Loading...
HomeMy WebLinkAbout09-8766Our File No.: 229401 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff CACH,LLC c/o Apothaker & Associates, P.C 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. MINDY A PETROSKI 757 HAMILTON COURT CARLISLE, PA 17013-1519 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: CA - 87(0(0 01-1v tt -Te-r rn NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 Our FiR No.: 229401 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff CACH, LLC c/o Apothaker & Associates, P.C 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. MINDY A PETROSKI 757 HAMILTON COURT CARLISLE, PA 17013-1519 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is CACH, LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are MINDY A PETROSKI, an adult individual residing at 757 HAMILTON COURT CARLISLE, PA 17013-1519. 3. Plaintiff, CACH, LLC, is the Assignee and Successor in Interest of Account #4888940997486747; and said account was issued to Defendant(s) by BANK OF AMERICA, N.A., the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $6,421.50. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". "T Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $6,421.50 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & S CIATES, P.C. Attorney or P ,tiff A Law Firm Eniza ed ' Debt Collectioi BY: Dated: 12/14/2009 David J. Apotlfaker, Esquire Our File No.: 229401 VERIFICATION David J. Apothaker, Esquire hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relatingAo un4worn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 12/14/2009 CACH,LLC MINDY A PETROSKI 757 HAMILTON COURT CARLISLE, PA 17013-1519 STATEMENT OF ACCOUNT Debtor's Name: MINDY A PETROSKI Account Number: 4888940997486747 Original Creditor: BANK OF AMERICA, N.A. Balance Due: $6,421.50 Our File No.: 229401 EXHIBIT "A" 0 iL'? 03 LiLC e 1 F 2: 2 4cla.00 Po A-aq Co t c6arIo9 ,F!F* a553CQ SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor 141 Per u1 ?i7q??l( OF THE r 2018 JAN _A AN 8: 4 4 Cach, LLC Case Number vs. Mindy A. Petroski 2009-8766 SHERIFF'S RETURN OF SERVICE 12/29/2009 06:25 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 29, 2009 at 1825 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Mindy A. Petroski now known as Mindy Cordell, by making known unto herself personally, at 757 Hamilton Court, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $33.84 e-*104*e? December 30, 2009 (C Cou11tySURO Shenft. Teleosoft. Inc. By ty Sheriff SO ANSWERS, Our File No.: 229401 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorney for Plaintiff CACH, LLC Plaintiff vs. MILADY A PETROSKI Defendant ~~i t 1- ~ :~._ ~ ~ ~- Ju4 a~ Pw~ ~t ~ n5 s -rir J.Y; ` .. .. ~.J c ~ ~' COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-8766 Civil Action PRAECIPE TO ENTER JUDGMENT PURSUANT TO STIPULATION TO THE PROTHONOTARY: Please enter a judgment in favor of plaintiff, CACH, LLC, and against Defendant, MILADY A PETROSKI, for failure to comply with the terms and conditions of the Stipulation in Lieu of Judgment (Stipulation}, filed with this Court on March 4, 2010, a copy of which is attached hereto as Exhibit "A". Assess damages in the amount of: Balance: Less: Payments: Plus: Interest from March 4, 2010 TOTAL Dated: July 16, 2010 $ 6,901.92 ~I¢.oo A p ~~Y e,~ aas9 ~3 1Jolcex. ~4~.c~ Attorney for Plaintiff Our File No.: 229401 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff CACH, LLC Plaintiff vs. MINDY A PETROSKI Defendant David J. Apothaker, Esquire, certifies as follows: Civil Action 1. I am an attorney with the Law Firm of Apothaker & Associates, P.C., attorneys for the Plaintiff in the above captioned matter, and as such, have full and complete knowledge of the facts herein. 2. The matter was settled by and between the parties by Stipulation in Lieu of Judgment (Stipulation), on March 4, 2010, a copy of the Stipulation is attached hereto and marked as Exhibit "A". 3. Defendant breached this agreement by failing to make payments in accordance with the terms of said Stipulation. 4. Therefore, pursuant to the Stipulation, Plaintiff is proceeding towards the entry of Judgment in the amount of $6,901.92, giving the Defendant credit for payments made totaling COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-8766 $570.00, plus interest in the amount of $ .00, for a total of $6,331.92. I verify that the statements made in this that false statements herein are made subject to the unsworn falsification to authorities. . true and correct. I understand of 18 Pa.C.S~:` §4904, relating to David J. ~er, Esq. Attorney r Plaintiff Dated: July 16, 2010 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: MINDY A PETROSKI 757 HAMILTON COURT CARLISLE, PA 17013-1519 CACH, LLC Plaintiff vs. MINDY A PETROSKI Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-8766 Civil Action NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. ~ JUDGMENT FOR FAILURE TO COMPLY WITH THE TERMS AND CONDITIONS OF THE STIPULATION IN LIEU OF JUDGMENT JUDGMENT BY DEFAULT ^ JUDGMENT IN REPLEVIN ^ JUDGMENT BY CONFESSION ^ JUDGMENT FOR POSSESSION ^ JUDGMENT ON AWARD OF ARBITRATORS IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker Esa at this telephone number: 215-634-8920 7/a~/~ Our File No.: 229401 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorney for Plaintiff COURT OF COMMON PLEAS OF CACH, LLC } CUMBERLAND COUNTY Plaintiff ) vs. ) NO.: 09-8766 MILADY A PETROSKI ) Civil Action Defendant ) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 757 HAMILTON COURT CARLISLE, PA 17013-1519. We inquired with the web site of the Defense Wilson Boulevazd, Suite 400, Arlington, VA 222 branch of the military. / Mary M. Snavely-Dixon, Director of the efe~ our inquiry indicated that the Defendant(s) is/are n in Data Center has sent back David J. Apothaker, Esq. Attorney for Plaintiff power Data Center, located at 1600 if the Deferant(s) is/are in any I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. I1e~Yaaeat ufD~ense Maapow«tr Data Cromer X1-16-2414 i2~46~.35 Y Stataa Report Pta~artt rio tle Senioe s r,:tvi RridAd P'~TRClSKI ! M11~Y A the iedivrdarf sd~taa.~» ~ 1~C does trot potaes4 aiq' iidoraeedEa L'pan xati3idt the a><orteaooa dr>r bada die D~,resnt afDtfmse Matpower Data Cea®er, batad ca ~e itiarmateoa tltet t dta above is tee ~ t~ d~e;adisdwi as m at<araarites atdwe 1+9~i6ormed saw tA~Y. Navy, Maca;e Ccittu, A+ Fnrer, T~d011A, Pti~ir ~ atd Coast Ci'urell. ~~. arise . ~~mt, caea 16(16 Bird.. Sdte l04 Adiapat>.'V'A 22249-2543 'Ilte Defeaat ~ Data t2eatcs ie an cr~naaatiao d the De~rroaot d Defamie that autiatair tGe I,kdalsc sees}a~.d~~+~ea~t,~~a.~.~~,~yiQy naa~ ~p•~iy aa~p~.t:>te .t ~~ Svvice lM~eea C1ril RcYetAd (SO USC ~-- ~~ ifll ~ ~, as aeaesded} (S~tA) t tonown a, the Saiiars' and Salocn' { Rel1r!'Aat a!r 19~4>). D3l~C Iles k+ued krad~cdt of t6otnaods e! ''~ not l ~J' ~~ ~ ~ Mte orivided is oo adi-r dtt~r" t'tiP~s. and ~ n smat error rabr. Ia t~s a~ttlare itdiaiitpf nAdtcared aitovq a ~y t~! naaei+a. ll~i~ti. or ~raaprRatiNS awets a ~ aMeaar drt be iadirj3tft h na aetiae dory, m it "u1ilt8 to ~e P+ Gi16c Sr7lA, yoo are slter{Ijr escr~ar~ ib obtm lisdwar ~iaooo of me ptss~oia saq~s b9 ca~MCOn~ ~t geesad's &~rrice ria ie'ddauraidc:d' tAtL ` ~ Itlw Iwtva +n~idoace the paraoa is oa acelts daty and for tai w obaie thin addidorrt Sart~ler wor>l~oa, pas'tiFatpttrvi~iatr elute 5C'RA may bt avobed a~ pYxt Ste 50 L"5C' App. §537(c~. g yaa atrtaw ari~6oai wfamatinr+ai~aat Cite pecaoa tee , ae SSTI> acswracp d Dl3B, a agddr¢ ewaee}, yva can salba4t 7~ regae! asae at this R'rb air and wr A pmvide a sew ces~catc~r stet gnery_ This re~ansa rellncts aAisa dNy s11~s ~i drte the ad'i~idad srae last an aaiwe duty, Ili avsis w>Iiis ~e ptsredaf 367' lope. Far iisloricai wiocc~oq pieaar ca+aerct ffir Service SC~A posts-af-caeta~t .wfari~6ewsR "~Ied++rpaQF~atar"' Aitiwa drtyr ltrrte as seporladn this ~CSAc tr defined in acoa[dasce vai610 t7SC ~ i01(dy(1) tae a patios atrnca than 34 eaaeeetrh+e days. L tLe case of a eatmbrcr aftl~e 2~tairtmi C>ttetd. iNdua3ts serxjce n+dat a rat m atxlur se><vioe artLa~ed by the Ptaesidmot dt tLe ' of Ddme:a far a petal of ntctis titan 30 dais ceder 32 tzSC ~ 302 fot Pis of respaadie~ io a aMiaaaR Y 'bY t9r Preeidnt •ad aartmorled s7 Fadaai tLads, A/ Acsbc~r Curd R,asa~c (AGR} treathers rnmt F-r aaayaed artitut en adhadee~d atnbisrba posiion it ~ roil ~ tuppoet Uis ~trlsdes Icy TARS. Native C«Ps ARe and f)oaat (Danes RPAa_ Arline ~' ataan abe applies tao a tJoifoemed Same ateaobes talq is as acstHe dsty soot~sionsd o6ctr of the U.&. Pabtbc Had6'Serviec a IMe Natitxtd Qcaeeic and Attavspltais Admiosgratriva t~AA Cuimeeossianesi Ceep~s) far a prtiod dmare tthee 3U trt< darn Gaa~r UatA- tfre Ski tr B~vairr iu9naar Gtetcz r`avaape mdet ~ St'9tA is brooder it same rates and ax~drs sane tate~aiea ot`persa~ an active duly fa pteposes af`Ht SERA wfia maid not be tepaet~ed as os Acsas Doty seder thin ceMl6cebe. Many tees o~rkes at: amrnded to catead dte period of acAwe sty, ~;bic} wY+oid tss~d r~'RA pec#ekias. Paws neeiCeg m rely oa tMic webair eadBgMion srodd check to ataltr are, titr aides on arhitk SL7tlU pi+etertioet ate boos ~ dot bem amended to c~daad the inc3asive daces at service: Fast`atnorr, soee peaoectiors tithe SCRA mq eatsad eo persons who Ttarr t4eeieed orders b reppet for suite ditty or do be ittdaebeds bat roelrf Dave scat acioaly be~oo arliwt lacy nr ~ ~r tdncau~n 73e Last Date as Acmes Daty eatryis important beraus,e a s>ralta at*pE~utertions aC SCRA extend belropol t3tr Ira dates of aeta4r doty. TLose tvho yrotiid rely an tltit c~caee ace arprd to seek 4 kgpl eatasd to et~ie Chet at ruts gaarao~rd to Sevier atearbers ender ttie SCRA are protette3 WARNII3Cx T}a eahl6cate firm podded based at a,aar erns Ssx pru~etled by tier requrstei_ Proaicioa as atrnteooe aaoec or SSI~t r+~ hoc an et~rmeoera eai3ate to be prot+itled Kepner • ....-r---- l~N~~~~~~~~ ~ ~~ iii ~~~3 ~ ~ ~5~ ' ~ ~'f~,. Our file No.: 229401 .,•~,. APOT'H(AKER & ASSOCIAT~~ ' ~ ~E11 `~' L ~U ~~ 520 Fellowship Road C306 ,~;~~ Mount Laurel, N7 08054 24 (Q K~1~ -~ FM x~ (800) 672-0215 '~---~""""~~~^~" Attorneys far Plaintiff ,,,,,,.... t~vS'~.V ~~l1A Attorney ID# ~PiA CACH, LLC ~ ~ I , vs. MILADY A PETROSKI Defendant. } COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCTCET NO.: 09-8766 Civil Action STIPULATION IN LIEU OF NDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been. agreed upon; It is an February 11, 2010, STIPULATED by and between Plaintiff, CAGH, LLC, and Defendant, MILADY A PETROSKI parties as follows: 1. Defendant agrees to pay the sum of $b,968.08, which sum Plaintiff agrees to accept in full settlement of its claim. herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $6,96$.08 shall be paid by the by Defendant, MILADY A PETROSKI, to the attorneys for Plaintiff in the following manner: a. $.190.00 to be paid on or before the 26~' day of each month, beginning. February 26, 2010 until paid in full. Ail cheeks are to made payable to CACH, LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 t)ur fife No.: 229401 3. In the event Defendant fails to pay in accordance with the terms set 'forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment- against Defendant ex parse, in :the sum of $6,968,08, giving Defendant credit far any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex paste application, with supporting certification, and. with notice to Defendant only in the form of a copy of the application addressed to MILADY A PETROSI~I by first-class, postage prepaid. We hereby consent to the form and entry of the. within Stipulation. APOTHAI~ER & ASSOCIATES, P,C. Attorneys far Plaintiff A Law Firm Engaged i9 Debt Collection ------ ly F. clan, Esquire A PETROSKI 229401 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS , CUMBERLAND COUNTY CACH, LLC )COURT OF COMMON PLEAS } CUMBERLAND COUNTY vs. ) MINDY A PETROSKI ) N0.09-8766 To: MINDY A PETROSKI 757 HAMILTON COURT CARLISLE, PA 17013-1519 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: January 21, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR DAVID J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 Fff Law Firm of Allan C. Smith, P.C Attorney I.D. No. 204756 1276 Veterans Hwy, Suite E-I Bristol, PA 19007 1-888-275-6399//(215)428-0666 Attorney for Plaintiff FILED-OFFICE uF THE PROTHONOTARY 2811 DEC 27 PM 12: 58 CACH, LLC 4340 S. MONACO STREET DENVER, CO 80237 Plaintiff, VS. MINDY A PETROSKI 757 HAMILTON CT CARLISLE, PA 17013 COURT OF COMMONW CUMBERLAND COUNTY No.: 098766 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of CACH, LLC, the plaintiff in this action. All n . Smith, Esq. I.D No. 204756 Law Firm of Allan C. Smith, P.C 1276 Veterans Hwy- Suite E-I Bristol, PA 19007 TO THE PROTHONOTARY: WITHDRAWAL OF APPEARANCE Kindly withdrawal my appearance on behalf of CACH, LLC, the plaintiffln this action. A"pothake & Associates 520 Fell wship Road, Suite C 306 Mount Laurel, NJ 08054 Phone: (800) 672-0215 Date: December 13, 2011 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO U9-8766 Civil CIVIL ACTION - LAbL' i'O THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CACH, LLC Plaintiff (s) Fx-om 1vI[NDY A. PETROSKI, 757 HAMILTON CT., CARLISLE, PA 170]3 (1)You arc directed to levy upon the property of the defendant (s)and to sell ANY AND ALL PERSONAL, PROPERTY TO BE LEVIED UPON . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISI~EE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishees} 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 $6,331.92 Interest Attv's Comm Atty Paid $170.84 PlaintilT Paid Date: OCTOBER 15, 2012 (Sea]) L.L. $.50 Due Prothy 52.25 Other Costs ,I nL ~1J ~~~ _ ___ David D. Buell, Prothonotary ~J~- ~~/ / d.~,2G1~ ,_ De ut p Y RF.QUhSI'iNG FARTY: Name : CORRYN KRONNAGEL, ESQUIRE Address: LAW FIRM OF ALLAN C. SMITH, P.C. T"i-IE BUCKS COUNTY OFFICE CENTER 1276 VETERANS HIGHWAY, SUITE E-1 BRISTOL, PA 19007 Attorney for: PLAINTIFF Telephone.-215-428-0666 Supreme Court ID No. PRAECIPE FOR WRIT OF EXECUTION (MONF,Y JUDGMENTS- P.R.C.P. 3101 to 3149 CACH, LLC IN THE COURT OF COMMON PLEAS OF' 4340 S. MONACO STREET, 2ND FLOOR CUMBERLAND COUNTY, PENNSYLVANIA DENVER. COLORADO 80:?37 Plaintiff[s], v s. Docket No.: 09 - 8766 MILADY A PETRO5KI 757 HAMIl_TON CT : CARLISLE,, PA 17013 : ;:: _: ~ K;, _ _~__ Defendant[s]. ~ ~ ~~ ,.. ,. TO THE PROTHONOTARY OF CUMBERLAND COUNTY: `"' ~ t.-~ - ;t_ __ ~,_-; , -__ - ~_,, ISSUE and INDEX WRIT OF EXECUTION IN THE ABOVE MATTER, },~-pj ,;,. ~' (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania, (2) against MILADY A PETROSKI Defendant(s); ANY AND ALL PERSONAL PROPERTY TO BE LEVIED ON. (3) anal against Garnishee(s); as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property to be levied upon by Sheriff) (4) Amount Due $ 6,331.92 Ulterest from TOTAL SC~ DATE: October 09, 2012 ~~ ~ a S~ s~ c~~ 33 ~ 8~f ~r t~ ~~ plus costs. ,--;. /~~ ' ~ "~ , f Corr Kronnagel, Esq. ~.__~ ~ a ~ , , , ~ .~ ~s ~ C~. `~~~~.~ ~~aao2,t ~~~~ ~ t~X ~SS~~'C~ CACH, LLC' : IN THE COURT OF COMMON PLEAS OF 4340 S. MONACO STREET, 2"~' CUMBERLAND COUNTY. PENNSYLVANIA FLOOR DENVER, COLORADO 80237 Plaintiff[s], vs. Docket No.: 09 - 8766 ~-~ - MINDY A PETROSKI ` ~~ ~ ~ ~ ~~ -~ - ,; --; 757 HAMILTON CT - ~' '- ~, CARLISI_.E. PA 1.7013 ""^ ~ ~ `'~' ,~`~; _~' Defendant[s]. _ ~-~ --~~..- - ~7 -~- . ~; _._;, WAIVER OF WATCHMAN ;. ~ ~,.. '~ c~ BY ORDER OF THE SHERIFF OF CUMBERLAND COUNTY COURTHOUSE -CARLISLE, PA 17013 SIR: There will be placed in your hands for service a Writ of Execution, styled as follows: CACH, LLC, Plaintiff(s) vs. MILADY A PETROSKI, Defendant(s). (1) The defendant will be found at: 757 HAMILTON£~ CARLISLE, PA 1701 ~, ; , ~~C,.9rry Kronnagel, Esq. ,~ (2) If Writ of Execution, state. below where Defendant will be found, what goods and chattels shall be seized and be levied upon. If real estate, attach three copies of description (not place of record) together with street and number of the premises. ANY AND ALL PERSONAL PROPERTY OF THE DEFEDNANT TO BE LEVIED ON LOCATED AT 757 HAMILTON CT CARLISLE, PA 17013. (3) WAIVER OF WATCHMAN -Any deputy sheriff levying upon or attaching any property under within m;ay leave same without a watchman, in custody of whoever is found in possession, after notifying such person of such levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof. ~i ~ ~ ; f' ( ~ Kronnagel, Esq. `~ LAW FIRM OF ALLAN C. SMITH, P.C THE BUCKS COUNTY OFFICE CENTER 1276 VETERANS HIGHWAY, SUITE E~-1 BRISTOL, PENNSYLVANIA 19007 PH: (215) 428-0666 /FAX: (2 l5) 428-0740