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