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HomeMy WebLinkAbout09-3595COMMONWEALTH OF PENNSYLVANIA MANUFACTURERS AND TRADERS TRUST COMPANY, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, VS. Term, 2009 JEFFREY A. MINAHAN, Docket No. 09 - 3585 C jv i l Te rnn Defendant. PRAECIPE TO FILE AND INDEX FOREIGN JUDGMENT To the Prothonotary of Cumberland County: Pursuant to the Uniform Enforcement of Foreign Judgments Act, 42 Pa. Cons. Stat. Ann. § 4306, kindly file and index the attached exemplified and certified copies of the docket entries and the judgment entered in favor of Plaintiff, Manufacturers and Traders Trust Company and against Defendant Jeffrey A. Minahan in the sum of $51,020.96 less payment of $1,009.70, totaling $50,011.26 in the New York State Supreme Court in and for the County of Erie, in the above captioned action, Index No. 12008-10072. Dated: May 27, 2009 Buffalo, NY GETMAN & BIRYLA, LLP By: Matthew D. Valauri, Esq. Attorneys for the Plaintiff 800 Rand Building 14 Lafayette Square Buffalo, NY 14203-1995 Tel. (716) 853-4340 Fax (716) 853-4349 HAChentMatters\M&T \Minahan, Jeffrey\manufmin.pracipe.dom.PA.052609.wpd .r ' ERIE COUNTY CLERK'S OFFICE 92 Franklin Street Buffalo, New York 14202 04/23/09 Q 00207 7246 TJ Dear County Clerk: The attached is a certified copy of a judgement filed in our Docket of Judgements in the Erie County Clerk's Office. This document is in a format appropriate for recording in your docket. The completion of the acknowledgment below and the return of this entire document to our office is required by Section 5018 CPLR. The use of a date stamp is acceptable. Sincerely, 40 dpva X4 %%ft KATHLEEN C. HOCHUL Erie County Clerk DOCKETING ACKNOWLEDGMENT To The Erie County Clerk Date Filed: 25 Delaware Avenue Buffalo, N.Y. 14202 Attn.: Judgments Department The County Clerk's Office has this date accepted and recorded the above referenced judgment document. Q 00207 7246 TJ } Z M F Q d O N z o U .. } r z W N ? r V C w ? ¢ ? o J O O N Q LL a H w a 0 'y FU?1 A m W J IL z ?Q U z ¢ z i w o ? N r 0 0 0 00 0 0 N H O z x W A z N \D 1 N f- O n n CD o f- N L1 .r O O Q J d d J } M w x a d' z w U. LL w w Q Q W J d O ' cn CD W W wa ?a ? C Q Q N U W Q Z Q N 3 A Z ¢ N z s ?i 0 H H A W U O GT I W J } 0 ? A ° A Q Z ? Q z ? W Q C9 z z 4 z ° W U ? u- o O ? U W p O U z Y ?' U ? W -? o ? .c v Q ? 0 W ? z? a W ? a Y 'c b O? O N O ,4 Ln ;_ X b G O U C Q O 0 L o cC cF.. oho Vmo '3 U cn o F O• 0 W Q O W W ¢ N W F O W O Ln x o '" O? Z Wog V1 E.. ? W ?' c W rs Z Q [mow ?w HN O z ° O ¢ z v Ca, ? pa Q? ¢ W UN o0 W U W F Q z 0 F- U L¢.. F uniteb &tam of America &ta t of *tin Pork 00. CAUMp of Erie I, KATHLEEN C. HOCHUL, Clerk of the County of Erie, and also Clerk of the Supreme and County Courts in and for said County, (the said Courts being Courts of Record) do hereby certify that the ,above and foregoing is a true and comple copy. ®? ((? 'rrcaiS cr t ?- 11 o -o a cA oh e-d1-444-l ; O & ao7 qdq? 5k& Ck YOr? z zC?0'0l 60-70 o v n ? O (' ? C` n u b'c?c-h? r? r s -? Trrde-F S 7 rV5a,? ? S P? S?lrQ./Yl c ?cY i na&4 on file and remaining of record in the County Clerk's Office of Erie County. IN WITNESS WHEREOF, I have hereunto set my hand and affixed the seal of said County and Courts, at Buffalo, this day of ERIE COUNTY Clerk. C ?•? 0,0 21merica t-1 J M? O ro O CM, -'k . COMMONWEALTH OF PENNSYLVANIA MANUFACTURERS AND TRADERS ) TRUST COMPANY, ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, ) VS. ) Term, 2009 JEFFREY A. MINAHAN, ) Docket No. Defendant. ) AFFIDAVIT IN SUPPORT OF REQUEST TO FILE AND INDEX FOREIGN JUDGMENT I, DOUG BUCHNER, being duly sworn, according to law, deposes and says that he is a Recovery Manager for Manufacturers and Traders Trust Company, the Plaintiff herein and as such is authorized to make this affidavit on behalf of Manufacturers and Traders Trust Company; and that, to the best of my knowledge, information and belief: 1. The names of the judgment debtor is Jeffrey A. Minahan. 2. The last known post office address of both of the judgment debtor is 262 Spangler Mill Road, New Cumberland, Pennsylvania 17070. The name of the judgment creditor is Manufacturers and Traders Trust Company. 4. The post office address of the judgment creditor is One M&T Plaza, Buffalo, New York 14203. 5. The judgment in favor of Plaintiff, Manufacturers and Traders Trust Company and against Defendant, Jeffrey A. Minahan, entered in the sum of $51,020.96 less payment of $1,009.70, totaling $50,011.26 on April 21, 2009 in the New York State Supreme Court in and for the County of Erie, is valid, enforceable, and wholly unsatisfied as of this date. SIGNATURES APPEAR ON THE FOLLOWING PAGE Manufacturers and Traders Trus Company By: Doug B hner, Recovery Manager Subscribed and sworn to before me on this AM day of 2009. to Public NORMA J. PAOLINI Notary Public, State of New York No.01PA4878275 Qualified in Erie County Commission Expires Jan 20, 20 -jL HAClientMatters\M&T\Minahan, Jeffrey\manufmin.aff.dom.PA.052709.wpd Jot, ' U ?• ? % {t frl ? • F r jr 4?Lfl 4a4 .0c) QQ ArN "rv 14a5G+3 eT* aaC. Dot COMMONWEALTH OF PENNSYLVANIA MANUFACTURERS AND TRADERS TRUST COMPANY, Plaintiff, VS. JEFFREY A. MINAHAN, Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term, 2009 Docket No. NOTICE OF REGISTRATION OF FOREIGN JUDGMENT TO: JEFFREY A. MINAHAN 262 Spangler Mill Road New Cumberland, Pennsylvania 17070 You are hereby notified that Manufacturers and Traders Trust Company has filed a petition seeking the registration of the judgment entered in the New York State Supreme Court in and for the County of Erie, against Jeffrey A. Minahan in Case No. 12009-10072. A copy of the New York Judgment was filed with the Cumberland County Prothonotary on or about the (Rrtd day of June, 2009; a copy of which is attached hereto. The address of the Plaintiff, Manufacturers and Traders Trust Company, is One M&T Plaza., Buffalo, New York 14203. Plaintiff's New York State Attorney is Matthew D. Valauri. of Getman & Biryla, LLP, located at 800 Rand Building, 14 Lafayette Square, Buffalo, New York 14203-1995. GETMAN & BIRYLA, LLP By: Matthew D. Valauri, Esq. Attorneys for the Plaintiff 800 Rand Bldg., 14 Lafayette Sq. Buffalo, New York 14203-1995 Tel. (716) 853-4340 /-/ "- P- - C. I ?'.' V4 COMMONWEALTH OF PENNSYLVANIA MANUFACTURERS AND TRADERS TRUST COMPANY, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, VS. Civil Term, 2009 JEFFREY A. MINAHAN, Defendant. Docket No. 09-3595 AFFIDAVIT OF SERVICE JOSEPH S. MONTAGNOLA, being duly sworn, according to law, deposes and says, that he is over the age of 18 and is not a parry to the above captioned action. That on the 4' day of June, 2009, a copy of the foregoing Notice of Registration of Foreign Judgment was mailed via certified mail, return-receipt requested to: JEFFREY A. MINAHAN 262 Spangler Mill Road New Cumberland, Pennsylvania 17070 Sworn to and subscribed before me on this 4th day of June, 2009. Notary Public Matthew D. Valauri Notary Public, State of New York Qualified in Erie County My Commission Expires on April 6, 2013 By: 4jet-4 eph S. ontagnola, Law C rk HAChentMatters\M&PN inahan, Jef&ey\manufmin.noticeofiling.052609.wpd Y v COMMONWEALTH OF PENNSYLVANIA MANUFACTURERS AND TRADERS ) TRUST COMPANY; . ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, ) VS. ) Civil Term, 2009 JEFFREY A. MINAHAN, ) Docket No. 09-3595 Defendant. ) NOTICE OF REGISTRATION OF FOREIGN JUDGMENT TO: JEFFREY A. MINAHAN 262 Spangler Mill Road New Cumberland, Pennsylvania 17070 You are hereby notified that Manufacturers and Traders Trust Company has filed a petition seeking the registration of the judgment entered in the New York State Supreme Court in and for the County of Erie, against Jeffrey A. Minahan in Case No. 12009-10072. A copy of the New York Judgment was filed with the Cumberland County Prothonotary on June 2°a, 2009; a copy of which is attached hereto. The address of the Plaintiff, Manufacturers and Traders Trust Company, is One M&T Plaza, Buffalo, New York 14203. Plaintiff s New York State Attorney is Matthew D. Valauri. of Getman & Biryla, LLP, located at 800 Rand Building, 14 Lafayette Square, Buffalo, New York 14203-1995. GETMAN & BIRYLA, LLP By. Matthew Esq. Attorneys for the Plaintiff 800 Rand Bldg.,. 14 Lafayette Sq. Buffalo, New York 14203-1995 Tel. (716) 853-4340 emu, FILED-01- FICF OF THc PPOT-'ua1OTARY 2009 JUH -8 PM 4: 18 PEA NSYLVANA