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Home My WebLink About03-5900COMMONWEALTH OF PENNSYLVANIA COUNTY OF: ~;uM~ERLAND Mag Ois[. NO 09-2-01 PAULA P. COP. REAL .~.~Ures. i COURTHOUSE SQUARE CA~LI SLE, PA re,eohooe (717'~ 240-6564 KIM & CATHLEEN P~A~AIGH 7 GOP~DON DRIVE CARLISLE, PA 17013 17013-0000 NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF/J U DGM Er~ Y~O~:ASs NAME and ADDRES ~RAEAIGH, KIM A CATHLEEN ~ 7 GOPJDON DRIVE CARLISLE, PA 17013 VS. DEFENDANT/JUDGMENTCNP,A~I~BRESS FHODGE, STACY ~ 839 N. WEST STREET CARLISLE, PA 17013 Docket No.: CV- 0000215- 03 Date Filed: 9/02/03 CROSS COMPLA NT 001 THIS IS TO NOTIFY Yeti IHAT: .- .......... . ...... JudgmenT: [~ Judgment was entered for: (Name) ~ Judgment was entered against: (Name) ~n the amount of $ FOR PT,ATNTIFF RARAT~R, WT~ & CA~RT,~'F3~ I, O41.6R on: (Date of Judgment) E~ Defendants are jointly and severally liable. ] Damages will be assessed on: ~This case dismissed without prejudice. E~ Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 $ E~ Portion of Judgment for physical damages arising out of residential lease $ (Date & Time) Amount of Judgment $ 1,0~3.68 Judgment Costs $ .00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 1,043.68 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 DISTRICT JUSTICES, IF THE JUDGMENT 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 DISTRICT JUSTICE . 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 DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. I certify that this is a true~e~o~F~/he p//ngs My commission expires first Monday of January, 2006 . AOPC315-03 DATE PRINTED: 9/09/03 4:13:18 PM , District Justice containing the judgment. , District Justice. SEAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Amount Due Interest Atty's Comm q,,~, L,/SL ¢ p,Q,Oosts'" '-'/'" : ( ) Confessed Judgment ( ) Other File No. 0 ~ - ~'-"~'o ,.~ TO THE PROTHONOTARY OFTHE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. IssUe writ of execution in the above matter to the Sheriff of ~.~/1/1-1 .~)L"/"/~'//7 C/ County, for debt, interest and costs, upon the following described property of the defendant(s) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). Date (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. - J ~ /'O/O,'~ Signature: Print Name: Address: Attorney for: Telephone: Supreme Court ID No.: (over) Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-5900 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO TIlE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due KIM C. AND CATHLEEN D. RARAIGH Plaintiff(s) From STACY J. HODGE, 316 N. COLLEGE ST., CARLISLE, PA 17013 (I) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY AND LEVY ON A 1999/2000 JEEP CHEROKEE PA LICENSE - ECMll02 VIN #1J4GW58N6XC632000. (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 gamishae(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 $1,043.68 Interest Atty's Corem % A~y Paid Plaintiff Paid $34.25 Date: 11/10/03 Due Prothy $1.00 Other Costs (Seal) P~EQUESTING 1>ARTY: Name KlM C..&ND CATHLEEN D. RARAIGII CURTIS R. LONG Prothonotary Address: 7 GORDON DR., CARLISLE, PA 17013 Attorney for: Telephone: Supreme Court ID No. ANGINO & ROVNER, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 E-mail j decinti~angino-rovner.com GLORIA D. PHILLIPS and ROY C. PHILLIPS, her husband, Plaintiffs C & T WHOLESALE COMPANY, CHARLES H. KINSLER, SR., CHARLES H. KINSLER, JR., and JEANNE E. K1NSLER, individually and t/d/b/a C & T WHOLESALE COMPANY, Defendants Attorneys for Plaintiffs: Gloria D. Phillips and Roy C. Phillips IN THE COURT OF COMMON PLEAS CUMBEKLAND COUNTY, PA CIVIL ACTION - LAW NO. 2003-05990 JURy TKLAL DEMANDED PLAINTIFFS' REPLY TO NEW MATTER OF DEFENDANTS AND NOW come the Plaintiffs, by and through their attorneys, Angino & Rovner, P.C., and hereby reply to the New Matter of Defendants as follows: 14. The allegation contained in this paragraph is a conclusion of law and of fact to which no response is required. To the extent that a response is deemed required, it is hereby specifically denied that Plaintiffs' claims are barred by thc applicable statute of limitations. On the contrary, Plaintiffs' claims were timely filed. Strict proof of this defense and all of Defendants' affirmative defenses is demanded at the time of trial. 15. The allegation contained in this paragraph is a conclusion of law and of fact to which no response is required. To the extent that a response is deemed required, it is hereby specifically denied that any of Plaintiffs' claims are barred or reduced by Plaintiffs' failure to mitigate damages. Strict proof of this defense and all of Defendants' affirmative defenses is demanded at the time of trial. 16. The allegation contained in this paragraph is a conclusion of law and of fact to which no response is required. To the extent that a response is deemed required, it is hereby specifically denied that any of Plaintiffs' claims and/or injuries were caused by anyone other than answering Defendants. Strict proof of this defense and all of Defendants' affirmative defenses is demanded at the time of trial. 17. The allegation contained in this paragraph is a conclusion of law and of fact to which no response is required. To the extent that a response is deemed required, it is hereby specifically denied that Plaintiffs~ were contributorily and/or comparatively negligent in this case. On the contrary, as stated in Plaintiffs' Complaint, Defendants alone caused Plaintiffs' injuries. Strict proof of this defense and all of Defendants' affinuative defenses is demanded at the time of trial. WHEREFORE, Plaintiffs demand judgment against all Defendants. Respectfully submitted, ANG .I~ O & ROVNER, P.C. I.D. No. 77421 4503 N. Front Street HanSsburg, PA 17110 (717) 238-6791 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Katherine D. Zimmerman, an ~mployee of Angino & Rovner, P.C., hereby certify that a true and correct copy of the foregoing Plaintiffs' Reply to New Matter of Defendants was served via United States first-class mail, postage prepaid, upon the following: Brooks R. Foland, Esquire Thomas, Thomas & Hafer 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 Counsel for All Defendants Dated: I~a~herine O. Zi ~ R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned SATISFIED. Sheriff's Costs: Docketing 18.00 Poundage 20.88 Advertising 10.00. Law Library Prothonotary 1.00 Mileage 10.35 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale 15.00 Garnishee TOTAL $ 115.23 Pd by Defendant Sworn and Subscribed to before me this/q~dayof )~ 200 A.D >a,a PROTHONOTARY ' So Answers; R. Thomas Kline, Sheriff DISTR/BUTION ATTORNEY }Om Raraigh WRIT NO. 2003-5900 Civil Kim C. Raraigh and Cathleen D. Raraigh Stacy J. Hodge Real Debt $ 1043.68 Interest Writ Costs, Atty 34.25 Writ Costs, Pltff. Miscellaneous Attorneys Fees $ 1077.93 Sheriff's Costs: Docketing Poundage Posting Sale Bills Law Library Prothonotary Service Misc. Bad Check Charge Advertising Postpone Sale Surcharge Garnishee Levy TOTAL Defendant Paid to Sheriff Advance Costs Total Collected $ 18.00 20.88 !.00 10.35 10.00 15.00 20.00 20.00 $ 115.23 $1193.16 150.00 $1343.16 DISTRiBUTION Pd. To Pltff. Refund of Adv. Costs Pd. To Prothonotary 1077.93 150.00 1.00 R. Thomas Kline, Sheriff