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HomeMy WebLinkAbout09-3644COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CLAIMS RECOVERY SYSTEMS, INC. Plaintiff vs. JUANITA KINNARD, Defendant TO THE CLERK OF SAID COURT: OQ- 3L?? No. Civil Term CIVIL ACTION PRAECIPE Please enter judgment in favor of Plaintiff Claims Recovery Systems, Inc. and against Defendant Juanita Kinnard in the amount of $8,199.75 plus costs and interest. Alan R. Mege, Es . Attorney ID No. 1288 Attorney for Plaintiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5.93 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUJIB$jtLAND Mag. Dist. No.: 09-1-01 MDJ Name: Hon. CBARLES A. CL=MNT, JB Address 400 BRIDGE ST OLDIE TON= CO10`ON-9 -SVITE 3 NEW CUIMEALAND, PA Telephone: (7 17 ) 774-5989 17070 CLAI11[8 RECOVERY SYSTMIS 6 EAST FALL PLAZA CARNEGIE, PA 15106 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JUDAKIZNT PLTF ® Judgment was entered for: NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rCLAMB RECOVERY SYSTMS ? 6 EAST NALL PLAZA CARNEGIE, PA 15106 L J VS. DEFENDANT: NAME and ADDRESS FX- XM M, JOANITA -1 729 GUNNISON BD APT/STE B YORK, PA 17404 L J Docket No.: CV-0000453-08 Date Filed: 9/02/08 (Date of Judgment) 11/21/08 (Name) CLAIMS RECOVERY SYST, =9 ® Judgment was entered against. (Name) 111100M, JUANITA in the amount of $ 8,199.7 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 Portion of Judgment for physical damages arising out of residential lease Q Amount of Judgment $_8, 000.00 Judgment Costs $ -- Interest on Judgment $ .tea Attorney Fees $ Total $ 8,199.75 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 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. Ir0' 2 1 2008 Date I certify that this is a true an c rrect c py of th 1/12/2009Date My commission expires first Monday of January, 2014 AOPC 315-07 DATE PRINTED: 1/12/09 12:01:00 PM Magisterial District JL gs containing the judgment. , Magisterial District Judge SEAL I IN THE COURT OF COMMON PLEAS OF, Cumberland COUNTY, PENNSYLVANIA Claims Recovery Systems, Inc. Plaintiff VS. NO. Juanita Kinnard Defendant AFFIDAVIT OF NON-MILITARY SERVICE The undersigned, being duly swom, according to law, deposes and says that the 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 Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; That Juanita Kinnard is over 18 years of age, resides at 239 4th Street, Apt. B, New Cumberland, PA 17070 and is employed That Defendant is years of age, resides at _ and is employed That Defendant is years of age, resides at and is employed That Defendant ----- . years of age, resides at and is employed is 1, Alan R. Mtge, Esquire, do hereby verify that I am the attorney for Plaintiff, that I am fully authorized to make this Verification on their behalf, that the Defendants are unavailable to make this Verification, that the facts contained in the foregoing pleading are true and correct to the best of my knowledge, information and belief, and the source of my information are interviews with my client and the Plaintiff's filed documents. The verifier understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswo%talsification to authorities. Signed: Dated: 6/1/09 FILE nr yr A, 1/ r L0IJ9 <U-N -3 Fill I : G i Ck.* 99a? R-T'?' ??1.t43 0c4?. k64IL4 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CLAIMS RECOVERY SYSTEMS, INC. Plaintiff No. Civil Term vs. CIVIL ACTION JUANITA KINNARD, ; Defendant ; ( ) Notice is hereby given that a Judgment in the above captioned matter has been entered against you in the amount of $8,199.75 plus costs and interest on 3 , 2009. ( ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. Prothonot By: If you have questions regarding this Notice, please contact the filing party: NAME: Alan R. M6e Esq ADDRESS: P.O. Box 1426 Bethlehem PA 18016 TELEPHONE NO. 610-954-5393 (This Notice is given in accordance with Pa.R.C.P.§236.) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY PENNSYLVANIA CIVIL DIVISION Claims Recovery Systems, Inc. V. Juanita Kinnard Case No.Q Amount Due $8,199.75 Interest from 11/21/08 @ 6% $246.00 Atty's Fee** Costs to be added PRAECIPE FOR WRIT OF EXECUTION To the Clerk of Courts: Issue a writ of execution in the above matter, (1) direct the Sheriff of Cumberland (2) against Juanita Kinnard COTy' defendant(s) and upon the (Name of Defendant(s)) following described property of the defendant(s) All tangli_ ble personal prole y of the def 39 4th Street, #B, New Cumberland, PA 17070 nnant Inratpn at (3) against (4) (Supply four copies of lengthy personalty list) (if real property supply six copies of the description) , gamishee(s) for the following property: and enter this writ in the judgment index (a) against _ and defendant(s) (b) against , as gamishee(s) as a hs pendens against real property of the defendant in name of garnishee as follows: (Specifically described property) Date:. 6/2/09 Signature: ?--? Print Name. Ian R. Meee Eso Address. PO Box 1426, Bethlehem, PA 18016-1426 Attorney for: Plaintiff Telephone: _(610) 954-5192 Supreme Court ID NO:_g12g8 ** Where judgment has been entered under Rule 295l(a), attorneys' fees may be included if they are authorized in the instrument and there has been a record appearance of counsel at any stage of the proceedings. Pa.R.C,P. 3251 TIT u $,%q.Co po A-rYY a17.015 C8F 6.50 +53 .'i5 - PD Am $a-CO LUA-W -5o t,L c-* 49xu Rr*- a&6143 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-3644 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CLAIMS RECOVERY SYSTEMS, INC., Plaintiff (s) From JUANITA KINNARD, 39 4th street, #B, New Cumberland, PA 17070 (1) You are directed to levy upon the property of the defendant (s)and to sell all tangible personal property . (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 $8,199.75 Interest from 11/21/08 @ 6% - $246.00 Atty's Comm % Atty Paid $53.75 L.L. $.50 Due Prothy $2.00 Other Costs Plaintiff Paid Date: 6/03/09 (Seal) C . R. Long, ary By: REQUESTING PARTY: Name ALAN R. MEGE, ESQUIRE Address: PO BOX 1426 BETHLEHEM, PA 18016-1426 Attorney for: PLAINTIFF Telephone: 610-954-5393 Supreme Court ID No. 81288 Deputy IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY. PENNSYLVANIA CIVIL DIVISION Claims Recovery Systems, Inc. V. Juanita Kinnard A MZ&) ZM Case No. 09-3644 Amount Due $8,199.75 Interest from 11/21/08 @ 6% ($246.00) Atty's Fee** Costs to be added _ Amended PRAECIPE FO&WRIT OF EXECUTION To the Clerk of Courts: Issue a writ of execution in the above matter, (1) direct the Sheriff of Cumberland county; (2) against Juanita Kinnard , defendant(s) and upon the (Name of Defendant(s)) following described property of the defendant(s) All tantanglible rcnna proputy of the defendant located at 329 4th Street, #B, New Cumberland, PA 17070 (Supply four copies of lengthy personalty list) (if real property supply six copies of the description) (3) against , garnishee(s) for the following property: (4) and enter this writ in the judgment index (a) against _ defendant(s) and (b) against , as garnishee(s) as a lis pendens against real property of the defendant in name of garnishee as follows: (Specifically described property) Date:. 6/8/09 Signature: Print Name: Alan R. Mee ZQ"" Address: PO Box 1426, Bethlehem, PA 18016-1426 Attorney for: Plaintiff Telephone: (610) 954-5393 Supreme Court ID No: 81288 "Where judgment has been entered under Rule 295l(a), attorneys' fees maybe included if they are authorized in the instrument and there has been a record appearance of counsel at any stage of the proceedings. Pa.R.C.P. 3251 OFF 4MOTIMOTARY 2009 JUN 10 PM 12#. 5 5 Ate E-&:10L-a WRIT OF EXECUTION and/or ATTACHMENT r COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CLAIMS RECOVERY SYSTEMS, INC., Plaintiff (s) From JUANITA KINNARD,Mi 0 street, #B, New Cumberland, PA 17070 (1) You are directed to levy upon the property of the defendant (s)and to sell all tangible personal property. (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 $8,199.75 Interest from 11/21/08 @ 6% -- $246.00 Atty's Comm % Atty Paid $53.75 Plaintiff Paid Date: 6/03/09 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs 24-aR4 C R. Long, P aryBy: NO 09-3644 Civil CIVIL ACTION - LAW Deputy REQUESTING PARTY: Name ALAN R. MEGE, ESQUIRE Address: PO BOX 1426 BETHLEHEM, PA 18016-1426 Attorney for: PLAINTIFF Telephone: 610-954-5393 Supreme Court ID No. 81288 IF G J