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
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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