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HomeMy WebLinkAbout10-5623IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE LLC Plaintiff No. It) - 5 ?? C?V i1TP.X? VS. KRISTY NOONAN Defendant CIVIL ACTION PRAECIPE FOR TRANSFER OF JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: L, 7 W N Kindly enter judgment: in favor of Plaintiff and against the above-named defendant(s), pursuant to Pa.R.C.P.D.J. No.402(D), for failure of defendant(s) to appeal, within 30 days, a judgement entered September 29, 2008 against the above-named defendant(s) before District Justice Charles A. Clement, Jr., as set forth in the transcript of judgment, which is attached hereto. Assess damages as follows: Judgment Amount 8,129.75 Payments Total $8,129.75 Dated: August 24, 2010 l •t :y AMATO AND ASSOCIATES, P.C. By: Wald Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM *V-,95 P0 All 2080239 C* 019( m e 2u-1 yrc Lf I u*e "cl COMMONWEALTH OF PENNSYLVANIA COUNTY OR Cp1®ERLAND Mag. DiSt. No. 09-1-01 MDJ Name "Hon. CHARLES A. CLEMENT, JR AJdresa400 BRIDGE ST OLDS TONNE CONKONS -SUITE 3 MM CMMZRLAND, PA Telephone: (717 ) 774-5989 17070 /O - 523 lc?T/T NOTICE OFCJ?UDGMENEN V CASE PLAINTIFF: NAME and ADDRESS FRUDSON & XZYSE LLC/C/O ANATO SONG 107 N COMMERCE MAY APT/STE 100 COLLECTION TRUST ACCOUNT LHETHLZRZK, PA 18017 J VS. DEFENDANT: NAME and ADDRESS rNOONAN, ZRISTY 415 5TH STREET APT/STE 2 NEW CUMBERLAND, PA 17070-1815 L J HUDSON a LEYSE LLC/C/O AMATO &USOC 107 N COMMERCE MAY APT/STE 100 DDocket No.: ate Filed: 8/15/088-08 COLLECTION TRUST ACCOUNT B11i ERM, PA 18017 ' THIS IS TO NOTIFY YOU THAT: DEFAULT JUD=ZNT PLTF Judgment: (Date of Judgment) 9/29/08 ON Judgment was entered for: (Name) HUDS I& 1[EYSE LLC/C/O AMATO i ® ® Judgment was entered against: (Name) NOONAN, KRZOTY in the amount of $ 6,129.77 1-1 Defendants are jointly and severally liable. 0 Damages will be assessed on Date & Time El 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 Judgment Costs interest on Judgment j Attorney Fees Total I Post Judgment Credits Post Judgment Costs $ 6,000.00 $ .7 $`. o $ 8,129.751 I Certified Judgment Total $ DIVISION. YOU ANY OF APPEAL WITH THE PROTHONOTARY/CLERK OF HE COURT F COMMON PLEAS, JUDGMENT NOTICE 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 HE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM HE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE . UNLESS THE JUDGMENT IS ENTERED IN HE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF HE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. SEP 2 9 20080ate I certify that this is a true 8/13/10 Date 2014 My commission expires first Monday of January, AOPC 315-07 DATE PRINTED: 9/29/08 Magisterial District Judge qs containing the judgment. , Magisterial District Judge 4:11:00 PM SEAL "?i i0 pt1G 3o Pty 3' 15 j JUN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE LLC Plaintiff No. VS. KRISTY NOONAN Defendant CIVIL ACTION CERTIFICATION OF ADDRESSES I do certify that the precise last known address of the within named plaintiff is: 382 Blackbrook Road Painesville OH 44077 I do certify that the precise last known address of the within named defendant is: 415 5th Street, #2 NEW CUMBERLAND PA 17070-1815 AMATO ASSOCIATES, P.C. By: Wald Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE LLC Plaintiff : No. vs. KRISTY NOONAN : CIVIL ACTION Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHAMPTON The undersigned, being duly sworn, according to law, deposes and says that he is unable to determine whether or not the above 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 Servicemembers Civil Relief Act; That Kristy Noonan is over 18 years of age, resides at 415 5th Street, #2, NEW CUMBERLAND PA 17070-1815 and is employed; Sworn to and subscribed before me this` day 2010 of0 NOTARY UBLIC NOTARIAL SEAL - GEOFFREY G SCHOENECK NotWy Public HANOVER TOWNa1FNP, NORTHAM;RTC:? C My Co 1- ifteloel Expk t 1w ah 2$, "; ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE LLC Plaintiff VS. KRISTY NOONAN No. : CIVIL ACTION Defendant NOTICE OF JUDGMENT (XX) NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST THE ABOVE-NAMED DEFENDANT(s) IN THE AMOUNT OF $8,1a9.175 ON Al • ?O , 2010. ( ? A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF THE IT N JUDGMENT IS/ARE ENCLOSED. I RY - CU BERLAND COUNTY PROTHO M4;? Per: If you have any questions concerning the above, please contact the undersigned. AMATO AND ASSOCIATES, P.C. By: Wald Amato, Esq., Atty ID #32323 Michael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE LLC Plaintiff Vs. KRISTY NOONAN 1q15 5k&.,*12 New &mb,--,&o(. PA 1'10?0 Defendant(s) cv No. 10-5623 Civil Term ` ; 11,;01 o "r7 --I r" F PRAECIPE FOR WRIT EXECUTION = Ti° (MONEY JUDGMENT) : ; .? c w M M To the Prothonotary - Cumberland County: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of CUMBERLAND County, for debt, interest and costs upon the following described property of the defendant(s) All cash on hand or in the possession of the defendant(s), accounts receivables, furniture, furnishings, eauipment, inventorv, tools. vehicles, electronic equipment, any and all other personal property belonging to the above- named defendant(s). (2) against KRISTY NOONAN, Defendant(s) (3) and against ........................................Garnishee(s) (4) and index this writ (a) against ..................................Defendant(s) and (b) 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 the property) * V.oo Pb" 0111. (25 C8F (5) Amount Due $ 8,129.75 a,50 1, Statutory Interest 5??5? ATM From August 30, 2010 $ 20.49 Less Payment $ 0.00 Costs $ Poundage $ a.oo NeCo Total $ 8,150.24 .50 LL AMATO AND LESSA, P.C. By: Date:September 14, 2010 Ronald Amato Attorney I.D. No. 32323 Attorney File#: 2080239 Attorneys for Plaintiff dfrol y8s 00148545 Ortq&" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE LLC Plaintiff No. 10-5623 Civil Term VS. KRISTY NOONAN CIVIL ACTION Defendant(s) CERTIFICATION OF DEFENDANT(s) ADDRESS FOR SERVICE c? Ca ? .YY.'p•q ? pip • i :'? ? mom ?„r ru ?s o -acs C-) ? Qn CYN I do certify that the precise last known address of the within named defendant(s) is the address provided below, and request that the Sheriff serve the above named defendant(s) at: 415 5th Street, #2 NEW CUMBERLAND PA 17070-1815 AMATO AND LESSA, P.C. By: loe Dated:September 14, 2010 l/ Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff Attorney File #:2080239 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HUDSON & KEYSE LLC Plaintiff VS. KRISTY NOONAN Defendant(s) To the Sheriff: No. 10-5623 Civil Term CIVIL ACTION -:s - 'y O C? ° C-) =C) C) WAIVER OF WATCHMAN v cr % Any deputy sheriff levying upon or attaching any property under the within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of 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 the sheriff's sale thereof. Dated: September 14, 2010 AMATO AND 7A,? By: RgKald Amato-,-Esq., Any ID #32323 ichael R. Lessa, Esq., Atty ID #88617 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Attorney File #: 2080239 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5623 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HUDSON & KEYSE LLC, Plaintiff (s) From KRISTY NOONAN, 415 5`h Street, #2, New Cumberland, PA 17070 (1) You are directed to levy upon the property of the defendant (s)and to sell all cash on hand or in the possession of the defendant, accounts receivables, furniture, furnishings, equipment, inventory, tools, vehicles, electronic equipment, any and all personal property belonging to the defendant . (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 $8,129.75 Interest from 8/30/10 -- $20.49 Atty's Comm % Atty Paid $53.75 Plaintiff Paid Date: 9/20/10 (Seal) L.L.$.50 Due Prothy $2.00 Other Costs ,.,y . REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: AMATO AND LESSA, PC 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone: 610-866-0400 Deputy Supreme Court ID No. 32323 RONNY R. ANDERSON Sheriff JODY S. SMITH Chief Deputy To Whom It May Concern: of ~Cuntbpr~~ ~a RICHARD W. STEWART Solicitor October 18, 2010 -, Hudson &Keyse, LLC c~ ~~ ° ...y ~~ vs ~~' r "' .- ;~~ `~ KristyNoonan . ~ cA . ~~ Writ No. 2010-5623 , '.,cc -o ~~ Pro ert Claim Determin p Y ati e' = ~ ~ ~ ~ ° rri ~~ ~~ '" ru £~ Reference is made to Property Claim dated October 7, 2010, entered by Nathan Wintergrass, Writ of Execution No. 2010-5623 Civil Term, Hudson &Keyse, LLC vs Kristy Noonan. Ronny R. Anderson, Sheriff, has determined that the claimant, Nathan Wintergrass, in the above mentioned property claim, is the owner of the property set forth in the claim. cc Ronald Amato, Atty for Plaintiff Kristy Noonan, Defendant Nathan Wintergrass, Claimant o~~ti~ OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 So Answers: R .Anderson, Sheriff By ~~ NOTICE OF PROPERTY CLAIM Hudson & Keyse, LLC In the Court of Common Pleas Cumberland County, Pennsylvania VS Kristy Noonan No. 2010-5623 Civil Term Writ of Execution TO THE DEFENDANT AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Nathan Wintergrass, claiming property listed therein. Unless an appraisal of the property is requested within (10) days from the date of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. Date 10-07-10 Cc Ronald Amato, Atty for Plaintiff Kristy Noonan, Defendant Nathan Wintergrass, Claimant S er' of Cumberland County B ., ~ "~ PROPERTY CLAIM ~UdSah q»d J~cySe LAC VS ~r i si., Naon a» TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVA1vIA In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. l d ~ ,r6 2 ~ The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY So'fA - w~lr~~P Glotln - ~ VALUE ~N4o,oo lov¢ S~af "wo'oalen yreeri c1~t-1 -I ~-PAi/S - ~'aN CJ07FV1 -.I~ g ~se,po ~~50.0p p"cfvrac5 ~~ ldya55 boo ,3 Camns ~ wti; is /n4r6/e -1_ _ 9z7S. oa 9 5-po, 00 ~1 >aa•oo T Fl Qvisl cN- 2vn 1'TG, .! SfcrPo - Or1li~o/7'~¢~~nr'~S "I `f d"V'vv ~ $pO.00 c, v P/' - Ci'a eWa pp. a0 rri n~0/' ~tp y~ $ 2174.0® (f-av» a Sys P.~ w 9 ~ y9• a~ ~s 3 y ~yq,oo r'e I arhoq e U N.Tpeh ~ y q, coo ~vlnr'je woodQn fllPfo®~o61e 4 2ZS,oo w Q. Mr• Co ~ /~ ni9P/'a for w ~'~P rieJ/p~4!'YP y yd.oo 4 ~p,pa S'foVC ~C JQG~rr'C ~~~ ~ 30®•po rt~'GpdWp v~ ~Crr`GGSOp»_~C~/OBI 61ocLr ' 9 4 (Odo°~~ q'15 7'DA 7'Qr -OSf 1a . -d.c50 V~O~ r J,5'-,Mr$G~IjlQG4; wood Qn vh i cvowu /v pl » aC>CJ.OC1 ~ oa SG~eI-f~ wooaloa S~ieJ-f' 9 R'BOO' In/ Ooo1e n ) anr~. i h5 S P~ GI~G'G4 ~o~' ~ g°~ ov .F'„ ~0 ~ ~g 4 ~ a.O o ~ ~- 7'a ~x~-page Date State. of Pennsylvania: County of Cumberland Claimant ~3'~ ,~ ~~,~,~,~,a~_ being duly sworn according to law, deposes and says that the above list in the property claim aze correct and true. Sworn and subscribed to before me ~ -~~'"'~y. - - NOTARY PUB11C -. _ ti8f~I8f8 ~, ~ ~Y Expb'ea April 4, 20)3 C t Nq-tGiGv1 /~. 1!~/;nfP~grgsS LII, 5fh S~reQ~ Apt• ~- /1 THE CLAIMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS: ., ~ .,~. ---- - riJeeerlaheovs G/b~5 __ __ y,~ oo,-©o V _ _. _ ~ _~ ~~ oo _ __ _ _ _ - _ __ _ _ _ _ _ Iv,igGelloweo~s v~dQO as am es ~ Soa'oa _ __ ~vomcJ an /bl v2 G lo'~y Cl~a ~ /` affray O`+~~FiG¢ G~iG,~r _ ~ _ 175, o~ _ _ _ _ _ __ __ _ _ _ ___ -- -_ -- _ -- _ ~efal -Filw/c^ Gabfget 3 ~oo..pd o ~ wooden en~e~~c~`nnooat C¢n~ Br_S~1 --~"G~'vv~ _clonnQ~___ _ ~ 4 224,©© _ _. _ - - (yoa~,l9o w~etG I I3~ h/~essvr- womde~ ` ~ / _ w ~rPrQr __ ~ tzoo,av_ __ _ _ _ - __ ___ --- - --_ ~ 2 5 O, 6 O _ ______ 9 9 Y v, o a _ - y~oae ! Llen rG'rd T'ovrvS p2 - ,.~ Sq ~ _ _ - _ _ _ _ vTiv T~At/'pSSsyYGz69~gy _ cGhd ~'f;~n o I~ _ ___ _ - - _ _ - _ _ __ - _ Wooc~Qr N Shel-~ l3oc~-~casQ IS a. po GDO~n c, -T-~°'o 15 - - _ - _ _ - _-_ _ _ _ - --_ 13 /o~i~' -F' 1 ivrJ c,a b~he-f -_ __ - -_ _ _- __ _ _ _- __ l ~ 5; o0 ___ -_____ -_ __ _ - __ ___ __ __ _ _ __ - _ _ __ - __ _ __ _ _. __ __- __ -____ __ -_ __ __ _ - _ - __ _ _ ___ -_ . , , i . Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SOIlCltOf SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~~~~s,~F of ~rurtg~,~,j~~~ a -~ ~ : ~-- FI~.ED-CJF~tCE OF T4~~' ~.~;r~pyOTARY 2Q10 ACT 2~ P~'9 !~~ U5 ~'t1i'{~~.Y~I~.~t~[4i~ (~t71Jfd ~ Y ~~~~~~ Y~~~,~cl~~l Hudson &Keyse LLC Case Number vs. 2010-5623 Kristy Noonan SHERIFF'S RETURN OF SERVICE 09/29/2010 04:28 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September 29, 2010 at 1628 hours, he served a true copy of the within writ of execution, upon the defendant, to wit: Kristy Noonan, by making known unto Kristy Noonan, at 415 5th Street, Apartment 2, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on 09-30-10. 10/07/2010 On Thursday, October 7, 2010 at hours, a property claim was filed by Nathan Wintergrass. All parties notified by mail this date. 10/18/2010 Reference is made to Property Claim dated October 7, 2010, entered by Nathan Wintergrass, Writ of Execution No. 2010-5623 Civil Term, Hudson &Keyse, LLC vs Kristy Noonan. Ronny R. Anderson, Sheriff, has determined that the claimant, Nathan Wintergrass, in the above mentioned property claim, is the owner of the property set forth in the claim, 10/29!2010 No objections filed to property claim. $ 25.00 refunded back to claimant this date. 1 012 9/2 0 1 0 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiffs attorney. SHERIFF COST: $ 80.66 SO ANSWERS, . ".-~-• October 29, 2010 RON R ANDERSON, SHERIFF a -oo ~. ~. S~ ~P~ , ~ ~ ~~ ~~~ ,~' ~.S'bS2/ (cj CountySuite Sheriff. Teleasoft. Inc.