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Home My WebLink About99-06634i No. 94-?la3? CiuilTerm VS. Court of Common Pleas Cumb. Co. KRISTIN S. CAMP, ESQUIRE Attorney I.D. #74593 304 North High Street West Chester, Pennsylvania 19380-2688 (610) 436-4400 THE BOROUGH OF WEST CHESTER Plaintiff vs. ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW STREETGARD, INC. :NO. 99- ?IQ4- Defendant PRAECIPE FOR WRIT OF EXECUTION UPON A CONFESSED JUDGMENT TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended, and for real property pursuant to Act 6 of 1974 as amended. ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER TO THE SHERIFF OF CUMBERLAND COUNTY, FOR DEBT, INTEREST AND COSTS, UPON THE FOLLOWING DESCRIBED PROPERTY OF THE DEFENDANT, STREETGARD, INC.: ANY AND ALL PERSONAL PROPERTY LOCATED AT 405 HISER LANE, CARLISLE, PENNSYLVANIA 17103. Index this Writ against STREETGARD, INC., Defendant, in the following amount: Principal Sum $23,000.00 V Interest Monthly from 9/30/97 at 2% $461.92 Attorneys Fees $1,000.00 TOTAL: $24.461.92 BUCKLEY, NAGLE, GENTRY, ORION, McGUIRE & MORRIS ur • Attorneys at Law • west Chester, Pennsylvania 193003600 I certify that (a) This Praecipe is based upon a judgment entered by confession, and (b) Notice has been served pursuant to Rule 2958.1 at least 30 days prior to the filing of the Praecipe as evidenced by the Certificate of Service filed of record. BUCKLEY, NAGLE, GENTRY, BRION, McGUIRE & MORRIS LLP r?. P BY: KRI TIN S. CAMP, Esquire ID No. 74593 Attorneys for Plaintiff 304 North High Street West Chester, PA 19380 (610) 436-4400 -2- BUCKLEY, NAGLE, GENTRY, ORION, ,WGUIRE RMORRIS ur • Attorneys at Lae • West Chester, Pennsylvania 19:11116261111 .:. KRISTIN S. CAMP, ESQUIRE Attorney I.D. #74593 304 North High Street West Chester, Pennsylvania 19380-268B (610) 436-4400 THE BOROUGH OF WEST CHESTER Plaintiff vs. STREETGARD, INC. Defendant ATTORNEY FOR PLAINTIFF :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99- L G3 4- CER71F1 CATE OF SERVICE I hereby certifiy that on September 16, 1999, 1 served by Certified Mail, return receipt requested, a copy of the Notice required under Rule 2958.1 of the Pennsylvania Rules of Civil Procedure. (copy attached). BUCKLEY, NAGLE, GENTRY, BRION, McGUIRE & MORRIS LLP BY: Jx1tatzl d?L GV)1?P KRIST N S. CAMP, Esqure ID No. 74593 Attorneys for Plaintiff 304 North High Street West Chester, PA 19380 (610) 436-4400 BUCKLEY, NAGLE, GENTRY, BRION, A1cGUIRE & NOR IR IS ur • Al lurncyti at Laa • West Chester, Pennsylvania 1931111.261111 KRISTIN S. CAMP, ESQUIRE Attorney I.D. #74593 304 North High Street West Chester, Pennsylvania 19380-2688 (610) 436-4400 THE BOROUGH OF WEST CHESTER Plaintiff vs. STREETGARD, INC. Defendant PENNSYLVANIA ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, :CIVIL ACTION- LAW :NO. 99- NOTICE UNDER RULE 2958.1 OF JUDGMENT AND EXECUTION THEREON To: Streetgard, Inc. A judgment in the amount of $24,461.92 has been entered against you and in favor of the Plaintiff without any prior notice or hearing based on a confessed judgment contained in a written agreement or other paper allegedly signed by you. The sheriff may take your money or other property to pay the judgment at any time after thirty (30) days after the date on which this notice is served on you. You may have legal rights to defeat the judgment or to prevent your money or property from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS. YOU SHOU LID 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. 5 ?naos'I', ocoe¢rv:•v.coaAC.+n.wRVe.?wa+...a.m Sepemlw 14. 1'lfi1R:'R41 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 or 1-800 990-9108 BUCKLEY, NAGLE, GENTRY, BRION, McGUIRE & MORRIS LLP (t? . •Lct/7Y BY: KRISTIN S. CAMP, Esq ire 304 North High Street West Chester, PA 19380 (610) 436-4400 Attorneys for Plaintiff 5 vvVJi FlC[n++e'eoe.'naisYrr'::coJFOeveNa+?a aeaau? mrra M +M?T{'M lu I'Yn4tliN1 riF_LFUrov nRinu Nr-f.l IIRF R %jnRRIG rnr • .ltlnrnrv. at Ln+' • «'?'sl Chest r, Pennselvania 197N0 :6N-M Z 272 850 636 C C a E i u a US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. nn nm o h. u.u . S-Sire c 7C- SreCldNumo r ^ D SJ. c c1» P t Ofhco State. d ZIP C 1. ? X110 Postage $ Certified Fee SPCOal Delivery Fee Restricted Delivery Fee r Return Receipt Showing to ' Where a Date Delivered i Retum Re:vpj&ovrgr,lVb m, Dale. B Addressees Ad4ess TOTAL POStagcB Fees Postmark or Dale DATE 09/14/99 CIVIL COURT kAN:IGEHE'IT SYSTEM PAGE 1 CASE SUMMARY REPORT 99-05294 VEST CHESTER BOROUGH OF THE V. STREETGARD INC CONFESSION OF JUDGMENT CASE INITIATION DATE 06/22/99 03:59 P NOT ACTIVE SINCE 00/00/00 CASE STATUS ACTIVE REOPEN DATE 00/00/00 ARBITRATION DATE ARBITRATION TIME TRIAL READY DATE 00/00/00 06/22/99 03:59 P $24461.92 TRP/TAK PARCEL R: JUDGMENT FOR: VEST CHESTER BOROUGH OF THE JUDGMENT AGAINST: STREETGARD INC PLAINTIFF REST CHESTER BOROUGH OF THE 401 EAST GAY STREET REST CHESTER PA 19380 ATTORNEY: 074593 TEL: 610-436-4400 KRISTIN A CAMP BUCKLEY NAGLE GENTRY BRIOY 6 304 NORTH HIGH STREET REST CHESTER, PA 19380.2688 ATTORNEY: 074593 TEL: 610-436-4400 KRISTIN A CAMP BUCKLEY NAGLE GENTRY BRION B 304 NORTH HIGH STREET REST CHESTER, PA 19380-26BB ATTORNEY: 016883 TEL: 610-436-4400 STEPHEN P. MCGUIRE BUCKLEY, NAGLE ET AL 304 H. HIGH STREET REST CHESTER, PA 19380 VS. DEFENDANT STREETGARD INC 405 RISER LANE CARLISLE PA 17103 ATTORNEY: 016883 TEL: 610.436-4400 STEPHEN P. MCGUIRE BUCKLEY, NAGLE ET AL 304 N. HIGH STREET REST CHESTER, PA 19380 ATTORNEY: 074593 TEL: 610-436-4400 KRISTIN A CAMP BUCKLEY NAGLE GENTRY BRION 304 NORTH HIGH STREET REST CHESTER, PA 19380-2688 DATE DOCKET INFORMATION 06/22/99 JUDGMENT ENTERED IN FAVOR OF REST CHESTER BOROUGH OF THE AGAINST STREETGARD INC IN THE AMOUNT OF $24,461.92 06/22/99 CERTIFICATION-NOTICE SENT 236 06/22/99 06/22/99 06/22/99 THIS JUDGMENT IS HEREBY CERTIFIED IN FAVOR OF The Borough of West Chester and AGAINST Strectgard,Inc. IN THE AMOUNT OF 06/22/99 524,461.92. (-mo I)r ATTEST: t"V Charles W. McLean, Jr. Deputy Prothonotary 06/22/99 September 14, 1999. G DATE 09/14/99 CIVIL COURT MANAG'9W SYSTEM PAGE 2 CASE SUMMARY REPORT rA'LOj? 06/22/99 NOTICE UNDER RULE 2958.1 OF JUDGMENT AND EXECUTION THEREON BY PLTF 06/22/99 COMPLAINT FILED 06/22/99 CERTIFICATION OF ADDRESS 06/22/99 AFFIDAVIT-BUSINESS/COMMERCIAL TRANS PLTF 06/22/99 APPEARANCE OF KRISTIN A CAMP FOR WEST CHESTER BOROUGH OF THE 06/22/99 APPEARANCE OF KRISTIN A CAMP FOR WEST CHESTER BOROUGH OF THE 06/22/99 APPEARANCE OF STEPHEN P. MCGUIRE FOR WEST CHESTER BOROUGH ?F THE 06/22/99 APPEARANCE OF STEPHEN P. MCGUIRE FOR STREETGARD INC 06/22/99 APPEARANCE OF KRISTIN A CAMP FOR STREETGARD INC BUCKLEY, NAGLE, GENTRY, BRION, McGUIRE & MORRIS, LLP BY: KRISTIN S. CAMP ATTORNEY I.D. ##74593 304 NORTH HIGH STREET WEST CHESTER, PA 19380-2688 THE BOROUGH OF WEST CHESTER Plaintiff VS. STREETGARD, INC. Defendant NOTICE UNDER RULE 2958.1 OF JUDGMENT AND EXECUTION THEREON Notice of Defendant's Rights To: Streetgard A judgment in the amount of S24,461.92 has been entered against you and in favor of the Plaintiff without any prior notice or hearing based on a confession of judgment contained in a written agreement or other paper allegedly signed by you. The sheriff may take your money or other property to pay the judgment at any time after thirty (30) days after the date on which this notice is served on you. You may have legal rights to defeat the judgment or to prevent our money or property from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROfvi THE JUDGMENT AND PRESENT IT TO AJUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON t+VHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS. 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. LAWYER REFERRAL SERVICE 15 West Gay Street Post Office Box 3191 West Chester, PA 19380 (610) 429-1500 Stephen P. McGuire. Esquire Kristin S. Camp. Esquire .103 N. High Street West Chester. PA 19380-2688 Attorneys for The Borough of tAfest Chester #1 ?a IN THE COURT OF COMMON PLEAS CHESTER COUNTY, PENNSYLVANIA COMPLAINT FOR CONFESSION OF JUDGMENT CASE NO. 99- C I RD C , ?L 5-/V . F 7 ?rt, I+,)t 11!p'' BUCKLEY, NAGLE, GENTRY, BRION, .MCGUIRE & MORRIS LLP • Attorney, at Um • Wes[ Cheiter, I'emuylvania 19380.26811 BUCKLEY, NAGLE, GENTRY, BRION, McGUIRE & MORRIS, LLP BY: KRISTIN S. CAMP ATTORNEY I.D. #74593 304 NORTH HIGH STREET WEST CHESTER, PA 19380-2688 THE BOROUGH OF WEST CHESTER Plaintiff vs. STREETGARD, INC. IN THE COURT OF COMMON PLEAS CHESTER COUNTY, PENNSYLVANIA COMPLAINT FOR CONFESSION OF JUDGMENT CASE NO. 99- Defendant CONFESSION OF JUDGMENT WHERE ACTION COMMENCED BY COMPLAINT Pursuant to the authority contained in the warrant of attorney, the original or a copy of which is attached to the complaint filed in this action, I appear for the Defendant and confess judgment in favor of the Plaintiff and against Defendant as follows: Principal Sum Interest at 6% Attorneys Fees $23,000.00 S461.92 S1,000.00 Tota I $24,461.92 BUCKLEY, NAGLE, GENTRY, BRION, McGUIRE & MORRIS, LLP Stephen P. McGuire, Esquire By: ' t •C CC?7, Kristit S. Camp, Esqui Attorneys for The Borough of West Chester ItUCKLEI', NAGLE, GENTRY. It RION, .M000IRE & MORRIS ur • Attarneys at Law West Chester, Pennsylvania 173110-2688 'I ?? S 4 \\ .? ? ? ? ? u? =_ .? ? ? •? ?.: ?? „?< ?- ? ? ?? ? ;; ? ? ?, ? ? ?' -?? s ? ? ? ?, -? .. ?. ?., ? ?i _?? ? ? -O ? V TRANSFER OF JUDGMENT