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HomeMy WebLinkAbout07-2911f ~ i ` ROBERT M. REIBSTEIN, ESQUIRE 705 Montgomery Avenue Narberth, PA 19072 (610) 664-1999 Attorney I.D. No. 20456 ANJ INCORPORATED as assignee of Chase Manhattan Bank c/o Robert M. Reibstein, Esquire 705 Montgomery Avenue Narberth, PA 19072 vs. JONATHAN CAMIS 1397 Creek Road, Apt. D Boiling Springs, PA 17001 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.~7 -o2Ql~ ~iu~~~~1L.y ATTORNEY I.D. NO. 20456 CIVII., ACTION PRAECIPE TO TRANSFER JUDGMENT TO THE PROTHONOTARY Please kindly enter judgment upon the District Court 09-3-OS judgment in favor of Plaintiff and against the Defendant in the above captioned case in the amount of $4591.58 plus court Costs. ~,~~~'' ROBERT M. REIBSTEIN Attorney for Plaintiff . EOMMONWEALTH OF PENNSYLVANIA COUNTY OF: CIIl~BE~tr',ttan Mag. Dist. No.: 09-3-05 MDJ Name: Hon. ffiARS 11IA~1:TIN Address: 507 N YORE ST 11tEC8ANICSBDRG, PA Telephone: (717 > 766-4575 17055 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF' NAME and ADDRESS rANJ INCORP/ASSIGNEE CHSE MANBTTN B~ 705 MONT AV, P08527 C/O ROBERT ~L REIBSTEIN ~NARBERTB, PA 19072 J VS. DEFENDANT: NAME and ADDRESS rCA1LI S , JONATHAN ~ 1397 CRE88 ROAD APT/ST8 D BOILING SPRINGS, PA 17001 ANJ INCORP/ASSIGNEE 088E MANBTTN BR L J 705 MONT AV, P0B527 Docket No.: CV-0000031-07 C/O ROBERT ![ REIBSTEIN Date Filed: 1/30/07 NAR88RT8, PA 19 0 7 2 - ~" ~ ~ THIS IS TO NOTIFY YOU THAT: Judgment: DEFADLT JIIDGI~NT PLTF (Date of Judgment) 3/02/07 Judgment was entered for: (Name) ANJ INCORP/ASSIGNEE CHSE 1[ANHT ® Judgment was entered against: (Name) CAIIIIS, JONATHAN in the amount of $ 4, 591.5 Defendants are jointly and severally liable. Damages will be assessed on Date & Time This case dismissed without prejudice. Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease Amount of Judgment $ 4, 467.58 Judgment Costs $ 124.00 Interest on Judgment $ Attorney Fees $ . 00 Total $ 4, 591.58 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ 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 OF JUDGMENTlTRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEASAND NO FURTHER-PROCESS MAY BE.ISSUED BY THE MAGISTERIAL DISTRICT JUDGE . UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTFifRWISE COMPLIES WITH THE JUDGMENT. " ~~~"~~~~ ~ Date ~/lti ~ ,Magisterial District Judge .,~ .. , .. 1 certify that this is a true and corre cop f the record of the proceedings containing the judgment. •.--- 2 Date ,Magisterial District Judge My commission expires first Monday of January, 2012 SEAL AOPC 315-06 DATE PRINTED: 3/02/07 10:17:00 AIL ~ ~ ~ fit., ^- _~ V i' 1 ~ ~ T C7 'LJ~r r,,~: f. fili l' ~~. .~` r"- Y r~ 0 _~ ~. c..~ .~y~p. ~,~~ -r-~ ~~ ~:: .,,!~ L ~ Y ~' .~ ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND MDJ Name: Hon. ~~ W • MARTIN BARCLAY BUILDING Address: 507 NORTH YORK STREET MECHANICSBURG, PA Telephone: ( 717) 766-4575 17055 CIVIL COMPLAINT PLaI"~"~TJ INCORPiEas assignee of ~ Chase Manhattan Bank ~ c/o Robert M. Reibstein~Esquire 705 Montgomery Ave., P. O. Box 527 Narberth, PA 18072 ~' VS. ~ DEFENDANT: NAME and ADDRESS ~ JONATHAN CAMIS ~ 1397 Creek Road, Apt. D Boiling Springs, PA 17001 I_ -~ Docket No.: CV-31-07 Date Filed: 1 / 30 / 07 AMOUNT DATE PAID _ -- __ FILING COSTS $ 117.50 1 / 30 / 07 POSTAGE $ 6.50 1 130 /07 SERVICE COSTS $ / / CONSTABLE ED. $ / / TOTAL $ / / Pa.R.C.P.D.J. No. 206 sets forth those costs recoverable by the prevailing party. TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for $ 4467.58 together with costs upon the following claim (Civil fines must Include citation of the statute or ordinance violated): On or about 7/1/02 Defendant requested and accepted a bank credit card from Chase Manhattan Bank account #5183377600243646 with the terms of a Card Member Agreement. 'Thereafter, Defendant made various charges as evidenced on monthly statements whereby as of 8/12/04 there remained a principal balance due and owing Chase Manhattan Bank in the sum of $3826.87. On or about 6/24/05, for value received, Chase Manhattan Bank sold ail of its right, title and interest in said credit card account to Plaintiff. As per the Card Member Agreement, Defendant is liable for continuing finance charges at the rate of $0.73 per day thereafter (7% annual percentage rate) in the sum of $640.71 whereby as of 1/2/07 there remains a principal balance due and owing Plaintiff in the sum of $4467.58. WHEREFORE, Plaintiff demands judgment against the Defendant in the sum of $4467.58 plus interest from the date of the filing of this complaint and record costs. I, ROBERT M. REIBSTEIN, ESQUIRE verify that the facts set forth in this complaint are true and correct to the best of my knowl~e, information, and belief. This statement !s made subject to the penalties of Section 4904 of the Crimes Code (18 PA. C.S. § 4904) related to unsworn falsification to authorities. ~ ~r~y.{>~ (Signature of r Authorized Agent) Plaintiffs Attorney: ROBERT M. REIBSTEIN, ESQUIRE Address: 705 Montgomery Avenue Telephone: (610) 664-1999 Narberth, PA 19072 IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD SO NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO, JUDGMENT MAY BE ENTERED AGAINST YOU BY DEFAULT. If you have a claim against the plaintiff which is within magisterial district judge jurisdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office at least five (5) days before the date set for the hearing. If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. AOPC 308A-05 f ~ ROBERT M. REIBSTEIN, ESQUIRE 705 MONTGOMERY AVENUE NARBERTH, PA 19072 (610) 664-1999 ATTORNEY LD. NO. 20456 ANJ INCORPORATED as assignee of Chase Manhattan Bank c/o Robert M. Reibstein, Esquire 705 Montgomery Avenue Narberth, PA 19072 vs. JONATHAN CAMIS 1397 Creek Road, Apt. D Boiling Springs, PA 17001 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. ATTORNEY LD. NO. 20456 CIVIL ACTION CERTIFICATION OF ADDRESSES TO THE PROTHONOTARY: This is to certify that the address of the Defendant is 1397 Creek Road, Apt. D, Boiling Springs„ Pennsylvania 17001; and the Plaintiffs address is c/o Robert M. Reibstein, Esquire, 705 Montgomery Avenue, Narberth, Pennsylvania 19072. ~/ ROBERT M. REIBSTEIN Attorney for Plaintiff n C :° "`' ---~ .~, -r: _~,-r ;'- - _ ~. __ 'c+ - ~-,:y _- c.~ _~,;, ;,~ az:' R ~. (Rule of Civil Procedure No. 236) ANJ INCORPORATED as assignee of Chase Manhattan Bank c/o Robert M. Reibstein, Esquire 705 Montgomery Avenue Narberth, PA 19072 vs. JONATHAN CAMIS 1397 Creek Road, Apt. D Boiling Springs, PA 17001 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PEN/N~A.]~' NO. U7 - .~9~~ ~tc.~~C.~ / ~t/• ATTORNEY LD. NO. 20456 CIVII., ACTION Notice is given that a judgment in the above captioned matter has been entered against Defendant on s 2007, in accordance with provision of Pa. R.C.P. 236. PROTHONOTARY ~- If you have any questions concerning the above captioned case, please contact: ROBERT M. REIBSTEIN, ESQUIRE 705 Montgomery Avenue Narberth, PA 19072 (610) 664-1999 Attorney I.D. No. 20456 r- ~` PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 Etc. ANJ INCORPORATED as assignee of IN THE COURT OF COMMON PLEAS OF Chase Manhattan Bank _________ CUMBERLAND COUNTY, PENNSYLVANIA c/o Robert M. Reibsten, Esquire 705 Montgomery Avenue Writ No. ____________________________ Term, t9______ Narberth;-~2k-- }902----=_----`---°--`-'"--- No. ____07-2911 Civil_Term Term, 19____-- ~a. JONATHAN CAMIS ------------------------------------------- 1397 Creek Road, Apt. D Boiling Springs, PA 17001 Amonnt due ____________ $ _ 4591 _58________ Interest from ___ 5j 1507____________________ Att'y's Com. _ Costs ____..__. To the Prothonotary of said Court: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, CUMBERLAND (1) Directed to the Sheriff of ________________________County, Penna.; (2) against _JONATHAN_CAMIS,_ levy__on all_personal_property__ lo~ated__at____ 1397 Creek Road, APt. D., Boiling Springs, PA__-17001_______ Defendant (s) ; (3) and against ------------------------------------------------------------------------ Garnis]ice (s) (4) and index this writ (a) aga'~'t --------------------------- _____ 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 : (•5pecifically describe property) (5) Exemption has (not) been waived. Dated __ 6~8~~~____--____-- Attorney for Plaintiff (s) ROBERT M. REIBSTEIN, ESQUIRE X620456 NOTE Under paragraph (1) when the writ is directed to the sheriff of another county as aubhorized by Rule 3103(b;, the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgement may be directed only to the sheriff of the county in which issued. Paragraph (3) above should be completed only if a named garnishee is to be included in the writ, Paragraph (4) (a) should be completed only if index ing of ~e execution in the county of issuance, is desired as suithorized by Rule 3104(a), W1iea the writ issues to another county indexing is required as of course in that ~ousLty by the prothonotary. See Rule 3104(~b), Paragraph (4) (b) should be completed only if real property in the name of a garnishee is attached and index- ing as a lis pendens is desired. See Rule 3104(c). ~ ~ ~ ~ ~~ ~ ~ c ~ yh' ~'' a V ~,M` f 7 f ~[ ~~ ~ ~~ ~ ~ ~ ~ G~ ~' 't ~ ''' d ~i {~ ; ~°ro o .. l "~ ~ ~. ~ '`~ ~ ~ ~~ ~ tL cl~ ~~ 1-a 1 ~„d ~ 7d ~ ~ ' :~ ~ ~ ~ t7~ 9 ~ ~ r ~ P' O ; O O ~ Csi Cs1 , ~ _"~ ~ '~, ~ C 1~ ~' N ~ Czl , w o ri~ , ~ ~ ~ b, ~~ v ~~ ... ~ ~, ~' ~ W RJ r'r1 .C ~ C.7 ~ C? ~ ~, -~ ~, ~, - ~~- . -, ~, w ~ / ~ i ~ y , O ~~ ~, ~ d ,~ +TS ~ ~, ~ to , N , , , -~ H , qd d rJ' Ci , `~ O tit N ry ~~ i p ~ ~ ~ y ~ '~ ~ '~ ro ~, C O+ t~ ~ % ~~ ~ i ~ ~ G fi ~, ,..+ ti3 ~ ~~ ~t d ~ ~i lTl i too '~. Z ~ '", .-~ c b .? ~ i , t rt , .tom ~i' , (7 ~,y ~ , ~ ~ r.~ l.J ~ C.... ~ , , ~ ~y. of . ~ ~ , ~ , , ~ , O , ~~ , ,~ ' , , , WRIT OF EXECUTION andlor ATTACHMENT x" `1. COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-2911 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ANJ INCORPORATED AS ASSIGNEE OF CHASE MANHATTAN BANK C/O ROBERT M. REIBSTEIN, ESQUIRE, Plaintiff (s) From JONATHAN CAMIS,1397 CREEK ROAD, APT. D, BOILING SPRINGS, PA 17001 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL PERSONAL PROPERTY LOCATED AT 1397 CREEK ROAD, APT. D., BOILING SPRINGS, PA 17001 . (2) You are also duected to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4591.58 Interest FROM 5115107 Atty's Comm Atty Paid $53.75 Plaintiff Paid Date: JUNE 11, 2007 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs liepury REQUESTING PARTY: Name ROBERT M. REIBSTEIN, ESQUIRE Address: 705 MONTGOMERY AVENUE NARBERTH, PA 19072 Attorney for: PLAINTIFF Telephone: 610-664-1999 Supreme Court ID No. 20456 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per Pennsylvania Rules of Court 3206 Property Claim. Sheriff s Costs: Advance Costs: 150.00 Sheriff's Costs: 67.59 Docketing 18.00 $ 82.41 Poundage 1.33 Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 07/20/07 Mileage 5.76 Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee Postage TOTAL $ 67.59 ~ ~~~(e ? So Answers; o ~ .~~ o T omas Kli Sheriff w R~~~-u ~~~~~.~p~a, By Claudia A. Brewbaker ~ aL ~~ ~ ~ ~ ~~~~~~ ~e~z ~s _ _ i ) !i L~ ~ f ;?! l~ ~ ~ ~ ~~ , ;,~ ; L_ _'T `~ r , ~ ~~ V ~ ~ ~ ~ qsa~ l~i.~ iy69?z' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-2911 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ANJ INCORPORATED AS ASSIGNEE OF CHASE MANHATTAN BANK C/O ROBERT M. REIBSTEIN, ESQUIRE, Plaintiff (s) From JONATHAN CAMIS, 1397 CREEK ROAD, APT. D, BOILING SPRING5, PA 17001 (1) You are duected to levy upon the property of the defendant (s)and to sell LEVY ON ALL PERSONAL PROPERTY LOCATED AT 1397 CREEK ROAD, APT. D., BOILING SPRINGS, PA 17001 . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4591.58 L.L. $.50 Interest FROM 5/15/07 Atty's Comm % Due Prothy $2.00 Atty Paid $53.75 Other Costs Plaintiff Paid Date: JUNE 11, 2007 R. Long, Prothonotary (Seal) Deputy REQUESTING PARTY: Name ROBERT M. REIBSTEIN, ESQUIRE Address: 705 MONTGOMERY AVENUE NARBERTH, PA 19072 Attorney for: PLAINTIFF Telephone: 610-664-1999 Supreme Court ID No. 20456 ., Real Estate Sergeant R. THOMAS KLINE Sheriff EDWARD L.SCHORPP Solicitor Dear Sir, 07/13/07 ANJ Incorporated, et. al. Vs Jonathan Camis Writ No. 2007-2911 Civil Property Claim Determine RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Sergeant N .~ ~ n ~ -~ ~, ~ (':, }r x~.. " >: ~ ,l ~ ~~~ -`; 4 w ~ ~.:. ~ ~~ "i7 ~_ r, :~ :..~ •. N ~ t.,) -< Reference is made to Property Claim dated July 3, 2007, entered by Crystal Meck, pertaining to Writ of Execution No. 2007-2911 Civil Term, ANJ Incorporated, et. al. -vs- Jonathan Camis. R. Thomas Kline, Sheriff, has determined that the claimant, Crystal Meck, in the above mentioned property claim, is the owner of the property set forth therein. ~~ Robert Reibstein, Atty for Pltff Jonathan Camis, Defendant Crystal Meck, Claimant o~~t~ of ~un~~Pr~~ ~ ~d OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 So Answer .~~ Thomas R. Kline, Sheriff n ti By `~ - ~,~ ~~,i~ ~~ ~ ~ ~ a - r ~C~S1V~`fl ~~~ ~~ ~ In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. ~,~~~ ` TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: OF PROPERTY ('~ VALUE ~'~ ~WC1 C1. ©c~~~n LTC \\` "' ~~`~ ~ ~~ ^- ^~ ~ a5 swan ~ ~ ti ~~ ~~ ^~ ~ roe ~ c ~~~U6-,~,`l ^~ ~ ~ o ~~k4 n ~ ~ l~ " ~a4~h '(~ rn~1i.: ~n (` ~~ : n ~ ~, ~,t~ l'~~ ~ rte`.\~~.. ~, S THE CLAIMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS: ~~~~ ~.~ ~- ~~j~ ~, o.M 0. c>a~c~Q MdsUc~ll u. s~ csko.~~c~o., off, . ~ q`6°! a1L c^c1v, o,.~(a orb.,. - - o ~ ~xi o oasv.v n Sm cn o r/~lu ,v v 1 v w Date `~- I h~ ~~- State. of Penn~ylyama: County of Cumberland above list in the property claim are correct and true. being duly sworn according to law, deposes and says that the crib to before m ti% of Claimant ~cnaa BREwaa~, NOTARYPUBUC Carlisle Bore, Cwnberiand ~~ My Commission Eriaires qp~ 4, 2009 PROPERT~CLAIM ~o~-a85is a- "`~~j ~ r e Vey _,~ "' jr^~ `-..' ~~1-~J~ ~..J'_~1 l.~ ~:J ~~ ;1 `.' ~, ,.w, wrta, ~" «~ f' b. ' ... ..