HomeMy WebLinkAbout04-5643IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK,
Plaintiff
V.
CHRISTOPHER LEONE,
Defendant
NO. Q1{ -- S & q3 0- t V
PRAECIPE FOR
JUDGMENT ON
DISTRICT JUSTICE
JUDGMENT/
TRANSCRIPT
I hereby certify that the true
and correct address of Plaintiff is:
C/O Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
and that the last known address of
Defendants is:
Christopher Leone
10 Richland Ln., Apt. T7
Camp Hill, PA 17011
e Law Offices
! Gr 99 ,l sf
Filed on behalf of
Target National Bank
Counsel of Record for This
Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
ix, A.P.C.
--,t
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
59
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK,
NO.
Plaintiff
V.
CHRISTOPHER LEONE,
Defendant
PRAECIPE FOR JUDGMENT ON DISTRICT JUSTICE TRANSCRIPT
TO: PROTHONOTARY
Please enter a judgment against the defendant, above named.
Amount of Judgment $5,082.96
Less payment on September 28, 2004 (-) $ 170.00
TOTAL
$4,912.96
With continuing interest on the principal amount of $4,912.96, with interest at the legal
rate, plus costs of suit.
& Felix, A.P.C. ,
By.
I/Gre s, Esqui
Patenaude.ix, A.P.C
213 E. eet
Carnegi , PA 15106
(41-9-7675
.COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
Mag. Dist. No.:
09-1-02
y. DJ Name: Hon.
ROBERT V. MANLOVE
Address: 1901 STATE STREET
'CAMP HILL, PA
Telephone: (717 ) 761-0583
ROBERT V. MANLOVE
1901 STATE STREET
CAMP HILL, PA 17011-0000
THIS IS TO NOTIFY YOU THAT:
Judgment:
a Judgment was entered for:
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: CIVIL CASE
NAME and ADDRESS
'TARGET NATIONAL BANK
213 E MAIN ST
CARNEGIE, PA 15106
L
VS.
DEFENDANT: NAME and ADDRESS
17011-0000 rL-EONE, CHRISTOPHER
10 RICHLAND LN APT/STE T7
CAMP HILL, PA 17011
L
?i
J
Docket No.: CV-0000388-04
Date Filed: 8/09/04
nRFAUT.T MMr. RNT PT.TF
(Name) TARrV.T WATTONAT, RANK
7 Judgment was entered against: (Name) T.RnNR, C_HRT..gTnPHF.R
in the amount of $ S ,OA2 _ q[ on: (Date of Judgment) q/20/04
Defendants are jointly and severally liable. (Date & Time)
15
Damages will be assessed on: 0, ?' ??1 y OF Amount of Judgment $ 4,966.46
??A Qgp• Judgment Costs $ 116.50
Interest on Judgment $ • 00
This case dismissed ut pre t?i, COAL Attorney Fees $ . 00
OP 1S ?n F Total $ 5,082.96
Amount of Judgment a
Attachment/42 Pa.C.S. 1? ,U •(1G? Post Judgment Credits $
Portion of Judgment for p y 1L'( Post Judgment Costs $
damages arising out
lease $ Certified Judgment Total $
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 THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/ T RANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, 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 DISTRICT JUSTICE.
UNLESS THE JUDGMENT IS ENTERED IN T1IE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
?tttttrrr,.r, .
,, f1 ?bate Dist( ict Justice
I ce ' y th this is a true..and correctcopy of a et;0 d, the ?roceedingslopo ning;t?i?i 1 d m*6
?.,v tr Date r tsr,,fi ?. :{l?.' -• <>' pistriGtJuqce
AR"
My commission expires first Monday of January, 2006. ?`!,+?,rSr',l?"';`
AnW-.115-03 "AMIP DDTwmi? )• 9/21/04 2:42:37 PM o??d' a?Sy
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
Magisterial District Number:
District Justice Name: Hon
Address:
Telephone:
FILING COSTS
POSTAGE'
SERVICE COSTS
CONSTABLE ED
TOTAL
09-1-02
ROBERT V. MANLOVE
1901 STATE STREET
CAMP HILL, PA 17011
(717)761-0583
AMOUNT
CIVIL COMPLAINT
PLAINTIFF: NAME and ADDRESS
TARGET NATIONAL BANK
• C/O GREGG L. MORRIS ESQ.
213 E. MAIN STREET
CARNEGIE, PENNSYLVANIA 15106
VS.
DEFENDANT: NAME and ADDRESS
CHRISTOPHER LEONE
10 RICHLAND LN. T7
CAMP HILL, PA 17011
Docket No.: CVr/??
Date Filed:
DATE PAID !!!
. ` s
THE DEFENDANT: THE ABOVE NAMED PLAINTIFF(S) ASKS JUDGMENT AGAINST YOU FOR $4,966.46 TOGETHER WITH COSTS UPON
THE FOLLOWING CLAIM (CIVIL FINES MUST INCLUDE CITATION OF THE STATUTE OR ORDINANCE VIOLATED):
UNPAID BALANCE ON TARGET NATIONAL BANK OPEN ENDED CREDIT CARD ACCOUNT No. 4352378347728178 IN THE
SUM OF $ 3,966.46 ALONG WITH REASONABLE ATTORNEY'S FEES IN THE AMOUNT OF $ 1,000.00 FOR A TOTAL BALANCE DUE OF
$4,966.46 PLUS INTEREST AND COSTS.
I, GREGG L. MORRIS, ESQ. VERIFY THAT THE FACTS SET FORTH IN THIS COMPLAINT A?E TRUE AND CO CT TO 74 BEST OF MY
KNOWLEDGE, INFORMATION, AND BELIEF. THIS STATEMENT IS MADE SUBJECT TO THE PENAUITIES OF SECTION 4 04/jOFiTOE RIMES CODE
(18 PA. C.S. § 4904) RELATED TO UNSWORN FALSIFICATION TO AUTHORITIES.
? e
Y
i SIG f}iiTTfA?D A?
PLAINTIFF'S GREGG L. MORRIS, ESQ. I ?./
ATTORNEY: PATENAUDE & FELIX ADDRESS' 213 E. MANN STREET
TELEPHONE: (412) 429-7675 CARNEGIE,,PA(?W06
IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD SO NOTIFY THIS OFFICE IMMEDIATELY
AT THE ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE.
UNLESS YOU DO, JUDGMENT MAY BE ENTERED AGAINST YOU BY DEFAULT.
IF YOU HAVE A CLAIM AGAINST THE PLAINTIFF WHICH IS WITHIN DISTRICT JUSTICE JURISDICTION 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.
AOPC 308A-02
LEONE, CHRISTOPHER 2050,2759.wpd
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
V.
CHRISTOPHER A LEONE
Plaintiff
Defendant(s)
PNC BANK
Garnishee
NO. CV-0000388-04
DL}.- 5(,Lf3 L' iv;1 -(erm
PRAECIPE FOR WRIT OF
EXECUTION
Filed on behalf o£
TARGET NATIONAL BANK
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA_134 Prop Writ of Exe
P&F File No. 2050.2759
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
V. )
CHRISTOPHER A LEONE )
)
io Riem"d L w%-, T7
` mp Hill, PA Defendant(s) )
1?al I )
PNC BANK )
Garnishee )
PRAECIPE FOR WRIT OF EXECUTION
To The Prothonotary:
Issue writ of execution in the above matter,
TARGET NATIONAL BANK )
Plaintiff ) NO. CV-0000388-04
(1) directed to the Sheriff of Cumberland County;
(2) against, CHRISTOPHER A LEONE Defendant(s);
(3) against, PNC BANK, Garnishee; 10 Noble $LN 0, Cou-Irmle, PA tM13
(4) and index this writ
(a) against, Defendant(s) CHRISTOPHER A LEONE, Defendant(s); and
(b) against PNC BANK, Garnishee; bevy on de4t,&A s aerzo,,
as a lis pendens against real property of the Defendant(s) in the name of the garnishee as follows:
$4,912.96
(5) Judgerlent Amount -(2,322.40)
Less Payments Received
Am n ,t Due $2,590.56
ou
Interest from November 09, 2004
At 5.00% per annum
(Costs to be added)
$48.19
Q'
PA_l34 Prcp Writ of Exe
P&F File No. 2050.2759
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 04-5643 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due TARAGET NATIONAL BANK, Plaintiff (s)
From CHRISTOPHER A. LEONE, 10 Richland Lane T7, Camp Hill, PA 17011
(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:
PNC BANK, 105 Noble Blvd, Carlisle, PA 17013
levy on defendant's bank account
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 $2,590.56
L.L. $.50
Interest from 11/09/04 at 5.00% per annum -- $48.19
Atty's Comm % Due Prothy $2.00
Atty Paid $46.25
Plaintiff Paid
Date: 2/04/08
(Seal)
REQUESTING PARTY:
Name GREGG L. MORRIS, ESQUIRE
Address: PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15106
Attorney for: PLAINTIFF
Telephone: 412-429-7675
Supreme Court ID No. 69006
Other Costs
(21
0Z) 0a 0,4dO J
Curti . Long, Pr tary
By:
Deputy
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2004-05643 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
TARGET NATIONAL BANK
VS
LEONE CHRISTOPHER
And now MICHAEL BARRICK Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0013:30 Hours, on the 11th day of February , 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
- -- ,-11-- if --'TT' , in the
hands, possession, or control of the within named Garnishee
PNC BANK 105 NOBLE BLVD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
VIOLA ROELKE (ASST MANAGER)
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to Her .
Sheriff's Costs: So answers;
Docketing .00 ?.
. .
Service .00
:, .., .
..
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
0 0 9rn-
02/11/2008 /f
1 /
Sworn and Subscribed to
before me this day of By % y
eputy he iff
A.D
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
NO. 04-5643
V.
CHRISTOPHER A LEONE
Defendant(s)
PNC BANK
Garnishee
PRAECIPE TO
DISCONTINUE WITHOUT
PREJUDICE AS TO THE
GARNISHEE ONLY
Filed on behalf of:
TARGET NATIONAL BANK
Counsel of Record for This Party:
Gregg L. Morris, Esquire
Pa I.D. #69006
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA_170 Prcp Disc w/o Pr do P&F File No. 2050.2759
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
TARGET NATIONAL BANK
Plaintiff
NO. 04-5643
V.
CHRISTOPHER A LEONE
Defendant(s)
PNC BANK
Garnishee
PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE AS TO THE GARNISHEE
ONLY
TO: Prothonotary
Please discontinue the matter captioned above without prejudice as to the garnishee, PNC
BANK, only. Thank you.
submitted:
&& Felix, A.P.C.
Date:
Sworn to and subscribed before me this
_Z ?? day of , 209.
?,4,
Notary Publ c
MMONWEALTH 01" P'E'NNSYLVANIA
Carolyn J SNotarial Seal
ewa? Notary Public
Camegla Boro, ANegheny County
My Commission Fires Aug.14, 2011
Member, Pennsylvania Association of Notaries
GiVgg L. Morris, Esquire
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA_170 Prep Disc w/o Pr do P&F File No. 2050.2759
I, GREGG MORRIS, attorney for Plaintiff, TARGET NATIONAL BANK, hereby
certify that a true and correct copy of foregoing document was served this date by ordinary mail
upon the following:
PNC BANK
500 FIRST AVE
PITTSBURGH PA 15219
Date:
Vegg L. Morris, Esquire
Patenaude & Felix, A.P.C.
213 E. Main Street
Carnegie, PA 15106
(412) 429-7675
PA-170 Prcp Disc w/o Pddc
P&F File No. 2050.2759
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R. Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED, DUE TO BANKRUPTCY.
Sheriff's Costs: Advance Costs: 150.00
Sheriff s Costs 85.99
Docketing $ 18.00 89.01
Poundage 1.69
Advertising
Law Library .50
Prothonotary 2.00 Refunded to Atty on 11/14/08
Milage 4.80
Surcharge 30.00
Levy 20.00
Post Pone Sale
Garnishee 9.00
Postage
TOTAL $
85.99 ?
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 04-5643 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due TARAGET NATIONAL BANK, Plaintiff (s)
From CHRISTOPHER A. LEONE, 10 Richland Lane T7, Camp Hill, PA 17011
(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:
PNC BANK, 105 Noble Blvd, Carlisle, PA 17013
levy on defendant's bank account
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 $2,590.56
L.L. $.50
Interest from 11/09/04 at 5.00% per annum -- $48.19
Atty's Comm % Due Prothy $2.00
Atty Paid $46.25
Plaintiff Paid
Other Costs
Date: 2/04/08
(Seal)
Curti . Long, Pro ary
By:
Deputy
REQUESTING PARTY:
Name GREGG L. MORRIS, ESQUIRE
Address: PATENAUDE & FELIX, A.P.C.
213 E. MAIN STREET
CARNEGIE, PA 15106
Attorney for: PLAINTIFF
Telephone: 412-429-7675
Supreme Court ID No. 69006