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Home My WebLink About02-5699 SANDLER & MARCHESINI, P.C, BY: PAUL N. SANDLER, ESQUIRE ATTORNEY ID# 15711 1429 Walnut Street, 16'" Floor Philadelphia, P A 19102 (215) 568-9300 DAVID AND VIRGINIA RAHAL 911 WALNUT ST. CARLISLE, P A 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs, LINDA BOUDER 1122 PINE ROAD CARLISLE, P A 17013 NO.: OJ. - J7P~1 ~~ PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment on behalf of plaintiffs, David and Virginia Rahal, and against defendant, Jeffrey Matta, in the sum of$3,571.04, Said judgment is based upon a certified judgment entered by the Honorable Paula P. Correal, District Justice, a copy of which is attached hereto as Exhibit "A". I hereby certify that the above stated addresses are true and correct. SANDLER & MARCHESINI, P.C. BY 2J);j~ PAUL N. SANDLER, ESQUIRE Attorney for Plaintiff (") C) 0 c: ;v -n :?.: z ;:gee ~ .-n C'...: F~ Z N -f'l Z ~, , ~~.' w ,c. 0' .' -: --,-) r:: c. ~ '. :r, T j-=----, :::: ,) 0 ~...,.. .... , ';?' L...(, r-n )>' ~ c ~ .{:> :..> :q .~ -<- EXHIBIT "A" () c> 8 c N ~.,: :z -UG~ ~::> n'ln -< , ' ~ Z::c N 0.: 7 C- O', ',-, ~~ , / - ~~ ~:::c. "T) - :!>", ~ ,~:,j c) :2:'""" c,-o 0lT1 Pc: -~; ~ :..) 53 .r:- --< COMMONWEALTH OF PENNSYL VANIA COUNTY OF: CUMBERLAND Mag. Dist. No' 09-2-01 OJ Name: Hon PAULA P. CORREAL Add"" 1 COURTHOUSE SQUARE CARLISLE, PA T,I'phOO' (717) 240-6564 17013-0000 ATTORNEY FOR PLAINTIFF : PAUL N. SANDLER 1429 WALNUT ST. %SANDLER & MARCHESINI,PC PHILADELPHIA, PA 19102 nl1s IS TO NOTIFY YOU THAT: Judgment: NOTICE OF JUDGMENTfTRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 'RAHAL, DAVID &VIRGINIA I 911 WALNUT ST. CARLISLE, PA 17013 L ~ VS. DEFENDANT: NAME and ADDRESS 'BOUDER, LINDA 1122 PINE ROAD CARLISLE, PA 17013 L Docket No.: CV-0000338-02 Date Filed: 8/02/02 I ~ . ~ ~ ORFAm.T JImaMl?M'l' PT.TF Judgment was entered for: (Name) RAl.J2H. "AUT" "VT1U~TNTA Judgment was entered against: (Name) J\ormRR. T.TNTlA ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF C( , __~~, ~'.'L uIVISION. YOU MUST INCLUDE A COpy OF THI~ NOTICE OF JU~"SCRIPT FORM WITH YOUR NOTICE OF APPEA~. 1\)-1--0.: Date (J.J:, ~~--e. i' . ,O!strTctJusli,ce ....."...-"'0. .'.. ". ,,':toji;, .,.c. ",_, ~- I certify that this is a true and9>lFfe'Cr py 0.1 the,.record 0~.t'he.A,1'0S~'9ings cont~!\Ig:1he.judgment. 10-1.-02 Date ,', .<: "/,:..,t/~::>;/IV". ji , Di'strict JustiC" in the amount of $ 1 <;71 04 on: o Defendants are jointly and severally liable, o Damages will be assessed on: o This case dismissed without prejudice. o o o Amount of Judgment Subject to Attachment/Act 5 of 1996 $ Levy is stayed for days or 0 generally stayed, Objection to levy has been filed and hearing will be held: Date: Place: Time: / My commission expires first Monday of January, Aope 315-99 2006 (Date of Judgment) 10/07/02 (Date & Time) Amount of Judgment Judgment Costs Intpn:::H:::t An .......r_ $ 3.499.04 $ 72.00 l,g ~ ~ -~ '7 \~ ~O'& \. \.. ~ (:;~ r.t:i{.' ":~ SEAL ,II' , . ,'f .. . 8 0 0 r", " ;;: :z: "-; ulU C) , ~m .<:: ""JfQ ;r, N ;-,m z:~ 0"0 OJ? <:QZ -:)0 ~C} -0 :-~-rt '." ~G :x ~o >-2 c~rn z: ~ o;! ~ ~ +" -< SANDLER & MARCHESINI, P.e. BY: PAUL N, SANDLER, ESQUIRE ATTORNEY ID# 15711 1429 Walnut Street, 16th Floor Philadelphia, P A 19102 (215) 568-9300 DAVID AND VIRGINIA RAHAL COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. LINDA BOUDER NO,: AFFIDAVIT OF NON MILITARY SERVICE Paul N. Sandler, Esquire, being duly sworn according to law, deposes and says that he represents the Plaintiff in the above matter; that he is authorized to make this Affidavit on behalf of the Plaintiff; and the above-named Defendant is over 18 years of age; the address ofthe Defendant is 1122 Pine Road, Carlisle, P A 17013; that the occupations ofthe Defendant is unknown; and that the Defendant is not in the Military Service of the United States nor any State or Territory thereof or its allies as defined in the Soldiers and Sailors Civil Relief Action of 1940 and the amendments thereto. CHESINI, p,e. J BY: PAUL N. SANDLER, ESQUIRE Attorney for Plaintiff NOTARIAL SEAL BARBARA A DAILY, Notary P City of Phladelphia, Phila Coonty My CommISsion Expires July 14, 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA DAVID AND VIRGINIA RAHAL 911 WALNUT ST. CARLISLE, P A 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. LINDA BODnER 1122 PINE ROAD CARLISLE, P A 17013 NO.: NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MA TTERHAS BEEN ENTERED AGAINST YOu. (I~ -tc~ ;( /, PROTHONOTARY J~ If you have any questions concerning the above, please contact: Paul N. Sandler. Esauire Attorney or Party Filing 1429 Walnut Street. 16'h FI. Address(number, street) Phi1ade1ohia. PA 19102 (City, State, Zip) 215-4568-9300 (Phone No.) ~ '~i '---' - ~ >u c: )-c i)' ~ :f -...i <0 ~ ~ ~, r , - -- \ ~ \ c::: >- ~v o s;: -ot~1 nlf,-' Z.~:) 7:r~ U-) -~ r;:: +-;C~, ~:--:: (--:. >'C~ L;;" ~ <--- (-~ W CS ~]0~ 'I-- - ' '-' '--' "\ Cl tv o ,J '=' ~ \ - c5 <: ;"",) 01 71 rr~ ~ , '{J -~ ~ "--, -' -,., :J1: :lf~ ~ :J:J -< f A' ~ :..> +' SANDLER & MARCHESINI, P.e. BY: PAUL N. SANDLER, ESQUIRE ATTORNEY ID# 15711 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 DAVID AND VIRGINIA RAHAL COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NO.: {J;(. 5t. 91' LINDA BOUDER CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things, pursuant to Rule 4009.22, Annamarie Denelsbeck, Esquire, attorney for the plaintiff, certifies that: 1. A Notice of Intent to Serve the Subpoena with a copy of the subpoena attached thereto was mailed or delivered to Defendant, Regina Booz, at least twenty (20) days prior to the date on which the subpoena is sought to be served; 2. A copy of the Notice of Intent and a copy the proposed subpoena was mailed on November 25, 2002 and the Notice has not been returned to sender; 3. No objection to the subpoena has been received; and 4. The subpoena which will be served is identical to the subpoena which is attached to the Notice of Intent to Serve a Subpoena. SANDLER & MARCHESINI, P.c. BY: lL{~ ~ NNAMARIE DENELSBECK, ESQUIRE (') c ~ ""OrD ITIITi Z:ri Zr: (f.)", , -s:/- c..C.-! ~ ,- Z(j ::...C:> ,.l>c:: Z ~ - " C) 1'V o r..., ("') o ~.n -on P"; - ,rn .~?y ':,:~; (~) <=,rj : '\-:-, <:() (,51""1'1 ---I 1:; -< G) ;t:;',. :J1.; If? ro SANDLER & MARCHESINI, P.e. BY: PAUL N. SANDLER, ESQUIRE ATTORNEY ID# 15711 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 DAVID AND VIRGINIA RAHAL COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NO.: 02-5~C;9 LINDA BOUDER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff intends to serve a subpoena identical to the one that is attached to this Notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. SANDLER & MARCHESINI, P.C. Bya~ ANNAMARIE DENELSBECK, ESQUIRE Attorney for Plaintiff (') 0 0 C N ., ..". C:J ~. -orD i'1 rnp"J ,) 2::11 -;7 ;:-.. (,?'~," (...) ::S ,cO C\...) :!::~ 3>- z'...} -.... --=( , I.D ~ .:.) Pc: ---I Z '-~ ,,- =< .:D CO -< ~ , SANDLER & MARCHESINI, P.C. BY: PAUL N. SANDLER, ESQUIRE ATTORNEY ID# 15711 1429 Walnut Street, 16th Floor Philadelphia, P A 19102 (215) 568-9300 DAVID AND VIRGINIA RAHAL COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NO.: 2002 - 5699 LINDA BOUDER PRAECIPE TO ISSUE STATE FORM 201 TO THE PROTHONOTARY: Kindly certify the attached State Form 201 in the above captioned matter reflecting the judgment entered against the defendant, Linda Bouder, whose date of birth is June 5, 1948. Judgment was entered on November 26,2002, in the amount of$3,571.04. I certify that this judgment arose out of a motor vehicle accident, that sixty days have elapsed since the entry of said judgment, that the judgment has not been satisfied of record and, further, that no appeal has been taken therefrom. SANDLER & MARCHESINI, P.C. BY: ~~ ANNAMARIE DENELSBECK, ESQUIRE Attorney for Plaintiff t::) \ 0 0 ~ c w 0 tt <>v -of?: -" -n ITlfT r'l"l C) ~S(, co ~ ~ D ../ ., -,:: ~ ~ ~ ~:: ~ ~ ~~ ~:~~ ..-.~... -.a ~~ c~~~ U':) r -,r- .. ~ '" ~ -<. (:) ~ DA VE and VIRGINIA RAHAL : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, P A v. : No. 02-5699 CIVIL LINDA BOUDER PETITION FOR INSTALLMENT PAYMENT OF JUDGMENT PER 75 Pa. C.S.A. ~1775 TO THE HONORABLE, THE JUDGE OF THE SAID COURT: AND NOW, comes Linda Bouder, Petitioner, by and through her attorney, Gregory Barton Abeln, Esquire, who petitions this Honorable Court for an installment payment of judgment and avers as follows: 1. October 7, 2002, ajudgment in the amount of$3,571.04 was entered against Petitioner, Linda Bouder, due to an accident that occurred in March 26,2002 in Carlisle, Pennsylvania. 2. On March 21, 2003, the Commonwealth of Pennsylvania, Department of Transportation, issued a suspension notice upon Petitioner pursuant to 75 Pa.C.S.A. ~ 1772 for the nonpayment of judgment. The effective date of suspension is April 25, 2003. 3. At the time of the incident, the Petitioner had her insurance coverage lapse due to her unemployment and was unable to make restitution payments. 4. The Petitioner has recently returned to full-time employment and needs her car in order to work. 5. Petitioner believes that she can pay $200.00 a month towards this obligation. 6. Plaintiff's, David and Virginia Rahal, have informed the undersigned counsel that their insurance company had their car repaired and they are not asking for restitution, but believe that their insurance company, Hartford Insurance Company, would be interested in restitution. WHEREFORE, for the foregoing reasons, it is respectfully requested of this Honorable Court that an Order be issued authorizing installment payments in the amount of$200.00 a month. Respectfully submitted, ABELN LAW OFFICES iffU:-(03 Dae ~~e~ Gregory Barton Abeln, Esquire 37 E. Pomfret Street Carlisle, PA 17013 717/245-2851 SANDLER & MARCHESINI, P.C. BY: PAUL N. SANDLER, ESQUIRE ATTORNEY ID# 15711 1429 Walnut Street, 16th Floor Philadelphia, P A 19102 (215) 568-9300 DAVID AND VIRGINIA RAHAL 911 WALNUT ST. CARLISLE, P A 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NO.: DrJ- 6-(Pqq {!uut LINDA BOUDER 1122 PINE ROAD CARLISLE, PAl 7013 .-~. ~ ~ $: % .~ -0 ....., ...... or !i1 m :c: hi ;g Z;J:l -....m zc;: N :09 $z Ci' 06 r: CJ - -1 -rj ;< -0 25 .,., TO THE PROTHONOTARY: ~8 ~ O~ ~2 ~ ~ Kindly enter judgment on behalf of plaintiffs, David and Virginia Rahal, ana against :< PRAECIPE TO ENTER JUDGMENT defendant, Jeffrey Matta, in the sum of$3,5 71. 04. Said judgment is based upon a certified judgment entered by the Honorable Paula P. Correal, District Justice, a copy of which is attached hereto as Exhibit "A". I hereby certify that the above stated addresses are truc~ and correct. SANDLER & MARCHESINI, P.e. By:iJJIJ~ PAUL N. SANDLER, ESQUIRE Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA DAVID AND VIRGINIA RAHAL 911 WALNUT ST. CARLISLE, PA 17013 COURT OF COMMON PLEAS CUMBERLMfD COUNTY vs. NO.: LINDA BOUDER 1122 PINE ROAD CARLISLE, PA 17013 NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOu. ~~L PROTHONOTARY v "'(J If you have any questions concerning the above, please contact: Paul N. Sandler. Esquire Attorney or Party Filing 1429 Walnut Street. 16th Fl. Address(number, street) Philadelphia. P A 19102 (City, State, Zip) 215-4568-9300 (Phone No.) SANDLER & MARCHESINI, P.C. BY: PAUL N. SANDLER, ESQillRE ATTORNEY ID# 15711 1429 Walnut Street, 16th Floor Philadelphia; P A 19102 (215) 568-9300 DAVID AND VIRGINIA RAHAL COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NO.: LINDA BOUDER AFFIDAVIT OF NON MILITARY SERVICE Paul N. Sandler, Esquire, being duly sworn according to law, deposes and says that he represents the Plaintiff in the above matter; that he is authorized to make this Affidavit on behalf of the Plaintiff; and the above-named Defendant is over 18 years of age; the address of the Defendant is 1122 Pine Road, Carlisle, PA 17013; that the occupations of the Defendant is unknown; and that the Defendant is not in the Military Service of the United States nor any State or Territory thereof or its allies as defined in the Soldiers and Sailors Civil Relief Action of 1940 and the amendments thereto. LER & l\.~CHESINI, P.e. ( - , BY: PAUL N. SANDLER, ESQUIRE Attorney for Plaintiff NOTARIAL SEAL BARBARA.A. DAILY. Notary P City of Ph~adelphia. Phila. County My Commission Expires Jut 14.2003 ;, EXHIBIT "A" '. C.OMMQNWEAL TH OF PENNSYLVANIA oJ COUNTY OF: CUMBERLAND Mag, Dls!. No,: 09-2-01 DJ Name: Hon. PAULA P. CORREAL Address: 1 COURTHOUSE SQUARE CARLISLE, PA Telephone: (717) 240-6564 17013-0000 ATTORNEY FOR PLAINTIFF : PAUL N. SANDLER 1429 WALNUT ST. %SANDLER & MARCHESINI,PC PHILADELPHIA, PA 19102 NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE . PLAINTIFF: NAME and ADDRESS ~, DAVID &VIRGINIA I 911 WALNUT ST. CAB1~ISLE, PA 17013 L -.J VS. DEFENDANT: NAME and ADDRESS fBOUDER, LINDA 1122 PINE ROAD CARLISLE, PA 17013 L Docke't No.: CV-0000338-02 Date Filed: 8/02/02 I -.J .',," ...... . , .- THIS IS TO NOTIFY YOU THAT: Judgment: DEFAm.T JUDGMENT PLTF [i] Judgment was entered for: (Name) 'R~'UT'I n~VTn "'VT'R~TWT~ [i] Judgment was entered against: (Name) ROITnR'R, r.TNnA in the amount of $ ~ I li71 04 on: D Defendants are jointly and severally liable. D Damages will be assessed on: D This case dismissed without prejudice. D Amount of Judgment Subject to Attachment/Act 5 of 1996 $ D Levy is stayed for days or D generally stayed. D Objection to levy.has been filed and hearing will be held: (Date of Judgment) 10/07/02 w . (Date & Time) Amount of Judgment $ 3.499.04 Judgment Costs $ 72.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 3.571.04 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ Date: Place: I I 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 INCLUDE A COpy OF THI~ N~TlCE OF JU~~SCRrPT FORM WITH YOUR NOTlC~ OF APPEAL. . '-i..." Date (.d./., ~"",-,-e. ' DlstrictJustice I certify that this is a true and correcfcopy of the record of the proceedings containlpQ the judgment. .. ,1./ '/. .... Date . ",..~"'" /'.-,. " .. ," .,;' ;:;; , District Justice. .' ,.~'";..._,....# \" "-: 1- '; ..0) , .", My commission expires first Monday of January, AOPC 315-99 2006 '. ,.' .... SEAL , .,"" DA VE and VIRGINIA RAHAL : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA v. : No. 02-5699 CIVIL LINDA BOUDER CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing PETITION FOR INSTALLMENT PAYMENT OF JUDGMENT by mailing a true and exact copy addressed to the following: For Hartford Insurance Company AND Plaintiffs, David and Virginia Rahal: Paul Sandler, Esquire 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 AND Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront OffiCe: Harrisburg, P A 17104-2516 Respectfully submitted, ABELN LAW OFFICES Date Lj -old. 0 ?> ~f1d- f. ~ Darlene F. Mellinger r Legal Assistant 37 East Pomfret Street Carlisle, PA 17013-3313 717/245-2851 ,<, j 2:~ ~: ._r.- ! C' ";-. 'U "'..J ",) 1'-) :".) :,J1 (.11 _:.. o -i1 --, ~I--! DA VE and VIRGINIA RAHAL : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, P A v. : No. 02-5699 CIVIL LINDA BOUDER ORDER OF COURT AND NOW, this 2 y~ day of +1 ,2003, upon consideration of the within Petition for Installment Payment of Judgment, said Petition is GRANTED. Petitioner is ordered to pay Hartford Insurance Company, Account No. SUV390394, $200.00 a month until the judgment sum of$3,57l.04 has been satisfied. Payment to the Hartford Insurance Company is to begin on the 1'5 - day of /lJ ~ ,2003. The Pennsylvania Department of Transportation shall restore Petitioner's operating privileges effective immediately, provided that the judgment debtor furnishes proof of financial responsibility. In the event the judgment debtor fails to pay any installment as specified by this Order, then, upon notice of the default the Department shall suspend the operating privilege of the judgment debtor until the judgment is satisfied. By the Court, Paul Sandler, Esquire - Cor''!. I'Y\ t~ F or the Hartford Insurance Com any and the Plaintiff Gregory Barton A?~ln, Esquire - Cory PE.uo..:f;z..[Cy 9 I CJ~ For the PetItIOner 1_ / Pennsylvania Department of Transportation, Office of Chief Counsel .. Co/J y m;;u~ J{/~u/OJ ~ .A~ cc: J. 'v'INV^lASNN3d JJ.NnO~) C1N\!:H:jBV'lnO 20 :OnlV r; l ddij 80 ^tl\{lC;~;~iH_J,;:.; ...JO =l~)I:J:iO-{j:\ SA;\lDLER & MARCHESINI, P.e. BY PAUL N, SANDLER, ESQUIRE ATTORNEY lD# 15711 1429 Walnut Street, 161h Floor Philadelphia, PA 19102 (215) 568-9300 DA VlD AND VIRGINIA RAHAL 911 WALNUT ST CARLISLE, PA 17013 VS, LlNDA BOeDER 1122 PINE ROAD CARLISLE, PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO,: 02-5699 - Civil ORDER TO MARK JUDGMENT SA TlSFlED TO THE PROTHONOTARY: Kindly Mark the Judgment entered on October 7, 2002 in the amount of $3,571.04 SA TIS FlED. (;\J\JNS\HAKTFORD\RahaJ-/\ord mark. saLwpd SANDLER & MARCHESINI, P.e. By:h~- P~ N. SANDLER, ESQUIRE Attorney for Plaintiff ..., r-:\ G) c', --~------