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HomeMy WebLinkAbout02-0541GREATE BAY HOTEL AND CASINO, INC. T/A THE SANDS HOTEL AND CASINO Plaintiff Vo DONALD CONNORS D~fendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW FOREIGN JUDGMENT PRAECIPE TO THE PROTHONOTARY: Please record the Foreign Certificate of Final Jud..mnent by Default from the Superior Court of the State of New Jersey, Atlantic County. Please enter the Judgment in favor of the Plaintiff and against the Defendant, DONALD CONNORS, with the amount due of $2,727.21 plus post-judgment interest at the rate of 6.% per annum from September 6, 2001 through the date of payment of Judgment. To Cumberland C. ounty Prothonotary Dated: / Robert D. Kodak, Attorney Attorney I.D. No. 18041 The State of New Jersey County ) SS. Atlantic ) I, Teresa Ungaro, Clerk of the Special Civil Part, in the County of Atlantic, do certify that the foregoing is a true copy of the record in the ease where, Greate Bay Hotel and Casino, Ine t/a The Sands Hotel and Casino is plaintiff and Donald Conners is defendant; DC-4229-01 as full, entire and complete as the same on file in said Court in the ease there stated. IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the seal of the said Court this/~, day of ~ Teresa Ungafo Clerk County ) Atlantic ) I, Honorable William C. Todd, Judge of Special Civil Part, in the County of Atlantic, do certify that the foregoing record and attestation made by Teresa Ungaro Clerk of the said Court, whose name is thereto subscribed and seal of office affixed are in due form and made by the proper officer. County ) Atlantic ) IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the seal of the said Court this I~'axt day of I, Teresa Ungaro, Clerk of Special Civil Part in the County of Atlantic, do certify that the Honorable William C. Todd by whom the foregoing attestation was made, whose name is thereunto subscribed was at the time making thereof and still is Judge of Special Civil Part, in the County of Atlantic, duly commissioned and sworn, to all whose aets as such, full faith and credit are and ought to be given as well as in Courts of Judieature as well as elsewhere. IN TETIMONY WHEREOF, I have hereunto set my hand and affixed the seal of the said Court this ~/ day of stw~moR COtmX 0V ~r~W mRSE¥, t~AW mvts~o?4, SPECtAt~ CVv~ Pratt Atlantic County G-reate Bay Hotel and Casino, Inc. Plaintiff ¥$ Defendant Donald Connors DOCKET NO. DC-4229-01 EXEMPI,1FIED COPY OF JUDGMENT We have inspected the files of The Atlantic County Special Civil Part and have found a certain judgment in the above captioned matter to be as follows: Judgment in favor of Plaintiff Greate Bay Hotel and Casino, Inc. t/a The Sands Hotel and Casino and against Defendant Donald Connors Date: Sept. 6, 2001 Amount: 2605.11 Costs: 49.00 court costs, 67.10 attorney fees, 6.00 exemplified copy Totals: 2727.21 On thisc~ay of g~~ 20~/~, I hereby certify the foregoing record to be exemplified, witness, Hon. Judge William C. Todd PJ., J.S.C. Presiding Judge of The Atlantic County Special Civil Part, 1201 Bacharach in Atlantic City, State of New Jersey. ¢ivt. l/l~q. Clerk Page: 1 Document Name: untitled CVM1023 AUTOMATED CASE MANAGEMENT SYSTEM PAGE: 001 OF 001 DOCUMENT LIST 10/10/01 14:21 VENUE : ATLANTIC COURT : LAW SCP DOCKET #: DC 004229 01 CASE TITLE : GREATE BAY HOTEL CASINO VS CONNORS DON~D DATE DOC DOCUMENT FILING/TARGET ATTORNEY MUL DOC S FILED NUM TYPE PARTY NAME NAME PTY STA 07 09 2001 001 COMPLAINT-MAIL GREATE BAY H %rANF24BDEN N 07 09 2001 002 AFFID DEL INQ GREATE BAY H VANEMBDEN N 09 06 2001 003 JDG DEFLT COURT INIT N 09 06 2001 004 AFF PRF AMT DUE GREATE BAY H VANEMBDEN N 09 25 2001 005 STAT FOR DOCKET GREATE BAY H VANEMBDEN N 10 05 2001 006 EXEMP COPY JUDG GREATE BAY H VANEMBDEN N CV900123 END OF SEARCH PFI=INQRY PF2=MAINT PF5=SCP JUDGEMENTS PF4=PROMPT PF6=CONSOLIDATED CASE LIST PF7=PRIOR PF8=NEXT PF22=HELP: 4-© 1 Sess-1 172.16.1.99 Date: 10/10/01 Time: 14:29:42 GREATE BAY HOTEL AND CASINO, INC. T/A THE SANDS HOTEL AND CASINO Plaintiff DONALD CONNORS Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. : C1VIL DMSION - LAW : FOREIGN JUI~MENT JUDGMENT CREDITOR'S AFFIDAVIT AND NOW, ~ Plaintiff, GREATE BAY HOTEL AND CASINO, INC. T/A THE SANDS HOTEL AND CASINO, and hereby avors that the aforesaid Judgment from the Superior Court of New Jersey, Law Division, Special Civil Part in the County of Atlantic, remains valid, enforceable and unsatisfied and that the Defendant, DONALD CONNORS, has an address at: POST OFFICE BOX 7056, MECHANICSBURG, PA 17050. It is further averred that the address of Creditor is: by its attorneys, Marino & Maurice, P.C.; 250 RT 28, STE 203, BRIDGEWATER NJ 08807. ~c:C°llec~i°n Man~e~r for Greate Bay Hotel and 'Casino t/a The Sands Hotel and Casino DATED: //~~ GREATE BAY HOTEL AND CASINO, INC. T/A THE SANDS HOTEL AND CASINO Plaintiff Vo DONALD CONNORS Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. c>a. - . : CIVIL DMSION - LAW : FOREIGN JUDGMENT To DONALD CONNORS, Defendant(s) You are hereby notified that on D~l~O~-.i ~ | (Judgment) has been entered against you in the above-captioned case. ,20~7~the following Jud?ment entered inthe amount of $2.727.21 + interest. DATE: I hereby certify that the name and address ofthe proper person(s) to receive this notice is: DONALD CONNORS 33 PARK DRIVE P O BOX 7056 MECHANICSBURG PA 17050 A/ ~ Defendido/a Defendidos/as Por este medio se le esta notificando que el .de del 20_, el/la siguiente0*allo) ha sido anot~do en contra suya en el caso mencionado en el epigrafe. FECHA:. Protonotario Certificao que la siguiente direccion es la del defendido/a segun indieada en el eefifieado de reside~ia: DONALD CONNORS 33 PARK DRIVE P O BOX 7056 MECHANICSBURG PA 17050 Abogado del Demandante PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 ~REATE BAY HOTEL AND CASINO. INC. T/A THE SANDS HOTEL & CASINO IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WriC No. Term 20 Plaintiff No. 02-0541-CIVIL TERM Term 2002 VS Amount due $ ~.727.21 ~QNALD CONNORS 33 PARK AVENUE MIDDLETOWN PA 17057 InterestFROM DATE OF JUDG. A~y's Comm. $ {01/31/02) 136.36 and Costs]~~ Defendant (s) TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of (2) against DONALD CONNORS DAUPHIN County, Pennsylvania; Defendant (3) and against (4) and index this writ and (a) against (b) against DONALD CONNORS Defendant(s) ~arnishee(s), as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy) Dated 02/28/02 LEVY UPON A/J~ PEIt~Ot~L PROPERTY OFABOVE-LISTED DEI~ DRESS. (5) Exemption has (not) been waived. Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717) 238-7151 Attorney For Plaintiff(s) X3~noo ~q3 ~o ~aqs ag3 o~ KTuo pa3oazTp ag Xe~ ~ua~pn~ pa~a~sue~3 e uo pan~ ~T~ e (3)EO~E aln~ ~apu~ 'pa~eoTp~ aq pT~oqs ~3~noo OZ z~ o z ~z o 0 z 0 z z o z 0 z o 0 H WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-541 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF DAUPHIN COUNTY: To satisfy the debt, interest and costs due GREATE BAY HOTEL AND CASINO, INC. T/A THE SANDS HOTEL & CASINO Plaintiff (s) From DONALD CO1N'NORS, 33 PARK AVENUE, MIDDLETOWN, PA 17057 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS. (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 $2,727.21 Interest FROM DATE OF JUDG (01/31/02) Atty's Corem % Atty Paid $32.50 Plaintiff Paid Date: MARCH 4, 2002 REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7151 Supreme Court ID No. 18041 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division Robe~ L. Knupp Robe~ D. Kodak Gaw J. Imblum Of Counsel Mark A. Mateya LAW OFFICES OF KNUPP, KODAK & IMB'LUM, P.C. CAMERON MANSION 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 Telephone: 717/238-7151 Facsimile: 717/238-7158 email: kki.law@verizon.net March 17, 2003 Robe~ E. Knupp (1909-1976) Robe~ H. Maurer (1923-1998) OFFICE OF THE PROTHONOTARY CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE PA 17013 RE: VS: Greate Bay Hotel and Casino, Inc. Donald Connors No. 02-541, Court of Common Pleas Cumberland County, Pennsylvania Our File No. 27834 Dear Prothonotary: Enclosed please find the Dauphin County Sheriff's Return on the Writ of Execution to number 609 NT 2002, and issued to the above term and number, by your office and directed to the Sheriff of Dauphin County. Please file this Return of Service with your office. As always, I thank you for your usual fine service. RDK/slm enclosure(s) Very tr ~..~~ rRo(~eb r~.rtk oDd'a kK°(~dvaekriz o n. n et .._ CC: PHILLIPS VAN EMBDEN PC POST OFFICE BOX 863 MILLVILLE NJ 08332 #22906 SHERIFF'S RETURN 0609-NT - - -2002 PERSONAL PROPERTY WRIT OF EXECUTION And Now: March 13, 2002 And Now: March 13, 2002 Receipt # 161390 CREATE BAY HOTEL & CASINO INC T/A THE SANDS HOTEL & CASINO vs CON-NORS DONALD at 2:26 P.M. at 2:45 P.M. RECEIVED FROM PROTHONOTARY - pp PAYMENT RECEIVED And Now: March 14, 2002 at 2:09 P.M. And Now: March 28, 2002 at 3:31 P.M. And Now: April 1, 2002 at 10:20 A.M. And Now: May 2, 2002 at 12:56 P.M. PER ATTY RETURN WRIT UNABLE TO LOCATE INITIAL SERVICE INITIAL SERVICE CALLED FOR BETTER ADDRESS RETURNED NOT FOUND And Now: May 14, 2002 at 8:50 A.M. ISSUED REFUND CHECK NO 9883 IN THE SUM OF $85.50 TO KNUPP KODAK & IMBLUM PC Sheriff,s Costs State/Prothonotary Fee Poundage $40.75 $23.75 $64.50 Answe s, J. R. Lotwick, Sheriff REFUND CHECK FOR $85.50 TO ATTORNEY os/14/2oo2 PAGE PRAECIPE TO REISSUE AND AMEND WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 31 49 GREATE BAY HOTEL AND CASINO, INC. T/A THE SANDS HOTEL & CAS INO IN THE COURT OF COFk40N PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Writ No. Term 20 Plaintiff No. 2002-0541-CIVIL TERM Term 2002 VS Amount due $ 2~727.21 DONALD CONNORS 333 TALL TREE DRIVE PITTSBURGH PA 15235 InterestFROM DATE OF JUDG. Atty' s Comm. (01/31/02) $. 136.36 and CostsTO BE DETERMINED$. Defendant (s) TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of ~T.?.RGWk~Y County, Pennsylvania; (2) against DONALD CONNORS Defendant (s) (3) and against Garnishee (s), (4) and index this writ (a) against DONALD CONNORS (b) against Defendant(s) and 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 property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy) LEVY UPONALLPERSOI~%LPROPERTY OF ABOVE-LISTEDDEFENDANT(S) AT ABOVE-LISTEDADDRESSIN~?'?'~GHENY Dated 05/05/03 (5) Exemption has (not) been waived. /~~~~~~~.~ Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717) 238-7159 Atto~ne~ For Plaintiff(s) buT×epuT pue pgqoe~;e ~T ~qsTu;eb ~q; ~o ~u,n~u ~q~ uT X¢;~do;d T~ JT ~Tuo Pe;~Tdmoo ~q pTno~s (q)()) yde;be;~d Xq X%unoo ~q% u! as3nos ~o s~ pa~Inb~3 sT 5uT×~pu7 K~unco ~q~ou~ o~ s~nss7 ~7~m ~q3 U~qM '{g))OI~ sIn~ Xq p~zT3oq%n~ '(~!3m ~q~ u! p~pnIouT sq o~ ST ~qsTuJ~b p~eu ~ uT XIuo p~l~Idmoo eq pTnoqs ~Aoq~) (f) qde36~3md · p~nssT qDTq~ UT X~unom ~q~ ~o ~T3aqg sq~ o~ Xiuo pm~m~3Tp sq Kem ~us~bpn~ ps33s~sue3~ e uo psnssT ~T3m e (~)COIC aTn~ 3~pu~ -pe%eoTpu7 sq pinoqs XQunoo ~q% '(q) foIE ~Tn~ Xq pezl~oq%ne s~ K~unoo zsq~ou~ ~o ~T3~qs eq% o~ p~oe3Tp ST %y~m ~q% u~qm (I) qde~be3ed ~spufl u ~ 0 121 0 m< o ~0 0 0 H WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF iMJ.Ivl~I[l~ To satisfy the debt, interest and costs due SANDS HOTEL & CASINO, Plaintiff (s) NO 02-541 Civil CIVIL ACTION - LAW COUNTY: GREATE BAY HOTEL AND CASINO, INC. T/A THE From DONALD CONNORS, 333 TALL TREE DRIVE, PITTSBURGH, PA 15235 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS IN ALLEGHENY COUNTY. (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 $2,727.21 Interest FROM DATE OF JUDG (01/31/02) Atty's Comm $136.36 % Atty Paid $109.50 Plaintiff Paid Date: MAY 13, 2003 (Seal) REQUESTiNG PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. 18041 L.t. Due Prothy $1.00 Other Costs CURTIS R. LONG Deputy