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HomeMy WebLinkAbout06-6199J: SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA 3451 Walnut Street Franklin Building, Room 216 Philadelphia, PA 19104 V. KIMBERLY TERESA ROBINSON 2017-B Mather Way Elkins Park, PA 19027 CUMBERLAND COUNTY COURT OF COMMON PLEAS Q(. - ?Q I Cpl U t t PRAECIPE Kindly docket the attached Judgment in the amount of $2,554.11 in favor of Plaintiff, University of Pennsylvania, and against the Defendant, Kimberly Teresa Robinson, for execution purposes only. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA 3451 Walnut Street Franklin Building, Room 216 Philadelphia, PA 19104 V. KIMBERLY TERESA ROBINSON 2017-B Mather Way Elkins Park, PA 19027 CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND The undersigned, being duly sworn according to law, deposes and says that the Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; that Defendant, Kimberly Teresa Robinson, is over eighteen (18) years of age, and resides at 2017-B Mather Way, Elkins Park, Pennsylvania 19027. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS OF 11C?9k-e - NOTARY / V'DAY COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL BRYAN W. SCHULTZ, Notary Public Concord Twp., Delaware County My Commission Expires June 10, 2010 J.'SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA 3451 Walnut Street Franklin Building, Room 216 Philadelphia, PA 19104 V. KIMBERLY TERESA ROBINSON 2017-B Mather Way Elkins Park, PA 19027 AFFIDAVIT CUMBERLAND COUNTY COURT OF COMMON PLEAS I, J. Scott Watson, Esquire, hereby certifies that the debt in the above matter is valid, enforceable and unsatisfied to date. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS )a-%AY OF CC / &P 2006. NOTARY COMMONVVEALrH OF PENNSYLVANIA NOTARIAL SEAL BRYAN W. SCHULTZ, Notary Public Concord Twp., Delaware County My Commission Expires June 10, 2010 J.-SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA 3451 Walnut Street Franklin Building, Room 216 Philadelphia, PA 19104 V. KIMBERLY TERESA ROBINSON 2017-B Mather Way Elkins Park, PA 19027 CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT I, J. Scott Watson, Esquire hereby certifies that the name and the last known address of Plaintiff and Defendant are as stated below: Plaintiff: University of Pennsylvania 3451 Walnut Street Franklin Building, Room 216 Philadelphia, PA 19104 Defendant: Kimberly Teresa Robinson 2017-B Mather Way Elkins Park, PA 19027 J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS /X DAY OF CW0 1W-/`_ 20? NOTARY +mmc7NWEALTH OF PENNSYLVAN NOTARIAL SEAL BRYAN W. SCHULTZ, Notary Public Concord Twp., Delaware County Ay Gorrnnission Exoires June 10, 2010 J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY 3451 Walnut Street COURT OF COMMON PLEAS Franklin Building, Room 216 Philadelphia, PA 19104 V. KIMBERLY TERESA ROBINSON 2017-B Mather Way Elkins Park, PA 19027 AFFIDAVIT OF NO APPEAL I, J. Scott Watson, Esquire, hereby certifies that the District Court judgement in the above matter was not appealed into a higher court to date. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS /,'DAY OF l/Clt if' 2006. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL BRYAN W. SCHULTZ, Notary Public Concord Twp., Delaware County NOTARY My Commission Expires June 10, 2010 COMMONWEALTH OF PENNSYLVANIA k z COUNTY OF PHILADELPHIA PHILADELPHIA MUNICIPAL COURT F LOUIS]. PRESENZA, PRESIDENT JUDGE CERTIFICATION OF JUDGMENT SC 05-12-27-8145 PLAINTIFF(S) DEFENDANT(S) University of Pennsylvania Kimberly Teresa Robinson 3451 Walnut Street 2017-B Mather Way Franklin Building, Room 216 Elkins Park, PA 19027 Philadelphia, PA 19104 THIS IS TO NOTIFY YOU THAT: X? JUDGMENT: For Plaintiff by Default X? JUDGMENT WAS ENTERED IN FAVOR OF: University of Pennsylvania X? JUDGMENT WAS ENTERED AGAINST: Kimberly Teresa Robinson X? IN THE AMOUNT OF: $2,554.11 DATE OF JUDGMENT: February 14, 2006 AMOUNT OF JUDGMENT 2 554.11 JUDGMENT COSTS INTEREST OF JUDGMENT ATTORNEY FEES TOTAL $2,554.11 POST JUDGMENT CREDITS POST JUDGMENT COSTS CERTIFIED JUDGMENT TOTAL $2,554.11 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENTS BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT FORM WITH YOUR NOTICE OF APPEAL. CERTIFIED FROM THE RECORD ON: PROTH A/ JOSEPH H. EVERS kRY OF PHILADELPHIA COUNTY BY: tL' C3 m cF Z 1M. ? ?; l 7 F OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY TO: Kimberly Teresa Robinson 2017-B Mather Way Elkins Park, PA 19027 UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY 3451 Walnut Street COURT OF COMMON PLEAS Franklin Building, Room 216 Philadelphia, PA 19104 V. KIMBERLY TERESA ROBINSON 2017-B Mather Way Elkins Park, PA 19027 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. PR THO ARY JUDGMENT BY DEFAULT X MONEY JUDGMENT JUDGMENT IN REPLEVIN JUDGMENT FOR POSSESSION If you have any questions concerning this Judgment, please call J. Scott Watson, Esquire at 610-358-9600. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Caption: University of Pennsylvania 3451 Walnut Street Philadelphia, PA 19104 VS. Kimberly Teresa Robinson 2017-B Mather Way Elkins Park, PA 19027 SSN XXX-XX-5230 PRAECIPE FOR WRIT OF EXECUTION ( ) Confessed Judgment ( X ) Other Writ of Execution Bank Attachment File No. 06-6199 Amount Due 2,554.11 Americhoice FCU 2175 Bumble Bee Hollow sll/14/07268.18 Mechanicsburg, PA ; Atty's Comm 17055 Garnishee : Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Qmberland for debt, interest and costs, upon the following described property of the defendant(s) Checking accounts, savings accounts, monies on deposit, safety deposit boxes, or County, any other personalty or realty which may be in the possession of the Garnishee belonging to the Defendant. GARNISHEE: Americhoice F.C.U., 2175 Bumble Bee Hollow Road Mechanicsburg, , i/Obb PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) checking accounts, savings accounts, monies on deposit, safety deposit boxes, or __any other personalty or realty which may be in the possession of the Garnishee bel=ing and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). to the defendant. (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date G 1/ `?1°' Signature: Print Name: Address: Attorney for: Telephone: Supreme Court ID No.: J. Scott Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 Plaintiff 610-358-9600 41060 (over) Notes: if real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. Ik -?- _ C= a Q 0 V MIt, r CD -n p (n p C r) ?D °? t F Y)3 y S ? C C> cn c WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6199 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIVERSITY OF PENNSYLVANIA, Plaintiff (s) From KIMBERLY TERESA ROBINSON, 2017-B Mather Way, Elkins Park, PA 19027 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: AMERICHOICE FCU, 2175 Bumble Bee Hollow Rd., Mechanicsburg, PA 17055 Checking accounts, savings accounts, monies on deposit, safety deposit boxes, or any other personalty or realty which may be in the posession of the Garnishee belonging to the Defendant. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) 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; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $2,554.11 Interest TO 11/14/17 -- $268.18 Atty's Comm % Atty Paid $47.00 Plaintiff Paid Date: 11/19/07 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs C is R. Long, Prothonot By: Nil Deputy REQUESTING PARTY: Name J. SCOTT WATSON, ESQUIRE Address: 24 REGENCY PLAZA GLEN MILLS, PA 19342 Attorney for: PLAINTIFF Telephone: 610-358-9600 Supreme Court ID No. 41060 SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-06199 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PENNSYLVANIA UNIVERSITY OF VS ROBINSON KIMBERLY TERESA And now TIM BLACK Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0010:45 Hours, on the 12th day of December-, 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , ROBINSON KIMBERLY TERESA in the hands, possession, or control of the within named Garnishee AMERICHOICE FCU 2175 BUMBLE HOLLOW ROAD MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to ELENA PAPOUTSIS (TELLER) , personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her Sheriff's Costs: So answ Docketing .00 Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 12/13/2007 Sworn and Subscribed to before me this day of By ,,,'Deputy Sheriff A.D 0 z) J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS V. KIMBERLY TERESA ROBINSON NO. 06-6199 INTERROGATORIES IN ATTACHMENT TO: AMERICHOICE F.C.U. 2175 Bumble Bee Hollow Road Mechanicsburg, PA 17055 You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. 1. At the time you were served or at any subsequent time, did you owe the Defendant any money or were you liable to the Defendant on any negotiable or other written instrument, or did the Defendant claim him that you owed the Defendant any money or were liable to the Defendant him for any reason ? 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the Defendant ? 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the Defendant or in which Defendant held or claimed any interest ? 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant had an interest ? 5. At the time before or after you were served did Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefor? 6. At any time after you were served did you pay, transfer or deliver any money or property to the Defendant or to any person or place pursuant to the Defendant's direction or otherwise discharge any claim of the Defendant against you? 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant have any funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. Section 8123? If so, identify each account. 9. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, exceeded the amount of the general monetary exemption under 42 Pa.C.S. Section 8123? If so, identify each account. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff DATE: December 21, 2007 C? d a'x r'?t t. , rn m F W N J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 BY: GREGORY J. ALLARD, ESQUIRE Identification Number 92218 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorneys for Plaintiff UNIVERSITY OF PENNSYLVANIA CUMBERLAND COUNTY COURT OF COMMON PLEAS v. KIMBERLY TERESA ROBINSON NO. 06-6199 ORDER TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, Americhoice F.C.U., discontinued upon payment of your costs only. 6d J. SCOTT WATSON, ESQUIRE GREGORY J. ALLARD, ESQUIRE Attorneys for Plaintiff D IN c ES C=o ? i c__, _ ' 3 CZ) Pennsylvania University VS Kimberly Theresa Robinson Writ of Execution Docket No. 2006-6199 Civil Term FILED- )ffiGE OF THE P;00'{!LP,'a()iARY 2009 AUG 31 A 11: 12 J ?!?Y R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned ABANDONDED. No action has been taken since December 31, 2007. Sheriff's Costs: Docketing $18.00 Surcharge 30.00 Garnishee 9.00 Mileage 10.56 Levy 20.00 Prothonotary 1.50 Poundage 1.78 $ 90.84 So Answers: R. Thomas Kline, Sheriff B Serge t q, 1"06 CO '; .0 LI- ck* 7 / yq( !,4-- a.3 00'16