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Home My WebLink About03-2512g:\WPDATALHML\CLIENTS~PROCESS RECOVERY CORP~Prae. to Transl. Judge..doc (ver. 05/20/03.1) PROCESS RECOVERY CORP., Plaintiff VS. THE GENERAL CASTING, CO., Defendant File No. 320-169 IN THE COURT OF COMMON PLEAS BERKS COUNTY, PENNSYLVANIA CIVIL ACTION - AT LAW NO. 03-3059 PRAECIPE TO TRANSFER JUDGMENT To the Prothonotary of Cumberland County: Pursuant to Pa. R.C.P. No. 3002, kindly enter judgment against the defendant in the amount of $79,652.68, plus accrued interest at a rate of 1.5% per month, at the diem rate of $3.54 being the amount demanded in the Complaint, in accordance with the following documents attached hereto: (1) certified copy of all the docket entries in the above-captioned case; and (2) certification of the amount of the judgment in the above-captioned case; and forthwith enter the judgment in the appropriate dockets and index it against the defendant in Cumberland County. Dated: Beaver, P.C. [Attorney for Plaintiff Attorney ID# 32328 Forry, Ullman, Ullman & Forty, P.C. 540 Court Street, P.O. Box 542 Reading, PA 19603 Phone: (610) 568-1417 S~\WPDATA~-IML\CLIENTS~PROCESS RECOVERY CORPXCertf. of Address.doc File No. 320-169 (vet. 05/09/03.1 PROCESS RECOVERY CORP., Plaintiff VS. THE GENERAL CASTING, CO., Defendant IN THE COURT OF COMMON PLEAS BERKS COUNTY, PENNSYLVANIA CIVIL ACTION - AT LAW NO. 03-3059 CERTIFICATE ADDRESS I, Thomas W. Beaver, Esquire, hereby certify that the following are the last known addresses of the parties to this matter or their respective attorneys. The General Casting Co. 275 North Queen Street Shippensburg, PA 17257 Dated: Thomas W. Beaver, P.C. Attorney for Plaintiff Attorney ID# 32328 Forty, Ullman, Ullman & Forty, P.C. 540 Court Street, P.O. Box 542 Reading, PA 19603 // T. 3/°mas W-Beaver, P.C. 4~ttomey for Plaintiff Attorney ID# 32328 Forry, Ullman, Ullman & Forty, P.C. 540 Court Street, P.O. Box 542 Reading, PA 19603 Phone: (610) 568-1417 PROCESS RECOVERY CORP. vs. THE GENERAL CASTING, CO. No. 03-3059 I, Mafiarme R. Sutton, Prothonotary of the Court of Common Pleas of Berks County, Pennsylvania, do hereby ce~ify that the above and foregoing pages contain a tree copy and correct transcript of the docket entries, which form the whole record. Judgment has been entered and certified in favor of PROCESS RECOVERY CORP., Plaintiff and against 'the Defendant, THE GENERAL CASTING, CO. in the sum of $79,652.68 plus interest and costs. IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the seal of said Court at Reading, PA, this 22nd day of May ~-~. 2003. Marianne R. Sutton, Prothonotary 5/22/2003 03 03059 Berks County Civil Court Information System COMPLETE DOCKET SUMMARY REPORT PROCESS RECOVERY CORP, *** VS *** GENERAL CASTING CO (THE), PAGE: 1 PTR350 PTBCAMPB DOCKET NUMBER: 03 03059 INITIAL ACTION TYPE: Misc. case/ Civil Act. INITIAL ASSIGNED JUDGE: Jeffrey L. Schmehl, J. OLD SYSTEM CASE#: ***** ** ** ** ** DATE 3/19/2003 4/17/2003 4/23/2003 5/13/2003 5/13/2003 5/13/2003 5/20/2003 DOCKET SUMMARY 01:33PM Civil Action-COMPLAINT $79,469.13 plus... Shrf served COMPLAINT upon GENERAL CASTING CO (THE) on 04/04/2003 Deptzd srvd P.I.C. Cumberland County Withdrawal of Appearance of Howard M Lightman, Esq and Entry of Appearance of Thomas W Beaver, Esq for Plaintiff 03:40PM Default Judgment against The General Casting Co in the amount of $79,652.68 plus...Copies and Notice sent 5/19/03. Notice of Intent to Take Default Judgment w/Certification Certification of Addresses Exemplified Judgment to Cumberland County, PA PLAINTIFF (S): PROCESS RECOVERY CORP ATTORNEY: Beaver, Thomas W 01 02 DEFENDANT ( S ): GENERAL CASTING CO (THE) ATTORNEY: OTHER(S): ATTORNEY: 5/22/03 Berks County Civil Court Information System 03' 03059 CASE COSTS SUMMARY REPORT PROCESS RECOVERY CORP *** VS *** GENERAL CASTING CO (THE) PAGE: PTR353 DOCKET NUMBER: 03 03059 INITIAL ACTION TYPE: Misc. case/ Civil Act. INITIAL ASSIGNED JUDGE: Jeffrey L. Schmehl, J. OLD SYSTEM CASE#: ***** ** ** ** ** DATE AMOUNT P/D/R 3/19/2003 114.25 PAID 4/17/2003 38.00 PAID 4/17/2003 34.30 PAID 5/13/2003 16.00 PAID 5/20/2003 17.75 PAID COMMENTS COMPLAINT SHERIFF Cumberland County JUDGMENT EXEMPLIFIED-CUMBERLAND CO SHEET BOOK PAGE PROCESS RECOVERY CORP., Plaintiff rS, ' THE GENERAL CASTING, CO., · Defendant · TO: THE GENERAL CASTING COMPANY IN THE COURT OF COMMON I:)LEAS BBRKS COUNTY, PENNSYLV~3qlA CIVIL ACTION - AT LAW NO. 03-3059 You are hereby notified in accordance with Pa. R. C. P. 236 that judgment has b~e.,n entered on a' ( ) Final Order* ( ) DecreeNisi* ( ) Verdict* ( ) Viewers Report ( X ) Default _ ( ) Assessment of Damages ( ) Arbitration Award ( ) Non Pros ( ) and entered to Docket No. 03-3059 ~ Defendant(-~ concerning Civil Suit No. 03-3059 .against on March 19, 2003 in the sum of $79,682.68** ~-e~fer-pl~ sion of *And that a Certificate has been filed that a copy of the Praecipe has been mailed to each party who has appeared in the action or to his attorney of record. **Interest rate of 1.5% per month at the per diem rate of $3.54. DATE: MARL~R. SUTTON, PROTHONOTARY Deputy Prothonotary S:\WPDATA~HML\CLIENTS~PROCESS RECOVERY CORP~Prae. for Default Judge..doc (ver. 05/09/03.1) File No-. 320-169 PROCESS RECOVERY CORP., Plaintiff VS. THE GENERAL CASTING, CO., Defendant To the Prothonotary: IN THE COURT OF COMMON l~LEAS BERKS COUNTY, PENNSYLV/:a2qlA CIVIL ACTION - AT LAW NO. 03-3059 PRAECIPE FOR DEFAULT JUDGMENT Please enter judgment of default in favor of plaintiff Process Recovery Corp. and against defendant The General Casting, Co. for defendant's failure to plead to the complaint in this action within the required time. The complaint contains a notice to defend within 20 days from the date of service thereof. Defendant was served w_ith the complaint on April 4, 2003, and defendant's answer was due to be filed on April 24,2003. Attached as Exhibit "A" is a copy of plaintiffs written "Important Notice", which I certify was mailed by regular mail to the defendant at his last known address of record on April 28, 2003, which is at least 10 days prior to the filing of this Praecipe. Please assess damages in the amount of $79,652.68, plus accrued 1.5% per month, at the diem rate of $3.54 being the amount demanded in the complaint. interest at a rate of Thorr/t~s W. Beaver, P.C. Att?i-ney for Plaintiff Attbrney ID# 32328 510 Park Road, North Wyomissing, PA 19610 Phone: (610) 288-2500 Fax: (610) 288-2525 EXHIBIT "A" S:\WPDATA~IML\CLIENTSkPROCESS RECOVERY CORP\Certf. of Address.doc File No. 320-169 (ver. 05/09/03.1 PROCESS RECOVERY CORP., Plaintiff VS. THE GENERAL CASTING, CO., Defendant IN THE COURT OF COMMON ~LEAS BERKS COUNTY, PENNSYLV~ CIVIL ACTION - AT LAW NO. 03-3059 CERTIFICATE ADDRESS I, Thomas W. Beaver, Esquire, hereby certify that the following are the last known addresses of the parties to this matter or their respective attorneys. The General Casting Co. 275 North Queen Street Shippensburg, PA 17257 Thomas W. Beaver, P.C. Attomey for Plaintiff Attorney ID# 32328 Forry, Ullman, Ullman & Forry, P.C. 540 Court Street, P.O. Box 542 Reading, PA 19603 Dated: /AAhOmas W. Beaver, P.C. ttomey for Plaintiff ttomey ID# 32328 Forry, Ullman, Ullman & Forty, P.C. 540 Court Street, P.O. Box 542 Reading, PA 19603 Phone: (610) 568-1417 PROCESS RECOVERY CORP., . Plaintiff VS. THE GENERAL CASTiNG, CO., Defendant TO: ' THE GENERAL CASTiNG CO. 275 North Queen Street Shippensburg, PA 17257 DATE: April 28, 2003 IN THE COURT OF COMMON I~LEAS BERKS COUNTY, PENNSYLVA.2qIA CIVIL ACTION - AT LAW NO. 03-3059 IMPORTJS2qT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWiNG OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service of the Berks County Bar Association 544 Court Street Reading, PA 19601 (610) 375-4591 Tho?~as W. B,~, P.C. A~t6mey loC'Plaintiff Attorney ID# 32328 Forry, Ullman, Ullman & Forry, P.C. 540 Court Street, P.O. Box 542 Reading, PA 19603 Phone No. (610) 568-1417 Forty, Ull~/~, U1 .& The General Cas%lng Co. '2003 275 North Queen Street : Shi nsbur ' · MAY BE USED FOR DOMESTIC AND IN ': FOR INSURANCE .... TERNAT~IONAL MAIL, D('~ES : . NOT P~OVIDE ~ ' MAY1976 ~17 PROCESS RECOVERY CORP., Plaintiff VS. THE GENERAL CASTiNG, CO., Defendant To the Prothonotary: Issue a (1) (2) 17257; and (3) (4) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - AT LAW NO. 03-2512 PRAECIPE FOR WRIT OF EXECUTION writ of execution upon a judgment entered by defatflt in the above matter: directed to the sheriff of Cumberland County; against the General Casting Company, 275 North Queen Street, Shippensburg, PA against _, Gamishee; and index this writ: (a) against the General Casting Company, defendant and (b) against the personal property of the defendant, including but not limited to Company office equipment. (Specifically describe property) (If space insufficient attach extra sheets) (5) Amount due Interest from 03/19/03 Attorneys' fees Costs to be added Date: $ 76,652.68 $1.5%/Month $ Reading, PA 19603 Counsel for Plaintiff PROCESS RECOVERY CORP., Plaintiff VS. THE GENERAL CASTING, CO., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - AT LAW NO. 03-2512 CERTIFICATE ADDRESS I, Thomas W. Beaver, Esquire, hereby certify that the following are the last known addresses of the parties to this matter or their respective attorneys. The General Casting Co. 275 North Queen Street Shippensburg, PA 17257 Thomas W. Beaver, P.C. Attorney for Plaintiff Attorney ID# 32328 Forty, Ullman, Ullman & Forry, P.C. 540 Court Street, P.O. Box 542 Reading, PA 19603 Dated: s W. Beaver, P.C. ey for Plaintiff Attorney ID# 32328 Forry, Ullman, Ullman & Forry, P.C. 540 Court Street, P.O. Box 542 Reading, PA 19603 Phone: (610) 568-1417 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO03-2512 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Process Recovery Corp. Plaintiff (s) From The General Casting Co. 275 North Queen Street, Shippensburg, PA 17257 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of against personal property of the defendant including but not limited to Company office equipment GARNISHEE(S) as follows: and.to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If pr°perry °f the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$76,652.68 Interest Atty's Comm % Atty Paid $37.50 PlainfiffPaid Date: June 5, 2003 L.L.$.50 Due Prothy $1.00 Other Costs (Seal) REQUESTING PARTY: Name Thomas W. Beaver, Esq. Address: 540 Court Street P.O. Box 542 Reading PA 19603 Attorney for: Plaintiff Telephone: 610-5681417 Supreme Court ID No. 32328 CURTIS R. LONG Prothonotam ,a~la~ I Deputy TRUE COPY FROM RECORD ¥~n~y whereof, I here ur~o set my t~and ~ ~he aeal ol said Court at Carlisle, R. Thomas Kline, Sheriff, who being duly swom according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing 18.00 Poundage 1.47 Advertising Law Library .50 Prothonotary 1.00 Mileage 13.80 Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee TOTAL $ 74.77 Advance Costs: 150.00 Sheriff's Costs: 74.77 $ 75.23 Refunded to Atty on 11/13/03 Sworn and Subscribed to before me This /,~ dayof 2003 A.D....ffl~t~ ~. ~/Prothonotary R. Thomas Kline, Sheriff By Claudia A. Brewbaker PROCESS RECOVERY CORP., : Plaintiff : VS. THE GENERAL CASTING, CO., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYUVANIA CIVIL ACTION - AT LAW NO. 03-2512 PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please mark the Judgment entered in the above captioned matter satisfied. Date: Thomas W. Beaver, Esquire. Attorney for Plaintiff Attorney ID# 32328 Forry, Ullman, Ullman & Forry, P.C. 540 Court Street Reading, PA 19603 Phone No. 610-568-1417 S:\W~ PDATA~-IML\CL1ENTSXPROCESS RECOVERY CORP\Certf. of Address.doc File No. 320-169 (ver. 08/14/03.1 ) PROCESS RECOVERY CORP., Plaintiff VS. THE GENERAL CASTING, CO., : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - AT LAW NO. 03-25][2 CERTIFICATE ADDRESS I, Thomas W. Beaver, Esquire, hereby certify that the following are the last known addresses of the parties to this matter or their respective attorneys. Dated: Michele Smolin, Esquire McDonald Hopkins Co., L.P.A. Attorneys for Defendant 2100 Bank One Center 600 Superior Avenue, E Cleveland, OH 44114 Thomas W. Beaver, Esquire Forry Ullman Ullman & Forry, P. C. Attorneys for Plaintiff Attorney ID# 32328 Forty, Ullman, Ullman & Forry, P.C. 540 Court Street, P.O. Box 542 Reading, PA 19603 /~l'homas~W~f, P.C. / Attorney for Plaintiff / AttomeyID# 32328 ~ Forry, Ullman, Ullman & Forty, P.C. 540 Court Street, P.O. Box 542 Reading, PA 19603 Phone: (610) 568-1417