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Home My WebLink About02-2612BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street · Suite 600 Philadclphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 l !:ereby certif5 that i flare served ~ ~'.,v,... oftins' ' paper upon all other ~;~ ),~r ~eir attorneys by: ~,¥~;/~!,ar mail ~ c~rtificd r. zail TEMPLE UNIVERSITY 1801 N. Broad Street Phila., PA 19122 Plaintiff ~S. MARY J. McGEE 318 Spring Lane Enola, PA 17025 Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION PRAECIPE TO TRANSFER JUDGMENT TO THE PROTHONOTARY: Please enter judgment against the above captioned Defendant in accordance with Pennsylvania Rules of Civil Procedure 3002 as tbllows: Amount of Judgment entered in the Philadelphia Municipal Court Court Costs Interest at 6% from 09/13/01 to 02/13/02 Less payments $3,578.50 + 5.00 + 88.20 21.50 AMOUNT OF JUDGMENT $3,650.20 GORDIN & BERGER, P.C. By: EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff TEMPLE UNIVERSITY (A PA Corp. not for Profit) Plaintiff PHILADELPHIA MUNICIPAL COURT FIRST JUDICIAL DISTRICT OF PENNSYLVANIA 34 South 1 lth Street, Philadelphia, PA 19107 ~ble Louis J. Presenza, President Judge 1801 NORTH BROAD STREET PHILADELPHIA PA 19122 Honorable Robert S. Blasi, Administratlve Judfie SC Number 01-07-24-8039 : MARY J. McGEE, f/k/a MARY 318 SPRING LANE ENOLA PA 17025 · JOHNSON : Defendant STATEMENT OF CLAIM PlaintilTis seeking a money judgment against the Defendant based on the following claim: While Defendant was enrolled at TEMPLE UNIVERSITY, Defendant did execute Promissory Notes to which Defendant was advanced by Plaintiff the sum of $3,200.00 as PERKINS LOANS. Copies of said Notes are attached hereto as Exhibit A. As set forth in the Affidavit, there remains outstanding an unpaid principal balance of $2,110.52, plus accrued interest of $208.80, as of JULY 2, 2001. A copy of said Affidavit is attached as Exhibit B. Defendant is liable for all attorney's fees and related court costs and charges for the collection of any amount not paid when due. Said attorney's fees at the rate of 50% amount to $1,159.66. AMOUNT CLAIMED Principal $. 2,110.52 Interest $. 208.80 Attorney Fees $. 1,159.66 Other Fees $. Subtotal $ 3~478.98 Court Service $ 40.00 State Fee $ 1.50 Court Costs $ 32.00 Automation Fee $ 5.oo TOTAL CLAIMED $ 3,557.48 I, the undersigned, verify and depose that the facts set forth in this Complaint are true and correct and acknowledge that I am subject to the penalties of 18 P.S. 4904 relating to Unswom Falsification to Authorities. Edward L. Berger Address 1760 Market Street Suite 600 Atty. ID# 34116 Signature Plaintiff/Attorney Philadelphia -1 19103 Phone# 215-564-2031 YOU HAVE BEEN SUED - READ THE ATTACHED NOTICES If you wish to resolve this matter without appearing in court, please contact the attorney shown above immediately. COMMONWEALTH OF PENNSYLVANIA The Philadelphia Municipal Court 34S. 11TH ST., PHILA., Pl. 19107 Louis J. Presenza, President Judge Robert S. Blasi, Administrative Judge STATEMENT OF CLAIM sc: 01-07-24.8039 Plaintiff(s) Defendant(s) TEMPLE UNIVERSITY (A PA Corp. not 1801 NORTH BROAD STREET MARY J. McGEE, f/Ida MARY 318 SPRING LANE ENOLA PA 17025 for Profit) PHILADELPHIA PA 19122 JOHNSON I.CONTINUED TO DATE: 2. CONTINUED TO DATE: 3. CONTINUED TO DATE: Time I.oom Time ]Room Time Plaintiff Appeared Defendant Appeared Plaintiff Appeared Defendant Appeared Plaintiff Appeared Defendant Appeared I lYES [ I NO [ lYES [ I NO [ lYES [ I NO I IYES [ I NO ! lYES [ I NO I IYES I I NO JUDGE JUDGE JUDGE Trial Disposition Plaintiff ATTY. NO. Appeared · [ X ] Did Not Appear [ ] 34116 Defendant ] ATTY. NO. Appeared I×] Did Not Appear I ] I 60[ ] No Service - Dis:nissed WITHOUT Prejudice. 83[ ] Withdrawn with Prejudice. 80 l XI Judgment by A;: reemcnt (See Remarks). 841 ] Case Settled, Discontinued, and Ended. 55 [ ] Venue transfer ~¥ithin the Commonwealth - transfer to 85 [ ] Case transferred to Common Pleas Court County. Court No. 82 [ ] Withdrawn h'c .~ Court List without Prejudice (will be relisted upon receipt orletter from either party). 91 [ ] Case to be consolidated with S.C.# 61 [ I Judgment ~or Ph, h*tiff b) Default Plus interest from __.AmountS. Time of judgmen: ---- Costs$ 62 I ] Judgment I,~r P : tiffp ts nterest from Time of judgment __ __ AmountS. Costs$. 70 J l Judgment for Defendant. 71 I } Judgment fi~r Defendant as Plaintiff in Counterclaim Amount $ 81 [ ] Judgmc~;t for '>efendant by Default. 72[ l Judgment for Plaintiff as a Defendant on Counterclaim Amount REMARK~ Judgement by ag[:eme ',t in the amount of $3578.50 DATE September 13, 2001 JUDGE Robert S. Blasi MB ZQ22 MCV1 ISSUE AMT. 3478..98 01-07-24-80390 SC 002 DISPOSED FEE INCIDENT 78 07/02/01 A/DF SC TYPE COMERCIAL PAPER M.V. ---- NEXT HEARING ..... ******** PLAINTIFF INFORMATION ******* TEMPLE UNIV A P A CORP 1801 N BROAD ST PHILA. PA 19122 ATTY 034116 BERGER EDWARD ******** DEFENDANT INFORMATION MCGEE MARY J 318 SPRING LANE ENOLA. PA 17025 PREMISES PROP AT PHILA. PA 19100 COURT ACTIVITY HEARING #01 09/13/01 4A JUDG 379 BLASI DISP 80-JUDG BY AGREEMNT FINE+COST 3578.50 JUDG FOR PL 3578.50 PRESS ENTER FOR PAGE 1 INFORMATION P/1 judgment certified in the a~ount of $3578.50 cost included BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street- Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 TEMPLE UNIVERSITY 1801 N. Broad Street Phila., PA 19122 Plaintiff VS. MARY J. McGEE 318 Spring Lane Enola, PA 17025 Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION ASSESSMENT OF DAMAGES AND NOW, to wit, this___ t_,~94..Xday of /~_~,d _2002, Judgment is entered in favor of the / above referenced Plaintiff, and against MARY J. McGEE, the above referenced Defendant, for failure to file an Answer m~d Plaimiffs damages are assessed in the sum of $3,650.20. BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street · Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 TEMPLE UNIVERSITY 1801 N. Broad Street Phila., PA 19122 Plaintiff VS. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION MARY J. McGEE 318 Spring Lane Enola, PA 17025 Defendant NO. 0:2- AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : .' SS COUNTY OF PHILADELPHIA : EDWARD L. BERGER, ESQUIRE, being duly sworn according to law, hereby deposes and says that I am the attorney for the Plaintiff in the above captioned action, and that the following Defendant is not in the Military Service of the United States of America or any State or Territory thereof. or its allies, and that the Defendant is not in any manner subject to the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940, as amended: Ms. Mary J. McGee 318 Spring Lane Enola, PA 17025 SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY B '~ hia ~' ~ County Ciot pt~tladel .... 5 EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff OFFICE To: Ms. Mary j. b~Cee 318 Spring Lane Enola, PA 17025 OF THE PROTHONOTARY cOURT OF COMMON PLEAS VS. CUMB~A%~) COUNTY : COURT OF COMMON PLEAS . : Term, 19 -. : NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as i~dicated below ~,7) ~ Prothonotar~ [] Judgment by Default II'II Money Judgment ~-] Judgment in Replevin [] Judgment for Possession [] Judgment on Award of Arbitration [] Judgment on Verdict [--1 Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY EDWARD L. BERGEN Esquire (Insert Attorney' x N,~n e) at this telephone number: (2]_5} 564-203[ IN' THE COURT OF COMMON PLEAS OF CUMBERI ~4,ND COUNTY, PENNSYLVANIA CIVIL DIVISION TEMPLE UNIVERSITY MARY J. McGEE- 160-48-7851 File No. 02-2612 Civil Term Amount Due $3,650.20 Interest Atty's Comm Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out ora 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. PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter to the Sheriffof CUMBERLAND County, for debt, interest and costs upon the following described property of the Defendant(s) ALL CONTENTS OF DEFENDANT'S RESIDENCE~ INCLUDING BUT NOT LIMITED TO ALL FURNITURE~ CLOTHIN~ JEWELRY~ ELECTRONI~UIPMENT: ELECTRICAL APPLIANCES~ KITCHEN UTENSILS~ SILVERWAREs_ TELEVISIONS STEROR E UIPMENT~ TOOLS AND ANY OTHER PROPERTY SUBJECT TO LEVY LOCATED AT 318aSSPRING LANE ENOLA PA 17025A 19508 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) and all other property of the Defendant(s) in the possession, custody or control of the said Garnishee(s). of the D~endantts) desc..n.',bed in the attached exhibit· Signature: Print Name: Address: (Indicate) Index this writ against the Garnishee(s) as a lis pendens against real estate Edward L. Berger, E~ Gordin & Berger, P.C. 1760 Market Street, Suite 600 Attorney for: Telephone: Supreme Court ID No. Philadelphia, PA 19103 Plaintiff 215-564-2031 34116 Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (Pa. R.C.P No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-2612 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TEMPLE UNIVERSITY, Plaintiff (s) From MARY J. MCGEE, 318 SPRING LANE, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL CONTENTS OF DEFENDANT'S RESIDENCE, INCLUDING BUT NOT LIMITED TO ALL FURNITURE, CLOTHING, JEWELRY, ELECTRONIC EQUIPMENT, ELECTRICAL APPLIANCES, KITCHEN UTENSILS, SILVERWARE, TELEVISIONS, STEREO EQUIPMENT, TOOLS AND ANY OTHER PROPERTY SUBJECT TO LEVY LOCATED AT 318 SPRING LANE, ENOLA, PA 17025. (2) Y°u are als° directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: 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 $3,650.20 Interest Atty's Cornm % Arty Paid $32.50 Plaintiff Paid Date: OCTOBER 29, 2002 L.L. $.50 Due Prothy $I.00 Other Costs (Seal) REQUESTING PARTY: Name EDWARD L. BERGER, ESQUIRE Address: GORDIN & BERGER, P.C. 1760 MARKET STREET, SUITE 600 PHILADELPHIA, PA 19103 CURTIS R. LONG Prothon~ Deputy Attorney for: PLAINTIFF Telephone: 215-564-2031 Supreme Court ID No. 34116 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-2612 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TEMPLE UNIVERSITY, Plaintiff (s) From MARY J. MCGEE, 318 SPRING LANE, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL CONTENTS OF DEFENDANT'S RESIDENCE, INCLUDING BUT NOT LIMITED TO ALL FURNITURE, CLOTHING, JEWELRY, ELECTRONIC EQUIPMENT, ELECTRICAL APPLIANCES, KITCHEN UTENSILS, SILVERWARE, TELEVISIONS, STEREO EQUIPMENT, TOOLS AND ANY OTHER PROPERTY SUBJECT TO LEVY LOCATED AT 318 SPRING LANE, ENOLA, PA 17025. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: 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 gamishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $3,650.20 Interest Atty's Comm % Atty Paid $32.50 Plaintiff Paid Date: OCTOBER 29, 2002 (Seal) REQUESTiNG PARTY: Name EDWARD L. BERGER, ESQUIRE Address: GORDIN & BERGER, P.C. 1760 MARKET STREET, SUITE 600 PHILADELPHIA, PA 19103 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG erothono~.~y Deputy Attorney for: PLAINTIFF Telephone: 215-564-2031 Supreme Court ID No. 34116 R..Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing $ 18.00 Poundage 1.39 Advertising Law Library .50 Prothonotary 1.00 Mileage 10.35 Misc. Surcharge 20.00 Levy 20. oo Post Pone Sale Garnishee 71.24 Sworn and Subscribed to before me This 2?ffdayof ~ 2002 A.D. (~,~, (? ~'l,t~}_~5 ~ /PrOthonotary Advance Costs: Sheriff's Costs: 150.00 71.24 /8.lb Refunded to Atty on 12 / 13/(52 R. Thomas Kline, Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERL'AND COUNTY, PENNSYLVANIA CIVIL DIVISION TEMPLE UNIVERSITY 1801 North Broad Street Philadelphia, PA 19122 MARY J. MCGEE 1003 LOUSIA LANE MECHANICSBURG, PA 17050 SS# 160-48-7851 File No. 02-2612 Amount Due $3.650.20 Less Payment $ 900.00 Interest 05/29/02 Atty's Comm Costs TO THE PROTHONOTARY OF THE $4ID COURT: The undersigned hereby certifies that the below does not arise out ora 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. PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter to the Sheriff of CUMBERLAND County, for debt, interest and costs upon tl~e following described property of the Defendant(s) All contents of Defendant's residence, including but not limited to all furniture, clothing, jewelry, electronic et~uioment, electrical appliances, kitchen utensils, silverware, televisions, stereo eauioment. tools and any other orooertv subieet to lew located at 1003 LOUSIA LANE, MECHANICSBURG, PA 17050 PRAECIPE FOR ATTACHM};NT EXECUTION Issue wri! of attachment to the She"iff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the lbllowing property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the Defendant(s) in the possession, custody or control of the said Garnishee(s). (Indicate) Index this writ against the Garnishee(s) as a lis pendens against real estate of the Detbndant(st) described in the attached exhibit. Print Name: Address: Attorney for; Telephone: _ Edward L. Berber. Esquire Gordin & Berger, P.C. 1760 Market Street. Suite 600 Philadelphia, PA 19103 ___ Plaintiff 215-564-2031 Supreme Court ID No. __ 34116 Notes: If real property, supply six copies of description including improvements and an original arid copy o f affidavit of ownership (Pa. R.C.P No. 3129). If lengthy personalty list, supply four copies of list. To index vvrit, file separate praecipe with writ. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OFPENNSYLVANIA) NO 02-2612 Civil COUNTY OF CUMBERLAND) CIVIL ACTION LAW TO TIlE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TEMPLE UNIVERSITY, Plaintiff (s) From MARY J. MCGEE, 1003 LOUSIA LANE, MECHANICSBURG, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL CONTENTS OF DEFENDANT'S RESIDENCE, INCLUDING BUT NOT LIMITED TO ALL FURNITURE, CLOTHING, JEWELRY, ELECTRONIC EQUIPMENT, ELECTRICAL APPLIANCES, KITCIlEN UTENSILS, SILVERWARE, TELEVISIONS, STEREO EQUIPMENT, TOOLS AND ANY OTHER PROPERTY SUBJECT TO LEVY LOCATED AT 1003 LOUISA LANE, MECIIANICSBURG, 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 follows: 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 $3,650.20 Interest Atty's Comm % Arty Paid $116.24 Plaintiff Paid Date: AUGUST 24, 2004 (Seal) REQUESTING PARTY: Name EDWARD L. BERGER, ESQUIRE Address: GORDIN & BERGER, P.C. 1760 MARKET STREET, SUITE 600 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-564-2031 Supreme Court ID No. 34116 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothono~ By: ~_~ Deputy ~ ~' t:::::':'::.:" !b&- l!::!b.c. ,11=; ,.. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee TOTAL $ 18.00 1.36 1.00 8.88 20.00 20.00 9.00 69.24 Sworn and Subscribed to before me This ~rz; day of 4/t~ q , - 2004 A.D. /:r' ~ (J :"rh/fI~ / ~ r honotary 11 <:'~il"d ..), < J - C' 7 3n1 , . kH ;U,~c}, . . ,:j:U Advance Costs: Sheriff s Costs: 150.00 69.24 $ 80.76 Refunded to Atty on 11/08/04 So Answers; ~ ~.. .' ,.~~ ~. ,?omas Kli7\ Shenff ~~LJ-~~t(/ By Claudia A. Brewbaker c;;- \", ~ .' t biL. es. l.if<I ,'--' C:Je.., '17 '8{,. q f2.u. / ~~FrJ ~:L WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02.2612 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due TEMPLE UNIVERSITY, Plaintiff (s) From MARY J. MCGEE, 1003 LOUSlA LANE, MECHANICSBURG, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL CONTENTS OF DEFENDANT'S RESIDENCE, INCLUDING BUT NOT LIMITED TO ALL FURNITURE, CLOTHING, JEWELRY, ELECTRONIC EQUIPMENT, ELECTRICAL APPLIANCES, KITCHEN UTENSILS, SIL VERW ARE, TELEVISIONS, STEREO EQUIPMENT, TOOLS AND ANY OTHER PROPERTY SUBJECT TO LEVY LOCATED AT 1003 LOUISA LANE, MECHANICSBURG, P A 17050 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: 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 $3,650.20 Interest Atty's Corom % Atty Paid $116.24 Plaintiff Paid Date: AUGUST 24, 2004 L.L. Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) Prothono~ ~ By: L//(p"'-tJ Q. 71!-/Vl-' V , ~ Deputy REQUESTING PARTY: Name EDWARD L. BERGER, ESQUIRE Address: GORDIN & BERGER, P.C. 1760 MARKET STREET, SUITE 600 PIDLADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-564-2031 Supreme Court ID No. 34116