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HomeMy WebLinkAbout09-4165ti Johnson, Duffle, Stewart & Weidner By: David W. DeLuce I.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff KEYSTONE STAFFING SERVICES, INC., 360 MARKET STREET LEMOYNE, PA 17043, Plaintiff V. CLARK RESOURCES, INC. 321 NORTH FRONT STREET HARRISBURG, PA 17101, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. n9 -All LS `'i.?L' l s PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment on behalf of the Plaintiff, Keystone Staffing Services, Inc., against the Defendant, Clark Resources, Inc. in the amount of $931.00 pursuant to the Judgment of the Magisterial District Justice, 30 days having elapsed since the judgment was entered with no appeal having been taken. Date: i WDavid E WAR & WEIDNER eLuce JUD GMENT AND NOW, this - ?ay of , 2009, judgment is entered as above requested in favor of Plaintiff Keystone Staffing Services, Inc. and a inst Defend t Clark Resources, Inc. C TIS R P THONOTARY By: Deputy CERTIFICATE OF SERVICE AND NOW, this ? day of June, 2009, the undersigned does hereby certify that he did this date serve a copy of the foregoing Praecipe to Enter Judgment upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Clark Resources, Inc. 321 North Front Street Harrisburg, PA 17101 JO laavvii UF S AR T WEIDNER By: Dd . DeL ce 368653 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Dist. No.: 09-1-02 MDJ Name: Hon. ROGER A. ESTEP (SR MDJ) Address: 1901 STATE ST CAMP HILL, PA Telephone: (717 ) 761-0583 17011 ATTORNEY FOR PLAINTIFF : DAVID W. DELUCE 301 MARKET ST PO BOX 109 LEMOYNE, PA 17043 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JUDGMENT PLTF ® Judgment was entered for: (Name) ® Judgment was entered against: (Name) in the amount of $ 931.01 Defendants are jointly and severally liable. Damages will be assessed on Date & Time 1-1 This case dismissed without prejudice. El Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 600.00 Judgment Costs $ 81.00 Interest on Judgment $ .00 Attorney Fees $ 25U. 0111) Total $ 931.00 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 JUDGMENT/TRANSCRIPT 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. 1Z l` ?q Date I certif tha his is a true Date i record My commission expires first Monday of January, 2012 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rEYSTONE STAFFING SERVICES INC 360 MARKET ST LEMOYNE, PA 17043 L J VS. DEFENDANT: NAME and ADDRESS r CLARK RESOURCES INC 321 N FRONT ST HARRISBURG, PA 17101 L J Docket No.: CV-0000072-09 Date Filed: 3/09/09 _ (Date of Judgment) 4/21/09 KEYSTONE STAFFING SERVICES INC CLARK RESOURCES INC ._./, Magisterial District Judge ?e aining the judgment. , Magisterial District Judge SEAL AOPC 315-07 DATE PRINTED: 4/21/09 9:09:00 AM FILM-40,1"F ICE OF THE PIRG r- OTARY 2009 JUN 18 PH 1: 49 cum, C l??` .?0?4 c? 2.*?-- a??4ol IVo-Lr ?? rnz? ?L r -r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: KEYSTONE STAFFING SERVICES, INC., Plaintiff V. CLARK RESOURCES, INC., 360 N. Fron+St Defendant 4138 PA 11 (Of and PNC BANK, Guarnishee [ ]Confessed Judgment [ ]Other File No. 09-4165 Civil Term Amount Due $931.00 Interest $ 26.22 nG? A 's Comm. $ 0 F-rae 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 funds Defendant holds at PNC Bank 4242 Carlisle Pike, Camp Hill, PA 17011. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland 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 personally list) Attach all funds and accounts of the Defendant, Clark Resources, Inc. on deposit at PNC Bank, includin but not limited to, those funds held in Bank Account No. 5005691202. 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) defendant(s) 7;ribed 'n the attached exhibit. Date Z o Signatu Print N Address: 301 Market Street, P.O. Box 109, Lemoyne, PA 17043 Attorney for: Plaintiff Telephone: 717-761-4540 Supreme Court ID No: 41867 0 n T? '1 i 1 f f.i i r/'47?/ 200? . U"N 23 Pl? 2: Ctj lt . C-IDAk? a?loq C $ 0'14.50 PO A r7Y a'1. a5 CBF 01.50 to ??' 015 - PD IvTty -co bue- '50 LL r?x-? aa?a7o LL)r,,+ 4 & 4"ulj WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-4165 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due KEYSTONE STAFFING SERVICES, INC., Plaintiff (s) From CLARK RESOURCES, INC., 321 N. Front Street, Harrisburg, PA 17101 (1) You are directed to levy upon the property of the defendant (s)and to sell personal property of Defendants . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: PNC BANK, 4242 Carlisle Pike, Camp Hill, PA 17011 Attach all funds and accounts of the Defendant, Clark Resources, Inc. on deposit at PNC bank, including, but not limited to, those funds held in Bank Account No. 5005691212 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 $931.00 L.L. $.50 Interest -- $26.22 Atty's Comm % Due Prothy $2.00 Atty Paid $54.25 Other Costs Plaintiff Paid Date: 6/23109 5 C is R. Long, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name DAVID W. DeLUCE, ESQUIRE Address: JOHNSON, DUFFIE, STEWART & WEIDNER 301 MARKET STREET PO BOX 109 LEMOYNE, PA 17043 Attorney for: PLAINTIFF Telephone: 717-761-4540 Supreme Court ID No. 41867 Sheriffs Office of Cumberland County R Thomas Klineu r-lerrt,Edward L Schorpp Sheriff' ?? Solicitor Ronny R Anderson Jody S Smith Chief Deputy ERIFF Civil Process Sergeant Keystone Staffing Services, Inc. Case Number vs. Clark Resources, Inc. 20094165 SHERIFF'S RETURN OF SERVICE 06/26/2009 12:17 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 26, 2009 at 1213 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Clark Resources, Inc., in the hands, possession, or control of the within named garnishee, PNC Bank, 4242 Carlisle Pike, Camp Hill, Cumberland County, Pennsylvania 17011, by handing to Bonnie Snyder, Banking Consultant, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 29, 2009 to Clark Resources, Inc., at 321 N Front Street, Harrisburg, PA 17101. 2009-4165 Keystone Staffinf Services, Inc. vs Clark Resources, Inc. So Answers, R. By Deputy Sher heriff C} C C' ? ? t r- ?y m { SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee KEYSTONE STAFFING SERVICES, INC. COURT OF COMMON PLEAS COUNTY OF CUMBERLAND VS. CLARK RESOURCES, INC. and : NO. 09-4165 PNC BANK, NATIONAL ASSOCIATION, GARNISHEE ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of PNC Bank, National Associgtion, Garnishee, in the above-captioned matter. Date: i ll { r r. 1 s Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ~4titir~t~, of ~:i~~~~brt~{:r~r ~.:,FF~~;~ :~:F rr;~ s,~~~~Fr ~~E~}~l)s~=1~E ZOD9 SEP t 4 ~~ i 9~ 2 7 CUP~t ~. ~ _ ; ,- J~~~,,, .= f, C'~~i~~~~Vt~ I,~l.i :~''IiN Keystone Staffing Services, Inc. Case Number vs. Clark Resources, Inc. 2009-4165 SHERIFF'S RETURN OF SERVICE 06/26/2009 12:17 PM -Michelle Gutshalf, Deputy Sheriff, who being duly sworn according to law, states that on June 26, 2009 at 1213 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Clark Resources, Inc., in the hands, possession, or control of the within named garnishee, PNC Bank, 4242 Carlisle Pike, Camp Hill, Cumberland County, Pennsylvania 17011, by handing to Bonnie Snyder, Banking Consultant, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 29, 2009 to Clark Resources, Inc., at 321 N Front Street, Harrisburg, PA 17101. 09/11/2009 R. Thomas Kline Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiffs attorney. Plaintiffs attorney states that they have been paid in full. SHERIFF COST: $112.50 (PAID) SO ANSWERS, September 11, 2009 / 9116Ib~ -/''"' R THOMAS KLINE, SHERIFF B Sharon R. Lantz t _ . :. ~~. ~ ~ '~ ~ ~ 7i9a~ ~ aT3~G/9 KEYSTONE STAFFING SERVICES, INC. vs. CLARK RESOURCES, INC. and COURT OF COMMON PLEAS COUNTY OF CUMBERLAND NO. 09-4165 PNC BANK, NATIONAL ASSOCIATION, GARNISHEE :ATTORNEY I.D.# Lf ~~ 87 ORDER TO SATISFY JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly mark the judgment entered against the Garnishee, PNC Bank, National Association, in the above matter, satisfied upon payment of your costs only. D VID D L CE Attorney for Plaintiff Dated: `~ Q lti.t~ ~ ~~'~Y _• 4 t ~'~. oo P ~ qm/ P.~ ast tsl