HomeMy WebLinkAbout94-03578
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IT IS HEREBY CERTIFIED THAT THE
WITHIN IS A TRUE AND CORRECT COpy
OF THE ORIGINAL FII.ED IN JHIS ,~CTlON
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BY' , .
----- ATTORNEy-h--..", .m.__.__u
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ROLAND ANSTINE,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 94-3578
CIVIL TERM
RUSSELL LENTZ, tldlbla
LBNTZ LANDSCAPING,
Defendant
Civil Action - Law
PRAECIPE TO ENTER A DEFAULT JUDGEMENT
To the Prothonotary:
AND NOW COMES PLAINTIFF, by his undersigned Counsel Barbara
Sumple-Sullivan, Esquire attests as follows:
1, On or about June 16,1994, a Complaint was filed against
the Defendant., Russel Lentz, l/d/b/a LENTZ LANDSCAPING.
2, On July 5, 1994, Defendant was duly served by the Sheriff
by handing a copy to Andrea Lentz, his wife at his place of
residence.
3, Upon service, Defendant made no responsive pleading to the
complaint,
4, On or about August 2, 1994, Plaintiff provided Defendant
with a Notice of Intent to Enter a Default Judgement, Said Notice
was served on the Defendant pursuant to First Class Mailing. The
Certificate of Mailing is attached hereto as Exhibit "A" and is
incorporated herein by reference,
5, Defendant has failed to take any action to defend the cause
of action within the ten (10) days of the date of the Notice and
its mailing.
6, Judgement is to be entered in favor of the Plaintiff in
the amount of Thirty-two Thousand, Three Hundred Fifty-nine and
31/100 ($32,359.31) dollars, plus interest and costs.
7. WHEREFORE, Plaintiff requests judQement be entered in his
favor by Default in the amount of Th~{ty-two Thousand, Three
Hundred Fifty-nine and 31/100 ($32,359.,1) dollJrs, plus interest
and costs, / /,/ .
<9k~ ~
Barbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, Pennsylvania 17070
(717)-774-1445
Supreme Court ID #32317
.9)J7f~
Dated:
ROLAND ANSTINE/
Plaint! ff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY/ PENNSYLVANIA
v.
No. 94-3578
CIVIL TERM
RUSSELL LENTZ, t/d/b/a
LENTZ LANDSCAPING,
Defendant
Civil Action - Law
PLAINTIFF/S MOTION TO COMPEL ANSWERS TO
INTERROGATORIES DIRECTED TO DEFENDANT
AND NOW comes Plaintiff, ROLAND ANSTINE, by and through his
attorney, BARBARA SUMPLE-SULLIVAN, Esquire, and hereby files the
following Motion to Compel as follows:
1. This action was initiated by Complaint on or about June
16, 1994,
On July 5, 1994, Defendant was duly served by the
Sheriff by handing a copy to Defendant's wife, Andrea Lentz at
their place of residence. Upon no response, judgment was entered
in favor of Plaintiff on August 16, 1994, in the amount of
$32,359.31, plus interest and costs,
2. On October 26, 1994, Plaintiff served a set of
Interrogatories in Aid of Execution pursuant to Pennsylvania Rules
of Civil Procedure Nos. 3117 and 4006. A copy of Plaintiff's said
Interrogatories are attached hereto as Exhibit "A" incorporated
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E. As used herein, "identify" or "identity" used in
referenoe to an individual or person means to state his
full name, present business and private addresses and
telephone numbers, his present or last known occupation,
his employer, and employer's address.
F. As used herein, "identify" or "identity" when used in
reference to a corporation, company, entity or
institution means to state its full name and present
address and telephone numbers, any fictitious names under
which it operates, and the present owners, officers and
directors thereof with their current addresses.
G.
As used herein, "identify" or "identity" when used in
reference to a document or commlJnication means to state '
the date, author, type of document or communication
(e. g., letter, memorandum, telegram, chart, etc.) or any
other means of identifying it, its present location, and
the name and address of its custodian. If any such
document or communication was, but is no longer, in your
possession or subject to your control, state what
disposition was made of it and who presently has it.
If a precise value amount or date cannot be supplied in
response to an Interrogatory, provide an approximate
value, amount or date.
H.
INTERROGATORIES
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2. State your gross taxable income as shown by
Tax returns for the years 1990 through 1994.
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What is your occupation?
your Federal Income I
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3.
What is your present average monthly income from .11 sources?
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4. Do you pay rent for your present liVing quarters? If so, state
the name and address of your landlord and the amount of rent you
I:pay per month.
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i[S. Do you own the home in which you now live? If so, state:
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, a. Who has title to the home in which you now live?
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b. When was the property purchased, what was the purchase '
:;price, by whom was it paid and what was the source of the funds
':used?
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Ii c. Is there a mortgage on the property? If so, state the name
'land address of the mortgagee, the amount of the original mort~age,
I the amount of the current mortgage balance, and the monthly
,Imortgage payments.
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1"1 d. What is the current market value of the heme in which you !
:live?
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!ifor
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c. The identity of any joint owner of the account or
certificate and the nature of your joint ownership;
d. The nature of the account or certificate; and
e. The purchase price of the certificate;
f. The dates and amounts of your deposits or contributions
the last three (3) years,
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;/ g. The dates
I th~ee (3) years;
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and amounts of your withdrawals for the last
current balance of the account
or value of the
I h. The
certificate.
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16. Have you sold, assigned, given or traded any tangible or
intangible personal property or interest in personal property with
a value of $100.00 or more to anyone with the last three (3) years?
If so, as to each transfer, please state:
a.
The description of the property;
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! property
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b.
The interest which you transferred;
The identity of the person to whom you transferred the
or interest therein;
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d. The date of the transfer;
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e. The consideration you received for each tranSfer;
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