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HomeMy WebLinkAbout07-0586 Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff AMERICAN HOME ASSURANCE COMPANY : Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07 - ST4, (21 PTD SERVICES LLC Defendant : CIVIL ACTION - LAW Praecipe for Entry Judgement Pursuant to Pa. R.C.P.M.D.J. No 402 D(1) and (2) To the Prothonotary: Pursuant to the attached District Justice Judgment Transcript, enter judgment on behalf of the plaintiff, American Home Assurance Company, and against the defendant, PTD Services LLC, and assess damages as follows: Judgment Transcript Interest from September 29, 2006 Judgment Amount $7,132.93 $136.01 $7,268.94 Burton Nei & sociates, P.C. By B n Neil, Esquire A rnev for the Plaintiff And now on this day of judgment is entered in favor of American Home Assurance Company and against PTD Services LLC in the total sum of $7,268.94. Prothonotary By Burton Neil & Associates, P.C. is a debt collector. E5 IT" t• r ? ?,r COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Dist. No.: 09-1-01 NOTICE OF JUDGMENT/TRAN CR PT CIVIL CASE, 2 /? PLAINTIFF: NAME and ADDRESS L-? FAMERICAN HOME ASSURANCE COMPANY 1060 ANDREW DRIVE APT/STE 170 BURTON NEIL & ASSOC PC ,!VEST CHESTER, PA 19380 J VS. DEFENDANT: NAME and ADDRESS rPTD SERVICES LLC 427 BRIDGE STREET NEW CUMBERLAND, PA 17070 L_ J Docket No.: CV-0000490-06 Date Filed: 8/30/06 MDJ Name: Hon. CHARLES A. CLE11[ENT, JR Address: 400 BRIDGE ST OLDS TOWNE COMMONS -SUITE 3 NEW CUMBERLAND, PA Telephone: (717 ) 774-5989 17070 AMERICAN HOME ASSURANCE COMPANY 1060 ANDREW DRIVE APT/STE 170 BURTON NEIL A ASSOC PC WEST CHESTER, PA 19380 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JUDGMENT PLTF (Date of Judgment) 9/29/06 T Judgment was entered for: (Name) AMERICAN HOME ASSURANCE COMPAN 1XI Judgment was entered against: (Name) PTD SERVICES LLC in the amount of $ 70132.9 ? Defendants are jointly and severally liable. ? Damages will be assessed on Date & Time ? This case dismissed without prejudice. ? Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 0, i ag • u u Judgment Costs $ 122.00 Interest on Judgment $ 256.93 Attorney Fees $ .00 Total $ 7,132.93 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 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 THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON 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 DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. 9/29/06 Date Magisterial District Judge I certify that this is a true a co rest copy of the rd of a eedings containing the judgment. 1/17/07 Date Magisterial District Judge My commission expires first Monday of January, 2008 SEAL AOPC 315-06 DATE PRINTED: 1/17/07 11:50:00 AM ox "Q. 1? {V n?I { N c? O J W O .?o O n j J rn ?f 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: Cumberland Mop. DML No.: 09-1-01 W NW W: Ham Charles A. Clement, Jr. Addms: 400 Bridge Street Suite 3 New Cumberland, PA 17070 Toloph": 7171774-5989 AMOUNT DATE PAID FILING COSTS $ 113.5 1 POSTAGE $ ! 1 SERVING COSTS $ 1 ! CONSTABLE ED. $ ! 1 TOTAL $ ! ! CIVIL COMPLAINT PLAINTIFF: NAME and ADDRESS r AMERICAN HOME ASSURANCE COMPANY c/o Burton Neil & Associates, P.C. 1060 Andrew Drive, Ste. 170 LWest Chester, PA 19380 VS. DEFENDANT: NAME wW ADDRESS rPTD SERVICES LLC 427 Bridge Street New Cumberland PA 17070 100 \ Docket No.: O- V YqC-C4r, Date Filed: Pa.R.C.P.D.J. No. 206 sets forth those costs recoverable by the prevailing parry. TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for $6,976, together with costs upon the following claim (Civil fines must Include citation of the statute or ordinance violated): For past due balance for an estimated Insurance audit for policy $6,754.00 Principal #WC 769-08-90 for the period 5113104-5N 3105 for the audit period $222.05 Interest 5113104-3126104. $.00 Attorneys Fees 00 Credit $6,976.05 Balance I, Burton Neil Esquire.Attorney for Plaintiff, verify that the facts set forth in this complaint are true and correct to the best of my knowledge, Information and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA. C. S. § 4904) related to unworn falsification to authorities. ?- > (S Xtcre of Ph"tift or Ax&*r=d Agent) Plaintiffs Attorney: Burton Neil Telephone: 610-696-2120 Address: 1060 Andrew Drive, Suite 170 West Chester, PA 19380 IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO, JUDGMENT MAY BE ENTERED AGAINST YOU BY DEFAULT. if you have a claim against the plaintiff which is within magisterial district judge jurisdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office at least five days before the date set for the hearing. If you are disabled and require reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. AOPC 30BA-05 Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff AMERICAN HOME ASSURANCE COMPANY : IN THE COURT OF COMMON PLEAS 1060 Andrew Dr, Ste 170, West Chester, PA 19380 Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. PTD SERVICES LLC : NO. vL CI 427 Bridge Street New Cumberland PA 17070 Defendant :CIVIL ACTION - LAW Certification of Address and Affidavit of Non-Military Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment creditor and debtor. 2. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA) the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. B u r, eil Associates, P.C. fil, Esquire for Plaintiff Burton Neil & Associates, P.C. is a debt collector. '/ 7Ti rte} C_= CD - - CJ ?-1? Burton Neil & Associates, P.C. By: Burton Neil, Esquire ID. NO. 11348 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff AMERICAN HOME ASSURANCE COMPANY IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. PTD SERVICES LLC Defendant : CIVIL ACTION - LAW Rule of Civil Procedure No. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on36, 26/,7. Prothonotary By: If you have any questions concerning the above, please contact: Burton Neil, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 Burton Neil & Associates, P.C. is a debt collector. PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.C.P. § 3103 to 3149 AMERICAN HOME ASSURANCE COMPANY Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. PTD SERVICES LLC Defendant(s) : NO. 07-586 : CIVIL ACTION - LAW To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER 1. Directed to the Sheriff of Cumberland County, Pennsylvania 2. against PTD SERVICES LLC , Defendant(s) 3. and against , Garnishee(s) 4. and index this writ (a) against (b) against Defendant(s) 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) Levy on all property of the defendant located at: 427 Bridge Street, New Cumberland PA 17070 5. Amount Due $7,132.93 Interest from 9/29/06 $161.88 Total $7,294.81 *Plus writ costs Dated: February 15, 2007 on Neil, Esquire ttorney for Plaintiff NOTE: Under paragraph 1 when the writ is directed to sheriff of another county as autho 'zed by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed on to the sheriff of the count in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). The firm of Burton Neil & Associates, P.C. is attempting to collect a debt. 76261 (ZI -b o A N V o c G T? r?- -?- JWL. Irk VI a V 1 1 ? ? e WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-586 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AMERICAN HOME ASSURANCE COMPANY, Plaintiff (s) From PTD SERVICES LLC (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL PROPERTY OF THE DEFENDANT LOCATED AT: 427 BRIDGE STREET, NEW CUMBERLAND, PA 17070. (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 $7,132.93 Interest FROM 9/29/06 - $161.88 Atty's Comm % Atty Paid $36.75 Plaintiff Paid Date: FEBRUARY 22, 2007 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs e?t - 6 V7 C is R. Lon 6th notary By: Deputy REQUESTING PARTY: Name BURTON NEIL, ESQUIRE Address: 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 Attorney for: PLAINTIFF Telephone: 610-696-2120 Supreme Court ID No. 11348 67-S-94, R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned Expired. Sheriff's Costs: Advance Costs: 150.00 Sheriff s Costs 79.05 Docketing 18.00 70.95 Poundage 1.55 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 08/13/08 Mileage 18.00 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Certified Mail Postage G ishee r, AL 79.05 ./ 8/11 105 So Answers; R. Thomas Kline, Sheffir BY !L c?.?Aa? ?,-I- C---j L syo t d q -?? 3297 JJ •, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-586 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AMERICAN HOME ASSURANCE COMPANY, Plaintiff (s) From PTD SERVICES LLC (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL PROPERTY OF THE DEFENDANT LOCATED AT: 427 BRIDGE STREET, NEW CUMBERLAND, PA 17070, (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 $7,132.93 L.L. $.50 Interest FROM 9/29/06 - $161.88 Atty's Comm % Atty Paid $36.75 Plaintiff Paid Due Prothy $1.00 Other Costs Date: FEBRUARY 22, 2007 (Seal) REQUESTING PARTY: Name BURTON NEIL, ESQUIRE Address: 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 Attorney for:`P*LAINTIFF Telephony: 610-696-2120 Supreme Court ID No. 11348 I (" ' "? t 4?- - Cull R. L of y By: Deputy