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HomeMy WebLinkAbout12-4182 ` IED-O F ICE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTNTk PROT ONOTARY NINETH JUDICIAL DISTRICT COMMONWEALTH OF PENNSYLVANIA 20 i 2 JUL -5 M 2: 2 CUMBERLAND COUNTY PENNSYLVANIA BEACON COURT HOMEOWNERS ASSOCIATION Plaintiff, VS. MICHAEL CHRISTI No. q - q u 9a 0,-Va Defendant. PRAECIPE FOR ENTRY OF APPEARANCE TRANSFER OF JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter my appearance for the Plaintiff in the above matter, enter judgment in favor of Plaint Beacon Court Homeowners Association and against Michael Christi on the duly authenticated cop., of the judgment hereto attached (Exhibit "A") of Magisterial District Court No. 09-1-01, Docket N CV-0000059-2012, entered in the jurisdiction noted therein, and assess damages as follows: $ 4,553.00 Judgment due $ 75.75 Interest from March 22, 2012 at 6% per annum ($0.75 per diem) $ 31.25 Prothonotary's Costs $ 4,660.00 Real Debt (continued on following page) HF 7493208v.1 #15964/0003 Cta?! U wa . aSFd al? c?14 ) ?4g Pursuant to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authoritie$ I verify that said judgment was entered in the said jurisdiction in said amount with costs and interes due as noted, no part of which has been paid (except as noted) and which is valid, enforceable, and unsatisfied. HERRICK, FEINSTEIN LLP DAMAGES ASSESSED AND JUDGMENT ENTERED AS ABOVE NOTICE GIVEN UNDER PA.R.C.P. 236 FOL W &w&--. By: El en . Goodman, Esquire Supreme Court I.D. No. 306608 210 Carnegie Center Princeton, New Jersey 08540 tel. 609.452-3800 fax. 609.520.9095 Dated: July 2, 2012 HF 7493208v.1 #15964/0003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NINETH JUDICIAL DISTRICT COMMONWEALTH OF PENNSYLVANIA BEACON COURT HOMEOWNERS ASSOCIATION Plaintiff, VS. MICHAEL CHRISTI No. Defendant. CERTIFICATION OF ADDRESS VALIDITY I, Ellen M. Goodman, the undersigned, hereby verify as follows: 1. The last known U.S. Post Office address of the Plaintiff and Judgment Creditor Beacon Court Homeowners Association is c/o Select Property and Association Management, Inc., 1000 North Prince Street, Lancaster, Pennsylvania, 17603. 2. The last known U.S. Post Office address of the Defendants and Judgment Debtor Michael Christi is 4007 Seneca Avenue, Camp Hill, Pennsylvania 17011. (continued on the following page) HF 7493208v.1 #15964/0003 I understand that any false statements made herein are subject to the penalties of 18 Pa. Const. Ann. § 4904 (relating to unsworn falsification to authorities). HERRICK, FEINSTEIN LLP By: 6" QS&1".. Ellen M. Goodman, Esquire Supreme Court I.D. No. 306608 210 Carnegie Center Princeton, New Jersey 08540 tel. 609.452-3800 fax. 609.520.9095 HF 7493208v.1 #15964/0003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NINETH JUDICIAL DISTRICT COMMONWEALTH OF PENNSYLVANIA BEACON COURT HOMEOWNERS ASSOCIATION Plaintiff, VS. MICHAEL CHRISTI No. a- L/116 Defendant. RULE 236 NOTICE To: Mr. Michael Christi 4007 Seneca Avenue Camp Hill, Pennsylvania 17011 Pursuant to Pa.R.C.P. No. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X Transferred Judgment: $4,660.50 Money Judgment by Default: Judgment in Award of Arbitrators Summary Judgment: IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: ELLEN M. GOODMAN, ESQUIRE at this telephone number: (609) 452-3800 (AA HF 7493208v.1 #15964/0003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NINETH JUDICIAL DISTRICT COMMONWEALTH OF PENNSYLVANIA BEACON COURT HOMEOWNERS ASSOCIATION Plaintiff, VS. MICHAEL CHRISTI No. Defendant. AFFIDAVIT OF NON-MILITARY SERVICE I, Ellen M. Goodman, Esquire, being duly sworn, according to law, deposes and says that is the attorney for the Plaintiff; that she is authorized to make this Affidavit on behalf of the and that the above-named Defendant Michael Christi is not in the Military or Naval Service of the United States or its Allies, or otherwise as defined within the provisions of the Soldiers' and Sailors Civil Relief Act of Congress of 1940 and the amendments thereto. ELLEN M. GOODMA , ESQUIRE SIGNED AND SWORN BEFORE ME THIS-4d DAY OF , 2012 L ?. L NOTARY PUBLIC A. LY NOTARYOPUUBLIC O FDN DV JERSEY MY COMMISSION EXPIRES MARCH S. 20/,S'- HF 7493208v.1 #15964/0003 COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ-09-1-01 MDJ Name: Honorable Charles A. Clement Jr. Address: 920 Linda Lane Camp Hill, PA 17011 Telephone: 717-737-3434 Ellen Miriam Goodman, Esq. 777 Township Line Road, Suite 120 Yardley, PA 19067-5559 Disposition Summary Beacon Court Homeowners V. Michael Christi Docket No: MJ-09101-CV Case Filed: 1/21/2012 Docket IN Plaintiff Defendant Disposition MJ-091 01 -CV-0000059-2012 Beacon Court Homeowners Michael Christi Default Judgment for Plaintiff Assoc Judgment Summary Participant Joint/Several Liability Individual Liability Beacon Court Homeowners Assoc $0.00 $0.00 Michael Christi $0.00 $8,153.25 Judgment Detail (•PostJudgment) In the matter of Beacon Court Homeowners Assoc vs. Michael Christi on 3/16/2012 the disposition is Default Ju and judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Civil Judgment SO.00 $8,000.00 Costs SO.00 $153.25 2012 03/16/2012 Amou It $0. 0 $8.153. 5 dgmen for Plaintiff A ut $8,000. 0 $153. 5 Grand Total: $8,153. ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE E OF A PEAL WITH THE PROTHONOTARY/CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY O THIS NOTICE OF JUDGMENTITRANSCRIPT 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 AY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FUL , SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. MAR 2 2 2012 Date ,g at <' w,A"1e Cc 0A el S'i , y.' 4 Magisterial District Judge Charles A. Clement Jr. 6/26/2012 qyy? 641\ Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed: 03/22/2012 8:37:32AM Beacon Court Homeowners Assoc Docket No.: MJ-09101-CV-0040059-2012 V. Michael Christi , =n l?' 44, Rwr 1 r ) -: * 9R L'a.7f 4ic, ?- ... - Private(s) ate r" -? N r Ellen Miriam Goodman, Esq. ip Ct 777 Township Line Road Suite 120 ( ' , Yardley, PA 19067-5559 -0 :V r Z" N Plaintiff(s) y Beacon Court Homeowners Assoc lrtr = 1 p00 N Pripcf St Lancaster, PA-17603 Defendant(s) Michael Christi 4007 Seneca Ave Camp Hill, PA 17011 c - MDJ5 315 Page 2 of 2 Printed: 031221201 8:37:32AM