Loading...
HomeMy WebLinkAbout03-6317COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL FROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT COMMON PLEAS N& 03-/.3~7 NOTICE OF APPEAL Notice is given that the appedlant has filed in the above Court of Comrno~ Pleas an appeal from the judgment rendered by the District Justice an the date and in the cme rnenficxled belov4 VIRGINIA REID-PRICE a.k.a. 811 WEST TRINDLE ROAD 11/6/03 VIRGINIA REID GAYLE A. ELDER MECHANICSBURG PA 1 7 0 ~ 5 hurchtown Church of God ~ Virgi~iaRe-id Legal~ ~ ~ ~ ~ N, Servic4 W_ ~/~-? .~7: '~'~ 8 Irvine Row CVLT 000027Z-U3 [ ~11~La?~.~_q400uame-l-a ~. ~mlc_rt Carlisle' PA 17013 This block will be signed ONLY when this notatian is required under Po. R.C.PJ.P. N~ 1008B. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possessian in this case Signature of Prothonotary or Deputy If appellant was CLAIMANT (see Pa. R.C.P.J.P. No. 1001 ( 6 ) in action before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. PRAEClPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of fo~m to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, deb~c,h from copy of notice of appeal to be served upon appellee). PRAECIPE: To Prothonotary {C. omnxm Pleas Ncx RULE: To Churchtown Church of Go~ (1) You am notified that a rule is hereby entered upon you to file a con~aint in this appeal within twenty (20) days after the date of service of this role upon you by personal service o~ by certified or registered mail. (2) If you do n~t file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of this ruJe If .vice was by maj, is the date of raailin~ AOPC 312-90 COURT FILE TO BE FILED WITH PROTHONOTARY - · .... ~]SCC~JER FINDNCIRLL.L F~-~ NO. : 615-6,41-681~ Dec, 04 2~3 11:39PJ'1 pJ. COMMONWEALTH OF PENNSYLVANtA COUNTY OF: COMBERLAND 09-3 -05 A~,.~ 507 N. M~CHANI CS~URG, PA (7171 766 '45?5 17055 GAYLE AG ELDF~ 507 N. YORK ST. MECHANICSBDHG, PA 17055 THIS IS ,T.O NOT FY Y~U THAT: du~ment: NOTICE OF JUDGMENT/TRANSCRIP' PL^ NT FF: RESIDENTIAL LEASE ~C3-u-~ C~u~c..~ GE' GOD BOILING ~RING~, PA 17007 D~FENDANT: C~ID, VIRG~ L 353 O~ S~OUSE RO~ S BOILHG ~PRING~, PA 1~007 Docket No,: LT-0000272-03 I ~ Date Filed: 10/2,~/03 FO~ PLATNTTPF IPhysicalOamage_s Leasehold $ Damages/UnjuEt Delentio~ Property $ [~ Attachment Prohibited/ 42 Pa.C.S. § 8127 [] This case dismissed without prejudice. [~Possessicn granted, [~ Judgment wss entered for: (Name) ~C~TO¥/N C.1EO~CH OF Judgment was enlered against P~EID, VIK~ZNIA L in a ~ Landlord~e~a~t actio~ i~ the amou,t of $ 6. 228.24 on 11/06/03 . (Date of Judgment) The ~mount of rent per month, aS es~blished by ~he Distric~ Justice, is $ 600.00. The total amount of th~ Securi~ Deposit is $ 600.00 Rent in Arrears $ · -- $ .00--~ .00 = $ .O0-$ .OO = $ .00 Less Amt Due Defendant/rom Cross Complaint - $ .00 Interest (if provided by I~ase) $ .00 '~ Judgment Amount $ Judgment Costs $ 1 ~ 1.50 A~orney Fees $ . Total Judgment $ Post JuQgme~ Credits $ Post Judgment ~osts Cedifi~ Judgment Total $  Possession granted if money judgment ~ not sat~she~ Dy t~me 0t ew~on. Possession not granted. ~ Defendants are jointly and severally liable. ~N ~N ACTION INVOLVING A RESIDENTIAL LE~SE, ANY PAR?Y HAS ~E RIGHT TO APPEAL FROM A JUDGME~ FOR POSSESSION WITHi TEN DAYS A~ER THE DATE OF ENTRY OF ~UOGMENT By FILING A NOTICE OF APPEA~ WITH THE PROTHONOTARY/CLERK OF COURTS OF TH E COURT OF COMMON ~LEAS, CIVIL DIVISi~. THl5 APPEAL WiLL iNCLUDE AN APPEAL OF THE MONEY ~UOGMENT, iF ANY. N ORDER TO OBTAIN A SUPERSEDEAS, THE AP~EL~ MU~ DEPOSff WITH THE PROTHONOTARY)CLERK OF COUETS THE LE~ER OF THREE MONTH~ RE~ OR THE RENT ACTUALLY IN ARREAR~ ON THE DATE,THE APPEAL ~ FILEt;'. IF A PARTY WISHES TO APPEAL ONLY TH~ MONEY PORTION OF A JUDGMENT INVOLVING A RE$IDE~IAL LEASE, ~E PAR~ HAS 30 DAYS A~ER ~E 0ATE OF ENTRY OF JU~ME~ IN WHICH TO FILE A NO~ICE OF APPEL WITH THE ~ROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON ~LEAS, CIVIL THE PARTY FILING AN APPEL MUST INCLUDE A COPY OF ~1~ NO~ICE OF JUDGME~ANSCRIpT FORM WITH THE NOTICE OF APPE EXCEPT A~ OTHERWIGE PROVIDED IN THE ~U[E~ OF C)VIL ~ROC~U~E FOR DISTRICT JU~T{CE~, ~F ~HE ~DGMENT HOLDER ELECTS TO ~ER THE JUDGME~ IN THE COURT OF COMMON ~L~S, ALL FURTHER PROCEg~ MU~T COME FROM THE COURT OF COMMON P~EAS AND NO FURTHER PROCESS MAY ~E ISSUE0 BY THE DISTRICT flUSTICE. UNLESS THE JUDGMENT 15 ENTERED IN THE COUR~ OF COMMON PLUS, ANYONE I~ERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR E~RY OF SATISFACTION W~H THE ~I~TEICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, OR OTHERWISE COMP~IE~ WITH ~HE JUDGME~. I ced~ ~tlat th~s ~s a true an~correc[ ~py o~e reco he nroc~edin~ ~-,~-, .... l ,, ,~ ct d~st~ce. ' Oat · ~ ~ ~.~,.,n~ ~n~ juugmenL j e , District JusticeJ qv commission expires first Monday of Januar, o~ ~.~ . Y 2006, SEAL CHURCHTOWN CHURCH OF GOD, Plaintiff VIRG1NIA REID-PRICE a~k/a VIRGINIA L. REID Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-b31 CIWLTEm PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow the defendant in this action, Virginia Reid-Price, to proceed in forma pauperis. I, Pamela G. Smith, attorney for the party proceeding i_gn forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Attorney for Defendant MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 PROOF OF SERVICE OF NOTICE OF APPEAL AND RULETO FILE COMPLAINT (This proof of service I',4UST BE FLED WITHIN TEN (t0) DAY8 AFT&~ filing !he notice of appeal. Check applicable boxes) COMMONWEAL~ OF PENNSYLVANIA AFFIDAVIT: I hereby swear or affrm that I served - '~" '7 ~a copy d. the Notice Common Pieas No. ~:7 ~'~ .... upon the District Justice designated therei~ on (dalo of servc~: ~ ~ ~ b~, personal service ~ by ~erti~ed (.f~), ma:,l, sender's ~ by personal service ~by (certified) (r~) ma~, sender's receipt attached hereto. the Rule was addressed on mail. sender's receipt attached hereto SWORN (AFFIRMED ANO SUBSCRIBED BEFORE ME THIS .... I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsifications to a~thorities.~~ q r~ COMMONWEALTH OF PENNSYLVANIA NOTICE OF APPEAL t - '~ COURT OF COMMON PLEAS f:K~M : JUDiCiAL DISTRICT DISTRICT JUSTICE JUDGMENT <t:3 ' 3/7 NOTICE OF APPEAL I~ofice is given that the appellant has filed in tl~ above Court of Common Pleas an appeal from the judgment renc~ed by the District Justice an the date and in the case mentioned belOW. VTRGTNTA I~ETD- PRZCE a.k.a. VZRGINZA ~EID 811 NEST TRINDLE ROAD 1 1 / 6 / 0 3 hu=chtown This block will be ~gr~;I ONLY ,~ :when this notation is required under~P~R~C~P~J~. ~ -' 1008B. ' " This t~tice of Appeal, when received b~-~e'District Justice, will operate as o SUPERSEDEAS to the judgment for possession in this case LT 0000272-03 'P~la G. Smith xrvxne ~ow I~1~ ~s CLAIMANT (s~ ~. B.C.P.J.P. No. Signature of Prothonotary or Deputy 1001( 6 ) in aCtion before Disb'ict Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This sectton of form to be used ONLY when appellant wes DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before Dist,'ict Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee). PRAECIPE: To Prothonotary Enter rule upon (Common Pleas RULEz To Chur=htown Church of God Name c~ a~oe~ee(~) *"~ .... ~"&' ..... ""~ ...... '~ ~'- = , appellee(s), to file a complaint in this appeal ~,~.) /_a J / )within twenty (20)days a~.~service of rule or s~ff~ entry of judgment of non pros, "/) ' i' .--, . ~(s). (1) You am 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 regi~femd mai (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date o/service of this rule if service was by me,l is the date of maili~ AoPc ~u-~0 COURT FILE Certified Mail Provides: · A mail[nD receipt (es~e~) eoo~ eu~00se uae~ Sd · A unique identifier for your mailpiece · A record of delivery kept by the Postal Service for two years Important Reminders: · Certified Mail may ONLY be combined with First-Class Mai~® or Pdority Mai[e. · Certified Ma[J is not available for any class of international mail. · NO INSURANCE COVERAGE iS PROVIDED with Certified Mail For valuables, please consider Jnsured or Registered Mail. · For an addJtJona fee, a Return Receipt may be requested to prov de proof of defiver¥ To obta n Re u n Receipt service, prease complste and attach a Return Receipt (PS Form 3811) to the article and add applicabre osta e to c v fee. E.ndorse rnailpiece "Return Rece t Re uest " P. g o. er the adu hcatereturn recet t aU P q ed .Torece~eafeewa~v~r for regu~red. P, SPSe postmark on your Certified Mail receipt is · For an additional fee, delvery may be restricted addressee's a~thorizpd a en* Advise the clerk or mark~-~ethmeaila~dres'~e or endorsement Res ncted~elivety~ p ace wrih the · If a pos mark on he Certified Mail receipt [s desired, lease present the arti- cle at the post office for postmarking. If a postrnar~ on the Certified Mail receipt is not needed, detach and affix label with postage and mail. IMPORTANT: Save this receipt and present it when making an inquiry. Internet access to delivery information is not available on mail addressed to APOs and FPOs. Certified Mail Provides: · A mailieg receipt · A unique identifier for your mailpiece (e~e. le~,) ~0o~ eur~..~Oge ua~ Sd · A record of deliven/kept by the Postal Service for two years Important Reminders.. · Certified Mail may ONLY be combined with First-Class Mai~e or Priority Mai~. · Certified MaiJ is not availabJe for any cJass of intemedonaJ mail · NO INSURANCE COVERAGE IS PROVIDED wth Certified Mail. For valuables, please consider insured or Registered Mail · F°ranaddfionalfee, aRetumReceiptma berequestedto rovideproofof delivery. TO ob ain Return Receipt service, p~ase cemplete anoP~ttach a Return Receipt (PS Form 38117, to the articte and add applicabta pos e t~ f~e,~;~ nE~? O. r a e m ailpiece Return Recei,~tR ........... tag cover the ~--~-,~ce[ereturnreceipt aUSPS ~'~s~n'~~',~u. mr.ecp.!veafeewalverfor equlred. ® p ark on your Cart fled Mall receipt is · For an additional fee, deJive ma - addressee's a,u, thori:~ed a eot. ~dvis~Yth be restricted to the. a~ldressee or endorsement Restr/cted~elivetT. e ctark or mark the rnallplece with the · Jfa postmark on the Certified MStJ receipt is desired, lease present the art - c~e at the post office for postmarking, f a est rece'pt is no needed, detach an ' ~ mar~ on the Certified Mail d affix tubal w~th postage and mail. IMPORTANT Save this receipt and present it when making an inquiry. lfllernef access fo delivery information Js eot available on mail addressed fo APOs and FPOs. 01/02/2004 14:19 7172431007 MDWO PAGE 05/05 CHURCHTOWN CHUKCH OF GOD, Plaintiff VIRGINIA REID-PKICE, a/k/a, VIRGINIA PEK) and GINNY REID ANDERSON Defendant IN THE COURT OF COMMON PLEAS OF CLrMBERLAND COUNTY, PENNSYLVANIA NO, 03-6317 Civil CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED STIPULATION AND AGI~MENT FOR EN'I~Y OF JUDGMENT AND NOW, comes Plaintiff, Churchtown Church of God, by and through its attorneys, MAKTSON DEAILDOKFF WILLIAMS & OTTO, and Defendant Virginia Keid-P:dce, a/k/a, Virginia Kdd and Ginny Reid A~derson who stipulate and agree as follows: 1. Pa. ILC.P. 1037 (c) provides that in all cases, the Court, on motion of a party, may enter an appropriate judgment against a party upon admission. 2. Defendant agrees and admits she forfeits her :~ecurity deposit with interest, if applicable, so that Judgment be entered against her in favor of ?laintiff in the mount of $5,000.00, plus interest accruing at 6% per annum. 3. If Defendant breaches any provision of the Settlement Agreement, Defendant agrees that Plaintiffmay gm'nish her wages up to ONE THOUSAND DOLLARS ($1,000.00) pursuant to 42 Pa.C.S.A. ~ 8127. 4. The parties agree that the Court, upon motion of Plaintiff, may emer Judgment pursuant to this Stipulation w/thout issuance of a Rule to Show Cause, and without further proceedings or notice, Vir~{a~id-Pric~, ~Ja, ' g' ' eld and Ginny Reid Anderson 811 Wcst Trindl¢ Koad Mcchan~csburg, PA 17055.4058 Defendant David K. Galloway, Esqua~e Martson Deardorff Willjam~ & Cr~to Tan East High Street Carlisle, PA 17013-3093 (717) 243-334! Attorney for CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Stipulation and Agreement for Entry of Judgment was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Pamela G. Smith, Esquire MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: January 21, 2004 CHURCHTOWN CHURCH OF GOD, Plaintiff VIRGINIA REID-PRICE, a/k/a, VIRGINIA REID and GINNY REID ANDERSON Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6317 Civil CiVIL ACTION-LAW JI),N 3 004 JURY TRIAL OF TWELVE DEMANDED ORDER OF COURT AND NOW, this~O'day of ~-4~, 2004, upon consideration of the attached Stipulation, Judgment is hereby entered in favor ofFlaintiff Churchtown Church of God and against Defendant Virginia Reid-Price, a/k/a, Virginia Reid and Ginny Reid Anderson in the amount of $5,000.00 with interest accruing at 6% per annum from date of Judgment. If Defendant breaches any provision of the Stipulation, ONE THOUSAND DOLLARS ($1,000.00) of the Judgment shall be subject to wage garnishment under 42 Pa.C.S.A. § 8127. Prothonotary is directed to enter and index this Judgment accordingly. BY THE ~ ~raa Plaintiff: vid R. Galloway, Esquire Ten East High Street Carlisle, PA 17013 ~,l>amDefendant: ela G. Smith, Esquire MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 OI -36-0j CHURCHTOWN CHURCH OF GOD, Plaintiff VIROINIA REID-PRICE, a/k/a, : VIRGINIA REID and GIN'NY REID : ANDERSON : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6317 Civil CIVIL ACTION-LAW .FURY TRIAL OF TWELVE DEMANDED STIPULATION AND AGREEMENT FOR ENTRY OF JUDGMENT 01/02/2004 14:19 71724S1807 MDWO PAGE 0§/05 CHURCHTOWN CHURCH OF GOD, Plaintiff VIROINIA REID-PKICE, a/k/a, : VIRGINIA REID and G1NNY REID : ANDERSON : Defendant : LN' THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6317 Civil CIVIL ACTION-LAW TRIAL OF TWELVE DEMANDED STIPULATION AN~ AGREEMENT FOR ENTRY OF JUDGME1Wf AND NOW, comes Plaintiff, Churchtown Church of God, by and through its attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, antt Defendant Virgi~a Reid-Price, a/k/a, Virginia Reid and Ginny Reid Anderson who stipulate and agree as follows: 1. Pa. R.C.P. 1037 (c) provides that in all ca,es, the Court, on motion ora party, may enter aa appropriate judgment against a party upon admission. 2. Defendant agrees and admits she forfeits her security deposit with interest, if applicable, so that Judgment be entered against her in favor of?laintiffin the mount of $$,000,00, plus interest accruing at 6% per annum. 3. If Defendant breaches any provision of the Settlement Agreement, Defendant agrees that Plaintiffmay garnish her wages up to ONE THOUSAND DOLLARS ($1,000.00) pursuant to 42 Pa.C.S.A. § 8127. 4. The parties agree that thc Court, upon motion of Plaintiff, may enter Judgment pursuant to tiffs Stipulation without issuance of a Rule to Show Cause, and without further proceedings Or notice. Vir~,~a(Reid-Price, a/k/a, Virginia Reid and Oinny Reid Andexson 811 West Trindle Road Mechardcsburg, PA 17055-4055 Defendant BYDavid R, Galloway, Esqu~ Martson Deardorff Williamq & O~to Ten East High Street Carlisle, PA 17013-3093 (7 ! 7) 243 -3341 Attorney for Plaintiff rate: CERTIFICATE O.F SERVICE I, Nichole L. Myers, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Stipulation and Agreement for Entry of Judgment was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Pamela G. Smith, Esquire MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: January 21, 2004