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HomeMy WebLinkAbout06-1818 712 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., NO. ()l,., - IPI}> CiULl'--r8L~ P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff vs. HARVEY A SINGER Defendant(s) PRAECIPE FOR JUDGMENT Mr./Ms. Clerk: Please enter Judgment in favor of Plaintiff and against Defendant(s), HARVEY A SINGER and pursuant to the District Justice Transcript. ( X ) Amount due Less credi ts TOTAL $ 2229.84 $ $ 2229.84, plus interest and costs ( X) I certify that the foregoing assessment of damage. is for specified amounts alleged to be due in the complaint and i. calculable a. 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: 3f~~ Signature: 4/f) Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / AndrewC. ~ears #87737 David R. Galloway #87326 /cTOn:Cij/;;...H:.,ChkPie ]JVJI52 Ronald M. Abramson #94266 / Ronald S. Canter #94000 Bruce H. Cherki. #18837 WOLPOFF & ABRAMSON, L.L.P. / Coun.el for Plaintiff Attorney. in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 NOW, (Yl~nr J.. .:J.q ,20Dk....., JUDGMENT IS Prothon ;.sion By: Deputy .-1 'T 1':: ....L' .;:,: c:; . ~OMMONWEAL TH OF PENNSYLVANIA COUNTY OF: CUJlBERLAllD Mag. Dist. No 09-3-03 MDJ Name Hon Address. SUSAJ!iI Ie. DAY 229 MILL ST, BOX 167 MT. BOLLY SPRINGS, PA Telephooe. (717) 486-7672 17065 GREAT SBlIIBCA C/O WOLPOFF&ABRAJlSON 4660 TRIRDLE RD 3RD PLOOR CAMP BILL, PA 17011 THIS IS TO NOTIFY YOU THAT: Judgment: NOTICE OF JUDGMENTfTRANSCRIPT PLAINTIFF CIVIL CASE NAME all.d ADDRESS IaREAT SBRBCA PINAJ!iICIAL CORP I 4660 TRIRDLE RD 3RD FLOOR ~P BILL, PA 17011 ~ VS. DEFENDANT: NAME and ADDRESS 'sINGER, BAll.VEY A 37 N. BALTIMORE AVE. MT. BOLLY SPRINGS, PA 17065 L I .J Docket No.: CV-0000339-05 Date Filed: 10/20/05 DEFAULT JUDGMKRT PLTF [iJ [iJ Judgment was entered for: (Name) nvva.T a!R1II1I!('Ia. IPT'II'a.1I'l"Ta.T. l"nv'D Judgment was entered against: (Name) in the amount of $ ATWO'RR. JI']lRVKY ]I 12/01/00; 2 229 A4 on: o Defendants are jointly and severally liable. o Damages will be assessed on: o This case dismissed without prejudice, O Amount of Judgment Subject to Attachment/42 Pa,C,S. S 8127 $ o Portion of Judgment for physical damages arising out of residential lease $ J~J-05 Date I certify that this is a true " n /-1 O-(~ Date My commission expires first Monday 01 January, 20 AOPC 315.05 DATE PRINTED: 1/10/06 (Date of Judgment) (Date & Time) Amount of Judgment $ 2,144.34 Judgment Costs $ 85.50 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 2,229.84 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ , Magisterial District Judge , Magisterial District Judge SEAL ._~ . ,) let 5 G_~_~~~C / C_.._.. 9:42:24 AM , 0 ~ - ::0 \ #0- ~ ---- 1- ~ () r-.,' ,'-'~ c:? ...~/ ~ C' ~ -f1 ..:;~.... .. -, .--1 -- "'- lie \. ...~.~ T:~;17l M 0 I "J.)" ~ ;:0 _4f~_\ ~ --u r-.l :~}'C? 0-{) u::> ~:~ \~il, - .~~ ~ -c::: "-Z\ - ....--r.." "- -',. ~~;~ ~A \lS' ~ --a ,0 ,-.j c .-. ",;... .- ff' -" <.f1 ~ -'" CP (' ~ \ r ---i t, "-' ,-' 711 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : No. 0<"" - iflP CluL l82..-l-vI P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff vs. CIVIL ACTION - LAW HARVEY A SINGER Defendant(s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: GREAT SENECA FINANCIAL CORP., P.O. BOX 1651 ROCKVILLE, MD 20849-1651 and certify that the last known address of the within Defendant(s) is: HARVEY A SINGER 37 N BALTIMORE AVE MT HOLLY SPGS PA 17065 ~. ,;;;!';:~' "'062/06"., ,. ,,"," '206" Philip C. Warholic 1/86341 / ~!!re,,-C. Spea!"L. 1187737 David R. Galloway 1187326 <:rfo'!ill'T'....ll.. Chippief}87s-s,J Ronald M. Abramson 1/94266 / Ronald S. Canter 1/94000 Bruce H. Cherkis 1/18837 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 ^l~' n ,""', '::(1 ";.-J ,'",' t..:.:;. \.:) (i C) 710 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., No. 0(." - IP/f C~L>~L~~ : P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff vs. CIVIL ACTION - LAW : HARVEY A SINGER 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, HARVEY A SINGER , above-named, is over 21 years of age; is last known to reside at 37 N BALTIMORE AVE MT HOLLY SPGS PA 17065 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. COMMONWEALTH OF PENNSYLVANIA NOlarial Saal Kimberly L Eisenhauer, Notary Public Hampden Twp., Cumberland County My Commission Expires Nov. 17,2009 Member, Pennsylvania Association of Notaries "'~~~'06' I 0..,., ,. .."... "06" Philip C. Warholic 1186341 / And.r,ewC. Slleara .-1187737 David R. Galloway #87326 Q'T~niiYn H. Chippie #878~ Ronald M. Abramson 1194266 /l<cinaldS;' Canter--//94UOO Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (71 7) 303-6700 SWORN and SUBSCRIBED to before me this ~ day of 1vIf.t Y{ h , 2fllL., 6. mfxJ.i( if f1 r;u; MJK'AC No ary Public ;,\ ~-:;- '....l) ...0 , .(;;: 709 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., NO. 01... IPi? QIOL-L'--r~ : P.O. BOX 1651 ROCKVILLE, HD 20849-1651 Plaintiff : VS. CIVIL ACTION - LAW HARVEY A SINGER 37 N BALTIMORE AVE MT HOLLY SPGS PA 17065 : Defendant (s) NOTICE OF ORDER, DECREE OR JUDGMENT TO: HARVEY A SINGER 37 N BALTIMORE AVE MT HOLLY SPGS PA 17065 You are hereby notified that the entered against you on fYl';;lnrl of Pa. R.C.P. 236. following ORDER, :2'1 26Dh I DECREE or JUDGKENT 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 $ 2229.84, 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 ( ) ( X ) ( ) motor vehicle operator's Depart ent By: If you have any questions regarding this Notice, please contact the filing party. ~ Amy ~~Yle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / Andrew C. Spears #87737 David R. Galloway If8732tpr"TOnilyn 'M-:-ciiTi>pi'e~2 Ronald M. Abramson If94266-/ Rou.ald-S-."C'anhf.. If94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel f ntiff Attorneys in the Practice of Debt Co1 4660 Trindle Road, 3rd Floor, Camp Hi '11 / (717) 303-6700 (This Notice is ~iven in accordance with Pa. R.C.P. 236.) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVtNtR; -0 GREAT SENECA FINANCIAL CORP., : ` ': Plaintiff : No. 06-1818 CIVIL TERM n n, •.7 r— -« vs. •: r7 : CIVIL ACTION HARVEY A. SINGER, Js >=' • Defendant PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO INTERROGATORIES IN AID OF EXECUTION And now comes Plaintiff and submits the instant Motion to Compel, and in suppo thereof avers as follows: 1. Judgment for Plaintiff and against Defendant in the sum of$2,229.84 plus costs was entered in Cumberland County on March 29, 2006. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on October 8, 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 November 12, 2013. A certificate of Service is attached hereto as Exhibit"A". 6. As of November 12, 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 (2, 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. Ala s ' . • ege, Esq. Attorney ID No. 812: : Attorney for Plain ' fs P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 • -2- LAW OFFICES OF ALAN R. MEGE, ESQ. P.O. BOX 1426 70 EAST BROAD STREET BETHLEHEM, PA 18016-1426 Licensed in PA and NJ (610) 954-5393 Todd A. Johns, Esq. Of Counsel (610) 954-5395 FAX AlanM_Esq@;ur^.r..^m. November 12, 2013 Harvey A. Singer 37 N. Baltimore Ave Mount Holly Springs, PA 17065 RE: Great Seneca Financial Corp. v. Singer; Cumberland County#06-1818 Civil Term Dear Mr. Singer: Enclosed please find a copy of Plaintiffs Motion to Compel which we intend to file with the Court. Please provide your concurrence or non-concurrence with regard to said Motion by November 26, 2013. I would 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, an R. Mege ARM/cic Enc. This message is from a debt collector, this is an attempt to collect a debt, and any information obtained will be used for that purpose. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • GREAT SENECA FINANCIAL CORP•, Plaintiff : No. 06-1818 CIVIL TERM vs. : CIVIL ACTION HARVEY A. SINGER, • Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire,hereby certify that on November 12, 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: Harvey A. Singer 37 N. Baltimore Ave, Mount Holly Springs, PA 17065. By: Al. • ' . Mege, Esquire Atty. 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., : �� �� Plaintiff : No. 06-1818 CIVIL TERM gyp' LJ vs. • te : CIVIL ACTION - cry A, I- HARVEY A. SINGER, : - - cI Defendant • ORDER c.? AND NOW, this ir day of 2013, upon consideration of Plaintiff's Motion to Compel, and Defendant's response thereto, if any, it is hereby ORDERED that Plaintiffs 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 will 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. BY THE COURT: Distribution: Alan R. Mege, Esq., 70 E Broad St., Bethlehem, PA 18016 Harvey A. Singer, 37 N. Baltimore Ave, Mount Holly Springs, PA 17065 � ,6-/�a COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., : Plaintiff : No. 06-1818 CIVIL TERM vs. • rn c=3 rn 0-1 r*"-i CIVIL ACTION, HARVEY A. SINGER, on Defendant • <z; • CERTIFICATE OF SERVICE ' ' I, Alan R. Mege, Esquire, hereby certify that on December 11, 2013, I served upon Defendant a true correct copy of this Court's December 4,2013,Order by mailing same,first class, postage prepaid to: Harvey A. Singer, 37 N. Baltimore Ave, Mount Holly Springs, PA 17065. By: R. Mege, Esquir- Atty. I.D. #81288 Attorney for Plaintiff P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426