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Home My WebLink About06-7054355 ASSOCIATES, Plaintiff V. RUPP & MEIKLE, P.C. Defendant :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA CONFESSED JUDGMENT NO. ?.. [ V 6 C C.?C. PRAECIPE TO ENTER FINAL JUDGMENT TO: The Prothonotary of Cumberland County Kindly enter judgment entered by confession in the Dauphin County Court of Common Pleas in the amount of $32,586.64, plus post judgment interest and costs of suit, plus reasonable attorneys' fees to the extent they exceed 10% of all amounts owed under the lease. The original exemplified record of the docket entries and judgment is attached . Respectfully submitted, LAW OFFICES OF MARKIAN R. SLOBODIAN Markian R. SlEsq. ID #41075 Andrew R. Eisemann, Esq. ID #87441 801 North Second Street Harrisburg, PA 17102 717/232-5180 Counsel for 355 Associates Dated: m o? In The Court of Common Vleaz of Maupbin Countp, Vennzplbania 355 Associates VS. No. 2006-NT-4726- Rupp & Meikle ,OF 355 N 21st St. Suite 201 Cramp Hill, PA 17011 CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT I, the undersigned Prothonotary of the Court of common Pleas of Dauphin County, Pennsylvania, do hereby certify that the attached is a full, true and correct copy of the docket entries in the above captioned case. I further certify that judgment was entered in favor of Plaintiff, 355 Associates and against Defendants, Rupp & Meikle on October 13, 2006 in said case in the amount of $32,586.64 In Teotimonp I fjereof, I have hereunto set my hand and affixed the seal of t e &urt, on Monday, December 04, 2006. '*-k") e.. f JUDGMENT $32586.64 Interest from $ Commission Attorney Due $3.00 Plaintiff Paid $33.00 Defendant Paid $ Prothy. Due $10.00 This record $20.00 Date: 1.211/20,96 Time: 02:13 PM Page 1 of 2 F i led: 10/13/2006 Dauphin County User: JMAURER Complete Case History Case: 2006-NT-4726- 355 Associates vs. Rupp & Meikle Physical File: Y Appealed: N Comment: Status History Pending Judge History Date Judge 10/13/2006 No Judge, Payments Markian R Slobodian Exemplified Record Markian R. Slobodian Miscellaneous Receipts Receipt Date 120214 12/1/2006 Plaintiff Name: 355 Associates Address: Phone: Home: Employer: Litigant Type: Comment: Attorneys Slobodian, Markian R. Defendant Name: Rupp & Meikle Address: Phone: Home: Employer: Litigant Type: Comment: 10/13/2006 Reason for Removal Current Receipt Date Type Amount 120214 12/1/2006 Miscellaneous 20.00 20.00 116701 10/13/2006 Civil Filing 33.00 Total 53.00 Exemplified Record 20.00 Sum: 20.00 Work: (Primary attorney) Work: Register of Actions 10/13/2006 New Civil Case Filed This Date. Filing: Complaint with Confession of Judgment Paid by: Markian R. Slobodian Receipt number: 0116701 Dated: 10/13/2006 Amount: $33.00 (Check) SSN: DOB: Sex: Send notices: Y Send Notices SSN: DOB: Sex: Send notices: Y No Judge, No Judge, Date:ll2/1/2Q06 Dauphin County Time: 02:13 PM Complete Case History Page 2 of 2 Case: 2006-NT-4726- 355 Associates vs. Rupp & Meikle Register of Act ions 10/13/2006 On Complaint filed Judgment in No Judge, favor of Plaintiff and against Defendant in the sum of Thirty-two thousand Five Hundred Eighty-six and 64/100 Dollars ($32,586.64 by virtue of authority contained in the Warrant of Attorney filed dated 4/27/99 payable installments with interest, costs, etc. --- for colt'n. Inquisition and Exemption Waived. Entered At 1:59 p.m. Stephen E. Farina, Prothonotary Plaintiff: 355 Associates Attorney of No Judge, Record: Markian R. Slobodian 10/19/2006 Certificate of service of the Notice under No Judge, Rule 2958.1 of Judgment and Execution, was served upon defendants, filed 10/27/2006 Complaint with Confession of Judgment No Judge, and Notice: Sheriffs Return filed stating service was completed. So answers J.R. Lotwick, Sheriff. 355 Associates Assigned to Dauphin Co Sheriffs Office Service fee $46.00 Served 10/27/2006 Judgment Order date In Favor Of Disposition Judgment 10/13/2006 Plaintiff 10/13/2006 Open Judgment Comment: 32586.64 Plaintiff: 355 Associates Defendant: Rupp & Meikle I hereby certify that the foregoin is true 0$ correct copy( of the on al User: JMAURER Prothonotary/Clerk-of C V (Q V F r? r C? _ c? v. 355 ASSOCIATES, :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. CONFESSED JUDGMENT RUPP & MEIKLE, P.C. Defendant :NO. RULE 236 NOTICE OF ENTRY OF JUDGMENT NOTICE OF DEBTOR'S RIGHTS TO: Rupp & Meikle, P.C., Defendant You are hereby notified that on the # day of December 2006, judgment No. 2006-NT-4726, Dauphin County Court of Common Pleas, was entered against you in Cumberland County in the sum of Thirty-Two Thousand Five Hundred Eighty-Six Dollars and 64/100 ($32,586.64) as follows: a. Unpaid rent due for November 1, 2005 - July 27, 2006 $ 27,594.63 b. Monthly rent for parking for November 1, 2005 - July 27, 2006 $ 532.26 c. Late charges for November 2005 - July 2006 $ 1,437.33 d. HVAC repairs $ 60.00 e. Attorney's fees (in the amount of 10% of all money owed) $ 2,962.42 TOTAL AMOUNT DUE $ 32,586.64* *Plus interest from date of judgment until Defendant's obligation is satisfied, plus costs of suit, plus reasonable attorney's fees to the extent they exceed 10% of all amounts owed under the Lease. DATE: Proth otary YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 I hereby certify that the name and address of the proper person to receive this Notice under Pa. R. Civ. 236 is: Rupp & Meikle, P.C. 355 North 21St Street, Suite 201 Camp Hill, PA 17011 Respectfully submitted, THE LAW OFFI o ARKIAN R. SLOBODIAN Markian R. 1 odian, Esq. ID #41075 Andrew R. Eisemann ID #87441 801 North Second Street Harrisburg, PA 17102 717/232-5180 2 ti 355 ASSOCIATES, v. RUPP & MEIKLE, P.C. :IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 06-7054 :CIVIL TERM Defendant :AMOUNT DUE $23,862.69 PLUS INTEREST FROM, : MAY 1, 2007, ATTORNEYS' FEES & COSTS FROM : FEBRUARY 1, 2007, PLUS COURT COSTS PRAECIPE FOR WRIT OF EXECUTION UPON A CONFESSED TUDGMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Issue a Writ of Execution Upon a Judgment Entered by Confession in the above Matter, (1) Directed to the Sheriff of Cumberland County, Pennsylvania, (2) against Rupp & Meikle, P.C., Defendant; and (3) against M & T Bank, Garnishee; (4) and index this Writ (a) against Rupp & Meikle, Defendant; (b) against M & T Bank, Garnishee; and (c)as a lis pendens against the personal property of the Defendant as follows: Proceed to levy upon any and all personal property of the Defendant located at: 355 North 219` Street, Suite 201, Camp Hill, PA 17011 and upon any accounts or other assets of the Defendant located at M & T Bank, 1002 North Seventh Street, Harrisburg, PA 17102, including but not limited to account number 73230340. (5) Amount due to Plaintiff: a Confessed judgment amount: b. Additional actual attorneys fees through 1/31/07: c. Additional interest at 6% through 4/30/07: d. Actual court costs (Sheriffs' service fees $146.00 & court filing fee $73.00): e. Payment received, post-judgment: TOTAL AMOUNT DUE $ 32,586.64 -? .'1:tL.f? 46 $ 122.08 $ 915.11 -x- 9:6@ 'it- $ (9,980.24) $ 23,862.69* *Plus interest from date of judgment until Defendant's obligation is satisfied, plus costs of suit, plus reasonable attorney's fees to the extent they exceed 10% of all amounts owed under the Lease. I certify that (a) This praecipe is based upon a judgment entered by confession, and (b) Notice was served by certified mail at least thirty (30) days prior to the filing of this Praecipe as evidenced by a certiciate of service filed of record on October 17, 2006. THE LAW OFFICES OF MARKIAN R. SLOBODIAN DATED: S+7107 By: - -AA-, MARKIAN R. SLOBODIAN, ESQ. I.D. No. 41075 801 North Second St. Harrisburg, PA 17102 (717) 232-5180 Attorneys for Plaintiff z u 44 .,4 A.a 0 C -JAL V j? C C C ?i A w '1 w -?" f i i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due 355 ASSOCIATES, Plaintiff (s) From RUPP & MEIKLE, P.C., 355 NORTH 21sT STREET, SUITE 201, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell ANY AND ALL PERSONAL PROPERTY OF THE DEFENDANT LOCATED AT 355 NORTH 211T STREET, 201, CAMP HILL, PA 17011. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of ANY ACCOUNTS OR OTHER ASSETS OF THE DEFENDANT LOCATED AT M & T BANK, 1002 NORTH SEVENTH STREET, HARRISBURG, PA 17102. INCLUDING BUT NOT LIMITED TO ACCOUNT NUMBER 73230340. 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 $22,606.40 Interest AT 6% THROUGH 4/30/07 - $915.11 Atty's Comm % Atty Paid $93.00 1/31/07 - $122.08 Plaintiff Paid Date: MAY 14, 2007 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs ATTORNEY'S FEES THROUGH A,& C s . Long, P ota) By: N006-7054 Civil CIVIL ACTION - LAW Deputy REQUESTING PARTY: Name MARKIAN R. SLOBODIAN, ESQUIRE Address: 801 NORTH SECOND ST. HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-232-5180 Supreme Court ID No. 41075 SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-07054 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND 355 ASSOCIATES VS RUPP & MEIKLE P C And now CPL. RICHARD SMITH ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0011:20 Hours, on the 30th day of May , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , RUPP & MEIKLE P C hands, possession, or control of the within named Garnishee M & T BANK 1 WEST HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to JESSICA REESE (CUSTOMER SVC) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge in the true and made So answers: .00 .00 .00 R. Thomas Kline .00 Sheriff of Cumberland County .00 00 ? 4 06/04/2007 Sworn and Subscribed to before me this day of By A.D ! 3 5 ? `l Y I '? 1 ?'• 1 ?? I ... _ ?, n ..o 4?0 ^f rA A '? nK1 Pc 7 A N Sw ti R "f'o INTERROGATORIES 1. Identify all real property currently owned jointly or individually by you, the address of each said real property, and the names and addresses of all persons having an ownership interest in the real property. ANSWER: UY,krowgr., _ 2. Identify all motor vehicles including, but not limited to, cars, trucks, trailers, motorcycles, wo?k vehicles, recreational vehicles, etc., currently owned by you jointly or individually,44 location, description, and financial encumbrance of each vehicle, and, if applicable, the names and addresses of any joint owners. ANSWER: U'A 1<' n&W'r, 3. Identify all accounts at any banks or savings institutions including, but not limited to, any checking, savings and miscellaneous accounts, currently possessed or controlled by you, jointly or individually, and identify the name and address of each bank 3 or institution, the type of account, the amount of balance in each and, if applicable, the names and addresses of the joint owners, and their interest in the accounts. ANSWER: U V% k W"Y' 4. Identify all stocks, bonds, certificates of deposit, notes, or any other securities currently owned by you, jointly or individually, and identify the nature of the security, its current value, the location of the security and, if applicable, the names and addresses of all joint owners. ANSWER: U xvk ah 5. Identify all personal property owned by you, jointly or individually, including all items of personal property in the possession, custody or control of you and others. ANSWER: ? V?kV?crwh 4 6. For each item identified above, identify the nature and location of the personal property, its value, and the names and addresses of all persons having an interest in the property. ANSWER: 7. Identify all persons currently liable to you (a) on any negotiable or other written instrument; (b) on advances due under any agreement, either written or oral; or (c) on monies due as income from any trust. For each of the above, state the amount owed or claimed to be owed, the name and address of the individual(s) or entity liable to you, and the nature of the liability. ANSWER: 8. Identify all persons who you claim to owe you any money or who are liable to you for any reason. Identify (a) amount owed or claimed to be owed, (b) name and address of the individual(s) or entity liable to you, and (c) nature of the liability. ANSWER: 5 9. Identify all real and personal property transferred by you by sale, gift, exchange, or otherwise within the four (4) years preceding the date of these Interrogatories. For each such transfer, please give a description of the property transferred, the manner of transfer, the name of the person or other entity to whom the property was transferred, the consideration received by you and the time and place of the transfer. ANSWER: U 10. Identify any agreements involving the purchase of any real estate anywhere in the United States to which you are a party. For each such agreement, state the full name and address of each party to the agreement. ANSWER: 0 -VV- t" 11. State whether or not the Defendant maintains any safety deposit box or boxes. If so, include the name of the institution, branch or branches, and the identification number or other designation of the box or boxes. Include a full description of the contents and also 6 the amount of cash among those contents. If the Defendant maintains any of these jointly with any other person or entity, identify all such other persons or entities. ANSWER: vr).r,l, trwh 12. Identify all other assets not mentioned in your Answers to the Interrogatories above that you own or that are in your possession, custody or control, including all properties in which you hold legal or equitable title, either jointly or individually, and identify the nature of the asset, its location, its approximate value and, if applicable, the names and addresses of any joint owners. ANSWER: U-t' %C' 13. Identify all mortgages, judgments, liens, or secured transactions recorded against you or any property currently owned by you and identify the nature and date of the 7 . a ' recording, the amount of the interest, the property against which the interest is filed and the names and addresses of the persons holding the interest. ANSWER: iS kY"k, 14. Identify any accounts receivable or work-in-progress which were collected by you or are in the process of being collected by any person other than the Defendant or its employees. For each such asset, identify the person collecting or responsible for collecting the asset and describe the disposition of any collected funds. ANSWER: LAW OFFICES OF MARKIAN R. SLOBODIAN -'? -t--1- MARKIAN R. SLOBODIAN Attorney I.D. No. 41075 801 North Second Street Harrisburg, PA 17102 (717) 232-5180 Attorneys for Plaintiff Dated: -7 b-X(67 8 W/ ss; -- - rYgQr (I? apv.Pnre- A he-'gre 1ne Q Mo'tn?r_? 1? 6?, ?'„Y Satom} octih ,r Rae- HCrberf a- T H ? 1 '??YY C ? Y l C- OY're O 'gr e 1 wr;y WCtl 6h ? r i G-j r r" y ? 7 • .a. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Advance Costs: 226.95 Sheriff s Costs: 226.95 Docketing 18.00 000.00 Poundage 4.45 Advertising 20.00 Law Library .50 Prothonotary 2.00 Refunded to Atty on 10/07/08 Mileage 48.00 Surcharge 40.00 Levy 40.00 Certified Mail Post Pone Sale 45.00 Garnishee Postage TOTAL $ 226.95 101-091h So Answers; c? R. T 9mas Kline, She ff o 'c By Cl udia A. Brewbaker UFFI'T S .? cJ S(7- l NPl OR, ? ? 5 ` d? ??SLL2 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N006-7054 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due 355 ASSOCIATES, Plaintiff (s) From RUPP & MEIKLE, P.C., 355 NORTH 21sT STREET, SUITE 201, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell ANY AND ALL PERSONAL PROPERTY OF THE DEFENDANT LOCATED AT 355 NORTH 21sT STREET, 201, CAMP HILL, PA 17011. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of ANY ACCOUNTS OR OTHER ASSETS OF THE DEFENDANT LOCATED AT M & T BANK, 1002 NORTH SEVENTH STREET, HARRISBURG, PA 17102. INCLUDING BUT NOT LIMITED TO ACCOUNT NUMBER 73230340. 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 $22,606.40 Interest AT 6% THROUGH 4/30/07 - $915.11 Atty's Comm % Arty Paid $93.00 1/31/07 - $122.08 Plaintiff Paid Date: MAY 14, 2007 L.L. $.50 Due Prothy $2.00 Other Costs ATTORNEY'S FEES THROUGH dog Curti . Long, Pr o iwk (Seal) By: Deputy REQUESTING PARTY: Name MARKIAN R. SLOBODIAN, ESQUIRE Address: 801 NORTH SECOND ST. HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-232-5180 Supreme Court ID No. 41075