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HomeMy WebLinkAbout09-0938J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 MISERICORDIA UNIVERSITY 301 Lake Streets Dallas, PA 18612 V. COLLEEN CUNNINGHAM 3700 Spring Road Carlisle, PA 17013 PRAECIPE Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS (q - gas Civil -Few Kindly docket the attached Judgment in the amount of $6,202.97 in favor of Plaintiff, Misericordia University, and against the Defendant, Colleen Cunningham, for execution purposes only. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA r:r)l INTY nF• LUZERNE Mag. Dist. No.: 11-3-09 MDJ Name: Hon. JAMES TUPPER Address: 11 CARVERTON ROAD TRUCSSVILLE, PA Telephone: (570 ) 696-4477 18708-1799 ATTORNEY DEF PRIVATE : J S. WATSON 24 REGENCY PLAZA GLEN MILLS, PA 19342 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT .TOR T PLTF NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS FiISERICORDIA UNIVERSITY 301 LASE STREET DALLAS, PA 18612 L J VS. DEFENDANT: NAME and ADDRESS rC- U=TNGK K, COLLEEN 7 3700 SPRING ROAD CARLISLE, PA 17013 L J Docket No.: CV-0000263-08 Date Filed: 8/12/08 raw _ (Date of Judgment) 12/03/08 © Judgment was entered for: (Name) KISBRICORDIA UNIVERSITY ® Judgment was entered against: (Name) CUNNXNGK"• COLLEEN 6 202 9 in the amount of $ ' Defendants are jointly and severally liable. Damages will be assessed on Date & Time ? This case dismissed without prejudice. Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 F] Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 6, 062.97 Judgment Costs $ • 00 Interest on Judgment $ .00 Attorney Fees $ • Total $ 6,202.97 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 JUDGMENTITRANSCRIPT 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 DIS.TRICT.IUDGE-.-.- 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. -.3-01y Date District Judge I certify that this is a true and corr the record of the proceedings containing the judgment. IV- y ! Date , Magisterial District Judge My commission expires first day of January, 2012 SEAL AOPC 315-07 DATE PRINTED: 2/02/09 10:17:00 AN J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff MISERICORDIA UNIVERSITY 301 Lake Streets Dallas, PA 18612 V. COLLEEN CUNNINGHAM 3700 Spring Road Carlisle, PA 17013 CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND The undersigned, being duly sworn according to law, deposes and says that the Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; that Defendant, Colleen Cunningham, is over eighteen (18) years of age, and resides at 3700 Spring Road, Carlisle, Pennsylvania 17013. SWORN TO AND SUBSCRIBED BEFORE ME THIS g 7"4 DAY J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff COMMONYMEAVM OF PENNMVANiA NOTARIALSEAL BRYAN W. SCHULU, Notary Public Concord Twp., Delaware County FMy Commission Expos June 10, 2010 OF 2009. J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 MISERICORDIA UNIVERSITY 301 Lake Streets Dallas, PA 18612 V. COLLEEN CUNNINGHAM 3700 Spring Road Carlisle, PA 17013 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT I, J. Scott Watson, Esquire, hereby certifies that the debt in the above matter is valid, enforceable and unsatisfied to date. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 9!-i DAY OF ?br7/QaIV 2009. NOTARV7 r-OMMOM ALIMCWPEN MYLVAMA NOTARIAL SEAL BRYAN W. SCHULTZ, Not Public Gxwrd Twp., Uclawa e Couuly l M Cwuni m E;p -?? surie 10,1010 J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff MISERICORDIA UNIVERSITY 301 Lake Streets Dallas, PA 18612 V. COLLEEN CUNNINGHAM 3700 Spring Road Carlisle, PA 17013 CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT I, J. Scott Watson, Esquire hereby certifies that the name and the last known address of Plaintiff and Defendant are as stated below: Plaintiff: Misericordia University 301 Lake Streets Dallas, PA 18612 Defendant: Colleen Cunningham 3700 Spring Road Carlisle, PA 17013 SWORN TO AND SUBSCRIBED BEFORE ME THIS g /,? DAY OF 42009. NOTARY J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff coMMO?V?A TMOFPLNNMVAP" RIAL BRYAN r 3CyULLTP 0 ary Po Concord Twp., Delaw M Commiare County .- ExRirss , 10,2010 J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff MISERICORDIA UNIVERSITY 301 Lake Streets : Dallas, PA 18612 : V. COLLEEN CUNNINGHAM 3700 Spring Road Carlisle, PA 17013 : CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT OF NO APPEAL I, J. Scott Watson, Esquire, hereby certifies that the District Court judgement in the above matter was not appealed,.into a higher court to date. SWORN TO AND SUBSCRIBED J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff =SCHULTZ m?ENNMVANU VV - SEJ?L Z, Notary Pubficc Icor lawar e Coun es June 10, 10 BEFORE ME THIS 9 DAY nF Aehr ad v goo9_ 1u ? ?/1 _ 1"r1 p - ?i t'7 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY TO: Colleen Cunningham 3700 Spring Road Carlisle, PA 17013 MISERICORDIA UNIVERSITY 301 Lake Streets Dallas, PA 18612 V. COLLEEN CUNNINGHAM 3700 Spring Road Carlisle, PA 17013 CUMBERLAND COUNTY COURT OF COMMON PLEAS NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. JUDGMENT BY DEFAULT X MONEY JUDGMENT JUDGMENT IN REPLEVIN JUDGMENT FOR POSSESSION ////fA6 P OTHO A Y If you have any questions concerning this Judgment, please call J. Scott Watson, Esquire at 610-358-9600. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: Misericordia UNIVERSITY 301 Lake Street Dallas, PA 18612 ( ) Confessed Judgment (X ) Other personal property Levy File No. 09-938 vs. COLLEEN CUNNINGHAM 3700 Spring Road Carlisle, PA 17013 Amount Due 6.202.97 Interest to 4/3/09 - $124.05 Atty's Comm Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) All contents of Defendant's residence, including but not limited to all furniture, clothing, jewelry, electronic equipment, electrical appliances, kitchen utensils, silverware, televisions, tools and any other property which may be subject to levy. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date 9 Signature: Print Name: Address: Attorney for: J. Scott Watson, Esquire 24 Regency Plaza Glen Mills, PA 19342 Plaintiff Telephone: 610-358-9600 Supreme Court ID No.: 41060 (over) OF THE ?i"!tx/py 200911 % 2? ,', 112: ti l ? J ? 1 ?r Notes: If real property, supply six copies oldpi Iudng improvements and an original and copy of affidavit of ownership (PaR.C.R No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. 8l4 . oo PO ATW aT as ezr 19.50 N 0 53 . 175 -PO Al"d a. 00 Aver • so U- ?? ?Ogalt? P?'? aas5?7 Lzrit 4 4 1&4,4-j WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-938 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MISERICORDIA UNIVERSITY, Plaintiff (s) From COLLEEN CUNNINGHAM, 3700 Spring Road, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell all contents of defendant's residence, including but not limted to all furniture, clothing, jewelry, electronic equipment, electrical appliances, kitchen utensils, silverware, televisions, tools and any other property which may be subject to levy. (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 $6,202.97 Interest to 4/03/09 -- $124.05 Atty's Comm % Atty Paid $53.75 Plaintiff Paid Date: 5/22/09 L.L. $.50 Due Prothy $2.00 Other Costs Curtis R. Ltft ,o ono (Seal) By: Deputy REQUESTING PARTY: Name J. SCOTT WATSON, ESQUIRE Address: 24 REGENCY PLAZA GLEN MILLS, PA 19342 Attorney for: PLAINTIFF Telephone: 610-358-9600 Supreme Court ID No. 41060 Y Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~~~~~~~,~ ~t ~a,r,t,~r~ijG r 2~f0 ~'~1`` ? f ~'oi = 24 ~., Misericordia University Case Number vs. Colleen Cunningham 2009-938 SHERIFF'S RETURN OF SERVICE 05/27/2009 On May 27, 2009 at 1610 hours, defendant was served with a copy of the writ of execution, but refused to permit entry to Deputy Harrison. 05/20/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $67.22 SO ANSWERS, May 21, 2010 RON R ANDERSON, SHERIFF -'7 /` By l,,.rS aron R. Lantz .„i Cou^.rySuite h'rnfi. ieieos:;H. L?e. RONNY R. ANDERSON Sheriff JODY S. SMITH Chief Deputy To Whom It May Concern: of ?un??Prr? OFFICE OF THE SHERIFF RICHARD W. STEWART Solicitor One Courthouse Square, Room 303 r' Carlisle, Pennsylvania 17013 C ? -A 1 im -V February 24, 2012 = r N W r ? S >C? Misericordia University ? MW vs o Colleen Cunningham c 7 ?' = ;. Writ No. 2009-938 '_" '0 Property Claim Determination Reference is made to Property Claim dated February 14, 2012, entered by Jeffery Cunningham, Writ of Execution No. 2009-938 Civil Term, Misericordia University vs. Colleen Cunningham. Ronny R. Anderson, Sheriff, has determined that the claimant, Jeffery Cunningham, in the above mentioned property claim, is the owner of the property set forth in the claim. cc J. Scott Watson, Atty for Plaintiff Colleen Cunningham, Defendant Jeffery Cunningham, Claimant So Answers: R. Anderson, Sheriff By NOTICE OF PROPERTY CLAIM Misericordia University VS Colleen Cunningham In the Court of Common Pleas Cumberland County, Pennsylvania No. 2009-938 Civil Term Writ of Execution TO THE DEFENDANT AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Jeffery Cunningham, claiming property listed therein. Unless an appraisal of the property is requested within (10) days from the (late of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. Date 02-14-12 Cc J. Scott Watson, Attorney for Plaintiff Colleen Cunningham, Defendant Jeffery Cunningham, Claimant of um erland Coun By PROPERTY CLAIM Misericordia University In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2009-938 VS Colleen Cunningham TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: TY VALUE ? (dam ?--Q ?^? ?V• `? ?? ? w ", o ie! s fan. ? !'1 v v a) (A i ? /tom ? 1"iA / 11/A, Dated Claimant d State of Pennsylvania: i' County of Cumberland above list in the property claim are correct and true. Sworn and subscribe to before me This 1'h day of , ;1? Notary Publi& ' being duly sworn according to law, deposes and says that the NOTARIAL SEAL 1/ (__/ JODY SMITH, NOTARY PUBLIC Carlisle Boro, Cumberland County My Commission Expires April 4, 2013 d' THE CLAIMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS: f? ti r2 cj t iv' t I Jl - _ ___ _ ice, $9 ?) a 3 41 J. SCOTT WATSON, P.C. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-%00 122 P' 9- '1ImnpL?: ? ?NS`f LV??t A Attorney for Plaintiff MISERICORDIA UNIVERSITY CUMBERLAND COUNTY COURT OF COMMON PLEAS V. COLLEEN CUNNINGHAM NUMBER 09-938 Civil Term ORDER TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the Money Judgment in the above matter as satisfied upon payment of your costs only. J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff