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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 .. w 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 W 00 `1 1. ) 00 . to 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 L ?P 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 WO 4 °C e4 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 tl- X- w