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HomeMy WebLinkAbout08-7552Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: (717] 541-5225 Attorney for Plaintiff: MID-ATLANTIC MATERIALS, INC. MID-ATLANTIC MATERIALS, INC. 6813 Quad Avenue Baltimore, MD 21237 Plaintiff v. ALTIERI HOMES 9017 Red Branch Road, Ste 201 Columbia, MD 21045 . DARREN B. ALTIERI . 9017 Red Branch Road, Ste 201 Columbia, MD 21045 . Defendants TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA aa- 7ss~ ~v~~`~F~s.- PRAECIPE Pursuant to Pennsylvania Rule of Civil Procedure 3002, enter judgment against the Defendants, Altieri Homes and Darren B. Altieri, in the amount of $300,015.00 in accordance with the certified copies of the Judgment Under Act of Congress in Case No. 13-C-08-73638 of the Circuit Court for Howard County, Maryland contemporaneously being filed, and index.id judgment against the Defendants. ; ,~ Date: December 29, 2008 By:L `~ ~ Lar v L. Mil e V Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: [717) 541-5225 MID-ATLANTIC MATERIALS, INC. . 6813 Quad Avenue Baltimore, MD 21237 Plaintiff . v. ALTIERI HOMES 9017 Red Branch Road, Ste 201 Columbia, MD 21045 DARREN B. ALTIERI 9017 Red Branch Road, Ste 201. Columbia, MD 21045 Defendants . Attorney far Plaintiff MID-ATLANTIC MATERIALS, INC. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA ~~ VERIFICATION OF VALIDITY OF FOREIGN JUDGMENT I, Larry L. Miller, Esquire, being duly sworn according to law, depose and state that I am the attorney for the Plaintiff, Mid Atlantic Materials, Inc., and I am authorized to make this Verification on its behalf; and that, to the best of my knowledge, information, and belief: 1. The names of the judgment debtors are Altieri Homes and Darren B. Altieri. 2. The last known post office addresses of the judgment debtors is 9017 Red Branch Road, Suite 201, Columbia, MD 21045. 3. Materials Inc. The name of the judgment creditor is Mid Atlantic 4. The post office address of the judgment creditor is 6813 Quad Avenue, Baltimore, MD 21237. 5. The judgment in favor of Plaintiff, Mid Atlantic Materials Inc., and against Defendants, Altieri Homes and Darren B. Altieri, was entered in the total sum of $300,015.00 in the Circuit Court for Howard County, Maryland, is valid, enforceable, and unsatisfied as of this date. I, LARRY L. MILLER, have read the foregoing and the factual statements contained therein are true and correct to the best of my knowledge, information and belief. I am authorized to make this Verification on behalf of my client, Mid Atlantic Materials Inc. The facts. set forth in the pleading are based upon my review of the documents and information furnished by Mr. Charles E. Gibson, President of Mid Atlantic Materials Inc. This Verification is made subject to the penalties of 18 Pa. Cons. Stat. Section 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to crimina DATE: December 29, 2008 By: Larry L. Miller, Esquire Pa. Supreme Court I.D. No. 28122 1423 State Road Duncannon, PA 17020 Telephone: [717) 541-5225 MID-ATLANTIC MATERIALS, INC. . 6813 Quad Avenue Baltimore, MD 21237 Plaintiff , v. , ALTIERI HOMES 9017 Red Branch Road, Ste 201 : Columbia, MD 21045 DARREN B. ALTIERI 9017 Red Branch Road, Ste 201 Columbia, MD 21045 Defendants . Attorney for Plaintiff: MID-ATLANTIC MATERIALS, INC. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA d8 - ~ ssa.- e- ' ~~- ~ v ~ £2~ PRAECIPE TO FILE AND INDEX FOREIGN JUDGMENT TO: THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Pursuant to the Uniform Enforcement of Foreign Judgments Act, 42 Pa. Cons. Stat. § 4306, kindly file and index the attached certified copy of the judgment entered in favor of Plaintiff, Mid Atlantic Materials, Inc., and against Defendants, Altieri Homes and Darren B. Altieri, in the total sum of $300,015.00 in the Circuit Court for Howard County, Maryland, in an action captioned Mid Atlantic Materials, Inc. v. Altieri Homes and Darren B. Altieri, Docket No. 13-C-08-73638 that was entered as a final judgment on July 21, 2008 by the Clerk of the Circuit Court. A true and correct certified copy of the judgment is attached hereto as Exhibit "A." Date: December 29, 2008 By: L rry ,~,, ller C el fo Plaintiff STATE OF MARYLAND, HOWARD COUNTY, TO WIT: `~+ ~ 1 I HEREBY CERTIFY that the aforegoing is a true photocopy of the original taken from the records of the Circuit Court for Howard County as recorded in Case Number: 13-C-08-73638 IN TESTIMONY WHEREOF, I hereto set my hand and affix the seal of the Circuit Court; for Howard County this 11th Day of December, 2008. `a~P4:"r OR Hp»~p n, ZV~ •G2 :r; Margar t D. Rappaport '-~•. . •~~~ *•.. ..~ Clerk of the Circuit Court •'2 NAR1'LANO ,,P for Howard County I, Diane O. Leasure Judge of the Circuit Court for Howard County, in the Fifth Judicial District of the State of Maryland, do hereby certify that Margaret D. Rappaport who has given the preceding certificate, was Clerk of the said Circuit Court for Howard County at the time of so doing, and that his/her attestation is in due form, and his/her signature thereto is genuine. ~`~ . ~ ~ W'~.~ STATE OF MARYLAND, HOWARD COUNTY, Sct. Diane O. Leasure Judge of the Fifth Judicial Circuit I, Margaret D. Rappaport, Clerk of the Circuit Court for Howard County, do hereby certify that the Honorable Diane O. Leasure Judge of the Circuit Court for Howard County, who has certified and signed the above attestation, was at the time of so doing, Judge of the said Court, duly commissioned and qualified; and that to all acts done by him/her in that capacity, full faith and credit are due and ought to be given; and that his/her signature thereto is genuine. IN TESTIMONY WHEREOF, I hereunto subscribe my hand and affix the seal of the Circuit Court for Howard County, on this 11th Day of December, 2008, A.D. l .~~~at FQ~ Margar t D. Rappaport Clerk of the Circuit Court for Howard County EXHIBIT A ~J CIRCUIT COURT FOR BALTIMORE COUNTY Suzanne Mensh Clerk of the Circuit Court County Courts Building 401 Bosley Avenue P.O. Box 6754 Towson, MD 21285-6754 (410)-887-2601, TTY for Deaf: (800)-735-2258 .Maryland Toll Free Number (800) 938-5802 O~ N O T I C E O F R E C O R D E D J U D G M E N T Case Number: 03-C-08 RJ Originating Court 1300873638 C I V I L Mid Atlantic Materials Inc vs Altieri Enterprises Inc, et al I HEREBY CERTIFY that the following Judgment has been recorded in this Court in the above entitled case: Judgment Against: Altieri Homes 9017 Red Branch Road Columbia, MD 21045 Judgment in Favor of: Judgment Ordered On: Judgment Entry Date: Amount of Judgment: PreJudgment Interest: Appearance Fee: Filing Fee: Mid Atlantic Materials Inc 07/21/08 07/21/08 Other Fee: $250,000.00 Service Fee: $.00 Witness Fee: $.00 Attorney Fee: $15.00 Total Judgment: Plus court costs. $.00 $.00 $.00 $50,000.00 $300,015.00 IN TESTIMONY WHEREOF, I hereunto set my hand and affix the seal of this Court. ., .,, ,. .,. , o Suzanne Mensh °+rcou~` Clerk of the Circuit Court, per S,~-~ Issued: 07/21/08 ~' Io A CIRCUIT COURT FOR BALTIMORE COUNTY Suzanne Mensh Clerk of the Circuit Court County Courts Building 401 Bosley Avenue P.O. Box 6754 Towson, MD 21285-6754 (410)-887-2601, TTY for Deaf: (800)-735-2258 Maryland Toll Free Number (800) 938-5802 N O T I C E O F R E C O R D E D Mid Atlantic Materials Inc vs Altieri J U D G M E N T ~~`p~j Case Number: 03-C-08i8~ RJ Originating Court 1300873638 C I V I L Enterprises Inc, et al ~' I HEREBY CERTIFY that the following Judgment has been recorded in this Court in the above entitled case: Judgment Against: Altieri, Darren B 9017 Red Branch Road Suite 201 Columbia, MD 21045 Judgment in Favor of: Judgment Ordered On: Judgment Entry Date: Amount of Judgment: PreJudgment Interest: Appearance Fee: Filing Fee: Mid Atlantic Materials 07/21/08 07/21/08 $250,000.00 $.00 $.00 $15.00 Plus court costs. Inc Other Fee: Service Fee: Witness Fee: Attorney Fee: Total Judgment: $.oo $.00 $.00 $50,000.00 $300,015.00 IN TESTIMONY WHEREOF, I hereunto set my hand and affix the seal of this Court. p~~1~'T C~~I.4 C~'~ a '~ ~; ~i'. /,~ Suzanne" Mensh °~ECOO"'~ nn Clerk of the Circuit Court, per S,f~, Issued: 07/21/08 e ~, ~ . _ ,_. _,. D ~ _: LsJ ~- _ , f ! _ .. ~ .. ~ ~ _ CJ _. O ~~ 1~ J„~ ,''O C'~ e~ f'~ ~ ~ a r_~~ o~ w -~ ~' 1~ ~~. ~ ~, ~ _r.f; - (Rule of Civil Procedure No. 236) MID-ATLANTIC MATERIALS, INC. 6813 Quad Avenue Baltimore, MD 21237 Plaintiff v. ALTIERI HOMES 9017 Red Branch Road, Ste 201 Columbia, MD 21045 DARREN B. ALTIERI 9017 Red Branch Road, Ste 201 Columbia, MD 21045 Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 0~3 - 7 ss"~. Notice is given that a judgment in the above-captioned matter has been entered against you on ! ~ ~c , ~ / , 2008. sy: If you have any questions concerning the above, please contact: Larry L. Miller, Esquire 1423 State Road, Duncannon, PA 17020 717.957.2828