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HomeMy WebLinkAbout04-0872RUSS BERRIE COMPANY Plaintiff ASAD ;AWAD T/A SAMIE'S CARDS GIFTS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CML DMSION - LAW : FOREIGN JUDGMENT PRAECIPE TO THE PROTHONOTARY.' Please record the Foreign Sealed Exemplified Judgment and Statement for Docketing from the Superior Court of the State of New Jersey, Law Division, Spec'mi Civil Part in Ocean County. Please enter the Sudgmem in favor of the Plaintiffand against the Defendant, ASAD JAWAD T/A SAMIE'S CARDS & GIFTS, with the amount due of $3,154.88 plus costs and attorney fees of $132.10 and imerest of $66.43 for a total amount due of $3,353.41. To Cumberland Coqnty Prothonotary Robert D. Kodak, Attorney for~laintiff Attorney I.D. No. 18041 · sPECIAL C~I¥~L Y~kRT SUMMON D RETURN OF SERVICE - PAGE Plaintif£6r Plaintiff's Attor?y information: Nar'R: ~ 7~ Kathleen R Wall ' Address: Kathleen R. Wall, Esq 2640 Highway 70 Manasquan, NJ 08736 Telephone No.: (732) 223-0111 Russ Berrie Company Plaintiff(s) versus 2 Demand Amount: $3,154.88 Filing Fee: $45.00 Service Fee: $4.00 Attorney's Fees $78.10 TOTAL $3,281.98 SUPERIOR COURT OF NEW JERSEY LAW DIV/SlON, SPECIAL CIVIL PART Ocean County 118 Washington St. Toms River , NJ 08754 (732) 929-2016 Docket Number: DC-006821-01 Asad Jawad Civil Action Defendant(s) SUMMONS Contract Defendant Information: Asad Jawad TA Samies Cards Gifts Samies Cards Gifts 682 Rte 70 Brick, NJ 08723 (732) 262-2374 Date Served: RETURN OF SERVICE IF SERVED BY COURT OFFICER (For Court Use Only) Docket Number' WM WF BM BF NAME: Description of Premises: Date: ---- Time: OTHER HT WT AGE MUSTACHE BEARD RELATIONSHIP: I hereby certify the above to be true and accurate: GLASSES Court Officer RETURN OF SERVICE IF SERVED BY MAIL (For Court Use Only) I, , hereby certify that on summons and complaint by regular and certified mail, return receipt requested. 7162706383714012202B ...... ' (.d.J A ! Detach Before Mailing- fiE... 00 & ~i 21 .~, O'J. · , I mailed a copy of the within Employee Signature ,Document Name: untitled CVM1023 AUTOFLATED CASE MANAGEMENT SYSTEM 12/24/03 PAGE: 001 OF 001 DOCUMENT LIST 9:00 VENUE : OCEAN COURT : LAW SCP DOCKET #: DC 006821 01 CASE TITLE : RUSS BERRIE COMPAi~Y VS JAW~JD AS~JD DATE DOC DOCUMENT NON FILING/TARGET ATTORNEY MUL DOC S FILED NUM TYPE CONF PARTY NAME NAME PTY STA 08 07 2001 00I COMPLAINT-MAIL 09 14 2001 002 JDG DEFLT 09 14 2001 003 PRF AMT DUE/NML %% 07 2001 004 MOT ENF LT 12 07 2001 005 ORD ENF LT RIT 01 29 2002 006 STAT FOR DOCKET RUSS BERRIE WALL N COURT INIT N RUSS BERRIE WALL N RUSS BERRIE WALL N RUSS BERRIE WALL N RUSS BERRIE WALL N GR GR I heret~y certify that the foregoing m a true copy of the original on In my ofice. Clerk Date: 12/24/03 Time: 09:00:37 Fil~ed Aug 07, 2001 Docket No.: OCN DC-006821-01 KATHLEEN R. WALL, ESQUIRE 2640 HIGHWAY #70 - PO BOX A MANASQUAN NJ 08736-063t (732} 223-0t 1t Attorney for Plaintiff Our File No: 30354 RUSS BERRIE & COMPANY SUPERIOR COURT OF NEW JERSEY LAW DIVISION: OCEAN COUNTY SPECIAL CIVIL PART: CIVIL Plaintiff ASAD JAWAD I/T/A SAMIE'S CARDS & GIFTS DOCKET NO. DC 682t-01 COMPLAINT Defendant Plaintiff, by way of Complaint against the Defendant above states: FIRST COUNT t. Defendant owes Plaintiff the sum of $3,t54.88 on a book account. 2. Payment has been demanded and has not been made. WHEREFORE, Plaintiff demands Judgment against the Defendant in the sum of $3,t54.88 together with interest and costs and further demands that Defendant defend by filing an Answer. SECOND COUNT t. Defendant is indebted to Plaintiff on a certain contract for goods sold and delivered and services rendered at the request of the Defendant and upon Defendant's promise to pay the agreed amounts. 2. Payment has been demanded in the amount of $3,154.88 and has not been made. Filed Aug 07, 2001 Docket No.: OCN DC-006821-0! WHEREFORE, Plaintiff demands Judgment against the Defendant in the sum of $3,154.88 together with interest and costs and further demands that the Defendant defend by filing an Answer. THIRD COUNT 1. Defendant is indebted to Plaintiff for the reasonable value of goods sold and delivered and services rendered by the Plaintiff to the Defendant on Defendant's promise and agreement to pay a reasonable price for same. 2. Payment has been demanded in the sum of $3,t54.88 and has not been made. WHEREFORE, Plaintiff demands Judgment against the Defendant in the sum of $3,154.88 together with interest and costs and further demands that the Defendant defend by filing an answer. KATHLEEN R. WALL, ESQUIRE Attorney for Plaintiff DATED: August 6, 200t /S/KATHLEEN R. WALL KATHLEEN R. WALL, ESQUIRE I certify that the above matter in controversy is not the subject of any other action pending in any court or of a pending Arbitration proceeding, and I have no knowledge that any other action or Arbitration proceeding is contemplated. To the best of my knowledge, no other party should be joined in this action. Filed Aug 07, 2001 DQcket No.: OCN DC-006821-01 I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. DATED: August 6, 2001 KATHLEEN R. WALL, ESQUIRE Attorney for Plaintiff /S/KATHLEEN R. WALL KATHLEEN R. WALL, ESQUIRE YOU ARE PUT ON NOTICE THAT WE ARE ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. WRITING A LETTER OR PLACING A TELEPHONE CALL TO THE OFFICE OF THE ATTORNEY OR THE CREDITOR IS NOT A SUBSTITUTE FOR THE FILING OF AN ANSWER TO THIS COMPLAINT. ({ [~ E F E N [! A N J ( S ) ) ":,' CI-!,EO] [DR,,G 30354 RUSS PERRIE COMP,-",N'F JOOGNENT IN file 6BOVE ENTIlLED L,,-,UCE WAS ENI'E:REO IN THE OCEAN C:OUNTYSPECIAI.d.,],V~L ..... PART IN FAVOR OF: ',AEiAINS~: ~ ' I ASA[I JALtAD iA SAMIES CARDS GtF]S 682 Route 70, Brick, NJ 08723 AN EXECLllION WAS ISSLIED ON AND WAS RETIJltNED ON MONIES RECEIVED BY SCP OFFICER TOTAL CRE:DII'S / / / / $, 0() JUDGMENT OATE 09/14/20<)~ ,JUI]GMEN'i AMOUNT(*) $3,154,88 COSTS & A'IFORNEY FEES $]27,1.0 ADOI'IION¢,L. CuSI'% $,00 TOTAL $3,28I, 9S CREDITS, IF ANi $,00 TOTAL $3,281, ?8 (~) INCLLII)L-S PI;:E .IUO_F:~HEN(' INTEREST (IF AN'¢; A,t; OF' THIS TIldE, ;, ........ ~:iEAI_ I HERE:DY LExl)FY 'f'HAI 'THE F(H;:E)~[IJ]h REF'I. ECTS THE JUD[)ME:N[ ANO [ h>TS OF RECORD IN THIS ....... OCEAN COIJNIY SPECIAl_ CIVIL PART I, THE UNI)ERSIGNED, AM (A'FIORNE¥ FOR) THE ABOVE NAMED PLAINTIFF, CERI'IFY IHAT A1 IlIE PRESENT TIME I'HERE IS DUE: UPON THE ABOVE MEN'IIONED JUDGMEN¥, WHICH IS ADOU1 TO BE DOCKETED IN 1HE SUPERIOR COUR1 OF NEW JERSEY, AS HEREIN SE1 FORTH. THE TOTAL JUDGMENT DUE INCLUOES THE $5,00 DODKE:TING FEE:, TOTAL JUDGMENT DUE TOTAL CREDITS $ SU8TOI'AI_ $__ 3 ~. 28__6_..._~_8___ INI'E:REST $ 66.43 TOTAl- DUI-5 THIS DATE $ 3~353.41 (BEING A SLIM NOT LESS THAN TEN DOLL I CERTIFY' THAT 'THE F'ORIEGOING S1ATEMEN~S MADE BY' ME ARE TR~ I AM AWARE THAT IF' ANY OF 1 FOREGOING STATEMENTS MADE 8Y ME ARE WILLFULLY FALSE, ~'~¢j~[;;~:;z~DJECT TO PUNISHMENT. ~,~uary l, 2002-- /~ Said Court, at Trenton, this OF NEW JERSEY Clerk of the Superior Court of New Jersey, The same being a Court of Record, do hereby certify That the foregoing is a true copy of STATEMENT FOR DOCKETING filed February 11, 2002 in the cause wherein RUSS BERRIE COMPANY is the Plaintiff and JAWAD ASA1) is the Defendant now on file in my office. IN TESTIMONY WHEREOF, I have hereto set my hand and affixed the seal of "/'---~k~Day of (~ ~0 t~~ Clerk of the Superior Court of New Jersey, do hereby certify That Donald F. Phelan, the above certificate, was, at that date thereof, and now is, the Clerk ffNew Jersey, that the foregoing attestation is in proper form, that the seal the seal of said court, and that the signature of the said Donald F. Phelan, is in handwriting. hand at the City of Trenton, this and two. Day of t~- made pursuant to an act of Congress Code, Sec. 1738 effective September 1, 1948) RUSS BERRIE COMPANY Plaintiff ASAD JAWAD T/A SAMIE'S CARDS & GIFTS Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : : CIVIL DMSION - LAW : FOREIGN JUDGMENT JUDGMENT CREDITOR'S AFFIDAVIT AND NOW, comes Plaintiff, RUSS BERRIE COMPANY, and hereby avers that the aforesaid Judgment from the Superior Court of New Jersey, Law Division, Special Civil Part in the County of Ocean, remains valid, enforceable and unsatisfied and that the Defendant, ASAD JAWAD T/A SAMIE'S CARDS 8: G1FTS, has an address at: 19 LOGANS RUN, ENOLA, CUMBERLAND COUNTY, PA 17025. It is further averred that the address of Creditor is: 111 BAUER DRIVE, OAKLAND, NEW JERSEY 07436. Ja s 7. O'Reardon/Jr. RUSS BERRIE COMPANY Plaintiff ASAD JAWAD T/A SAMIE'S CARDS & GIFTS Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL DMSION - LAW FOREIGN JUDGMENT To ASAD JAWAD T/A SAMIE'S CARDS & GIFTS, Defendant(s) You are hereby notified that on '~ ( (Judgment) has been entered against you in the above-captioned case. · 20_~, the following DATE: Judgmem entered in the amount of $3,353.41. Prothonotary I hereby certify that the name and address of the proper person(s) to receive this notice is: ASAD JAWAD T/A SAMIE'S CARDS & GIFTS 19 LOGANS RUN ENOLA PA 17025 A/ASAD JAWAD T/A SAMIES CARDS & GIFTS, Defendido/a Defendidos/as Por este medio se le esta notiflcando que el de del 20__, el/la siguiemeCFallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe. Protonotario Certificao que la siguiente direccion es la del defendido/a segun indicada en el cetificado de residencia: ASAD SAWAD T/A SAMIE'S CARDS & GIFTS ,- 19 LOGANS RUN ENOLA PA 17025 Abogado del Demandante PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 RUSS BERRIE COMPANY IN THE COURT OF COf~40N PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Writ No. Term 20 Plaintiff NO. 04-0872 CIVIL Term 2004 Vs ASAD JAWAD T/A SAMIE'S CARDS & GIFTS 19 LOGANS RUN ENOLA PA 17025 Defendant (s) Amount due $ 3,353.41 InterestFROM DATE OF JUDG. (03/01/04) Atty's Comm. $ 167.67 and CostsTO BE DETERMINED$ TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of CL~4BE~ County, Pennsylvania; (2) against ASAD JAW~ T/A SAMIE'S CARDS & GIFTS (3) and against Defendant (s) Garnishee (s), (4) and index this writ (a) against ASAD JAWAD T/A SAMIE'S CARDS & GIFTS (b) against Defendant(s) and 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 property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy) LEVY UPON~LL PERSOI~%L PROPERTY OF ABOVE-LISTEDDEFENDANT(S) AT BUT NOT LIMITED TO A 1995 DODGE STATION ~%~ON, YIN 2B4GH2533Sl~21 (5) Exemption has Dated 04/19/04 (not) been waived. x LISTED~DDRESS INCLUDING 2002 Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717) 238-7159 Attorney For Plaintiff(s) oI PENNSYLVANIA DEPARTMENT OF TRANSPORTATION VEHICLE RECORD ABSTRACT 4/06/0~ PAGE I 0~09707160001~9 REFERENCE # 28q75 OWNER : ASAD JAWAD 19 LOGANS RUN ENOLA PA I7025 LESSEE : NONE OO2 TITLE NUMBER TAG NUMBER VIN : 484~2856 EKY2002 2B4GHZ533SR25978I MAKE DODGE MODEL CAR RENEWAL WID 032043901360948 001 PREVIOUS TAG AWG3016 LIENS : NO STOPS : NO TITLE BRAND INFORMATION NO TITLE BRANDS EXIST FOR THIS TITLE TITLE DATE : 05/25/95 REGISTRATION EXPIRY DATE: 09/04 BODY TYPE : SW ODOMETER READING : 90,146~ ~ACTUAL MILEAGE DUPLICATE TITLE COUNT : Q VEHICLE YEAR : 1995 STOLEN DATE LIEN INFORMATION NO LIENS EXIST FOR THIS TITLE ADDRESS CORRESPONDENCE TO: DEPARTMENT OF TRANSPORTATION VEHICLE RECORD SERVICES PO BOX 68691 HARRISBURG, PA 17106-869I INFORMATION: (7:00 AM TO 9:00 PM) IN STATE 1-800-932-4600 OUT-OF-STATE 717-391-619Q TDD IN STATE 1-800-228-0676 TDD OUT-OF-STATE 717-391-6191 WWW.DOT,STATE.PA.US WR/T OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 04-872 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due RUSS BERRIE COMPANY, Plaintiff (s) From ASAD JAWAD T/A SAM1E'S CARDS & GIFTS, 19 LOGANS RUN, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS INCLUDING BUT NOT LIMITED TO A 1995 DODGE STATION WAGON, VIN 2B4GH2533SR239781. (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 gamishee(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 $3,353.41 L.L. $.50 Interest FROM DATE OF JUDG 3/1/04 Atty's Comm % Due Prothy $1.00 Arty Paid $37.50 Other Costs Plaintiff Paid Date: APRIL 20~ 2004 (Seal) REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 71%238-7159 Supreme Court ID No. 18041 CURTIS R. LONG Deputy R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee TOTAL $ Advance Costs: Sheriffs Costs: 150.00 91.35 $ 58.65 18.00 21.50 .50 1.00 10.35 20.00 20.00 Refunded to Ally on 12/03/04 91.35 So Answers; C> r:~-~t:pt!~ ; R. Thomas Kline, 'Sheriff \' f't 0 aud-iu C;. ,,-3UuJh~ 'Bytlaudia A. Brewbaker ~r- Sworn and Subscribed to before me This l'fe day of /J.t~ 2004 A.D. ~ (Jivu'J7t7h, ,~ Prot onotary ~ ~. ..-c"" ~y'~ '<;1\ H'q" 1 J,S H.~3d _,.', (' ; iJ I ~ ""'i?l\ ~ = ~ \f\fU \10. ".I l1Z I Il \Id1 ^ ,'O,,'JiWO 'iNO' J ... ,.-' 0 H\\131l<> \p.l .;0 ]~\H \,'>-1) ':1'1..11 'i D..-o R.cu~ /JJ'53"'- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-872 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due RUSS BERRIE COMPANY, Plaintiff (s) From ASADJAWAD T/ASAMIE'SCARDS & GIFTS, 19 LOGANS RUN, ENOLA, PA 17025 (I) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS INCLUDING BUT NOT LIMITED TO A 1995 DODGE STATION WAGON, VIN 2B4GH2533SR239781. (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) Ifproperty 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 $3,353.41 Interest FROM DATE OF JUDG 3/1/04 L.L. $.50 Atty's Cornm % Arty Paid $37.50 Plaintiff Paid Date: APRIL 20, 2004 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) protho~ p ~ ,----By: tY).-L--. Yl.~ r Deputy REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. 18041