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Home My WebLink About13-2458 IF IL O-C)r OF THIL PROTHONOTARY 2013 ill Y --3 Pm 2:. 4�► CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CLEVELAND BROTHERS EQUIPMENT CIVIL DIVISION COMPANY, - Plaintiff, No. vs. TYPE OF PLEADING: COMPLETE PROPERTY SERVICES LLC and JUSTIN CRIDER a/lda JUSTIN D. CRIDER, Defendants. PRAECIPE FOR ENTRY OF JUDGMENT PURSUANT TO CERTIFICATION OF DOCKET ENTRIES FILED ON BEHALF OF: CLEVELAND BROTHERS EQUIPMENT COMPANY, PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: Donald L. Phillips, Esquire PA I.D. #01339 Ann E. L. Shapiro, Esquire PA I.D. #35166 Donald L. Phillips, P.C. Suite 800, Lawyers Building 428 Forbes Avenue Pittsburgh, PA 15219 (412) 281 -1977 Attorneys' Firm I.D. #0327 , *33 c4t H 30y . �jo� rt•le. ? *a 9 W 33 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CLEVELAND BROTHERS EQUIPMENT ) COMPANY, ) Plaintiff, ) vs. No. COMPLETE PROPERTY SERVICES LLC ) and JUSTIN CRIDER a/k/a JUSTIN D/ CRIDER ) Defendants. ) PRAECIPE FOR ENTRY OF JUDGMENT PURSUANT TO CERTIFICATION OF DOCKET ENTRIES TO: PROTHONOTARY OF CUMBERLAND COUNTY Pursuant to the attached Certification of Docket Entries entered in Allegheny County, please enter judgment on behalf of the Plaintiff, Cleveland Brothers Equipment Company, and against the Defendant, Complete Property Services and Justin Crider a/k/a Justin D. Crider, individually, jointly and severally, in the amount of $11,471.26. DONALD L. PHILLIPS, P.C. Donald L Phillips, Esquire Attorney for Plaintiff Q EXEMPLIFICATION OF RECORD Commonwealth of Pennsylvania, > Set. Allegheny County > Among the Records and Proceedings of the COMMON PLEAS Court in and for the County of Allegheny, and State of Pennsylvania, the Following may be found as matter of File and of Record at No. AR- 12- 004079 DOCKET ENTRY CLEVELAND BROTHERS EQUIPMENT CO., INC. VS SEE ATTACHED SHEETS COMPLETE PROPERTY SERVICES LLC, and JUSTIN CRIDER a /k/a JUSTIN D. CRIDER THE COMMONWEALTH OF PENNSYLVANIA Commonwealth of Pennsylvania ) County of Allegheny ) ss: I, Kate Barkman, Director, Department of Court Records in and for said County and Commonwealth, certify that the foregoing is a full and correct copy of the whole record of the case therein stated, wherein CLEVELAND BROTHERS EQUIPMENT CO., INC, VS COMPLETE PROPERTY SERVICES LLC and JUSTIN CRIDER a/k/a JUSTIN D. CRIDER As the same remains of record before the said Court at No. GD -12- 014539 In testimony whereof, I have hereunto set my hand and affixed this seal, Director A. ANDREWS Clerk Commonwealth of Pennsylvania ) County of Allegheny ) ss: I, Donna Jo McDaniel, President Judge of the Court of Common Pleas in and for said County, certify that Kate Barkman, by whom the above attestation was made, was at the date thereof Director, Department of Court Records of said Court, duly qualified; and the said attestation is in due form of the law and made by the proper officer. Witness my hand and seal, the 18th day of APRIL J X 20 13 President Judge Commonwealth of Pennsylvania ) County of Allegheny ) ss: I, Kate Barkman, Director, Department Court Records, for the Court of Common Pleas for said County, certify that the Honorable Donna Jo McDaniel, President Judge, by whom the above certification was given and whose name is thereby subscribed in her own proper handwriting, was at the date thereof, President Judge of the said Court, duly commissioned, sworn and acting. In witness whereof, I have hereunto set my hand and affixed this seal, Director A. AND Clerk Page 1 of 2 AR -12-004079 No. CLEVELAND BROTHERS EQUIPMENT CO., INC. vs COMPLETE PROPERTY SERVICES LLC, and JUSTIN CRIDER a/k/a JUSTIN D. CRIDER EXEMPLIFICATION OF RECORD At No. AR -12- 00 from the Court of Common Pleas, in and for the County of Allegheny, Pennsylvania DEBT $ 11,471.26 { INTEREST FROM ALLEGHENY COUNTY COSTS $433.50 1 ' - THIS RECORD $20.00 w . DONALD L. PHILLIPS, ESQUIR ATTORNEY FOR PLAINTIFF Page 2 of 2 Home Allegheny County - Department of Court Records Civil /Family Division Docket Report AR -12- 004079 Cleveland Brothers Equipment vs Complete Property Run Date: 04/18/2013 Run Time: 11:41:58 AM Court Type: Arbitration Case Type: Contract - Debt Collection Related Cases: Judge: No Judge Jury Requested: No Current Status: Exemplification of Record - Out Amount In Dispute: $ 8193.78 Pa rties -- Litigants -- ID I LName jAddress Phone Attorney Cleveland Brothers E hay liam Penn Phillips @1462515 Equipment Company - -- - -- Plaintiff Murrysville PA -- Donald L, Inc. @1909706 Compl ete Property Defendant No Default Address ❑� Services LL C Available @1909707 Crider Justin Defendant No Default Address Available -- Attorney -- ID LName FName MI Type Address Phone 01339 Phillips Donald L� Plaintiff's Suite 800 Lawyers Building 428 Forbes Avenue 428 1[ 12811977 412) Attorney Forbes Avenue Pittsburgh PA 15219 -- Non Litigants -- ID LName FName MI Typ Address Phone ARBC Arbitration Arbitration 414 Grant Street Courtroom 2 7th Floor Center I L11 1 center Pittsburgh PA 15219 -- Alternative Names J ID Name Alternative Name @1909707 Crider Justin Crider aka Justin D. Docket Entries Filing Docket Type Docket Text Filing Party Date �� Cleveland I ' y Count #1: $8,193.78. Plus costs /attorney fees. Hearing Brothers 06/29/2012 Complaint date 10/04/12. Equipment Company Inc. Cleveland 08/24/2012 Praecipe to complaint Brothers Reinstate Equipment Company Inc. Dated 08/24/12. Petioner /Plaintiff may serve Cleveland 08/27/2012 Petition & Order Respondent/Defendant by sending a copy of the Brothers reinstated Complaint as well as all subsquent pleadings Equipment and notices as specified copies mailed 8/27 Wettick,J Company Inc. CONTINUED - Arbitration Center 09/21/2012 DEFT. NOT SERVED of Reinstated Complaint and Notice of Suit on Defendants Cleveland 09/28/2012 Affidavit of Service on 08/31/2012 upon Defendants by regular with certificate Brothers of mailing on 08/31/2012. Equipment Company Inc. Cleveland 10/02/2012 Bill of Costs Brothers Equipment Company Inc. In default of an answer in the amount of $11471.26. Cleveland 10/02/2012 Default Judgment Certification of mailing of 10 day notice on 9/21/12 upon Brothers (Complete Property Services). Notice of judgment sent. Equipment Company Inc. 10/17/2012 Letter Exemplification ordered on 10/04/2012. Exemplification Phillips Donald L completed and phoned on 10/17/2012. Cleveland 01/08/2013 Bill of Costs Brothers Equipment Company Inc. Cleveland 04/16/2013 Exemplification of Brothers Record - Out Equipment Company Inc. Judgment Against ID Type Name I Amount I Satisfied Docket Filing Date @1909707 Defendant Crider Justin 11471.26 N� Default Judgment 10/02/2012 F@1 9097061pjfendant J Complete Property Servic:es7L:L:C Default Judgment 10/02/2012 Judgment For ID Type Name Amount Docket I it�g Date @1462515 Plaintiff Cleveland Brothers Equipment Company Inc. 11471.26 Default Judgment 10/02/2012 Event Schedule (Event Scheduled IlEvent Date Arbitration Hearing 10/4/2012 1, 4 IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA CLEVELAND BROTHERS EQUIPMENT ARBITRATION DIVISION CO., INC., No. AR12- 004079 Plaintiff, Q TYPE OF PLEADING: vs. PRAECIPE FOR DEFAULT COMPLETE PROPERTY SERVICES LLC, JUDGMENT and JUSTIN CRIDER a/k/a JUSTIN D. CRIDER, FILED ON BEHALF OF: Defendants. PLAINTIFF, CLEVELAND BROTHERS EQUIPMENT CO., INC. COUNSEL OF RECORD FOR THIS PARTY: Donald L. Phillips, Esquire PA I.D. 401339 Ann E. L. Shapiro, Esquire ll, N PA I.D. #35166 J Donald L. Phillips, P.C. Suite 800, Lawyer Building 428 Forbes Avenue536I612629 Pittsburgh, PA 152 �jp.o�) -2012 04 :20:33 (412) 281 -1977 Attorneys' Firm 1. id3 , I IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA ARBITRATION DIVISION CLEVELAND BROTHERS EQUIPMENT ) CO., INC., ) Plaintiff, ) vs. ) No. AR12- 004079 COMPLETE PROPERTY SERVICES LLC, ) and JUSTIN CRIDER a/k/a JUSTIN D. ) CRIDER, ) Defendants. ) E PRAECIPE FOR DEFAULT JUDGMENT TO: COURT RECORDS CIVIL DIVISION F Enter judgment against the above named Defendants, Complete Property Services LLC, and Justin Crider a/k/a Justin D. Crider, individually, jointly and severally, in the amount of $11,471.26 plus court costs, liquidated as follows: Amount claimed in Complaint $ 8,193.78 . Plus monthly service charges at 1.5% per month from January 31, 2012 991.48 E SUBTOTAL $ 9,185.26 f 20% attorney's fees per written i agreement of Defendants 1,837.05 SUBTOTAL $11,022.31 Costs of record including = ` entry of judgment 448.95 ? TOTAL JUDGMENT $11,471.26 DONALD L. PHILLIPS, P.C. i Donald L. Phillips, Esquire G Attorney for Plaintiff j r IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA ARBITRATION DIVISION CLEVELAND BROTHERS EQUIPMENT ) E CO., INC., ) Plaintiff, ) t vs. ) No. AR12- 004079 COMPLETE PROPERTY SERVICES LLC, ) and JUSTIN CRIDER a/k/a JUSTIN D. ) CRIDER, ) i Defendants. ) TO: COMPLETE PROPERTY SERVICES LLC 805 Marshall Drive Carlisle, PA 17013 DATE OF NOTICE: September 21, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP; i LAWYER REFERRAL SERVICE The Allegheny County Bar Association 11 " Floor - Koppers Building, 436 Seventh Avenue Pittsburgh, Pennsylvania 1.5219 F ' Telephone: (412) 261 -5555 /s/ Donald L. Phillips E Donald L. Phillips, Esquire Donald L. Phillips, P,C. Suite 800, Lawyers Building I 428 Forbes Avenue Pittsburgh, PA 15219 t (412) 281 -1977 f IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA ARBITRATION DIVISION CLEVELAND BROTHERS EQUIPMENT ) CO., INC., ) ) Plaintiff, ) } vs. ) No. AR 12-004079 COMPLETE PROPERTY SERVICES LLC, ) and JUSTIN CRIDER a/k/a JUSTIN D. ) CRIDER, } Defendants. ) TO: JUSTIN CRIDER a/k/a JUSTIN D. CRIDER 805 Marshall Drive Carlisle, PA 17013 DATE OF NOTICE: September 21, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERRAL SERVICE The Allegheny County Bar Association 11`h Floor - Koppers Building, 436 Seventh Avenue Pittsburgh, Pennsylvania 15219 Telephone: (412) 261 -5555 /s/ Donald L. Phillips Donald L. Phillips, Esquire Donald L. Phillips, P.C. Suite 800, Lawyers Building 428 Forbes Avenue Pittsburgh, PA 15219 (412) 281 -1977 IN THE COURT,OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA ARBITRATION .DIVISION CLEVELAND BROTHERS EQUIPMENT ) CO., INC., ) Plaintiff, ) i vs. ) No. A.R12- 004079 COMPLETE PROPERTY SERVICES LLC, ) and JUSTIN CRIDER a/k/a JUSTIN D. ) CRIDER, ) Defendants. ) i VERIFICATION OF NON - MILITARY SERVICE ` 1, Donald L. Phillips, on advice and belief hereby swear or affirm that the above named Defendant(s) is /are not presently in the active military service of the United States of America and that they are not members of the Army of the United States, United States Navy, the Marine Corps, or the Coast Guard, and are not officers of the Public Health Service detailed by proper authority for duty with the Army or Navy; nor are they engaged in any active military service or active military duty with any military or naval units covered by the Soldiers and Sailors Civil Relief Act of 1940 as designated therein as military service, nor has either of them, to the best of my knowledge, enlisted in military service covered by this act that the averments herein set forth, insofar as they are within my knowledge are correct, and true; and insofar as they are based on information received from others, are true and correct, and I verily believe. This Verification is made under the provisions of the Soldiers and Sailors Civil Relief Act of 1940. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Donald L. Phillips, Esquire Attorney for Plaintiff i i I f IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA ARBITRATION DIVISION CLEVELAND BROTHERS EQUIPMENT ) CO., INC., ) Plaintiff, ) vs. ) No. AR12- 004079 COMPLETE PROPERTY SERVICES LLC, ) and JUSTIN CRIDER a/k/a JUSTIN D. ) CRIDER, ) Defendants. ) CERTIFICATION OF ADDRESSES I certify that the address of the plaintiff - creditor is as follows: 4 CLEVELAND BROTHERS EQUIPM=ENT CO., INC. c/o DONALD L. PHILLIPS, P.C. Suite 800, Lawyers Building 428 Forbes Avenue Pittsburgh, PA 15219 and that the name(s) and address(es) of all parties entitled to notice of entry of judgment is /are as follows: COMPLETE PROPERTY SERVICES LLC 805 Marshall Drive Carlisle, PA 17013 JUSTIN CRIDER a/k/a JUSTIN D. CRIDER 805 Marshall Drive Carlisle, PA 17013 and that on September 21, 2012 notice of intention to file the within Praecipe for Default Judgment in the form required by Pa. R.C.P. 237.1(c) was mailed to the defendant(s) against whom the judgment is to be entered, and to their attorney of record, if any, this notice being sent after the default occurred and at least 10 days prior to date of the filing of this Praecipe for Default Judgment. A copy of the said notice, as mailed, is being filed along with this certification and Praecipe for Default Judgment. j. DONALD L. PHILLIPS, P.C. Donald L. Phillips, Esquire Attorney for Plaintiff- Creditor IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CLEVELAND BROTHERS EQUIPMENT ) COMPANY, ) Plaintiff, ) vs. ) No. ysF COMPLETE PROPERTY SERVICES LLC ) and JUSTIN CRIDER a/k/a JUSTIN D CRIDER ) Defendants. ) VERIFICATION OF NON - MILITARY SERVICE I, Donald L. Phillips, on advice and belief hereby swear or affirm that the above named Defendant(s) is /are not presently in the active military service of the United States of America and that they are not members of the Army of the United States, United States Navy, the Marine Corps, or the Coast Guard, and are not officers of the Public Health Service detailed by proper authority for duty with the Army or Navy; nor are they engaged in any active military service or active military duty with any military or naval units covered by the Soldiers and Sailors Civil Relief Act of 1940 as designated therein as military service, nor has either of them, to the best of my knowledge, enlisted in military service covered by this act that the averments herein set forth, insofar as they are within my knowledge are correct, and true; and insofar as they are based on information received from others, are true and correct, and I verily believe. This Verification is made under the provisions of the Soldiers and Sailors Civil Relief Act of 1940. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Donald L. Phillips, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CLEVELAND BROTHERS EQUIPMENT ) COMPANY, ) Plaintiff, ) vs. ) No. COMPLETE PROPERTY SERVICES LLC ) and JUSTIN CRIDER a/k/a JUSTIN D. CRIDER, ) Defendants. ) CERTIFICATION OF ADDRESSES 1 certify that the address of the plaintiff - creditor is as follows: CLEVELAND BROTHERS EQUIPMENT COMPANY, c/o DONALD L. PHILLIPS, P.C. Suite 800, Lawyers Building 428 Forbes Avenue Pittsburgh, PA 15219 and that the name(s) and address(es) of all parties entitled to notice of entry of judgment is /are as follows: Complete Property Services 805 Marshall Drive Carlisle, PA 17013 Justin Crider a/k/a Justin D. Crider 805 Marshall Drive Carlisle, PA 17013 DONALD L. PHILLIPS, P.C. Donald L. Phillips, Esquire Attorney for Plaintiff - Creditor IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CLEVELAND BROTHERS EQUIPMENT CIVIL DIVISION COMPANY, No. o Plaintiff, rrrico ch vs. ..� w C t— � r TYPE OF PLEADING:, COMPLETE PROPERTY SERVICES D � ,, and JUSTIN CRIDER a/k/a JUSTIN D CRIDER, --i � PLAINTIFF'S BILL OF COSTS Defendants. FILED ON BEHALF OF: CLEVELAND BROTHERS EQUIPMENT COMPANY, PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: Donald L. Phillips, Esquire PA I.D. #01339 Ann E. L. Shapiro, Esquire PA I.D. 935166 Donald L. Phillips, P.C. Suite 800, Lawyers Building 428 Forbes Avenue Pittsburgh, PA 15219 (412) 281 -1977 Attorneys' Firm I.D. #0327 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CLEVELAND BROTHERS EQUIPMENT ) COMPANY, ) Plaintiff, ) / vs. ) No. COMPLETE PROPERTY SERVICES LLC ) and JUSTIN CRIDER a/k/a JUSTIN D CRIDER ) Defendants. ) PLAINTIFF'S BILL OF COSTS Notice of entry of judgment required by Pa. R.C.P. 236 and /or local rule of Court $20.00 TOTAL $20.00 DONALD L. PHILLIPS, P.C. '04� '�. x4 Donald L. Phillips, Esquire Attorney for Plaintiff