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HomeMy WebLinkAbout01-0813LANDSTAR LOGISTICS, 1NC. and LANDSTAR GEMINI, INC. Plaintiffs, V. KENNETH L. LONG and TIMEWAY CORP, INC. Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Docket No. Gl PRAECIPE TO ENTER FOREIGN JUDGMENT Plaintiffs, Landstar Logistics, Inc. and Landstar Gemini, Inc,, by and through its counsel, Saul Ewing LLP, respectfully requests this Court enter the Judgment originally entered by the U.S. District Court for the Middle District of Pennsylvania in its favor against Defendants, Kenneth L. Long and Timeway Corp., Inc. in the amount of $ l 6,379.10, together with interest at statutory rate of 5% per annum, plus cost of suit, as a judgment in this Court. A certified copy of the Abstract of Judgment is attached hereto and is marked as Exhibit "A". Respectfully submitted, Dated: February 8, 2001 Pai~e Macdonald-Matthes Attorney I.D. No. 66266 Saul Ewing LLP Penn National Insurance Tower 2 North Second Street, 7th Floor Harrisburg, PA 17101 (717) 257-7500 Exhibit A ABSTRACT OF JUDGMENT Notice pursuant to Title 28, Un~ted States Code, Section 3201, this judgment, upon the filing of thin abstract in the manuer in which a notice of tax hen would be ftled under paragraphs (1) and (2) of 26 U.S.C 6323(I'), creates a hen on all real property of the defendant(s) and has priority over all other liens or encumbrances which are perfected later in time. The lien created by this section ia effective, unless satisfied, for a period of 20 years and may be renewed by filing a notice of renewal. If such notice of renewal is filed before the expiration of the 20 year period to prevent the expiration of the lien and the court approves the renewal, the lien shall relate back to the date the judgment was filed. Names and addresses of parties against whom judgments have been obtained Names of Parties in whose favor judgments have been obtained Kenneth L. Long Landstar Logistics, Inc. 13 Westwood Court Enola, PA 17025 Landstar Gemini, Inc. Timeway Corp, Inc. 2841 Turnpike Industrial Middletown, PA 17057 Park Docket No. 1:CV-00-0034 US Middle Distr~ct of PA Amount of Judgment Names of Creditors' Attorneys When Docketed $16,379.10 Paige Macdonald-Matthes 15% interest Saul Ew~ng per annum 2 No~ch Second Harr~burg, PA (717) 238-7675 UNITED STATES OF AMERICA, 1/22/01 LLP Street, 7th Floor 17101 CLERK'S OFFICE U,S. DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA I CERTIFY, that the foregoing is a correct Abstract of the Judgment entered or registered by this court. ate,, h Deputy Clerk LANDSTAR LOGISTICS, INC. and LANDSTAR GEMINI, INC. Plaintiffs, V. KENNETH L. LONG and TIMEWAY CORP, INC. Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Docket No. C)/- ~5~,~ NOTICE OF ENTRY OF JUDGMENT To: Kenneth L. Long and Timeway Corp, Inc., Defendants YOU ARE HEREBY NOTIFIED that on January 22, 2001, the following Judgment has been entered against you in the above captioned case in the sum of Sixteen Thousand Three Hundred Seventy-Nine and 10/100 Dollars ($16,379.10), together with interest at statutory rate of 5 % per annum, plus cost of suit. Prothonotary I hereby certify that the names and addresses of the proper persons to receive this Notice under Pa. R.C.P. 236 is: Kenneth L. Long 13 Westwood Court Enola, PA 17025 Timeway Corp, Inc. 2841 Turnpike Industrial Park Middletown, PA 17057 794682 2/8/01 LANDSTAR LOGISTICS, INC. and LANDSTAR GEMINI, INC. Plaintiffs, V. KENNETH L. LONG and TIMEWAY CORP, INC. Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Docket No. 01-813 Civil Term PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Please issue a Writ of Executiun in the above matter, (1) (2) (3) (4) directed to the Sheriff of Cumberland County; against Kemaeth L. Long, 13 Westwood Court, Enola, PA 17025 and Timeway Corp, Inc., 2841 Turnpike Industrial Park, Middletown, PA 17057, defendants; and against Fulton Bank, 3~d & Locust Streets, Harrisburg, PA 17108, garnishee: and index this writ (a) against Kenneth L. Long and Timeway Corp, Inc., defendants (b) against Fulton Bank as garnishee, as a hs pendens against real property of the defendants and the name of garnishee as follows: (a) any property located in the defendants' residence located at 13 Westwood Court, Enola, Cumberland County, Pennsylvania 17025. (b) any and all bank accounts titled in the name of Kenneth L. Long, Individually and Timeway Corp, Inc., and account no. 181-912-2020 titled in the name of Timeway Corp, Inc. (5) Amount due $ 16,379.10 Interest from 1/22/01, 15% per annum Plus Costs $ to be determined $ 192.52 $16,379.10 Plus interest from 1/22/01 and costs ~94642 2/9/01 Dated: February 9, 2001 Paige Macdonald-Matthes ' Attorney I.D. No. 66266 Saul Ewing LLP Penn National Insurance Tower 2 North Second Street, 7th Floor Harrisburg, PA 17101 Attorney for Plaintiff 794642 2/9/01 -2- LANDSTAR LOGISTICS, INC. and LANDSTAR GEMINI, INC. Plaintiffs, V. KENNETH L. LONG and TIMEWAY CORP, INC. Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Docket No. 01-813 AMENDED PRAECIPE TO ENTER FOREIGN JUDGMENT Plaintiffs, Landstar Logistics, Inc. and Landstar Gemini, Inc., by and through its counsel, Saul Ewing LLP, respectfully requests this Court enter the Judgment originally entered by the U.S. District Court for the Middle District of Pennsylvania in its favor against Defendants, Kenneth L. Long and Timeway Corp., Inc. in the amount of $16,379.10, together with interest at a rate of 15% per annum, plus cost of suit, as a judgment in this Court. A certified copy of the Abstract of Judgment is attached hereto and is marked as Exhibit "A". Respectfully submitted, Dated: February 16, 2001 Paige Macdonald-Matthes Attorney I.D. No. 66266 Saul Ewing LLP Penn National Insurance Tower 2 North Second Street, 7th Floor Harrisburg, PA 17101 (717) 257-7500 79468.2 2/16/01 Exhibit A ABSTRACT OF JUDGMENT Notice Pursuant to Title 28, United States Code, Section 3201, this judgment, upon the filing of this abstract in the manner in which a notice of tax lien would be filed under paragraphs (1) and (2) of 26 U.S.C 6323 (f), creates a lien on all real propert~ of the defendant(s) and has priority over all other liens or encumbrances which are perfected later in time. The lien created by this section is effective, unless satisfied, for a period of 20 yea~s and rn~y be renewed by ill/rig a notice of renewal. If such notice of renewal is filed before the expiration oftha 20 year period to prevent the expiration of the lien and the cour~ approves the renewal, the lien shall relate back to the date the judgment was f~.ed. Names and addresses of Parties against whom judgments have been obtained Kenneth L. Long 13 Westwood Court Enola, PA 17025 Timeway Corp, Inc. 2841 Turnpike Industrial Middletown, PA 17057 Park Docket No. 1:CV-00-0034 US Middle District of PA Names of Parties in whose favor judgments have been obtained Landstar Logistics, Inc. Landstar Gemini, Inc. FILED HARRISBURG, PA FEB 8 2005 Amount of Judgment Names of Creditors' Attorneys When Docketed $16,379.10 15% interest per annum Paige Macdonald-Matthes Saul Ewin9 LLP 1/22/01 UNITED STATES OF AM~RICA~ CLERK'S U,S. DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA I CERTIFY, that the forego~g is a correct Abstract of the Judgment entered or registered by. this, court. Mary E. D'Andrea, Clerk of Court Certified f orn re ord Mary E.. Ancirea, Olerk LANDSTAR LOGISTICS, INC. and LANDSTAR GEMINI, INC. Plaintiffs, ¥. KENNETH L. LONG and TIMEWAY CORP, INC. Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Docket No. 01-813 AMENDED NOTICE OF ENTRY OF JUDGMENT To: Kenneth L. Long and Timeway Corp, Inc., Defendants YOU ARE HEREBY NOTIFIED that on January 22, 2001, the following Judgment has been entered against you in the above captioned case in the sum of Sixteen Thousand Three Hundred Seventy-Nine and 10/100 Dollars ($16,379.10), together with interest at a rate of 15 % per annum, plus cost of suit. I hereby certify that the names and addresses of the proper persons to receive this Notice under Pa. R.C.P. 236 is: Kenneth L. Long 13 Westwood Court Enola, PA 17025 Timeway Corp, Inc. 2841 Turnpike Industrial Park Middletown, PA 17057 LANDSTAR LOGISTICS, INC. and LANDSTAR GEMINI, INC. Plaintiffs, V. KENNETH L. LONG and TIMEWAY CORP, INC. Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Docket No. 01-813 PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the above referenced Judgment, which was entered in favor of Plaintiffs, Landstar Logistics, Inc. and Landstar Gemini, Inc., and against Defendants, Kenneth L. Long, Individually and Timeway Corp., Inc. in the mount of $16,379,10, together with interest at a rate of 15% per annum, plus cost &suit on January 22, 2001, as satisfied. Respectfully submitted, Dated: March 16, 2001 Paige Macdonald-Matthes Attorney I.D. No. 66266 Saul Ewing LLP Penn National Insurance Tower 2 North Second Street, 7th Floor Harrisburg, PA 17101 (717) 257-7500 80216.1 3/16/01 CERTIFICATE OF SERVICE I, Aimee J. Albright, hereby certify that on this 16th day of March, 2001, I served a true and correct copy of the foregoing Praecipe to Satisfy Judgment via First Class Mail, postage prepaid, upon the following: Lloyd Persun, Esquire Mette, Evans & Woodside 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 Secretary to Paige Macdonald-Matthes WRIT OF EXECUTION and/or ATrACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cumberland COUNTY: from 01-813 CIVILTERM CIVIL ACTION - LAW To satisfy the debt, interest and costs due Landstar Logistics, Inc. and Landstar Gemini, Inc. PLAINTIFF(S) Kenneth L. Long, 13 Westwood Court, Enola, PA 17025 and Timeway Corp, Inc., 2841 Turnpike Industrial Park, Middletown, PA 17057 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to seil any property located in the defendants' residence located at 13 Westwood Court, Enola, PA 17025 You are also directed to attach the properly of lhe defendant(s) not levied upon in the possession of __ any and all bank accounts titled in the name of Kenneth L. Long, Individually and Timeway Corp, Inc., and account no 181-912-2020 titled in the name of Timeway Cox]p, Inc. Garnishee Fulton Bank, 3rd & Locust Streets, Harrisburg, PA 17108 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are 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 lhat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $16,379.10 Interest from 1/22/01, 15% per annu~n Atty's Corem % Atty Paid $33.00 Plaintiff Paid Date: REQUESTING PARTY: Name Address: Attorney for: Telephone: Supreme Cou~t ID No. _ Paiqe Macdonald-Matthes, Esq. 2 North Second Street, 7th Floor Harrisburg, PA 17101 Plaintiff 7~7-238 $57~ q~ 66266 L.L. $.50 Due Prothy $1.00 Other Costs $192.52 Deputy to law, states sheriff's Costs: Docketing Poundage Law LSbrary Prothonotary Service Out of County Surcharge Levy Dauphin County Garnishee R. Thomas K]ine, Sheriff, who being duly sworn according this writ is returned SATISFIED. Advance Costs: $460.53 518.00 Sheriff's Costs: 460,53 327.58 $ 0,00 .50 1.00 6.20 9.00 40.00 20.00 29.25 9.99 $460.53 Thomas K]in~, Sherif Sworn and subscribed to before me day - / / Prothonotary ~heriff LANDSTAR LOGISTICS, INC. and LANDSTAR GEMINI, INC. Plaintiffs, ¥. KENNETH L. LONG and TIMEWAY CORP, INC. Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Docket No. 01-813 PRAECIPE TO SATISFY JUDGMENT TO THEPROTHONOTARY: Kindly mark the above referenced Judgment, which was entered in favor of Plaintiffs, Landstar Logistics, Inc. and Landstar Gemini, Inc., and against Defendants, Kenneth L. Long, Individually and Timeway Corp., Inc. in the amount of $16,379.10, together with interest at a rate of 15% per annum, plus cost of suit on January 22, 2001, as satisfied. Respectfully submitted, Dated: March 16, 2001 Paige Macdonald-Matthes Attorney I.D. No. 66266 Saul Ewing LLP Penn National Insurance Tower 2 North Second Street, 7th Floor Handsburg, PA 17101 (717) 257-7500 CERTIFICATE OF SERVICE I, Aimee J. Albright, hereby certify that on this 16th day of March, 2001, I served a true and correct copy of the foregoing Praecipe to Satisfy Judgment via First Class Mail, postage prepaid, upon the following: Lloyd Persun, Esquire Metre, Evans & Woodside 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 Aim J.~A~~~ Secretary to Paige Macdonald-Matthes SHERIFF'S RETURN 0335-N - -2001 PERSONAL PROPERTY WRIT OF EXECUTION & ATTAC~IMENT LANDSTAR LOGISTICS INC AND LANDSTAR GEMINI INC vs LONG KENNETH L AND TIMEWAY CORP INC D/Id Now: February 14, 2001 A-nd Now: February 15, 2001 Receipt % 146548 And Now: February 15, 2001 at 9:42 A.M. Receipt # 146549 /Lnd Now: February 15, 2001 at 9:54 A.M. Receipt # 146549 And Now: February 15, 2001. at 3:13 P.M. And Now: February 15, 2001 at 3:14 P.M. And Now: February 15, 2001 at 3:17 P.M, And Now: February 15, 2001 at 3:23 P.M. And Now: February 16, 2001 at 12:25 P.M. SERVED ROBINDATA STRAUSER CSR And Now: March 2, 2001 at 4:45 P.M. PPER ATTY COLLECTED $9966.85 ON ACCT And Now: March 7, 2001 BAL DUE $116.33 A/id Now: March 16, 2001 Receipt # 147661 at 3:03 P.M. RECEIVED FROM PROTHONOTARY - PP at 9:37 A.M. PAYMENT RECEIVED at 11:03 A.M. at 11:41 A.M. PAYMENT RECEIVED PAYMENT VOIDED INITIAL SERVICE INITIAL SERVICE INITIAL SERVICE INITIAL SERVICE SERVED GARNISHEE(S} PP ~ STAYED BALANCE DUE PAYMENT RECEIVED Pm/TS Sheriff's Costs State/Prothonotary Fee Poundage $47.00 $20.00 $199.33 $266.33fW! J. R. Lotwick, Sheriff 3/19/2001 PAGE