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
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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-'
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,-.
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.
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-;'1
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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 _ ,-
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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
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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
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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