HomeMy WebLinkAbout02-5160COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
09-1-02
ROBERT V. MAN-LOVE
Add ..... 1901 STATE STREET
CAMP HILL, PA
(717) 761-0583
17011-0000
PFB MEMBERS SERVICE CORP
PO BOX 8736
CAMP HILL, PA 17001'8736
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
~FB MEt~BERS SERVICE CORP
PO BOX 8736
CAMP HILL, PA 17001-8736
VS.
DEFENDANT: NAME and ADDRESS
rAL'S TIRE OF NORTHEi~N CAMBRIA INC ~
908 40TH ST
NORTHERN CAMBRIA, PA 15714
Docket No.: CV-0000347-02
Date Filed: 7/22/02
THIS IS TO NOTIFY YOU THAT:
Judgment:
[] Judgment was entered for: (Name)
[] Judgment was entered against: (Name)
DEFAULT a*UD~M~qT PLTF
AT,~ TT~ OF NORTHRRN ~AM~WTA TNC
in the amount of $
on:
(Date of Judgment)
] Defendants are jointly and severally liable.
E~ Damages will be assessed on:
[~ This case dismissed without prejudice.
]Amount of Judgment Subject to Attachment/Act 5 of t996 $.
[] Levy is stayed for__days or [] generally stayed.
D Objection to levy has been filed and hearing will be held:
(Date & Time)
Amount of Judgment $ 5,276.57
Judgment Costs $ 101.50
Interest on Judgment $ .00
Attorney Fees $. .00
Total
Post Judgment Credits
Post Judgment Costs
Certified Judgment Total
$ 5,378.07
$
Date: Place:
Time:
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST II~CLU~E A COPY OF ml'~ ~ITH YOUR NOTICE OF APPEAL.
¢/~.~ Date-.-.~//~ ~,//~ ~ ,D ,strict Ju st ice
cert~y that this is a t~,~ ~Op~~nrnnp~dJna8 containing the udgment.
/ ~//~ ~ , District Justice
My commission expires first Monday of January, 2006
SEAL
AOPC 315 99
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS)
P.R.C.P. 3101 to 3149 Etc.
pFB MEMBERS SERVICE CORP.. Plaintiff
VS.
AL'S TIRE OF NORTHERN CAMBRIA. INC.. Defendant
VS.
PNC BANK, NATIONAL ASSOCIATION, Garnishee
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
: Writ No. Term, 20
: No. 02:5160 Term, 20 02
:
: Amount Due $5,378.07
:
Interest From September 9, 2002
Attorney's Com.
:
: Costs _$ 29.75
TO THE PROTHONOTARY OF SAID COURT:
( 1 ) Directed to the Sheriff of Cumberland
(2) Against AL'S TIRE OF NORTHERN CAMBRIA, INC
908 40th Street, Northern Cambria. PA 15714
Please issue WRIT OF EXECUTION in the above matter,
County, Pennsylvania;
Defendant (s);
(3) and against
PNC Bank. National Association
105 Noble Boulevard, Carlisle. PA 17013
Garnishee (s);
(4) and index this writ
(a) against
AL'S TIRE OF NORTHERN CAMBRIA. INC
Defendant (s); and
(b) against
PNC Bank. National Association
105 Noble Boulevard. Carlisle. PA 17013
Garnishee (s),
as a lis pendens against the real property of the Defendant (s) in the name of the Garnishee (s) as follows: (Specifically
describe property)
Attach all property or funds of the Defendant, Al's Tire of Northern Cambria, Inc. in the possession or
control of Garnishee, PNC Bank, National Association, including all funds, accounts, obligations, wherever
located, or other moveable personalty of the Defendant in possession or control of Garnishee PNC Bank,
National Association, 105 Nobel Boulevard, Carlisle, PA 17013.
(5)
Date:
: 164760
Exemption has (not) been waived. ~/~
Attorney for Plaintiff (s)
NOTE
Under paragraph (1) when the writ is directed to the sheriffof another county as authorized by Rule 3103(b), the county should be indicated.
Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued.
Paragraph (3) above should be completed only ifa named gm'nishee is to be included in thc writ.
Paragraph (4) (a) should be completed only if indexing office execution in the county of issuance, is desired as aufl~orized by Rule 3104(a).
When the writ issues to another county indexing is required as of course in that county by the prothonolm% See Rule 3104(b).
Paragraph 4 (b) should be completed only if real property in fl~e name of a garnishee is attached aod indexing as a lis pendens is desired. See
Rule 3104(c).
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 02-5160 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PFB MEMBERS SERVICE CORP Plaintiff (s)
From AL'S TIRE OF NORTHERN CAMBRIA INC. 908 40TM STREET, NORTERN CAMBRIA
PA 15714
(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 PNC BANK, NATIONAL ASSOCIATION, 105 NOBLE BOULEVARD, CARLISLE PA
17013.
GARNISHEE(S) as follows:
ATTACH ALL PROPERTY OR FUNDS OF DEFT IN THE POSSESSION OR CONTROL OF
GARNISHEE INCLUDING ALL FUNDS, ACCOUNTS, OBLIGATIONS WHEREVER LOCATED
OR OTHER MOVEABLE PERSONALTY OF DEFT IN POSSESSION OF GARNISHEE.
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 other, vise 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 $5,378.07
Interest FROM 9/9/02
Atty'~ Comm %
Atty Paid $37.25
Plaintiff Paid
Date: NOVEMBER 8, 2002
(Seal)
REQUESTING PARTY:
Name DAVID J LANZA, ESQ.
Address: 301 MARKET ST., P O BOX 109
LEMOYNE PA 17043-0109
Attorney for: PLAINTIFF
Telephone: (717) 761-4540
Supreme Court ID No. 55782
L.L. $.50
Due Prothy $1.00
Other Costs
CURTIS R. LONG
Prothq~?tary
SIRLIN GALLOGLY & LESSER, P.C
By: Jori C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
PRB MEMBER SERVICE CORP.
VS.
AL'S TIRE OF NORTHERN CAMBRIA, INC.
and
PNC BANK, NATIONAL ASSOCIATION,
GARNISHEE
: COURT OF COMMON PLEAS
: COUNTY OF CUMBERLAND
:
: NO. 02-5160
:
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of PNC Bank, National Association, Garnishee, in the
above-captioned matter.
JON'L'"'fS~'~
Attor~f (or Garnishee
Date:
SIRLIN GALLOGLY & LESSER, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
PRB MEMBER SERVICE CORP.
VS.
AL'S TIRE OF NORTHERN CAMBRIA, INC.
and
PNC BANK, NATIONAL ASSOCIATION,
GARNISHEE
Attorney for Garnishee
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
NO. 02-5160
2.
3.-6.
7.
ANSWERfl TO 1NTERROGATflRIEfl IN ATTACHMENT
TO: PRB MEMBER SERVICE CORP., Plaintiff
No.
No, Defendant has no assets with PNC Bank, National Association·
No.
See answer to number two above.
j
VERIFICATION
Tyieshia M. Hayes, being duly sworn according to law, deposes and says that she is the
Writ Administrator o f'PNC Bank, National Association, the within garnishee, and
verifies that the statements made in the foregoing ^nswers to Interrogatories are t~e and
correct to the best of her knowledge. Said garnishee 'understands that the statements
herein are made subject to the penalties of 18 Pa. 'C.S.A. Section 4904 relating to
unsworn falsification to authorities.
TYIESHIA M. HAYES
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 02-5160 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PFB MEMBERS SERVICE CORP Plaintiff (s)
From AL'S TIRE OF NORTHERN CAMBRIA INC. 908 40TM STREET, NORTERN CAMBRIA
PA 15714
(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 PNC BANK, NATIONAL ASSOCIATION, 105 NOBLE BOULEVARD, CARLISLE PA
17013.
GARNISHEE(S) as follows:
ATTACH ALL PROPERTY OR FUNDS OF DEFT IN THE POSSESSION OR CONTROL OF
GARNISHEE INCLUDING ALL FUNDS, ACCOUNTS, OBLIGATIONS WHEREVER LOCATED
OR OTHER MOVEABLE PERSONALTY OF DEFT IN POSSESSION OF GARNISHEE.
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 $5,378.07
Interest FROM 9/9/02
Atty's Comm %
Atty Paid $37.25
Plaintiff Paid
Date: NOVEMBER 8, 2002
(Seal)
REQUESTING PARTY:
Name DAVID J LANZA, ESQ.
Address: 301 MARKET ST., P O BOX 109
LEMOYNE PA 17043-0109
Attorney for: PLAINTIFF
Telephone: (717) 761-4540
Supreme Court ID No. 55782
L.L. $.50
Due Prothy $1.00
Other Costs
CURTIS R. LONG
ero ota , !t
R. Thomas Kline, Sheriff, who being duly swom according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff's Costs:
Docketing 18.00
Poundage 1.44
-Advertising
Law Library .50
Prothonotary 1.00
Mileage 3.45
Misc.
Surcharge 20.00
Levy 20.00
Post Pone Sale
Garnishee 9.00
TOTAL 73.39
Sworn and Subscribed to before me
this /9-' dayof-~
2003 A.D. ~,*o--. tr~ ~'~l.~t~,,..,, ~-
protlSonotary
Advance Costs: 150.00
Sheriff's Costs: 73.39
76.61
Refunded to Atty on 5/14/03
R. Thomas Kline, S~
/ ' ,
SIRLIN GALLOGLY & LESSER, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
PRB MEMBER SERVICE CORP.
VS.
AL'S TIRE OF NORTHERN CAMBRIA, INC.
and
PNC BANK, NATIONAL ASSOCIATION,
GARNI,qH~E
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
NO. 02-5160
To: David J. Lanza, Esquire
301 Market Street
P.O. Box 109
Lemoyne, PA 17043
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 indicated below·
X PRAECIPE FOR RULE OF NON PROS
_ JUDGMENT BY DEFAULT
_ MONEY JUDGMENT
__ JUDGMENT IN REPLEVIN
_ JUDGMENT FOR POSSESSION
_ JUDGMENT ON AWARD OF ARBITRATION
_ JUDGMENT ON VERDICT
_ JUDGMENT ON COURT FINDINGS
SIRLIN GALLOGLY & LESSER, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
PRB MEMBER SERVICE CORP.
VS.
AL'S TIRE OF NORTHERN CAMBRIA, INC.
and
PNC BANK, NATIONAL ASSOCIATION,
GARNISHEE
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
.'
· NO. 02-5160
TO THE PROTHONOTARY:
PRAECIPE
Kindly enter a Rule upon Plaintiff to either seek judgment against Garnishee, PNC Bank,
National Association under Rule 3143(g) or to place the issue between Plaintiff and Garnishee upon
the list for trial, or in the alternative, to suffer judgment of non pros against Plaintiff and in favor of
Garnishee, PNC Bank, National Association·
J
Date:
SIRLIN GALLOGLY & LESSER, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
PRB MEMBER SERVICE CORP.
VS.
AL'S TIRE OF NORTHERN CAMBRIA, INC.
and
PNC BANK, NATIONAL ASSOCIATION,
GARNISI--IF~E
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
;
· NO. 02-5160
TO THE PROTHONOTARY:
RIII,E
AND NOW, this .]q~day of ')~,~ ,2003, a Rule is hereby granted upon Plaintiff
to seek judgment against Garnishee, PNC Bank, National Association, under Rule 3143(g) or to
place the issue between Plaintiff, Defendant and Garnishee upon the list for trial within twenty (20)
days after the service hereof or to suffer Judgment of Non Pros against Plaintiff.
PROTHONOTARY
SIRLIN GALLOGLY & LESSER, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
PRB MEMBER SERVICE CORP.
VS.
AL'S TIRE OF NORTHERN CAMBRIA, 1NC.
and
PNC BANK, NATIONAL ASSOCIATION,
GARNISHEE
: COURT OF COMMON PLEAS
: COUNTY OF CUMBERLAND
:
: NO. 02-5160
To: David J. Lanza, Esquire
301 Market Street
P.O. Box 109
Lemoyne, PA 17043
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 indicated below.
X JUDGMENT OF NON PROS
JUDGMENT BY DEFAULT
MONEY JUDGMENT
JUDGMENT IN REPLEVIN
JUDGMENT FOR POSSESSION
JUDGMENT ON AWARD OF ARBITRATION
JUDGMENT ON VERDICT
JUDGMENT ON COURT FINDINGS
SIRLIN GALLOGLY & LESSER, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
PRB MEMBER SERVICE CORP.
VS.
AL'S TIRE OF NORTHERN CAMBRIA, 1NC.
and
PNC BANK, NATIONAL ASSOCIATION,
GARNISHEE
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
NO. 02-5160
PRAECIPE TO ENTER .HJDGMENT OF NON PROS
TO THE PROTHONOTARY:
Kindly enter a Judgment of Non Pros in favor of PNC Bank, National Association,
Garnishee and against Plaintiff, PRB MEMBER SERVICE CORP., for failure to enter judgment
against the Garnishee within twenty days after service of a Rule to seek judgment against Garnishee
under Rule 3143(g) or to place the issue between Plaintiff, Defendant, and Garnishee upon the list
for lrial.
Dated:
s i=i
Attor~ for Garnishee
SIRLIN GALLOGLY & LESSER, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
1529 Walnut Street, Suite 600
Philadelphia, PA 19102
(215) 864-9700
Attorney for Garnishee
PRB MEMBER SERVICE CORP.
VS.
AL'S TIRE OF NORTHERN CAMBRIA, INC.
and
PNC BANK, NATIONAL ASSOCIATION,
GARNISHEE
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
NO. 02-5160
CERTIFICATE OF SERVICE
JON C. SIRLIN, being duly sworn according to law, deposes and says that he is counsel for
the Gamishee, First Union National Bank, that he is authorized to and does take this affidavit on its
behalf and that he served a Pmecipe and Rule pursuant to Pa.R.C.P. 3143(g) to Enter Judgment or
suffer judgment of Non Pros, upon David J. Lanza, Esquire, counsel for Plaintiff, by letter dated
May 21, 2003, which was sent via certified mail and that Exhibits "A" and "B" attached hereto are
tree and correct copies of the transmittal letter addressed to Plaintiffs counsel and the certified mail
return receipt.
AO~o~'y for Garnishee
Date:
EXHIBIT "A"
I · Complete Items 1, 2, and 3. Also complete
Item 4 if Restricted Delivery is desired.
i · Print your name and address on the reverse
~ so that we can return the card to you.
, · Attach this card to the back of the mailpiece,
I or on the front if space permits.
I 1. Article Addressed to:
A, Signature
B. Recaived by (Pr~ted~me) ~j~C. Date of Delivel
D. Is daiive~y address d~ ~ ~ 1 ? D Yes
[] Insured Mail [] C.O.D.
~2. Article Number
~~'~.s~r~o~¥i~beO 7002 2030 0007 7695 9656
!PS Form 3811, August 2001 ~mestlc Return R~i~
[] Express Mail
[] Return Receipt for Merchandi,~
EXHIBIT "B"
SIR. LIN GALLOGLY ~ LESSER`
A PROFESSIONAL CORPOKATION
ATTORNEYS AT LAW
JON C. SIILLIN
TIMOTHY A. GALLOGLY
PETER A, LESSER*
JOHN D. BENSON*
SUSAN J. KUPERSMITH*
MARK E. SQUIRES '~
DKNA S. pLON*
DOROTHY ANNIg HAMILL*
JERRY I. DREW*
May 21, 2003
PENNSYLVANIA OFFiCE
1529 WALNUT STREET
SUITE 600
PHILADELPHIA, PA 19102
(215) 864-9700
FAX (215) 864-9669
NEW JERSEY OFFICE
102 BROWNING LANE
BUILDING C
CHERRY HILL, NJ 08003
(8S6) 616-1900
FAX (856) 216-7459
David~L Lanza, Esquire
301 Market Street
P.O. Box 109
Lemoyne, PA 17043
Re:
PRB Members Service Corp. vs. Al's Tire of Northern Cambria, Inc.
and PNC Flank, National Association, Garnishee
Dear Mr. Lanza:
I enclose a copy of the Praecipe to Enter Rule against Plaintiff pursuant to Pa.R.C.P.
3143(g) to either seek judgment against Garnishee or to place the issue between Plaintiff and
Garnishee upon the trial list, which Rule was entered on or about May 24, 2003.
The purpose of this proceeding is merely to enable me and my client to close our files in
this old attachment. Under the circumstances, I would appreciate your signing the enclosed Order
to Discontinue Attachment Execution. If this is agreeable with you, please sign the enclosed Order
and return to me for filing with the Court. However, if you do not respond promptly and
against Plaintiff at the earliest opportunity.
trtesy and cooperation.
qQUIRIES TO - 215-864-9700, EXT. 33.
Si1