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
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.;:,:
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.
~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
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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
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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
;,\
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,
.(;;:
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