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HomeMy WebLinkAbout13-2109 Counsel for Plaintiff David R. Galloway r THE PRO TH0No-F}"r� ! ff Attorney I.D. 87326 � 54 E. Main Street ` $ P11 { Mechanicsburg, PA 17055 CUMBERLAND COUNTY Telephone: 717-697-4650 PENNSYLVANIA Facsimile: 717-697-9395 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES F. BASSETT, JR., Plaintiff CIVIL ACTION - LAW V. NO: PAMELA NAWROCKI, Defendant PRAECIPE TO ENTER JUDGMENT ON MAGISTERIAL DISTRICT JUDGE'S TRANSCRIPT OF JUDGMENT In accordance with the transcript of the Magisterial District Judge which is attached hereto, enter judgment in favor of Plaintiff and against Defendant, in the sum of$4,117.04 which consists of$760.49 as Rent in Arrears, $2,688.42 as Unjust Detention, $500.00 as Attorney Fees, plus Magisterial District Justice filing fees of$168.13 and costs of this action. ectfully submitted, By David R. Gallo y Attorney No. 8 326 AFFIRMATION OF NO APPEAL As of the date of this filing an appeal has not been filed in the Court of Common Pleas of Cumberland County, Pennsylvania. Respectfully submitted, By David R. Galloway Attorney No. 87,- 6 r!LEu-iJy David R. Galloway t T C I E P R G H O NI` �� Y Counsel for Plaintiff Attorney I.D. 87326 2013 APR 18 PM li: G a 54 E. Main Street Mechanicsburg, PA 17055 CUMBERLAND COUNTY Telephone: 717-697-4650 P E N S Y L A 1 A Facsimile: 717-697-9395 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES F. BASSETT, JR., Plaintiff CIVIL ACTION - LAW V. NO: /3 _ 21 q Li L PAMELA NAWROCKI, Defendant CERTIFICATE OF SERVICE & LAST KNOWN ADDRESS I hereby certify that a copy of the foregoing Praecipe to Enter Judgment on Magisterial District Judge's Transcript of Judgment was served this date by mailing same via first class mail, postage prepaid, addressed as follows to Defendants' last known addresses: Ms. Pamela Nawrocki 237 Pine Grove Road Gardners, PA 17324 Reszecifully submitted, Date: April , 2013 By b David R. Galloway Attorney I.D. 873 �4 /3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Notice of Judgment/Transcript Residential Lease Mag. Dist.No: MDJ-09-3-05 James F. Bassett Jr. MDJ Name: Honorable Brenda M. Knepper V. Address: 507 North York Street Pamela Nawrocki Mechanicsburg, PA 17055 ITelephone: 717-766-4575 James F. Bassett Jr. Docket No: MJ-09305-LT-0000039-2013 960 Eppley Road Case Filed: 2/22/2013 Mechanicsburg, PA 17055 Disposition Details Grant possession. Yes Grant possession if money judgment is not satisfied by the time of eviction. No Disposition Summary Docket No Plaintiff Defendant Disoosition Disposition Date MJ-09305-LT-0000039-2013 James F.Bassett Jr. Pamela Nawrocki Judgment for Plaintiff 03105/2013 Judgment Summary Participant Joint/Several Liability Individual Liability Amount James F. Bassett Jr. $0.00 $0.00 $0.00 Pamela Nawrocki $0.00 $4,117.04 $4,117.04 Judgment Detail *Post Judgment) In the matter of James F. Bassett Jr.vs. Pamela Nawrocki on 3/05/2013 the judgment was awarded as follows: Judgment Component Joint/Several Liability. Individual Liability Deposit Applied Amount Rent in Arrears $0.00 $760.49 $760A9 Unjust Detention $0.00 $2,688.42 $2,688.42 Filing Fees $0.00 $168.13 $168.13 Attorney Fees $0,00 $500.00 $500.00 Grand Total: $4,117.04 Portion of judgment for physical damages arising out of residential lease: $0.00 IN AN ACTION INVOLVING A RESIDENTIAL LEASE,ANY PARTY HAS THE RIGHT TO APPEAL FROM A JUDGMENT FOR POSSESSION WITHIN TEN DAYS AFTER THE DATE OF ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURT OF THE COURT OF COMMON PLEAS,CIVIL DIVISION. AN APPEAL MUST BE FILED WITHIN THIRTY DAYS IN RESIDENTIAL LEASE ACTIONS INVOLVING A VICTIM OF DOMESTIC VIOLENCE. THIS APPEAL WILL INCLUDE AN APPEAL OF THE MONEY JUDGMENT, IF ANY. IN ORDER TO OBTAIN A SUPERSEDEAS,THE APPELLANT MUST DEPOSIT WITH THE PROTHONOTARY/CLERK OF COURTS THE LESSER OF THREE MONTHS RENT OR THE RENT ACTUALLY IN ARREARS ON THE DATE THE APPEAL IS FILED.HOWEVER,LOW-INCOME AND/OR SECTION 8 TENANTS SHOULD REFER TO Pa.R.C.P.M.D.J.NO.1008 OR 1013 FOR DIFFERENT PROCEDURES REGARDING THIS DEPOSIT. IF A PARTY WISHES ONLY TO APPEAL THE MONEY PORTION OF A JUDGMENT INVOLVING A RESIDENTIAL LEASE,THE PARTY HAS 30 DAYS AFTER THE DATE OF ENTRY OF JUDGMENT IN WHICH TO FILE A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTS OF THE COURT OF COMMON PLEAS,CIVIL DIVISION. THE PARTY FILING AN APPEAL MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH THE 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. MDJS 315A Page 1 of 3 Printed:03/05/2013 11:17:35AM t y., James F. Bassett Jr. Docket No.: MJ-09305-LT-0000039-2013 V. Pamela Nawrocki Date Magisterial District Judge Brenda M.Knepper ° certify that this is a true and correct copy of e record of the proceedings containing the judgment. �9-13 2g.�-z' Date Magisterial District Judg F r .2, 9. fvl MDJS 315A Page 2 of 3 Printed:43/05/2413 11:17:35AM James F. Bassett Jr. Docket No.: MJ-09305-LT-0000039-2013 V. Pamela Nawrocki Participant List Private(s) David R. Galloway, Esq. 54 E Main St Mechanicsburg, PA 17055 Plaintiff(s) James F. Bassett Jr. 960 Eppley Road Mechanicsburg, PA 17055 Defendant(s) Pamela Nawrocki 403 West Marble Street Apt C Mechanicsburg, PA 17055 MDJS 315A Page 3 of 3 Printed:03/05/2013 11:17:35AM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES F. BASSETT, JR., Plaintiff CIVIL ACTION - LAW V. NO: ?j — 21or( PAMELA NAWROCKI, c� Defendant NOTICE OF JUDGMENT Notice is hereby given that a Judgment in the above-captioned matter has been entered against you as follows: in the sum of$4,117.04 which consists of$760.49 as Rent in Arrears, $2,688.42 as Unjust Detention, $500.00 as Attorney Fees, plus Magisterial District Justice filing fees of$168.13 and cost$ pf this action. NOW,this day of April, 2013, JUDGMENT lg\NTEfKD A OVE. Pro ary/ er , ivi Division By: Deputy I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Ms. Pamela Nawrocki 237 Pine Grove Road Gardners, PA 17324 R ully submitted, By David R. Gallo y Attorney I.D. 326 David R. Galloway -J t E U-U r ` Y ��: -�}�� �,��-i-�,����� fsh����, Counsel for Plaintiff Attorney I.D. No. 87326 54 E. Main Street 20,13 APR 18 PM 4: 03 Mechanicsburg, PA 17055 Telephone: (717) 697-4650 CUMBERLAND COUNTY IN THE COURT OF COMMON PLEMMMMAND COUNTY,PENNSYLVANIA JAMES F.BASSETT,JR., Plaintiff CIVIL ACTION/-LAW -/ No. V. PAMELA NAWROCKI, Defendant PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of Plaintiff James F. Bassett,Jr. Papers may be served at the address set forth below. Respectfully submitted, David R Galloway, #87326 54 E. Main Street Mechanicsburg,PA 17055 Telephone: (717)697-4650 David R. Galloway Attorney I.D. 87326 Counsel for Plaintiff 54 E. Main St. Mechanicsburg, PA 17055 Telephone: 717-697-4650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES F. BASSETT, JR. : ❑ Confessed Judgment Plaintiff, : © Other : Docket No. 2013-02109 : Judgment Amount: $ 4,117.04 v. : Less Payments: $ 0.00 : Int. from MDJ Judgment: $ 157.69 PAMELA NAWROCKI : Atty's Comm: $ '7 Defen ant. : Costs- Calculated by Proth.: $ 23`7 voe. airorco R (27aa ohs f4y PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: 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. Please issue a 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): Every item of nonexempt tangible personal property on the levied premises, including what is hanging on the walls, contained in the drawers, and stored in the closets, attic, basement, garage(s), and any outbuildings. Respectfully Submitted, 5/ ' zs � 5r-- _ By d -9 Pc/ /� David R. Galloway Attorney I.D. #87326 _rj - Lis ...57) /0/2 fr.3 rn c[1:: 225 bue- t.W C /moo ?I-02.8736 �l�'f ask / sJv WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 2013-2109 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due James F.Bassett,Jr. Plaintiff(s) From Pamela Nawrocki-237 Pine Grove Road,Gardners,PA 17324 (1) You are directed to levy upon the property of the defendant(s)and to sell Every item of nonexempt tangible personal property on the levied premises,including what is hanging on the walls, cotained in the drawers,and stored in the closets,attic,basement,garage(s),and any outbuildings. (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$4,117.04 Plaintiff Paid$ Interest$157.69 Attorney's Comm. % Law Library$.50 Attorney Paid$59.75 Due Prothonotary$2.25 Other Costs$ Date: 10/24/2013 IstAiede: David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : David R. Galloway,Esq. Address: 54 E. Main St. Mechanicsburg,PA 17055 Attorney for: Plaintiff Telephone: 717-697-4650 Supreme Court ID No. 87326 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith .0.0 3idttrttr��t,49 � Chief Deputy = ' , Richard W Stewart w L' Solicitor c�7 � .. James F Bassett, Jr vs. Case Number Pamela Nawrocki 2013-2109 SHERIFF'S RETURN OF SERVICE 11/13/2013 02:40 PM - Ryan Burgett, Deputy, being duly sworn according to law, states that on November 13, 2013 at 2:40 PM hours, served the requested Writ of Execution and Claim for Exemption Form by"personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Pamela Nawrocki at 237 Pine Grove Road, Dickinson Township, Gardners, PA 17324, informed Defendant of contents of same and levied upon personal property as directed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on November 14, 2013. 01/02/2014 Ronny R.Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as STAYED. Defendant paid plaiintiffs attorney directly. SHERIFF COST: $157.36 SO ANSWERS, January 02, 2014 RONR ANDERSON, SHERIFF et 0 5 p i Ll 3b6 6. u,,, :h ,c`• ::-.,. David R. Galloway - Attorney I.D. 87326 Counsel for Plaintiff 54 East Main Street Mechanicsburg, PA 17055 Telephone: (717) 697-4650 PENNS Y'LVA A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES F. BASSETT, JR., • Plaintiff, • • CIVIL ACTION - LAW v. • • DOCKET NO: 2013-2109 PAMELA NAWROCKI, Defendant. • PRAECIPE TO SATISFY TO THE PROTHONOTARY: Please mark the judgment docketed in the above-captioned action as satisfied. Respectfully submitted, By: David R. Galloway :7326 CERTIFICATE OF SERVICE I, David R. Galloway, certify I served a copy of the within Praecipe to Satisfy on this date, upon Defendant by first-class Mail, postage pre-paid, addressed as follows: Ms. Pamela Nawrocki 237 Pine Grove Road Gardners, PA 17324 Res.- submitted, By: Date: January 9 , 2014 David R. Galloway Counsel for Plaintiff