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
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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