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Home My WebLink About07-4675~~ / COMMONWEALTH OFPENNSYLVANIA ,, COURT OF COMMON PLEAS Judicial District, County Of NOTICE OF APPEAL FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS No. 0'1" yl(o r15' C iV~ ~ ~~- NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District Judge on the date and in the case referenced below. NAME OF APPELLANT MAG. DIST NO. NAME OF MDJ Hudson &Keyse, LLC 09-3-03 Susan K. Day ADDRESS OF APPELLANT CITY STATE ZIP CODE C/o Ronald Amato, Esquire, 107 North Commerce Way, Bethlehem PA 18017 DATE OF JUDGMENT IN THE CASE OF (Plaintiff) (Defendant) 7/12/07 Hudson &Keyse, LLC vs. Cindy Tubbs DOCKET No. SIGNATURE OF APPELLAry3 ORY VH AIiEN I CV-160-07 ~ ~'~ RnnalcfyAmato. Attornev for Appellant This block will be signed ONLY when this notation is required under Pa. If appel/ent was Claimant (see Pa. R.C.P.D. J. No. (001(6) in action R.C.P.D. J. No. 10086. This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COMPLAINT MUST BE FILED operate as a SUPERSEDERS to the judgment for possession in this case. within twenty (20) days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.D.J. No. 1001(7) in action before Magisterial District Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon Name of appellees) appellee(s), to file a complaint in this appeal (Common Pleas No. )within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or attorney or agent RULE: To appellees) Name of appellees) OWNER (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date 20 Signature of Prothonotary or Deputy YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTlTRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-05 COURT FILE TO BE FILED WITH PROTHONOTARY -~ ~ , ,~ ~~~ _'~~~ rr~,~f c~~ ~~rv~cF ~J~`~~'. '~" ~dt~'l~ t~"f7"~+C; ~"'N ~10,~ ~7AY,~ A~'"F!~ fi"Iirt~~ t~~ r~~~~r.;°~ :,~ ~~~,~~ ~~. ,'~~.a~ r~~~~~1i~~~~ ~ .;~~~>,i c { -.. -`~., ~~- x. ~~, :: -_ ~ 4 3 ~~ i-" G ~, G,- ~ ~ :~_ "' +.! ~ r - __ _ t ~- ._ a~ 3z. _i 'ri _. _._~ _.._ ~ - _Q_ .. :~ ~~.. G I'! ~11~ NWEALTH OF PENNSYLVANIA NOTICE OF JUDGMENT/IRA C` ~,O ~ CIVIL CASE COUNTY pF: CII~re>Rr.s>~an ~~ ~ ~~ '~Mag. Dist. No.: PLAINTIFF: NAME and ADDRESS 09=3-03 ~EIIDSON Sc SSYSS, LLC MDJName: Hon. 107 ~. C01®I[SRCE SPAY APT/STS 100 SIISAN R. DAY C/O ANATO S~ ASSOCIATSS Address: 229 ![ILL ST, BOa 167 LBBTHLSHSlI[, PA 18017 J l[T. HOLLY SPRINGS, PA VS. DEFENDANT: NAME and ADDRESs Telephone: (717) .;486-7672 17065 rTIIBBS, CINDY ~ 49 GARDSN P~PY CARLISLE, PA 17013 L J HIIDSON S~ SEYS$, LLC 107 N. CO!®I~RCS SPAY APT/STS 100 Docket No.: Cv-0000160-07 C/O ANATO Sie ASSOCIATES Date Filed: 5/02/07 BSTHLEHE~, PA 18017 ~ ~~ THIS IS TO NOTIFY YOU THAT: FOR DSFS1itDAPT 7 / 12/ 0 7 ---..~ : _._Judgment: _ _ .. _ ._ .: : _::___ .:,_-__. ... _. ~__ _ _. __ _- _ ._(1?_ate _of Judgments ®Judgment was entered for: (Name) TIIBBS, CINDY ® Judgment was entered against: (Name) HIIDSON ~ EEYSS, LLC in the amount of $ ' 0 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 $ . 00 Judgment Costs $ . 00 ~8 Interest on Judgment $ Attorney Fees $ .00 Total $ .00 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Totat $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OFAPPEAL 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 ~UR~'F~ PROCESS'MAY BE IS$UEDBY THE'MAGIS`I'ERiAL-1315`r'F~I`CT'7UDTaE"" ""~''`" UNLESS THE JUDGMENT IS ENTERED IN THE COURT`OF~COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE- A REQUEST FOR ENTRYOF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. SEAL AOPC 315-06 DATB PRINTED: ..7/12/07 9:58:00 Ali[ A ~ ~ ~" n (`- N ~ ' ~ ~ 'LJ t,i.' .`,~ ~°' ~7 y,, ` ~ (~ ~ • ~-r 1- -~ ~~ " ~ ~ ~1 . ~ ~ ~ 1j f7 S D iT A Q~ ~..C - """fCj 6~ ~ D A~ o ~rn ~ ~ D cn .~ w'' 4 .~ww«w,,..wau~wwwm,e~~.,~o ~wiax~ww,a.~w.~~~ ~ ,~~.~.„Ww..,,,~wwa~~ ~on~.MZ~.r~ w. ~..r,a~,,~~ uoro~~d~«~au «w~, ~nw .- ~,.u,urew«um~~,~~~wa~ry.~rww~u~nww~,,,arro.,.~~w~wvwu~e,~wW.~«~u~w,n~w~:~~,~ ~ i~ i; Iii"/,4 ~w.d' i ~ q f i ~ d Y d }nR'~ t ^~ "Y 'f ~ - ~~+ ~u~^~=~~,„< il~~,.,a, ~M' ~ ~~,..~.~~~ ~'~~~~a~',11~~} .~.~.~~~ ~~~P~I~ ~..~~~~~' b.~ .~~~'"f?"~"~ ~~t~'7,~ qr s~+ ~gj~•,.~ _..~ ~ +~.~~.k ~°'r ~oa N~~ X 07-4675 07-4675 Cindy Tubbs ~. R-14-07 3 ~~ v NOTARIAL SEAL QEOFFREY D SCHOENECK Noury Publlo tiANOVER TOWNSHIP, NORTHAMPTQtI Cl17Y My Commtsston Expires Mer 29, 2008 4Y1~~c,lu1L O~SYYw~-, ~~ S~ 7~~00-7 ~' COMMONWEALTH OF•PENNSYLVANIA r COURT OF COIVJMON PLEAS NOTICE OF APPEAL ~~ Judicial District, County Of FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS No. ~ - t f fp q5 C I V i ~ Tenn NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District Judge on the date and in the case referenced below. NAME OF APPELLANT Hudson ~ )~eyse, LLC ADDRESS OF APPELLANT C/o I~aluald Ameto, MAG. DlST. NO._ NAME OF MDJ a9-3-03 Susan K. Day Esquire, 107 North Cotm~erce Wary, Bethlehem STATE ZIP CODE PA 18017 nv i n~ ur~x ~r tnainon) (Defendant) 7/12/07 Hudson & Keyae, I,1.C vs. Cindy Tubby DOCKET No. CV-160-07 This block will be signed ONLY when this notation is required under Pa. R.C.P.D. J. No. 10088. This Notice of Appeal, when received by the Magisterial District Judge, will operate as a SUPERSEDERS to the judgment for possession in this case. was before a Magisterial District Judge, A COMPLAINT MUST BE FILED within twenty (20) days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.D.J. No. 1001(7) in action before Magisterial District Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon Name o/appellee(s) appellee(s), to file a complaint in this appeal {Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or attorney or agent RULE: To appellees) Name of appellees) OWNER (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date 20 Signature of Prothonotary or Deputy YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. ~. Postage I $ Certi1ed Fee Return Receipt Fee jEndotsemeM Required) Restricted Delivery Fee (Endorsement Required) Total Postage & F sera To Street Apt. No.; or PO Box No. City, State, Zip+4 ~~~ ~~` 1 ~. HONORABLE JUDGE SUSAN DAY MAG. DIST. CT. 09-3-03 229 MILL STREET, BOX 167 MT. HOLLY SPRINGS, PA 17065 8114!2007 4:33 PM S A ~ Certified Fee • - - ~ Hei Return Receipt Fee (Endorsement Requiter!) ~ 7 Q Vj <Q", Restricted Delivery Fee ~/ 3l _ \~''~ (Endorsement Required) Total Postage & Fees Q` sent To CINDY TUBES street, Apr. No.; 47 GARDEN PARKWAY or Po sox No. CARLISLE, PA 17013 City, State, zip+~t 8/14/2007 4:33 PM O O N Gl 0 U O O N ui 0 U ' ~~.~ ~~ w': t'~ ~' ( C",^y i ) (. C:: , ~' .~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN~ ~ p CNIL ACTION -LAW ~~ "'' -'~' ~F ,- ~. ~ v> :~iT HUDSON & KEYSE, LLC - n~ ~~="'' a ~ ° r c-, Plaintiff No. 07-4675 - --, _ -~-' ~F: <-, - - _ = rn ~~• .. -, CINDY TUBBS Defendant CNIL ACTION NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 1F YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMATO AND ASSOCIATES, P.C. By: Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM ' COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA r CIVIL ACTION -LAW HUDSON & KEYSE, LLC Plaintiff No. 07-4675 vs. . CINDY TUBBS CIVIL ACTION Defendant COMPLAINT The above Plaintiff brings this action against the above Defendant to recover the sum of $7,324.00, with interest thereon as hereinafter stated, upon the following cause of action: 1. Plaintiff, HUDSON & KEYSE, LLC, is a Delaware limited liability company located at 382 Blackbrook Road, Painesville, OH 44077. 2. Defendant, CINDY TUBBS, is an adult individual located at 47 Gazden Parkway, Cazlisle, PA 17013. 3. At the special instance and request of Defendant, Household Company, LLC, issued to Defendant a personal loan. A true and correct statement of Defendant's account is attached hereto, made a part hereof and marked Exhibit "A". 4. For value received, Household Company, LLC assigned, transferred and set over to Plaintiff all its rights, title and interest in this claim. 5. By virtue of said assignment, Plaintiffacquired legal title to said account, and became the legal holder of the claim against Defendant. 6. Defendant has not adhered to the agreed repayment obligations that govern the aforesaid personal loan, by reason of which Defendant is in default thereof. 7. A total amount which became due as a result of the aforesaid default, after allowance for all proper credits for payments and/or adjustments, if any, was $4,644.30. Plaintiff is entitled to receive interest on the above amount determined by applying the agreed interest rate of 18.00%per annum to the past due balance. As of August 15, 2007 the total amount of interest due to Plaintiff is $2,679.70. 9. Plaintiff is entitled to have the 18.00% interest charge continue to accrue as set forth above, from August 15, 2007 on down to the date of judgment in this matter. 10. Plaintiff has made demand against Defendant for the aforesaid sum, but Defendant failed or refused to pay the same or any part thereof. WHEREFORE, Plaintiff demands judgment against Defendant for $7,324.00 together with the continually accruing interest charge at the agreed rate of 18.00% per annum from August 15, 2007, costs of suit and all other relief to which Plaintiff may be entitled. COUNT II Alternative to Count I -Unjust Enrichment 11. Plaintiff incorporates the allegations of every paragraph enumerated above of this Complaint as if said paragraphs were fully set forth here at length. 12. The goods, wares, merchandise and/or services, described in the exhibits attached hereto were purchased by Defendant, and Defendant received and accepted the benefit of such goods, wares, merchandise and/or services provided by Plaintiff. 13. At all times material hereto, Defendant was aware that Plaintiff was providing the aforesaid goods, wares, merchandise and/or services to Defendant, and that Plaintiffexpected to be paid for such. 14. At all times material hereto, Defendant, with the aforesaid knowledge, permitted i~ Plaintiff to provide and/or deliver said goods, wares, merchandise and/or services, and to incur damages. 15. At all times material hereto, Defendant was unjustly enriched by retaining the benefit of receiving said goods, wares, merchandise and/or services without paying Plaintiff fair and reasonable compensation. 16. By reason of the aforesaid unjust enrichment of Defendant at Plaintiff s expense, an implied contract exists between Plaintiff and Defendant, and Defendant is obligated to pay Plaintiff the quantum meruit value of the goods, wares, merchandise,and/or services described in the exhibits attached hereto, in the amount of $4,644.30. WHEREFORE, Plaintiff demands judgment against Defendant for $4,644.30 together with the continually accruing interest charge at the statutory rate of 6.00% per annum from August 15, 2007, costs of suit and all other relief to which Plaintiff may be entitled. AMATO AND ASSOCIATES, P.C. By: Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM gun. 26. 2007 ~:;3Pi'U AMATO AND ASSOCIATES FC No, 444 F. 3 ~' VERIFICATION Nancy A. Quere Account Mans>a<er of hereby states that he/she is the ~tid=On ~ KQyN' L.I»G. ,Plaintiff in this action, and verifies that the statements made in the attached Complaint are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements herein are made subject to the penalties of 18 PA C.S. §4904 relating to unsworn falsification to authorities. i~~~ ~ t~~~~w~, dr~~ .a-..I..I ~~~~ ;~ sroa~~Il 440.354.6978 Phone ~~,'~~ ~~~~ ~~ 440.354.1336 Fax • ~ ~~~~ ~ 382 Blackbrook Road 800.654.5391 Toll Free Painesville, Ohio 44077 www.hkllc.biz r ~ -- STATEMENT OF ACCOUNT CREDITOR NAME: Hudson & Keyse, L.L.C. CREDITOR ADDRESS: 382 Blackbrook Road, Painesville, Ohio, 44077 ORIGINAL CREDITOR: BENEFICIAL COMPANY LLC ORIGINAL ACCOUNT NUMBER: 71171400507472 HUDSON & KEYSE, L.L.C. ACCOUNT NUMBER: 456342*1 DEBTOR NAME: CINDY J. TIIBBS DEBTOR ADDRESS: 47 GARDEN PARKWAY, CARLISLE, PA, 17013 DATE ACCOUNT OPENED: MAY 26 2000 DATE LAST PAID TO ORIGINAL CREDITOR: 02 JUN 2003 DATE LAST PAID TO HUDSON & KEYSE, L.L.C.: PRINCIPAL BALANCE DUE: $4,644.30 INTEREST BALANCE DUE: $2,022.37 TOTAL BALANCE DUE: $6,666.67 INTEREST RATE: 18.00 LAST DATE INTEREST CHARGED: OCT 31 2006 I-ITTP: WWW.HKLLC.BIZ LOCAL: (440}354-6978 FAX: (440)354-1336 •- • ~•~ •• ••~ EMAII.: COLLECTIONS@HKINC.COM TOLL FREE: 1(800)654-5391 & 1(800)654-1660 PAY YOUR ACCOUNT ON-LINE VIA CHECK, DEBIT OR CREDIT CARD AT.' WWW.HKI,LC.BIZ PLEASE SEND CORRESPONDENCE TO:POST OFFICE BOX 1090, MENTOR, OH, 44061 ~, ~~ ~ , v~ t t ~ ~ =tti .-tJ '''~~i`t ='" '--~~ . -- ~;>~~: ..~ 1 w COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW HUDSON & KEYSE, LLC Plaintiff No. 07-4675 vs. CINDY TUBBS : CIVIL ACTION Defendant(s) CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of Plaintiff's Complaint was served via first class mail, postage prepaid on August 28, 2007: Cindy Tubbs 47 Garden Parkway Carlisle PA 17013 AMATO AND ASSOCIATES, P.C. By: Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM n rya C7 -ra ~,~-;, .- ~ } ,. ~ ~~ ~~ _ ' . ,l t.~ ~ .~ -~ ~ ~ " ~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW HUDSON & KEYSE, LLC Plaintiff No. 07-4675 vs. CINDY TUBBS , CIVIL ACTION Defendant PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: Kindly enter judgment by default for want of an answer in favor of Plaintiff and against the above-named defendant(s) only and assess damages as follows: Debt S 7, 324.00 Interest (from 8/15/07 to 9!28/07 at 18% per annum) 164.79 Payments 0.00 Total $ 7,488.79 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. Pursuant to RCP 237.1, I certify that a copy of the annexed written notice(s) of intention to file this praecipe was mailed or delivered to all parties against whom judgment is to be entered and to their attorney of record, if any, after the default occurred, and at least ten days prior to the date of filing of this praecipe. Please note that said notice was mailed to all parties on September 18, 2007. Dated: 2007 AMATO AN.~i~~OCI ES, P.C. BY~ Ronald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM 2064007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW HUDSON & KEYSE, LLC Plaintiff No. 07-4675 vs. . CINDY TUBBS . CIVIL ACTON Defendant CERTIFICATION OF ADDRESSES I do certify that the precise last known address of the within named plaintiff is: 382 Blackbrook Road Painesville OH 44077 I do certify that the precise last known address of the within named defendant is: 47 Garden Parkway Carlisle PA 17013 AMATO AND AS OCIAT , P.C. By: onald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW HUDSON & KEYSE, LLC Plaintiff No. 07-4675 vs. CINDY TUBBS Defendant(s) CIVIL ACTION AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHAMPTON The undersigned, being duly sworn, according to law, deposes and says that the above Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of The Servicemembers Civil Relief Act of 2003; That Cindy Tubbs is over 18 years of age, resides at 47 Garden Parkway, Carlisle PA 17013 and is employed; Sworn to and subscribed before me this "' day of (7~ 2007 A. NOTAR PUBLIC NOTARIAL SEAL GEOFFREY G SCHOENECK Notary Public HANOVER TOWNSHIP, NORTHAMPTON CNTY My Commission Expires Mar 29, 2008 ~~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW HUDSON & KEYSE, LLC Plaintiff No. 07-4675 vs. CINDY TUBBS Defendant(s) T0: Cindy Tubbs 47 Garden Parkway Carlisle PA 17013 Date of Notice: September 18, 2007 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMATO AND ASSOCIA ES, P.C. By: ,- Ronald Amato, ., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Attorney File# 2064007 r--- ~~_~ -•7~ ~ :~ -ri * ~ ~ ~ ' T~ ~ ~- .Q J ~7 ~ ~ ~ ~ -' ~ ~ -~ ~ l"> ~ a =c _ ,~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW HUDSON & KEYSE, LLC Plaintiff No. 07-4675 vs. CINDY TUBBS CIVIL ACTION Defendant NOTICE OF JUDGMENT (XX- NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST THE ABOVE-NAMED DEFENDANT(s) IN THE AMOUNT OF 57,488.79 ON pCT ~{ , 2007. ( 1 A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN JUDGMENT IS/ARE ENCLOSED. PROTHONOTARY -CUMBERLAND COUNTY If you have any questions concerning the above, please contact the undersigned. AMATO AND OC ES, P.C. By: onald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty ID #72412 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM IN THE COURT OF COMMON PLE\AL ACT ON BLAW ND COUNTY, PENNSYLVANIA CI HUDSON & KEYSE, LLC Plaintiff No. 07-4675 vs. CINDY TUBBS , ~F'1 F~rden ~~~`~ ~ttsle . Pa I'7at3 Defendant(s) . PRAECIPE FOR WRIT . EXECUTION (MONEY JUDGMENT) To the Prothonotary -Cumberland County: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of CUMBERLAND County, for debt, interest and costs upon the following described property of the defendant(s) All cash on hand or in the aossession of the defendants accounts receivables furniture furnishin s e ui ment inventor tools vehicles electronic a ui ment an and all other ersonal ro ert belon in to the above- named defendant(s). (2) against CINDY TUBBS, Defendant(s) ..................................Garnishee(s) (3) and against...... (41 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 the property) (5) Amount Due 5 7'488'79 Statutory Interest g 220.95 From October 4, 2007 Less Payment S 0.00 Costs $ Poundage $ Total S 7,709.74 AMATO AND ASSOCIATES, P.C. By: Date:March 26. 2008 Ronald Amato Attorney I.D. No. 32323 Attorney File#: 2064007 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAL ACT ON BLAW ND COUNTY, PENNSYLVANIA CIVI HUDSON & KEYSE, LLC Plaintiff No. 07-4675 vs. ' CINDY TUBBS ; CIVIL ACTION Defendant(s) CERTIFICATION OF DEFENDANT(s) ADDRESS FOR SERVICE I do certify that the precise last known address of the within named defendant(s) is the address provided below, and request that the Sheriff serve the above named defendant(s) at: 47 Garden Parkway Carlisle PA 17013 AMATO AND ASSOCIATES, P.C. By: Dated:March 26. 2008 _ Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff Attorney File #:2064007 n -6~. _ R' -~ ~ ~ r-~ na ~ p,, 1 r-- .~ .. ~ ~ V, ~ ~ ~ O O ~ V ~ ~T.n .--P - ~ ' ~~ ~ ~ ~ ~ r ~ _ ~ ~ d r; - C.7 -~{ ~ D ~^,, •. ~. 0 WRIT OF EXECUTION and/or ATTACHMENT NO 07-4675 Civil COMMONWEALTH OF PENNSYLVANIA) CIVIL ACTION -LAW COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HUDSON & KEYSE, LLC, Plaintiff (s) From CINDY TUBBS, 47 Garden Parkway, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell all cash on hand or in the possession of the defendant, accounts receivables, furniture, furnishings, equipment, inventory, tools, vehicles, electronic equipment, any and all other personal property belonging to the above named defendant . (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 of the defendant paying any debt to or for the account of the defendant (s) and from delivering any property (s) or otherwise disposing thereof; (3) If property of the defendant h elev~eu re duectedboenotifytthim/her tthat he/she has been added as a of anyone other than a named g ~ Y garnishee and is enjoined as above stated. L.L. $.50 Amount Due $7,488.79 Interest -statutory interest from 10/04/07 - $220.95 Atty's Comm % Due Prothy $2.00 Other Costs Atty Paid $118.75 Plaintiff Paid Date: 4/03/08 (Seal) REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: AMATO AND ASSOCIATES, P.C. 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone: 610-866-0400 Supreme Court ID No. 32323 Curti .Long, o By: Deputy R, ~~~~e, Sheriff, who being duly sworn according to law, stakes this eturned STAYED, DUE TO BANKRUPTCY. Sheriff s Costs: Advance Costs: 150.00 Sheriff's Costs 97.41 Docketing $ 18.00 52.59 Poundage 1.91 Advertising 10.00 Law Library .50 Prothonotary 2.00 Refunded to Atty on 07/28/08 Milage 10.00 Surcharge 20.00 Levy 20.00 Post Pone Sale 15.00 Garnishee Postage TOTAL $ 97.41 ~~ 1301 ~ P ~ So Answer ; ~ ~.~~~ R. Thomas Klink, Sheriff By II ~ ~~ ~~J~~ ~;:, z, h Z ~6 d S - ~Jdti 8801 ~~ ~~ ~~ ~ ~ ~-4sbs~ ~ air ~Gr G J WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4675 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HUDSON & KEYSE, LLC, Plaintiff (s) From CINDY TUBBS, 47 Garden Parkway, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell all cash on hand or in the possession of the defendant, accounts receivables, furniture, furnishings, equipment, inventory, tools, vehicles, electronic equipment, any and all other personal property belonging to the above named defendant . (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 $7,488.79 L.L. $.50 Interest -statutory interest from 10/04/07 -- $220.95 Atty's Comm % Due Prothy $2.00 Atty Paid $118.75 Plaintiff Paid Other Costs Date: 4/03/08 (Seal) REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: AMATO AND ASSOCIATES, P.C. 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone: 610-866-0400 Supreme Court ID No. 32323 Curtis R. Long, Pro By: Deputy