HomeMy WebLinkAbout11-4194F.AF I LES/Chents\12175 DannoreA12175.4pra. transfer
Created. 1/21/05 44.23PM
Revised. V6/ 11 2 17PM
Christopher E. Rice, Esquire ?
Attorney I.D. No. 90916
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER }- -
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a s
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MARTSON LAW OFFICES k
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,UMBERLAI
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Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ANTHONY DAMORE,
Plaintiff
V.
CHARLES R. COOK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. I 1 - '41q CIVIL TERM
PRAECIPE TO ENTER JUDGMENT ON
DISTRICT JUSTICE'S TRANSCRIPT OF JUDGMENT
Pursuant to Act of July 9, 1976, P.O. 586, No. 142, § 42 Pa.C.S.A. 1516, and in accordance
with the transcript of the District Justice which is attached hereto, enter judgment in favor of
Anthony Damore, Plaintiff, and against Charles R. Cook, Defendant, in the sum of $2,330.50, which
consists of $2,200.00 as principal and $130.50, as costs, plus interest thereon from March 23, 2011,
as provided by law.
Plaintiff hereby certifies that the last known address of Defendant is 332 East King Street,
Shippensburg, PA 17257.
Date: -S J411/
MARTSON LAW OFFICES
By: e? '50.
Christopher E. Rice, Esquire
I. D. Number 90916
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
a"+ '% a7.a5 f «
C,k- 44 aSR 5E
C-0 (9%-V 7 YS
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Notice of Judgment/Transcript
Residential Lease
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
Anthony Damore
V.
Charles R Cook
Anthony Damore Docket No: MJ-09301-LT-0000009-2011
631 Eric Drive
Shippensburg, PA 17257 Case Filed: 2/22/2011
Disposition Details
Grant possession. No
Grant possession if money judgment is not satisfied by the time of eviction. Yes
Charles R Cook
Wage attachment is prohibited due to lack of personal service. No
Wage attachment is prohibited under Title 42 Section 8127. No
Disposition Summary
Docket No Plaintiff Defendant
MJ-09301-LT-0000009-2011 Anthony Damore Disposition Disposition Date
Charles R Cook Judgment for Plaintiff 03/23/2011
Judgment Summary Joint/Several Liability Individual Liability Amount
Participant
Charles R Cook $0.00 $2,330.50 $2,330.50
Judgment Detail ('Post Judgment)
In the matter of Anthony Damore vs. Charles R Cook on 3/23/2011 the disposition is Judgment for Plaintiff and judgment was awarded
as follows:
The amount of rent per month, as established by the Magisterial District Judge, is $900.00
Judgment Component JointlSeveral Liability Individual Liability Deposit Applied Amount
Rent in Arrears $0.00 $2,200.00
$2
200.00
Filing Fees
$0.00 $130.50 ,
$130 50
Grand Total: $2,330.50
Portion of judment arising out of residential lease: $0.00
Amount of judgment subject to attachment 42 PA C.S. 8127: $0.00
MDJS 315A Page 1 of 2 Printed: 03/24/2011 11:53:59AM
E 1 MAY -6 PFD
3:21
PENNSYLVANIA')
Anthony Damore Docket No.: MJ-09301 -LT-0000009-201 1
V.
Charles R Cook
IN AN ACTION INVOLVING A RESIDENTIAL LEASE, ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION
WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURT OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF
ANY. IN ORDER TO OBTAIN A SUPERSEDEAS, THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE
LESSER OF THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED. HOWEVER, LOW-INCOME
AND/OR SECTION 8 TENANTS SHOULD REFER TO Pa.R.C.P.M.D.J. NO. 1008 OR 1013 FOR DIFFERENT PROCEDURES REGARDING THIS
DEPOSIT.
IF A PARTY WISHES ONLY TO APPEAL THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE, THE PARTY HAS
30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF
COURTS OF THE COURT OF COMMON PLEAS, CIVIL DIVISION.
THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THE 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.
Date
,?•,a •rnr
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 315A Page 2 of 2 Printed: 03/24/2011 11:53:59AM
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent for Martson Law Offices, hereby certify that a copy of
the foregoing Praecipe to Enter Judgment on District Justice's Transcript of Judgment was served
this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid,
addressed as follows:
Charles R. Cook
332 East King Street
Shippensburg, PA 17257
MARTSON LAW OFFICES
By, Qt?
*Teennastt e
h Stre et
Carlisle, PA 17013
(717) 243-3341
Dated: ,5_ (o//?
THIS IS A DEBT COLLECTION FIRM ATTEMPTING TO COLLECT A DEBT FOR
ANTHONY DAMORE. ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE.
FILED- OF F I
20 11 MAY --6 PM 3: 21
Christopher E. Rice, Esquire CUMBERLAND 00Uh 1 t
Attorney I.D. No. 90916 PENNSYLVANIA
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
ANTHONY DAMORE, IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 11 -4194 CIVIL TERM
CHARLES R. COOK, ;
Defendant
AFFIDAVIT OF NO APPEAL
As of May 6, 2011, a District Justice appeal has not been filed in the Court of Common
Pleas of Cumberland County.
MARTSON LAW OFFICES
By: ?;,
Date: _?'/?/`l
Sworn to nd subsc before me
this day ofribz
Not rv PlIblic
2011.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Mary M. Price, Notary PJAc
Carlisle Boro, Cumberland Cotxdy
My Owwrlission E*ires Aug. 18, 2011
Christopher E. Rice, Esquire
Attorneys for Plaintiff
Member, Pennsylvania Association of NoWles
FILED-OFFICE
Christopher E. Rice, Esquire OF THE PROTHONOTARY
I.D. No. 90916I,UH 30 AM ID: 59
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALL
MARTSON LAW OFFICES CUMBERLAND COUNTY
10 East High Street PENNSYLVANIA
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiffs
ANTHONY DAMORE
Plaintiff
V.
CHARLES R. COOK
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 11 - 4194 CIVIL TERM
CERTIFICATION OF JUDGMENT CREDITOR-LANDLORD
I certify that:
1. The Plaintiff ("Judgment-Creditor") is Anthony Damore, with an address of 631 Eric
Drive, Shippensburg, Cumberland County, Pennsylvania 17257.
2. Defendant ("Judgment-Debtor") Charles R. Cook has a last known address of 332
East King Street, Shippensburg, Cumberland County, Pennsylvania 17257.
3. The employer/garnishee is Walmart, 100 South Conestoga Drive, Shippensburg,
Cumberland County, Pennsylvania 17257.
4. The judgment arises out of a residential lease for the premises at 332 East King Street,
Shippensburg, Cumberland County, Pennsylvania 17257, for which Judgment-Creditor is the
landlord.
5. (a) The amount of the judgment is $2,330.50, plus costs of suit and interest at a
rate of 6% per annum from March 23, 2011.
(b) A security deposit in the amount of $900.00 is being held by the Judgment -
Creditor. This security deposit has been applied to payment of the rent due
on the same premises prior to the judgment being entered, and therefore does
not reduce the amount of the judgment.
6. This praecipe is filed within five years of the date of the original judgment upon
which execution is sought.
7. The judgment was entered in a civil action commenced in the Court of Common
Pleas.
I certify that the statements made in this Certification are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 :relating to unsworn
falsifications to authorities.
Anthony Damore
RECEIVED
JUN 2 8 2011
MAR4I-SUIV
F:\FILES\C1ients\12175 Damore\12175A.pra.attach.wpd
OF THE PRO THONO TA R Y
2011,1U1, -S A
Christopher E. Rice, Esquire n ?1'. 14
I.D. No. 90916 CUMBERLAND COUNTY
R. Christopher VanLandingham, Esquire PENNSYLVANIA
I.D. No. 307424
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiffs
ANTHONY DAMORE
Plaintiff
V.
CHARLES R. COOK
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 11 - 4194 CIVIL TERM
PRAECIPE FOR NOTICE OF INTENT TO ATTACH WAGES PURSUANT TO
PA.R.C.P. 3302.
TO THE PROTHONOTARY:
Dated:
Issue a Notice of Intent to Attach Wages in the above matter against:
Defendant Charles R. Cook, 332 East King Street, Shippensburg, PA 17257, and
MARTSON LAW OFFICES
By. r
Christopher E. Rice, Esquire
I.D. Number 90916
R. Christopher VanLandingham, Esquire
I.D. Number 307424
Ten East High Street
Carlisle, PA 17013
/ (717) 243-3341
`? 1 ( Attorneys for Plaintiffs
.??yAl 0 °l t 9-0
ek* a.?4i> > s _
?2 4,i3/
ANTHONY DAMORE
Plaintiff
V.
CHARLES R. COOK
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 11 - 4194 CIVIL TERM
NOTICE OF INTENT TO ATTACH WAGES, SALARY OR COMMISSIONS
Date of service of this Notice:
(Date to be inserted by the Sheriff)
A judgment has been entered against you in court for nonpayment of rent for, or damage to,
residential property that you rented. The judgment creditor-landlord has begun proceedings to attach
10% of your net wages, salary or commissions for each pay period until the judgment is satisfied.
The following exception will prevent your wages from being attached:
Poverty Guidelines--Your wages may not be attached if your net income is below the
poverty income guidelines as provided annually by the Federal Department of Health and
Human Services or if the amount of the attachment would cause your net income to fall
below the poverty income guidelines. A copy of the guidelines is attached to this notice.
If this exemption is applicable to you, you must return the claim for exemption of wages
which is attached to the prothonotary within 30 days of the date of service of this notice upon
you. The date of service of this notice is set forth above. If you return the form claiming this
exemption within 30 days, your wages will not be attached without subsequent court
proceedings.
There may be other legal grounds for opposing the wage attachment that you may be able to raise
by filing a motion with the court. For example, your wages may not be attached if you are an abused
person or victim as set forth in Section 8127(f) of the Judicial Code when the attachment is to satisfy
a judgment for physical damages to the leased premises.
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 Lawyer Referral Service
32 South Bedford Street
Carlisle, PA 17013
(717) 249 - 3166
ANTHONY DAMORE
Plaintiff
V.
CHARLES R. COOK
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 11 - 4194 CIVIL TERM
CLAIM FOR EXEMPTION FROM WAGE ATTACHMENT
NOTICE
This Claim for Exemption must be filed with the Prothonotary of the Court within
30 days of service upon you of the Notice of Intent to Attach Wages.
To the Prothonotary:
I, the above-named defendant, claim exemption of my wages, salary or commissions from attachment
on the following ground:
- My net monthly income is below the poverty income guidelines as provided by the Federal
Department of Health and Human Services.
OR
_ The amount of wages to be attached would place my net income below the poverty income
guidelines as provided annually by the Federal Department of Health and Human Services.
I have - dependents.
(Number)
My net monthly income is $
(Net monthly income is your total monthly wages less (1) any support payments made to the court, (2)
federal, state and local income taxes, (3) F.I.C.A. payments and nonvoluntary retirement payments, (4) union
dues and (5) health insurance premiums.)
I certify that the statements made in this Claim for Exemption are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to
authorities.
Date:
This claim for exemption shall be delivered or mailed to:
Office of the Prothonotary
Cumberland County Court of Common Pleas
1 Courthouse Sq.
Suite 100
Carlisle, PA 17013
Phone: 717.240.6195 Fax: 717.240.6573
Defendant
ANTHONY DAMORE : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 11 - 4194 CIVIL TERM
CHARLES R. COOK
Defendant
NOTICE OF CLAIM OF EXEMPTION OF WAGES FROM ATTACHMENT
To the above-named plaintiff:
The defendant in the above-captioned matter has filed a claim for exemption from
attachment of his or her wages, salary or commissions. A copy of the claim is attached. If you
wish to challenge the claim for exemption, you should file with the court a motion setting forth
facts which show that the defendant's net income is not below the Federal Department of Health
and Human Services poverty income guidelines or that the attachment will not cause the
defendant's net income to fall below those poverty income guidelines.
Date:
Prothonotary
CERTIFICATE OF SERVICE
I, Julia Rabich, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO
GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by
depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as
follows:
Charles R. Cook
332 East King Street
Shippensburg, PA 17257
MARTSON LAW OFFICES
By:
Julia Rabich
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: :::T /0QoII
THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR
ANTHONY DAMORE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
FG C t r?
Ronny R Anderson
Sheriff of Comb"
16 F
Jody S Smith ``
Chief Deputy
Richard W Stewart
fi'?! ,'e.+''.
Solicitor
Anthony Damore
vs.
Charles R. Cook
Case Number
2011-4194
SHERIFF'S RETURN OF SERVICE
08/15/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Charles R. Cook, but was unable to locate him in his
bailiwick. He therefore returns the within Notice of Intent to Attache Wages as not found as to the
defendant Charles R. Cook. Request for service at 332 E. King Street, Shippensburg, Pennsylvania
17257 the Defendant was not found. To date The Shippensburg Postmaster has been unable to provide
good forwarding address for Charles R. Cook.
SHERIFF COST: $53.44
August 15, 2011
SO ANSWERS,
(5Z'
RON R ANDERSON, SHERIFF
01, i0u"'Y5J1t1?? 5hentk TeI8c50tt h!",
FAF1LEWlients\12175 Damore\12175A.pra.reissue.wpd
Christopher E. Rice, Esquire
I.D. No. 90916 zn?r
R. Christopher VanLandingham Esquire
vZ, ?
I.D. No. 307424 r-? +v ?
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER a„
MARTSON LAW OFFICES =
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=
10 East High Street ?
)
Carlisle, PA 17013 r .?.,
rv
(717) 243-3341
Attorneys for Plaintiffs
ANTHONY DAMORE : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 11 - 4194 CIVIL TERM
CHARLES R. COOK
Defendant
PRAECIPE TO REISSUE NOTICE OF INTENT
TO ATTACH WAGES PURSUANT TO PA.R.C.P. 3302.
TO THE PROTHONOTARY:
Please Re-issue a Notice of Intent to Attach Wages in the above matter against:
Defendant Charles R. Cook, c/o Walmart Superstore, 100 South Conestoga Drive,
Shippensburg, Cumberland County, Pennsylvania 17257.
MARTSON LAW OFFICES
Dated:
By:
Christopher E. Rice, Esquire
I.D. Number 90916
R. Christopher VanLandingham, Esquire
I.D. Number 307424
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiffs
ANTHONY DAMORE
Plaintiff
V.
CHARLES R. COOK
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 11 - 4194 CIVIL TERM
NOTICE OF INTENT TO ATTACH WAGES. SALARY OR COMMISSIONS
Date of service of this Notice:
(Date to be inserted by the Sheriff)
A judgment has been entered against you in court for nonpayment of rent for, or damage to,
residential property that you rented. The judgment creditor-landlord has begun proceedings to attach
10% of your net wages, salary or commissions for each pay period until the judgment is satisfied.
The following exception will prevent your wages from being attached:
Poverty Guidelines--Your wages may not be attached if your net income is below the
poverty income guidelines as provided annually by the Federal Department of Health and
Human Services or if the amount of the attachment would cause your net income to fall
below the poverty income guidelines. A copy of the guidelines is attached to this notice.
If this exemption is applicable to you, you must return the claim for exemption of wages
which is attached to the prothonotary within 30 days of the date of service of this notice upon
you. The date of service of this notice is set forth above. If you return the form claiming this
exemption within 30 days, your wages will not be attached without subsequent court
proceedings.
There may be other legal grounds for opposing the wage attachment that you may be able to raise
by filing a motion with the court. For example, your wages may not be attached if you are an abused
person or victim as set forth in Section 8127(f) of the Judicial Code when the attachment is to satisfy
a judgment for physical damages to the leased premises.
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 Lawyer Referral Service
32 South Bedford Street
Carlisle, PA 17013
(717) 249 - 3166
ANTHONY DAMORE
Plaintiff
V.
CHARLES R. COOK
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 11 - 4194 CIVIL TERM
CLAIM FOR EXEMPTION FROM WAGE ATTACHMENT
NOTICE
This Claim for Exemption must be filed with the Prothonotary of the Court within
30 days of service upon you of the Notice of Intent to Attach Wages.
To the Prothonotary:
I, the above-named defendant, claim exemption of my wages, salary or commissions from attachment
on the following ground:
_ My net monthly income is below the poverty income guidelines as provided by the Federal
Department of Health and Human Services.
OR
_ The amount of wages to be attached would place my net income below the poverty income
guidelines as provided annually by the Federal Department of Health and Human Services.
I have dependents.
(Number)
My net monthly income is $
(Net monthly income is your total monthly wages less (1) any support payments made to the court, (2)
federal, state and local income taxes, (3) F.I.C.A. payments and nonvoluntary retirement payments, (4) union
dues and (5) health insurance premiums.)
I certify that the statements made in this Claim for Exemption are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to
authorities.
Date:
This claim for exemption shall be delivered or mailed to:
Office of the Prothonotary
Cumberland County Court of Common Pleas
I Courthouse Sq.
Suite 100
Defendant
Carlisle, PA 17013
Phone: 717.240.6195 Fax: 717.240.6573
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO
GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by
depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as
follows:
Charles R. Cook
100 Deerfield Lane
Shippensburg, PA 17257
MARTSON LAW OFFICES
By: V;4,4) -A
Maly . Price
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: 9/?a////
THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR
ANTHONY DAMORE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
PROfH i}
Sheriff
o?g% p of atmLr ? ? Jody S Smith 2012 MAR -8 AM $° 54
Chief Deputy z lY y CUMBERLAND i..ir,t€H f
Richard W Stewart
y
Solicitor OFFICE OF THE SA=RIFF PENNSYLVANIA
Anthony Damore
vs.
Charles R. Cook
Case Number
2011-4194
SHERIFF'S-RETURN OF SERVICE
09/21/2011 11:26 AM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
September 21, 2011 at 1126 hours, he served a true copy of the within Notice of Intent to Attach Wages,
upon the within named defendant, to wit: Charles R. Cook, by making known unto himself personally, at
4041 Deerfield Commons, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at
the same time handing to him personally the said true and correct copy of the same.
SHERIFF COST: $68.44
September 22, 2011
A9 GERA iL WORTHINGTON, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
(c`, CountySutte Shenff. Teleosoft. Inc.
Christopher E. Rice, Esquire
I.D. No. 90916
R. Christopher VanLandingham, Esquire c
I.D. No. 307424 r" o _ y
MARTSON DEARDORFF WILLIAMS O TTO GILROY & FALLER =rn ' y
MARTSON LAW OFFICES w c
10 East High Street c
Carlisle, PA 17013 ?-
(717) 243-3341
Attorneys for Plaintiffs
ANTHONY DAMORE : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 11 - 4194 CIVIL TERM
CHARLES R. COOK
Defendant
I . 00 vu Vie,
Sti,ppcn.sbu°V ? 19lS7
PRAECIPE TO ATTACH WAGES OF DEFENDANT CHARLES R. COOK
TO THE PROTHONOTARY:
Issue a writ for the attachment of wages of defendant Charles R. Cook. A Certification of
Judgment Creditor-Landlord was filed on June 30, 2011 .*: - *k'- &,"0Nw44 'r1.33 0, S"0 Plus cons a F s?f
"'A YtihhC4,
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A4' MARTSON LAW OFFICES
SI•?Ppe??? 17a-S7
Dated:
S',2- 3- 3' Cass
00
r
r S3 y y
13 P °LY
B: C-4
Y S /L,
Christopher E. Rice, Esquire
I.D. Number 90916
R. Christopher VanLandingham, Esquire
I.D. Number 307424
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiffs
? r
CERTIFICATE OF SERVICE
I, Julia Rabich, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO
GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by
depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as
follows:
Charles R. Cook
100 Deerfield Lane
Shippensburg, PA 17257
MARTSON LAW OFFICES
By:
Julia Rabich
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: 3/023/?,2i
THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR
ANTHONY DAMORE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
ANTHONY DAMORE
Plaintiff
V.
CHARLES R. COOK
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 11 - 4194 CIVIL TERM
WRIT OF ATTACHMENT OF WAGES, SALARY OR COMMISSIONS
TO: Walmart,100 South Conestoga Drive, Shippensburg, PA 17257, employer of the Defendant
Charles R. Cook.
You have been identified as the employer of the above-named defendant.
You are directed to withhold the wages, salary and commissions of the defendant in your
possession to satisfy the judgment against the defendant.
You are notified that:
1. An attachment of wages, salary and commissions has been issued;
2. You are ordered to withhold from the wages, salary and commissions of the
defendant an amount per pay period which does not exceed ten (10) percent of the
defendant's net wages, salary and commissions;
Net wages are all wages paid less only the following items: (1) any support payments
made to the court, (2) federal, state and local income taxes, (3) F.I.C.A. payments and
nonvoluntary retirement payments, (4) union dues and (5) health insurance
premiums.
2f 3. The total amount attached is $2,330.50, plus costs of suit and interest, and the
withholding must continue until the amount of the attachment is satisfied;
4. The attached wages shall be sent to the prothonotary of the court of common pleas
within 15 days from the close of the last pay period in each month. The check must
a. contain the name of the employee whose wages are being withheld,
b. be made payable to the Prothonotary, and
c. be sent to:
Office of the Prothonotary
Cumberland County Court of Common Pleas
Wage Attachment Remittance
1 Courthouse Sq.
Suite 100
Carlisle, PA 17013
Phone: 717.240.6195
5. You are entitled to deduct each pay period from the money collected from the
defendant employee the costs incurred from the extra bookkeeping necessary to
record the transaction, not exceeding $5.00 of the amount of money so collected.
6. By law, you may not take any adverse action against the defendant because his or her
wages, salary or commissions have been attached.
7. You shall send the following notice to the prothonotary if the defendant has never
been or is no longer an employee:
I have received a Writ of Attachment in the following case:
ANTHONY DAMORE : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 11 - 4194 CIVIL TERM
CHARLES R. COOK
Defendant
The following person, Charles R. Cook, has never been (__) or is no longer an employee
U•
Date:
Employer
Seal of Court
Prothonotary
By:
Deputy
ANTHONY DAMORE IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS CIVIL DIVISION
CHARLES R. COOK No. 11-4194 Civil Term
Employee
TO: WALMART, 100 SOUTH CONESTOGA DRIVE, SHIPPENSBURG, PA 17257
RE: Residential Lease between Plaintiff and Defendant
WRIT OF ATTACHMENT
The above employer shall attach and deduct from the wages of the above employee a sum not to
exceed ten (10%) of the net wages per pay period of said employee or a sum not to place employees net
income below poverty income guidelines as provided annually by the Federal Office of Management and
Budget, whichever is less. "Net wages" shall mean all wages paid, less only the following items:
1. Federal, State and Local income taxes;
2. F.I.C.A. payments and non-voluntary retirement payments;
3. Union dues; and,
4. Health insurance premiums
The amount wages to be attached shall total $2,330.50 (plus costs)
The employer shall send the attached wages to the Prothonotary, Cumberland County
Courthouse, One Courthouse Square, Carlisle, PA 17013, payable to Plaintiff-Creditor: ANTHONY
DAMORE within fifteen (15) days from the close of the last pay period in each month. The employer
shall be entitled to deduct from the wages collected from the employee pursuant hereto the costs incurred
from the extra bookkeeping necessary to implement the terms within the Writ of Attachment, not exceeding
$5.00 of the amount of the wages so deducted. If you, the employer, are served with more than one Writ of
Attachment for damages arising out of a residential lease against the same employee, then the wage
attachments shall be satisfied in the order in which said Writs of Attachment were served. Each prior wage
attachment shall be satisfied before any effect is given to a subsequent attachment.
You shall not take any adverse action against the employee solely because his wages, salaries or
commissions have been attached. Violations may result in (i) you being adjudged in contempt and
committed to jail or fined by the court and (ii) an action against you by the employee for damages.
Willful failure to comply with this Writ of Attachment may result in (i) you being adjudged in
contempt of court and committed to jail or fined by the court; (ii) you being held liable for any amount not
withheld, or withheld but not forwarded to the Prothonotary's office; and, (iii) attachment of your funds or
property.
This Writ of Attachment has been entered pursuant to 42 PA. C.S.A. 8127, as amended by House
Bill 908, Act 5 of 1996, effective February 15, 1996. A copy of this Writ of Attachment has been sent by
U.S. Mail, postage prepaid, to the employee's last known address at:
CHARLES R. COOK, 100 DEERFIELD LAND, SHIPPENSBURG, PA 17257
Any questions should be directed to the Plaintiff-Creditor:
Christopher E. Rice, Esq. Martson Law Offices Ten East High Street, Carlisle, PA 17013 (717)243-
3341
Date: 03/23/2012
David D. Buell, Pr thonotary
Costs: $183.13 pd atty By Deputy: d-A 4MZZ!?M
You shall send the following notice to the Prothonotary if the defendant has never been or is on longer an
employee on company letterhead:
I have received a Writ of Attachment in the following case:
Plaintiff v. Defendant
No of Year
The following person, has never been L?
Or is no longer and employee (__)
Signature of Employer
Print name of Employer
Address
Address
Telephone #
For Prothonotary use only
Date:
David D. Buell, Prothonotary
Deputy
(Sea] of the Court)