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HomeMy WebLinkAbout12-6117Jeffrey S. Wilson, Esquire I.D. #50503 P.O. Box 42321 Philadelphia, PA 19101-2321 610-543-0434 .f ='~"_ ~ S~: i... Fol.` (1~~['SV I~" 4~ ~~I? 0~? - I i~~-1(~ 35 ~~,~~ iC'~LAND COUNTY Attorney for Plaintiff c~>~~r~sYLV~,NIa IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ~U t DACO LIMITED PARTNERSHIP NO. I a' ~0~~1 vs. DAVID TRACY DESIGN INC. PRAECIPE TO FILE AND INDEX FOREIGN JUDGMENT AND ASSESS DAMAGES TO THE PROTHONOTARY: Pursuant to the Uniform Enforcement of Foreign Judgments Act, 42 Pa.Cons. Stat. Sec. 4306, kindly file and index the attached exemplified and certified copies of the docket entries and the judgment entered in favor of Plaintiff, DACO LIMITED PARTNERSHIP and against Defendant, DAVID TRACY DESIGN INC. in the total sum of $7,170.97 in the Superior Court of New Jersey, in an action captioned DACO LIMITED PARTNERSHIP v. DAVID TRACY DESIGN INC., No. DC-1260-12, DJ- 133430-12, and assess damages in favor of Plaintiff, DACO LIMITED PARTNERSHIP, and against Defendant, DAVID TRACY DESIGN INC., as follows: Amount of Foreign Judgment $7,170.97 Interest 5/12-9/12 143.42 Total: $7,314.39 plus court costs ttorn for Plaintiff eke ~~~~ ~~asiy~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW DACO LIMITED PARTNERSHIP NO. vs. DAVID TRACY DESIGN INC. AFFIDAVIT OF VAILIDTY Jeffrey S. Wilson, Esquire being duly sworn according to law, deposes and says that he is the attorney for Plaintiff, DACO LIMITED PARTNERSHIP, is authorized to make this affidavit on its behalf; and that to the best of his knowledge, information and belief: 1. The name of the judgment Debtor is DAVID TRACY DESIGN INC.; 2. The last known post office address of the judgment Debtor is 5020 Ritter Road, Suite 1, Mechanicsburg, PA 17055; 3. The name of the judgment creditor is DACO LIMITED PARTNERSHIP; 4. The last known post office address of the judgment Creditor 300 Myrtle Avenue, Boonton, NJ 07005; 5. The judgment in favor of Plaintiff, DACO LIMITED PARTNERSHIP and against Defendant, DAVID TRACY DESIGN, INC., entered in the total sum of $7,170.97 in the Superior Court of New Jersey, is valid, enforceable, and unsatisfied as of this date. Sworn to and subscribed before e t is~t7 day of 12. BY: tt rney Plaintiff oo~t ~.wwrn .>~~~ auttNr, -~- PubNc TredyffrMl TWp., ChNOer QountY CAnMnitsbn Lunt 21 2014 MHISER PENNMYANM ~r S~TPERIOR COURT OF NEW JERSEY I, JENNIFER M. PEREZ, Clerk, Superior Court Clerk's Office, the same being a Court of Record, do hereby certify that the foregoing CERTIFICATION OF STATEWIDE JUDGMENT LIEN is a true record of the judgment filed and recorded as a lien June 27, 2012 in the cause wherein DACO LIMITED PARTNERSHIP is the Plaintiff; and DAVID TRACY DESIGN INC. is the Defendant, now on file in my office. IN TESTIMONY WHEREOF, I have hereto set my hand and affixed the seal of Said Court, at Trenton, this 26th day of July, Two Thousand and Twelve. Cler I, PHILIP S. CARCHMAN, Judge of the Superior Court of New Jersey, do hereby certify that Jennifer M. Perez, whose name is subscribed to the above certificate, was, at that date thereof, and now is, the Clerk, Superior Court Clerk's Office, that the foregoing attestation is in proper form, that the seal thereto annexed is the seal of said. court, and that the signature of the said Jennifer M. Perez, is in her own proper handwriting.. WITNESS my hand at the City of Trenton, this 26th day of July, Two Thousand and Twelve. Judge NOTE--This certificate is made pursuant to an act of Congress (Title 28 U.S. Code, Sec. 1738 effective September 1, 1948) ' FAGS 001 OF 001 SUPERIOR COURT OF NEW JERSEY CIVIL JUDGMENT AND ORDER DOCKET DACO LIMITED PARTNER (PLAINTIFF(S)) VS DAVID TRACY DESIGN I NC (DEFENDANT(S)) PROCESSING VENUE: MORRIS DOCKET NO. MRS DC-001260-12 JUDGMENT N0. DJ-133430-12 DEBT N0. 001 OF 001 CERTIFICATION OF STATEWIDE JUDGMENT LIEN --------------------------------------------------------------------------------------------- IN FAVOR OF: AGAINST: DACO LIMITED PARTNERSHIP DAVID TRACY DESIGN INC 5020 RITTER ROAD CREDITOR CONTACT: SUITE 101 MITNICK & MALZBERG MECHANICSBURG, PA 17055 908-996-3716 JUDGMENT AMOUNT(*) $6,412.70 DATE OF JUDGMENT ENTRY: 05/10/2012 COSTS & ATTORNEY FEES 748.27 DATE STATEWIDE JUDGMENT LIEN RECORDED: 06/27/2012 TOTAL $7,160.97 STATEWIDE JUDGMENT LIEN STATUS: OPEN (*)INCLUDES PRE-JUDGMENT INTEREST(IF ANY) --------------------------------------------------------------------------------------------- DEBT AMOUNT: $7,170.97 DEBT STATUS: OPEN STATUS OF DEBT AS TO: DAVID TRACY DESIGN INC OPEN COMMENTS: --------------------------------------------------------------------------------------------- I HEREBY CERTIFY THAT THE FOREGOING REFLECTS THE JUDGMENT AND COSTS OF RECORD IN THIS COURT. ADJUSTMENTS AFTER THE DATE OF THE JUDGMENT, SUCH AS INTEREST OR CREDITS, MAY NOT BE INCLUDED IN THE TOTALS. PLEASE CONTACT THE CREDITOR OR CREDITOR'S ATTORNEY FOR THE CURRENT TOTAL AMOUNT DUE, IF ANY. ~"~ CLERK OR DEPUTY CLERK OF SUPERIOR COURT DATE: 07/12/2012 CVM1023 AUTOMATEp CASE MANAGEMENT SYSTEM 07/16/12 PAGE: 001 OF 001 DOCUMENT LIST 10:58 VENUE MORRIS COURT LAW SCP DOCKET #: DC 001 260 12 CASE TITLE DACO LIMITED PARTNER VS DAVID TRACY DESIGN ---------- - I NC -------- -- --- -------- -------------- DATE ----- DOC ----------------------- DOCUMENT NON ---- - FILING/TARGET ATTORNEY MUL DOC S FILED NUM TYPE CONF PARTY NAME ------------- NAME -------- -- --- PTY STA -------- ---------- 01 31 ---- 2012 ---- 001 ------------------------ COMPLAINT-MAIL --- DACO LIMITED MITNICK & MA N 03 28 2012 002 MISC OTHER DACO LIMITED MITNICK & MA N 04 04 2012 003 MOT ENT DEF JUD DACO LIMITED MITNICK & MA N GR 05 10 2012 004 ORD ENT DEF JUD DACO LIMITED MITNICK & MA N GR 05 10 2012 005 JDG DEFLT DACO LIMITED MITNICK & MA N 05 25 2012 006 STAT FOR DOCKET DACO LIMITED MITNICK & MA N CV900123 END OF SEARCH PF1-DOCUMENT-DETAIL PF4=PROMPT PF6=CONSOLIDATED CASE LIST PF7=PRIOR PFB=NEXT PF22=HELP: 4-ei 1 Sess-1 172.16.1.27 TA000017 2/8 Certified to be a tree Dopy of the original on file in the Superior Court CI 's Office /~,,. ~~ ]rGlt M. PE ESQ. CL.BRK OF SUPERIOR COURT Jeffrey S. Wilson, Esquire I.D. #50503 P.O. Box 42321 Philadelphia, PA 19101-2321 610-543-0434 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW DACO LIMITED PARTNERSHIP NO. vs. DAVID TRACY DESIGN INC. CERTIFICATION OF ADDRESS I, Jeffrey S. Wilson, Esquire counsel for Plaintiff in the above captioned matter hereby certifies that the correct address for each parties is as follows: Plaintiff s correct name and address: DACO LIMITED PARTNERSHIP 300 Myrtle Avenue Boonton, NJ 07005 Defendant's correct name and address: DAVID TRACY DESIGN INC. 5020 Ritter Road, Suite 1 Mechanicsburg, PA 17055 ~~~ Je re S. Wi n, Esquire Attorney f Plaintiff (Rule of Civil Procedure No. 236) -Revised IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACT10N -LAW DACO LIMITED PARTNERSHIP ) NO I ~-~ 1~ ~ Cv~~ Plaintiff VS. DAVID TRACY DESIGN INC. ) Defendant Notice is given that an order in the above captioned matter has been judgment decree verdict award entered against you on ~~~~ PROTHONOTARY If you have any questions concerning the above, please contact: JEFFREY S. WILSON, ESQUIRE POST OFFICE BOX 42321 PHILADELPHIA, PA 19101-2321 1ol~l~a 610-543-0434 120-303 PRAECIPE FOR WRIT OF EXECUTION -(MONEY JUDGMENTS) P.R.C.P 3101 to 3149 DACO LIMITED PARTNERSHIP # IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA VS. DAVID TRACY DESIGN INC. SOaO V`� No. 12-6117 Civil sum � I %,e(x 0 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION MEMBERS F SK FEDERAL CREDIT UNION (MONEY JUDGMENTS) 51 , _ 1--3 Garnishee. To the Director of the Prothonotary: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER: (1) Directed to the Sheriff of CUMBERLAND County,Pennsylvania; (2) against DAVID TRACY DESIGN INC.............Defendant(s); �n CZ 3, (3) and against... ...............Garnishee(s); ;1= ­4 :!77 (4) and Index this writ (a)against DAVID TRACY DESIGN INC...........Defendant(s) (b)against ...... ........Gamishce(s) as a lis pendens against the real property of the defendant(s)in the name of the Gamishee(s)as follows:(Specifically describe property) Check Blocks Needed r---JReal Estate r--JPersonal Property (5) Amount due $7,314.39 Less Payments ($1,500.00) Interest from 9/12-3/13 $ 174.43 Total $5,988.82 Plus costs Dated March 21,2013 .... .... ... ............ .... ttorney the Plaintiff (s) Under paragraph(1)when the writ is directed to the sheriff of another county as authorized by Rule 3103(b),the county should be indicated. Under Rule 3103(c)a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued. Paragraph(3)above should be completed only if a named garnishee is to be included in the writ. Paragraph(4)(a)should be completed only is indexing of the execution in the county of issuance,is desired as authorized by Rule 3104(a). When the writ issues to another county indexing is required as of course in that county by the Prothonotary. See Rule 3104(b). Paragraph(4)(b)should be completed only if real property in the name of a garnishee is attached and indexing as a lis pendens is esired. See Rule 3104(c) OD � OL 33 -SO ot Jv 25TO I C/-?,-/o No.12-6117 Civil IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DACO LIMITED PARTNERSHIP, Plaintiff VS DAVID TRACY DESIGN INC. Defendant(s) 8 MEMBERS FIRST FEDERAL CREDIT UNION Garnishee. PRAECIPE FOR WRIT OF EXECUTION (Money Judgments) P.R.C.P 3101 to 3149 etc. Attorney for Plaintiff Address: JEFFREY S. WILSON, ESQUIRE POST OFFICE BOX 42321 PHILADELPHIA, PA 19101-2321 (610) 543-0434 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 12-6117 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due DACO LIMITED PARTNERSHIP Plaintiff(s) From DAVID TRACY DESIGN INC.,5020 RITTER ROAD,SUITE 1,MECHANICSBURG,PA 17055 (1) You are directed to levy upon the property of the defendant(s)and to sell (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: MEMBERS FIRST FEDERAL CREDIT UNION,814 WEST HIGH STREET,CARLISLE,PA 17013 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$5,814.39 Plaintiff Paid$ Interest$ Law Library$.50 Attorney's Comm. % Due Prothonotary$2.25 Attorney Paid$810.77 Other Costs$ Date:3/25/13 David D.Buell,Prothonotary Al B • Deputy REQUESTING PARTY: Name :JEFFREY S.WILSON,ESQUIRE Address:P.O. BOX 42321 PHILADELPHIA,PA 19101-2321 Attorney for:PLAINTIFF Telephone:610-543-0434 Supreme Court ID No. JEFFREY S. WILSON,ESQUIRE RECEIVEI? ATTORNEY NO. 50503 ~ �L " �~ POST OFFICE BOX 42321 ' " ilt ' LIAR 2 9 2g13 PHILADELPHIA,PA 19101-2321 2013 APR _4 AM 11: 4 I 610-543-0434 DACO LIMITED PARTNERSHIP COURT OF COMMON PLEAS OF I EUMBERLAND COUNTY,PENNSYLVANIA vs. } DAVID TRACY DESIGN INC. } No. 12-6117 Civil } Defendant(s) } r MEMBERS FIRST FEDERAL CREDIT UNION } Garnishee. Sw�,-s INTERROGATO IES TO GARNISHEE You are required to file answers to the following Interrogatories within twenty(20) days after service upon you. Failure to do so may result in Judgment against you. These Interrogatories are to be deemed continuing. Unless otherwise specified, the questions are directed to the "time" of service of the attachment all "time" subsequent thereto. The answers should specify and clearly describe the information requested, including, but not limited to arnounts of money held or owing, account numbers, serial numbers, and detailed description of property, your interest therein, and any claims by you or others therein, including addresses and phone numbers where they may be reached. 1. At the time you were served or at any subsequent time did you owe the Defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? If so, describe the property and state its value.. 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself or others any property or any nature, including but not limited to checking account and promissory notes and saving accounts, owed solely or in part by the Defendant? If so, state the property and/or the joint possessor, custodian, or entity controlling said property. N� 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owed solely or in part by the Defendant? If so, please describe. RECEIVED MAR 2 9 2013 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the Defendant has interest? If so, please describe. NL 5. At any time after you were served did you pay,transfer or deliver any money or property to the Defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the Defendant against you? If so, to what extent? NA� 6. At any time before or after you were served, did the Defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so, what was the consideration therefore? Ll 3, 7. At any time you were served or at any subsequent time, did you have any safe deposit boxes, pledges, documents of title, securities, notes, coupons, receivables, collateral, checking, savings, tax or other accounts or deposits in which Defendant has an interest? � o 8. Please describe and state the value of all property belonging to Defendant in your possession. n ad t 500 to DATED: March 21, 2013 AtforAeyf7pintff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson �.� €=� � y'++ U} I-ii: , Sheriff at.0x'p tit luiltrc,P,4 Jody S Smith Chief Deputy. Std 2 Richard W Stewart CUMBERLAND COUNTY Solicitor 0M CE OF THE W-CRIr" PENNSYLVANIA DACO Limited Partnership Case Number vs. David Tracy Design, Inc. 2012-6117 SHERIFF'S RETURN OF SERVICE 03/28/2013 01:45 PM -William Cline, Deputy,who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, PA 17015, Cumberland County, by handing to Jan Finkle, Member Service Rep., personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on April 2, 2013 to David Tracy Design at 5020 Ritter Road, Mechanicsburg, PA 17055. 09/26/2013 Ronny R.Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $88.40 SO ANSWERS, '. September 26, 2013 RbNW R ANDERSON, SHERIFF S`0 -�� 93 (C)CountySuite Sheriff,Teleosoft,Inc.