HomeMy WebLinkAbout07-4007
ROBERT M. REIBSTEIN, ESQUIRE
705 Montgomery Avenue
Narberth, PA 19072
(610) 664-1999
Attorney LD. No. 20456
CACV OF COLORADO, LLC
c/o Robert M. Reibstein, Esquire
705 Montgomery Avenue
Narberth, PA 19072
4
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA.
NO. ~7 ~-'SIC-b~ ~LC~~~~F%
ATTORNEY LD. NO. 20456
VS.
BRENT A. SAII..HAMER
525 S. Hanover Street
Carlisle, PA 1701.3
CIVIL ACTION
PRAECIPE TO TRANSFER JUDGMENT
TO THE PROTHONOTARY
Please kindly enter judgment upon the District Court 09-2-02 judgment in favor of
Plaintiff and against the Defendant in the above captioned case in the amount of $5041.48 plus
court casts.
ROBERT M. REIBSTEIN
Attorney for Plaintiff
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' COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CD~~T•,~
Mag. Dist. No.:
09-2-02
MDJ Name: Hon.
JESSICA BRS[1BA]IER
Address: 1 CODRTHOIISB '-.SQ -$ iilIl'<G". ,.
CARLISL$, PA
Telephone: (717) 240-654' 1T013
C/O ROBERT ~. REIBSTEIIfI, 8SQ
7 0 5 )s[O~iTQO)lLERY AV8
P.O. BOZ 527
NARBBRTH, PA 19072
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAI~iTIFF
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF' NAME and ADDRESS
rCACV OF COLORADO, LLC ~
7 0 5 l[O~iT60ItSB.Y AVE
P.O. BOZ 527
y:, ~xAUBS>~Ta, PA 19072. J
VS.
DEFEND/~NT: NAMEand ADDRESS
rSAIL>BA>~. 88ffiQT _A ~
52s s. anaovax sr.
CARLISLE, PA I7013
L J
Docket No.: CV-0000141-07 _
Date Filed: 4/02/07
~~ .
(Date of Judgment)
® Judgment was entered for: (Name) ~~ OF COLORADO, LLC
5/03/07
® Judgment was entered against: (Name) SAIT•A,~4, BRB>IIT A
in the amount of ~ 5, 041.4
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, 915.48
Judgment Costs $
Interest on Judgment $
Attorney Fees $ _ 00
Total $ 5, 041.48
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 JUDGMENT/TRANSCRIPT 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 PLEAS AND 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 OTHERWISE COMPLIES WITH THE JUDGMENT.
~~ ~ ~ / Date
rial District J
I certify that this is a tru an rrect copy of the ecord of the proceedings containing the judgment.
b Date CQ.. ,Magisterial District-Judge
My commission expires first Monday of January, 2012 SEAL
AOPC 315-06
DATl! PRIN'P~: 6/25/07 8:42:00 Alt
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COMMONWEALTH OF PENNSYLVAf~IA
COUNTY OF: CUMBERLAND
2-02
m1~ Naroe: Flon. JESSICA E . BREWBAKER
CUMBERLAND COUNTY COURTHOUSE
Address: ONE COURTHOUS QUAKE, EAST WING
CARLISLE, PA
Telephone: (717) 240-6564 17013
AMOUNT DATE PAiD
FILING COSTS $ ~ ~
POSTAGE $ ~ ~-
SERVICE COSTS $ ~ ~
CONSTABLE ED. $ ~ ~
TOTAL $ ~ 00 ~ . ~ O
CtVtL OC)t~tF~LAIfVT
PLAINTIFF: NAPAE and ADDRESS
~ CACV OF COLORADO LLC ~
c/o Robert. M. Reibstevl esquire
705 Montggomery Ave.,. ~'. 0. Box 527
~_ NarberCti, FA 13072
VS . -~
DEFENDANT: NAME and ADDRESS
BRENT A. SAILHAIViER -1
525 S. Hanover Street
Carlisle, ;PA 17013
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Docket No.: ~ tI' L„i -~' 7
Date'iled: ~ - ~ ' O `~
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; 5 • together with costs
upon the following claim (Civil fines must include citation of the statute or ordinance violated):
On or about 2/26/04 Defendant requested and accepted a bank credit card from Maryland National Bank, account
#4264299451686430 with the terms of a Card Member Agreement. Thereafter, Defendant made various charges as
evidenced on monthly statements whereby as of 11/9104 there remained a balance due and owing Maryland National Bank
in the sum of $319721. On or about 11/I6/04 for value received, Maryland National Bank sold all 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 through 3/15/07 at the rate of $1.26 per day thereafter ('.11.99% annual perct,'ntage rate) in the sum of
$1078.83 and its reasonable attorney fees of 25% of the principal balance in the sum of $639.44 whereby there remains a
principal balance due Plaintiff in the sum of $4915.48. WI-~EF:EFORE, Plaintiff demands judgment against the Defendant
in the sum of $4915.48 plus continuing interest from the date of the filing of this complaint. and record costs.
1, ROBERT M. REIBSTEIN, ESQUIRE verify that the facts set forth in this complaint are true and correct to the
best of my knowledge, information, and belief. Thls statement is made subject to tl~e penalties of Section 4904 of the Crimes
Gode {18 PA. G, S. § 49Q4) related to unsvtirorn falsifications to ar;tisorities. ,G
(Signature of r Authorized Agent)
Plaintiff s
Attorney: ROBERT M. REIBSTEIN, ESQUIRE Address: 705 Montgomery Avenue
Telephone: (610) 664-1999 Narberth, F'A 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 NiEARING 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
ROBERT M. REIBSTEIN, ESQUIRE
705 MONTGOMERY AVENUE
NARBERTH, PA 19072
(610)664-1999
ATTORNEY LD. NO. 20456
CACV OF COLORADO, LLC
c/o Robert M. Reibstein, Esquire
705 Montgomery Avenue
Narberth, PA 19072
VS.
BRENT A. SAILHAMER
525 S. Hanover Street
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PE(N-N~A-'.
NO. D'1' ' 't{biG ? e t v i,t~. l 1r2~
ATTORNEY LD. NO. 20456
CIVIL, ACTION
CERTIFICATION OF ADDRESSES
TO THE PROTHONOTARY:
This is to certify that the address of the Defendant is 525 S. Hanover Street, Carlisle,
Pennsylvania 17013; and the PlaintifFs address is c/o Robert M. Reibstein, Esquire, 705
Montgomery Avenue, Narberth, Pennsylvania 19072.
C,
ROBERT M. REIBSTEIN
Attorney for Plaintiff
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(Rule of Civil Procedure No. 236)
CACV OF COLORADO, LLC
c/o Robert M. Reibstein, Esquire
705 Montgomery Avenue
Narberth, PA 19072
VS.
BRENT A. SAILHAMER
525 S. Hanover Street
Carlisle, PA 17413
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
No. 07 - ~lbG'~ ~ u~C,~~
AT`T'ORNEY LD. NO. 20456
CIVIL ACTION
Notice is given that a judgment in the above captioned matter has been entered against
Defendant on ~~. , 2007, in accordance with provision of Pa. R.C.P. 236.
OTHONOTARY L--
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
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS)
P.R.C.P. 3101 to 3149 Etc.
IN THE COURT OF COMMON PLEAS OF
CACV OF COL_ ORADO, LLC __________________ CUMBERLAND COUNTY, PENNSYLVANIA
c/o Robert M. Reibstein, Esquire
705 Montgomery Avenue Writ No. ____________________________ Term, j9______
Narbe~t'lI; -PA---i~f?32'-'--'--------------- Na, ___ 07-4007_ CIVIL_ TERM_ Term, Is______
~• Amount due ------____-- S _5041 .48 ---_----
BRENT A. SAILHAMER 7/2/07
------------------------------------------- Interest from ----------------------------------
525 S. Hanover Street
Carlisle, PA 17013 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 __-_BRENT A. SAILHAMER_ -_ Levy on_ all_personal _pro~erty_ belong-ing
to Defendant located at 525 S. Hanover Street
---------------------------------------- Carlisle,- PA---1701 ------ Defendant (s) ;
(3) and against ------------------------------------------------------------------------ Garnishee (s) ;
(4) and index this writ
(a) against --------------------------------- --------------------------------------------------
------------------------------------------------------------------- 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 : (•Specifically
describe property)
(5) Exemption has (not) been waived.
Dated ----- 8/ 1 /07 ---------
Attorney for Plaintiff(s)
ROBERT M. REIBSTEIN, ESQUIRE 420456
NOTE
Under paragraph (1) when the writ is directed to the sheriff of another county as authorized by Rule 3103(b;,
the county should be indicated.
Under Rule &103(c) a writ issued on a transferred judgement may be directed only to the sheriff of the county
is 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 the execution in the county of issuance, is desired as
authorized by Rule 3104(a). When the writ issues to another county indexing is required as of course in that
~oumty 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).
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-4007 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CACV OF COLORADO, LLC, C/O ROBERT M.
REIBSTEIN, ESQUIRE, Plaintiff (s)
From BRENT A. SAILHAMER, 525 S. HANOVER STREET, CARLISLE, PA 17013
(1) You are directed to lery upon the property of the defendant (s)and to sell LEVY ON ALL
PERSONAL PROPERTY BELONGING TO DEFENDANT LOCATED AT 525 S. HANOVER
ST., CARLISLE, PA 17013 .
(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 gamishee(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 $5041.48
Interest FROM 7/2/07
Atty's Comm
Atty Paid $53.75
Plaintiff Paid
Date: AUGUST 3, 2007
(Seal)
REQUESTING PARTY:
Name ROBERT M. REIBSTEIN, ESQUIRE
Address: 705 MONTGOMERY AVENUE
NARBETH, PA 19072
Attorney for: PLAINTIFF
Telephone: 610-664-1999
Supreme Court ID No. 20456
L.L. $.50
Due Prothy $2.00
Other Costs
Lcj~u~y
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-4007 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CACV OF COLORADO, LLC, C/O ROBERT M.
REIBSTEIN, ESQUIRE, Plaintiff (s)
From BRENT A. SAILHAMER, 525 S. HANOVER STREET, CARLISLE, PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL
PERSONAL PROPERTY BELONGING TO DEFENDANT LOCATED AT 525 S. HANOVER
ST., CARLISLE, PA 17013 .
(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 duected to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $5041.48
Interest FROM 7/2/07
Atty's Comm
Atty Paid $53.75
Plaintiff Paid
Date: AUGUST 3, 2007
(Seal)
REQUESTING PARTY:
Name ROBERT M. REIBSTEIN, ESQUIRE
Address: 705 MONTGOMERY AVENUE
NARBETH, PA 19072
Attorney for: PLAINTIFF
Telephone: 610-664-1999
Supreme Court ID No. 20456
L.L. $.50
Due Prothy $2.00
Other Costs
a~a.Yu~y
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriffls Costs: Advance Costs: 150.00
Sheriff's Costs 66.61
Docketing 18.00 83.39
Poundage 1.31
Advertising
Law Library .50
Prothonotary 2.00 Refunded to Atty on 04/30/08
Mileage 4.80
Misc.
Surcharge 20.00
Levy 20.00
Post Pone Sale
Certified Mail
Postage
Garnishee
/3~e L~6 F
TOTAL 66.61
So Answers,
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MORRIS & ADELMAN, P.C.
BY: ROBERT M. MORRIS, ESQUIRE
IDENTIFICATION #67896
POB 30477
Philadelphia PA 19103-8477
215/568-5621
CACV of Colorado, LLC
1999 Broadway
Denver, CO 80202
vs.
Brent A. Sailhamer
525 S. Hanover Street
Carlise, PA 17013
ATTORNEY FOR PLAINTIFF
CACV of Colorado, LLC C'3 c v
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n~'-: r*'t ~~
cu
COURT OF COMMON P ~4S
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CUMBERLAND COUNTY
c~
CIVIL DIVISION ~~". s"
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NO. 07-4007
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance for CACV of Colorado, LLC, Plaintiff
in the above-captioned matter.
S ~ &//ADELMAN , P . C .
BY : `--~
ROBE M. MORRIS
orney for Plaintiff
<. ..
MORRIS & ADELMAN, P.C.
BY: ROBERT M. MORRIS, ESQ.
IDENTIFICATION #67896
POB 30477
Philadelphia PA 19103-8477
215/568-5621
CACV of Colorado, LLC
1999 Broadway
Denver, CO 80202
ATTORNEY FOR PLAINTIFF n o
CACV of Colorado, LLC .~~ .°,~
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COURT OF COMMON 3>,, ,
PL~ s~.
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CUMBERLAND COUNTY ~ `'
CIVIL DIVISION ~ ~ ,,,
vs.
Brent A. Sailhamer
57.5 S. Hanover Street
Carlise, PA 17013
NO. 07-4007
ORDER TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Please mark the judgment in the above-entitled case
satisfied upon payment of your costs only.
So Ordered As Above:
BY:
MORRIS ,&~DELMAN, P .
yC 1.1. 1'1VLCiC1.7, 1-"~~U1K~
rneys For Plaintiff
Prothonotary