! '=' n"g~ t:l.~:s >- <I) ~-oc::.9-5 . o -$ .!2 r/I ~ O'j:. . U)!3~ t:. ~i-lj1!z! a'i6-g-,," c..rO"OE-S~ r"i~~$g. ~'g ~ ~1!~ !U~~g Q): a: '- III .- ]i",a~~1! o..~ >>'ta r.... . gE:€~S_~ ()~a.g<1.o . . . ~ D .g 1'. 'a .~ ::;", ~EO c.il ci "ID . O~ U1i fTli fTI1 Ul o ! e ~ ru ~ Cl _ ~ Ul ." l ~ f'- iil~~ f'- 2l~-~'5 Cl '~811'Sg1'. J1 DD ~ .~ ~ ~ ~ \ 1 ~ ~Ii \ (\ 0 g "3f'- ~I S +- "'- -..::: ~~ '0~ .i. .. ~~ ~ c::0 b I ~ ~ ~ ~ c6 )i-- .; ~ -j!. -- "" P.. --- ~ <> <> N I ~ ~ Ji .l\E~ E e r- ~ - <j) ;z.l; '" ~ ~ E )i! ~ <f) 0. & ~" -:i. <:;L. !, 2) " 09-1-02 NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 'GREAT SEII1ECA FINANCIAL CORP, ETC -, 4660 TRIHDLE RD APT/STE 301 'Ii WOLPOFF &: ABRAMSON LLP ~P ~ILL, PA 17011 ~ VS. , .cOMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Dis1, No MDJ Name: HOIl ROBERT V. MANLOVE Add,." 1901 STATE ST CAMP BILL, PA '.::':,:', .:,..::,.;._.....\,:_.:_.:...: ,'..i',',::."""; Telepho" (717)' 7,61.-0583 17011-0000 DEFENDANT: NAME.and ADDRESS fjYAM1JGl:SB,A, RICJlARIII.. BT,AL. 402,W.qR,ESTWOODDR.. APT/STS CAMP BILL; PA 17011-1206 L -, C7 GREAT SEII1ECA FINANCIAL CORP, BTe 4660 TRIHDLB RD APT/STB 301 'Ii WOLPOFF &: ABRAMSON LLP CAMP BILL. PA 17011 Docket No.: CV-0000454-05 Date Filed: 9/13/05 ~ . THIS IS TO NOTIFY YOU THAT: .. -. J(jd(lr1lent: .. .~. '''r''.' !il Judgment was entered for: ".,,,," "n.AUL\'.ttm~ DEli'." ,--;..,-.....-.., .;-" (Name) ~YJ.ljmaTR1flt. llTI'1flt.lln !il Judgment was entered against: (Name) all'Rlt.'I' R'RN'lU'A lI'TJII'AJII'C'!TllT. C'!nllP, iii: in the amount of $ 00 on: (Date of Judgment) 11/n7/n!'. O. Defendants are jOintly~nd severally liable, Damages will be assessed on: (Date & Time) D This case dismissed without prejudice. D Amount oj Judgment Subject to Atlachmentl42 Pa.C.S. S 8127 $ o Portion of Judgment jor physical damages arising out of residential lease $ AmountotJud~ment $ --. ~OO,. Judgn)Elnt Costs $ ;OO! Interest on Judgment $ .00 Attorney Fees $ .00 Total $ .00 Post Judgment Credits $ Post Judgment Costs $ . ------------ ------------ Certified Judgment Total $ .. ANY PAR,TY tjAS ~H~ RI"}H; TO A~PEAL WI1HIN 3ODAY~_AfT~R TiH,E E~TF\YOI~~D~MENT BY FiLlNq 1 i~ClTICE OF APPEAL WiTH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIUDIVISION, YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTfTRANSCRIPT 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 SA TISFAC110N WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. ~ 55.95 , Magisterial DistrictJudge q the proceeding~ containing the judgment. . trict Judge AOPC 315-05 DATE PRINTED: 11/07/05 11:44:04 AM SEAL 13bfo27'1J.9 My commission expires first Monday of January, 2006 . r- q] fTl o U1 , U.S. Postal Servic~'M : CERTIFIED MA1LM RECEIPT 1 (Domestic Mall Only; No Insurance Coverage Provided) ~ r=c."""""."""'.""'..',."r~""'A "::ToTI('~ :"'!";"';~""', ~ 'H_~:rt,::::J-- I ~ (E"d:'::;::~",i::~;~d~ r-==l ru Aestncled Delivery Fee j-- ~ (Eoo""meo' Req,"ed) ~_ U1 To,"' Postage & Fee, L$_ I o o ['- Postmark Hem y~B I Sam To l uu___uulm~___H~M.Q.[d,_kutLl[~h\1~.___#u()_~~_I_::_9.0uu Street. Apt. No.; 9. " ~:.:.,,_".~~,r:~:uuJ u<?.Lu5.Jg,;u,L..?1:muuumummuuuu. .. . Clty,Stale,ZlP+4') l+'I( n .. . - "'" \. V. (701 :11 -1 U.S. Postal Ser ice~ ' CERTIFIED ,(iL. RECEIPT (Domestic Mall Only; "I_nee Coverage Provided) rc...< o U1 I J ~ r=c."'~"'''''''''''''''''''''''''"''';'A ..,;n,m. . """,,,,,,," ['- --------;,o"ag~~..==----,--. g ---- ~ o Return Receipt Fee (Endorsement Required) ___ o ru Restrictecl Delivery Fee I ~ (Endorsement Required) I Total Postage & Fees $ -' U1 ~ ~~t'.~uq):~k,,!:J.u,1'KLil.i1d"'m_C3X<!'!':\))0_:s_~gu_m_u._ ;!.~~~::;:'u~CJ~u_~I:u6.Jtw.p'~."',~E':.::t.J~.r_.C;_,J_n. C'Iy,S..te.ZlP+4 Co.'^< Ii.'il PII 17ol! . Postmarl< Here ,JQ\3. ,OO - , PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF _CU"",~ 'X [1l"J ; 58 AFFI DAVIT: I hereby swear or affirm that I served Iri a copy of the Notice of Appeal\ Common Pleas No,O)-- ~)~ 3 {!, 'v 11 to rWvupon the District Justice designated therein on f-' (date of service) V(JCI.\IIIber I;). . year~. , Dby perso~al service y (ce~ified)(registered) mail, sender's receipt attachfd hereto, and upon the appellee, (name 1 ",d ""c.1 I . on ~e a... ,Il{ Q... year ::J ooJ , D by personal servic~ by (certified) (registered) mail. sender's receipt attached hereto, o and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom the Rule was addressed on , year , D by personal service Dby (certified) (registered) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS ---1Z.- DAY OF Dtt. , YEAR 'If:t:l7, Omarch. "" II>>') Signature of official before whom affidavit was made T""OfO"~ My commission expires on Oct. 3 ,year~ Nal8IlaI8e8I . -...... K8IMI'. NalalY .... """"-1'lip.. Cw.......,~ ~dtLJh<l~0aI.3. _r, "",..eytvonIa Ao.."...... 01 NallIIIIit ~{;- Signature of Affiant r'-..':l = = ,,;_,~t {:J .on Co I'd L'"""') GO:< c::' C) COMMONWEALTH OF PENNSYLVANIA NOTICE OF APPEAL COURT OF COMMON PLEAS FROM DISTRICT JUSTICE JUDGMENT JUDICIAL DISTRICT ,.lJ~'J:f:~~,:~i<.;\\) ~:(j\.;~'T\ COMMON PLEAS. No. (),'. / 'I ,~).../ ,>ovl./ ......; , .."'~ , "-1""" /(i/h , . NOTICE OF APPEAL Notice is given th<lt the <lppell<lnt h<ls filed in the <lbove Court of Common Pleas an appeal from the judgment rendered by the DIs- trict Justice on the date and In the case mentioned below. NAME OF APPELLANT MAG. OIST. NO. OR NAME OF D.J. Gh.I:~..,i,'i ~),I':.i.,i':.~:A ~;,j',};C ~c'~" CUi i, " ADDRESS OF APPELLANT CITY STATE ZIP CODe 11,.' '/ / '.;',) r,b1:\1~: ::',(;i\ '-1L.,4GbU ThLi0L;:. ';JJ I (':L~l:Hl~ c:~~:\~; :~!~'~:/;:~ Al\: t 11'\' L - ~Fj TJ' '5L;\: '.'-;; . (, U~\'tJ!.~.e\}]<. 6~ DATE OF JUDGMENT CV YEAR Lt~-)4-U:, (DEFENDANT) t)JtU!.. VS. :-;l(,:'"'i-',:"1' ': .;, cSt-'-.:' SIGNATURE OF APPELLANT OR HIS ATTORNEY OR AGENT ; l ;,'~ i' CLAIM NO. L T YEAR This block will be signed ONLY when this notation is required under PA. R.C.P.J.P. No. 1008B. This notice of Appeal, when received by the District Justice, will operate as A SUPERSEDEAS to the Judgment for possession in this case. If appellant was Ctaimant (see PA R.C.P.J.P. No. 1001(6)) in' action before district Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. ::J/gnarure or t'romonoUJry or uepury PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be u~ed ONLY when appellant was DEFENDANT (see PA R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be seIVed upon appellee. PRAECIPE: To Prothonotary Enter rule upon Name of appellee(s) , appellee(s), to file a complaint in this appeal (Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or his attorney or agent RULE: To Name of appellee(s) , appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty(20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this lime, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU UPON PRAECIPE. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: , Year Signature of Prothonotary or Deputy White Green Yellow Pink Gold Prothonotary Copy Court File Copy Appelan!'s Copy Appellee Copy D. J. Copy Proth. ~ 76 o lG\~ ~ LAW OFFICES WOLPOFF & ABRAMSON, LL.P. ATTORNEYS IN THE PRACTICE OF DEBT COLLECTION 4660 TRINDLE ROAD THIRD FLOOR CAMP HILL. PA 17011 717-303-6700 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF KEY BANK, Plaintiff No. 2005-6283 vs. CIVIL ACTION - LAW RICHARD BY AMUGISHA, Defendant 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 twenty (20) days after th,s Complaint and Nolice is served, by entering a written appearance, personally of by attorney, and filing in waiting 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 in the Complaint, or document, or for any other claim or relief requested by the Plaintiff. You may lose money or property or other right important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT O~CE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 dernandado a used en la corte. 5i used quaere defenses de esas dernandas expuestas en las paginas, siguientes, used liene viente (20) dias de plaza al partir de la fecha de lademanda y la notifiation. Used debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones a last demandas en contra de su persona. Sea avisado que si used no se defienda, la corte tomara medidas y psedida entrar una orden contra used sin previa aviso 0 notificacion y por cualqmer queja 0 alivio que es pedido en la peticion de demanda. Used puede perder dinero a sus propiedades 0 otros derechos importantes para used. LLEVE ESTA DEMANDA A UN ABADOAGO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENEE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO V A Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SU PUEDE CONDEGUIR ASSITANCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 (717) 249-3166 (800) 990-9108 LAW OFFICES WOLPOFF & ABRAMSON, LL.P. ATTORNEYS IN THE PRACTICE OF DEBT COLLECnON 4660 TRtNDLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717-303-6700 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF KEY BANK, Plaintiff No. 2005-6283 vs. CIVIL ACTION - LAW RICHARD BY AMUGISHA, Defendant COMPLAINT AND NOW, this \~ ~~day of \).r"~r , 2005, comes the Plaintiff, Great Seneca Financial Corp., a Maryland Corporation, Assignee of Key Bank, by and through its attorneys, the law firm ofWolpoff & Abramson, L.L.P., and files the within Complaint and in support avers as follows: 1. Plaintiff, Great Seneca Financial Corp., a Maryland Corporation, Assignee of Key Bank, is a corporation doing business within the Commonwealth of Pennsylvania and the other states of the United States, with its principal offices located at P.O. Box 1651, Rockville, MD 20849. 2. Defendant, Richard Byamugisha, is an adult individual with a last known address of 402 West Crestwood Drive, Apt. C7, Camp Hill, Cumberland County, Pennsylvania 17011-1296. 3. It is averred that on February 9, 1999, Defendant was issued a loan account by Plaintiffs assignor, Key Bank, with account number 0001300845. This account was created through an agreement between Plaintiffs assignor and Defendant, accepted by Defendant when he utilized the account. LAW OFFICES WOLPOFF & ABRAMSON, L.LP. AITORNEYS IN THE PRACTiCE OF DEBT COLLECTION 4660 TRINOLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717-303-6700 4. At all relevant times material hereto, Defendant has been a regular user of said account for the purchase of products, goods and/or for obtaining services and/or funds. 5. Defendant received monthly statements from Key Bank which accurately stated all purchases and payments made during the month, interest charges imposed on the unpaid balance, and the amount due. 6. Defendant did not object to the above-mentioned monthly Statements of Account submitted by Plaintiffs assignor to Defendant. 7. Defendant has made sporadic and irregular payments, if any, which have been applied to the outstanding balance of this account. Defendant's last payment was made on December 7, 2001. 8. As of the date of the within Complaint, the remaining balance due, owing and unpaid on Defendant's account, as a result of charges made by said Defendant and/or any authorized users is the sum of Seven Thousand Two Hundred Four and 60/100 ($7,204.60) Dollars. 9. Pursuant to the Agreement and/or applicable Pennsylvania law, any unpaid and/or delinquent balances on said account shall continue to bear interest at the rate of 18.00% percent. 10. The amount of interest which has accrued on the aforementioned account is the sum of One Thousand Thirty-Seven and 46/100 ($1,037.46) Dollars 11. Plaintiffhas retained the services of the law firm ofWolpoff & Abramson, L.L.P. in the collection of the amount due from Defendant. LAW OFFICES WOLPOFF & ABRAMSON, LL.P. AITORNEYS IN THE PRACTICE OF DEBT COLLECTION 4660 TRINDLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717-303-6700 12. As of the filing of this Complaint, Plaintiff has incurred reasonable attorney's fees from the law office ofWolpoff & Abramson, L.L.P. in the collection of the amounts due from Defendant incident to the within action, the Plaintiff shall continue to incur such attorney's fees throughout the conclusion of the proceedings. 13. The amount of attorney's fees incurred in this matter is the sum of One Hundred Forty-One Dollars and 66/100 ($141.66) Dollars. 14. Despite reasonable and repeated demands for payment, Defendant has failed, refused and continues to refuse to pay all sums due and owing on the aforementioned account balance, all to the damage and detriment of the Plaintiff. 15. Any and all conditions precedent to the bringing of this action have been performed by Plaintiff. 16. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. LAW OFFICES WOLPOFF & ABRAMSON, LLP. AITORNEYS IN THE PRACTICE OF DEBT COILECTION 4660 TRINDlE ROAD THIRD FLOOR CAMP HilL PA 17011 717-303-6700 WHEREFORE, Plaintiff, Great Seneca Financial Corp., a Maryland Corporation, Assignee of Key Bank, respectfully requests this Honorable Court enter judgment in favor of Plaintiff and against Defendant, Richard Byamugisha, in the amount of Eight Thousand Three Hundred Eighty-Three and 72/100 ($8,383.72) Dollars, plus costs of this action and such other relief as the Court deems proper and just. Respectfully submitted, (>le Q ~ Andrew C. Spears, Esquire ID No. 87737 Wolpoff & Abramson, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3'd Floor Camp Hill, P A 17011 (717) 303-6700 Counsel for Plaintiff LAW OFFICES WOLPOFF & ABRAMSON, L.L.P. ATTORNEYS IN THE PRACTICE OF DEBT COlLECTION 4660 TRINDLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717-303-6700 VERIFICA nON I I I I I I The undersigned hereby states that he/she is the attomey for the Plaintiff, Great Seneca Financial Corp., a Maryland Corporation, Assignee of Key Bank, who is located outside of this jurisdiction and in order to file the within document in an expedient and timely manner, he/she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his/her 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 unswom falsification to authorities. l~ \ It 0') (" _/ Andrew C. Spears, Esquire ID No. 87737 Wolpoff & Abramson, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3'd Floor Camp Hill, P A 17011 (717) 303-6700 Counsel for Plaintiff . 'i\ ,- C':' .... .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. ASSIGNEE OF ASCENSION SERVICES ASSIGNEE OF KEY BANK, N.A. Plaintiff NO. 05-6283 vs. CIVIL ACTION - LAW RICHARD BY AMUGISHA and HILDA BY AMUGISHA Defendant( s) AFFIDAVIT OF SERVICE Commonwealth of Pennsylvania ss. County of Cumberland AND NOW, TO WIT, this \ C\ \L- day of j\)~ ,2001.,...., comes the undersigned who being duly sworn according to law, deposes and says that they are the Attorney for the Plaintiff in the above-captioned action; that on December 12, 2005 they caused a true copy of the NOTICE OF APPEAL in the above-captioned action to be sent by Certified Mail, Return Receipt Requested, hereto attached, to RICHARD BY AMUGISHA at the last known address, 402 W CREASTWOOD DR. APT C7, CAMP HILL, PA 17011, and that said copy was received by said individual(s), as indicated by the return receipt card attached hereto dated December 13, 2005. Amy F. Doyle / Daniel F. Wolfson / Bruce H. Cherkis / Philip C. Warholic / Tonilyn M. Chippie/ Andrew C. Spears / Ronald M. Abramson / Ronald S. Canter/David R. Galloway W olpoff & Abramson, LLP/Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road-3" Floor, Camp Hill, PA 1701 I (717) 303-6700 SWORN and SUBSCRIBED to before me this ~ day of "ICln , 20a:,. ~ KDMJh.. Notary Public OP NotarI8ISeal Amanda KalIl8l', Notal)' PublIC Hampden Twp., Cumberl8nd County My CommlNlon e.plrea Oct. 3. 2009 Member, Pennsytvanla AIaoClatfon of Notaries ..- '" SENDER: COMPLETE THIS SECTION . Complete items 1, 2, and 3. Also complete nom 4 if Restricted Delivery Is desired. . Print your name and address on the reverse so that we can return the card to you. Attach this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: c..l,ard .wl ~llda By 4"-1 v:; 15[",0. "\ I}J. Cr~sr lIoxl Vf'. -All+- C 1 . 'VIP ~:t( PA /19/1 2. Article Number (T>ansfer from serv/CflIebeJ) - PS Form 3811, February 2004 . . . . A Signature , . 0 Agent X U 11 8 ClrnuoIShq 0 Ad_ 8. Recelved by (Printed Name) C. Date of Delivery li-lr II 8 GIf tShJ;;J 05- D. Is delivery address different from Item 1? If YES. enter delNery address below: 3. Selvice Type .s Certified Mall D Express Mall o Registered ~ Return Receipt for Merchandise o Insured Mall 0 C.O.D. 4. RestrIcted Delivery? (Extra Fee) 0 Yes 7005 1820 0007 7502 5021 102595-02-M-1540 Domestic Return Receipt \3loG~")y~q 5ePL \lOt o(2a.po. , -' .) .:L - GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, : ASSIGNEE OF ASCENSION SERVICES, ASSIGNEE OF KEY BANK, N .A. , Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-6283 v. CIVIL ACTION - LAW RICHARD BYAMUGISHA, Defendant ANSWER 1. I am without sufficient information, knowledge or belief to respond. 2 . Admitted. 3. Denied. I do not believe I ever signed any documents to get a loan. I believe my ex-wife may have signed my name. I have no documentation. I do not believe I ever used the account mentioned. 4. Denied. See response to paragraph #3. 5. Denied. I do not know of any purchases or payments made regarding the mentioned account. 6. The statements were recall ever seeing a statement. reason to object to anything. sent to my ex-wife. I do not Accordingly, I would have no 7. Denied. I never made any payments. 8. I have not been given any documentation as to what amounts are owed and why I am responsible for these amounts and am without sufficient information, knowledge or belief to otherwise respond. 9. I do not have a copy of the agreement and am therefore without sufficient information, knowledge or belief as to be able to respond. Proof is demanded at trial. .. 10. I am without sufficient information, knowledge or belief to respond. Proof is demanded at trial. 11. Admitted. 12. I am without sufficient information, knowledge or belief to respond. Proof is demanded at trial. 13. I am without sufficient information, knowledge or belief to respond. Proof is demanded at trial. 14. It is denied that I owe any money. Accordingly, no demands for payment could be reasonable. 15. I do not know what conditions precedent Plaintiff is alleging to have performed and therefore cannot adequately respond. 16. Admitted. NEW MATTER 17. Defendant incorporates paragraphs 1 through 16 above as if fully set forth herein. 18. limitations. Plaintiff's Complaint is barred by the statute of DATE: 1/27/06 Respectfully submitted, "CHARD ~AMUG:'HA' Defendant Apt. C-7 402 W. Crestwood Drive Camp Hill, PA 17011-1206 (717) 315-3823 . - VERIFICATION I hereby verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subj ect to the penal ties of 18 Pa. C. S. section 4904, relating to unsworn falsification to authorities. (l ~ Dated: 1/27/06 RICHARD BYAMUGISHA CERTIFICATE OF SERVICE I certify that I have served a true and correct copy of this document upon attorney for Plaintiff by mailing same, postage prepaid at Harrisburg, PA, on January 27, 2006 to: Andrew C. Spears, Esq. WOLPOFF & ABRAMSON, LLP 4660 Trindle Road Third Floor Camp Hill, PA 17011 ~\ DATED: 1/27/04 ---- } RICHARD BYAJo UGISHA Q ~-" -O\~< rnf~' '-/ . :21. U].' -,~ " r:;. ;: ~,'~~.. ):"'C' .--> = = 4' <- ~ v> o S>. 'P" :-5- ~ ::C--n ,n r~'~ -nr-r'. 'J8 '~~~~~) - . '::::. ''T~ '51 - - Q "'- LAW OFFICES WOLPOFF & ABRAMSON, L.L.P. ATTORNEYS IN THE l'RACTrCE OF DEBT COUECTlON 4660 TAINDLE ROAD THIRD FLOOR CAMPHILl,PI\17011 717-303-6700 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF KEY BANK, Plaintiff No. 2005-6283 vs. CIVIL ACTION - LAW RICHARD BY AMUGISHA, Defendant REPLY TO NEW MATTER AND NOW, TO WIT, this M-day of February, 2006, comes the Plaintiff, Great Seneca Financial Corp., a Maryland Corporation, Assignee of Key Bank, by and through its attorneys, and the law firm ofWolpoff & Abramson, L.L.P., and files the following Reply to New Matter and avers as follows: 17. The statements in paragraph 17 of Defendant's New Matter constitute an incorporation paragraph to which no response is required. To the extent Plaintiff is required to answer, the same is denied, and strict proof is demanded at the time oftrial. 18. Conclusion oflaw, no response required. To the extent that Plaintiff is required to a,lswer, Plaintiff specifically deaies the allegations contained in this paragraph and demands strict proof thereof. By way of further response, any and all allegations or insinuations by the Defendant any wrong doing on the part of the Plaintiff are hereby specifically denied and strict proof is demanded at trial. - LAW OFFICES WOLPOFF & ABRAMSON, L.LP. ATTORNEYS iN THE PRACTICE OF DEBT COLLECTION 4660 TRINDLE ROAD THIRD FLOOR CAMP Hill, P1< 17011 717-303-6700 WHEREFORE, Plaintiff respectfully requests that this Honorable Court dismiss Defendant Richard Byamugisha's New Matter with prejudice and enter judgment in favor of Plaintiff and against Defendant, along with the allowable costs of this action, and such further relief as the Court deems just and appropriate. Respectfully submitted, we" Andrew C. Spears;-Esquire ill No. 87737 Wolpoff & Abramson, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3'd Floor Camp Hill, PA 17011 (717) 303-6700 Counsel for Plaintiff LAW OFFICES WOI.POFF & ABRAMSON, L.L.P. A1TORNEYS IN THE I'RACTICF. OF DEBT COLLECTION 4660 TRINDLE ROAD THIRD FLOOR CAMP Hill, FA 17011 117-303-6700 II VERIFICATION The undersigned hereby states that he/she is the attorney for the Plaintiff, Great Seneca Financial Corp., a Maryland Corporation, Assignee of Key Bank, who is located outside of this jurisdiction and in order to file the within document in an expedient and timely manner, he/she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Reply to New Matter are true and correct to the best of his/her 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. ~l~lo~ C Andrew C. Spears, Esquire ID No. 87737 Wolpoff & Abramson, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor Camp Hill, P A 17011 (717) 303-6700 Counsel for Plaintiff LAW OFFICES WOLPOFF & ABRAMSON, L.LP. A1TORNEYS IN THE PRACTICE OF DEBT COLLECTJO.'J 4660 TRINDlE ROAD THIRD FLOOR CAMP HilL, PA 17011 717-303-6700 I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF KEY BANK, Plaintiff No. 2005-6283 vs. CIVIL ACTION - LAW RICHARD BY AMUGISHA, Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that a copy of the foregoing Reply to New Matter has been served upon counsel for Defendant, by First Class Mail, Postage Pre-Paid, a copy thereof on this:ll day of February, 2006, to: Richard Byamugisha Apt.C-7 402 W. Crestwood Drive Camp Hill, P A 17011-1206 ~~ . Amy F. Doy e, ESquire ID No. 87062 Daniel F. Wolfson, Esquire ID No. 20617 Philip C. Warholic, Esquire ID No. 86341 Andrew C. Spears, Esquire ID No. 87737 David R. Galloway, Esquire ill No. 87326 Tonilyn M. Chippie, Esquire ill No. 87852 Wolpoff & Abramson, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3cd Floor Camp Hill, PA 17011 (717) 303-6700 Counsel for Plaintiff n (- ~ ....., o -n ~--I ~~ .J--n rn-.u! r-' ':G~'] .~ (1.1 (,..J ~:~., ~, pi c;,J -' -on ...l'_ -:~(:~ :,-l ~?) :<. en w GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF KEY BANK " IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO~ PENNSYLVANIA NO. 6283 CIVIL 2005 19 v. RICHARD BYAMUGISHA RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following fonn: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: ANDREW C. SPEARS, ESQUIRE respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of the plaintiff in the action is $ 8383 . 72 The counterclaim of the defendant in the action is N / A , counsel for the plaintiff/defendant in the above action (or actions), The following attorneys are interested in the case(s) as counselor are otherwise disqualified to sit as arbitrators: N/ A WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, ~~~ ORDER OF COURT AND NOW, , 19_, in consideration of the Esq., ,Esq., are appointed arbitrators in the above captioned action (or foregoing petition, Esq., and actions) as prayed for. By the Court, PJ. ~ ~ X) "'"- f- ~ .CJ1 /'.,;) = 0 C> = ." 0.... -- :2 () -.;...... :r.:::::;..lI rTJ~ 9-J "'"""'< '- r -orn ~ ~ N ;J)Y W ~=:~ (~) ~ W :? ~~~ a; vt -:::t:.. aNi - ~ ~ r:-? ~ :IJ ~ <::> -< ..~". GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF KEY BANK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNfY, PENNSYLVANIA NO. 6283 CIVIL 2005 19 v. RICHARD BYAMUGISHA RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following fonn: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: ANDREW C. SPEARS, ESQUIRE respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of the plaintiff in the action is $ 8383.72 The counterclaim of the defendant in the action is N / A ,counsel for the plaintiff/defendant in the above action (or actions), The following attomeys are interested in the case(s) as counselor are otherwise disqualified to sit as arbitrators: N/ A WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted. ~rc~ ORDER OF COURT fk;;u 02a(; AND NOW. ~ . .1-9_. in consideration of the foregoing pe~n. yrzf~ 'If. '-fJ1(! ftt ftlr' Esq.. ~ aJ. ~ Es~.. and _ ,X# 9 't{a h LA . Esq.. are appointed arbitrators in the above captioned action (or actIOns) as praye or. i ~~ ~ '-L. c~ ~. \ '<:Set; \ "S::. t) " t 2\.w u..~ ~ y~ t .... F.~ 'Orf> X) \-> "6Q... 'i - if- ~ \) 0 ...., '- C) ~ = ~ 9-.) = ....:( C7' ~ p:! :::": -l ~ :t.;'... :r: W -~ rn:::!J N .. -om a; <.It w :uy -- ?3 ~~,~ ~ $ '. -0 ,~~ ~+'i C -", ~ -"",. '>0 ~~ ~ ;,::)rn :-I -< 15 0 -< If) >- ..:t t:;; Ci:> :0 -. , - :d , .c::; -' '" f"" I ..... ..-. ..,,:.- ::::> ~ LU ....., ....~O- ...0 = ~j ~ b GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF KEY BANK, In The Court of Common Pleas of Cumberland Plaintiff RICHARD BYAMUGISHA County, Pennsylvania No. 2005 _ 6283 Defendant Civil Action - Law. Oath (\ We do sol~mn1y swear (or affirm) that we will support, obey and def~nd the Constitution of the United ;:~:~:,e Constitution of this C/i;,eaI~ ~ti we will diSCharge~dpUI office J4 ~p ! ~~l ~ Signa~ .,g-".-- , Signa e Marlin R. McCaleb Name (Chairman) Law Offices - Marlin R. McCaleb Law Firm TIN: 23-2393754 219 East Main Street Address David W. Knauer Name Knauer & Associates, LSC Gregory J. Katshir Name Law Finn Law Firm 4llA East Main Street Address. 900 Market Stre~t A.cl.c., , Mechanicsburg, PA 17055 Mechanicsburg, PA 17055 Lemoyne, PA 17043 City, Zip City, Zip' :#"15738 City, Zip :#- I BSqq Award We, the undersigned arbitrators, having been dilly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) We find in favor of the Plaintiff and against the Defendant in the amount of -=It lIiP q 1.0 $8,383.72. . Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: August 31, 2006 Date of Award: August 31, 2006 Notice of Entry of Award ~ Now, the ~sf day of AIJIltJ!:\f- ,20 OlL, , at 1:1./7 , ~.M., the above award was entered upon the docket and notic~ by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal; $ "'~94tt) By: Prothonotary Deputy /' C) f~ r-' C? C:J c:r> :t>'" c: G-:' W ~~ie& ~ 8-.31.0(, 40: A~ Spe4.rs ~ ~- t.ieho.nl ByQ.M\lSi....Cl eA o~ ~~ 10~e; p\A, 9(JeP o .,., ::::! rl"iJ:' I t? .-c'''' .-""'... );?:.-; "-~ .~t 2E ~ -.j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA oS NO. ))&--6283 CNIL TERM Great Seneca Financial Corp. Plaintiff vs. CIVIL ACTION - LAW Richard B yamugisha Defendant PRAECIPE FOR JUDGMENT ON ARBITRATION AWARD PURSUANT TO PA.R.CIV.P.1307(C) TO THE PROTHONOTARY: Enter Judgment on the arbitration award entered in these proceedings in favor of Great Seneca Financial Corp. and against Richard Byamugisha in the amount of $8,383.72 with interest of six percent (6%) from August 31,2006 and costs. Respectfully Submitted, </)lr Amy F. Doyle Philip C. Warholic David R. Galloway #87326 onilyn M. Chippie #8785 Ronald M. Abramson #94266 I ona Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, LLP I Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, P A 17011 (717) 303-6700 GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF KEY BANK, In The Court of Common Pleas of Cumberland Plaintiff County, Pennsylvania No. 2005 - 6283 RICHARD BYAMUGISHA Defendant Civil Action - Law. Oath (\ We do sol~mn1y swear (or affinn) that we will support, obey and def~nd the Constitution of the United ~:~:~:,e Constitution of this Coii~ 7 Ii we ml1 diSCharge~d~ office ~'" ~~p : ~ ~l .1fiU Signature ~ ,_ ' Signa e Marlin R. McCaleb Name (Chairman) Law Offices - Marlin R. McCaleb Law Firm TIN: 23-2393754 219 East Main Street Address David W. Knauer Name Knauer & Associates, LSC Gregory J. Katshir Name Law Finn Law Firm Mechanicsburg, PA 17055 411A East Main Street Addres2. Mechanicsburg, PA 17055 900 Market Stre~t AClclcc.u Lemoyne, PA 17043 City, Zip City, Zip :It 15738 City, . Zip =#" I BSqq Award We, the undersigned arbitrators, having been dilly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) We find in favor of the Plaintiff and against the Defendant in the amount of '=It HiD q l.o $8,383.72. . Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: August 31, 2006 Date of Award: August 31, 2006 Notice of Entry of Award Now, the otsf' day of Aua~+- . ,20 O~ , at /:'1,,/ ,"p".M., the above award was entered upon the docket and notic~ by mail to the parties or their attome1.s. R['. TRUE COPY FROM RECO, Arbitrators' compensation to be paid upon appeal: $ ~~~Q) in TmdlmoRywhereM 1 onto set my fk<;" r and 1M.. of saic'"J CarUsle, Pa. , , Pmfuonornry By. ~~~: ~A-:,-:?-I // (' f 3<.tJ(o ~l429 ~ I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-6283 CIVIL TERM Great Seneca Financial Corp. Plaintiff vs. CIVIL ACTION - LAW Richard B yamugisha Defendant CERTIFICATE OF SERVICE I, Kimberly L. Eisenhauer, an authorized agent of Wolpoff & Abramson, LLP, hereby certify that a copy of the foregoing award was served this I LP day of cr.-.1DiY r , 2006, by depositing same in the Post Office at Camp Hill, P A, first class mail, postage prepaid, addressed as follows: Richard' B yamugisha 402 W Crestwood Dr., Apt C7 Camp Hill, PA 17011 WOLPOFF & ABRAMSON, LLP By~vQStJ7ralOC 4660 Trindle Rd., 3rd Fl. Camp Hill, PA 17011 (717) 303-6700 -,:J (:) ~ "t; ..c 'f. ~ C> r-.:> 0 c.:.> ~ c;::l ....-".\ r:.'f" () .......\~ ,..~-.-.- 0 r -l:: ~ ..;b._ - \ ~ C 0" ~ VJ ~ -0 _-f">'" C) E- _.....,.,. - u.-) c:- .. 1 4 '--~ -/ f ~::'~ r0 ",/..: - . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. A MARYLAND CORPORATION, NO. 05-6283 CIVILTER Plaintiff vs. CIVIL ACTION - LAW RICHARD BYAMUGISHA Defendant(s) NOTICE OF JUDGMENT x Notice is hereby given that a JUDGMENT the above-captioned matter has N\en entered against you in the 8383.72 plus interest, on _~~O___~________, 20~~. amount of in $ x A copy of all documents filed with the prothonotary in support of the within judgment is/are attached. sian By: If you have any questions regarding this Notice, please contact the filing party. ----------------------------------------- Amy #87062 / Daniel F. Wolfson Philip #86341 / Andrew C. S ears David R. Galloway #87326 / Ronald M. Abramson #94266 / Rona Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. Counsel for Plainti Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 1701 (717) 303-6700 (This Notice is given in accordance with Pa.R.C.p. 236.) NOTICE SENT TO: RICHARD BYAMUGISHA 402 W CRESTWOOD DR APT C7 CAMP HILL PA 17011-1206 STNTC/PANOJ W&A FILE NO. 136627429 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • GREAT SENECA X83 • FINANCIAL CORP., r ; Plaintiff : No. - • VS. C "T3 _- : CIVIL ACTION c—) RICHARD BYAMUGISHA, : a� Defendants : = 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$8,383.72 plus costs was entered in Cumberland County on November 6, 2006. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on September 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 October 17, 2013. A certificate of Service is attached hereto as Exhibit"A". 6. As of November 5, 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. 812: Attorney for Plainti s P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 -2- • COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • GREAT SENECA • FINANCIAL CORP•, Plaintiff : No. 2005-14524 • vs. • CIVIL ACTION RICHARD BYAMUGISHA, • Defendants CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on October 17, 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: Richard Byamugisha, 402 W. Crestwood Drive, Apt. C7, Camp Hill, PA 17011. By: " — Ala• ' . Mege, Esquire tty. I.D. #81288 Attorney for Plaintiff P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • GREAT SENECA FINANCIAL CORP•, • 35- 1,.018,3 lnnc i ec1� t--; Plaintiff No. �s �,- _0--J • - vs. : CIVIL ACTION -� RICHARD BYAMUGISHA, Defendants • -- 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: November 5, 2013 By: A . • . Mege, Esquir- Atty. I.D. #81288 Attorney for Plai iff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 I , d'N' COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA : FINANCIAL CORP., • O6-LoA83 Plaintiff : No. - (.-, t,,, Fry., -% w ---+ vs. • zm o r�_n CIVIL ACTION uzr-° < ,rry RICHARD BYAMUGISHA : `�� c,,a C 7 ' Defendants • 2:* ` f� ORDER ib : AND NOW, this 13 day of Noveru,bcr , 2013, upon consideration of Plaintiff's Motion to Compel, and Defendant's response thereto, if any, it is hereby ORDERED that Plaintiff's Motion is GRANTED; and IT IS FURTHER ORDERED that Defendant must make full and complete answers to the interrogatories, without objection or motion for protective order, within twenty(20) days of the date of this Order or appropriate sanctions may be imposed upon Defendant following application to this Court. IT IS FURTHER ORDERED that counsel fees of$100.00 are awarded to Plaintiff and against Defendant as compensation for the preparation, service, and presentation of this motion, same to be paid within twenty (20) days of the date of this Order or appropriation. \\VL i I Distribution: - ; n R. Mege, Esq., 70 E Broad St., Bethlehem, PA 18016 Richard Byamugisl� , 402 W. Crestwood Drive, Apt. C7, Camp Hill, PA 17011 e I (r2a. 1 ilia PO ' ril COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • GREAT SENECA • FINANCIAL CORP., Plaintiff : No. 2005-6283 vs. • • CIVIL ACTION '�a ' RICHARD BYAMUGISHA, : -=`' Defendants • cn r <c CERTIFICATE OF SERVICE = ry I, Alan R. Mege, Esquire, hereby certify that on November 15, 2013, I served a true correct copy of the Court's November 13, 2013, Order by mailing same, first class, postage prepaid to: Richard Byamugisha, 402 W. Crestwood Drive, Apt. C7, Camp Hill, PA 17011. By: • an R. Mege, Esquire Atty. I.D. #81288 Attorney for Plaint',f P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426