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Home My WebLink About13-1111COMMONWEALTH OF PENNSYLVANIA COl1RT OF COMMON PLEAS Judicial district, County Of NOTICE OF APPEAL FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT _ COMMON PLEAS No. ~ 3 '~ ~~ NOTICE OF APPEAL ..~t~d ~ -~-~ I3 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 Jud eon th~eCda-t-e~-and in the ca1ls,,e referenced below. y _ . / '~ _~Q 1h~1 L.~ + Ul._) Ca ~ Y I ~'~ u ~ r7"C -!7Q -~-hZ ~ ~ ~~ _ t,.. ~.. n. ~n 11 S' ~"l~a c n. _ f Yn ~ In . ~ ( I ~yt~ AD'Jf<ESS OF ArPELLn~tiT CITY STP,TE ZIP CODE DATE GF JUCGPAENT IN THE CASE OF (Plamtift) `G) ~~ Zt,De~endant)' ~ Cam... DOCKET No. ~ Ot' SIGNA T URE OF El. NT OR ATTORNEY OR AGENT 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. Signature of Prothonotary or Deputy If~f~eQant 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. 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 appellee(s) (Common Pleas No. Signature of appellant or attorney or agent RULE: To , appellees} Name of appeilee(s) (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 MAYBE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date:~~20~3 1 Signature of Prothonotary or Deputy ~~ ~~ !~ YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/' M THIS NOTICE OF APPEAL. ~~ ~ Nti ~~ 83~ $:I~t AOPC 312-05 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. ~~, ~?'#i D NA H,l Q d 3N.i ~ ~l~.~f3-~~1~ s 1U.3.-mil '~ ~~ C~~~ COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ-09-3-03 MDJ Name: Honorable Susan K. Day Address: 229 Mill Street P.O. Box 167 Mount Holly Springs, PA 17065 Telephone: 717-486-7672 James F Walker 204 H St. Carlisle, PA 17013 Disposition Details Disposition Summary Docket No MJ-09303-CV-0000301-2012 James F Walker V. Senad Camdzic D/B/A Alpine Auto Sales LLC j 3 (j-a so ~t .~ c ,~'(~e y ~~~I15/c / ~'~ /7~/3 Docket No: MJ-09303-CV-0000301-2012 Case Filed: 1 2/1 212 0 1 2 Plaintiff Defendant Disposition Disposition Date James F Walker Senad Camdzic D/B/A Alpine Judgment for Defendant 01/30/2013 Auto Sales LLC ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARYlCLERK 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. nk` a a' e' 4~b Date Magisterial District Judge Susan K. Day ~b1Dr`~~ certi at is is a rue an come copy o e recor o t e procee ings con aimng a lu gmen . Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed: 01/30/2013 10:40:58AM No. ~3-~Irl February 19, 2013 James F. Walker Plaintiff Docket No. MIO-9303 CV-0000301-2012 v. Case Filed 12/12/12 Sinad Camdzic D/B/A Alpine Auto Sales, LLC ~ N ~. Defendant c~ `*t ~~- ~ w f~+'1 ° --I ~`+ ~ Judgement Entered p N ~' January 29, 2013 ~~ a O~ ~° <+d s~ a. ~ s ~~ Answer to is osition A ~,A, Of Magistrate Day's Ruling .""-~ .~- Motion to Recover '~ ~ 'c` ~~ 1. On March 23, 2012 Mr. Walker purchased a vehicle from Sinad Camdzic of Alpine Auto Sales, LLC. 2. Mr. Walker is a black man, residing at 204 "H" Street, Carlisle, PA 17013. 3. Mr. Walker purchased this vehicle by virtue of the trust he invested in Mr. Camdzic and the belief that Mr. Candzic and Alpine Auto Sales were reputable. 4. Mr. Walker was not a victim of "sales puffing". Mr. Walker was told he was purchasing a "good" car.... Not a "fantastic or great" car. Therefore, Mr. Camdzic prevaricated in his effort to sell the car (in question) to Mr. Walker. On that premise Mr. Walker was victimized by the unethical practice of deception. 5. Shortly after purchasing said vehicle Mr. Walker endured excessive, uncontrollable shaking of the steering wheel. 6. The defense will hold "that it did not deceive Mr. Walker. The Plaintiff, will prove to the contrary. 7. Let the record reflect that the Defendant will prove Mr. Camdzic deceived Mr. Walker in and on the bridge of familiarity. 8. Mr. Camdzic, in fact, failed to honor rules of ethics, protocol, and sound business practicum. 9. On or about or within two months after the purchase of the car... Mr. Walker solicited a second opinion from Noble Auto at 56 West Baltimore Street, Carlisle, Pa 17013, a licensed inspection station. Mr. Bob Mentzer, one of the licensed mechanics, alerted Mr. Walker of the myriad of difficulties with the vehicle that could result in extensive monetary burden. This, too, will be substantiated when the certified mechanic, Bob Mentzer verifies his work and inspection of the vehicle in question. 10. Mr. Mentzer will testify in depth to the extent of the problems located with the car. 1 1. The Plaintiff, too, will offer the court the testimony of three mechanics as to the state of the car when inspected in search of problems undisclosed at the time of purchase of said vehicle. 12. The vehicle in question: a 2004 Nissan Maxima. 13. The Plaintiff will chronologically offer in detail the events that led to this infraction of law. 14. Mr. Camdzic's veracity rises (in question), as Mr. Camdzic gives different versions of the accounts as they relate to the purchase of the vehicle in question when confronted about the myriad of wrongs with the car. Answers are inconsistent and manufactured. ADDENDUM A. Exhibits of Lemon Law. B. My handwritten accouonts of the entire unpleasant experience with Mr. Camdzic, as it Relates to car in question. C. All receipts and written communication with lawyers, mechanics, along with copy of Warranty and Title of Vehicle. D. Plaintiff will prove that he is adhering to every accent of the law while enduring this Unpleasant ordeal. LO IN The Plaintiff trusts the court in its hearing of this Motion will find that Mr. Camdzic did violate the letter of the law, and will not allow this ever increasing illegal practice of deception to continue and prevent others, as well, from being victimized. VERIFICATION I, hereby, verify that all contained herein are true and factual to the best of my knowledge and abilities. )a~ie F. Wacker, plaintiff ADOPTION In its drafting, 1, dames F. Walker, hereby adopt all herein contained and provided for in the menu of this Motion. ~ s F. Walker, Plaintiff C�: George F. Douglas, 11.1, Esq. Attorney 11)No. 61886 --u 7! SALZMANN HUGHES, P.C. 354 Alexander Spring Road, Suite I Carlisle, PA 17015 (717) 249-6333 JAMES F. WALKER, IN THE COURT OF COMMON PLEAS, 204 H. Street CUMBERLAND COUNTY, Carlisle, PA 17013 PENNSYLVANIA Plaintiff No. 13-1111 VS. Civil Action—Law SENAD CAMDZIC d/b/a ALPINE AUTO SALES, LLC 13 Gasoline Alley Carlisle, PA 17013 Defendant PRAECIPE Under Pennsylvania Rule of Civil Procedure Rule 1006, the Defendant, Senad Camdzic d/b/a Alpine Auto Sales, LLC,requests that the Prothonotary mark the appeal of the appellant stricken for failure to file a complaint within twenty(20) days of the filing of his appeal as required by Rule 1004(A). Please enter judgment in favor of the Defendant and against the Plaintiff, Jarnes F. Walker. Respectfully submitted, SALZMANN HUGHES, P.C. Ice— Date: By: George F. Douglas, 111, Esquire Attorney ID No. 61886 354 Alexander Spring Road, Suite I Carlisle, PA 17015 Attorney for Dqfendant Appeaj 3f>4� in anwd 7).fV &A/w ve, P to Sa -t 10, i2 4- 'a A fyyiA to 0. Row-, P"TKa"ney CERTIFICATE OF SERVICE I hereby certify that on the'D !'('d"dIy of March, 2013, 1 served a true and correct copy of the foregoing document via United States mail, first class mail, postage prepaid, and addressed as follows: JAMES F. WALKER, 204 H. Street Carlisle, PA 17013 Salzmann Hughes, P.C. By: - George F Douglas, 111, Esquire