The URL can be used to link to this page

Home My WebLink About01-04283LAW OFFICE OF PATRICK LAUER 2108 Market Street Camp Hill, PA 17011 Plaintiff v. LEE & SARA VANASDLEN 16 Hill Road P. O. Box 636 Carlisle, PA 17013 Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. p~ - kzP3 e-iJ~~~~-~, PRAECIPE Please enter Judgment in the amount of $437.50, plus costs, against Lee and Sara Vanasdlen as per the attached Notice of Judgment/Transcript Civil Case. Date: _ Z~,~p~ Charles Rector, Esquire 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA rro•inirv rvF• CDMBSRLAND Mag. Dist. No.: 09-3-02 DJ Name: Non HLLSN B. SHDLENBSRGSR ^tltlfe55 P.O. `BOX 155 27 W. BIG SPRING AVENUE NEWVILLE, PA Telephone (717 ~ 776-3187 17241 ATTORNEY FOR PLAIHTIFF NOTICE OF JUDG~+MENT/TRANSCRIPT PLAINTIFF: CIVIL VASE NAME antl ADDRESS _ rLAW OFFICE OF PATRICK LADER 2108 MARKET STREET CAMP HILL, PA 17011 L J VS. DEFENDANT: NAME andnooaess rVANASDLSN, LEE, ST AL. ~ 16 HILL ROAD CARLISLE, PA 17013 CHARLE5 RECTOR, 13SQ. L J 1104 FERNWOOD AVENUE APT.# 203 DocketNo.: CV-0000056-01 CAMP HILL, PA 17011-6912 Date Filed: 4/18/01 THIS IS TO NOTIFY YOU THAT: Judgment: _DBFAIILm rUDC-MBNT ~LT1? _~~,_,_ Judgment was entered for: (Name) T.AW OgarrR nF vamRrrx r.ArrFR Judgment was entered against: (Name) _ VAUrASnr,xnr, LS8 in the amount of $ a37 _ sn on Defendants are jointly and severally liable. Damages will be assessed on: This case dismissed without prejudice. Amouht of Judgment Subject to AttachmenUAct 5 of 1996 $ Levy is stayed for days or ~ generally stayed. Objection to levy has been filed and hearing will be held: Date: Place: I Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OFJUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. ~ ff + /~ " ~ ~ 4rt~Qate ' District,Justice ti r :, t certify th2t,this is`a true end c~o`rrect copy of., the record of: the proceedmgs contaltt~ng the judgment: `~~ ~~_ Date ~:;~; ~?Rn.. ; DistricfJustice My commission expires first Monday of January, 2006 SEAL AOPC 315-99 (Date of Judgment)- 5/99/n1 (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total Post Judgment Credits Post Judgment Costs Certified Judgment Total $ . . ,_ ,.. . .~ w COMMONWEALTH OF PENNSYLVANIA NOTICE OF ~1UDGMENTfI~A~RISCRIPT cc~~rr~"~F: CUMBERLAND .,-n ~-~ CIVIL CASE Mag. Dist NO.l . ~ ~ 'PLAINTIFF: ~ NAME antl ADDRESS, -~ - 09-3-02 rLAW OFFICE OF PATRICR LPiUER ~ DJ Name: Hon. 2108 MARKET STREET - .: HELEN B. SHULENBSRGSR CAMP HILL, PA 17011 Atltlress: P.O. 'BOX 155 L_ J 27 W. .BIG SPRING AVENUE - VS. NEWVILLE, PA DEFENDANT: NAME andAOOeESs ' `~ '7o~tlPnane:-(41'7) 776-3'187 ' 17241 rVANASDLSN,' ZSS, ET AL7 16: HILL. ROAD ATTORNSY.FOR :PLAINTIFF CARLISLE;•'PA.17013 - ,.,, CHARLES RECTOR, ESQ._ r Lxl 1`: _~ ,. ,• J :. J.104 FERNWOOD AVENUE APT.# 203 DocketNo.: CV-0000056-01 CAMP HILL, PA 17 011-6912 Date Filed: 4/18/01 THIS IS TO NOTIFY YOU THAT: - _ _ ,k,dgment: ~ ~ - R~T-s~LIJ~G~'~'I~tT ~~Lmlr _. X Judgment was ente for. Name ~ r Aw~~ ~ ~ ~~ ~ ~ ' red -. ( ) '. nuFTUg nu nn,murrR i.ATI6R Judgment was entered against: (Name) vAxASnr.~T SARA ,... in the amount of $ , aa7 _ ~n ot: (Date of Judgment) 5/29/n1 'Defendarits are jointly ahd severally liable. '` (Date & Time) Damages will be assessed on: This case dismissed without pre)udice. Amount of Judgment Subject to AttachmenUAct 5 of 199fi $ Levy is stayed for days or ~ generally stayed. Objection to levy has been filed and hea ng~ivill be held: Attb"rney Fees Total Post Judgment Credits $ Post Judgment Costs $ ----------- Certified Judgment Total $ LAW OFFICE OF PATRICK LAUER 2108 Market Street Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. LEE & SARA VANASDLEN 16 Hill Road Carlisle, PA 17013 Defendant NO.Ol-4283 CIVIL TERM CIVIL NIIGMENT PRAECIPE FOR WRIT OFEXECUTIOIO' TO THE PROTHONOTARY: Issue writ of execution in the above matter, (1) directed to the Sheriff of Cumberland Countv; (2) against Lee & Sara Vanasdlen, Defendants; and (3) against ,Garnishee; (4) and index this writ (a) against Lee & Sara Vanasdlen Defendants ,~ A.uy ~eC. ~.L . ~~L ~~/~y (b) against , Garnishee, as a lis pendens against real property of the Defendant in name of Garnishee as follows: N/A (5) Amount of Judgment $ 437.50 Attorney Fees $ 150.00 Total $ 587.50 (plus costs) BY:_~I^,Q~~ Charles Rector, Esquire ID# 39121 Date:1 ~ D~ 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717)761-8101 o ~ ~ "~ l ~ ~. ~ ~ ~ ~ ~ 8 ~c~~ ~ ~ ` 'v ~~ ~ e ~J eo ~~- mES".'.AY'R91 Gr§~.:-~?~SWt },Trvg3F,:C"319'SPV~Ft0~6IDy.M.SRU!C'~$nF~ LAW OFFICE OF PATRICK LAUER 2108 Market Street Camp Hill, PA 17011 Plaintiff/Petitioner v. LEE & SARA VANASDLEN 16 Hill Road Carlisle, PA 17013 Defendants/Respondents AND NOW, this day of Plaintiff s Motion to Direct Sheriff to 2001, upon consideration of and Enter Premises and to Effect Personal Properly Levy, a Rule is hereby issued upon Respondents to show cause, if any, why the requested relief should not be granted. RULE RETURNABLE ten (10) days following service of this Rule upon Respondent. _II'O~ 9-a IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~~lil~!v'T~71,SNiJ~c cJ ~ 1 .~; u~~l~~ (Z d ~S ~ u ~ :;:ifs a;~,•iJ~1J ~'~ .~rR LAW OFFICE OF PATRICK LAVER : IN THE COURT OF COMMON PLEAS 2108 Market Street :CUMBERLAND COUNTY PENNSYLVANIA Camp Hill, PA 17011 Plaintiff N0.4#9A~b60 UI - N~~3 L"tui~, ~~ v. LEE & SARA VANASDLEN 16 Hill Road Carlisle, PA 17013 Defendants MOTION TO DIRECT THE SHERIFF TO BREA%AND ENTER PREMISES TO EFFECT PERSONAL PROPERTYLEVY AND NOW, comes the Plaintiff, Law Office of Patrick Lauer, by and through their attorney, Charles Rector, Esquire, and files the within Motion to Direct the Sheriff to Break and Enter to Effect Personal Property Levy: Plaintiff is a judgment creditor of the Defendants in the above-matter. 2. A Writ of Execution was issued by the Prothonotary of this Court and delivered to the Sheriff, whose deputy was refused admittance to the premises to conduct the levy in obedience of said Writ of Execution. 3. The Sheriffs office advised counsel for Plaintiff on August 14, 2001, that unless the Sheriff is Ordered by the Court to break and enter the said premises, the Sheriff will be unable to make a valid levy by viewing the personal property, Defendant will be enabled to obstruct the lawful process of this Court via its Writ of Execution and Plaintiff will be frustrated in its efforts to enforce its judgment. 5. The refusal to admit the deputy Sheriff was a willful, vexatious, dilatory and obdw'ate attempt to obstruct the service of the lawful process of this Court. 6. Plaintiffs counsel has expended two hours in preparing, filing and attending to this Motion and counsel's ordinary, usual and customary hourly rate for the same is $150.00. WHEREFORE, Plaintiff respectfully urges this Court to Order the Sheriff of Cumberland County to break and enter Defendants' premises as soon as possible for the purpose of conducting a personal property levy and award $300.00 attorney's fees to Plaintiff as costs. RESPECTFULLY SUBMITTED, Charles Rector, Esquire 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Attorney for Plaintiff Date: CERTIFICATE OF SERVICE I, Charles Rector, Esquire, do hereby certify that on the ~ day of September, 2001, I caused a true and correct copy of the within Motion to be served upon the following individuals by depositing same in first class, United States mail, postage paid, in Camp Hill, Pennsylvania: Lee & Sara Yanasdlen 16 Hill Road Carlisle, PA 17013 Date: ! uw) By: ~~ ~ ~e Charles Rector, Esquire 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717)761-8101 0 ...e~ °.~" V' C' vJ -~ V ,, -~, ` _ - ~~i- /p Cr'' J (.; i -C „ x5: :y1 ~, ~-.T c~0 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned STAYED. Sheriff s Costs: Advance Costs: 150.00 Sheriffls Costs 74.21 Docketing 18.00 75.79 Poundage 1.46 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 07/ 17/07 Mileage 3.25 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee TOTAL 74.21 ~/ 7 ~ 4 o-~ /- So Answers; R. Thomas Kline, Sheriff B}~i &~~~ ~~ili~N~ ;~"t~ .;~.~U ~~ ~~,,. ~y5 75v c r WRIT O~ EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO COUNTY OF CUMBERLAND) TO THE SHERIFF OF _rti,p~~rlanr7 _ ________,_COUNTY Ol_-4283 CIVIL ~ ~~ CIVIL ACTION -LAW To satisfy the debt. interest and costs due Law Office of Patrick Lauer ~_-- --------- --- -- -~_ PLAINTIFF(S) from _ i,P,e & Sara Vanasdlen. 16 Hill Road, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Any and all personal property (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 notrfy 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 tonotify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $437.50 Interest Atty's Comm °lo Atty Paid $31.75 Plaintiff Paid Date 18, 2001 L.L. $.50 Due Prothy $1.00 Other Costs $150.00 Curtis R. Long REQUESTING PARTY: Name_ rharlPG Rec or Esq. Address: 1104 FPrn`,vood Avenue, Ste. 203 S'amP ~i~~, PA 17011-6912 __ Attorney for: Rlaintiff Telephone: _~~~~ _R~ n1 Prothonotary, Civil Division