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
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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
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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
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