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HomeMy WebLinkAbout07-4736.- ROBERT M. REIBSTEIN, ESQUIRE 705 Montgomery Avenue Narberth, PA 19072 (610} 664-1999 Attorney I.D. No. 20456 CACH, LLC IN THE COURT OF COMMON PLEAS c/o Robert M. Reibstein, Esquire :CUMBERLAND COUNTY, PENNA. 705 Montgomery Avenue Narberth, PA 19072 : NO. 07 - y73(o C; v~ t Tern ATTORNEY LD. NO. 20456 VS. MIRANDA PETROU 1810 Willow Road Carlisle, PA 17013 : CIVII.. ACTION PRAECIPE TO TRANSFER JUDGMENT TO THE PROTHONOTARY Please kindly enter judgment upon the District Court 09-2-01 judgment in favor of Plaintiff and against the Defendant in the above captioned case in the amount of $3487.21 plus court costs. ROBERT M. REIBSTEIN Attorney for Plaintiff r CbMMON1NEALTH OF PENNSYLVANIA COUNTY nF: _ C0ILHERLAriD THIS IS TO NOTIFY YOU THAT: Judgment: FOjt PLAI~iTIFF NOTICE`OF JUDGMENTRRANSCRIPT .CIVIL CASE ..; , PLAINTIFF: NAME and ADDRESS rCACH LLC ~., PO BOZ 527 _ r, 7 0 5 )s[O11iT(~O~LB$X::< AVS ~ <. ~~TARBBRTH, Ply 7.y9 07ta ~ T. s ~ :~ ;,~~; ,, ~' ~,:~~ ~;':, '` VS:. ~' ~ ..may` , ;M z ~ a ~; ~~?EFFND~INT. , , + e; , v NAME and~~DRESS '~ ~ ~ ~ ~ ~~ ~ , ~~'~ `n ## ~18~10=~ ~ILLO ~ ~~ ~,~r~ ~. ~ ~, ,: 11fl~s.xa111D ~; ~ . `~-~ w~ . , ,.~ CABLI$L$; ; ~ PA 17~013~ K ~. . ~-- ~ J Docket No. CV-0000056-07 ~ _ Date Filed: 4/16/07 - _ (Date of Judgm`en't} ': 'S/21/0~7~ Judgment was entered for: (Name) ~~ LLC ® Judgment was entered against: (Name) PBT~FOII, >~IBAIlIDA in the amount of $ 3, 487.2 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 $ 3, 397.21 Judgment Costs $ 0.00 ~I Interest on Judgment $ - Attorney Fees $ . 00 Total $ 3 , 4 87.21 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 JUDGMENTlfRANSCRIPT 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. -b Date ,Magisterial District Judge I certify that this is a true corre t co y of a rec rd a proceedin containing the judgment. vZ "' d ~ _ Date ,Magisterial District Judge n.a My commission expires first Monday of January, x012 AOPC 315-06 DAT$ PLtI]fiTgD : 7/ 2 6/ 0 7 8:03:00 1l-1~ SEAL `~~ N ~O COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CIVIL COMPLAINT MDJ Name: Hen. PAULA P . CORREAL 2260 SPRING ROAD, SUITE 3 Address: CARLISLE, PA T~~a,e: ( 717} 218-5250 17013 AMOUNT DATE PAID FlLING COSTS $ ~i. St7 I I POSTAGE $ g S~ I I SERVICE COSTS $ I / CONSTABLE ED. $ / / TOTAL $ 90 , ~~ ~/ )(p /C'~ PLAINTIFF: NAME and AccRESs I- CACH LLC ~ c/o Robert M. Reibsteu~, Esquire 705 Montgomery Ave., P. O. Box 527 Nar6erth, PA 19072 L_ VS. DEFENDANT; NAME and ADDRESS (- MIRANDA PETROU --~ 1810 Willow Road Carlisle, PA 17013 L_ J Docket No.: ~~' ~JCv ' ~`~ Date Filed: ~ V ~ ~ ~ Q~ ~M Pa.R.C.P.D.J_ No. 20S sets forth those. costs recoverable by the prevailing party TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for S 339 7.21 together with costs upon the following claim (Civil fines must include citation of the statute or ordinance violated): On or about 7/15/03 Defendant requested and accepted a bank credit card from Chase Manhattan Bank, account #5187481550045923 with the terms of a Card Member Agreement. Thereafter, Defendant made various charges as evidenced on monthly statements whereby as of 10/31/OSthere remained a balance du:e and owing Chase Manhattan Bank in the sum of $3397.21. On or about 11!23/05 for value received, Chase Manhattan Bank sold all of its right, title and interest in said credit card account to Plaintiff. WHEREFORE, Plaintiff demands judgment against the Defendant in the sum of $3397.21 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 knowledge, information, and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA. C.S. § 4904) related to unsworn falsification to authorities. Plaintiff's Attorney: ROBERT M. REIBSTEIN, ESQUIRE Telephone: (610) 664-1999 (Signature of r Authorized Agent) Address: 705 Montgomery Avenue 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-OS ROBERT M. REIBSTEIN, ESQUIRE 705 MONTGOMERY AVENUE NARBERTH, PA 19072 (610) 664-1999 ATTORNEY LD. NO. 20456 CACH, LLC IN THE COURT OF COMMON PLEAS c/o Robert M. Reibstein, Esquire :CUMBERLAND COUNTY, PENNA. 705 Montgomery Avenue Narberth, PA 19072 : NO. :ATTORNEY I.D. NO. 20456 VS. l~'1IRANDA PETROU 1810 Willow Road Carlisle, PA 17013 :CIVIL ACTION CERTIFICATION OF ADDRESSES TO THE PROTHONOTARY: This is to certify that the address of the Defendant is 1810 Willow Road, Carlisle, Pennsylvania 17013; and the Plaintiffs address is c% Robert M. Reibstein, Esquire, 705 Montgomery Avenue, Narberth, Pennsylvania 19072. ~'' ~, ~..~. ROBERT M. REIBSTEIN Attorney for Plaintiff Tv ~ ~ ~ t-? rv ~ =~ ~ :~ ~ ~ 1 ~ ~ r „ ~ --r a _ r~. ~ ~ -~ 00 ~ _ - ~ -~ tS"i ~ C.~ ~ i -: ~7 ~,a ~', t ~ ~~ „ ` . ~:~ .~ c~ :;~ :~ = -, -< / OTHONOTARY 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 ri ', (Rule of Civil Procedure No. 236) CACH, LLC c/o Robert M. Reibstein, Esquire 705 Montgomery Avenue Narberth, PA 19072 VS. 1~~IIRANDA PETROU 1810 Willow Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. ATTORNEY 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. PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 Etc. CACH, LLC c/o Robert M. Reibstein, Esquir 705 Montgomery Avenue Nar~~~ttr;- gA---i48-72------------------- vs. MIRANDA PETROU__________________________ 1810 Willow Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Writ No. ____________________________ Term,19___--- 07-4736 Civil Term ]vo. -------------------------------- Tern, 19------ Amount due ------____-- $ _3487.21 ---_---- Interest from ____ 8~9~~~ __________ _ __ Att'y's Com. ----------------------------------- costs----------------$ ------------------------ To the Prothonotary of said Court: ISSUE WRIT OF EXECUTION IN THE ABOVE MA'T'TER, (1) Directed to the Sheriff of __ CUMBERLAND --_---County, Penna.; MIRANDA-PETROU---levy-on all personal property belonging to (2) against -------------- - _ _ Defendant located at 1810 Willow Road __ _____ Carlisle,_ PA__ 17013 __ _____________ 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) Exemplion has (not) been waived. 11/1/07 ' Dated ------------------------ Attorney for Plaintiff(s) • ROBERTppM. REIBSTEIN, ESQUIRE ~~20456 NOTE P~ L7 ~~, "7~5 ~p14`+'Qomer~ Ave, I~rber~-h Under paragraph (1) when the wrist is directed to the sheriff of another county as autihoriz by Hul 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 'Q ~7p~ in which issued. _ 1 Paragraph (3) above should be completed only if a named garnishee is to be included in the writ. ~~p„ ~„ ~Qpq Paragraph (4) (a) should be completed only if indexing of tie execution in the county of issuance, is desired as ,_, / autthorized by Rule 3104(a). When the writ issues to another county indexing is required as of course in that gourLty lry 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). --.+ ~ o ~ _ ~~ fi C'+ '~{ ~ ~ '' Cr! 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WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4736 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CACH, LLC, Plaintiff (s) From MIRANDA PETROU, 1810 Willow Road, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell all personal property belonging to defendant located at 1810 Willow Road, 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 directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $3,487.21 Interest from 8/09/07 Atty's Comm Atty Paid $53.75 Plaintiff Paid Date: 11/05/07 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs C rtis R. Long, Prothonotary By: Deputy REQUESTING PARTY: Name ROBERT M. REIBSTEIN, ESQUIRE Address: PO BOX 527 705 MONTGOMERY AVENUE NARBERTH, PA 19072 Attorney for: PLAINTIFF Telephone: 610-664-1999 Supreme Court ID No. 20456 Rt:-gs ~~ o WRIT OF EXECU'T10N and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANLA) COUNTY OF CUMBERLAND) NO 07-4736 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CACH, LLC, Plaintiff (s) From MIRANDA PETROU, 1810 Willow Road, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell all personal property belonging to defendant located at 1810 Willow Road, 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 directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $3,487.21 L.L. $.50 Interest from 8/09/07 Atty's Comm Atty Paid $53.75 Plaintiff Paid Due Prothy $2.00 Other Costs Date: 11!05107 (Seal) REQUESTING PARTY: Name ROBERT M. REIBSTEIN, ESQUIRE Address: PO BOX 527 705 MONTGOMERY AVENUE NARBERTH, PA 19072 Attorney for: PLAINTIFF Telephone: 610-664-1999 C rtis R. Long, Prothonotary By: Deputy Supreme Court ID No. 20456 ~_ ~= t~ ~ 6' ~ p -i- 0~0 f0 ~ ~ ~' ROBERT M. REIBSTEIN, ESQUIRE ?OS Montgomery Avenue Narberth, PA 19072 (610) 664-1999 Attorney I.D. No. 20456 CACH, LLC IN THE COURT OF COMMON PLEAS c/o Robert M. Reibstein, Esquire :CUMBERLAND COUNTY, PENNA. 705 Montgomery Avenue : Narberth, PA 19072 : NO. 07-4736 CIVII., TERM ATTORNEY LD. NO. 20456 VS. NIIRANDA PETROU ; 1810 Willow Road ; Carlisle, PA 17013 :CIVIL ACTION PRAECIPE TO RELSSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Please kindly Reissue the Writ of Execution in the above case. ~~ti~~. ROBERT M. REIBSTEIN Attorney for Plaintiff C") "'. ~ ~ , ~ C~ - ~ „~ - csa rx i ~ ~ ° ~ ~ O ~ t'ii~ ,,,~ ~ : ~ `Q'T f'f. Sty i ~J =t J C~ ~ ,, r ~ ~ ~ i ~ ~ oe ~ ~ .. ~~ r~ D ~~ .. e ~~ w c.r`s R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing 18.00 Advance Costs: 150.00 Poundage 1.31 Sheriff's Costs: 66.61 Advertising 83.39 Law Library .50 Prothonotary 2.00 Refunded to Atty on 1 /20/09 Milage 4.80 Surcharge 20.00 Levy 20.00 Certified Mail So Aaiswers; Post Pone Sale Garnishee ~~~~ ~~ 0 `' Bad Check Postage ~0 9 / R. Thomas Kline, Sheriff ~~;-, w Q /l ' -~ ~ ~ -c- Total i~ a 66.61 ~ , ,; . , t ~ c° By Claudia A. Brewbaker (--j 1.. N ~~ !°~ C.:'3 -Ti _ ~ ~ Tll T 1 ..~ ~? t r } ~ r 7U lp ~ -;; ~, ~- = C~ ~ (~ ~ _ _~~ ~ ~ ._ -' _, CSi 7 i`J --C A t i ~ ~ -`;~ ~ AA-- 7~-~ ~ T'' ~ - ~ ~.- w ~ ~ a ~-~ ~ ~ ~ ~ ~ 7~ <<t~ 1 ~ ~ ;~ a% a U REI 3S U E b WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-4736 Civil CIV1L ACT10N -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CACH, LLC, Plaintiff (s) From MIRANDA PETROU, 1810 Willow Road, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell all personal property belonging to defendant located at 1810 Willow Road, 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 directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $3,487.21 Interest from 8/09/07 Atty's Comm Atty Paid $53.75 Plaintiff Paid Date: 11/05/07 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs C is R. Long, Prothonotary By: Deputy RF,QUESTING PARTY: Name ROBERT M. REIBSTEIN, ESQUIRE Address: PO BOX 527 705 MONTGOMERY AVENUE NARBERTA, PA 19072 Attorney for: PLAINTIFF Telephone : 610-664-1999 Supreme Court ID No. 20456 LAW FIRM OF ALLAN C. SMITH, P.C. THE BUCKS COUNTY OFFICE CENTER 1276 VETERANS HIGHWAY, SUITE E-1 BRISTOL, PENNSYLVANIA 19007 Attorney for Plaintiff 6?- L4 73(.CACH, LLC. 4340 SOUTH MONACO STREET 2ND FLOOR DENVER, CO 80237 Plaintiff, VS. MIRANDA H PETROU 1810 WILLOW ROAD CARLISLE, PA 17013 COURT OF COMMON PLEAS CUMBERLAND COUNTY =m ? =X, c t- No.: CV-0000056-07? -? .r c) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance of behalf of CACH, LLC., the plaintiff in this action. Allan C. S th, Esq. I.D No. 204756 Law Firm of Allan C. Smith, P.C 1276 Veterans Hwy- Suite E-1 Bristol, PA 19007 WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdrawal my appearance of behalf of CACH, LLC., the plaintiff in this action. Law Office of Harrison Ross Byck, Esq. P.C 1276 Veterans Hwy- Suite E-I Bristol, PA 19007 Ros Esq. t ney ID No.: 61511 Date: November 16, 2011