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HomeMy WebLinkAbout13-1290 SHERIFF'S OFFICE OF CUMBERLAND COUN(}T�"Y#}�} FILER/-O([ # i IL1` Ronny R Anderson `- THE PROTHON it`,f�''l` Sheriff at cutuGrrt Jody S Smith ` k 2013 MAR 20 PM 3: Q7 Chief Deputy CUMBERLAND COUNTY Richard W Stewart t A y�{ Solicitor OFFICE OFTkESRERIFF PENNSYLVANIA LVANIA USFoods Inc. f/k/a US Foodservice, Inc. Case Number vs. Goodthmye, Inc. (et al.) 2013-1280 SHERIFF'S RETURN OF SERVICE 03/15/2013 11:30 AM-Deputy William Cline,being duly sworn according to law,served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Essam Haggag, Owner,who accepted as"Adult Person in Charge"for Goodthmye, Inc.at 397-A Baltimore Ro , Shippensburg Township, Shippensburg, PA 17257. 4 MLLIAO CLINE, DEPUTY 03/15/2013 11:30 AM-Deputy William Cline,being duly sworn according to law, served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Essam Haggag, Owner,who accepted as"Adult Person in Charge"for Adam Haggag d/b/a Goodthyme Diner at 397-A Baltimore Road, Shippensburg Township, Shippensburg, PA 17257. xal WILLIAM CLINE, DEPUTY SHERIFF COST: $64.00 SO ANSWERS, March 18, 2013 RONR7 R ANDERSON, SHERIFF (C)Caun(ySu?to Shoriff.?ejea$of;_7:7c. o- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW USFOODS INC. f/k/a US FOODSERVICE, INC. i c� Plaintiff No. 13-1290 Civil c ' rn" M . VS. = .. f �. jr wo GOODTHYME, INC. and ADAM HAGGAG d/b/a GOODTHYME DINER ' cam. �. ,.�,.� CIVIL ACTION . .� C) Cn Defendant -< PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY, CUMBERLAND COUNTY: Kindly enter judgment by default for want of an answer in favor of Plaintiff and against the above-named defendant(s) only and assess damages as follows: Debt $31 ,695.19 Interest (from March 1 , 2013 to April 23, 2013 at 18% per annum) $713.15 Costs $184.25 Total $32,592.59 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. Pursuant to RCP 237.1 , 1 certify that a copy of the annexed written notice(s) of intention to file this praecipe was mailed or delivered to all parties against whom judgment is to be entered and to their attorney of record, if any, after the default occurred, and at least ten days prior to the date of filing of this praecipe. Please note that said notice was mailed to all parties on April 9, 2013. Dated: April 23, 2013 AMATO AND LESSA, P.C. Michael R. Lessa, Esq., Atty ID #88.617 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 107 North Commerce Way n��� G Bethlehem, PA 18017 NA (610) 866-0400 A DEBT COLLECTION LAW FIRM CIV Cl 2122765 � ao IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW USFOODS INC. f/k/a US FOODSERVICE, INC. Plaintiff No. 13-1290 Civil vs. GOODTHYME, INC. and ADAM HAGGAG d/b/a GOODTHYME DINER CIVIL ACTION Defendant CERTIFICATION OF ADDRESSES I do certify that the precise last known address of the within named plaintiff is: 9399 W Higgins Rd. Rosemont IL 60018 1 do certify that the precise last known address of the within named defendant is: 397-A Baltimore Road. Shippensburg PA 17257 AMATO AND LESSA, P.C. By: Michael R. Lessa, Esq., Atty ID #88617 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400` A DEBT COLLECTION LAW FIRM x COURT OF COMMON PLEAS OF CUMBERLAND`COUNTY, PENNSYLVANIA CIVIL ACTION - LAW USFOODS INC. f/k/a US FOODSERVICE, INC. Plaintiff No. 13-1290 Civil VS. GOODTHYME, INC. and ADAM HAGGAG d/b/a GOODTHYME DINER CIVIL ACTION Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF NORTHAMPTON The undersigned, being duly sworn, according to law, deposes and says that he is unable to determine whether or not the above Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of The Servicemembers Civil Relief Act; That Adam Haggag is over 18 years of_age, resides at 397-A Baltimore Road, Shippensburg PA 17257. Sworn to and subscribed before me this--�4P'`day of 4L,- 2013 A.D. � c NOTARY PUBLIC ;COMMONWEALITH OF PENNSYLVAN Notarial Seal lle C.Bright,Notary public ethlehem,Northampton County mmission Expires]une 6,2015 MEMBER,PENNSYLVANIA A=—UATION OF NOTARIES COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW USFOODS INC. f/k/a US FOODSERVICE, INC. Plaintiff No. 13-1290 Civil VS. GOODTHYME, INC. and ADAM HAGGAG d/b/a GOODTHYME DINER Defendants TO: Adam Haggag d/b/a Goodthyme Diner 397-A Baltimore Road Shippensburg PA 17257 Date of Notice: April 9, 2013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMATO AND SSA, P.C. By: Michael R. Lessa, Esq., Atty ID #88617 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID 984464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Attorney File# 2122765 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW USFOODS INC. f/k/a US FOODSERVICE, INC. Plaintiff No. 13-1290 Civil VS. GOODTHYME, INC. and ADAM HAGGAG d/b/a GOODTHYME DINER Defendants TO: Goodthyme, Inc. d/b/a Goodthyme Diner 397-A Baltimore Road Shippensburg PA 17257 Date of Notice: April 9, 2013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMATO ANRLESSA, P.C. By: Michael R. Lessa, Esq., Atty ID #88617 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM Attorney File# 2122765 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW USFOODS INC. f/k/a US FOODSERVICE, INC. Plaintiff No. 13-1290 Civil VS. GOODTHYME, INC. and ADAM HAGGAG d/b/a GOODTHYME DINER CIVIL ACTION Defendant NOTICE OF JUDGMENT (XX) NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN.THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST THE ABOVE-NAMED DEFENDANT(s) IN THE AMOUNT OF $32,592.59 ON Prpri) 'd4, 2013. ( ) A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF CUMBERLAND COUNTY IN SUPPORT OF THE JUDGMENT IS/ARE ENCLOSED. PROTHONOTA (';:© N TY If you have any questions concerning the above, please contact the undersigned. AMATO AND LESSA, P.C. By: - Michael R. Lessa, Esq., Atty ID #88617 David A. Lovejoy, Esq., Atty ID #19829 Justin N. Davis, Esq., Atty ID #84464 Daniel A. Wechsler, Esq., Atty ID #203922 Paul F. Troisi, Esq., Atty ID #309511 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 A DEBT COLLECTION LAW FIRM d a: COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW USFOODS INC. f/k/a US FOODSERVICE,INC. Plaintiff No. 13-1290 Civil vs. ' - GOODTHYME, INC. and ADAM HAGGAG Q d/b/a GOODTHYME DINER �� ry s- CIVIL ACTION Defendants : z c N C)r CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of Default Judgment entered against Defendants was served via first class mail, postage prepaid on June 10, 2013: Goodthyme, Inc. d/b/a Goodthyme Diner 27 N. Center Street Cleona PA 17042 Adam Haggag d/b/a Goodthyme Diner 27 N. Center Street Cleona PA 17042 AMATO AND LESSA, P.C. By: Michael R. Lessa, Esq., Atty ID #88617 Attorney for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400