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HomeMy WebLinkAbout13-1454 Mobile Mini, Inc. vs SC3 — Transcript of Judgment page 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA, CIVIL DIVISION MOBILE MINI, INC., CIVIL ACTION — LAW Plaintiff, vs. SC -3 STACKABLE COMMERCIAL CERTIFIED COPY OF MAGISTERIAL CONSTRUCTION CONCEPTS, INC., DISTRICT JUDGE'S JUDGMENT Defendant, Filed on Behalf of Plaintiff, MOBILE MINI, INC. COUNSEL OF RECORD FOR THIS PARTY: CERTIFICATE OF ADDRESSES John R. Keating, Esquire See Attached PA I.D. No. 52779 KEATING LAW FIRM, P.C. 4232 Northern Pike, Suite 202 Monroeville, PA 15146 (412) 856 -8484 Phone (412) 856 -4444 Fax COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND - Case Mag. Dist. No: MDJ- 09 -3 -05 Mobile Mini, Inc. MDJ Name Honorable Brenda M. Knepper V Address: 507 North York Street SC -3 Stackable Commerical Construction Mechanicsburg, PA 17055 Concepts Inc. Telephone: 717- 766 -4575 John Robert Keating, Esq. Docket No: MJ- 093(! WY -O( 226 Keating Law Firm, P.0 m– r Case Filed: 11 /3 /20tt - — -_ -,_ 4232 Northern Pike <'. c: Suite 202 v! C -3 Monroeville, PA 15146 -� . �41 Disposition Summary Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09305 -CV- 0000229 -2012 Mobile Mini, Inc. SC -3 Stackable Commerical Default Judgment for Plaintiff 02/08/2013 Construction Concepts, Inc. Judgment Summary Participant Joint/Several Liability Individual Liability Amount Mobile Mini, Inc. $0.00 $0.00 $0.00 SC -3 Stackable Commerical Construction $0.00 $7,449.37 $7,449.37 Concepts, Inc. Judgment Detail ( `Post Judgment) In the matter of Mobile Mini, Inc. vs. SC -3 Stackable Commerical Construction Concepts, Inc. on 2/08/2013 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $7,261.44 $7,261.44 Filing Fees $0.00 $187.93 $187.93 Grand Total: $7,449.37 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY /CLERK 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. 1 y a Date Magisterial District Judge Brenda M. Knepper I certify that this is a true and correct copy of the record of the proceedings containing the judgment. Date Magisterial District Judge 4,3r-.2,S pY MDJS 315 Page 1 of 2 Printed: 02/08/2013 11:08:42AM Mobile Mini, Inc. Docket No.: MJ- 09305 -CV- 0000229 -2012 v. SC -3 Stackable Commerical Construction Concepts, Inc. Participant List Private(s) John Robert Keating, Esq. Keating Law Firm, P.C. 4232 Northern Pike Suite 202 Monroeville, PA 15146 Plaintiff(s) Mobile Mini, Inc. C/O Keating Law Firm, P.C. 4232 Northern Pike Suite 202 Monroeville, PA 15146 Defendant(s) SC -3 Stackable Commerical Construction Concepts, Inc. 706 Moores Mountain Road Mechanicsburg, PA 17055 MDJS 315 Page 2 of 2 Printed 02/08/2013 11:08:42AM COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CIVIL COMPLAINT Magisterial District Number PLAINTIFF: NAME and ADDRESS 09 -3 -05 F — MDJ Name: Hon MObIIe Mini, Inc. Mark W. Martin c/o Keating Law Firm, P.C. Address: 507 North York Street 4232 Northern Pike, Ste, 202 Mechanicsburg, PA 17055 Monroeville, PA 15146 Telephone: ( 717)766-4575 VS. DEFENDANT: NAME and ADDRESS F— SC -3 Stackable Commerical Construction Concepts, Inc. 706 Moores Mountain Rd Mechanicsburg, Pa 17055 J Docket No.: O—V— Date Filed: 0 1 - AMOUNT DATE PAID FILING COSTS $ IL43 U0 11/29/12 POSTAGE SERVICE COSTS $ 1 �' ' O - l l Social security numbers and financial information $ ;5.00 l l (e.g. PINS) should not be listed. If the identity of an CONSTABLE ED. $ 5 ,0113, l l account number must be established, list only the TOTAL $ ' g' , 00 ; , � �� last four digits. 204 Pa. Code §§ 213.1 - 213.7. Pa.R.C.P.D.J. No. 206 sets forth those costs recoverable by the prevailing party. TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for $ 7.261.44 _ together with costs upon the following claim (Civil fines must include citation of the statute or ordinance violated): Balance due Plaintiff by Defendant for good and or services sold and delivered on or about February 11, 2011 through May 15, 2012 for which the Defendant has failed or refused to pay despite repeated demands. Amount: $ 7,049.95 Interest at 6 0 /I per annum from June 15, 2012 $ 211.49 TOTAL $ 7,261.44 f, John R. Keating verify that the facts set forth in this complaint are true and correct to the best of my knowledge, information, and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA. C.S. § 4904) related to unsworn falsification to authorities. J (Signa of Plaintiff or Authorized Agent) The plaintiff's attorney shall file an entry of appearance with the magisterial district Jant to Pa. R.C.P.M.D.J. 207.1. IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOUL ffjudge THIS OFFICE IMMEDIATELY AT THE ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AYOUR DEFENSE. UNLESS YOU DO, JUDGMENT MAY BE ENTERED AGAINST YOU BY DEFAULT. If you have a claim against the plaintiff which is within magisterial di risdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office at least five (5) days before the date set for the hearing. If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. ,� 0w AOPC 308A -? Mobile Mini, Inc. vs SC3 — Transcript of Judgment page 5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA, CIVIL DIVISION MOBILE MINI, INC., ) CIVIL ACTION — LAW Plaintiff, ) No. vs. ) SC -3 STACKABLE COMMERCIAL ) CONSTRUCTION CONCEPTS, INC., ) Defendant, ) CERTIFICATE OF ADDRESSES I, the undersigned counsel do hereby certify that the last known address of the parties hereto are as follows: Plaintiff: Mobile Mini, Inc. P.O. Box 79149 Phoenix, AZ 85062 -9149 Defendant: SC -3 Stackable Commercial Construction Concepts, Inc. 706 Moores Mountain Road Mechanicsburg, PA 17055 Joh <fC'ing, Esquire Mobile Mini, Inc. vs SC3 — Transcript of Judgment page 6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA, CIVIL DIVISION MOBILE MINI, INC., ) CIVIL ACTION — LAW Plaintiff, ) No. vs. ) SC -3 STACKABLE COMMERCIAL ) CONSTRUCTION CONCEPTS, INC., ) Defendant, ) NOTICE OF ORDER, DECREE OR JUDGMENT TO: SC -3 Stackable Commercial Construction Concepts, Inc. 706 Moores Mountain Road Mechanicsburg, PA 17055 ( ) Plaintiff ( X) Defendant ( ) Additional Defendant You are hereby noticed that an Order, Decree or Judgment was entered in the above captioned proceeding on ( ) A copy of the Order or Decree is enclosed; or ( X ) The judgment is as follows: $7,449.37 plus costs Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Mobile Mini, Inc. ❑Confessed Judgment Plaintiff ❑✓ Other v5. File No. 2013-01454 SC-3 Sry-)CK dL -� s Cansue��dr $7,449.37 -vim zz CvNC�`7�'7-S, Ti.1C, Amount Due M Defendant Interest $72.25 Address: Atty's Comm -C D CJ ' 706 Moores Mountain Road Costs Mechanicsburg, PA 17055 : ;Fa �..,- fn TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract,or account based on a confession of judgment,but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of CUMberland County,for debt, interest and costs,upon the following described property of the defendant(s) Personal Property PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County,for debt,interest and costs,as above,directing attachment against the above-named garnishee(s)for the following property (if real estate,supply six copies of the description;supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s). ❑ (Indicate)Index this writ against the garnishee(s)as a lis pende gainst rea ate of the defendant(s)described in the attached exhibit. Date May 16, 2013 Signature: Print Name: hn R. Keating, Esq. aS.50 P� f 4232 Northern Pike, Ste, 202 81 • oq5 CQF' Address: Monroeville, PA 15146 .. 75 P,0 A Attor ey r: Mobile Mini, Inc. Telephone: 412-856-8484 Supreme Court ID No: 52779 a,a5 3)_0 00 LL c#I�57 �#�9671v8 ly IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA, CIVIL DIVISION MOBILE MINI, INC., CIVIL ACTION - LAW Plaintiff, No. 2013 — 01454 vs MONEY JUDGMENT SC-3 STACKABLE COMMERCIAL PRAECIPE FOR CONSTRUCTION CONCEPTS, INC., WRIT OF EXECUTION Defendant Filed on Behalf of Plaintiff MOBILE MINI, INC. COUNSEL OF RECORD FOR THIS PARTY John R. Keating, Esquire PA I.D. No. 52779 Keating Law Firm, P.C. 4232 Northern Pike, Suite 202 Monroeville, PA 15146 412-856-8484 phone 412-856-4444 fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA, CIVIL DIVISION MOBILE MINI, INC., ) CIVIL ACTION — LAW Plaintiff, ) No. 2013 — 01454 vs ) SC-3 STACKABLE COMMERCIAL ) CONSTRUCTION CONCEPTS, INC., ) Defendant, ) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: (1) Directed to the Sheriff of Cumberland County (2) Against Defendant SC-3 Stackable Commercial Construction Concepts, Inc. (3) Amount Due: $7,449.37 6% interest from 03/18/13 $ 72.25 TOTAL $7,521.62 Res p Ily submitted, Ke ing L w Firm, P BY: Joh sting WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 2013-1454 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF YORK COUNTY: To satisfy the debt, interest and costs due MOBILE MINI, INC., Plaintiff(s) From SC-3 STACKABLE CONSTRUCTION CONCEPTS,INC.,706 Moores Mountain Road, Mechancisburg,PA 17055 (1) You are directed to levy upon the property of the defendant(s)and to sell personal property (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$7,449.37 Plaintiff Paid$ Interest -- $72.25 Attorney's Comm. % Law Library$.50 Attorney Paid$59.75 Due Prothonotary$2.25 Other Costs$ Date: 5/20/13 / I - _ i/ a David D. Buell,Prothonotary Deputy REQUESTING PARTY: Name : JOHN R. KEATING, ESQUIRE Address: KEATING LAW FIRM PC 4232 NORTHERN PIKE, SUITE 202 MONROEVILLE, PA 15146 Attorney for: PLAINTIFF Telephone: 412-856-8484 Supreme Court ID No. 52779 Richard P Keuerleber Sheriff Reuben B Zeager Chief Deputy, Operations SHERIFF'S OFFICE OF YORK COUNTY 3 IL/Si/cj PETER J. MANGAN, ESQ. Solicitor Richard E Rice, II Chief Deputy, Administration MOBILE MINI, INC VS SC -3 STACKABLE COMMERCIAL CONSTRUCTION CONCEPTS, INC dba SC 3 INC/MAS Case Number 2013 -NO -4585-32 SHERIFF'S RETURN OF SERVICE 06/05/2013 09:50 AM - DEPUTY MICHAEL DONOVAN, BEING DULY SWORN ACCORDING TO LAW, ATTEMPTED SERVICE OF THE REQUESTED LEVY. A PERSON REPRESENTING THEMSELVES TO BE MICHAEL BARRETT, OWNER REFUSED ENTRY AS "ADULT PERSON IN CHARGE" FOR SC -3 STACKABLE COMMERCIAL CONSTRUCTION CONCEPTS, INC. DBA SC 3 INC/MAS AT 706 MOORES MOUNTAIN ROAD, MECHANICSBURG, PA 17055. MICHAEL" NOVAWDEPUTY ' 10/23/2013 LEVY NOT DONE WITHIN LIFE OF WRIT. WRIT EXPIRED, DEPUTY WAS REFUSED ENTRY ONTO THE PREMISES SHERIFF COST: $90.80 SO ANSWERS, October 31, 2013 RICHARD P KEUERLEBER, SHERIFF (c)CountySHto SI -tariff TatansoftIrc COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MOBILE MINI, INC. Plaintiff VS. SC -3 S1TACKABLE COMMERCIAL CONSTRUCTION CONCEPTS, INC. Defendant(s) : No.2013-01454 : CIVIL ACTION :1.111; OCT 2_9 i 3:34 • COUNTY PENNS F LVANIA PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please satisfy the judgment entered in the above -captioned case. AMATO KEATING AND LESSA, P.C. By: Michael R. Lessa, Esq., Atty ID #88617 John R. Keating, Esq., Atty ID #52779 David A. Lovejoy, Esq., Atty ID #19829 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 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW• MOBILE MINI, INC. Plaintiff vs. SC -3 STACKABLE COMMERCIAL CONSTRUCTION CONCEPTS, INC. Defendant(s) : No.2013-01454 : CIVIL ACTION CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of Plaintiffs Praecipe to Satisfy Judgment was served via first class mail, postage prepaid on October 22, 2014, upon: SC3 Stackable Commercial 706 Moores Mountain Road Mechanicsburg PA 17055 AMATO KEATING AND LESSA, P.C. By: Michael R. Lessa, Esq., Atty ID #88617 John R. Keating, Esq., Atty ID #52779 David A. Lovejoy, Esq., Atty ID #19829 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