HomeMy WebLinkAbout08-1948r
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff
VS.
MARIA TSIRIGOTIS
Defendant
No. OR- M9 Civil (--rM
: CIVIL ACTION
PRAECIPE FOR ENTRY OF JUDGMENT
AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY, CUMBERLAND COUNTY:
Pursuant to the Pennsylvania Rule of Civil Procedure 3002, kindly file and index the attached
certified docket entries and judgment previously entered in the Court of Common Pleas of Dauphin
County, in an action captioned HUDSON & KEYSE, LLC vs. MARIA TSIRIGOTIS, at docket no.
2007-CV-00828-NT, and assess damages in favor of the Plaintiff, HUDSON & KEYSE, LLC , and
against the Defendant, MARIA TSIRIGOTIS, as follows:
Amount of Foreign Judgment $3,218.09
Interest (from January 29, 2007 to March 12, 2008
2008 at statutory
of 6% per annum) 230.48
TOTAL $3,448.57
Dated: March 12, 2008
Attorney File # 2061342
Damages assessed and judgment
entere as above:
/il
oil
PROT TAR
AMATO AND ASSOCIATES, P.C.
By:
n Amato, Esq., Atty ID #32323
chael J. Kennedy, Esq., Atty ID #72412
Michael R. Lessa, Esq., Atty ID #88617
Justin N. D vis, Esq., Atty ID #84464
ttorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
A DEBT COLLECTION LAW FIRM
319108
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff No.
VS.
MARIA TSIRIGOTIS
Defendant(s)
CIVIL ACTION
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 Maria Tsirigotis is over 18 years of age, resides at 19 Gettysburg Pike, #4,
Mechanicsburg PA 17055 and is employed;
Sworn to and subscribed
before me this \1 day
of(l^Q. n 2008 A.D.
L?:J
NOTA Y PUBLIC
NOTARIAL SEAL
GEOFFREY Q SCHOENECK
Notary Public
HANOVER TOWNSHIP, NORTHAMPTON CNTY
My Commission Expires Mar 29, 2008
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff No.
VS.
MARIA TSIRIGOTIS
CIVIL ACTION
Defendant
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
. SS:
COUNTY OF NORTHAMPTON
Ronald Amato, Esquire, being duly sworn according to law, deposes and says that he is the
attorney for Plaintiff, HUDSON & KEYSE, LLC, is authorized to make this affidavit on its behalf; and
that, to the best of his knowledge, information and belief:
1. The name of the judgment debtor is MARIA TSIRIGOTIS.
2. The last known post office address of the judgment debtor is 19 Gettysburg Pike, #4,
Mechanicsburg PA 17055.
3. The name of the judgment creditor is HUDSON & KEYSE, LLC.
4. The last known post office address of the judgment creditor is 382 Blackbrook Road,
PAINESVILLE OH 44077.
5. The judgment in favor of Plaintiff, HUDSON & KEYSE, LLC , and against Defendant,
MARIA TSIRIGOTIS, entered in the total sum of $3,218.09 in the Court of Common Pleas of
Dauphin County, is valid, enforceable, and unsatisfied as of this date; March 12, 2008.
SWORN TO AND SUBSCRIBED
BEFORE ME THIS DAY
OF , 2008.
Ronald Amato
Notary Public
Date: ,3/7/2008 Dauphin County
Time: 10:43 AM Complete Case History
Page 1 of 2 Case: 2007-CV-00828-NT
Hudson & Keysevs.Maria Tsirigotis
Filed: 1/29/2007
Subtype: Notes
Comment
Physical File: Y
Appealed: N
Status History
Pending 1/29/2007
Judge History
Date Judge
1/29/2007 No Judge,
Reason for Removal
Current
Payments Receipt Date Type
Amato And Associates 137384 7/30/2007 Civil Filing
Amato, Ronald (attorney for Hud 123960 1/29/2007 Civil Filing
Plaintiff
Name: Hudson & Keyse
Address: 107 N Commerce Way
Bethtlehem PA 18017
Phone: Home: Work:
Employer:
Litigant Type :
Comment:
Attorneys
Amato, Ronald (Primary attorney)
Defendant
Name: Tsirigotis, Maria
Address: 5236 Winding Way
Harrisburg PA 17109
Phone: Home: Work:
Employer:
Litigant Type:
Comment:
Register of Acti ons
1/29/2007 New Civil Case Filed This Date.
Plaintiff: Hudson & Keyse Attorney of
Record: Ronald Amato
Filing: Judgment - DJ Paid by: Amato,
Ronald (attorney for Hudson & Keyse)
Receipt number: 0123960 Dated:
1/29/2007 Amount: $23.00 (Check)
Transcript of Judgment from the Docket of
Joseph S. Lindsey, District Justice
12/04/06. Judgment for $3218.09
Entered At 2:20 p.m.
Stephen E. Farina, Prothonotary
District Justice Costs $84.00 included in
amount.
Total
SSN:
DOB:
Sex:
Send notices: Y
Send Notices
SSN:
DOB:
Sex:
Send notices: Y
No Judge,
No Judge,
No Judge,
No Judge,
User: TWASHINGTO
Amount
29.00
23.00
52.00
Date: 3/7/2008 Dauphin County
Time *fU:43 AM Complete Case History
Page 2 of 2 Case: 2007-CV-00828-NT
Hudson & Keysevs.Maria Tsirigotis
Register of Actions
7/30/2007 Filing: Writ of Execution Paid by: Amato No Judge,
And Associates Receipt number: 0137384
Dated: 7/30/2007 Amount: $29.00
(Check)
Writ of Execution No Judge,
Garnishee -
Sheriff - Dauphin County
Amount Due $3218.09 + Costs. See
Praecipe filed
10/15/2007 Writ Stayed per Atty Shffs Cost $47.00. No Judge,
So Ans. J.R Lotwick, Sheriff.
Judgment
Order date In Favor Of Disposition Judgment
01/29/2007 Plaintiff 01/29/2007 Open DJ Judgment
Comment: 3218.09
Plaintiff: Hudson & Keyse
Defendant: Tsirigotis, Maria
Judgment
Order date In Favor Of Disposition Judgment
07/31/2007 Plaintiff 07/31/2007 Open Writ of Execution
Comment: 3218.09
Plaintiff: Hudson & Keyse
Defendant: Tsirigotis, Maria
I hereby certify that the foregoing is a
true and correct copy of original filed.
Prothonotary/Clerk of C rt
User: TWASHINGTO
c,o
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff : No.
vs.
MARIA TSIRIGOTIS
: CIVIL ACTION
Defendant
NOTICE OF JUDGMENT
Please be advised that the above-named Plaintiff, HUDSON & KEYSE, LLC , has transferred to
the Court of Common Pleas of CUMBERLAND County, Pennsylvania, a judgment entered
against you in the Court of Common Pleas of Dauphin County. Said judgment being entered in
the Court of Common Pleas of CUMBERLAND County, Pennsylvania, to the above civil action
number against the above named defendant(s) in the amount of $3,448.57, this 61714 day of
I Oxah , 2008.
1 t4
PR THON Y - MBERLAND COUNTY
Per:
If you have any questions concerning the above, please contact the undersigned.
AMATO AND ASSOCIATES, P.C.
By:
onald 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
VS.
MARIA TSIRIGOTIS
Iq Ge+fysburl Pike, '#y
Meehan icsl ur , PA 17056
No. 08-1948 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 MARIA TSIRIGOTIS, 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 $ 3,218.09
Statutory Interest
From March 27, 2008 $ 70.18
Less Payment $ 0.00
Costs $
Poundage $
Total $ 3,228.27
AMATO AND ASSOCIATES, P.C.
By:
Date:July 21, 2008
Rona mato
Attorney I.D. No. 32323
Attorney File#: 2061342 Attorneys for Plaintiff
! ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff
VS.
MARIA TSIRIGOTIS
Defendant(s)
No. 08-1948 Civil
CIVIL ACTION
CERTIFICATION OF DEFENDANT(s) ADDRESS FOR SERVICE
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:
19 Gettysburg Pike, #4
Mechanicsburg PA 17055
AMATO AND ASSOCIATES, P.C.
By:
Dated:July 21, 2008
Ronald Amato
Attorney I.D. No. 32323
Attorneys for Plaintiff
Attorney File #:2061342
C7 1
p -? 71
177
T
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C(A
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-1948 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HUDSON & KEYSE, LLC, Plaintiff (s)
From MARIA TSIRIGOTIS, 19 Gettysburg Pike, #4, Mechanicsburg, PA 17055
(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 defendants.
(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 $3,218.09
Interest from 3/27/08 -- $70.18
Atty's Comm %
Atty Paid $55.50
Plaintiff Paid
Date: 7/31/08
L.L. $.50
Due Prothy $2.00
Other Costs
Curti R. Long, ary
(Seal)
By:
Deputy
REQUESTING PARTY:
Name RONALD AMATO, ESQUIRE
Address: AMATO AND ASSOCIATES, PC
107 NORTH COMMERCE WAY
BETHLEHEM, PA 18017
Attorney for: PLAINTIFF
Telephone: 610-866-0400
Supreme Court ID No. 32323
C=^
An-
w
R. Thomas Kline, Sheriff, who being duly sworn
according to law, states this writ is returned
ABANDONDED. No action has been taken in the last
six months.
Sheriff's Costs:
Docketing $18.00
Law Library .50
Prothonotary 2.00
Surcharge 30.00
Mileage 12.00
Poundage 1.25
$63.75
So Answers:
-?
R. Thomas Kli m-?f
8Y L ",.
Ser eant
8 Z .` a 1- t)P' f &COZ
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V.1- DO C o
`? a-3D0r4
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-1948 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HUDSON & KEYSE, LLC, Plaintiff (s)
From MARIA TSIRIGOTIS,19 Gettysburg Pike, #4, Mechanicsburg, PA 17055
(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 defendants.
(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 $3,218.09
Interest from 3/27/08 -- $70.18
Atty's Comm %
Atty Paid $55.50
Plaintiff Paid
Date: 7/31/08
L.L. $.50
Due Prothy $2.00
Other Costs
C . Lon otary
(Seal)
By:
Deputy
REQUESTING PARTY:
Name RONALD AMATO, ESQUIRE
Address: AMATO AND ASSOCIATES, PC
107 NORTH COMMERCE WAY
BETHLEHEM, PA 18017'
Attorney for: PLAINTIFF
Telephone: 610-866-0400
Supreme Court ID No. 32323
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