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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 $5041.48 plus court casts. ROBERT M. REIBSTEIN Attorney for Plaintiff ~ Q ~ ~° s°I'1f' ~'"' ..~~ ~~ i~..~ { ..~) I? N ~~.~it _ _ '. ~ _r jj-V~ ~? ) ) ~ ~. L_. ~ .. _~~ ;..j ,C ~ t ~ ' COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CD~~T•,~ Mag. Dist. No.: 09-2-02 MDJ Name: Hon. JESSICA BRS[1BA]IER Address: 1 CODRTHOIISB '-.SQ -$ 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 ~:---- Z~'~ ~ ~ ~ ~ ~ ~ o f~ ~- ~ ~- _ -NS3 ~_~ ~Y '~ R. y ^ y ~_ w~ ~ w ^ 1~ ~~ 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 -- .J 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 C> N rJ' ~- ` ~ ..,~, -n ~ - t' ~•-~ ~°~-- .~ -,- 1~1~ ir~ n ° s N ~ c"= ` ~^, ~'_) ":7 ~` 7 {, y.~ `.. W *.vi .~ (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). -..1 !" 1 ~ _ , rt ~ ~ O ~ °~ o ~ ~ ~ ~ t A ~ ~ ~ ~ ~"~ . ~ *d !~ ~ i d ~ `~%{ H ~d ~ o ~ ~ ~ ~ ~ ~ o o~ ~ c ' ,..~ ro H ~ O i ~ ~ Cs1 ~ ~ ~, ~ ~ ro Kai 1 ~ ~ l 1 i ~"~1 N+~ i-- 1 ~ ~ W M W 00 O r ~~ ~ ~~ "~ , r' ,~ ~ ' ~ µ ; ~ `~ V ~ i V '„ ~` 9 ~~ ~ ~' r' '7j ~ K~ ~1~ o ~ W ~ ~~ r] ~ W ~~ ~ ~` ~ ,.- , ' w~~ d'' "' ~ ~, i i CC /'+ ' ~ ~ R ~ A Gr ~ +~ 4 ~ 1 ti ~ ~ ~ t , ~ O ~ ~ ~ ~ ~ i ~ 1 ;~ Q,n;9 ;~ UiO~~ i~ ~ ~~,0 ~1~ ~ ~~~ `ice ~ r* ~ r 1b ~ ~~d 9 ~ ti ~w '~ ~;° ;~ ~ ~ i C'' '° iN ~ '~'~ ~ n i N ~ ~ r• ~~ ~; N ; ~ ~~ i ~ ~~ ~ ', t ~ i ~ i ~ ~ i ~~ w i~7 •^ h ~ d V~ V ~ 1 ~ ~ "0 0 d r ~ +~ ~Y y f M ~ j A ~ ~ ~ I, r,7~ ° ~' ~x ',~ z r17 Cn '~ ~ ~, ~~ ~~ r ~ ~ ^ ~ ~ 1 V ~ ~1 N i ~ ~G ~ O ~ ~~ ~~ ~~ x~ ~~ , ~O ~~ ~ 1 ~ `t ~ -'d ~,~. ~' G ro ~] z ~z r cr,, '~ :, ~ ~ ^~ t L 1 ~ ` 1 1 r ~.~ rti' :c;; , ~ ~ , _. T x. i ~~ x fff ' " w am ~~.~ -y JI ~ 4~ j ~-^ _ 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, " R. o s~I e, '~J~'~.r i ~;~(--~ sy _ _.. _ ~-- ~ i.,. o.~l ~l `~~, o~~ ~; ~~ O ~.crv~ ~~ c:~ (, 3 ~o `l r 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 ~ A -'t'1 n~'-: r*'t ~~ cu COURT OF COMMON P ~4S ~ ~ cn CUMBERLAND COUNTY c~ CIVIL DIVISION ~~". s" ~: ~ ~ ~~ 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 .~~ .°,~ ~-~ " v~v ~: ?'t ` to ~~': ~ ~C.= ~ ~ COURT OF COMMON 3>,, , PL~ s~. ~ ~i ~~ 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