The URL can be used to link to this page

Home My WebLink About01-0913 FX , COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BELL ATLANTIC - PENNSYLVANIA, INC, Plaintiff No. 2001-00913 vs. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant(s) ORDER AND NOW, this day of , 2002, upon consideration of Defendant's Petition to Stay execution and renew petition to strike/Open Judgment, Plaintiffs response thereto, and after hearing thereon, it is hereby; ORDERED that Defendant's Petition is DENIED. BY THE COURT: J. ~[''Y~''''71 """",:,"~'''i"::,-,,,;:-,,<;fil*,,'.''~</'.' '- .-~.",.;j:"_:~.',-'>,:;1"'''-;:I\;l!I'.;:''!''1',;" -,,,~,.,,(',-,,,,=, . -, '" ",1 - .~, .0-:0__"-,-' .,' "-,," ."'-, "~."''-'_-:-'':'''', .!!")L,./ll'!!,,,,.,.,,,. .,".' _~.' ., , COURT OF COMMON PLEAS OF CUMBERLAND. COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BELL ATLANTIC - PENNSYLVANIA, INC. Plaintiff No. 2001-00913 vs. KARL E, ROMINGER i/t/a ROMINGER WEB Defendant(s) ORDER AND NOW, this day of , 2002, upon consideration of Defendant's Petition to Stay execution and renew petition to strike/Open Judgment, Plaintiffs response thereto, and after hearing thereon, it is hereby: ORDERED that Defendant's Petition is DENIED. BY THE COURT: J. ~<'?=' , '-"'-'~'."".-,~ .,. -'""."''';- "~"'. _._~):c~'.I~1 '-,'..~-."1" _,., C'" _ ','C,'_'.." . 'I~- . - ~--, '--'/~-~'.=~".'~""'.~- ,"~' '- " ,- MAR 1 9 2001!! COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BELL ATLANTIC - PENNSYLVANIA, INC. Plaintiff No. 2001-00913 vs. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant( s) ORDER AND NOW, this day of , 2001, upon consideration of Defendant's Petition to Strike/Open Judgment, Plaintiffs response thereto, and after hearing thereon, it is hereby; ORDERED that Defendant's Petition to Strike/Open Judgment is DENIED. BY THE COURT: J. r.', ~ ~. ., _ '"_"' "", -,' _ ,,' , , 1',1- ,.,-- . COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BELL ATLANTIC - PENNSYLVANIA, INC. Plaintiff No. 2001-00913 vs. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant( s) ORDER AND NOW, this day of , 2001, upon consideration of Defendant's Petition to Strike/Open Judgment, Plaintiff's response thereto, and after hearing thereon, it is hereby: ORDERED that Defendant's Petition to Strike/Open Judgment is DENIED. BY THE COURT: J. ',-,^!", .'~."71':'."".."..",".,~=,.."" o^ .,. ,.,.,. ,', ~".I'!!!!L~,_..-""",,",, ..,~''''_',,",.'~. ,_ ~" - - ,< ~ ~ . BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant ORDER OF COURT AND NOW, this _ day of , 2001, upon consideration of the Petition to Strike/Reopen Judgment of the Defendant, A Rule to Show Cause is issued upon Bell Atlantic Pennsylvania to show cause why the relief requested should not be granted. Said Rule returnable (20) twenty days of the date of service of this Order. Pending resolution of this Petition a Stay of Execution is granted. By the Court: 1. Distribution: Karl E. Rominger, Esquire Ronald Amato, Esquire Cumberland County Sheriff ,,,,JI!'1, . r I MAR 0 6 200f 6P BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant ORDER OF COURT AND NOW, this _ day of ,2001, upon consideration of the Petition to Strike/Reopen Judgment of the Defendant, A Rule to Show Cause is issued upon Bell Atlantic Pennsylvania to show cause why the relief requested should not be granted. Said Ru1e returnable (20) twenty days of the date of service of this Order. Pending resolution of this Petition a Stay of Execution is granted. By the Court: J. Distribution: Karl E. Rominger, Esquire Ronald Amato, Esquire Cumberland County Sheriff :",- 11 . ,. , BELL ATLANTIC - PENNSYLVANIA, Plaintiff ; IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant PETITION TO STRIKEIREOPEN JUDGMENT AND NOW, comes Karl E. Rominger, pro se, and avers as follows: 1. Judgment was entered on the 2 7/lday of 0 C f. ,2000, in Philadelphia Municipal Court. 2. Said Judgment was transferred on February 14,2001 to Cumberland County Prothonotary for entry upon the record. 3. Petitioner disputes the validity of that Judgment. 4. Petitioner believes and therefore avers that the Judgment was entered by a Court which did not have subject matter jurisdiction to do such. I. MOTION TO STRIKE FOR LACK OF SUBJECT MATTER JURISDICTION 5. Previous paragraphs incorporated by reference. 6. Under the Judicial Code and pursuant to the Rules of Civil Procedure governing actions which proceed before District Justices, in particular Rule 302. Venue., subject matter jurisdiction did not exist. 7. The Judgment transferred to Cumberland County is based upon a Court Order and "''''.,_ 0.- 1.1 c c. " Judgment where the underlying Court did not have subject matter jurisdiction, and the Judgment is void. 8. Petitioner requests that this Court strike said Judgment from the Cumberland County Docket with prejudice. WHEREFORE, Petitioner respectfully requests that this Honorable Court strike or vacate the Judgment in the above captioned matter, and pending resolution Stay of Execution. II. MOTION TO STRIKE/REOPEN JUDGMENT FOR LACK OF PERSONAL JURISDICTION 9. Previous paragraphs incorporated by reference. 10. The Judgment transmitted to Cumberland County is defective on its' face insomuch as it does not contain any evidence that personal jurisdiction was obtained by the issuing authority. 11. Without personal jurisdiction, the Judgment is infirm and should be voided or struck from the record. WHEREFORE, because the Judgment in the above referenced matter, contains no evidence of the Court securing personal jurisdiction over the Defendant, Petitioner respectfully requests that this Honorable Court strike said Judgment or in the alternative open said Judgment. Respectfully submitted, ?~ Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Date: March 2, 2001 ,,~-~ , ~ - 1--1 ._0 , BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; No. 2001-00913 v. KARL E. ROMINGER i/t1a ROMINGER WEB Defendant CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, pro se do hereby certify that I this day served a copy of the Motion to Strike upon following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Ronald Amato, Esquire AMATO AND MARGLE, P.C. 107 North Commerce Way Bethlehem, PA 18017 ~~ Karl E. Rominger, Esquire Pro Se Dated: March 2, 2001 ':!:..,OCJ! '1" , Ll .. ~ " .ill MAR 0 6 ZOOt.P BELL ATLANTIC - PENNSYLVANIA, Plaintiff ; IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant ORDER OF COURT AND NOW, this _ day of , 2001, upon consideration of the Petition to Strike/Reopen Judgment of the Defendant, A Rule to Show Cause is issued upon Bell Atlantic Pennsylvania to show cause why the relief requested should not be granted. Said Rule returnable (20) twenty days of the date of service of this Order. Pending resolution of this Petition a Stay of Execution is granted. By the Court: J. Distribution; Karl E. Rominger, Esquire Ronald Amato, Esquire Cwnberland County Sheriff ,'q~, 'I'" I I' .", "11 '""~, " " BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; No. 2001-00913 v. KARLE. RONUNGERiWa ROMINGER WEB Defendant PETITION TO STRIKEIREOPEN JUDGMENT AND NOW, comes Karl E. Rominger, pro se, and avers as follows: 1. Judgment was entered on the 2 #lday of () C I. ,2000, in Philadelphia Municipal Court. 2. Said Judgment was transferred on February 14, 2001 to Cumberland County Prothonotary for entry upon the record. 3. Petitioner disputes the validity of that Judgment. 4. Petitioner believes and therefore avers that the Judgment was entered by a Court which did not have subject matter jurisdiction to do such. I. MOTION TO STRIKE FOR LACK OF SUBJECT MATTER JURISDICTION 5. Previous paragraphs incorporated by reference. 6. Under the Judicial Code and pursuant to the Rules of Civil Procedure governing actions which proceed before District Justices, in particular Rule 302. Venue., subject matter jurisdiction did not exist. 7. The Judgment transferred to Cumberland County is based upon a Court Order and ,;L. i"" .'e""" If , -' '" Judgment where the underlying Court did not have subject matter jurisdiction, and the Judgment is void. 8. Petitioner requests that this Court strike said Judgment from the Cumberland County Docket with prejudice. WHEREFORE, Petitioner respectfully requests that this Honorable Court strike or vacate the Judgment in the above captioned matter, and pending resolution Stay of Execution. II. MOTION TO STRIKE/REOPEN JUDGMENT FOR LACK OF PERSONAL JURISDICTION 9. Previous paragraphs incorporated by reference. 10. The Judgment transmitted to Cumberland County is defective on its' face insomuch as it does not contain any evidence that personal jurisdiction was obtained by the issuing authority. 11. Without personal jurisdiction, the Judgment is infirm and should be voided or struck from the record. WHEREFORE, because the Judgment in the above referenced matter, contains no evidence of the Court securing personal jurisdiction over the Defendant, Petitioner respectfully requests that this Honorable Court strike said Judgment or in the alternative open said Judgment. Respectfully submitted, ?~ Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ill # 81924 Date: March 2,2001 ... '1 , ~.,. 1"1 " '., . " BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER iltla ROMINGER WEB Defendant CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, pro se do hereby certif'y that 1 this day served a copy of the Motion to Strike upon following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Ronald Amato, Esquire AMATO AND MARGLE, P.C. 107 North Commerce Way Bethlehem, PAl 80 17 ~~ Karl E. Rominger, Esquire Pro Se Dated: March 2, 2001 :~.;~~,~~"" 'j 1'1 ., ., r -~~ / MAR 0 6 200tfP BELL ATLANTIC - PENNSYLVANIA, Plaintiff ; IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant ORDER OF COURT AND NOW, this _ day of ,2001, upon consideration of the Petition to Strike/Reopen Judgment of the Defendant, A Rule to Show Cause is issued upon Bell Atlantic Pennsylvania to show cause why the relief requested should not be granted. Said Rule returnable (20) twenty days of the date of service of this Order. Pending resolution of this Petition a Stay of Execution is granted. By the Court: J. Distribution: Karl E. Rominger, Esquire Ronald Amato, Esquire Cumberland County Sheriff . , ~., ',_hr_ ,< '~.'"'~'~_ 1"1 ~- . . BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant PETITION TO STRIKE/REOPEN JUDGMENT AND NOW, comes Karl E. Rominger, pro se, and avers as follows; 1. Judgment was entered on the 2 7/lday of 0 C f. ,2000, in Philadelphia Municipal Court. 2. Said Judgment was transferred on February 14, 2001 to Cumberland County Prothonotary for entry upon the record. 3. Petitioner disputes the validity of that Judgment. 4. Petitioner believes and therefore avers that the Judgment was entered by a Court which did not have subject matter jurisdiction to do such. I. MOTION TO STRIKE FOR LACK OF SUBJECT MATTER JURISDICTION 5. Previous paragraphs incorporated by reference. 6. Under the Judicial Code and pursuant to the Rules of Civil Procedure governing actions which proceed before District Justices, in particular Rule 302. Venue., subject matter jurisdiction did not exist. 7. The Judgment transferred to Cumberland County is based upon a Court Order and '!L , --~. . .-11 -!" I Judgment where the underlying Court did not have subject matter jurisdiction, and the Judgment is void. 8. Petitioner requests that this Court strike said Judgment from the Cumberland County Docket with prejudice. WHEREFORE, Petitioner respectfully requests that this Honorable Court strike or vacate the Judgment in the above captioned matter, and pending resolution Stay of Execution. II, MOTION TO STRIKEIREOPEN JUDGMENT FOR LACK OF PERSONAL JURISDICTION 9. Previous paragraphs incorporated by reference. 10. The Judgment transmitted to Cumberland County is defective on its' face insomuch as it does not contain any evidence that personal jurisdiction was obtained by the issuing authority. 11. Without personal jurisdiction, the Judgment is infirm and should be voided or struck from the record. WHEREFORE, because the Judgment in the above referenced matter, contains no evidence of the Court securing personal jurisdiction over the Defendant, Petitioner respectfully requests that this Honorable Court strike said Judgment or in the alternative open said Judgment. Respectfully submitted, ?~ Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ID # 81924 Date: March 2, 2001 " y~ -I" ^.. I BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, pro se do hereby certifY that I this day served a copy of the Motion to Strike upon following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Ronald Amato, Esquire AMATO AND MARGLE, P.C. 107 North Commerce Way Bethlehem, PA 18017 ~~ Karl E. Rominger, Esquire Pro Se Dated: March 2, 200 I " " 1'1" , . ~~~lf~c;ri;;:~:t~~2;;t,\.~%1!:w{~;~~t:t;;~t?;;:Z~;i;;"',\i;j';}4,;<f~~J;;';;YC;~Yf~~"f5. ~~ ~ i 11:0 ~ ,,f' ~", "'it () fl t',r~ ~ '€'~ ~:4 tf"",,14 a: -.t:r",~......"o "f:~I.~(iC::J ~:r 'f; '" ~ Q,g; ~ oJJ'-"N ~f'o,-..."!'.. -f.: -':-1J''t ..;i" ..~ ~ ~ ~ l .~ ~ ~ 1'1-' i :i>;J;:> ., 1;5 11).... - ~ I;; - 0 ~c o g c_ o~ ::J:c .r:;C ;;,f o _ "'II) "'''' "'- -6 u ,~"" . __'c,",,, I c..5 ~ ~. l? ,-,.....JiS '3 g ,-,,, O"'~ 2 ~ '" ,-,0 ~ s ~ o"Q S--< tilZo,,-< S --< u " --<0'125 "r:lf-<o~ ~--<Z~ s~"iJ ~--<;::d5 - , -"~h::;t~i~4:';ihY;::);'!j.~ffk:~11,'-:JiAit;l22;it~';;J:'f~~t:t.:;;;~;%/~'* .1 , I i " ,1 , T! ~ ~ ~ .~ ~ ~" :~ijti)~;. L;';;:' ~n ~,1ltl if: m I~J ~-!>;~/~~J t' (! ~ ~ ,< \>j. "'" I~ '(~'... 'tiI' """,-J r~ "~.fJMiO ~. ~: <10 ~ C) "'if if: """ Il'i ....,J 'iJ"", 'r'" ;; ,... ~" '.' .., I~ <il- ~ C Gl- > c o g 6~ XC .cC -Gl "<L o _ "'Gl "',. '" '- -5 o ,"'" ,..'0' ,~',,~_;;,',;,;.:," :J. III r "~" 'dr"'-'i'r!1ll:1'~' '" ..... .=: (l) g.~ "'r:J"J i:iI '"' . '" t"'1 ~ > ~ OIlOi2 .S 1a- S::r:<r; O..s I'l-; ~ ~ . . 0 '" ~r./J$ "gon"g ~~u -:~""-,,,,,_c,._,_ }- ',;;;''1(;1 ':;:~~J;~R~f[%t'fJ~j')~~il~1l5Jj~'lj;~~g~4~ ': ':: "" " , '-';'-'--" - "..j;;.-- P/iMnWz~/F 2u/t r!J)1ft~ 155 South Hanover Street Carlisle, pennsylVania 17013 . , '''::".>~c; :,"':v ,.../,,'.--~""- ~;;":'-,",,,,')-;;':J .."., ,~- ~- ,- ,~f~~,.r {:;" ~ *" * .... [j~~...==tI -";"..<l~~- 196 ::', ~rE'.873~.4A7 "'~';;-"$'O. 0 7,,4.1I _ { ~ c < _-' 4 11 '2 '5 ~Ah,,-ED FROFi1 CARLJSl.f.:?A. 1 7' 0 ., :3 Cumberland County Sheriff One Courthouse Square Carlisle, P A 17013 l!! ':,;! '\" f;~ ;'\" ?i~ i;*: ~;f: :{~ ~ i0'l ~) f,*: ti~i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BELL ATlANTIC - PENNSYLVANIA, INC. Plaintiff No. 01 - 9/3 Gu'll '-r~ vs. KARL E. ROMINGER i/t/a ROMINGER WEB CIVIL ACTION Defendant NOTICE OF JUDGMENT (XX) NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST THE ABOVE-NAMED DEFENDANT(s) IN THE AMOUNT OF $ ON , 2001. () A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN JUDGMENT ISIARE ENCLOSED. PROTHONOTARY - CUMBERLAND COUNTY Per: ~~. If you have any questions concerning the above, please contact the undersigned. Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 'h'"-'~ - .. 1 _.~~, ,__,_._,.,c~"__"""",''''~",_~'''''--"",,I~,",~_ W""~.M.. _~" .'~_' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BELL ATlANTIC - PENNSYLVANIA, INC. Plaintiff No. vs. KARL E. ROMINGER i/t/a ROMINGER WEB CIVIL ACTION Defendant PRAECIPE FOR TRANSFER OF JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: Kindly enter judgment in favor of Plaintiff and against the above-named defendant(s), pursuant to Pa.R.C.P.D.J. No.402(D), for failure of defendant(s) to appeal, within 30 days, a judgement entered October 27, 2000 against the above-named defendant(sl before Philadelphia Municipal Court, as set forth in the transcript of judgment, which is attached hereto. Assess damages as follows: Judgment Amount Post Judgment Interest (from October 27, 2000 to February 8, 2001 at 6% per annum) Payments Total Dated: February 8, 2001 :~A~ ,. Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 2002227 I" . - 7,229.63 ~:&;63 ~. $7,353.26 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BELL ATLANTIC - PENNSYLVANIA, INC. Plaintiff No. vs. KARL E. ROMINGER i/t/a ROMINGER WEB CIVIL ACTION Defendant CERTIFICATION OF ADDRESSES I do certify that the precise last known address of the within named plaintiff is: 1717 Arch St., 20th Floor Phila., PA 19103 I do certify that the precise last known address of the within named defendant is; 149 S. Hanover St CARLISLE PA 17013 AMATO AND MARGLE, P.C. BY:~ v Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 , . ,,--. -"0,_ ,.. , , ~. ,,,., , I ~,. N"~"_ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BELL ATLANTIC - PENNSYLVANIA, INC. Plaintiff No. vs. KARL E. ROMINGER i/t/a ROMINGER WEB CIVIL ACTION Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF NORTHAMPTON: The undersigned, being duly sworn, according to law, deposes and says that the Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers and Sailor' Civil Relief Act of Congress of 1940 as amended; That Karl E. Rominger is over 18 years of age, resides at 149 S. Hanover St, CARLISLE PA 17013 and is employed as Rominger Web. ~ ,. Sworn to and subscribed before me this \'} day of <;-e\o ( 2001 A.D. C; t ~ b ') (Lt~JLc't NOTAR'l\.PUBLlC f~"-.-- r.;tu~~~A~~ t " Notary PubIc , i l"c..0v~ lOWNSHIP,NOJlIHAMPTONCNrr I L;: (::ommS$iO.~.~.~,!!' 2OQc' 1 ;;:,,,,~ ~ _''''.'^''f. -. I..., -. ,. . , ZR36 MCV1 . 0.0.-0.8-25-27770. SC 121 DISPOSED ISSUE AMT. FEE INCIDENT . 7156.13 33 0.1/0.1/99 A/DF Y SO TYPE OTHER M.V. ---- NEXT HEARING ----- ******** PLAINTIFF INFORMATION ******* BELL ATLANTIC PENNA. INC 1717 ARCH S T 2o.TH FL PO BOX 280.0.0. PHILA, PA 1910.3 ATTY 0.32323 AMATO RONALD ******** DEFENDANT INFORMATION ******* ROMINGER KARL E 10. S COURTHOUSE AVE #3 CARLISLE PA 170.13 PREMISES PROP AT PHILA. PA 1910.0. C 0 U R T ACT HEARING #0.1 10./27/0.0. 4A JUDG 379 BLASI FINE+COST 7229.63 JUDG FOR PL I V I T Y DISP 7229,63 61-JUDG FOR PL DEFLT *** PRESS ENTER FOR PAGE 1 INFORMATION P/1 JUDGEMENT CERTIFIED IN THE AMOUNT OF $7229,63 COSTS INCLUDED, BY: I,,. I"''' "..~ "r _ ". ,., ..<., ",. ,,_ _ ,,- ,-'-.~I ZR36 MCV1 ' 00-0,8-25-27771 SC 121 DISPOSED ISSUE AMT. FEE INCIDENT - 7136.13' 33 01/01/99 A/DF Y SC TYPE OTHER M.V. ---- NEXT HEARING ----- ******** PLAINTIFF INFORMATION ******* BELL ATLANTIC PENNA. INC 1717 ARCH S T 20TH FL PO BOX 28000 PHILA. PA 19103 ATTY 032323 AMATO RONALD ******** DEFENDANT INFORMATION ******* ROMINGER WEB 10 S COURTHOUSE AVE #3 CARLISLE PA 17013 PREMISES PROP AT PHILA. PA 19100 COURT AC HEARING #01 10/27/00 4A JUDG 379 BLASI FINE+COST 7229.63 JUDG FOR PL TIVITY DISP 7229.63 61-JUDG FOR PL DEFLT *** PRESS ENTER FOR PAGE 1 INFORMATION P/1 JUDGEMENT CERTIFIED IN THE AMOUNT OF $7229.63 COSTS INCLUDED. GY: ,:.1;"'<--;""1.,0 "'r..,O.' _., ",' .of -Ii "- ":,'~,. ,\, ;C',~" .'_ ~,~-'_'!:'.'> ., , . -, '."..... >0,'"._ ~_"'_"'>' ,.c'J,,,,,,.,c_.,.,, ,''-'. ~ " ' THE. PHILADELP1-IIA MUNICIPAL COURT 34 South 11th Str~et. Philadelphia, PA 19107 Louis J. Presenza, President Judge Robert S. Blasi, Administrarive Judge BELL ATLANTIC - PENNSYLVANIA, INC. P.O. Box 28000 20th Floor 1717 Arch Street Philadelphia, PA 19103 No. SC- TY~ED BY COURT COSTS Attorney KARL E. ROMINGER 1mB CODE 10 South Courthouse Ave. #3 CARLISLE PA 17013 Plaintiff(s) D CONSTABLE SERVICE SERVICE ADDRESS (INFORMATION) if other than above Defendant(s) DATE OF ACCIDENT LICENSE PLATE NO. D MOTOR VEHICLE CASE - Defendant License Information ~.,. , OPERATOR. DATE OF BIRTH I DEFENDANT. OPERATOR NO. OWNER - DATE OF BIRTH OWNER - OPERATOR NO. '. ^~ . u ., , y , TO THE DEFENDANT: The above named plalntlff(s) ask judgment In this Court against you for $ plus court costs upon the follOWing claim; , At the special instance and request of Defendant, Plaintiff provided advertising in its publication kno~n as "Yellow Pages". After applying all proper credits, there remains a principal balance due of $4,431.22, as set forth in the attached statement of account. As provided in the attached advertisement contract, Plaintiff is also entitled to interest on the above amount from 01/01/99 to 08/15/00 at the agreed rate of 18% per annum totalling $1,293.68 and its attorneys fees in the amount of $ $1,431.23, for a total of $7,156.13, which, despite demand Io.ttorney'sFee; by Plaintiff, remains due. Plaintiff maintains a place of $1.431.23 business in Philadelphia establishing a proper basis for venue in this county. Lucas Enterprises, Inc. vs. Paul C. Harmon, Inc., 417 A.2d 720 (1980). .. ~T1CE TO DEFEND FILED COUNSEL FOR PLAINTIFF/ATTY. 1.0. NO., NAME & ADDRESS P CODE Amato and MargIe, p.e., 107 N. Commerce Way, Bethlehem, COMMONWEALTH OF PENNS'i'LVANIA COUNTY OF PHILADELPHIA ss: Ronald Amato Atty Fi Ie II 2002227 Principal Amoun$ 4 , 4 3 1 . 2 2 '$ Interest at from 1 R 01 101 /99 Sl,293.68 % $ Other: $ TOTAL $ $7,156.13 PLUS COURT COSTS PHONE A 18017 866-0400 SUMMONS to the defendant: You are hereby ordered to appear at a hearing sched- uled as follows: CITACION - AI Demandado: Por la presente, usted esta dirijido a presentarse a Ie siguiente vista en: I ff'E'l!:Ch8)27, 2000 TIME(Hofa) " Courtroom 4- :l IMPORTANT NOTICE TO THE DEFEN::NT Fourth Floor, 34Ns:;~::::e~TANTE PAl, El ACUSADO You have been sued in court. If you wish to defend against the claims set Usted ha side demandado en corte~j usted desea defenderse contra las quejas que forth, you must appear at the date, time and place as shown. You are warned aparecen en contra suya debe usted a~(ar el die, la hore y sitic que se senale. Usted esta that jf you fail to appear, the case may proceed without you and a judgment advertido que si no comparece, e! c1so puede cotinuar sin su presencia y una querella may be entered against you by the Court without further notice for any money puede ser puesta en contra suya per J~lcorte sin ninguna nolificacion, por dinero reclamado, claimed in the complaint or for any other claim or relief requested by the 0 por'alguna otra queja requierda per e~ dernandante. Usted puede perder dinero, propiedad plaintiff. You may lose money or property or other rights important to you. U otros derechos importantes para us:ted, II THEMUNICIPALCOURTCOMPLIESWITHTHEAMERICANSWITHDISABILlTIES II LA CORTE MUNICIPAL CUMPl1' CON EL DECRETO DE AMERICANOS INCAPACITADOS ACT, WHICH REQUIRES THAT ALL COURT SERVICES AND FACILITIES BE (AMERICANS WITH DISABILlTIE ACT). ESTE DECRETO REQUIERE QUE TOoOS LOS SER~ ACCESSIBLE TO PERSONS WITH DISABILITIES ON AN EQUAL BASIS TO THOSE VICIOS Y FACILlDADES DE CORT SEAN ACCESIBlE A PERSONAS INCAPACITADAS, AL IGUAL WITHOUTDISABILlTIES.IFYOUHAVEADISABILlTY,ANDREQUIREREASONABLE QUE PERSONAS NO INCAPAC ADAS. SE USTED ESTE INCAPACITADO Y NECESITA ACCOMMODATIONS TO FILE A CLAIM, PARTICIPATE IN A MUNICIPAL COURT ACOMODACIONES RAZONABLES, PARA DOER RADICAR UNA OEMANDA, PARTICIPAR EN AlGUN PROCEEDING, OR USE ANY SERVICE PROVIDED BYTHE COURT, PLEASE CALL666-7966. PROCEOIMIENTO 0 UTILlZAR SERVICIOS N LA CORTE MUNICIPAL POR FAVOR lLAME Al TELEFONO REQUESTS FOR REASONABLE ACCOMMODATIONS MUST BE MADE AT LEAST THREE 686.7966. PARA SOLlCITAR ACOMODACIO ~S RAZONABLES OEBE LLAMAR POR LO MENOS TRES OIAS BUSINESS DAYS BEFORE ANY HEARING, OR WITHIN THREE BUSINESS DAYS AFTER DE TRABAJO ANTES DE SU AUDlENCIA d DENTRO DE TRES DIAS DESPUES DE RECIBIR SU CITA SERVICE (DElIVERY) OFTHE NOTICE OF HEARING, WHICHEVER IS LATER. SEGUN La QUE DCURRA PRIMERD 'I ;/" Receipt N~,.~l ' Paid to Prothonotary /5SZ/Cl} I, ' depose and say that the facts set forth in this complaint are true and correct and ackno e that I am subject to the penalties 18 p, 0 elating to Unsworn Falsification (' s. LOCATION (S;lio) A 03-7 (Rev. 2/00) r COURT RECORD - ENTER DISPOSITION ON PART 2 ~ .J .........-. !;~" ,....~~ '", 'c, ,","' 'I~I~ '-I 12:30pm Signature ,I ~ 1 ',;";" ." ". ~~- Robert S. Blasi, AdministrafiVe- J.u g BELL ATLANTIC - PE NSYLVANIA. P.O. Box'28000 20th 1loor 1717 Arch Stree~ Philadelphia, PA 19103 I RO!U~GEB. WEB CODE 10 South Courthouse Ave. #3 CARLISLE PA 17013 ,. Plainfiff(s) D CONSTABLE SERVICE Defen~ant(s) . DATE 1. CASE CONTINUED TO ROOM DATE 2. CASE CONTINUED TO ROOM DATE 3. CASE CONTINUED TO ROOM }. PLAINTIFF DEFENDANT pLA!NnFF OEFEmlAHT PlAINTIFF o APPEARED 0010 NOT APPEAR 0 APPEARED 0 DID NO,T APPEAR 0 APPEARED 0010 NOT APPEAR 0 APPEARED 0 DID NOT APPEAR 0 APPEARED 0010 NOT APPEAR JUDGE JUDGE JUDGE ,Ii ""':'t"1 o APPEARED 0.1(:110 NOT APPEAR '., , ,~ TRIAL DISPOSITION PLAINTIFF o Appeared 0 Did Not Appear ATTY. NO. DEFENDANT o Appeared 0 Did Not Appear ATTY. NO. . 0600 0800 0810 082 0 No service - Dismissed WITHOUT Prejudice 0830 0840 0850 Case Settled, Discontinued, and Ended Withdrawn with Prejudice Judgment by Agreement (see Remarks) Judgment for Defendant by Default COURT Nt!. Withdrawn from Court List without Prejudice (will be relisted upon receipt of letter from either party) Case transferred to Common Pleas Court 0550 Venue transfer within the Commonwealth - transfer to County. 0910 S.C.# Case to be consolidated with DATE JUDGE PLAINTIFF Appeared 0 Did Not Appear Judgment for Plaintiff by Default plus ,nter;t,giz. 7/ MPluS Time of juClgment ;.1:2 ATTY. NO. DEFEND o Appeared Did Not Appear A TrY. NO. 061 AMOUNT A.M. P.M. 070 o Judgment for Defendant D Judgment for Defendant as Plaintiff in Counterclaim COSTS . ! AMOUNT I' ,I AMOUNT 1 } ... I I. , I 071 062 0 Judgment for Plaintiff plus interest from plus AMOUNT Time of judgment A.M. P.M. REMARKS DATE IJUDG' 03-7(Paga2) COURT RECORD DISPOSmON A' corpo':';ticik;d~?iirir~c "'1." In such cases~ 21 corpor.at, For further, information}--c-a 03-7(Rev.2100} " CERTIFIED MAil-IMPORTANT SEE OTHER SIDE . " ~, .~~$~!i1{S~':'i~~-:~1~i~~~::-:~~i-ti~'~;;~:~i~-~\~ff~~~.' ~~f~;~f;..~t~~f2e!~,.~~~ ~,,~~~~;.~~~,~~:~~,on ~~t.,~~~::~.~~,_. '-.,., ..--'-' .,",'.- .','. ""i\l'~~ l : :'~~'f~'"')'{;'f .~ i i , t ' ~, . '"" -y-~- .Ii , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL:VANIA CIVIL ACTION - LAW BELL ATLANTIC - PENNSYlVANIA, INC. Plaintiff No. 2001-00913 vs. KARL E. ROMINGER i/t/a ROMINGER WEB PRAECIPE FOR WRIT EXECUTION (MONEY JUDGMENT) Defendant(s) To the Prothonotary - Cumberland County: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) All cash on hand or in the possession of the defendant(sl. accounts receivables, furniture, furnishinQs, equipment. inventorv. tools. vehicles, electronic equipment, anv and all other personal propertv belon!:!in!:! to the above- named defendant(s). (2) against KARL E. ROMINGER ilt/a ROMINGER WEB, Defendant(s) (3) and against.................................... ....Garnishee(s) (4) and index this writ (a) against..................................Defendant(s) and (b) against............................. ......... .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 the property) (5) Amount Due Statutory Interest From February 14, 2001 $ 7,353.26 $ 1.22 Less Payment Costs Poundage $ 0.00 $ $ Total $ 7,354.48 Date:Februarv 15, 2001 ~~A~ Ronald Amato Attorney J.D. No. 32323 Attorneys for Plaintiff Attorney File#; 2002227 '0- I" .'^ ',~ "H,' 'q. -~,,~,"', c, ,-"..~f._>~..I!"'I'I"".,...~..,..~="'.,,~___,.~:",".,..,,,, I' _" """".=.","" . _~" ,""',~ _~~'"d_ ~.."_ ".__ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYL;VANIA CIVil ACTION - LAW BELL ATLANTIC - PENNSYLVANIA. INC. Plaintiff No. 2001-00913 vs. KARL E. ROMINGER i/t/a ROMINGER WEB WRIT OF EXECUTION (MONEY JUDGMENTS) Defendant(s) WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY. PENNSYLVANIA To satisfy the judgment. interest and cost against KARL E. ROMINGER i/t/a ROMINGER WEB. Defendant(s); (1) You are directed to levy upon the property of the defendant(s) and to sell his, her (or their) interest therein; (Inquisition and Exemption Laws (are) (are not) waived. (2) You are also directed to attach the property of the defendant not levied upon in the possession of.................... .................................................... .Garnishee(s) and to notify the Garnishee(s) that (al 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 and subject to attachment is found in the possession of anyone other than the named garnishee(s), you are directed to notify him that he has been added as a garnishee and is enjoined as above stated. Amount Due Statutory Interest From February 14,2001 $ 7,353.26 $ 1.22 Less Payments Costs $ 0.00 $ Poundage $ Total $ 7.354.48 plus add'l costs $ DATED (SEAL) Prothonotary - Cumberland County Court of Common Pleas, Cumberland County By Attorney File#: 2002227 Deputy ~ ~ ,,,''''~'' .."",~ .:,w,=c ',-",",M~', .~..K,~~_=",I!'I_~~ ~,,~_. ._'., "".0.'''" , ~~ "~. =... ~ , .~- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYI.:VANIA CIVIL ACTION - LAW BELL ATlANTIC - PENNSYLVANIA, INC. Plaintiff No. 2001-00913 vs. KARL E. ROMINGER i/t/a ROMINGER WEB CIVIL ACTION Defendant(s) CERTIFICATION OF DEFENDANTls) ADDRESS FOR SERVICE I do certify that the precise last known address of the within named defendant(s) is the address provided below, and request that the Sheriff serve the above named defendant(s) at: 149 S. Hanover St CARLISLE PA 17013 Dated:Februarv 15. 2001 AMATO AND MARGLE, P.C. BY~ " Konal mato Attorney LD. No. 32323 Attorneys for Plaintiff Attorney File #:2002227 , ".'~ '. """',"""F'?>9!j'"~:ry,)"<,,i''','' ' "-".1,"" .. ~. J!!I'II, 0 "=-~"-,,. ,,.~. ",;' :"-:I~~'-- '~-"-''''''''''' "".,_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL:VANIA CIVil ACTION - LAW BELL ATLANTIC - PENNSYLVANIA, INC. Plaintiff No. 2001-00913 vs. KARL E. ROMINGER i/t/a ROMINGER WEB CIVIL ACTION Defendant(s) WAIVER OF WATCHMAN To the Sheriff: Any deputy sheriff levying upon or attaching any property under the within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before the sheriff's sale thereof. Dated: February 15, 2001 Ronald Amato Attorney 1.0. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 Attorney File #: 2002227 1""- --;""'-"""*:_""""'_'"C'''''''~''''' .'~ "'. ",,,,,",,t,,,'!':m.. _ _ . - ._ .~. .~~- , '''1 ~-"-, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYlVANIA CIVIL ACTION - lAW BELL ATlANTIC - PENNSYLVANIA, INC. Plaintiff No. 2001-00913 vs. KARL E. ROMINGER i/t/a ROMINGER WEB CIVIL ACTION Defendant WRIT OF EXECUTION NOTICE THIS PAPER IS A WRIT OF EXECUTION. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD OR TAKEN TO PAY THE JUDGMENT. YOU MAY HAVE LEGAL RIGHTS TO PREVENT YOUR PROPERTY FROM BEING TAKEN. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY OF THESE RIGHTS. IF YOU WISH TO EXERCISE YOUR RIGHTS, YOU MUST ACT PROMPTLY. THE LAW PROVIDES THAT CERTAIN PROPERTY CANNOT BE TAKEN. SUCH PROPERTY IS SAID TO BE EXEMPT. THERE IS A DEBTOR'S EXEMPTION OF $300. THERE ARE OTHER EXEMPTIONS WHICH MAY BE APPLICABLE TO YOU. A SUMMARY OF SOME OF THE MAJOR EXEMPTIONS ARE LISTED ON THE NEXT PAGE. YOU MAY HAVE OTHER EXEMPTIONS OR OTHER RIGHTS. IF YOU HAVE AN EXEMPTION, YOU SHOULD DO THE FOLLOWING PROMPTLY: (1) FILL OUT THE ATTACHED CLAIM FORM AND DEMAND FOR A PROMPT HEARING (2) DELIVER THE FORM OR MAIL IT TO THE SHERIFF'S OFFICE AT THE ADDRESS NOTED. YOU SHOULD COME TO COURT READY TO EXPLAIN YOUR EXEMPTION. IF YOU DO NOT COME TO COURT AND PROVE YOUR EXEMPTION, YOU MAY LOSE SOME OF YOUR PROPERTY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 :{ii"", - 1 .' :?"i""'_''':_i''".^"~"",,.< ,~". ~,~,.~""".'''''". ,'~ ~I!!!!I,~",,,, ".'."'.'''-.,, _ '~" ."".<;" ,~,"' 1- ""--, ., ". ~~- ".~, - . " IN THE COU~TOF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYlVANIA CIVIL ACTION - LAW BELL ATlANTIC - PENNSYlVANIA, INC. Plaintiff No. 2001-00913 vs. KARL E. ROMINGER i/t/a ROMINGER WEB CIVIL ACTION Defendant(s) CLAIM FOR EXEMPTION To the Sheriff: I, the above-named defendant, claim exemption of property from levy or attachment: (1) From my personal property in my possession which has been levied upon, (a) I desire that my $300 statutory exemption be (i) set aside in kind (specify property to be set aside in kind): (ii) paid in cash following the sale of the property levied upon; or (b) I claim the following exemption (specify property and basis of exemption): (2) From my property which is in the possession of a third party, I claim the following exemptions: (a) my $300 statutory exemption: _ in cash; _ in kind(specify property): (b) Social Security benefits on deposit in the amount of $ (c) other (specify amount and basis of exemption): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made SUbject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date; Defendant THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY: South Hanover Street, Carlisle, PA 17013 717-240-6195 ~~.~. ",,< .,..r,f,>~ ..~""___"" C".' .". "..~_. ' -",,~'I~I.., , ___ ___ ___ ,r. ,-- r- ,," '," MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300.00 STATUTORY EXEMPTION 2. BIBLES, SCHOOL BOOKS, SEWING MACHINES, UNIFORMS AND EQUIPMENT 3. MOST WAGES AND UNEMPLOYMENT COMPENSATION 4. SOCIAL SECURITY BENEFITS 5. CERTAIN RETIREMENT FUNDS AND ACCOUNTS 6. CERTAIN VETERAN AND ARMED FORCES BENEFITS. 7. CERTAIN INSURANCE PROCEEDS 8. SUCH OTHER EXEMPTIONS AS MAY BE PROVIDED BY LAW '." ~ ,- ,-, "~~_ .,'".~, ,~, ,~"".=-. ,~. . Ok~",JIl., ~1*1~{ih:;gf~Rg,~1~J~~g;'~~,@~'./;{JQ;" - . -.. COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) .' WRIT OF EXECUTION and/or ATTACHMENT NO. 01-913 CIVIL HK TERM CIVIL ACTION - LAW " ,TO THE SHERIFF OF Cumberland COUNTY: . To satisfy the debt, interest and costs due Ill> 11 A-tl;mt-i" - P<>nm'yl ""ni" Tn" PLAINTIFF(S) from Karl E, Rominger i/t/a Rominqer Web, 149 S. Hanover St., Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property ofthe defendant(s) and to sell All "ash on hann or in -the possession of the defendant(s), ac=unts receivables, furniture, furnishinqs, equipment, inventory, tools, vehicles, electronic equipment, any and all other personal property belonging to the above-named defendant (s) . (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/are 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/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due Interest Atty's Comm Atty Paid Plaintiff Paid $7,353.26 $1. 22 % L.L. Due Prothy Other Costs $.50 $1. 00 $32.50 Date: February 27. 2001 Prothonotary ~ Civii Divisi n ~O/nC>' P. ~~J b)<:.. REQUESTING PARTY: Name Ronald Amato, Esq. Address: 107 North Commerce .Way Bethlehem, PA 18017 Attorney for: Plaintiff Telephone; 610-866-0400 Supreme Court ID No. 32323 Deputy ! I '0"_""'''Ul!><1~., .. , . ""~ I.".'.. ....,..,'''"''',.~, ,,~__,~ ". ~. . , . tgij" ~ I '" ~"~'<W'<,'~' '."'~""'-'''.,., ~~ , ,," ~,,(jpv~/:o ci.H!.J.ILfLIL ~ fj~ ~I-- Tb S&Ufu Q" /JiW I/~ '%-: ~/~ .. ' ~fMJ f~ dJ~(.1-- W6-AL 1J;Js, ~ docw~JJ.: 6tJ~ ~~. J snJ- ohd-- ~L dJS ~- . JitwJI\s - 90~ t! ~ ~; t ,.. ~ - 0 Iry.~ """""1 r "= ~""'. ~" ,,,. ,-- 1iI1JLUIH '1IN'1AlASNN3d :.1; C; 1'1 \J ~f t", .,1 "'_" ,'t\f 101 Wd 011 E I HUM A!NnOo OHY1ij3BHOO lI.:1l\l3HS 3;;1 ~O 3QI.:UO 'Ub1F1;j1iJfi~qji"Th~~?'~\i?ffi:~"fi;jf~jJ ll' ~ - ~~;~'~I~"!;"'~'~'''I.'iii''''-;:$~~~~MJ6l!lti,J.11J _ mmJf4lRl,,,"~ ......",.; , BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant PETITION TO STRIKEIREOPEN JUDGMENT AND NOW, comes Karl E. Rominger, pro se, and avers as follows: 1. Judgment was entered on the 2 7!lday of 0 C f- , 2000, in Philadelphia Municipal Court. 2. Said Judgment was transferred on February 14, 2001 to Cumberland County Prothonotary for entry upon the record. 3. Petitioner disputes the validity of that Judgment. 4. Petitioner believes and therefore avers that the Judgment was entered by a Court which did not have subject matter jurisdiction to do such. I. MOTION TO STRIKE FOR LACK OF SUBJECT MATTER JURISDICTION 5. Previous paragraphs incorporated by reference. 6. Under the Judicial Code and pursuant to the Rules of Civil Procedure governing actions which proceed before District Justices, in particular Rule 302. Venue., subject matter jurisdiction did not exist. 7. The Judgment transferred to Cumberland County is based upon a Court Order and '--.~."~, , .I~ 1 . u _ ,'., ~~ , Judgment where the underlying Court did not have subject matter jurisdiction, and the Judgment is void. 8. Petitioner requests that this Court strike said Judgment from the Cumberland County Docket with prejudice. WHEREFORE, Petitioner respectfully requests that this Honorable Court strike or vacate the Judgment in the above captioned matter, and pending resolution Stay of Execution. II, MOTION TO STRIKE/REOPEN JUDGMENT FOR LACK OF PERSONAL JURISDICTION 9. Previous paragraphs incorporated by reference. 10. The Judgment transmitted to Cumberland County is defective on its' face insomuch as it does not contain any evidence that personal jurisdiction was obtained by the issuing authority. II. Without personal jurisdiction, the Judgment is infirm and should be voided or struck from the record. WHEREFORE, because the Judgment in the above referenced matter, contains no evidence of the Court securing personal jurisdiction over the Defendant, Petitioner respectfully requests that this Honorable Court strike said Judgment or in the alternative open said Judgment. Respectfully submitted, ?~ Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Date: March 2, 2001 -'''_c ,., . ,_..I-I<V- -,.. ., BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA ; No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, pro se do hereby certifY that I this day served a copy of the Motio/l to Strike upon following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Ronald Amato, Esquire AMATO AND MARGLE, P.C. 107 North Commerce Way Bethlehem, PA 18017 ~~ Karl E. Rominger, Esquire Pro Se Dated: March 2, 2001 . ,.-. ~ ~ , -~-' . - "r"l- .,. " COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BELL ATLANTIC - PENNSYLVANIA, INe, Plaintiff No. 2001-00913 vs. KARL E, ROMINGER i/t/a ROMINGER WEB Defendant(s) PLAINTIFF'S ANSWER TO DEFENDANT'S PETITION TO STRIKE/REOPEN JUDGMENT 1. Admitted. 2. Admitted. 3. Denied. It is specifically denied that Defendant disputes the validity of the Judgment. To the contrary, Defendant received notice of entry of Judgment in October, 2000. To date, Defendant has not filed a motion or petition with the Court that entered said Judgment disputing same. 4. Denied. It is strictly denied that the Judgment was entered by a court that lacked subject matter jurisdiction. To the contrary, the contract was entered into in Philadelphia County and Defendant was also required to make payment to Plaintiff in Philadelphia County. The cause of action, the failure of Defendant to make payment, arose in Philadelphia County. Defendant has failed to object to venue in this matter at all previous hearings. ,,"" ~. '~"~ ,~.~. ~~~ """ I. PLAINTIFF'S ANSWER TO DEFENDANT'S MOTION TO STRIKE FOR LACK OF SUBJECT MATTER JURISDICTION 5. Plaintiff incorporates the allegations of every paragraph enumerated as if said paragraphs were fully set forth here at length. 6. Denied. It is specifically denied that the Philadelphia Municipal Court lacked . subject matter jurisdiction. To the contrary, the Philadelphia Municipal Court had proper jurisdiction for the reasons set forth in Paragraph 4 above. It is further denied that the Philadelphia Municipal Court is bound by the Pennsylvania Rules of Civil Procedure for District Justices (Pa.R.C.P.D.J.). To the contrary, the rules applicable to the Philadelphia Municipal Court are the Philadelphia Municipal Court Rules of Civil Procedure (Phila.M.C.R.Civ.P.). 7. Denied. It is specifically denied that the Judgment transferred from Philadelphia Municipal Court to the Cumberland County Court is void for lack of jurisdiction. To the contrary, the Philadelphia Municipal Court had proper jurisdiction. Furthermore, Pennsylvania is a unified judicial system. The Philadelphia Municipal Court and the Court of Common Pleas of Cumberland County are members of that judicial system. Defendant cannot object to a judgment in the transferee court in Pennsylvania on a judgment entered in another Pennsylvania court. Any petition to open or strike judgment by Defendant must be filed in the court where the underlying judgment was entered and not in the transferee court. 8. Admitted and Denied. It is admitted that Defendant is requesting the Court of Common Pleas of Cumberland County to strike with prejudice the Judgment entered in the Cumberland County Docket. It is denied that Defendant is entitled to the relief requested. ~r' j ^~, "', . -. ~." '''''' .. Wherefore, Plaintiff respectfully requests Defendant's Petition be denied. II, PLAINTIFF'S ANSWER TO DEFENDANT'S MOTION 1'0 STRIKE/REOPEN JUDGMENT FOR LACK OF PERSONAL JURISDICTION 9. Plaintiff incorporates the allegations of every paragraph enumerated as if said paragraphs were fully set forth here at length. 10. Admitted in Part and Denied in Part. It is specifically denied that the Judgment entered by the Philadelphia Municipal Court was "transmitted" to the Court of Common Pleas of Cumberland County. It is admitted that the Judgment entered by the Philadelphia Municipal Court was transferred to the Court of Common Pleas of Cumbe~land County. It is further denied that the Judgment is defective on its face or that the Philadelphia Municipal Court lacked proper jurisdiction to enter the judgment. Defendant was properly served by the Philadelphia Municipal Court, failed to object to venue or jurisdiction and allowed a default judgment to be entered. 11. Denied. It is specifically denied that the Philadelphia Municipal Court lacked personal jurisdiction over Defendant, that the Judgment entered is infirm, or that the judgment should be voided or struck from the record. To the contrary, for the reasons stated above, the Philadelphia Municipal Court had proper jurisdiction. As such, the Judgment is proper and may not be voided or struck after being properly transferred to the Court of Common Pleas of Cumberland County. Wherefore, Plaintiff respectfully requests Defendant's Petition be denied. '"-", """"". -';'., .,,- "'\'"' _..~' .' ~'~'""', ~ .. PLAINTIFF'S NEW MATTER TO DEFENDANT'S PETITION 12. Defendant does not have a meritorious defense to the underlying claim. 13. Defendant's Petition to Strike/Reopen was not timely filed. 14. Defendant has no reasonable excuse for the delay in filing a petition to open or strike judgment. 15. No fatal defect in the judgment appears on the face of the record. 16. Plaintiff's complaint, filed with the Philadelphia Municipal Court, was served upon Defendant. 17. Defendant did not object to venue or jurisdiction of the Philadelphia Municipal Court. 18. Defendant allowed a default judgement to be entered against him by the Philadelphia Municipal Court. 19. Defendant was aware that the judgment was entered within the first two weeks of November 2000. 20. Defendant received a letter from Plaintiff's counsel on or about December 7, 2000 notifying him that judgment was entered. 21. Defendant did not file the within petition until after Plaintiff filed an praecipe for writ of execution and attempted to levy on property of the Defendant. :;, ,-, "', . ,.." ".C' - ,. .. ".",' O.''''~'~ ~,," .C '~"'''''I,". A.,,,,. ...,,'- l" WHEREFORE, Plaintiff respectfully requests that Defendant's petition to open or strike be denied as Defendant has filed the petition with the wrong court, the Defendant has failed to allege a meritorious defense, the Defendant has failed to allege that the petition was timely filed, the Defendant has failed to allege that there is a reasonable excuse for the delay in filing the petition, and that the Defendant has failed to allege that a defect in the judgment appears on the face of the record. AMATO ~P.C. By: Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 . J. ,~". ,4< _,r=1 ~~~, " "''''' ,."."",. VERIFICATION I, Michael Kennedy, Esquire, hereby state that I am the attorney-in-fact for Plaintiff in this action and, as such, am authorized to make this verification on behalf of Plaintiff as their verification cannot be obtained within the time allowed for filing, that the statements of fact made in the foregoing Answer and New Matter to Defendant's Petition to Strike/Reopen judgment are true and correct to the best of my knowledge, information and belief based upon the information and documentation provided by Plaintiff and my own information. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ;-",,~~, '''','' '-"'_?" .~-_-___ ..I'?'l.".' .~~" '~^"~_"'~" ,'0 _ ~.~~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BELL ATLANTIC - PENNSYLVANIA, INC, Plaintiff No. 2001-00913 vs. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant(s) PLAINTIFF'S ANSWER TO DEFENDANT'S PETITION TO STRIKE/REOPEN JUDGMENT 1. Admitted. 2. Admitted. 3. Denied. It is specifically denied that Defendant disputes the validity of the Judgment. To the contrary, Defendant received notice of entry of Judgment in October, 2000. To date, Defendant has not filed a motion or petition with the Court that entered said Judgment disputing same. 4. Denied. It is strictly denied that the Judgment was entered by a court that lacked subject matter jurisdiction. To the contrary, the contract was entered into in Philadelphia County and Defendant was also required to make payment to Plaintiff in Philadelphia County. The cause of action, the failure of Defendant to make payment, arose in Philadelphia County. Defendant has failed to object to venue in this matter at all previous hearings. ~ '-' ,-", "",,"~--I'-"'j. - .,-,' ',~~" -- ~" > .. - ",' - . I. PLAINTIFF'S ANSWER TO DEFENDANT'S MOTION TO STRIKE FOR LACK OF SUBJECT MATTER JURISDICTION 5. Plaintiff incorporates the allegations of every paragraph enumerated as if said paragraphs were fully set forth here at length. 6. Denied. It is specifically denied that the Philadelphia Municipal Court lacked . subject matter jurisdiction. To the contrary, the Philadelphia Municipal Court had proper jurisdiction for the reasons set forth in Paragraph 4 above. It is further denied that the Philadelphia Municipal Court is bound by the Pennsylvania Rules of Civil Procedure for District Justices (Pa.R.C.P.D.J.). To the contrary, the rules applicable to the Philadelphia Municipal Court are the Philadelphia Municipal Court Rules of Civil Procedure (Phila.M. C.R.Civ.P .). 7. Denied. It is specifically denied that the Judgment transferred from Philadelphia Municipal Court to the Cumberland County Court is void for lack of . jurisdiction. To the contrary, the Philadelphia Municipal Court had proper jurisdiction. Furthermore, Pennsylvania is a unified judicial system. The Philadelphia Municipal Court and the Court of Common Pleas of Cumberland County are members of that judicial system. Defendant cannot object to a judgment in the transferee court in Pennsylvania on a judgment entered in another Pennsylvania court. Any petition to open or strike judgment by Defendant must be filed in the court where the underlying judgment was entered and not in the transferee court. 8. Admitted and Denied. It is admitted that Defendant is requesting the Court of Common Pleas of Cumberland County to strike with prejudice the Judgment entered in the Cumberland County Docket. It is denied that Defendant is entitled to the relief requested. ,.~,. - 1"""1, ... . d-~~?__ I' Wherefore, Plaintiff respectfully requests Defendant's Petition be denied. II. PLAINTIFF'S ANSWER TO DEFENDANT'S MOTION TO STRIKE/REOPEN JUDGMENT FOR LACK OF PERSONAL JURISDICTION 9. Plaintiff incorporates the allegations of every paragraph enumerated as if said paragraphs were fully set forth here at length. 10. Admitted in Part and Denied in Part. It is specifically denied that the Judgment entered by the Philadelphia Municipal Court was "transmitted" to the Court of Common Pleas of Cumberland County. It is admitted that the Judgment entered by the Philadelphia Municipal Court was transferred to the Court of Common Pleas of Cumberland County. It is further denied that the Judgment is defective on its face or that the Philadelphia Municipal Court lacked proper jurisdiction to enter the judgment. Defendant was properly served by the Philadelphia Municipal Court, failed to object to venue or jurisdiction and allowed a default judgment to be entered. 11. Denied. It is specifically denied that the Philadelphia Municipal Court lacked personal jurisdiction over Defendant, that the Judgment entered is infirm, or that the judgment should be voided or struck from the record. To the contrary, for the reasons stated above, the Philadelphia Municipal Court had proper jurisdiction. As such, the Judgment is proper and may not be voided or struck after being properly transferred to the Court of Common Pleas of Cumberland County. Wherefore, Plaintiff respectfully requests Defendant's Petition be denied. i'3:!,~, , '1"1' - ~. "..' - PLAINTIFF'S NEW MATTER TO DEFENDANT'S PETITION 12. Defendant does not have a meritorious defense to the underlying claim. 13. Defendant's Petition to Strike/Reopen was not timely filed. 14. Defendant has no reasonable excuse for the delay in filing a petition to open or strike judgment. 15. No fatal defect in the judgment appears on the face of the record. 16. Plaintiff's complaint, filed with the Philadelphia Municipal Court, was served upon Defendant. 17. Defendant did not object to venue or jurisdiction of the Philadelphia Municipal Court. 18. Defendant allowed a default judgement to be entered against him by the Philadelphia Municipal Court. 19. Defendant was aware that the judgment was entered within the fIrst two weeks of November 2000. 20. Defendant received a letter from Plaintiff's counsel on or about December 7, 2000 notifying him that judgment was entered. 21. Defendant did not file the within petition until after Plaintiff filed an praecipe for writ of execution and attempted to levy on property of the Defendant. ~ 'v":l8W( __~,,,~- r,."_,, _""". ---~".' ,",,"'I' "'-",' ". " , " " ,- "WHEREFORE, Plaintiff respectfully requests that Defendant's petition to open or strike be denied as Defendant has filed the petition with the wrong court, the Defendant has failed to allege a meritorious defense, the Defendant has failed to allege that the petition was timely f1led, the Defendant has failed to allege that there is a reasonable excuse for the delay in filing the petition, and that the Defendant has failed to allege that a defect in the judgment appears on the face of the record. AMATO ^i!PRGLE. P.C. By: f7L- Ronald Amato Attorney I.D.No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 ~ , "',~ ,., 1'1' I ' r ~ _ 0 ~ _. ~ . VERIFICATION I, Michael Kennedy, Esquire, hereby state that I am the attorney-in-fact for Plaintiff in this action and, as such, am authorized to make this verification on behalf of Plaintiff as their verification cannot be obtained within the time allowed for filing, that the statements of fact made in the foregoing Answer and New Matter to Defendant's Petition to Strike/Reopen judgment are true and correct to the best of my knowledge, information and belief based upon the information and documentation provided by Plaintiff and my own information. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ',!""... ..,,' "I'~I " ..,.., ". ~, . ~ PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and subnitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argunent Court. --------------------------------------------------------------------------------------- CAPTION OF CASE (entire caption must be stated in full) BELL ATLANTIC - PENNSYLVANIA, INC. (Plaintiff) vs. KARL E. ROMINGER i/t/a ROMINGER WEB (Defendant) No. 2001 Civil 00913 19 1. State matter to be argued (i. e" plaintiff' s rn:>tion for new trial. defendant' s danu=er to canplaint. etc,): Defendant's Petition to Strike/Reopen Judgment 2. Identify counsel who will argue case: (a) for plaintiff: Michael J, Kennedy, Esquire or Alan Mege, Esquire l\ddress: Amato, MargIe & McKarski, P.C. 107 North Commerce Way Bethlehem PA 18017 (b) for defendant: Karl E. Rominger pro se l\ddress: 155 South Hanover Street Carlisle PA 17013 3. I will notify all parties in writing within b.u days that this case has been listed for argunent. 4, ArgI.ment Court Date: << Dated: April 30, 2001 ,"""',""~:""'..~_~.""~., ~"'.H" '__~ ."' "~".",..~." '"",~' - .., -".. ,,,,,~ '~ii, ',,' '''~'<~ ''''''H'~ ., ',,---, " ,,,,~,:;, -"c.; ,~"-",,,,,..,,- ""' "-,,~-,.;,,, ",'~' '.' ~'~'-", ".'fl 'P''''f''''-i;i'i-<''i~ .,< .," '"'o~ ... JIliJeJl Lllff 0 0 0 C .-., R ':]: "'"OG,; ~ f1'1rTi -'I:: Z:::c ZC" I 'i} (f)~:::: ", -<L ., ~: ,.-'-, !;:C: _",--..J ~G -" ;:-t~~ :::r':: t7-' 6:(-) T~;h;~ )>C .. '_~ ' Z '0 > ~ :rJ .1:" -< l!$Il!IIII~!'I!_oe,:mll;ll"!~!tl m_~Am*1~i""!R~f~,"""f!"~i~'o/,~:~i!lmir'1'Wi1J'MJiF!jj!I!I'~~~lM,1",~"'ll!'1'!l~~U._ J!J __,~ BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant PRAECIPE TO REMOVE FROM ARGUMENT LIST TO THE PROTHONOTARY: Please remove the above captioned matter that is scheduled for July 25,2001, from the argument list by agreement of the parties, without prejudice to relist at a later date. Respectfully submitted, ~ / .Jt- - .. ---- Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court 1D # 81924 Attorney for Defendant Date: July 20, 2001 i.\ji " ','j"'.r-~,--".'.,ik=- ','(.,,~",.S"i" _' ,--,'.""""", '."'''''__<", ,p,l!m"c,,,,,,' , ",'~""- "",. ._0.. .2_,' ,_ , __ 'v. ' " Ii, " _ ,~"~ ,;: ::)" "., ,,'., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY., PENNSYLVANIA , CIVIL AcflON - LAW . BELL ATLANTIC - PENNSYLVANIA, INC. Plaintiff No. 2001-00913 vs. KARL E. ROMINGER i/tla ROMINGER WEB PRAECIPE FOR WRIT EXECUTION (MONEY JUDGMENT) Defendant(s) To the Prothonotary - Cumberland County: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) All cash on hand or in the possession of the defendant(sL accounts receivables, furniture. furnishinQs. eQuipment, inventorv, tools. vehicles. electronic eQuipment. anv and all other personal propertv belonQinQ to the above- named defendant(s). (2) against KARL E. ROMINGER i/t/a ROMINGER WEB, Defendant(s) (3) and against........ ...................... ......... .Garnishee(s) (4) and index this writ (a) against..................................Defendant(s) and (b) against................................ ...... .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 the property) (5) Amount Due Statutory Interest From February 14,2001 $ 7,353.26 $ 372.50 Less Payment Costs Poundage $ 1,500.00 $ $ Total $ 6,225.76 Date:Januarv 4, 2002 AMA~ By: ~ Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff Attorney File#: 2002227 "ii, T^-"sr~,~;:,/-d.:"";;~,-.^$:, ,"_' . ". !' .,'_'. "'1'"'I~I~ ","" ,~t" ")'. ''<~''''''''''~} , . I . ""~'" ,~,' ,.,- .,. ",,'.c- __N~_~,~~~<_ ",-,-,." ,,, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY., PENNSYLVANIA CIVil AcTION - LAW . BELL ATLANTIC - PENNSYLVANIA, INC. Plaintiff No. 2001-00913 vs. KARL E. ROMINGER i/t/a ROMINGER WEB WRIT OF EXECUTION (MONEY JUDGMENTS) Defendant(s) WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA To satisfy the judgment, interest and cost against KARL E. ROMINGER i/t/aROMINGER WEB, Defendant(s); (1) You are directed to levy upon the property of the defendant(s) and to sell his, her (or their) interest therein; (Inquisition and Exemption Laws (are) (are not) waived. (2) You are also directed to attach the property of the defendant not levied upon in the possession of.................... .................................................... .Garnishee(s) 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 and subject to attachment is found in the possession of anyone other than the named garnishee(s), you are directed to notify him that he has been added as a garnishee and is enjoined as above stated. Amount Due Statutory Interest From February 14, 2001 $ 7,353.26 $ 372.50 Less Payments Costs $ 1,500.00 $ Poundage $ Total $ 6,225.76 plus add'l costs $ DATED (SEAL) Prothonotary - Cumberland County Court of Common Pleas, Cumberland County By Attorney File#: 2002227 Deputy ..,~, -" ,","-",~-, -'.";~~' ','7"';<'0'">' ,,'"_,,""_.'~,.-1~1'~"_9. "'""" "'r-.,~~.~, -,~ '1- ..~ - .' .~ - ,,- IN THE COpRT O'F COMMON PLEAS OF CUMBERLAND COUNTY., PENNSYLVANIA CIVil ACtiON - LAW . BELL ATLANTIC - PENNSYLVANIA, INC. Plaintiff No. 2001-00913 vs. KARL E. ROMINGER ilt/a ROMINGER WEB CIVIL ACTION Defendant(sl CERTIFICATION OF DEFENDANT(s) ADDRESS FOR SERVICE I do certify that the precise last known address of the within named defendant(sl is the address provided below, and request that the Sheriff serve the above named defendant(sl at: 155 South Hanover St CARLISLE PA 17013 AMATO AND By: Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff Dated:Januarv 4. 2002 Attorney File #:2002227 j:,,?, ,'" ., '-"'_-' ~.",,~, "%,'-'""'(I\?i!!.-,, - ., '>-,- ,," - ~ _,0'_ - ',' IN THE Co.URT OF COMMON PLEAS OF CUMBERLAND COUNTY., PENNSYLVANIA CIVIL ACtiON - LAW BELL ATLANTIC - PENNSYLVANIA, INC. Plaintiff No. 2001-00913 vs. KARL E. ROMINGER i/t/a ROMINGER WEB CIVIL ACTION Defendant(s) WAIVER OF WATCHMAN To the Sheriff: Any deputy sheriff levying upon or attaching any property under the within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before the sheriff's sale thereof. , Dated: January 4, 2002 Ronald Amato Attorney J.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 Attorney File #: 2002227 , i!,_ . . ""'~ ".~:"";,"",,,,,'V..\",,,'\'O,, "~""""~,,'~'J'!l'k '__ C ""","'."" " -,~",,,- _' ..,~_ '..~",. '". 0_ _, , . ." ~__ ~ " " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY., PENNSYLVANIA . CIVIL ACtiON - LAW . BEll ATLANTIC - PENNSYLVANIA, INC. Plaintiff No. 2001-00913 vs. KARL E. ROMINGER i/t/a ROMINGER WEB CIVIL ACTION Defendant WRIT OF EXECUTION NOTICE THIS PAPER IS A WRIT OF EXECUTION. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD OR TAKEN TO PAY THE JUDGMENT. YOU MAY HAVE LEGAL RIGHTS TO PREVENT YOUR PROPERTY FROM BEING TAKEN. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY OF THESE RIGHTS. IF YOU WISH TO EXERCISE YOUR RIGHTS, YOU MUST ACT PROMPTLY. THE LAW PROVIDES THAT CERTAIN PROPERTY CANNOT BE TAKEN. SUCH PROPERTY IS SAID TO BE EXEMPT. THERE IS A DEBTOR'S EXEMPTION OF $300. THERE ARE OTHER EXEMPTIONS WHICH MAY BE APPLICABLE TO YOU. A SUMMARY OF SOME OF THE MAJOR EXEMPTIONS ARE LISTED ON THE NEXT PAGE. YOU MAY HAVE OTHER EXEMPTIONS OR OTHER RIGHTS. IF YOU HAVE AN EXEMPTION, YOU SHOULD DO THE FOLLOWING PROMPTLY; (1) FILL OUT THE ATTACHED CLAIM FORM AND DEMAND FOR A PROMPT HEARING (2) DELIVER THE FORM OR MAIL IT TO THE SHERIFF'S OFFICE AT THE ADDRESS NOTED. YOU SHOULD COME TO COURT READY TO EXPLAIN YOUR EXEMPTION. IF YOU DO NOT COME TO COURT AND PROVE YOUR EXEMPTION, YOU MAY LOSE SOME OF YOUR PROPERTY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 I I , j'J ". "~:!":-,,~::,,,~. ".".~Y:'" ,<.~,?,-,,'+'~ ~. <",.--<,.".,.t"'>I~I'", ._ .~"F'!",."C' "~-c '~"'. ".:',,",', -~ " . <),", ' ~, . . "... .. IN THE COpRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENI'!SYLVANIA CIVIL ACilON - LAW BELL ATLANTIC - PENNSYLVANIA, INC. Plaintiff No. 2001-00913 vs. KARL E. ROMINGER i/t/a ROMINGER WEB CIVIL ACTION Defendant(s) CLAIM FOR EXEMPTION To the Sheriff: I, the above-named defendant, claim exemption of property from levy or attachment: (1) From my personal property in my possession which has been levied upon, (a) I desire that my $300 statutory exemption be (i) set aside in kind (specify property to be set aside in kind): (ii) paid in cash following the sale of the property levied upon; or (b) I claim the following exemption (specify property and basis of exemption): (2) From my property which is in the possession of a third party, I claim the following exemptions: (a) my $300 statutory exemption: _ in cash; _ in kind(specify property): (b) Social Security benefits on deposit in the amount of $ (c) other (specify amount and basis of exemption): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date: Defendant THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY: South Hanover Street, Carlisle, PA 17013 717-240-6195 "'," ~" '-"'~''''S''~."r"'''''''''-' . -",'''> ,.,",:..."'i"!O"'-,,,,I"f>I~, __"'O,""/'."^ 0'._' , " _'-' "__l. 'r"",_~ ,,,__. ."^. _".,.c ,."._ MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300.00 STATUTORY EXEMPTION 2. BIBLES, SCHOOL BOOKS, SEWING MACHINES, UNIFORMS AND EQUIPMENT 3. MOST WAGES AND UNEMPLOYMENT COMPENSATION 4. SOCIAL SECURITY BENEFITS 5. CERTAIN RETIREMENT FUNDS AND ACCOUNTS 6. CERTAIN VETERAN AND ARMED FORCES BENEFITS. 7. CERTAIN INSURANCE PROCEEDS 8. SUCH OTHER EXEMPTIONS AS MAY BE PROVIDED BY LAW ""'<"f"" .. ",if' - "".--,~,,,"-"";,,-,.__.,""_,~;.II![I!I.,."""'''-'"';'~'''I''''''_ "'''+,<, ',n... ,I- ., ""'" ,-, , . ~"--." -- , ", " r:,! , i, 'l- ,"':,(.~::~ ~" ! .(-,!~) ! ,L1JiY 02 JrV I! Ai, 8 i>1J": : lJ. Q C' '\.c .. ~ U//ir-',",., ,'. . /jfj;J~<-"S~~;/{ ,/~qUNTY -.. !!...//"\IViA i/~oO ?c:l ~ IS'.DD - Cork ~():.. /1;.00- /. .r ~ ":PI !;. 00 - Ii ,( .$/I.ou Co C2.lLJ4. I J...PJ'lb l~~ 1').()S7~ BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant PETITION TO STAY EXECUTION AND RENEW PETITION TO STRIKE/REOPEN JUDGMENT AND NOW, comes Karl E. Rominger, pro se and avers as follows: 1. A Petition to Strike/Reopen Judgment was filed on March 2, 2001. (Exhibit "A") 2. Said Petition to Strike/Reopen Judgment was never decided on its merits and was instead scheduled for Argument Court. 3. Said matter included a request for a Stay of Execution. 4. Counsel for Plaintiff, Bell Atlantic praeciped to place the same on the Argument List for argument on July 25,2001. 5. The matter was removed without prejudice to re-list from the Argument List, by agreement ofthe parties, by Praecipe of Defendant on July 20,2001. (Exhibit "B") 6. On January 17, 2002, Bell Atlantic Pennsylvania had the Sheriff execute a levy on what is allegedly Defendant's property. 7. Defendant/Petitioner now asks that this Court stay the execution of the judgment and place the Petition to Strike/Reopen Judgment back on the Argument List to be decided on its merits. -""".4 ~_ ~ '.~. -, , -rl""'l - - _.~, ,- WHEREFORE, Petitioner respectfully requests this Court place the Petition to Strike/Reopen Judgment originally filed on March 2, 2001, on the Argwnent List and Order a Stay of the Execution. Respectfully submitted, - ?' Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Date: January 17,2002 0".,,-. "~ ' . I"-I~.~. ',' , ", - "~. BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA ; No. 2001-00913 v. KARL E. ROMINGER i/tJa ROMINGER WEB Defendant ORDER OF COURT AND NOW, this _ day of ,2001, upon consideration of the Petition to Strike/Reopen Judgment of the Defendant, A Rule to Show Cause is issued upon Bell Atlantic Pennsylvania to show cause why the relief requested should not be granted. Said Rwe returnable (20) twenty days of the date of service of this Order. Pending resolution of this Petition a Stay of Execution is granted. By the Court; J. Distribution: Karl E. Rominger, Esquire Ronald Amato, Esquire Cumberland County Sheriff Ex ~ih't- 1///1 "~r;~ - - ~ ,~" . . BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYL VANIA : No. 2001-00913 - ,oj v. ,,- ,. KARL E. ROMINGER i/t1a ROMINGER WEB -,-'" Defendant ~;.) ',] ._J PETITION TO STRIKE/REOPEN JUDGMENT AND NOW, comes Karl E. Rominger, pro se, and avers as follows: I. Judgment was entered on the 2 #lday of 0 C I. . 2000, in Philadelphia Municipal Court. 2. Said Judgment was transferred on February 14,2001 to Cumberland County Prothonotary for entry upon the record. 3. Petitioner disputes the validity of that Judgment. 4. Petitioner believes and therefore avers that the Judgment was entered by a Court which did not have subject matter jurisdiction to do such. I. MOTION TO STRIKE FOR LACK OF SUBJECT MATTER JURISDICTION 5. Previous paragraphs incorporated by reference. 6. Under the Judicial Code and pursuant to the Rules of Civil Procedure governing actions which proceed before District Justices, in particular Rule 302. Venue., subject matter jurisdiction did not exist. 7. The Judgment transferred to Cumberland County is based upon a Court Order and '"'_M..,1"l~~~', -~ .... Judgment where the underlying Court did not have subject matter jurisdiction, and the Judgment is void. 8. Petitioner requests that this Court strike said Judgment from the Cumberland County Docket with prejudice. WHEREFORE, Petitioner respectfully requests that this Honorable Court strike or vacate the Judgment in the above captioned matter, and pending resolution Stay of Execution. II. MOTION TO STRIKEIREOPEN JUDGMENT FOR LACK OF PERSONAL JURISDICTION 9. Previous paragraphs incorporated by reference. 10. The Judgment transmitted to Cumberland County is defective on its' face insomuch as it does not contain any evidence that personal jurisdiction was obtained by the issuing authority. II. Without personal jurisdiction, the Judgment is infirm and should be voided or struck from the record. WHEREFORE, because the Judgment in the above referenced matter, contains no evidence of the Court securing personal jurisdiction over the Defendant, Petitioner respectfully requests that this Honorable Court strike said Judgment or in the alternative open said Judgment. Respectfully submitted, ?~ Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Date: March 2, 2001 _'Ii """ I ~,~.~, , r-'I' ~, BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, pro se do hereby certifY that I this day served a copy of the Motion to Strike upon following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Ronald Amato, Esquire AMATO AND MARGLE, P.C. 107 North Commerce Way Bethlehem,PA 18017 ~~ Karl E. Rominger, Esquire Pro Se Dated: March 2,2001 '0""'_1 -,-- "~" . -, 1'"1_,0 ~ - .~ BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER i/tla ROMINGER WEB Defendant PRAECIPE TO REMOVE FROM ARGUMENT LIST TO THE PROTHONOTARY: Please remove the above captioned matter that is scheduled for July 25,2001, from the argument list by agreement ofthe parties, without prejudice to relist at a later date. Respectfully submitted, ~ /~~ ... - Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendant Date: July 20,2001 Ex ~//;I-t lIb II ''''''fUi''''''~'~r - .r-'!,- ~~~, " "~ ~S,_" BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER i/t1a ROMINGER WEB Defendant CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, Pro Se do hereby certifY that I this day served a copy of the Petition to Stay Execution and Renew Petition to Strike/Reopen Judgment upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Cumberland County Sheriffs Office One Courthouse Square Carlisle, P A 17013 Ronald Amato, Esquire AMATO AND MARGLE, P.C. 107 North Commerce Way Bethlehem, PA 18017 Via Fax and First Class Mail ~ .... Karl E. Rominger, Esquire Pro Se Dated: January 17,2002 ''''-0-'1 _" q ,I"!'I-" BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant ORDER OF COURT AND NOW, this z!" day of 1- ...., ,2002, upon consideration of the Defendant's Petition and prior Petition to Strike/Reopen Judgment of March 2, 2001, a Rule to Show Cause is issued upon Plaintiff to show why this matter should not be placed on the list for the next scheduled Argument Court. Pending resolution of this Petition and the underlying Petition to Strike/Reopen Judgment, a Stay of Execution is granted by the Court. Said Rule is returnable in twenty (20) days from the date of this Order. Distribution: ~~. Rominger, Esquire fald Amato, Esquire ~berland County Sheriff J J. ~:;;d1t~~d :';'_J~ II -I, -~".,^.,.)I':l M1~I-;" .. w _', ,. i/il........_........, ~l!!!lI~Ia!lIi!!"k!!IOi~*'''''.~''''";,-;l"~,,,'J"'''&'''Lii';6-_.,Mkilj~~ - ~.~'=~ ., " ,_. _~.;,. ,,,,p'~".~."_ ~"_" ~ ~.~,_,~~.. ,~<'O _. -'';';'' I ~~~....... ~ ~~""'\lijl~ "'lED-OfFiCE OF e::rfkJi''Uf,i\RY 02 JArJ 25 PI'I 3: 45 CUMBERu1;\iD COUNTY PENNSYlVAIIJIA I ~ "'_~~' _" llIliIIiIii" ~ " COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BELL ATLANTIC - PENNSYLVANIA, INC. Plaintiff No. 2001-00913 vs. KARLE, RONUNGERiffla ROMINGER WEB Defendant(s) PLAINTIFF'S ANSWER TO DEFENDANT'S PETITION TO STAY EXECUTION AND RENEW PETITION TO STRIKE/REOPEN JUDGMENT 1. Admitted. 2. Admitted. 3. Admitted 4. Admitted. Defendant failed to request the argument be scheduled on his petition. 5. Admitted that Defendant removed case from argument. Denied that the parties agreed that Defendant could remove the case without prejudice. The agreement was that Defendant would discontinue his petition to strike/reopen judgment. 6. Admitted. 7. Admitted. Denied that Defendant is entitled to the relief requested. Wherefore, Plaintiff respectfully requests Defendant's Petition be denied. PLAINTIFF'S NEW MATTER TO DEFENDANT'S PETITION 8. Plaintiff filed suit against Defendant in the Philadelphia Municipal Court. 9. A default judgment was entered against Defendant and in favor of Plaintiff. 10. Plaintiff transferred said judgment and filed a writ of execution against Defendant. 11. Defendant filed a petition to open and petition to strike judgment. '~.l .,'0.. '1.._ ~'" _,r'^<,~'. ~.'__,_v~I""I, ". -,' 'c" _..,. -' .., "I, '. <,_,., - '," """ .,.C'", ,,_, ~.~"" ,< -' -. ~~ ,,- "dO'_ > ; 12. The parties settled the above matter and Defendant agreed to pay to Plaintiff $5,000.00. A true and correct copy of Plaintiffs settlement letter is attached hereto, made a part hereof, and marked Exhibit "A". 13. Defendants payments of $500.00 were due on July 28, 2001 and the 28th of each month thereafter until $5,000.00 was paid. 14. Defendant made two payments to Plaintiff: $1000.00 on September 10, 2001 and $500.00 on October 22, 2001. 15. Thereafter defendant failed to make further payments and a writ of execution was again filed by Plaintiff and Defendant reschduled his petition to open and petition to strike judgment. ~ATO~PC Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem. P A 1801 7 (610) 866-0400 "l""",,,,?!, .,,~"".,,>~,-', >,-","-. "'1"J",.,"""e"~',~I~I~,,~, .~~~~,~, ~, ,".M ,_ . LAW OFFICES OF . :AMATO, MARGLE & McKARSKI, 'P.C. 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017-8930 TELEPHONE (610) 866-0400 FACSIMILE (610) 866-9155 RONALD AMATOt ramato@amatolaw.com STANLEY J. MARGLE, lIlt smargle@amatolaw.com EDWARD J. McKARSKIt emckarski@amatolaw.com MICHAEL J. KENNEDyt ALAN R. MEGEt KRISTOPHER T. SMULLt JEFFREY H. LEVYtt mkennedy@amatolaw.com amege@amatolaw,com ksmull@amatolaw.com OF COUNSEL MargIe Direct: Collection Status Requests: Phone (610) 865-9970 VokeMail(6IOlJ66-24S4 status@amatolaw.com tAdmllled in PA only ttAdmitted in MD and DC only July 20, 2001 Karl E. Rominger 1 55 South Hanover St CARLISLE PA 17013 Re: BELL ATLANTIC. PENNSYLVANIA,INC. v. KARL E. ROMINGER Court of Common Pleas of Cumberland County Civil Action No.: 2001-00913 Our File #: 2002227 Dear Mr. Rominger: This letter will confirm that our client is willing to accept your offer of $5,000.00 in full settlement of this claim. The settlement is to be funded in monthly installments of $500,00, commencing July 28, 2001. The offer will be accepted in full settlement of the above- captioned matter. All payments are due on the 28th of the month. Once we are in receipt of cleared funds we will satisfy the judgment entered of record in the above Common Pleas Court case and in the Philadelphia Municipal Court. You have agreed to withdraw your petition to open/strike judgment with prejudice. Please confirm this by letter to the court today and service on our office by facsimile. You have 15 days to cure any default in the payment and we will take no further steps regarding execution on the judgment pending payment. In order to insure DrODer credit. all checks under this aClreement are to be made Davable to "Ronald Amato, Attv for Bell Atlantic-Penna, Inc." and forwarded to our Bethlehem office. If you have any questions regarding the aforementioned, please do not hesitate in contacting our office. As time is of the essence of this settlement, it is required that this settlement be funded in a timely fashion. Your prompt attention and cooperation in closing out this matter is required. Very truly yours, AMATO, MARGLE & McKARSKI, P.C. By: Michael J. Kennedy FORWARDED VIA FACSIMILE AND REGULAR MAIL TO 717-241-6878 !. EXHIBIT 1!i !~ ,'''',""," r -, C",",,"" ,",,,,,,~,,,,, ''',.', ~"~"', ,""..~ 1.""1 ~_~.~~ ~,'- __.~__= -,'" HP LASERJET 3150 PRINTER/FAX/COPIER/SCANNER SEND CONFIRMATION REPORT FOR AMATO AND MARGLE PC 610-866-9155 JUL-20-01 10:25AM JOB START TIME USAGE PHONE NUMBER/ADDRESS TYPE PAGES MODE STATUS 261 7/20 10:24AM 0'2711 17172416878.... ....,.......,. SEND. ....... ..... 1/ 1 EC144 COMPLETED. ........... .... "n' ... TOTAL 0'27" PAGES SENT: PAGES PRINTED: 0 LAW OFFICES OF AMATO, MARGLE & McKARSKI, P.C. 107 NORTH COMMBRCE WAY BliTHLEHEM, fA 18017-8930 1'aBPHONB(6/l)jB66-OolOO FACSIMJJ..B (610) ll6l\-'Jl~5 1000oUDA\cA.tot ,_._ $TAlfU!YI.w.ROl.I!,ml~._ BD"'AKDJ.~I~..... -'- "....."_..................,.,, ~._- -- ~~~.:s..~! ~::.- ~T.5MULLt -.-......._ MM1eyll.L~ll O~OOlllWD. 1_~'..""jj_"..P...DC.... July 20, 2001 Karl e, Rominger 156 SQlJth Hanover St CARUSLE PA 17013 RI: BELL AtLANTIC. PENNSYLVANIA,INC. v. KARl E. ROMINGER CDIJJt of Common Pfut, of Cumblrlllnd County CI"II Actfon No.: 2001-00913 01lI RJe #: 2002227 OuarMr, Rominger: Thll telter wm conflllT1 that our elle t I Jill slnlement of this claim. The .8ttlem~nt ~.: b~g~O d 8~CtPt YOU~ olf.r of $5,000.00 In full '~m, enelng July 28. 2001. The offer will be 8~C:Pte~~:nf~,:Ysl:~:~~e~t.,o::6~OO. captonadmatter.Allpaymlnlssredusontho28th f h n 0 eave- cle..red fundi we wlU satisfy tho Judgment entenld ~ftre~n;:~t~nc:e we are In receipt of Court eNO and In too PhHadei&mla Munic/pll Court. e abovl Common PIli' You havl agreed to wlthdrtwy 1111 ' confirm this by leller to tha cou;~;:Il~ 0; 10 ~PflnfetrJku Judgment with prejudice. Please daye 10 cure tny default In tha psyment lIen~ ;~rv ~~ ~~ our fffl~e by facsimile. ,Vou halle 15 onlhllJudllmontpondlngpovrnent. w eno urt erstepllregard,ngelClH:utlon InordertlllnelmlDMI'lIDOt'.MIlIt a1lch."'lteund.rthl...... ~Ron.1d AmarI!> _ Attv t.... Ball At/anlle.Penna Ine.;""d ;;::::=~:t~,~ 1l:;'::h::'~:O If you haV8l1nyquestlonl regarding the aforemenl1oned ptessedo nothet o. ourofflcs, AI time la ot the elsence ofthlssettl " I . ltatelncontllcllng fundedlnstlmelytaehlo y emsn!. It s requlrod thai thia settlement be Is required. n, ourpromptattenllonllndcooperlltJoninclosinlloutthlsmllttor FORWARDED VIA FACSIMILE; AND REGULAR MII,IL TO 717-241-6878 Verytrulyvours, :~TO:~RG~&~c~tKI, P.C. 1t.!1J. a-~ PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and subnitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter f= the next Argunent Court. CAPTION OF CASE (entire caption must be stated in full) BELL ATLANTIC - PENNSYLVANIA, INC. (Plaintiff) vs, KARL E. ROMINGER i/t/a ROMINGER WEB ( lleferrlant ) No. 00913 Civil Action I~ 2001 1. S tate matter to be argued (i. e.. plaintiff's lIOtion for new trial. deferrlant' s demurrer to complaint. etc.): Defendant's Petition To Strike/Reopen Judgement 2. Identify counsel who will argue case: (a) for plaintiff: Address: Michael J. Kennedy 107 North Commerce Way Bethlehem, PA 18017 (b) for deferrlant: Address: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle PA 17013 3. I will notify all parties in writing within two days that this case has been listed for argunent. 4. Argunent Court Date: May 22, 2002 'o';~'!~""""",ij<lf,,,,\ '''',\, e II ~ Attorney f= Plaintiff Ronald A\uiiirro~ ~~~I';':"f' - , "~^ ,II!I~: Dated: March 7, 2002 r'~LHJ-Ol:f"lCE OF" " ;.:: !:!-:'n~L,:;-:,t',rff.1\~\Y ~ I I ~ I g [' ~. l ,~ " , I ,. ,) I I "I,,'j ": ,,- -,' Ti t.-~ r,~', .', . \, j~ 1 ",.1, . , {.~ '" . Ci 'I !,I ,,_. " ,. '''''''I'T\( ,-.h',;L);-i-'V 1-',,\'1 : ( " 1: ,,\1. _, _ ",",,' ..J~''-F~! I PENNSYLVi\N!A ~ . t ~ t ;r' , , c 'J. . ~ ~, ~ i ~ . I . . ~ J!i I I (Jr/~ <../ MAY 1 7 2000 BELL ATLANTIC - PENNSYLVANIA, Plaintiff ; IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant ~ AND NOW, thi~ day of ORDER OF COURT scheduled for May 22, 2002, is rescheduled , 2002, the Argument previously next Argument Court. The Prothonotary is directed to list the matter for the same. Distribution; Karl E. Rominger, Esquire Robert A. Amato, Esquire ~ ~ S,.21-0.i..J Q-, Prothonotary's Office "''''~'''''Io,.", I!!""I - . ~ >',..-",. ,. "'I"""_IiiM_,""~KW~Mi1'J1;.",,,;;!,,~.j"'Y"".'.~o!i,~.,tL.,,,,,...,;,,,,,,,~;;\1illl\'*~!IlllIiilllilJii"~' .. " ~ "",,,,,",,",,,,,". I~l,__.",. FI! l='f--('lj..T1C~ n,- 'n :1---"::'~:: :';, l! t Ii :>".-' .~,-Y\'l ?'\\!nl"~""\i -" ; 'I_"i :!),.;],.~,jAdr 0211A'f 2 I Mill; f7 . "'UI,Cq'r- v 'v!tJt "{u\'.~i') ('F1Uf\J1'V PEN"!C;lfl'\!A~N~1 ^ ' " ~vr , .1 '1"\ I ;]~:X,.~,--,Jl~]r,_, ,.","'i' .'*"''''''''''',''=I~_~ ,~ ~ ~ ~.."".,~ ,_ ,'_~ ~~~" -<-. ., "I '" BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant MOTION FOR CONTINUANCE AND NOW, comes Karl E. Rominger,pro se, and avers as follows: 1. There is a hearing scheduling in Argument Court for May 22, 2002 at 8:30 a.m. 2. Karl E. Rominger, Esquire has to be in Superior Court for Argument on the same day. 3. Attorney Rominger is unable to continue the Superior Court Argument. 4. Opposing Attorney Michael Kennedy has been contacted and is in agreement with the continuance. WHEREFORE, Defendant respectfully requests a continuance on the Argument now scheduled for May 22, 2002, and requests that same be rescheduled to the next Argument Court. ~ Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ID # 81924 Date: May 16, 2002 '~-';~I .,~" ""I ~. BELL ATLANTIC - PENNSYLVANIA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-00913 v. KARL E. ROMINGER i/t/a ROMINGER WEB Defendant CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, pro se do hereby certify that I this day served a copy of the Motionfor Continuance upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows; Robert A. Amato, Esquire AMATO AND MARGLE, P.C. 107 North Commerce Way Bethlehem, PA 18017 ~/ Karl E. Rominger Pro Se ~__ ,llI"W, .~I""I.. <. <~ ~ '.- - . ' Ui F\L.tD-O\::\::\CE L ' ;,;,;l".,:~.\\"..\O\?H'{ I I - . ~ 0'2 Fjf\':( \ G PH 3: 08 1"'1 \' I) -,_ ,'" I' _,", ,",,'-' \~ I'l'J \...A/\\;\~.xJ\L.r\i\U <'JUU1'41 \ PENNSYL\iN~\i'\ I I ~ " . i . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BELL ATLANTIC - PENNSYLVANIA, INC, Plaintiff No. 2001-00913 vs. KARL E, ROMINGER i/t/a ROMINGER WEB CIVIL ACTION Defendant(s) PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please satisfy the judgment entered in the above-captioned case. AMATO AND MA By: onald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 ~,~>.~ ',1 ,~""",,," __~_ ,.... R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff s Costs; Docketing $ 18,00 Poundage 40,00 Advertising ~ Law Library ~ Prothonotary 1 . 00 ~ Mileage 3.45 &b Misc. l? .) Surcharge 2()I;OOC Levy 20,00 Post Pone Sale Garnishee 112,45 Sworn and Subscribed to before me This 6~dayof . nJ1ul' 2002A.D.Qr. CJ ),,,,io.. "~ Prothonotary '-"~""4-'" ,'!!!""I Advance Costs; Sheriffs Costs: 150,00 112,45 '. 37,55 , , if ~ Refunded to Arty on 7/22/02 0,' - , --I> \::;:; so~~' ..~ 1'~ as Kline, Sheriff IT~uJ~ By ~1).SI1l'\3d 'i\l'\~ "1\1\;'1 -\-"i c: 1 ,r'::'~ \\ ~1f l~, ~\d oZ Z . i.l\jrH10 kl-llnc'J ~~i. ~tQ 3n\~~O H\\\:!\\S \,1iU e,K6 f) (,\ 't ~ /;)~Dfl.. '"1' .,....'.,..,."'!'y , ~", & "_. ^ _U._ I WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NOOI-913 Civil CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Bell - Atlantic - Pennsylvania, Inc.PLANTIFF(S) From Karl E. Rominger i/tla Rominger Web, 155 South Hanover St., Carlisle, PA 17013 (I ) You are directed to levy upon the property of the defendant( s) and to sell All cash on hand or in the possession of the defendant(s) , accounts receivables, furniture, furnishings, equipment, inventory, tools, vehicles, electronic equipment, any and all other personal property belonging to the above-narned defendant(s). (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 arty property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty 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 himiher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $6,225.76 Interest Arty's Comm % Arty Paid $45.00 I'laintiffPaid L.L. Due Prothy $1.00 Other Costs Date: January II, 2002 CURTIS R. LONG Prothonotary, Civil Division REQUESTING PARTY: Name Rouald Amato, Esq. ~: Ao~ P 71;01J(~~ Address: 107 North Commerce Way Bethlehem, PA 18017-8930 Attorney for: Plaintiff Telephone: 610-866-0400 Supreme Court ID No. 32323 5Vf "._ ,~~~~._ !II_"l\l'J~I"ll1\\l'J'~ ~ _~.,..-~~ ~ _v.~"""",,,,,,,i1W.1'I!"1lw.'.w'i<J'l'R~_';,,,,,,,~~~~;-,,,,,,,,,,.,,,C_-'i:,"- '-'-"P,~"-;["1'~"I'~'''i,9I!J!V-~':''''~*]{'1''-"f;'';'\J''.<;;.~j;~rK,_~_~__. "