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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 M1+ • V k, N t,fJ ?a CD -1 F- tt ni r- rl -R; rn r,It 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 ?pC t?,E W a t oQ W S> d 1 b a a r lir to "V 0 .L id to UI O p 'G CP C3 f ?+J 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 ? • a 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 Op ? j c? # Ty. d .c a , -rz? W 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 ? i??a yl? 8 So Answers; .ter R Thomas I i S . By w - - bit :F d 9- 93J 0001 t ,- bd ', Ulin03 GtO 16'3 Wlllj CO- 3A183HS 3H1 J0 3313.0 Lk 4 &'_. ???SPI 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