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HomeMy WebLinkAbout08-3509 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FINANCIAL PACIFIC LEASING, LLC, as : Assignee of Paramount Financial Services, LLC Plaintiff, V. NO. 0$ - 3609 Civil TerM Maria A. Rosito, Individually and d/b/a La Casa Beauty Boutique and La Casa Beauty Boutique Defendants. PR AFf iPF. TO THE PROTHONOTARY: Pursuant to Pennsylvania Rule of Civil Procedure 3002, enter judgment against the defendant, La Casa Beauty Boutique in the amount of $36,304.27, plus additional attorney's fees, costs, expenses and interest, in accordance with the attached certified copy of all docket entries and the certification of amount of judgment for Docket No. 2007-cv-8653 of Dauphin County, and index said judgment against defendant, La Casa Beauty Boutique. LAMM RUBENSTONE LLC By: J Brian H. Smith, Es/quire Attorney ID No. 65627 3600 Horizon Boulevard, Suite 200 Trevose, PA 19053 (215) 638-9330 Attorneys for Plaintiff Damages assessed and judgment entered as above. 3831681 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FINANCIAL PACIFIC LEASING, LLC, as : Assignee of Paramount Financial Services, LLC Plaintiff, V. NO. Maria A. Rosito, Individually and d/b/a La Casa Beauty Boutique and La Casa Beauty Boutique Defendants. CERTIFICATION OF ADDRESSES TO THE PROTHONOTARY: The address of the Plaintiff, Financial Pacific Leasing, LLC, as Assignee of Paramount Financial Services LLC is 3455 South 3440' Way, Suite 300, Federal Way, Washington 98063 and the last known address of the Defendant, La Casa Beauty Boutique is 6 East Main Street, Camp Hill, Pennsylvania 17011. Dated: ?r LAMM RUBENSTONE-LLC By: / Brian H. Smith, Esglire Attorney ID No. 65627 3600 Horizon Boulevard, Suite 200 Trevose, PA 19053 (215) 638-9330 Attorneys for Plaintiff 3831681 . I , 1 In The Court of Common j9Yeao of Maupbin Countp, 3penn-Opfbania Financial Pacific Leasing, LLC, as Assignee of Paramount Financial Services, LLC 3455 South 344th Way, Suite 300 Federal Way, Washington 98063 VS. Maria A. Rosito, Individually and d/b/a La Casa Beauty Boutique 6 East Main Street Camp Hill, PA 17011 No. 2007-CV-08653-CV CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT I, the undersigned Prothonotary of the Court of Common Pleas of Dauphin County, Pennsylvania, do hereby certify that the attached is a full, true and correct copy of the docket entries in the above captioned case. I further certify that judgment was entered in favor of Plaintiff, Financial Pacific Leasing, LLC, as Assignee of Paramount Financial Services, LLC and against Defendant, Maria Rosito Individually and d/b/a La Casa Beauty Boutique on January 7, 2008 in said case in the amount of $36,304.27 3n Zestimonp Wbereof, I have hereunto set my hand and affixed the seal f e Court, on Friday, May 23, 2008. nL.. Prothonot By; Deputy Date:, 5123/2008 Time: 02:20 PM Page 1 of 3 Filed: Subtype: Comment: Physical File: Y Appealed: N Status History Pending 8/23/2007 Pending / Judgment 1/7/2008 Judge History Date Judge Reason for Removal 8/23/2007 No Judge, Current Payments Receipt Date Type Lamm Rubenstone 149742 1/7/2008 Civil Filing Lamm Rubenstone, LLC 161756 5/23/2008 Miscellaneous Exemplified Record 20.00 Lowe, Sherry D (attorney for Fin. 139256 8/23/2007 Civil Filing Total Miscellaneous Receipts Receipt Date 161756 5/23/2008 Exemplified Record Plaintiff Name: Financial Pacific Leasing Address: Phone: Home: Employer: Litigant Type: Comment: Assignee Attorneys Unterlack, Andrew L Plaintiff Work: (Primary attorney) Name: Paramount Financial Services Address: Phone: Home: Employer: Litigant Type: Comment: Attorneys Unterlack, Andrew L Dauphin County Complete Case History Case: 2007-CV-08653-CV Financial Pacific Leasing, etal. vs. Maria A Rosito, etal. 8/23/2007 Civil Work: (Primary attorney) 20.00 Sum: SSN: DOB: Sex: Send notices: Y Send Notices SSN: DOB: Sex: Send notices: Y Send Notices User: LBECHTEL Amount 18.00 20.00 117.00 155.00 20.00 Date: 5/23/2008 Time: 02-'20 PM Page 2of3 Dauphin County User: LBECHTEL Complete Case History Case: 2007-CV-08653-CV Financial Pacific Leasing, etal. vs. Maria A Rosito, etal. Defendant Name: Rosito, Maria A SSN: Address: DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Defendant Name: La Casa Beauty Boutique SSN: Address: DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Register of Actions 8/23/2007 New Civil Case Filed This Date. No Judge, Filing: Complaint Paid by: Lowe, Sherry D No Judge, (attorney for Financial Pacific Leasing) Receipt number: 0139256 Dated: 8/23/2007 Amount: $117.00 (Check) Plaintiff: Financial Pacific Leasing Attorney No Judge, of Record: Andrew L Unterlack Plaintiff: Paramount Financial Services No Judge, Attorney of Record: Andrew L Unterlack Complaint filed. No Judge, 9/7/2007 Complaint: Sheriff's Return filed stating No Judge, service was completed. So answers J.R. Lotwick, Sheriff. Maria A Rosito (Cumberland Co) Assigned to Dauphin Co Sheriffs Office Service fee $80.00 Served 9/7/2007 Complaint: Sheriffs Return filed stating No Judge, service was completed. So answers J.R. Lotwick, Sheriff. La Casa Beauty Boutique (Cumberland Co) Assigned to Dauphin Co Sheriffs Office Service fee $0.00 Served 9/7/2007 9/12/2007 Complaint: Sheriffs Return filed stating No Judge, service was completed. So answers J.R. Lotwick, Sheriff. Maria A Rosito Assigned to Dauphin Co Sheriffs Office Service fee $0.00 Served 9/12/2007 1/7/2008 Filing: Judgment Paid by: Lamm No Judge, Rubenstone Receipt number: 0149742 Dated: 1/7/2008 Amount: $18.00 (Check) Date:. 5/23/2008 Dauphin County User: LBECHTEL ' , Time: 01:20 PM Complete Case History Page 3 of 3 Case: 2007-CV-08653-CV Financial Pacific Leasing, etal. vs. Maria A Rosito, stal. Register of Actions 1/7/2008 Default Judgment is entered in favor of No Judge, Plaintiff and against Defendant(s) Maria Rosito, individually and d/b/a La Casa Beauty Boutique and La Casa Beauty Boutique in the amounts as follows: (a) Remaining Rental Payments: $30153.9: (including Residual Value) (b) Sales Tax: $1809.23 (c) Delinquent Late Charges: $294.97 (d) Default Penalty: $3015.39 (e) Return Check Fees: $105.00 (f) Insurance Premiuns: $79.76 (g) Miscellaneous Collection Expense: $96.00 (h) Attorney's fees: $750.00 (as alleged at paragraph 15 of the Complaint) TOTAL: $36304.27 for failure to answer Plaintiff's Complaint. See Praecipe & Notice filed. Copies of all documents mailed. Judgment Order date In Favor Of Disposition Judgment 01/07/2008 Plaintiff 01/07/2008 Open Default Comment: 36304.27 Plaintiff: Financial Pacific Leasing Paramount Financial Services Defendant: La Casa Beauty Boutique Rosito, Maria A I hereby bertify that the foregoing is a true and corKect copy of t1le original filed. Prothonotary/Clerk of Courts C6 COPIES OFALL DOCUMM MAILED i 2008 JAN7? AM 11= 02 0AUPHIN CG" ?i'i Y PENNA IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA FINANCIAL PACIFIC LEASING, LLC 3455 South 344th Way, Suite 300 Federal Way, Washington 98063 Plaintiff V. MARIA ROSITO, Individually and d/b/a La Casa Beauty Boutique 2128 Chatham Way Harrisburg, PA 17110 and LA CASA BEAUTY BOUTIQUE 6 East Main Street Camp Hill, PA 17011 Defendants CIVIL ACTION NO. 2007-ev-8653 MAY 2 3 P,-nA- { hereby cmrtily that t 3 foregoing is a true and correct copy of the original filed. pr... o tho I tary TO: Maria Rosito, individually and d/b/a La Casa Beauty Boutique 2128 Chatham Way Harrisburg, PA 17110 La Casa Beauty Boutique 6 East Main Street Camp Hill, PA 17011 373729_ I.DOC I 1 . . NOTICE PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE HEREBY NOTIFIED THAT JUDGMENT HAS BEEN ENTERED AGAINST YOU IN THE ABOVE PROCEEDING AS INDICATED BELOW. PROTHONOTARY X Judgment by Default X Money Judgment X Judgment in Replevin X Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings c rr ` ;?' l ' o - tv IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE; PLEASE CALL ATTORNEY: ALAN M. ROSEN, ESQUIRE AT THIS TELEPHONE NUMBER: (215) 638-9330. 373729-1 IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA FINANCIAL PACIFIC LEASING, LLC 3455 South 344th Way, Suite 300 Federal Way, Washington 98063 Plaintiff V. MARIA ROSITO, Individually and d/b/a La Casa Beauty Boutique 2128 Chatham Way Harrisburg, PA 17110 CIVIL ACTION NO. 2007-cv-8653 and LA CASA BEAUTY BOUTIQUE 6 East Main Street Camp Hill, PA 17011 Defendants PRAECIPE FOR DEFAULT JUDGMENT c? u+ G - L1 ? CL N Please enter a judgment by default in favor of Plaintiff, Financial Pacific Leasing, LLC, and against Defendants, Maria Rosito, individually and d/b/a La Casa Beauty Boutique and La Casa Beauty Boutique. The Defendant, La Casa Beauty Boutique, was served with the Complaint on September 7, 2007 and the Defendant, Maria Rosito, individually and d/b/a La Casa Beauty Boutique was served with the Complaint on September 12, 2007. The Defendants' Answers were due to be filed on September 27, 2007 and October 2, 2007, respectively, and to date no responsive pleadings to the Complaint has been filed. True and correct copies of the Affidavits of Service are attached hereto as Exhibit "A." Attached as Exhibit "B" are copies of Plaintiffs written Notices of Intention to File Praecipe for Entry of Default Judgment which I certify were caused to be mailed First Class 373729-1 Mail, postage prepaid by Certificate of Mailing, addressed to the Defendants at their last known addresses on October 1, 2007 and October 3, 2007, which is at least ten (10) days prior to the filing of this Praecipe. Please enter judgment in favor of Plaintiff, Financial Pacific Leasing, LLC, and against Defendants, Maria Rosito, individually and d/b/a La Casa Beauty Boutique and La Casa Beauty Boutique, jointly and severally, for possession of the Equipment, or in the alternative, its equivalent value, plus continuing late charges, attorneys' fees, costs of suit and such other and further relief as this Honorable Court shall deem just and proper, pursuant to Count II of the Complaint and assess damages pursuant to Count I of the Complaint, in the amount of $36,304.27, plus additional attorney's fees, costs, expenses and interest; as they continue to accrue, and such other relief as this Honorable Court deans just and proper, as follows: LEASE (a) Remaining Rental Payments $30,153.92 (includes Residual Value) (b) Sales Tax 1,809.23 (c) Delinquent Late Charges 294.97 > m d Default Penal 3,015.39 (e) Return Check Fees 105.0°_ (f) Insurance Premiums 79.70 m - 'J C) (g) Miscellaneous Collection Expense 96.06T,c - (h) Attorney's fees 750.00 s ?° r (as alleged at paragraph 15 of the Complaint) n°.? TOTAL 373729-! $36,304.27 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR THE SPECIFIC RELIEF REQUESTED AND SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. LC LAMM RU =C By: Alan M. Rosen, Esquire Attorney I.D. No. 34753 3600 Horizon Blvd., Suit Trevose, PA 19053 Phone: (215) 638-9330 Attorneys for Plaintiff C e 20Q 'z? c... 0 rw AND NOW, this day of-:Sa-pUaI 2008, JUDGMENT FOR MONEY DAMAGES IS ENTERED IN FAVOR OF THE SAID PLAINTIFF Financial Pacific Leasing, LLC, and against Defendants, Maria Rosito, individually and d/b/a La Casa Beauty Boutique and La Casa Beauty Boutique by default for want of an Answer for possession of the Equipment, or in the alternative, its equivalent value, plus continuing late charges, attorneys' fees, costs of suit and such other and further relief as this Honorable Court shall deem just and proper, pursuant to Count II of the Complaint and assess damages pursuant to Count I of the Complaint, in the amount of $36,304.27, plus additional attorney's fees, costs, expenses and interest, as they continue to accrue, and such other relief as this Honorable Court deems just and proper. Pro ongtaly. 373729-I 1 0 1 nrE1LVEO OFFIC OF 1008 JAN -7 AM If: 03 DAUPHIN COUN'll'Y PENNA EXHIBIT "A" I . , , , , Mary Jane Snyder /-^jfisE 0# CEP o$heriff Charles E. Sheaffer William T. Tully Solicitor Dauphin County . Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin c7 N c C- 2 C . '. s w? VC t?J Sheriff's Return No.8653-CV - - -2007 AND NOW:September 7, 2007 at 2:06PM served the within COMPLAINT upon ROSITO MARIA A D/B/A LA CASA BEAUTY by personally handing BOUTIQUE (CUMBERLAND CO) to DEFENDANT 1 true attested copy(ies) of the original COMPLAINT and making known to him/her the contents thereof at 6 EAST MAIN ST SHIREMANSTONN, PA 17011-0000 So Answers, Sheriff of Dauphin County, Pa. Plaintiff: FINANCIAL PACIFIC LEASING LLC AS ASSIGNEE OF PARAMOUNT FINANCIAL SERVICES Sheriff's Costs: $80.00 PD 09/04/2007 RCPT NO 234470 Michael W. Rinehart Assistant Chief Deputy Mary Jane Snyder William T. Tully Solicitor Office of *e *4rriff Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 7SM590 fm (717) 255-2889 Jack LotMck Sheriff Commonwealth of Pennsylvania County of Dauphin Sheriff's Return No.8653--CV - - -2007 Charles E. Sheaffer Michael W. Rinehart Assistant Chief Deputy C) rv g c C- r.. y.i 0 W AND NOW:September 12, 2007 at 12:30PM served the within COMPLAINT upon ROSITO MARIA A by personally handing to MR. ROSITO, HUSBAND OF MARIA 1 true attested copy(ies) of the original COMPLAINT and making known to him/her the contents thereof at 2128 CHATHAM WAX HBG, PA 17110-0000 So Answers, Sheriff of Dauphin County, Pa. IMHOF Plaintiff: FINANCIAL PACIFIC LEASING LLC AS ASSIGNEE OF PARAMOUNT FINANCIAL SERVICES Sheriff's Costs: $80.00 PD 09/04/2007 RCPT NO 234470 . I EXHIBIT "B" 1008 JAN -1 AM 11.03 DAUPPENNAUr"i Y ,HIVED --n08JAH -7 AN 11: 03 DAUPHiN GOWN] PENNA IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA FINANCIAL PACIFIC LEASING 3455 South 344th Way, Suite 300 Federal Way, Washington 98063 Plaintiff V. MARIA ROSI TO, Individually and d/b/a La Casa Beauty Boutique 2128 Chatham Way Harrisburg, PA 17110 and LA CASA BEAUTY BOUTIQUE 6 East Main Street Camp Hill, PA 17011 Defendants TO: La Casa Beauty Boutique 6 East Main Street Camp Hill, PA 17011 I CIVIL ACTION I NO. 2007-ov-8653 Date: October 1, 2007 372575-1 t f NQnCE - RULE 237.1 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (101 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. DAUPHIN LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, Pennsylvania 17101 (717) 232-7536 LAMM RUBENSTONE LESAVOY BUTZ & DAVID LLC By: `IAAIM- Sherry D. Lowe, Esquire Andrew L. Unterlack, Esquire Attorneys for Plaintiff Attorney I.D. Nos. 66096 / 94166 3600 Horizon Blvd., Suite 200 Trevose, PA 19053 Phone: (215) 639-9330 rs c; 0 i 0 w "W C1 372575-1 . , $ . d ' 2C p.' : rr C.) ?. O w IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PA FINANCIAL PACIFIC LEASING, LLC Plaintiff V. CIVIL ACTION No. 06 - 01525 MARIA ROSITO, Individually and d/b/a La Casa Beauty Boutique, and LA CASA BEAUTY SALON Defendants. TO: Maria Rosito, individually and d/b/a La Casa Beauty Boutique 2128 Chatham Way Harrisburg, PA 17110 Date: October 3, 2007 NOTICE, RULE 237.1 IMPORTANT NOTICE . YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A VWMN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (101 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 372573-1 IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER DAUPHIN LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, Pennsylvania 17101 (717} 232-7536 LAMM RUBENSTONE LESAVOY BUTZ & DAVID LLC By: 4 Sherry D. Lowe, Esquire Andrew L. Unterla* Esquire Attorneys for Plaintiff Attorney I.D. Nos. 66096 / 94166 3600 Horizon Blvd., Suite 200 Trevose, PA 19053 Phone: (215).638-9330 0 m 0 i Zc-- r.: b r v a Z O CA) 372573-1 1 ? ? ? . I ooe P? olOrarwfr ?' ? U.S. POSTAL SERVICE Peoa%vd Fmm: L R L One piece of WdbWy mel afteuW 1e: AA. ?1 , 1 PS Form 3617, 3 ?1a a l 00 J N © O Q ? (31 ;?7 '/v1LLE p\ OCT 01 2007 U MML. DOES NOT N d c^ w .. o . ca B, J A a 3- in"." i1SPa ? y J» N O 'D ?iYi 111 h ) ' , , j . , 1 IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA PACIFIC LEASING, LLC Plaintiff MARIA ROSITO, V* Individually and d/b/a La Casa Beauty Boutique and LA CASA BEAUTY BOUTIQUE Defendants CIVIL ACTION D w cc NO. 2007-cv4653 b= z y 1 , r: W AFFIDAVIT OF LAST KNOWN ADDRFM I, Linda L. Bush, of full age, being duly sworn according to law, depose and say that 1 am a litigation specialist employed by the Plaintiff, that I am authorized to make this Affidavit on behalf of Plaintiff, that to the best of my knowledge, information and belief, the last known address of the above-named Defendant, Maria Rosito, individually and d/b/a La Casa Beauty Boutique is 2128 Chatham way, Harrisburg, Pennsylvania 17110. Sworn subs M before me this day of • 2009. y 14 ota?y Public V. IJ 1 Co to Wt 1 i..?.. ]937!9-1 9?, Linda L. Bush , t' , 1 I • IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA PACIFIC LEASING, LLC Plaintiff v MARIA ROSM), V. Individually and d/b/a La Can Beauty Boutique and LA CASA BEAUTY BOUTIQUE Defendants C c? D cm CIVIL ACTION z - 1 -r M NO. 2007-cv-8653 = c. G r-j ?y -? C.-) rn - O tv AFFIDAVIT OF NON-MILITARY SERVICE I, Linda L. Bush, of full age, being duly sworn according to law, upon my oath, depose and say that I wn a litigation specialist employed by the Plaintiff, that I am authorized to make this Affidavit on behalf of Plaintiff that to the best of my knowledge, information and belief, the above-named Defendant, La Casa Beauty Boutique is a company and acoazdb*y the Defendant is not subject to the Military Service of the United States, nor any other State or Territory thereof or its allies as defined in the Soldier's and Sailor's Civil Relief Act of 1940, and the Amendments thereto. Sworn and Snbecn d before me this day of 2008. • J Notary Public 373729-1 Lin& L. Bush R s * I 4 I . N ;,i l'Yf.U ??11 HG?O?xAk 2008JAN -? AM I t s 03 CIVIL ACTION NO. 2007-cv-8653 AFFIDAVIT OF LAST KNOWN ADDRESS I, Linda L. Bush, of full age, being duly sworn according to law, upon my oath, depose IN THE COURT OF COMMON PLEAS DAUPH EN COUNTY, PENNSYLVANIA UAUFPENNA?H"" FINANCIAL PACIFIC LEASING, LLC Plaintiff V. MARIA ROSITO, Individually and d/Wa La Casa Beauty Boutique and LA CASA BEAUTY BOUTIQUE its and say that I am a litigation specialist employed by the Plaintiff, that I am authorized to make this Affidavit on behalf of Plaintiff, that to the best of my knowledge, information and belief, the last known address of the above-named Defendant, Ut Casa Beauty Boutique is b But Main Street, Camp Hill, Pennsylvania 17011. W Linda L. Bush Sworn to and Subscribed before me this day of J,*, t?..-4 , 2008. • LAC o- G???-.--C/L_ Notary Public 373719•[ ?o?A! y % .04t% 512312008 Time: 02:20 PM Received of: Lamm Rubenstone, LLC Dauphin County Receipt Twenty and 00/100 Dollars NO. 0161756 Page 1 of 1 $ 20.00 Case: 2007-CV-08653-CV Plaintiff: Financial Pacific Leasing, etal. vs. Maria A Rosito, etal. Amount Exemplified Record 20.00 Total: Check:103375 Payment Method: Check Amount Tendered: Clerk: LBECHTEL 20.00 20.00 Stephen E Farina, Prothonotary Rv Deputy Clerk -60- O CZ3 rrx?1 s 13 ` 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FINANCIAL PACIFIC LEASING, LLC, as : Assignee of Paramount Financial Services, LLC Plaintiff, V. NO. Maria A. Rosito, Individually and d/b/a La Casa Beauty Boutique and La Casa Beauty Boutique Defendants. i TO: La Casa Beauty Boutique 6 East Main Street Camp Hill, Pennsylvania 17011 NOTICE PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE HEREBY NOTIFIED THAT JUDGMENT HAS BEEN ENTERED AGAINST YOU IN THE ABOVE PROCEEDING AS INDICATED BELOW. PROTHONOTARY X Judgment by Default X Money Judgment X Judgment in Replevin X Judgment for Possession Judgment on Award of Arbitration 3831681 I Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL, ATTORNEY, BRIAN H. SMITH, ESQUIRE, AT THIS TELEPHONE NUMBER: (215) 638-9330. (1/10/08 Prothonwicv.y 3831681 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FINANCIAL PACIFIC LEASING, LLC 3455 South 344th Way, Suite 300 Federal Way, Washington 98063 CIVIL ACTION Plaintiff V. NO. 2008-3509 MARIA ROSITO, Individually and d/b/a La Casa Beauty Boutique 2128 Chatham Way Harrisburg, PA 17110 and : LA CASA BEAUTY BOUTIQUE 6 East Main Street Camp Hill, PA 17011 Defendants PRAECIPE FOR WRIT OF EXECUTION Money Judgment TO THE PROTHONOTARY OF CUMBERLAND COUT T ? -. ISSUE WRIT OF EXECUTION UPON A JUDGMENT IN THE ABOVE MATTER, (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) Against La Casa Beauty Boutique 6 East Main Street Camp Hill Pennsylvania 17011, Defendant; and (3) index this writ in the judgment index (a) Against La Casa Beauty Boutique Defendant; and as a lis pendens against real property of the defendant as follows: 3848911 . . LEVY: upon all personal/business property and business assets of any kind or sort, including but not limited to CASH, tools, equipment, furniture, office eguipment, telephones, computers, radio/stereo equipment, tables, chairs, televisions, VCR's, DVD's, desks, motor vehicles or any other personal/business property of any kind and as outlined in the attached Schedule A at 6 East Main Street, Camp Hill, PA 17011. (5) Amount due $ 36,304.27 Interest from 6/10/2008 to 7/23/2008 $ 256.71 At a rate of statutory 6% Interest from 7/23/2008 to $ At a rate of statutory 6% Costs to be added $ Brian H. Smith, squire Lamm Rubenstone LLC 3600 Horizon Boulevard, Suite 200 Trevose, PA 19053 (215) 638-9330 Attorneys for Plaintiff' 3848911 ? ? ?7L }: aJ ? ? ',?` ????? ? ? ?. .? Y ?A ? ? Fv - • ?... E ? ,... !c_s - ; ?.. L _ ... `,,a C? } ? ? ?- - --! ?f. -µ f f?..M ^?i ? . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-3509 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FINANCIAL PACIFIC LEASING LLC Plaintiff (s) From LA CASA BEAUTY BOUTIQUE 6 EAST MAIN STREET, CAMP HILL PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell UPON ALL PERSONAL/BUSINESS PROPERTY AND BUSINESS ASSETS OF ANY KIND OR SORT INCLUDING BUT NOT LIMITED TO CASH-TOOLS-EQUIPMENT-FURNITURE-OFFICE EQUIPMENT-TELEPHONES-COMPUTERS-RADIO/STEREO EQUIPMENT-TABLES- CHAIRS-TELEVISIONS-VCR'S- DVD'S- DESKS-MOTOR VEHICLES OR ANY OTHER PERSONAL/BUSINESS PROPERTY OF ANY KIND AND AS OUTLINED IN THE ATTACHED SCHEDULE A AT 6 EAST MAIN STREET CAMP HILL PA 17011. (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 $ 36,304.27 L.L.$0.50 Interest FROM 6/10/08 TO 7/23/08 AT A RATE OF STATUTORY 6% $256.71 Atty's Comm % Atty Paid $55.50 Plaintiff Paid Due Prothy $2.00 Other Costs Date: JULY 309 2008 (Seal) s .s R. Long, Proflionotal? 'Irx- r, By: )R.,, Deputy REQUESTING PARTY: Name BRIAN H SMITH ESQ LAMM RUBENSTONE LLC Address: 3600 HORIZON BOULEARD SUITE 200 TREVOSE, PA. 19053 Attorney for: PLAINTIFF Telephone: (215) 638-9330 Supreme Court ID No. 65627 . '. SCHEDULE A 474225.901 LEASE # Thin Schedule A is to be atudod to and beoome pat of that llgttipment Leue Agreement dated 1121/ 07 .200 by and beta= tho Uden%Wd and Partsnonnt Randal Satvices, Li,C, an Atizgnz..li> *Cd liability coaap;oi vendor(s): SunFX Pro USA 7525 Metropolitan Drive, Suite 301-302 San Diego, CA 92.108 , + SCHEDULE A. QrY DB800-nOlf SN'S= 3892, 3381, AND 3954 LEASE # Titis Schedule A is to be,t u &d wand bmim part of tlut Bquiprreat Leaae Agreement dated 200 by and brit$ & 4 Faraa mmFm xW Sarvicea, LLC, an Arizona lb&4 li"TY Qom any. 3 SunFX Pro. Series System 3 SunFX Training including Bronzes Solution .3 Bztia.Gtin 3 2 Bottles:ech; Solution.#1; Solution #2, Solution #3 3 1 each d Cutter 0o6 Lotto,n Body Polio 3 , , . 1 each Body Tan in a Can Glow All- Over Bd, l: QIT 17 RDMQF Glow All Over Bogy Polish 12 Glaw All Over Body Wash ? ?=°?• .. _ . - 1. :?ver?aicdor?toisturi?ers - - ,r ?.'• {'i1bw'1~?)v?r Bl?y??er ?;. _ ? , . y; 12 'Glow ll,0yer Tan in a Can 300 Pairs Sticky Feet 600 SunFX Care Brochures 3 Tan Tent 3 Set SunFX Promotional Poster's 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: 56.61 Docketing $ 18.00 93.39 Poundage 1.11 Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 09/09/08 Milage 15.00 Surcharge 20.00 Levy Post Pone Sale Garnishee Postage TOTAL $ 56.61 R jtObl ?- So Answers; rThiomas. Kline, Sh By -nc?.?dl4 a vC13? Cie- 4 S? PS- a,,, a?gyal a b L, 0 `o WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-3509 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FINANCIAL PACIFIC LEASING LLC Plaintiff (s) From LA CASA BEAUTY BOUTIQUE 6 EAST MAIN STREET, CAMP HILL PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell UPON ALL PERSONAL/BUSINESS PROPERTY AND BUSINESS ASSETS OF ANY KIND OR SORT INCLUDING BUT NOT LIMITED TO CASH-TOOLS-EQUIPMENT-FURNITURE-OFFICE EQUIPMENT-TELEPHONES-COMPUTERS-RADIO/STEREO EQUIPMENT-TABLES- CHAIRS-TELEVISIONS-VCR'S- DVD'S- DESKS-MOTOR VEHICLES OR ANY OTHER PERSONAL/BUSINESS PROPERTY OF ANY KIND AND AS OUTLINED IN THE ATTACHED SCHEDULE A AT 6 EAST MAIN STREET CAMP HILL PA 17011. (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 $ 36,304.27 L.L.$0.50 Interest FROM 6/10/08 TO 7/23/08 AT A RATE OF STATUTORY 6% $256.71 Atty's Comm % Atty Paid $55.50 Plaintiff Paid Date: JULY 30, 2008 (Seal) Due Prothy $2.00 Other Costs Al C"'. P. 41, / Curtis R. Long, Prothonotiry By: -T )kJ Deputy REQUESTING PARTY: Name BRIAN H SMITH ESQ LAMM RUBENSTONE LLC Address: 3600 HORIZON BOULEARD SUITE 200 TREVOSE, PA. 19053 Attorney for: PLAINTIFF Telephone: (215) 638-9330 Supreme Court ID No. 65627 i I'RO TN0! OT ? ; 211211AR 28 Hi 1* 14 CUMBERLAND COUNT PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FINANCIAL PACIFIC LEASING, LLC, Plaintiff, V. CASE NO. 2008-3509 MARIA ROSITO, individually and d/b/a LA CASA: BEAUTY BOUTIQUE and LA CASA BEAUTY BOUTIQUE Defendants. PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly mark the judgment in the above-captioned case as VACATED. DATED:312,0 // L LAMM RUBENSTONE LLC Linda Alle-Murphy Attorneys for Plaintiff 433292_1.DOC433292_1.DOC