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HomeMy WebLinkAbout08-1943 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff : No. d$- 1443 vs. lCLT 1'° Annette Kelly-Eyler : CIVIL ACTION Defendant PRAECIPE FOR TRANSFER OF JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: (2 iv << err.' Kindly enter judgment in favor of Plaintiff and against the above-named defendant(s), pursuant to Pa.R.C.P.D.J. No.402(D), for failure of defendant(s) to appeal, within 30 days, a judgement entered August 31, 2006 against the above-named defendant(s) before District Justice Richard S. Dougherty, as set forth in the transcript of judgment, which is attached hereto. Assess damages as follows: Judgment Amount 8,123.50 Post Judgment Interest (from August 31, 2006 to March 19, 2008 at 6% per annum) 658.03 Payments 1,620.00 Total $7,161.53 Dated: 2008 AMATO AND ASSOCIATES, P.C. By: ;' Wald 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 2061258 a- C. - co k W_ co 0 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUIWERLAND Mag. Dist. No.: 09-1-03 MDJ Name: Hon. RICBARD S. DOUGHERTY Address: 9 8 S ENOLA DR STE 1 ENOLA, PA Telephone: (717 ) 728-2805 17025 ATTORNEY FOR PLAINTIFF : AMATO AND ASSOCIATES, P.C. 107 N. COMMERCE WAY APT/STE 100 ATTN: RONALD AMATO, ESQ. BETHLEHEM, PA 18017 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT -JET PLTF NOTICE OF JUDGMENTNRANSC?SIP4 CIVIL CASE PLAINTIFF: NAME and ADDRESS ri=SON A EEYSB, LLC 107 N. COMMERCE WAY APT/STS 100 C/O MATO AND ASSOCIATES LBSTBLEBEK, PA 18017 J VS. DEFENDANT: NAME and ADDRESS rEBLLY-EYLER, ANNETTE 228 WEST BRADY LANE ENOLA, PA 17025 L J Docket No.: CV-0000212-06 Date Filed: 7/17/06 _ .. (Date of -Judgment] 8/31/06 Judgment was entered for: (Name) BUDSON & SBYSE, LLC ® Judgment was entered against: (Name) KELLY-EYLSR, ANNETTE in the amount of $ 8.123.5 Defendants are jointly and severally liable. 1-1 Damages will be assessed on Date & Time This case dismissed without prejudice. F1 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 Judgment Costs Interest on Judgment Attorney Fees Total $ 8,000.00 $ 123.50 $- 00 $ .00 $ 8,123.501 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 MAGISTERIAL DISTRICT JUDGES, 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 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. lJ? Date , Magisterial District Judge I certify that this is a tru an co th ? B of edings containing;#l';e kudgriert. Date Magisterial DistrictJudge My commission expires first Monday a uary, 20 SEAL AOPC 315-07 DATE PRINTED: 3/12/08 1:41:00 PM ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff No. VS. ANNETTE KELLY a/k/a Annette Kelly-Eyler CIVIL ACTION Defendant CERTIFICATION OF ADDRESSES 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: 228 West Shady Lane Enola PA 17025-2237 AMATO AND ASSOCIATES, P.C. By: 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. VS. ANNETTE KELLY a/k/a Annette Kelly-Eyler : CIVIL ACTION Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHAMPTON The undersigned, being duly sworn, according to law, deposes and says that he is unable to determine whether or not 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; That Annette Kelly is over 18 years of age, resides at 228 West Shady Lane, Enola PA 17025-2237 and is employed; Sworn to and subscribed before me this}? day of PN x„ 2008 A.D NOTAR PUBLIC NOTARIAL SEAL GEOFFREY 0 SCKOENECK HANOVER TOWNSHIP, NORTHAMPTON CNTY My Commlaaton Exptrea Mar 29, 2008 1 lJ C-n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff No. VS. ANNETTE KELLY a/k/a Annette Kelly-Eyler : 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 $ 1. IA3.50 ON Marl, a,? , 2008. ( ) A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN JUDGMENT IS/ARE ENCLOSED. PROTH NOT - CU BERLAND COUNTY Per: If you have any questions concerning the above, please contact the undersigned. AMATO AND ASSOCIATES, P.C. By: /??rnald 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 PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff ?bpk vs. Annette Kelly-Eyler d28-W,Sha6y Lane Enofa, PA I,7oa5-za3'7 : No. 08-1943 Civil PRAECIPE FOR WRIT EXECUTION (MONEY .JUDGMENT) Defendant(s) 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 possession of the defendant(s) accounts receivables furniture furnishings equipment inventory, tools vehicles electronic equipment any and all other personal property belonging to the above- named defendant(s). (2) against ANNETTE KELLY a/k/a Annette Kelly-Eyler, 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 the property) (5) Amount Due $ 7,161.53 Statutory Interest From March 27, 2008 $ 3.74 Less Payment $ 0.00 Costs $ Poundage $ Total $ 7,165.27 AMATO AND ASSOCIATES, P.C. By: Date:March 31, 2008 Rona ato Attorney I.D. No. 32323 Attorney File#: 2061258 Attorneys for Plaintiff Sul pul St (? o a Q, o o ? 0 1 N ?' Tt s " N f . t7 rti [..? ?7 A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff No. 08-1943 Civil VS. ANNETTE KELLY a/k/a Annette Kelly-Eyler 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: 228 West Shady Lane Enola PA 17025-2237 AMATO AND ASSOCIATES, P.C. By: Dated:March 31, 2008 Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff Attorney File #:2061258 rya C ri?i F?' -?'"? ?? ? '?+.? ?... ? ? } 5 .S? C. ? GJ CW) IT! /r -{ ? _"? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-1943 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HUDSON & KEYSE, LLC, Plaintiff (s) From ANNETTE KELLY-EYLER, 228 W. Shady Lane, Enola, PA 17025-2237 (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; possession (3) If property of the defendant(s) not levied dire tedbo suject to notify him/he attachment hat he/she has been added as a of anyone other than a named garnishee, you are garnishee and is enjoined as above stated. Amount Due $7,161.53 Interest - statutory interest from 3/27/08 -- $3.74 Atty's Comm % Atty Paid $ 53.75 Plaintiff Paid L.L. $.50 Due Prothy $2.00 Other Costs Date: 4/07/08 (Seal) C s R. Long, notary By: Deputy 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 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE, LLC Plaintiff vs. ANNETTE KELLY a/k/a Annette Kelly-Eyler Defendant(s) No. 08-1943 Civil CIVIL ACTION ASSIGNMENT OF JUDGMENT For value received, this rd day of 2008, Hudson & Keyse, LLC, Plaintiff in the above-captioned matter, hereby sells, transfers, sets over and assigns all of its right, title and interest in the judgment, debt, interest and costs in the above-captioned matter to Bluestone Investments, Inc. Sworn and subscribed to before me this 2?> day of „p ?C tMt?a.e??' , 2008 Ju ' M. Hostetler Notary Public My Commission Expires: 7,ol z__ At?:L Mark Finston Chief Financial Officer Hudson & Keyse, LLC o- „.TE OF ^?,. JULIE M. HOSTETLER Notary Public, State of Ohio My Commission Expires March 20, 2012 (Recorded in Cuyahoga County) 2061258 21 - f i 3 F' ? Film ? v c ?f 0-1 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED, DUE TO BANKRUPTCY. Sheriff's Costs: Advance Costs: 150.00 Sheriff's Costs 77.01 Docketing $ 18.00 72.99 Poundage 1.51 Advertising Law Library , So Prothonotary 2.00 Refunded to Atty on 11/14/08 Milage 15.00 Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee Postage TOTAL $ 77.01 So Answers; 0 le?r R. Thomas Kline, Sheriff By SO :i i V 01 8dV 8002 c..U" (-. oC 7 lL a/n.2S WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-1943 Civil CIVIL ACTION -- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HUDSON & KEYSE, LLC, Plaintiff (s) From ANNETTE KELLY-EYLER, 228 W. Shady Lane, Enola, PA 17025-2237 (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 $7,161.53 Interest - statutory interest from 3/27/08 -- $3.74 Atty's Comm % Atty Paid $ 53.75 Plaintiff Paid Date: 4/07/08 L.L. $.50 Due Prothy $2.00 Other Costs 04?? Curt' R. Long, onotary (Seal) By: Deputy 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