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Home My WebLink About10-5286-- /D 5ag(a s COMMONWEALTH OF PENNSYLVANIA r_nl INTV nG COMMERLAW 09-3-02 MDJ Name: Hon. VIVIAN COBICK Addrew, 55 PENN DR NBNVILLS, PA Telephone: (717) 776-3187 17241 CARLISLE, PA 17015 in the amount of $ S86TRON 1 ZWZNG & FABRICATION L J 85 J=Z ROAD Docket No.: CV- 0000160 - 09 CARLISLE, PA 17015 Date Filed: 11/19/09 veto THIS IS TO NOTIFY YOU THAT: Judgment: FOR PLAINTIFF (Date of Judgment) 2/09/10 ® Judgment was entered for: (Name) PRIi11TJ! - O - STAT, IM, ® Judgment was entered against: (Name} 813MROM WELDIM & FABRICATION 1 104 43 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 $ Amount of Judgment $ J., UJJ a i7 Judgment Costs $71-0 Interest on Judgment $~UO Attorney Fees $- UU Total $ 1,104.29 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. NOTICE OFCJIU? CASE RRANSCRIPT PLAINTIFF: NAME ant ADDRESS I rP-RYNT-0-STAT, INC 5040 LOUISE DRIVE SUITE 110 ?NECHANICSBDRG, PA 17055 J VS. DEFENDANT: NAME and ADDRESS rSErTRM UMDI>6>PG & FABRICATION 85 KUTZ R0hD -/& -- Date r,-)d - IF District I certify that this is a true and rrect copy of thiVreco of the,proceedings containing the judgment. 8 - -0701 U Date , Magisterial District Judge My commission expires first Monday of January, 2012 SEAL AOPC 315-07 DATE PRINTED: 2/09/10 10:17:00 AN ZoAgeris Arta: rs Fax2s r?"L )W? Cldl* 3LGZS 12-4` dtl (0(.85 /)C,4It£. rrtk i ?40( v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PRINT-O-STAT, INC. 5040 LOUISE DRIVE, SUITE 110 MECHANICSBURG, PA 17055 . Plaintiff No. V. SHETRON WELDING & FABRICATION 85 KUTZ ROAD CARLISLE, PA 17015 Defendants NOTICE OF FILING JUDGMENT (X) Notice is hereby given that a Judgment in the above-captioned matter has been entered against you in the amount of $1,104.29 plus costs on February 9, 2010. (X) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. &thonotary Civil Div. If you have any questions regarding this Notice, please contact the filing party: NAME: Glenn J. Smith, Esquire ADDRESS: 135 North George Street g, York, PA 17401 e? TELEPHONE NO: (717) 848-4900 (This Notice is given in accordance with Pa. R.C.P. 236.) - 1 NOTICE SENT TO: NAME Shetron Welding & Fabrication: 85 Kutz Road • - _ Carlisle, PA 17015 (00401596/1) FILED-OFFICE OF THE PROTHONOTARY 2011 FEB -8 AM 11: 50 CUMBERLAND NVCOUNTY COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRINT-O-STAT,INC., Plaintiff, V. Docket No.: 10-5286 SHETRON WELDING & CIVIL TERM FABRICATION, , Defendant. For Plaintiff: Glenn J. Smith, Esquire Supreme Court I.D. #85925 135 North George Street York, PA 17401 717-848-4900 For Defendant: Shetron Welding & Fabrication 85 Kutz Road Carlisle, PA 17015 Stephanie DiVittore, Esq. Rhoads & Sinon, LLP One South East Market Street 12th Floor P.O. Box 1146 Harrisburg, PA 17108-1146 PLAINTIFF'S MOTION TO COMPEL INTERROGATORIES IN AID OF EXECUTION AND REIMBURSEMENT OF LEGAL COSTS DIRECTED TO DEFENDANT Submitted by Print-O-Stat, Inc. (ooaaz0621) COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRINT-O-STAT,INC., Plaintiff, V. Docket No.: 10-5286 SHETRON WELDING & CIVIL TERM FABRICATION, Defendant. PLAINTIFF'S MOTION TO COMPEL INTERROGATORIES IN AID OF EXECUTION AND REIMBURSEMENT OF LEGAL COSTS DIRECTED TO DEFENDANT NOW COMES, Print-O-Stat, Inc., by and through its undersigned counsel and files the within Motion to Compel Interrogatories in Aid of Execution and Reimbursement of Legal Costs t and states as follows in support thereof. 1. Movant is Plaintiff, Print-O-Stat, Inc., who initiated the within action by transferring a Magisterial District Judgment to the Cumberland Court of Common Pleas on August 10, 2010. 2. Respondent is Defendant, Shetron Welding & Fabrication, whom judgment is held against in the above captioned case. 3. Plaintiff served Defendant with Interrogatories in Aid of Execution ("Interrogatories") pursuant to Pennsylvania Rule of Civil Procedure 4009.1 on or about October 21, 2010. A copy of said discovery request is attached hereto and incorporated herein as Exhibit «A» 4. Defendant has failed and/or refused to provide answers to the Interrogatories. {00442062/3} 5. On January 17, 2011 Plaintiff directed correspondence to Defendant requesting answers to the Interrogatories within seven (7) days. A copy of said correspondence is attached hereto and incorporated herein as Exhibit "B". 6. On January 24, 2011 Defendant's counsel advised Plaintiff that Defendant was no longer in business and that it had closed its doors. A true and correct copy of the January 24, 2011 correspondence from Defendant's counsel is attached hereto, made a part hereof and marked as Exhibit "C". 7. Since receiving said letter, Plaintiff has observed that Defendant is still in operation despite its counsel asserting otherwise. 8. On January 24, 2011, Defendant's counsel also advised that it discontinued their representation of Defendant; although, no praecipe has been filed by counsel. See Exhibit "C". 9. Defendant has indicated that it will not respond to Plaintiff's Interrogatories in Aid of Execution. 10. Defendant's conduct, specifically its claim to have ceased operations in order to avoid the underlying judgment, is dilatory. 11. As a result of Defendant's dilatory conduct, Plaintiff has been forced to incur additional legal costs, including the preparation and presentation of this Motion and, therefore, requests reimbursement from Defendant of its cost to do so in the amount of $750.00. WHEREFORE, Plaintiff respectfully requests that this :Honorable Court enter an Order compelling Defendant to provide full and complete responses to Plaintiff's First Set of Interrogatories in Aid of Execution within one (1) week's time via electronic mail, regular mail, (00442062/3) or facsimile and reimburse Plaintiff the sum of $750.00 for the preparation and presentation of this Motion within thirty (30) days. Respectfully submitted, CGA L Sm' so By: Supreme Court I.D. #85925 135 North George Street York, PA 17401 717-848-4900 717-843-9039 GSmith@CGALaw.com Attorney for Plaintiff (00442062/3) AR L A W F I R M Shane M. Rohrbaugh Litigation Paralegal srohrbaugh@cgalaw.com Ext. 146 October 21, 2010 VIA FIRST CLASS MAIL Shetron Welding & Fabrication 85 Kutz Road Carlisle, PA 17015 Re: Print-O-Stat, Inc. v. Shetron Welding & Fabrication Dear Sir or Madam: Enclosed please find a copy of Plaintiff's First Set of Interrogatories in Aid of Execution. Please complete the Interrogatories in full within 30 days of the date of this letter and return them in the postage paid envelope. If you have any questions, comments, or concerns regarding the Interrogatories please do not hesitate to contact our office and we will be glad to assist you. Sincerely, Shane M. Rohrbaugh Litigation Paralegal /smr Enclosure {00416071/I) EXHIBIT CGA Law Firm, CGA Professional Center, 135 N. George Street, York, PA 17401, 717.848.4900, Fax 717.843.9039, www.caalaw(-nr„ "Wf"Alk' L A W F I R M Shane M. Rohrbaugh Paralegal srohrbaugh@cgolaw.com Ext. 146 January 17, 2011 Stephanie DiVittore, Esq. Rhoads & Sinon, LLP One South East Market Street 12`h Floor P.O. Box 1146 Harrisburg, PA 17108-1146 Shetron Welding & Fabrication 85 Kutz Road Carlisle, PA 17015 Re: Print-O-Stat, Inc. v. Shetron Welding & Fabrication Dear Attorney DiVittore and Sir or Madam: On October 21, 2010, Attorney Glenn Smith, Counsel for Print-O-Stat, Inc. sent Interrogatories in Aid of Execution with a letter requesting a response within 30 days of the date of the letter. Our office has yet to receive a response to the Interrogatories in Aid of Execution. Please forward the Answers to our office within 7 days of the date of this letter. If we do not receive a copy of the Answers we will file a Motion to Compel with the Cumberland County Prothonotary Office. Please guide yourself accordingly. Sincerely, Shane M. Rohrbaugh Paralegal /smr EXHIBIT B 10441911!1 f CGA Law Firm, CGA Professional Center, 135 N. George Street, York, PA 17401, 717.848.4900, Fax 717.843.9039, www.cgalaw.com Stephanie E. DiVittore ph (717) 237-6781 RHOADS & SINONLLP s (717)138-8623 sd i v i tt o re @ r h o ad s-n i n o n .com FILE NO: 9787/1 January 24, 2011 Re: Print-O-Stat, Inc. v. Shetron Weldin & Fabrication Shane Rohrbaugh CGA Law Firm 135 N. George Street York, PA 17401 Dear Mr. Rohrbaugh: Please be advised that Shetron Welding & Fabrication is no longer in business. We have discontinued our representation of the company. Shetron Welding has closed its doors, and we have no authorization to take any action with respect to ongoing litigation. As a result, we are not authorized to respond to discovery in the above-captioned matter. Please advise if there are any questions or comments. Very truly yours, RHOADS & SWON LLP By: e;?7 v 1 _4-?_ `-Z? Stephanie E. DiVittore 805296.1 One South Market Square, 12th Floor • P.O. Box 1146 • Harrisburg' PA 17108-1146 • ph: 717.233.5731 www rhoads- - sinon.com CERTIFICATE OF SERVICE I hereby certify that on this 7th day of February, 2011 Plaintiff's Motion to Compel Interrogatories in Aid of Execution Directed to Defendant has been served via first-class mail, postage prepaid, upon the following: Shetron Welding & Fabrication 85 Kutz Road Carlisle, PA 17015 Stephanie DiVittore, Esq. Rhoads & Sinon, LLP One South East Market Street 12th Floor P.O. Box 1146 Harrisburg, PA 17108-1146 CGA LAW FIRM Shane M. Rohrbaugh, Paralegal for Glenn J. Smith, Esquire {00442062/3) PRINT-O-STAT, INC., Plaintiff V. SHETRON WELDING & FABRICATION, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-5286 CIVIL TERM CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 24th day of February, 2011, the Defendant is directed to serve upon Plaintiff full and complete responses to Plaintiff's First Set of Interrogatories in Aid of Execution within 30 days of today's date or suffer sanctions. By the Court, Edward E. Guido, J. ? Marisa G. Butten, Esquire CGA Law Firm 135 North George Street York, PA 17401 Attorney for Plaintiff ? Shetron Welding & Fabrication 85 Kutz Road Carlisle, PA 17013 srs Co,-1e5 rua, led of -4/( tom, ? `? ? j??fi CO e ; . 4 ? ? j