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HomeMy WebLinkAbout06-0558 611 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., NO. Olo - ~~p C;uLI€/z.~ P.O. BOX. 1651 ROCKVILLE, MD 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 Less credits TOTAL $ 5045.20 $ $ 5045.20, 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: ll).~/ 61t Signature: Daniel Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1120617 1187737 1187852 1194000 Amy F. oyle #87062 / Philip C. War olic #86341 / David R. Galloway #87326 / 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 (717) 303-6700 NOW" J~.) ,:;} ~ - , 20~, JUDGMENT I ion By: PRAEDJ/PANOJ W&A FILE NO. 135024027 \:::' Address THOMAS A. PLACBY 104 S SPORTXNG HXLL MBCBARXCSBORG, PA RD NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME <1nd ADDRESS 'GREAT SBRBCA l"XNARCXAL CORP. -, 4660 TRXRDLB ROAD C/O WOLPOl"l" & ABRAMSON ~AMP HXLL, PA 17011 ~ VS. COMMONWEAL TH'OF PENNSYLVANIA 'COUNTY OF: CUMBBRLAND Mag Dist. No 09-3-04 MDJ Name: Hon ",,,phoc, (717) 761-8230 17050 DEFENDANT: DSBL, DARLEE C 65 SXLVBR CROWN DR MECBARXCSBORG, PA 17050 L I, / .' I \( ,(\ ) .-~: / '''\''-) ../' Docket No.: CV-0000341-05 Date Filed: 6/24/05 NAME and ADDRESS -, GREAT SBNECA l"XNARC:tAL CORP. 4660 TRXRDLB ROAD C/O WOLPOl"l" & ABRAMSON CAMP HXLL, PA 17011 ~ a~_ ~ THIS IS TO NOTIFY YOU ,THAT: Ju~ment "..,,,., c, .i [il Judgment was entered for: (Name) ,DK"Il~T .TT11lmf~PLTl!' , t1l11f1L'I' A1l1I1fC"1. 1I'T'N'1LV('lT1LT. rnll'P [il Judgment was entered against: (Name) alIIA1U., nlt.VT.~ C! in the amount of $ 1;,040; 20 on: (Date of Judgment) 9/19/01; t f. r , , I o Defendants are jointly and severally liable. o Damages will be assessed on: o This case dismissed without prejudice. (Date & Time) O Amount of Judgment Subject to Attachment/42 Pa.C.S. 9 8127 $ o Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 4,929.70 Judgment Costs $ 115.50 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 5.045.20 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ANYPARTYHAS THE.RIGHT TO APPEAL WITHIN 30 DAYS AFT~R TH~ ~NTRY OF JUDGM~NT BY FILING A NOTICE .' j ,,' " I.",' ,." ....,,__ .".. ,,' '," .. " ",-'" OF APP~AL WITH THE f'!'lOTHONOTARY/CLERK OFJH~ COURT OF COMMON PL~AS, CIVIL DIVISION. YOU MUST INCLUDE A COpy OF THIS NOTIC~ OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTIC~ 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 JUDG~ IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. " ~ Date Magisterial District Judge I certify that this is a true a d correct co of the p oceedings containing the judgment. ~ Date , Magisterial District Judge My commission expires first Monday of January, 2010 SEAL AOPC 315-05 DATE PRXRTBD: 8/18/05 9:27:23 AM c~ '1- -r __ B ~ r ~ ~ ~ <"" t: () Jf:: l' ..0 \t- }J (.f\ -.... ~~ ~~ r l~:;), ~~} c__ \>,'7 r<) 6' -, ::...~ <-:-? - ~ ~ ~--- -' -. "- 610 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., No. Ols. - .r'5" P 0- I~ LLU~L. ~ " 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 FORWARD PROPERTIES, ASSIGNEE OF HOUSEHOLD 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 Amy F. Doyle #8 062 Philip C. War olic #86341 / David R. Galloway #87326 / Ronald M. Abramson #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 Andrew C. Spears Toni1yn M. Chippie Ronald S. Canter 1120617 1187737 1187852 1194000 PCRES/PANO] __W&A FILE NO. 135024027 ,. c-' c ~ ,.) ,-. 609 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., No. Ol&. - S'SP C!,-u~L ~~~ 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 OF CUMBERLAND 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, DARLEE ANSEL , above-named, is over 21 years of age; is last known to reside at 65 SILVER CROWN DR MECHANICSBURG PA 17050-1638 County of CUMBERLAND the United States or Servicemembers Civil , Pennsylvania; is not in the military service of its Allies, or otherwise within the provisions of the Relief Act and its Amendments. __CUMrl/l0NWEALTH OF PENNSYLVANIA i Notarial Seal l Kimberly L. Eisenhauer, Notary Public I Hampden Twp., Cumberland County ~ Commission F:.xpir8s Nov. 17,2009 Member, P01lnsivania Associati0n ot NOlaries LJ. Am F. Doy 1187062 / Philip C. rholic #86341 / David R. Galloway #87326 / 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 (717) 303-6700 Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter #20617 1187737 #87852 1194000 SWORN and SUBSCRIBED to before me this ;;J~ day of 0 n[Afl n { , 2r1JLP. ~~5l~ Nota y ublic ' PNMAFFlPANOJ W&A FILE NO. 135024027 c. C~) v (--) -;'1 -Jl 608 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., NO. 01- - S'sf C;CJ~L~~ \ P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff VS. DARLEE ANSEL CIVIL ACTION - LAW 65 SILVER CROWN DR MECHANICSBURG PA 17050-1638 Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT TO: DARLEE ANSEL 65 SILVER CROWN DR MECHANICSBURG PA 17050-1638 You are hereby notified that the following ORDER, entered against you on .J::t. ~ .:Jl,. ~r\rll.. of Pa. R.C.P. 236. I ( ) ( ) ( ) ( ) ( X ) ( ) DECREE or JUDGMENT has been in accordance with the provisions Decree Nisi in Equity Final Decree in Equity Judgment of ( ) Confession ( ) Defaul t ( ) Non-pros Judgment is in the amount of $ District Justice transcript of judgment of $ 5045.20, plus costs. If not satisfied within sixty (60) days, your license will be suspended by the Pennsylvania of Transportation. ( ( ( ) ) ) Verdict Non-suit Arbitration Award , plus costs. in civil action in the amount motor vehicle operator's Department k_ By: If you have filing party. contac 1120617 1187737 1187852 1194000 Amy F. oyle 1187062 / Philip C. Warhol c #86341 / David R. Gallowa #87326 / 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 / in accordance with Pa. R.C.P. 236.) Daniel F. Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter (717) 303-6700 (This Notice is given COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : Plaintiff No. 06-558-Civil Term vs. c°a CIVIL ACTION DARLEE ANSEL, M� rte` r=3 _ ,- =70 .>{: Defendant C'0 r— E c: S>C-0 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: August 6, 2013 By: n R. Wge, Esqu' e Atty. I.D. #8128 Attorney for P aintiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C-) Z2 . C:� GREAT SENECA FINANCIAL CORP., : Z Plaintiff No. 06-558-Civil Term -, -�A w C) VS. �--.�. --4c) CIVIL ACTION ` DARLEE ANSEL, � N C)c ze Defendant -i. t1- V r-q ;X 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$5,045.20 plus costs was entered in Cumberland County on January 26, 2006. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on August 6, 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 6, 2013. A certificate of Service is attached hereto as Exhibit"A". 6. As of September 6, 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. r 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. n R. Mege, Esq. Attorney ID No. 81 88 Attorney for Plain iffs 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. 06-558-Civil Term VS. CIVIL ACTION DAR-LEE ANSEL, Defendant CERTIFICATE OF SERVICE I,Alan R. Mege, Esquire, hereby certify that on September 6, 2013, 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: Darlee Ansel,65 Silver Crown Dr., Mechanicsburg. PA 17050. By: Al ege, Esquire Atty. I.D. #81288 Attorney for Plaintiff P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 GREAT SENECA IN THE COURT OF COMMON PLEAS OF FINANCIAL CORP., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION—LAW DARLEE ANSEL, Defendant NO. 06-558 CIVIL TERM PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO INTERROGATORIES IN AID OF EXECUTION ORDER OF COURT AND NOW, this 13`h day of September, 2013, upon consideration of Plaintiff's 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, Christyle L. Peck, J. Alan R. Mege, Esq. P.O. Box 1426 Bethlehem, PA 18016-1426 Attorney for Plaintiff �, Darlee Ansel 65 Silver Crown Drive am = :.. Mechanicsburg, PA 17050 - , - rill Defendant, pro Se :rc =CD Pa 9// f�3 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA t-; c t C 'r GREAT SENECA FINANCIAL CORP. CIO Plaintiff No. 06-558-Civil Term � ` '- �, ry mss, • rte—� c.,3 c,,�:' VS. ; CIVIL ACTION DARLEE ANSEL, ' ` ' Defendant CERTIFICATE OF SERVICE I,Alan R. Mege,Esquire,hereby certify that on September 19,2013,I served a true correct copy of the Court's September 13, 2013 Rule by mailing same, first class, postage prepaid to: Darlee Ansel, 65 Silver Crown Dr., Mechanicsburg. PA 17050. By: an R. Mege, Esquir -Atty. I.D. #81288 Attorney for Plain ff P.O. Box 1426 70 East Broad S . Bethlehem, PA 18016-1426 GREAT SENECA : IN THE COURT OF COMMON PLEAS OF FINANCIAL CORP., : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL ACTION—LAW DARLEE ANSEL, • Defendant : NO. 06-558 CIVIL TERM PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO INTERROGATORIES IN AID OF EXECUTION ORDER OF COURT AND NOW, this 6th day of November, 2013, upon consideration of Plaintiff's Motion To Compel Defendant's Answers to Interrogatories in Aid of Execution, and of Defendant's response thereto stating that "this is from 17 years ago and it was not my bill I was only a co-signer and it is from 17 years ago the time is expired," and upon further consideration of 42 Pa. C.S.A. §5529 (providing that execution against personal property must be issued within 20 years after the entry of the judgment upon which the execution is to be issued), Plaintiff's motion to compel is granted and Defendant shall provide answers to the interrogatories within 30 days of the date of this Order. BY THE COURT, / < Christy Beck, J. Alan R. Me Es ge� Esq. 9 P.O. Box 1426 Bethlehem, PA 18016-1426 ' Attorney for Plaintiff -ox w T rn ac -47 ..: ,/Darlee Ansel r o 65 Silver Crown Drive r- c2, Mechanicsburg, PA 17050 >r) Defendant, pro Se :rc cd 1 es "a /00P 3 . � 1,17) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : Plaintiff No. 06-558-Civil Term 5. = rnrn :jr _:.• V S. t- -►. : CIVIL ACTION n r -r DARLEE ANSEL, Defendant • c 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$5,045.20 plus costs was entered in Cumberland County on January 26, 2006. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on August 6, 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 November 6, 2013 requiring Defendant, within twenty(20) days, to make full and complete answers to Interrogatories. A true and correct copy of the November 6, 2013 Order is attached as Exhibit 5. As of January 9, 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 9, 2014. A Certificate of Service is attached hereto. 7. Counsel for Plaintiff sent correspondence to Defendant on December 18, 2013, seeking concurrence, and Defendant is unopposed. 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 November 6, 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 will be imposed upon Defendant following application to this Court. an R. Mege, Esq. Attorney ID No. 8 " 88 Attorney for Pl.' tiff 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 Plaintiff v. : CIVIL ACTION—LAW DARLEE ANSEL, • Defendant : NO. 06-558 CIVIL TERM PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO INTERROGATORIES IN AID OF EXECUTION ORDER OF COURT AND NOW, this 6th day of November, 2013, upon consideration of Plaintiff's Motion To Compel Defendant's Answers to Interrogatories in Aid of Execution, and of Defendant's response thereto stating that "this is from 17 years ago and it was not my bill I was only a co-signer and it is from 17 years ago the time is expired," and upon further consideration of 42 Pa. C.S.A. §5529 (providing that execution against personal property must be issued within 20 years after the entry of the judgment upon which the execution is to be issued), Plaintiffs motion to compel is granted and Defendant shall provide answers to the interrogatories within 30 days of the date of this Order. BY THE COURT, Christylte L. eck, J. Al. ' ' . Mege, Esq. P 4. Box 1426 ethlehem, PA 18016-1426 Attorney for Plaintiff 3 , —; =� zrn (75 p rn Darlee Ansel N 65 Silver Crown Drive -<3' as ° Mechanicsburg, PA 17050 110\ ; 7. 2013 <� ;�: g <-) Defendant, pro Se • _ . -- n= � 'Y"? :rc 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 December 18, 2013 Darlee Ansel 65 Silver Crown Dr. Mechanicsburg. PA 17050 RE: Great Seneca Financial Corp v. Ansel #06-558-Civil Term Dear Ms. Ansel: You are in contempt of the Court's November 6, 2013 Order directing you to provide answers to the interrogatories. Because of this our office intends to file a Motion for Sanctions. Please notify our office of your disposition concerning same by January 3, 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 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. • t / • COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : Plaintiff : No. 06-558-Civil Term • vs. : CIVIL ACTION DARLEE ANSEL, • Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on January 9, 2014, I served upon Defendant,a true and correct copy of Plaintiff's Motion for Sanctions and proposed Order by mailing same,first class,postage prepaid to:Darlee Ansel,65 Silver Crown Dr.,Mechanicsburg,PA 17050. By: Al. ' . Mege, Esquire tty. I.D. #81288 Attorney for Plai iff P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 GREAT SENECA FINANCIAL CORP., Plaintiff v. DARLEE ANSEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION — LAW : NO. 06-558 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 served on the Defendant on August 6, 2013, for a judgment that was entered against the Defendant on September 16, 2005, the motion for sanctions is denied at this time. Alan R. Mege, Esq. P.O. Box 1426 Bethlehem, PA 18016-1426 Attorney for Plaintiff Darlee Ansel 65 Silver Crown Drive Mechanicsburg, PA 17050 Defendant, pro Se :re eiV, es nut_ red BY THE COURT, Chri y ee L. Peck, rn - r. • -1C) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL DIVISION Great Seneca Financial Corp v. Darlee Ansel To the Clerk of Courts: Case No, 06 -558 -Civil Term Amount Due $5045.20 Interest from January 23, 2006 = $2,623.50 for a total of $7,668.70 Atty's Fee** Costs to be added b PRAECIPE FOR WRIT OF EXECUTION Issue a writ of execution in the above matter, (1) direct the Sheriff of Cumberland (2) against Darlee Ansel r� t o Aa 'cp D CD -r? y1� � ^ ` 86 - county; 1county; , defendant(s) and`>on:e (Name of Defendant(s)) following described property of the defendant(s) All tanglible personal property of the defendant located at 65 Silver Crown Dr. Mechanicsburg, PA 17050 (Supply four copies of lengthy personalty list) (if real property supply six copies of the description) (3) against , garnishee(s) for the following property: 1.0.8.50 PD ATn° rt 45 0,11F r 4ry.7& Po any (4) and enter this writ in the judgment index (a) against , defendant(s) and (b) against , as garnishee(s) as a lis pendens against real property of the defendant in name of garnishee as follows: Date: 9/30/14 las .fie ' 5011 - (Specifically described property) Signature: Print Nara :: • an R. Melte, Esq. Address: PO Box 1426, Bethl- em, PA 18016-1426 Attomey for: Plaintiff Telephone: (610) 954-5393 Supreme Court ID No: 81288 ** Where judgment has been entered under Rule 2951(a), attorneys' fees may be included if they are authorized in the instrument and there has been a record appearance of counsel at any stage of the proceedings. c#a5a 31A/3/ I,0rri-o & ° Pa.R.C.P. 3251 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suitel00 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net GREAT SENECA FINANCIAL CORP. Vs. NO 06-558 Civil Term CIVIL ACTION — LAW DARLEE ANSEL WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against DARLEE ANSEL, 65 Silver Crown Drive, Mechanicsburg, PA 17050, Defendant (s) (1) 'you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; All tangible personal property of the defendant located at 65 Silver Crown Dr, Mechanicsburg, PA 17050. (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. 1 (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $5,045.20 Interest from 1/23/06 @ - $2,623.50 Attorney's Comm. % Attorney Paid $47.75 Date:. 10/9/14 REQUESTING PARTY: Name : ' ALAN R. MEGE, ESQUIRE Address: LAW OFFICES OF ALAN MEGE PO BOX 1426 BETHLEHEM, PA 18016-1426 Attorney for: PLAINTIFF Telephone: 610-954-5393 Supreme Court ID No. 81288 Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs Waal/ David D. uell, Prothonot. By: Deputy MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL DIVISION GREAT SENECA FINANCIAL CORP. ASSIGNEE OF FORWARD PROPERTIES; : Case No. 05 -5825 -CIVIL TERM ASSIGNEE OF METRIS Amount Due $10,686.26 v. Interest from January 23, 2006 @6% = $5,610.29 for a total of $16,296.55 1.-.3r BRENDA YOHE Atty's Fee** CI C `` Costs to be added„,� .- —I�_ rnt:11 C) Z ▪ rT1t”" =irJ -4 "'i7r*a r tn PRAECIPE FOR WRIT OF EXECUTION r-= To the Clerk of Courts:• CD-n :ro = fir`- Issue a writ of execution in the above matter, 7>z-' (1) direct the Sheriff of Cumberland county; (2) against BRENDA YOHE , defendant(s) and upon the (Name of Defendant(s)) following described property of the defendant(s) All tanglible personal property of the defendant located at 802 Ritner Highway Apt 1 Shippensburg, PA 17257 (Supply four copies of lengthy personalty list) (if real property supply six copies of the description) (3) against , garnishee(s) for the following property: (4) and enter this writ in the judgment index ,a8.5o PA Am (a) against , defendant(s) 48.i(0 CBF and 50 (b) against , as garnishee(s) q. oo as a lis pendens against real property of the defendant in name of garnishee as follows: lel.t(� PbfaTrt Date: 9/30/14 4a.a,5 Que ,r7 • 6o L_L ,*3Ia Iia ,Utrt oP ** Where judgment has been entered under Rule 2951(a), attorneys' fees may be included if they are authorized cJin the instrument and there has been a record appearance of counsel at any stage of the proceedings. (Specifically described property) Signature: Print Name: Alan R. Melte, Esq. Address: PO Box 1426, Bethlehem, PA 18016-1426 Attorney for: Plaintiff Telephone: (610) 954-5393 Supreme Court ID No: 81288 Pa.R.C.P. 3251 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net GREAT SENECA FINANCIAL CORP. Assignee of FORWARD PROPERTIES; Assignee of METRIS Vs. NO 05-5825 Civil Term CIVIL ACTION — LAW BRENDA YOHE WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against BRENDA YOHE, 802 Ritner Highway Apt 1 Shippensburg, PA 17257, Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; All tangible personal property of the defendant located at 802 Ritner Highway Apt 1, Shippensburg PA 17257. (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $10,686.26 Interest from 1/23/06 @ 6% - $5,610.29 Attorney's Comm. % Attorney Paid $141.16 Date: 10/9/14 REQUESTING PARTY: Name : ALAN R. MEGE, ESQUIRE Address: LAW OFFICES OF ALAN MEGE PO BOX 1426 BETHLEHEM, PA 18016-1426 Attorney for: PLAINTIFF Telephone: 610-954-5393 Supreme Court ID No. 81288 Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs David D.el1, rothonota By: Deputy MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 2 m m CD DI Cilitthei-6. Wr— C°3 <C) Zi —‹ —4 QF,F * FT', Great Seneca Financial Corp vs. Darlee C Ansel Case Number 2006-558 SHERIFF'S RETURN OF SERVICE 10/22/2014 05:06 PM - Shawn Gutshall, Deputy , being duly sworn according to law, states that on October 22, 2014 at 5:06 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: Darlee C Ansel at 65 Silver Crown Drive, Silver Spring Township, Mechanicsburg, PA 17055, 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 10-23-14. 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: $75.49 SO ANSWERS, October 29, 2014 (c) CountySuite Sheriff, Teleosof, Inc. RONNY R ANDERSON, SHERIFF 3 /. 03