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 $3487.21 plus
court costs.
ROBERT M. REIBSTEIN
Attorney for Plaintiff
r
CbMMON1NEALTH OF PENNSYLVANIA
COUNTY nF: _ C0ILHERLAriD
THIS IS TO NOTIFY YOU THAT:
Judgment: FOjt PLAI~iTIFF
NOTICE`OF JUDGMENTRRANSCRIPT
.CIVIL CASE ..; ,
PLAINTIFF: NAME and ADDRESS
rCACH LLC
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PO BOZ 527 _ r,
7 0 5 )s[O11iT(~O~LB$X::< AVS ~ <.
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CABLI$L$; ; ~ PA 17~013~ K
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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
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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.
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ROBERT M. REIBSTEIN
Attorney for Plaintiff
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/ 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).
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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
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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
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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
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Bad Check
Postage
~0 9
/ R. Thomas Kline, Sheriff
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Total i~ a
66.61
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By Claudia A. Brewbaker
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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
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No.: CV-0000056-07?
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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