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HomeMy WebLinkAbout03-0714BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street. Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF WEST FLORIDA 11000 University Parkway Pensacola, FL 32514 Plaintiff I nave served upon all other : '~c~'nevs by: CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION VS. JACQUELINE PATTI 139 Burnhouse Road Carlisle, PA 17013 Defendant NO. OS- 7]y PRAECIPE TO TRANSFER JUDGMENT TO THE PROTHONOTARY: Please enter judgment against the above captioned Defendant in accordance with Pennsylvania Rules of Civil Procedure 3002 as follows: Amount of Judgment entered in the C.P. Chester Court Court Costs Interest at 6% from 03/22/02 to 12/22/02 $8,535.36 + 6.25 + 426.77 Dated: AMOUNT OF JUDGMENT $8,968.38 GORDIN & BERGER, P.C. EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff DATE 12/16/02 CIVIL COURT MANAGEMENT JYSTEM CASE SUMMARY REPORT PAGE 02-02474 I FOREIGN JUDGMENT CASE INITIATION DATE 03/22/02 CASE STATUS ACTIVE ARBITRATION DATE TRIAL READY DATE 00/00/00 03/22/02 11:27 A TWP/TAX PARCEL #: LIEN FOR: LIEN AGAINST: PLJklNTIFF WEST FLORIDA UNIVERSITY OF V. JACQUELINE PATT 11:27 A ARBITRATION TIME $8585.36 NOT ACTIVE SINCE 00/00/00 REOPEN DATE 00/00/00 PLUS COSTS WEST FLORIDA UNIVERSITY OF JACQUELINE PATTI WEST FLORIDA T~IIVERSITY OF 11000 UNIVERSITY PARKWAY PENSACOLA FL 32514 ATTORNEY: 034116 TEL: 215-564-2031 EDWARD L. BERGER C-ORDIN & BERGER, P.C. 1760 MARKET ST STE 600 PHILADELPHIA, PA 19103 PA 19335 VS. DEFENDANT JACQUELINE PATTI 416 GARFIELD AVENUE DOWNINGTOWN 03/22/02 DATE DOCKET INFORMATION 03/22/02 03/22/02 03/22/02 03/22/02 03/22/02 03/22/02 03/22/02 lO/¢4/o2 LIEN ENTERED IN FAVOR OF WEST FLORIDA UNIVERSITY OF AGAINST JACQUELINE PATTI IN THE AMOUNT OF $8,585.36 PRAECIPE FOR FILING OF FOREIGN JUDGMENT PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAG ES AFFIDAVIT OF NAMES AND ADDRESSES OF PARTIES AND VALIDIT Y OF JUDGMENT CERTIFICATION OF MAILING COPY OF PRAE FOR FILING OF FOREIGN JUDGMENT CERTIFICATION-NOTICE SENT 236 APPEARANCE OF EDWARD L. BERGER FOR WEST FLORIDA UNIVERSITY OF PRAEcIPE - EXECUTION & WRIT ISSUED CERTIFIED FROM THE RECORD DATE 12/16/02 CIVIL COURT MANAGEMENT ~YSTEM CASE SUMMARY REPORT PAGE WRITS TO SHERIFF BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street. Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF WEST FLORIDA 11000 University Parkway Pensacola, FL 32514 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff VS. JACQUELINE PATTI 139 Bumhouse Road Carlisle, PA 17013 Defendant NO. O3 ASSESSMENT OF DAMAGES AND NOW, to wit, this /(~ day of~, Judgment is entered in favor of the above referenced Plaintiff, and against JACQUELINE PATTI, the above referenced Defendant, for failure to file an Answer and Plaintiffs damages are assessed in the sum of $8,968.38. BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street. Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF WEST FLORIDA 11000 University Parkway Pensacola, FL 32514 Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION VS. JACQUELINE PATTI 139 Bumhouse Road Carlisle, PA 17013 Defendant NO. 03 AFFIDAVIT OF NON-MII,ITARY SERVICE COMMONWEALTH OF PENNSYLVANIA · · SS COUNTY OF PHILADELPHIA · EDWARD L. BERGER, ESQUIRE, being duly sworn according to law, hereby deposes and says that I am thc attorney for the Plaintiff in the above captioned action, and that the following Defendant is not in the Military Service of thc United States of America or any State or Territory thereof, or its allies, and that the Defendant is not in any manner subject to the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940, as amended: Jacqueline L. Patti 139 Burnhouse Road Carlisle, PA 17013 SWORN TO AND SUBSCRIBED BEFORE ME THIS / 6~DAY OF ~Vavd · , 2002. NOTARY PU/£ICd ' f / ~AL S~L ~ ~_~ 8d~lN, Nota~ Public J ,,~hilad~phia, ~i~. Coun~ ] [~My ~omm~n Exp~ ~a~ ~, ~5 EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff OFFICE ~ROTHONOTARy · - To: Ms. Jacqueline Patti 139 Burnhouse Road Carlisle, PA 17013 OF cOuRT OF COMMON THE PROTHONOTARY PLEAS UNIVERSITY OF WEST FLORIDA VS. JA~QUELINE PA~I CUMBERLAND OOUNTY COURT OF COMMON PLEAS Term, 19_ No. -- '7/',/ NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you ate hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. /') Prothonotary [] Judgment by Default ~ Money Judgment [] Judgment in Replevin at this telephone number: [~ Judgment for Possession [] Judgment on Award of Arbitration [] Judgment on Verdict [~ Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY EDWARD L. BERGER (Inse~t Attorney's N~ne) Esquire (215)564-2031 5-60 (2) (Rev. 4,'78) IN THE COURT OF COMMON PI,EAS OF CUMBERLAND COUNTY~ PENNSYLVANIA CIVIL DIVISION UNIVERSITY OF WEST FLORIDA 11000 UNIVERSITY PARKWAY PENSACOLA, FL 32514 V. JACQUELINE L. PATTI 139 BURNHOUSE ROAD CARLISLE, PA 17013 SS# 264-63-7182 File No. 03-714 Amount Due $8,968.38 Interest from 02-19-03 Atty's Comm Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter to the Sheriff of CUMBERLAND County, for debt, interest and costs upon the folli53Ving described property of the Defendant(s) All contents of Defendant's residence, including but not limited to all furniture, clothing, jewelry, electronic equipment, electrical appliances, kitchen utensils, silverware, televisions, stereo equipment, tools and any other property subject to levy located at 139 BURNItOUSE ROAD, CARLISLE, PA 17013.. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the Defendant(s) in the possession, custody or control of the said Garnishee(s). __ (Indicate) Index this writ against the Garnishee(s) as a lis pendens against real estate of the Defendar~t(s) described in the attached exhibit. DATE: ~~m\ Signature: Print Name: Address: Attorney for: Telephone: Supreme Court ID No. Edward L. Berger, Esquire Gordin & Berger, P.C. 1760 Market Street, Suite 600 Philadelphia, PA 19103 Plaintiff 215-564-2031 34116 Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (Pa. R.C.P No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-714 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIVERSITY OF WEST FLORIDA, Plaintiff (s) From JACQUEL1NE L. PATTI, 139 BURHOUSE ROAD, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL CONTENTS OF DEFENDANT'S RESIDENCE, INCLUDING BUT NOT LIMITED TO ALL FURNITURE, CLOTHING, JEWELRY, ELECTRONIC EQUIPMENT, ELECTRICAL APPLIANCES, KITCHEN UTENSILS, SILVERWARE, TELEVISIONS, STEREO EQUIPMENT, TOOLS AND AND ANY OTHER PROPERTY SUBJECT TO LEVY LOCATED AT 139 BURNHOUSE ROAD, CARLISLE, PA 17013. (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 $8,969.38 Interest FROM 2/19/03 Atty's Comm % Arty Paid $37.50 Plaintiff Paid Date: MARCH 31, 2003 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Deputy REQUESTING PARTY: Name EDWARD L. BERGER, ESQUIRE Address: GORDIN & BERGER, P.C. 1760 MARKET STREET, SUITE 600 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-564-2031 Supreme Court ID No. 34116 R, THOMAS KLINE Shedff EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF One Cou~house Square Carlisle, Pennsylvania 17013 RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Deputy May 1, 2003 University of West Florida vs Jacqueline L. Patti No. 2003-714 Civil Term Property Claim Determination Dear Sir, Reference is made to Property Claim dated April 22, 2003, entered By Steve Fredette pertaining to Writ of Execution No. 2003-714 Civil Term, University of West Florida -vs- Jacqueline L. Patti. R. Thomas Kline, Sheriff, has determined that the claimant, Steve Fredette, in the above mentioned property claim, is prima facie the owner of the property set forth therein. CC: Edward Berger, Atty for Pltff Jacqueline L. Patti, Deft. Steve Fredette, Claimant So Answers: as Kline, Sheriff R. THOMAS KLINE Sheriff EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Deputy May 1, 2003 University of West Florida vs Jacqueline L. Patti No. 2003-714 Civil Term Property Claim Determination Dear Sir, Reference is made to Property Claim dated April 22, 2003, entered By Jacqueline L. Patti, for property of Mainli'ne Consulting Consortium, Inc. pertaining to Writ of Execution No. 2003-714 Civil Term, University of West Florida -vs- Jacqueline L. Patti. R. Thomas Kline, Sheriff, has determined that the claimant, Jacqueline L. Patti, in the above mentioned property claim, is prima facie the owner of the property set forth therein. CC; So Answers: Edward Berger, Atty for Pltff Jacqueline L. Patti, Deft. Jacqueline L. Patti, Mainline Consulting Consortium, Inc., Claimant R. THOMAS KLINE Sheriff EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF One Cou~house Square Carlisle, Pennsylvania 17013 RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Deputy May 1, 2003 University of West Florida vs Jacquelinc L. Patti No. 2003-714 Civil Term Property Claim Determination Dear Sir, Reference is made to Property Claim dated April 22, 2003, entered by Cynthia A. Patti, pertaining to Writ of Execution No. 2003-714 Civil Term, University of West Florida -vs- Jacqueline L. Patti. R. Thomas Kline, Sheriff, has determined that the claimant, Cynthia A. Patti, in the above mentioned property claim, is prima facie the owner of the property set forth therein. CC: Edward Berger, Atty for Pltff Jacqueline L. Patti, Deft. Cynthia A. Patti, Claimant So Answers: R. Thomas Kline, Sheriff R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Post Pone Sale Garnishee TOTAL 18.00 1.26 · .50 1.00 3.45 20.00 20.00 $ 64.21 Advance Costs: 150.00 Sheriff's Costs: 64.21 $ 85.79 Refunded to Atty on 01/09/04 Sworn and Subscribed to before me This ~ ~day o · ~Ptothonotary ' R. Thomas Kline, Sheriff By Claudia A. Brewbaker