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HomeMy WebLinkAbout01-1444IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AMERICAN PROPERTY CONSULTANTS, LTD., Plaintiff, vs. ZAMIAS SERVICES, INC., GEORGE D. ZAMIAS, individually and doing business as GEORGE D. ZAMIAS DEVELOPER, DAMIAN G. ZAMIAS individually and doing business as GEORGE D. ZAMIAS DEVELOPER, CALYPSO ~AMIAS LIMITED PARTNERSHIP, PROTESILAUS ZANIAS LIMITED PARTNERSHIP APOLLO GP, L.P., APOLLO ZAMIAS LIMITED PARTNERSHIP and ARGO ZAMIAS LIMITED pARTNERSHIP CIVIL DIVISION ~o. OI- Iqqq PRAECIPE TO TRANSFER JUDGMENT Defendants. FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: CHARLES E. BOBINIS, ESQUIRE PA I.D, #30665 Bernstein Law Firm, P.C. Firm #718 1133 Penn Avenue Pittsburgh, PA 15222 412-456-8100 DIRECT DIAL: (412) 456-8102 BERNSTEIN FILE NO. 59920400 IN THE COURT OF COMMON PLEAS OF CUMBERLAlVD COUNTY, PENNSYLVANIA CIVIL DIVISION AMERICAN PROPERTY CONSULTANTS, LTD., Plaintiff Civil Action No. ZAMIAS SERVICES, INC., GEORGE D. ZAMIAS, individually and doing business as GEORGE D. ZAMIAS DEVELOPER, DAMIAN G. ZAMIAS individually and doing business as GEORGE D. ZAMIAS DEVELOPER, CALYPSO ZAMIAS LIMITED PARTNERSHIP, PROTESILAUS ZAMIAS LIMITED PARTNERSHIP, APOLLO GP, L.P., APOLLO ZAMIAS LIMITED PARTNERSHIP and ARGO ZAMIAS LIMITED PARTNERSHIP Defendants PRAECIPE TO TR3%NSFER JUDGMENT Prothonotary: Please transfer the within Judgment entered in The Court of Common Pleas of Allegheny County, Pennsylvania, known as No, GD-01-002978, and index it against the Defendants above named, in the amount of $11,369,338.80. Allegheny County costs to follow Judgment. BERNSTEIN LAW FIRM, P.C. Pittsburgh, PA 15222 (412) 456-8100 We certify that the correct address of the Plaintiff is: c/o Bernstein Law Firm, P.C., 1133 Penn Ave., Pgh, PA 15222 And the correct known address of Defendant is: 300 Market St., Johnstown, PA 15901 COPY OF DOCKET ENTRIES COMMONWEALTH OF PENNSYLVANIA '~ SS. t ALLEGHENY COUNTY J Among the Records and Proceedings of the Court of Common Pleas in and for the County of Allegheny, and State of Pennsylvania, the following is a true and correct copy of the Docket Entries at No. v.n-0~-n0~97a American Property Consultants, LTE. DOCKET ENTRY VS Zamias Services, Inc., George D. Zamias, individually and d/b/a George D. Zamias Developer, VS. SEE Attached Sheets Damian G. Zamias individually a/d/b/a as George D. Zamias Developer, Caypso Zamias Limited Partnership, Protesilaus Zamias Limited Partnership, Appollo GP, L.P., Apollo Zamias Limited Partnership and Argo Zamias Limited Par_tnershiD. I, Michael E. Lamb, Acting MrotEonota~ of the Court of Common Pleas in and for said County, Certi~ that the foregoing is a full and correct copy of the Docket Entries wherein GD-01-002978 mER~c~a~ PROPERTY LTD., Plaintiff and before the said Court, at No. Defendant; a., GD-01-002978 IN TESTIMONY WHEREOF, I have hereunto set my hand and Court, the 1st day of March, 2001 D. ZAMIA$, individually and PAGE 1 ~EPORT : CDRDOCT Allegheny County Prothonotary RUN DATE 03/01/01 ~ Civil Docket Report RUN TIME 09:56 AM CASE ID GD-01-002978 CASE NUMBER CASE CAPTION FILING DATE COURT LOCA CASE TYPE TION TYPE GD 01-002978 American Property Consultants vs Zamias Services e 14-FEB-2001 GD PO FJ Type Party_ Name PLTF American Property Consultants~ PATY Krawec, Nich,/las D. DEFT Zamias Services Inc., DEFT Zamias, George D DEFT George D. Zamias DeveloEer, DEFT Zamias, Damian G. DEFT Calypso Zamias Limited Partnership, DEFT Protesilaus Zamias Limited Partnership, DEFT Apollo GPL. P., DEFT Apollo Zamias Limited Partnership, Alias Name Filing Date Filing Party Docket Entry 14 FEB-2001 22 FEB-2001 22-FEE 2001 American Property Consultants Affidavit of Foreign Judgment Foreign Judgment Notice of Judgment Mailed Interrogatories in attachment Praecipe for Writ of Execution $11369338.80 plus att¢}rney costs $100. Filin~ Date Docket Entr~ 14 FEB 2001 Foreign Judgment 14 FEB-2001 Foreign Judgment 14 FEB-2001 Foreign Judgment 14 FEB 2001 Foreign Judgment 14 FEB-2001 Foreign Judgment 14-FEB-2001 Foreign Judgment 14-FEB-2001 Foreign Judgment 14-FEB-2001 Foreign Judgment 14-FEB 2001 Foreign Judgment Judgment Party Name Judgment Amt FOR American Property Consultants, 11,369,388.80 FOR Apollo GPL. P., 11,369,388.80 AGA Apollo zamias Limited Partners 11,369,388.80 AGA Calypso Zamias Limited Partner 11,369,388.80 AGA George D. Zamias Developer, 11,369,388.80 AGA Protesilaus Zamias Limited Par 11,369,388.80 AGA Zamias Services Inc., 11,369,388.80 AGA Zamias, Damian G. 11,369,388.80 AGA Zamias, George D 11,369,388.80 AGA IN THE COORT OF COMMON PLEAS OF ALLEGHEAPf COUNTY, PENNSYLVA/gIA D~4ERICAN PROPERTY CONSULTD/qTS, LTD., Plaintiff VS. CIVIL DIVISION No. 0/f PRAECIPE TO FILE FOREIGN JUDGMENT ZD~4IAS SERVICES, INC., GEORGE D. ZAMIAS, individually and doing business as GEORGE D. ZAMIAS DEVELOPER, DAMIAN G. ZAMIAS individually and doing business as GEORGE D. ZAMIAS DEVELOPER, CALYPSO ZAMIAS LIMITED PARTNERSHIP, PROTESILAUS ZAMIAS LIMITED PARTNERSHIP, APOLLO GP, L.P., APOLLO ZAMIAS LIMTED PARTNERSHIP and ARGO ZAMIAS LIMITED PARTNERSHIP, Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: NICHOLAS D. KRAWEC, ESQUIRE PA I.D. #38527 Bernstein Law Firm, P.C. Firm #718 1133 Perin Avenue Pittsburgh, PA 15222 412-456-8100 DIRECT DIAL: (412) 456-8103 IN TEE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, CIVIL DIVISION AMERICAN PROPERTY CONSULTANTS, LTD. , Plaintiff vs. PENNSYLVANIA Civil Action NO. CERTIFIED ~ T~~,~-' RECORD ZAMIAS SERVICES, INC., GEORGE D. ZAMIAS, individually and doing business as GEORGE D. ZAMIAS DEVELOPER, DAMIAN G. ZAMIAS individually and doing business as GEORGE D. ZAMIAS DEVELOPER, CALYPSO ZAMIAS LIMITED P TNERSHIP, PROTESI S Z IAS LIM%TED P~TN~gHIP, APOLLO GP, L.P., A~OLLO Z~ZAS LIMITED P~ERSHIP and ~GO Z~IAS LIMITED P~RSHIP, Defendants PRAECIPE TO FILE FOREIGN JUDGMENT TO THE PROTHONOTARY: Please file the enclosed certified transcript of Judgment of the Supreme Court of the State of New ¥ork~ County of New York, in accordance with Section E of the Uniform Enforcement of Foreign Judgment Act (42 Pa. C.S.A. Section 4306), and also mail notice of the filing of the Judgment to the Judgment-debtor at the address shown on the attached verification. Amount of Judgment computed as follows: Principal Amount of JudgmenC Interest at 9% per annum from January 22, 2001 Prior Costs To,al Judgment $11,317,886.02 $ 50,232.78 $ 1,220.00 $11,369,338.80 IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, CIVIL DIVISION AMERICAN PROPERTY CONSULTANTS, LTD., Plaintiff vs. Civil Action No. ZAMIAS SERVICES, INC., GEORGE D. ZAMIAS, individually and doing business as GEORGE D. ZAMIAS DEVELOPER, DAMIAN G. ZAMIAS individually and doing business as GEORGE D. ZAMIAS DEVELOPER, CALYPSO ZAMIAS LIMITED PARTNERSHIP, PROTESILAUS ZAMIAS LIMITED PARTNERSHIP, APOLLO GP, L.P., APOLLO ZAMIAS LIMITED PARTNERSHIP and ARGO ZAMIAS LIMITED PARTNERSHIP, Defendants PENNSYLVANIA NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee Your are hereby notified that the following Order or Judg~nent was entered against you on Zamias Services, Inc. 300 Market Street Johnstown, PA 15901 (xx) Assumpsit Judgment in the amount of $11,369,338.80 plus costs. Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgqnent of (xx) Court Order ) Non-Pros ) Confession ) Default ) Verdict ) Arbitration Award Prothonotary By: PROTHONOTARY DEPUTY) Supreme Court, New lor~ ~unty. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. {4904 relating to unsworn falsification to authorities, that the undersigned is the attorney for the Judgment Creditor, AMERICAN PROPERTY CONSULTANTS, LTD., that the last known address of the Judgment Creditor is c/o Bernstein Law Firm, P.C., 1133 Penn Avenue, Pittsburgh, Pennsylvania 15222; and that the last known address of the Judgment Debtor is 300 Market St.,Johnstown, PA 15901; that the Foreign Judgment is valid, enforceable and unsatisfied, and that the facts set forth in the foregoing Praecipe are true and correct to the best of the undersigned's knowledge information and belief.