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HomeMy WebLinkAbout07-0562COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND 07'S6,;2 I Mag. Dist. No.: 09-3-04 MDJ Name: Hon. THOMAS A. PLACEY Address: 104 S SPORTING HILL RD MECHANICSBURG, PA NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS FBENT CREEK LIMITED PARTNERSHIP ? 100 GEORGETOWN ROAD MECHANICSBURG, PA 17050 L DEFENDANT: Telephone: (717 ) 761-8230 17050 FSONNEXANN, PENNY 683 DEER ROAD BOILING SPRINGS, BENT CREEK LIMITED PARTNERSHIP 100 GEORGETOWN ROAD MECHANICSBURG, PA 17050 J VS. NAME and ADDRESS PA 17007 L J Docket No.: CV-0000689-06 Date Filed: 11/15/06 THIS IS TO NOTIFY YOU THAT: - Judgment: DEFAULT JUDGMENT PLTF (Date-of Judgment) _12/21/06_ T Judgment was entered for: (Name) BRIT CREEK LIMITED PARTNERSHIP ® Judgment was entered against: (Name) SONl ZKkNN, PENNY in the amount %J $ 984.2 Defendants are jointly and severally liable. ? Damages will be assessed on Date & Time This case dismissed without prejudice. F] Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease ?) Total Post Judgment Credits Post Judgment Costs $ 875.00 $ 10325 $ .00 $ .00 $ 984.251 Certified Judgment Total $ 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 INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THEAOUFJT OF COMMON PLEAS, ALL FURTHER PROCESS MUST eO ESS THE JUDGMENT IS NTEREO IN THE CO UR FURTHER PRCCE'SS7MAY BE 1S Cf Ry 111 "M4kir, *TERIAt CJIS7RICT JUDGE U T OF' COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. 1417A 106 Date _ I certify that this is a true C u 6 Date My commission expires first Monday of January, 2010 Magisterial District Ju containing the judgment. , Magisterial District Judge SEAL AOPC 315-06 DATE PRINTED: 12/21/06 11:26:00 AIL b ? Q rQ' v 3 ? 0 T 0 P-40 o F o > ) N Q " c I Bent Creek Limited Partnership 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Penny Sonneman 683 Deer Road Boiling Springs, PA 17007 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA NO. 07-562 CIVIL ACTION - LAW PETITION FOR A RULE TO SHOW CAUSE WHY AN ORDER GRANTING WAGE ATTACHMENT SHOULD NOT ISSUE AND NOW, comes the Plaintiff, Bent Creek Limited Partnership, and hereby petitions the Honorable Court to issue a Rule to Show Cause as to why relief in the instant Petition should not be granted upon the Defendant, Penny Sonneman and the Defendant's employer, Harrisburg Hospital, 205 S. Front Street, Harrisburg, PA, in support thereof avers as follows: 1. This matter arises out of a dispute concerning a residential lease. 2. Judgment was entered against the Defendant by District Justice Thomas A. Placey, Magisterial District 09-3-04 on December 21, 2006 in the amount of $875.00, Docket Number CV-0000689-06. Post judgment costs increased this amount to $984.25, which is shown on the certified judgment. 3. The District Justice Judgment was filed with this Court on January 29, 2007, under Docket Number 07-562 Civil Term. 4. Reasonable attempt has been made to contact and make payment arrangement to satisfy Judgment Docket Number CV-0000689-06. No response was received from defendant. 5. The Defendant is currently employed at Harrisburg Hospital, 205 S. Front Street, Harrisburg, PA. 6. Pursuant to 42 Pa. C.S.A. Section 8127, the Plaintiff is entitled to garnish 10% of the net wages per pay period of the Defendant, this judgment debtor-tenant. 7. The Plaintiff requests that this Court issue an order attaching the wages of the Defendant to satisfy the judgment, as permitted by 42 Pa. C.S.A. Section 8127. 8. Copies of the District Justice Judgment and the proposed attachment order are attached hereto. 9. WHEREFORE, the Plaintiff hereby requests that the Honorable Court issue the proposed rule to show cause against both the Defendant, Penny Sonneman and her current employer, Harrisburg Hospital, 205 S. Front Street, Harrisburg, PA. Respectfully Submitted: Date: _ Pietro Leone Attorney, PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 (717)657-5729 COMMON ..,/EALTH OF PENNSYLVANIA. COUNTY OF: CUMBERLAt+?D 07' Mag. Dist. No.: 09-3-04 MDJ Name: Hon. THOMAS A. PLACEY Address: 104 S SPORTING HILL RD MECHANICSBURG-, PA [NOTICE OF UD GI ENT/TRANSCRIPT U? PLAINTIFF: NAME and ADDRESS FBE?oTiT CREEK LIMITED PARTNERSHIP ? 100 GEORGETOWN ROAD MECHANICSBURG, PA 17050 L J vs. NAME and ADDRESS PA 17007 DEFENDANT: Telephone: (717 ) 761- 8230 17050 FSONNSMANN, PENNY 683 DEER ROAD BOILING SPRINGS, BENT CREEK LIMITED PARTNERSHIP 100 GEORGETOWN ROAD MECHANICSBURG, PA 17050 L -? Docket No.: CV-0000689-06 Date Filed: 11/15/06 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JUDGMENT PLTF 12/21/06_ (Date-.of Judgment) ® Judgment was entered for: (Name) BENT CREEK LIMITED PARTNERSHIP ® Judgment was entered against: (Name) SONNM[ANN, PENNY 984.2 in the amount of $ Defendants are jointly and severally liable. Damages will be assessed on Date & Tim( This case dismissed without prejudice. Amount of Judgment $ 875.00 Judgment Costs $ 109.25 Interest on Judgment $ .00 Attorney Fees $ .00 Totals $ 984.251 Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ 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 INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE,COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE°COURT"OF COMNION'.PLEAS AND NO FURTHER PROCESS` MAY BE ISSUED, BY THE MAGISTERIAL: DISTRICT JUDGE. _ UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBZOR Pf!!KS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. III It ?06 Date Y Magisterial District Judge I certify that this is a true an y eedings containing the judgment. 4?24? br Date , Magisterial District Judge My commission expires first Monday of January, `0y? SEAL AOPC 315-06 nmTT2 QuTi?*t;'TaTT• 17/71 /og 11 _7F•Gf) AN CERTIFICATE OF SERVICE I hereby certify that I am this day serving Plaintiff's Petition For A Rule To Show Cause: Why An Order Granting Wage Attachment Should Not Issue upon the person and in the manner indicated below, which service satisfies the requirement of Pa. R.C.P. 440: Service by certified mail, addressed as follows: Penny Sonneman 683 Deer Road Boiling Springs, PA 17007 Respectfully Submitted, Date: zz- ?? ?/ ._ y: Pietro Leone, Attorney PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 717-657-5729 V .4 Bent Creek Limited Partnership 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Penny Sonneman 683 Deer Road Boiling Springs, PA 17007 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA NO. 07-562 CIVIL ACTION - LAW AMENDEMENT TO PETITION FOR A RULE TO SHOW CAUSE WHY AN ORDER GRANTING WAGE ATTACHMENT SHOULD NOT ISSUE Please add the following motions: 1. There has been no prior judge involvement, except for Ruling by District Justice Placey (see attached). 2. Concurrence of opposing counsel was sought but was not obtained due to the Defendant's lack of appearance at the December 21, 2006 hearing. Respectfully Submitted: Date: 5 7 ?aaJ Pietro Leone Attorney, PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 (717)657-5729 ;MMO,`.. JEALTH OF PENNSYLVANIA .;OUNTY OF: CUNBERLAND 07' Mag. Dist. No.: 09-3-04 MDJ Name: Hon. THOMAS A. PLACEY Address: 104 S SPORTING HILL RD MECRA-NICSBURG, PA Telephone: (7 17 ) 761-8230 17050 BENT CREEK LIMITED PARTNERSHIP 100 GEORGETOWN ROAD MECHANICSBURG, PA 17050 NOTICE OFCJIUDGMENT/TRANSCRIPT &? CASE PLAINTIFF: NAME and ADDRESS FBENT CREEK LIMITED PARTNERSHIP 100 GEORGETOWN ROAD MECHANICSBURG, PA 17050 L DEFENDANT: FSONKZVJ NN, P=NY 683 DEER ROAD BOILING SPRINGS, J vs. NAME and ADDRESS PA 17007 L -? Docket No.: CV-0000689-06 Date Filed: 11115106 ITHIS IS TO NOTIFY YOU THAT: DEFAULT JUDGMENT PLTF 12/21/06_ Judgment(Date.of Judgment).- P9 Judgment was entered for: (Name) BENT CREEK LIMITED PARTNERSHIP ® Judgment was entered against:. (Name) SONNBaIANN, PENNY in the amount of $ 9 84.2 F1 Defendants are jointly and severally liable. Damages will be assessed on Date & Time This case dismissed without prejudice. F1 Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease $ Total Post Judgment Credits Post Judgment Costs $ 875.00 $ 109. 25 $ .00 $ .00 $ . 984.251 S Certified Judgment Total $ 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 INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THEt.COUF3T OF COMMON PLEAS, ALL FURTHER PROCESS MUST ...COME- FROM_THE' CO1JRT'OF°COMII1(YW..PCEAS"AND NO FI?RTHER PROCESSMAY BE.19SUEDBY_THE MA67STERIALDISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PA[XS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. 2 21 b Date , Magisterial District Judge 1 certify that this is a true an eedings containing the judgment. 4?2A C_ Date Magisterial District Judge My commission expires first Monday of January, SEAL AOPC 315-06 r s n?TS rf7? a»?*!*? _ 7 ?1 l ?f 1 / A ? 1 7 _ •f G - A A > >e _n T71 -r- r ` " " y. w _. ? ( r 1 f w APR 85 20 Bent Creek Limited Partnership IN THE COURT OF COMMON PLEAS 5351 Jaycee Avenue CUMBERLAND, COUNTY, PENNSYLVANIA Harrisburg, PA 17112 Plaintiff : Vs NO. 07-562 Penny Sonneman 683 Deer Road CIVIL ACTION - LAW Boiling Springs, PA 17007 Defendant RULE TO SHOW CAUSE AND NOW, this 1( ^ day of ffi!?r 2001, upon consideration of the foregoing Petition For A Rule To Show Cause Why An Order Granting Wage Attachment Should Not Issue, it is hereby ORDERED and DECREED as follows: 1. a rule is issued upon the Defendant, Penny Sonneman, and her current employer, Harrisburg Hospital, 205 S. Front Street, Harrisburg, PA, to show cause why the petitioner is not entitled to the relief requested; 2. the respondent shall file an answer to the petition within aO days of service; 3. the petition shall be decided under Pa. R.C.P. No. 206.7. 4. notice of the entry of this order shall be provided to all parties and to the current employer of the Defendant, Harrisb 205 S. Front Street, Harrisburg, PA. h I :Z l,il d i 1 k%141 LOU 3IRL dG Bent Creek Limited Partnership 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Penny Sonneman 683 Deer Road Boiling Springs, PA 17007 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA NO. 07-562 CIVIL ACTION - LAW PLAINTIFF'S MOTION TO MAKE RULE ABSOLUTE AND NOW, Pursuant to Pennsylvania Rule of Civil Procedure 206.7, Plaintiff, Bent Creek Limited Partnership, hereby files this Motion to make Rule Absolute, and in support of same avers as follows: 1. On April 18, 2007, Plaintiff, Bent Creek Limited Partnership, filed a Petition for A Rule to Show Cause Why an Order Granting Wage Attachment Should Not Issue. 2. On May 11, 2007, this Honorable Court issued a Rule to Show Cause with a return of twenty (20) days. 3. The Defendant has not answered the Rule. 4. Pursuant to Pa. R.C.P. 206.7, when a Rule is not answered, the averments of fact may be deemed admitted and the court shall enter an appropriate order. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant its Petition For a Rule to Show Cause Why An Order Granting Wage Attachment Should Not Issue and GRANT a wage attachment against the Defendant's current employer, Harrisburg Hospital, 205 S. Front Street, Harrisburg, PA, as well as all current or subsequent employers. Respectfully Submitted: Date: 4Q .?4© 4-eetro Leone, Attorney PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 (717) 657-5729 CERTIFICATE OF SERVICE I hereby certify that I am this day serving Plaintiff s Motion to Make Rule Absolute upon the person and in the manner indicated below, which service satisfies the requirement of Pa. R.C.P. 440: Service by certified mail, addressed as follows: Penny Sonneman 683 Deer Road Boiling Springs, PA 17004 Harrisburg Hospital 205 S. Front Street Harrisburg, PA Date: (, ?Z - 6? yd-7 Respectfully Submitted, By: Pietro Leone, Attorney, PA Bar #85127 5351 Jaycee Avenue, Harrisburg, PA 17112 717-657-5729 rs ` ` c°-. -n t"nm v i F3 4W Bent Creek Limited Partnership 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Penny Sonneman 683 Deer Road Boiling Springs, PA 17007 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA NO. 07-562 CIVIL ACTION - LAW PLAINTIFF'S MOTION TO WITHDRAW WAGE ATTACHMENT AND NOW, Pursuant to Pennsylvania Rule of Civil Procedure 206.7, Plaintiff, Bent Creek Limited Partnership, hereby files this Motion to Suspend Wage Attachment, and in support of same avers as follows: 1. Rule to Show Cause was granted against Defendant on May 11, 2007. 2. Plaintiff received notice that Defendant currently has a pending bankruptcy case. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant that the wage attachment against the Defendant's current employer, Harrisburg Hospital, 205 S. Front Street, Harrisburg, PA, be withdrawn pending the outcome of the bankruptcy case. Respectfully Submitted: Date: ?p c) 7 Pietro Leone, Attorney PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 (717) 657-5729 _, ::? ? ?.: ----i =? - ..: t,,: ;._ ?_:; j :;::: Bent Creek Limited Partnership 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Penny Sonneman 683 Deer Road Boiling Springs, PA 17007 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA NO. 07-562 CIVIL ACTION - LAW PLAINTIFF'S AMENDED MOTION TO WITHDRAW WAGE ATTACHMENT AND NOW, Pursuant to Pennsylvania Rule of Civil Procedure 206.7, Plaintiff, Bent Creek Limited Partnership, hereby files this Motion to Suspend Wage Attachment, and in support of same avers as follows: 1. Rule to Show Cause was granted against Defendant on May 11, 2007. 2. There has been prior judge involvement, a Civil Ruling by District Justice Thomas A. Placey, docket number CV-0000689-06 and an Order for a Rule to Show Cause by Judge Guido, docket number 07- 562 Civil Term. 3. Concurrence of opposing counsel was sought but was not obtained due to the Defendant's lack of appearance at the December 21, 2006 hearing for the Civil Judgment CV-0000689-06. Concurrence was also not obtained on the filing of the Rule to Show Cause Order number 07-562 Civil Term. 4. Plaintiff received notice that Defendant currently has a pending bankruptcy case. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant that the wage attachment against the Defendant's current employer, Harrisburg Hospital, 205 S. Front Street, Harrisburg, PA, be withdrawn pending the outcome of the bankruptcy case. Date: 7 _l6 _ ado-2 y PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 (717) 657-5729 Respe lly Submitted: Pietro Leone Atto e ? ?ri ?? ? c.a ?=- ? ?? .? l ?.z? r'". ?? . "?7 "??. , , . ?? - . `' ., rrte.?? 1..? -'?.% ?? t.J J Bent Creek Limited Partnership 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Penny Sonneman 683 Deer Road Boiling Springs, PA 17007 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA NO. 07-562 CIVIL ACTION - LAW PLAINTIFF'S AMENDED MOTION TO WITHDRAW WAGE ATTACHMENT AND NOW, Pursuant to Pennsylvania Rule of Civil Procedure 206.7, Plaintiff, Bent Creek Limited Partnership, hereby files this Motion to Suspend Wage Attachment, and in support of same avers as follows: 1. Rule to Show Cause was granted against Defendant on May 11, 2007. 2. There has been prior judge involvement, a Civil Ruling by District Justice Thomas A. Placey, docket number CV-0000689-06 and an Order for a Rule to Show Cause by Judge Guido, docket number 07- 562 Civil Term. 3. Concurrence of opposing counsel was sought but was not obtained due to the Defendant's lack of appearance at the December 21, 2006 hearing for the Civil Judgment CV-0000689-06. Concurrence was also not obtained on the filing of the Rule to Show Cause Order number 07-562 Civil Term. 4. Plaintiff received notice that Defendant currently has a pending bankruptcy case. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant that the wage attachment against the Defendant's current employer, Harrisburg Hospital, 205 S. Front Street, Harrisburg, dP A, bi-, withdrawn pending the outcome of the bankruptcy case. - i, Respectfully Submitted: h_ Date: 7-16-1007 ietro Leone, Attorney PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 (717) 657-5729 Nip r` !_ Bent Creek Limited Partnership 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Penny Sonneman 683 Deer Road Boiling Springs, PA 17007 Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND, COUNTY, PENNSYLVANIA NO. 07-562 ° C -c -n CIVIL ACTION - LAW ' c.N PLAINTIFF'S AMENDED MOTION TO WITHDRAW WAGE ATTACHMENT AND NOW, Pursuant to Pennsylvania Rule of Civil Procedure 206.7, Plaintiff, Bent Creek Limited Partnership, hereby files this Motion to Suspend Wage Attachment, and in support of same avers as follows: 1. Rule to Show Cause was granted against Defendant on May 11, 2007. 2. There has been prior judge involvement, a Civil Ruling by District Justice Thomas A. Placey, docket number CV-0000689-06 and an Order for a Rule to Show Cause by Judge Guido, docket number 07- 562 Civil Term. Concurrence of opposing counsel was sought but was not obtained due to the Defendant's lack of appearance at the December 21, 2006 hearing for the Civil Judgment CV-0000689-06. Concurrence was also not obtained on the filing of the Rule to Show Cause Order number 07-562 Civil Term. 4. Plaintiff received notice that Defendant currently has a pending bankruptcy case. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant that the wage attachment against the Defendant's current employer, Harrisburg Hospital, 205 S. Front Street, Harrisburg, PA, be withdrawn pending the outcome of the bankruptcy case. Date: 7 - U, ddo 7 Resp lly Submitted: Pietro Leone, Attorne PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 (717) 657-5729 Bent Creek Limited Partnership 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Penny Sonneman 683 Deer Road Boiling Springs, PA 17007 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA NO. 07-562 CIVIL ACTION - LAW r..; -n PLAINTIFF'S AMENDED MOTION TO WITHDRAW WAGE ATTACHMENT AND NOW, Pursuant to Pennsylvania Rule of Civil Procedure 206.7, Plaintiff, Bent Cree- Limit Paship, hereby files this Motion to Suspend Wage Attachment, and in support of same avers as folldzys: r 1. Rule to Show Cause was granted against Defendant on May It, 2007. 2. There has been prior judge involvement, a Civil Ruling by District Justice Thomas A. Placey, docket number CV-0000689-06 and an Order for a Rule to Show Cause by Judge Guido, docket number 07- 562 Civil Term. 3. Concurrence of opposing counsel was sought but was not obtained due to the Defendant's lack of appearance at the December 21, 2006 hearing for the Civil Judgment CV-0000689-06. Concurrence was also not obtained on the filing of the Rule to Show Cause Order number 07-562 Civil Term. 4. Plaintiff received notice that Defendant currently has a pending bankruptcy case. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant that the wage attachment against the Defendant's current employer, Harrisburg Hospital, 205 S. Front Street, Harrisburg, PA, be withdrawn pending the outcome of the bankruptcy case. Respectfully Submitted: Date: do 07 Pietro Leone, Attorney PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 (717) 657-5729 Bent Creek Limited Partnership 5351 Jaycee Avenue ; PENNSYLVANIA Harrisburg, PA 17112 Plaintiff Vs Penny Sonneman 683 Deer Road Boiling Springs, PA 17007 Defendant JUN 14 2002aW IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, NO. 07-562 CIVIL ACTION - LAW ORDER AND NOW, this day of , 2006, upon consideration of the foregoing Motion to Withdraw Wage Attachment, i is hereby ORDERED AND DECREED the wage attachment shall be withdrawn pending outcome of bankruptcy case. So ?tC •r1 ?' a 1 ! t.U6 1 "H 9