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Home My WebLink About08-6764.1 11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARYWOOD UNIVERSITY Plaintiff No. d8 -`74. / vs. JEREMY GRAD CIVIL ACTION Defendant PRAECIPE FOR TRANSFER OF JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: (1i .,- C_? Kindly enter judgment in favor of Plaintiff and against the above-named defendant(s), pursuant to Pa.R.C.P.D.J. No.402(D), for failure of defendant(s) to appeal, within 30 days, a judgement entered July 16, 2008 against the above-named defendant(s) before District Justice Daniel O'Donnell, as set forth in the transcript of judgment, which is attached hereto. Assess damages as follows: Judgment Amount 6,717.61 v/ Post Judgment Interest (from July 16, 2008 to November 5, 2008 at 6% per annum) 126.08 Payments Total $6,843.69 Dated: November 5, 2008 AMATO AND ASSOCIATES, P.C. By: 5D_?_ ald 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 2080737 CQMMONWEALTH OF PENNSYLVANIA COl1NTY nF• LUZERNE . Mag. Dist. No.: . ' 11-3-03 MDJ Name: Hon. DANIEL O'DONNELL Address: 5 S MAIN ST 'SUITE 6 SUGARLOAF, PA Telephone: (570 ) 788-1191 18249 DANIEL O' DONNZLL 5 S MAIN ST SUITE 6 SUOARLOAF, PA 18249 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JUDGMENT PLTF NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rMARYMOD UNIVERSITY 107 N COMMERCE WAY APT/STE 100 C/O MICHAEL-LESSA LBETBLESEM, PA 18017 J VS. DEFENDANT: NAME and ADDRESS r-oxim, JEREMY 109 MISTY LADE DRUMS, PA 18222 L J Docket No.: CV-0000136-08 Date Filed: 6/12/08 (Date of Judgment) 7/16/08 rX1 Judgment was entered for: (Name) MARYWOOD UNIVERSITY 71 Judgment was entered against: (Name) GRAD, JEREMY in the amount of $ 6, 717.6 Defendants are jointly andseverally liable. ? Damages will be assessed on Date & Time This case dismissed without prejudice. ? Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 6,587.61 Judgment Costs $ 130.00 Interest on Judgment $ .00 Attorney Fees $ .1010 Total $ 6,717.61 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. Date I certify that this is a true and c re ~( Date My commission expires first Monday of January, 2012 AOPC 315-07 DATE PRINTED: 7/16/08 9:44:00 AM w PZ Magisterial District?Judge the proceedings containing We juj$ment. Magisterial District Judge SEAL n ? o lC=lb n 477=vIT OF No A2pxA - NOVEMBER 5, .2008 MARYWOOD UNIVERSITY District U-Mstics Docket Nt=mber; CV-136-08 Plaintiff VS. JEREMY GRAD Defendant As of NOVEMBER 5, 2008 A District J'astics appeal has not been filed in the Court of Common $lsas of L U Z E R N E County im tha above captioned matter. Ronald Amato, Esquiie, Attorney for the Plaintiff 1 J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARYWOOD UNIVERSITY Plaintiff VS. JEREMY GRAD Defendant No. 08 - ta7`y CIVIL ACTION CERTIFICATION OF ADDRESSES C- 15?jn I do certify that the precise last known address of the within named plaintiff is: C/o Ronald Amato, Esquire 107 North Commerce Way Bethlehem PA 18017 I do certify that the precise last known address of the within named defendant is: 1408 Bradley Dr, Apt. 211 Carlisle PA 17013 AMATO A ASSOCIATES, P.C. By: ald 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 o r ?-- Z 2c Qrn COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARYWOOD UNIVERSITY Plaintiff No. 1C6 - LILY VS. JEREMY GRAD : CIVIL ACTION Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHAMPTON ?J • l.. lu• L C L . 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 Jeremy Grad is over 18 years of age, resides at 1408 Bradley Dr, Apt. 211, Carlisle PA 17013 and is employed; Sworn to and subscribed before me this k ? day of CbO 2008 A.D. NOTAR UBLIC NOTARIAL ML GEOFFREY Q SCHOEN-= ;:t NoWl Public NANOMTOWNMEP, NORTHAMPTON 0M1Y My Ca¦dinia ExpUN M- n' 29, 2012 P?j v 1:1" m y A CD rtt l?.w' •S ') I ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARYWOOD UNIVERSITY Plaintiff No. ?g _ y'1`Lf VS. ll JEREMY GRAD CIVIL ACTION (21UZL'7'zAv7 Defendant NOTICE OF JUDGMENT (XX) NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST THE ABOVE-NAMED DEFENDANT(s) IN THE AMOUNT OF $16V7.1.I ON II/ly , 2008. ( ) A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN JUDGMENT IS/ARE ENCLOSED. PROTHONOTARY - CUMBERLAND COUNTY Per: /g, Zt4 l If you have any questions concerning the above, please contact the undersigned. AMATO AN ASSOCIATES, P.C. By: Wald 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 f MARYWOOD UNIVERSITY 41 Plaintiff : No. 08-6764 Civil VS. JEREMY GRAD 14o g &nd 1 ey Dr, Ap+ 411 0O rhale , PA 11013 Defendant(s) PRAECIPE FOR WRIT EXECUTION (MONEY JUDGMENT) 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 eauipment inventory, tools vehicles, electronic eauipment, any and all other personal property belonging to the above- named defendant(s). (2) against JEREMY GRAD, 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 $ 6,717.61 Statutory Interest From 7/16/08 $ 242.31 Less Payment $ 0.00 Costs $ Poundage $ Total $ 6,959.92 AMATO AND ASSOCIATES, P.C. By: Date:February 23. 2009 Ronald Amato Attorney I.D. No. 32323 Attorney File#: 2080737 Attorneys for Plaintiff fl Fl/ U T 7U Es -J R ? ?y. c; 7IC "? f t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARYWOOD UNIVERSITY Plaintiff VS. JEREMY GRAD Defendant(s) No. 08-6764 Civil CIVIL ACTION CERTIFICATION OF DEFENDANT(s) ADDRESS FOR SERVICE I 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: 1408 Bradley Dr, Apt. 211 Carlisle PA 17013 Dated:Februarv 23. 2009 AMATO AND ASSOCIATES, P.C. By: - - Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff Attorney File #:2080737 ° C> ..a c n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARYWOOD UNIVERSITY Plaintiff No. 08-6764 Civil VS. JEREMY GRAD . CIVIL ACTION Defendant(s) WAIVER OF WATCHMAN To the Sheriff: Any deputy sheriff levying upon or attaching any property under the within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before the sheriff's sale thereof. Dated: February 23, 2009 AMATO AND ASSOCIATES P.C. By: 'Ronald 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 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Attorney File #: 2080737 ? ?'' ?ri ? ? ? rsl*: ,, ???? s? ?, . r ? ? ?r7 ' ". ? ? . ,?^ Z- -'' K .?.? ? ?1 '~'7 A, siM' ?.u ?! .I'' C r = t ..+ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARYWOOD UNIVERSITY Plaintiff : No. 08-6764 Civil VS. JEREMY GRAD : CIVIL ACTION Defendant WRIT OF EXECUTION NOTICE THIS PAPER IS A WRIT OF EXECUTION. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD OR TAKEN TO PAY THE JUDGMENT. YOU MAY HAVE LEGAL RIGHTS TO PREVENT YOUR PROPERTY FROM BEING TAKEN. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY OF THESE RIGHTS. IF YOU WISH TO EXERCISE YOUR RIGHTS, YOU MUST ACT PROMPTLY. THE LAW PROVIDES THAT CERTAIN PROPERTY CANNOT BE TAKEN. SUCH PROPERTY IS SAID TO BE EXEMPT. THERE IS A DEBTOR'S EXEMPTION OF $300. THERE ARE OTHER EXEMPTIONS WHICH MAY BE APPLICABLE TO YOU. A SUMMARY OF SOME OF THE MAJOR EXEMPTIONS ARE LISTED ON THE NEXT PAGE. YOU MAY HAVE OTHER EXEMPTIONS OR OTHER RIGHTS. IF YOU HAVE AN EXEMPTION, YOU SHOULD DO THE FOLLOWING PROMPTLY: (1) FILL OUT THE ATTACHED CLAIM FORM AND DEMAND FOR A PROMPT HEARING (2) DELIVER THE FORM OR MAIL IT TO THE SHERIFF'S OFFICE AT THE ADDRESS NOTED. YOU SHOULD COME TO COURT READY TO EXPLAIN YOUR EXEMPTION. IF YOU DO NOT COME TO COURT AND PROVE YOUR EXEMPTION, YOU MAY LOSE SOME OF YOUR PROPERTY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARYWOOD UNIVERSITY Plaintiff VS. JEREMY GRAD Defendant(s) To the Sheriff: No. 08-6764 Civil CIVIL ACTION CLAIM FOR EXEMPTION I, the above-named defendant, claim exemption of property from levy or attachment: (1) From my personal property in my possession which has been levied upon, (a) I desire that my $300 statutory exemption be (i) set aside in kind (specify property to be set aside in kind): (ii) paid in cash following the sale of the property levied upon; or (b) I claim the following exemption (specify property and basis of exemption): (2) From my property which is in the possession of a third party, I claim the following exemptions: (a) my $300 statutory exemption: _ in cash; _ in kind(specify property): ; (b) Social Security benefits on deposit in the amount of $ ; (c) other (specify amount and basis of exemption): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: Defendant THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY: One Courthouse Sq., Carlisle, PA 17013 717/240-6195 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300.00 STATUTORY EXEMPTION 2. BIBLES, SCHOOL BOOKS, SEWING MACHINES, UNIFORMS AND EQUIPMENT 3. MOST WAGES AND UNEMPLOYMENT COMPENSATION 4. SOCIAL SECURITY BENEFITS 5. CERTAIN RETIREMENT FUNDS AND ACCOUNTS 6. CERTAIN VETERAN AND ARMED FORCES BENEFITS. 7. CERTAIN INSURANCE PROCEEDS 8. SUCH OTHER EXEMPTIONS AS MAY BE PROVIDED BY LAW WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-6764 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MARYWOOD UNIVERSITY, Plaintiff (s) From JEREMY GRAD, 1408 Bradley Drive, Apt 211, Carlisle, PA 17013 (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 defendant . (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 $6,717.61 Interest statutory from 7/16/08 - $242.31 Atty's Comm % Atty Paid $53.75 Plaintiff Paid Date: 3/09/09 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs PC- s R. Lo otary By: Deputy REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: AMATO AND ASSOSCIATES PC 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone : 610-866-0400 Supreme Court ID No. 32323 Sheriffs Office of Cumberland County R Thomas Kline 401" st €urp,ypt?l Edward L Schorpp Sheri Fr" Solicitor Ronny R Anderson Jody S Smith Chief Deputy cE OF THE SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/04/2009 08:10 AM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2009, 2009 at 0810 hours, he attempted to serve a true copy of the within writ of execution, upon the defendant, to wit: Jeremy Grad at 1408 Bradley Drive, Apt. 211, Carlisle, Cumberland County, Pennsylvania 17013. At that time it was learned that the defendant had moved. A post office check revealed a new address of 109 Misty Lane, Drums, PA 18222. 05/07/2009 R. Thomas Kline Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiff. SHERIFF COST: $45.90 -/ s-/e 7 /b q 9 -- SO ANSWERS, May 07, 2009 R THOMAS KLINE, SHERIFF or- By: Sharon R. Latnt ?S - 0 ? N a -s 1 31. J J CCXD) ? ? ua1 ?..GgyV`f e A Y P3 t 4 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-6764 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MARYWOOD UNIVERSITY, Plaintiff (s) From JEREMY GRAD, 1408 Bradley Drive, Apt 211, Carlisle, PA 17013 (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 defendant . (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 $6,717.61 L.L. $.50 Interest statutory from 7/16/08 -- $242.31 Atty's Comm % Due Prothy $2.00 Atty Paid $53.75 Plaintiff Paid Other Costs Date: 3/09/09 (Seal) /;L 4x 64? s R , othono By: Deputy REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: AMATO AND ASSOSCIATES PC 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone: 610-866-0400 Supreme Court ID No. 32323 • - Sheriffs Office of Cumberland County R Th6mas Kline ?„ iv er am;, rf Sheriffs Ronny R Anderson ChiejDeputy 0FR;E Edward L Schorpp Solicitor Jody S Smith Civil Process Sergeant r Plaintiff Defendant Marywood University VS, Jeremy Grad L J Attorney for the Plaintiff: Sheriffs Sale Date: Ronald Amato Writ of Execution No.: 08-6764 107 North Commerce Way Bethlehem, PA 18017 Advance Sheriff Costs: 150.00 Location of the real estate: Sheriff Costs Docketing 18.00 Service Mileage 4.50 Poundage 0.90 Surcharge 20.00 Prothonotary, ... 2.00 Law Library 0.50 Total Sheriff Costs 45.90 Judgment Costs Judgment 6,717.61 Interest 242.31 Misc. Costs Atty paid 53.75 TotalJudgment Costs 7,013.67 Receipts Advance Costs (03-13-09) $ 150.00 Total Receipts $ 150.00 Distribution Paid to Atty/Plaintiff $ 104.10 Paid to Sheriff's Costs 45.90 Total Distribution $ 150.00 Sheriffs poundage cost will be calculated according to the current law and added to the Sheriffs, costs after the sale. Cunberland County Sheriff, Carlisle, Pennsylvania, 17013, (717) 240-6390, (717) 240-6397 (fax) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARYWOOD UNIVERSITY Plaintiff No. 08-6764 Civil vs. JEREMY GRAD G CIVIL ACTION :c Defendant(s) -r? ?c CV p PRAECIPE TO SATISFY JUDGMENT co TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please satisfy the judgment entered in the above-captioned case. AMATO AND ASSOCIATES, P.C. By: ?J Ro ald Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM