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Home My WebLink About10-7726COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of CUMBERLAND NOTICE OF APPEAL FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS No. I(~ _~~ ~ ~ /~ ~` I NOTICE OF APPEAL v (~ Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District Judge on the date and in the case referenced below. NAME OF APPELLANT MAG. DIST. NO. NAME OF MDJ BLUESTONE INVESTMENTS, INC. 09-3-01 (Cumberland) Harold E. Bender ADDRESS OF APPELLANT CITY STATE ZIP CODE C!O Amato and Lessa, P.C. 107 North Commerce Way Bethlehem PA 18017 DATE OF JUDGMENT IN THE CASE OF (Plaintiff) (Defendant) 12/2/10 BLUESTONE INVESTMENTS, INC. vs KATRINA MOORE DocKET No. SIGNATURE OF APPELLANT OR ATTORNEY OR AGENT CV-283-2010 ~~~ This block will be signed ONLY when this notation is required under Pa. R.C.P.D.J. No. 10088. This Notice of Appeal, when received by the Magisterial District Judge, will operate as a SUPERSEDERS to the judgment for possession in this case. If appellant was Claimant (see Pa. R. C. P. D. J. No. 1001(6) in action before a Magisterial District Judge, A COMPLAINT MUST BE FILED within twenty (20) days after filing the NOTICE of APPEAL. of Prothonotary or PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R. C. P.D.J. No. 1001(7) in action before Magisterial District Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon Name of appellees) (Common Pleas No appellee(s), to file a complaint in this appeal within twenty (20) days after service of rule or suffer entry of judgment of non pros. fgnature o appel ant or attorney or agent RULE: To , appellees) Name of appellees) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: , 20_ Signature of Prothonotary or Deputy YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-05 ~~ ~~~ ~ QrMQN ~~'~r~` 2010 OEC i 6 ~~ 8~ 34 vUMBERLA~d~i CpUN~~ PENNSY~Vq~IA p~~~' ,mot :ql•~ s ~ Mae ~. ILSSO- a C ~ ~ ~a 3 ?may ~Q~ied No'~~~~ COMMONWEALTH OF PENNSYLVANIA ,000N~'Y OF CUMBERLAND Notice of JudgmentlTranscript Civil Case Mag. Dist. No: MDJ-09-3-01 MDJ Name: Honorable Harold E. Bender Address: 35 West Orange Street Shippensburg, PA 17257 Telephone: 717-532-7676 Justin N. Davis, Esq. C/O Amato and Lessa, P.C. 107 North Commerce Way Bethlehem, PA 18017 Bluestone Investments v. Katrina Moore Docket No: MJ-09301-CV-0000283-2010 Case Filed: 11/3/2010 Disposition Summary. Docket No Plaintiff Defendant Disposition Disposition Date MJ-09301-CV-0000283-2010 Bluestone Investments Katrina Moore Judgment for Defendant 12/02/2010 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 COURT OF COMMON PLEAS, CIVIL DIVISION. YOU 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 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. .~,ao,p pp•~oC.. _~~mA~ y ~N~ Fob ...~;'r%{ St /~ ~-l4 ~ ~V, g .~~~.a Date Magisterial District Judge Harold E. Bender ~-»~ I certify that this is a true and correct copy of the record of the proceedings containing the judgment. Date Magisterial District Judge Harold E. Bender MDJS 315 Page 1 of 1 Printed: 12/03/2010 9:53:52AM COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Magisterial District No.: 09-3-01 (Cumberland) MDR Names Mon. Harold E. Bender Address: 35 W. Orange St. Shippensburg, PA 17257 Telephone: 717 /532-7676 AMOUNT DATE PAID FILING COSTS S / / POSTAGE S / / SERVICE COSTS $ / / CONSTABLE ED. S / / TOTAL S / / CIVIL CQMPLAINT PLAINTIFF: NAME and ADDRESS BLUESTONE INVESTMENTS, INC. c/o Amato and Lessa, P.C. 107 North Commerce Way, Bethlehem, PA 18017 (6101 666-0400 VS DEFENDANT: NAME end Address KATRINA MOORE 21 N Washington Street. Shippensburg PA 17257 ~ Docket No: L ~- a- V v- L U Date filed: , (~ 3l /O k ~. Social security numbers and financial information (e.g. P/NSJ should not be /isfed. /f the identity of an account number must be established, list only the last four digits. 204 Pa. Code § § 213.1-213.7. Pa.R.C.P.D.J. No. 206 sets forth those costs recoverable b the revailin arty. TO THE DEFENDANT: The above named Plaintiff(s) asks judgment against you for $5,782.49 together with costs upon the following claim (Civil fines must include citation of the statute or ordinance violated: Chase Bank USA, N.A. issued a credit card to Defendant(s). Thereafter, Defendant(s) used said credit card account and defaulted in the repayment terms thereunder. For value received, all legal rights to this claim were assigned to Plaintiff. By virtue of said assignment, Plaintiff acquired legal title to said account and the right to collect it. Despite demand by Plaintiff, Defendant{s) have failed andlor refused to pay any part thereof. AMOUNT DUE $5,123.83, plus INTEREST of S658.66. I, Justin N. Davis, Esq., Atty ID# 84464, verify that the facts set forth in this complaint are true and correct io the best of my knowledge, information and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code 118 PA. C.S. § 4904{ related to unsworn falsification to authorities. Plaintiff's Attorney File Number: 1100730 Attorney: Amato and Lessa. P.C. Telephone: (670) 866.0400 FAX 610-866-9155 ISlpnaturr of Plaintiff or Authorized Aeantl Address: 107 North Commerce Wav Bethlehem. PA 18017 IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD SO NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO JUDGMENT MAY BE ENTERED AGAINST YOU BY DEFAULT. If you have a claim against the plaintiff which is within magisterial district judge jurisdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office at feast five t5) days before the date set for the hearing. If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. AOPC 308A-10 Me FILL to 0- E : 10E i HE ?' ?;? ,Fr I. ,., l 10 DEC 28 AM 11:172 CUMBERLt,ND I?CjLi t?i T .3, PENNSYf-`6JAINIA' PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILLED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHAMPTON ; ss AFFIDAVIT: I hereby (swear) (affirm) that I served ?' a copy of the Notice of Appeal, Common Pleas No. 10-7726 Civil, upon the Magisterial District Judge designated therein on (date of service) December 20, 2010, ? by personal service F by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) KATRINA MOORE_, on December 20. 2010 ? by personal service ?' by (certified) (registered) mail, senders receipt attached hereto. (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF , 20 Signature of official before whom affidavit was made Signatu afant Title of official My commission expires on , 20 AOPC 312A-05 7185 9704 3350 0003 4337 Postage $ Certified Fee E I JIM per` Postmark ,Y \ Here Return Receipt Fee (EndorsementRequin4 J \ a j?\ p Restricted Delivery Fee (Endorsement Requred) a' 2 c Total Postage & Fees 4 t Lu s - C? Sent To Honorable Harold E. Bender street, APt. No.; District Court 09-3-01 or PO Box No. City, SIM., Lp.4 35 W. Oanp St Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement R.gWred) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BLUESTONE INVESTMENTS, INC. Plaintiff vs. KATRINA MOORE Defendant(s) a v c rr) No. 10-7726 Civil -<> ? C° ' CIVIL ACTION . ", ?i ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Plaintiff, BLUESTONE INVESTMENTS, INC., in the above-captioned matter. AMATO AND LESSA, P.C. By: Ronald 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 BLUESTONE INVESTMENTS, INC. Plaintiff VS. KATRINA MOORE No. 10-7'726 Civil c r :X Q ? -o C1 Defendant CIVIL ACTION PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: Kindly enter judgment by default for want of an answer in favor of Plaintiff and against the above-named defendant(s) only and assess damages as follows: Debt $5,791.13 Interest (from December 23, 2010 to February 8, 2011 at 6% per annum) 28.96 Payments Total $5,820.09 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. Pursuant to RCP 237.1, 1 certify that a copy of the annexed written notice(s) of intention to file this praecipe was mailed or delivered to all parties against whom judgment is to be entered and to their attorney of record, if any, after the default occurred, and at least ten days prior to the date of filing of this praecipe. Please note that said notice was mailed to all parties on January 25, 201 1 . Dated: February 8, 2011 AMATO 1A)LESSA, 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 Q A DEBT COLLECTION LAW FIRM U a?7 1100730 i;65115 ?c?ice .?10u.1? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BLUESTONE INVESTMENTS, INC. Plaintiff VS. KATRINA MOORE Defendant No. 10-7726 Civil CIVIL ACTION CERTIFICATION OF ADDRESSES I do certify that the precise last known address of the within named plaintiff is: C/o Amato & Lessa, P.C. 107 North Commerce Way Bethlehem PA 18017 I do certify that the precise last known address of the within named defendant is: 21 N Washington Street Shippensburg PA 17257 AMATO ESSA, P.C. By: ald 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 BLUESTONE INVESTMENTS, INC. Plaintiff VS. No. 10-7726 Civil KATRINA MOORE 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 Katrina Moore is over 18 years of age, resides at 21 N Washington Street, Shippensburg PA 17257 and is employed; Sworn to and subscribed before me this 0e-1 day of C-6) 2011 A.D NOTAR PUBLIC NOTARIAL SEAL GEOFFREY G SCHOENRCK Nohry PuM10 H." `.OVER TOW N*NP,NORTHAIAPTt:: MY COeMIMMbD Expkn Uwah 20, t : f COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW BLUESTONE INVESTMENTS, INC. Plaintiff : No. 10-7726 Civil VS. KATRINA MOORE Defendant(s) TO: Katrina Moore 21 N Washington Street Shippensburg PA 17257 Date of Notice: January 25, 2011 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 Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMATO AND LES , P.C. By: Ronald 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 Attorney File# 1100730