Loading...
HomeMy WebLinkAbout13-2527 =M rn{ - ::u N - C - r Keith O. Brenneman„ Esquire CD 44 West Main Street CeD Mechanicsburg, PA 17055 (717) 697 -8528 Attorney ID #47077 Assistant Solicitor, Cumberland County COMMONWEALTH OF IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA, ex rel. COUNTY CUMBERLAND COUNTY, PENNSYLVANIA OF CUMBERLAND, Plaintiff NO. 2013 — V. CIVIL CIVIL ACTION —LAW DIMITRI ZOZOS, . Defendant Confession of Judgment WARRANT OF ATTORNEY FOR JUDGMENT Pursuant to the authority contained in the warrant of attorney, the original or a copy of which is attached to the Complaint filed in this action, I appear for the Defendant Dimitri Zozos and confess judgment in favor of the Plaintiff and against the Defendant as follows: Principal Balance: $ 1,000.00 Total Due: $1,000.00 BY: l�Zr Keith O. Brenneman, Esquire 44 W. Main Street LAW OFFICES Mechanicsburg, PA 17055 SNELBAKER EC (717) 697 -8528 BRENNEMAN P.C. Date Attorney for Defendant " L337 C= c� _ tT1 M tit C Keith O. Brenneman, Esquire; f ~" 44 West Main Street " Mechanicsburg, PA 17055 (717) 697 -8528 Attorney ID #47077 Assistant Solicitor, Cumberland County COMMONWEALTH OF IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA, ex rel. COUNTY CUMBERLAND COUNTY, PENNSYLVANIA OF CUMBERLAND, Plaintiff NO. 2013 — V. CIVIL ACTION —LAW DIMITRI ZOZOS, Defendant Confession of Judgment COMPLAINT Plaintiff Commonwealth of Pennsylvania, for the use of the County of Cumberland, by its attorney, Keith O. Brenneman, Assistant County Solicitor, files this Complaint as follows: 1. Plaintiff is the Commonwealth of Pennsylvania for the use of Cumberland County, having an address at One Courthouse Square, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Dimitri Zozos, an adult individual with a last known address of 4 Nita Court, Mechanicsburg, Cumberland County, Pennsylvania. 3. Attached hereto and incorporated by reference herein as "Exhibit A" is a true and correct reproduced copy of the original Bail Bond executed by Defendant as surety (the 'Bail Bond "). LAW OFFICES SNELBAKER & BRENNEMAN, P.C. 4. The Bail Bond has not been assigned. 5. Judgment is not being entered by confession by this action against a natural person in connection with a consumer credit transaction. 6. Judgment has not been entered on the Bail Bond in any jurisdiction. 7. Default under the Bail Bond or the occurrence of a condition precedent has taken place in that Matthew Robert Fordyce has failed to appear as required in the criminal matter docketed to Cumberland County CP- 21 -CR- 0494 -2013, thereby resulting in a bench warrant issued for his arrest and forfeiture of bail in the amount of $1,000.00 noted in the Order dated February '25, 2013, a true and correct copy of which Order is attached hereto and incorporated by reference herein as "Exhibit B ". 8. The itemized computation of the amount due consists of the following: Monetary amount of Bail Bond: $1,000.00 Filing and service costs: To be determined WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $1,000 plus costs of this action. SNELBAKER & BRENNEMAN, P. C. BY: Keith O. Brenneman, Esquire 44 W. Main Street Mechanicsburg, PA 17055 (717) 697 -8528 Assistant Solicitor, Cumberland County Date: /rij G, Z °r3 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. -2- `i1. 7013?f1U 2rP!',4 Cii�,�DERL,SNIIU C0UN Y PRISGW � X f¢o, 1119�',Gu�U ii�o. 7446 P. ?N• 011 cu RAIL 300 con, mc),1weahl' of P nr,*VB 'nio V. R L 54575.2 h ?DJ hoc 1�DJ p� a� Data of char£ret; S / � hlo.' S VIDJ Doc}:2t Na; FfJ ! 304 Crc-QaavoBB 2 "$ f�tacfstsrial Dlstdt[ C,�suri OS.S•.6G atfJem�,4d {roes; MEOt ewR66er Fordyca IJc�x C,aurtArtion 5>.75EaziTrindla Pond 15E 8unny5id5 Dr r rziiminary f iesrina Sulte 110 Cariisia,PA 1701 4?LRZOt�1C:Qaam 1"�^ttknikst�u�LPA 'i 7C5p f17- 6$7.2205 - LEA: OFp�hdSB Al Retail Theft Mdse AMMONAL LrikRG SAY rzy PLEASE :-E A,DIpITioP. /.- HARGES PAGE TYPF_IS) OF r = LEASE: cn a6dltional pag .* ® ROF. []. `JnesGarad Ball [] Non Ror tsy Gattdf at�(a1 (e_ tksninal Bel{ hlabratary Ca Iticr�s) in the anourt os 31,0GO,db TIriE GONDITIC)NS 01 rHis BAIL BOND A-r AS FOLLIIthCs t. The defandant muatappeW r; { all 0M 65 requlmd unfit full and final disposition of the case(s). 2, The eefennam rnw oli*Y all tullher.oeders of the bail authority. g, '1�,s defendant muse provido $ cu�,ant address and must QiY6 vt r= notic� to 4he bail aumacity, the clerk of courts, tits dlsErt4 a(komey, and the craurf bail agency or otherdeSignatei court b8il0MCK of any Chehge of addrsss wi hln 6s hours of the date of the change �. The defendant must n2tthcr a. not cava$ to be d6hs, nor pernfi ro be done on his or her beha�, any cam: as Pmsc �*"ee by Sactlan d dS2 of tha Crimes cmie (relrgjN to irrtimidaflwn of wnhaesaa or vintlms) or by S9cl;on 8a3 {rafting fp ra ilatlpn agalr�t vJitness s a vlCeitr.$). S6 Pa-LS. § ds!i2, 4953, 5. The aefondaw must refrain from criminal ac6v ty. 6, The defendant mu6t rtamply with any fingerprint order if any i3 i:S by fltle ooutk I var ify that the above conditions of bBll have been imprsed Data T��ES OF SECURITY: Q Cast�quivatant "� G+sv't Bearar 8on8 [� Realty ttj�tn Gammonwaalth 1 !0 Cash [] .Surety Bond [] kp -alry aumide Comrnonxe�ILh TOTAL AMOUNT BAIL SET PF ANY); 57.000.4 (900 "1"01102 pago) BAIL DaPOSITOR(S) Depasttor Nam-- F1ftloUYtt This bond is valid for the ankh$ Rro:esdings End untif full and final cfmposition of the case inoludin@ all avanue" of dlract appeal to the $Opp - ,rrg Courl of Pennsylvania, l f.GP TiiAT t V6LL APFtr --AZ kT ALL sUaSzQU�ENT PRWE-rMINOiS AS REQUIRED A.F?D coMpLY WLTH ALL THE GONDMONS of 7HE TICS BOND VGMFC 3 ON at,a Penney4k�nia '� ' ignature of Defendant SigneFture of Wftness Dercroaryt'S t edrass: REE - T RUE - O M (5utt�) III ICSWIE Ony whereof. I het'-, iimin c-:a1 i rl and ti e seal of said Court at Gad isle, A. This a ""Gay of Y b 20.E Clerk of The C, f' l pt EASE SEE ATTACHED PAGES FOR ADO€T OW1 jRpo.; tI TION, Cumberland County Printed: Q2l� 412(213 � 55:39?Plt NtDJS 4 14 Reoo ived lime F 6. 11, 2013 6 :09PM Igo. 2904 EXHIBIT A FEB 11, 2013)E10,23PY1 CUMBFRLAf'ID COUNTY PRiKN AX P!p 1I1iiCI:il"U6t ht 4t6 P. I` ,Tu SUPF ElTtfl°ORNIII.A T IC) i "` rron ealtk ' t o �f�il5i.... �4m H� c. i bi �`oC'.n5 }�VPriia v_ � CST( , : L 764575.2 MDLj Nal Nt� t}� 3 U UeCe eF C'r arge5 a2n 572Q ; 3 GCNo,: SIL2P4302a13 MCJ QodstNb; IJ{1Q30e•GnpOpDD6� nef Name'Addrssa: Ma [thaw Robert FordycL WF't (o=t A;16m �a tieserlat �ittr c Court a9 3 -p4 3b Sunriyalde Dr }Preliminary Hs6ring 6275 Eeat T ;hd1z Noad Carlisle, PA 77093 0 =w4DI31p:DDam fiuttelio Madisnics burg, PA 1705D 717 - 697-7201 ?, L) t G 1�� ( �f7�C d� the Q11deralgned surety, have pond security In the amount of t i'YPES GtF SECU€ZiT1': [] CasiYYcglti�al<nf � �ov4 l3aar�r 4ohd(�) � Reat`y+rv'llr, Gnn,manx+salth [] -- ;Cash Surs'y Band Fealty outatda Cornmonweah r � - I have read this information, and t acknowledge that i, ray personal representatives, successors, heir€ and asaigtts are jointly and severally bound whh Mattiaaw Robert Fordyce and any other sureties to pay to te Gommonwealth of Pennsylvania fhe sum of $1,000. , wtr th is the full amount of the Mnetary condkicnn of release I, the event the ball bond is forfeited. I understand that when a monetary condition of release Is imposed, If Matthew Robert Fordyce appears at all timat required by the court and satisfies %ll the other conditions set iorih in the bail bond, than upon full and final disposition of ti,a Casa, this bond shall he vold. I, Matthew Robert Fordyce calls to appear as r &qulr6d or to comply with the cGridllons of {kre bail bond, ev1 this bore shall remain in full force, and the full sum of the monetary condition of ralaase rrmy he forfeited,. Matthew. Ra�ert Fordyce relr.sse may b e revflked, and a warrant for Matthew Reobert Fordyce arrest. may bd iesu-& WAftRANT OF ATTOIRNEY: REC(QGhlITJH�3 THAT I AM WAIVING CERTAIN IMPORTANT IJGY4TS, INCLUDING THE RIGHT OF PRE.f OGMENT NOTICE AND KEARING, fn a=rdance with the law, I do hereby empower any attorney of any cour, of record vAlhin the Commornwealth of Pennsylvanle or elsewhere to appear for ms at any time, and with OF vrithotr. de<clsratlpns filed, and whwthtr or not Matthew Robert Fordyce be in default, to confess judgment againKrnLe, end in favor of the Cemmonveealth of Rennsylvanin far use of the county, and its assigns, during any term ar session of a court of record of the county for the full amount of tf,e monetary oondltlon of release set forth on tine iirst page of this bell bond, and costs. I unde stand that any real estate which I have posted es security, In this case may be levied upon bo blteet i<ha amount confessed. I waive ana releasa any right of inquisition on that real estate, voluntedly candemrr It; and authorize the Prothonotary, upon a Wrh d Ex�cutlon, to enter my vgluntary condemnation, f also agree that any real estate posted by me in this case may b& sold an a Writ af'Execution_ I hereby forever wawa and release any and all errors which m arise in any proceeding to confess judgment in this rase, waive an rights of stay of execution, and waive all laws now in force or laws pessed in the future which exempt real of personal property from execution Since a copy of the ball bond and warrant of attomby is baing filed in the defendants case, it shall not be necessary to file the criglnal as a warrAtlt of attorney, notwithstandtnq any law or rate of coot to the contrary. t, verify that the f5ots set fotth in this forrn are true and correct to the best of my knowledge, information and ballsf. This statement is made subject to the penalties of Section 404 of the Crimes Cade (1 & Pa.C.S. Section 4K4) relating to unswom falsific t ron to authorities. (Signature of Defendant or Sure (Addres° f s ty, Sute3ty Cornpany or Qefandant) (Witness! Ball Authority) ° Refund of all bail Mass any ball related fees or commisslans allowed bylaw and reasonable casts, if any, of administering the percentage cash ball program) vt'ill be made within 2D days attar full and final disposition (Pa- R.GrIm.P. 6357, ° B i1g Gash Bail Receipt to Clark of Courts or Issuing Authority. A TRLl ,GPI r ;C': :' :) :; , In Testi no I � , y 1'Ph_ rC.J!, ! il_•:. Uf ?iv ,'_ i 'iy i': ter: and the seat ol said Court ai Cali is le, P.a. This b , day of )- A k -,Jj 20-L—� MaM414A5 _, ✓ � � ed.Q7Jt E!�?013 6 PM Receit'ed Time Ft6. 11. 2013 6:09PM No. 2904 Cler ;oT��Court i Cumberland County COMiViON- \WEALTH IN THE COURT OF COMI\4ON PLEAS OF CU? =P -L_4ND COUNTY, PENNSYLVANIA VS. CP- 21 -CR- 0494-2013 MAT. THEW ROBERT FORDYCE ORDER AND NOW, this 2 S ` day of February, 2013, a bench warrant is issued for the arrest of the defendant and his production for arrai,=, ient. Bail in the amount of $1,000.00 is forfeited. BY THE COURT, Kevin Hess, P. J. / Office of District Attorney Matthew Robert Fordyce 136 S=yside Drive Carlisle, PA 17013 Sheriff Court Administrator = :rlm A TRUE COPY FP;.) RECD In Testimony whereof, I here unto set rn: hur;d and the se-al of said Court at CaJis!e, PA. � ;---�� This 2b t " d ayof maw 20 V 3.14 1 EXHIBIT B Clerk of tine Co�irt Cuniderlar,d county C i VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Barbara B. Cross, Chairman Cumberland County Board of Commissioners Date: Yvl 2 3 LAW OFFICES SNELBAKER & BRENNEMAN. P.C. G CD c-, ... : CD Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055 (717) 697 -8528 Attorney ID #47077 Assistant Solicitor, Cumberland County COMMONWEALTH OF IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA, ex rel. COUNTY CUMBERLAND COUNTY, PENNSYLVANIA OF CUMBERLAND, Plaintiff NO. 2013 — 5�� G ov V. CIVIL ACTION —LAW DIMITRI ZOZOS, Defendant Confession of Judgment NOTICE UNDER RULE 2958.1 OF JUDGMENT AND EXECUTION THEREOF NOTICE OF DEFENDANT'S RIGHTS TO: DIMITRI ZOZOS, Defendant A judgment in the amount of $1,000.00 has been entered against you and in favor of the plaintiff without any prior notice or hearing based on a confession of judgment contained in a written agreement or other paper allegedly signed by you. The sheriff may take your money or other property to pay the judgment at any time after thirty (30) days after the date on which this notice is served on you. You may have legal rights to defeat the judgment or to prevent your money or property from being taken. LAW OFFICES SNELBAKER & BRENNEMAN, P.C. YOU MUST FILE.A PETITION SEEKING RELIEF FROM THE JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, Pennsylvania 17013 -3302 (717) 249 -3166 By: Keith O. Brenneman, Esquire Snelbaker & Brenneman, P. C. 44 W. Main Street Mechanicsburg, PA 17055 (717) 697 -8528 Assistant Solicitor, Cumberland County -2- LAW OFFICES - - - SNELBAKER & BRENNEMAN, P.G. Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055 (717) 697 -8528 Attorney ID #47077 Assistant Solicitor, Cumberland County COMMONWEALTH OF IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA, ex rel. COUNTY CUMBERLAND COUNTY, PENNSYLVANIA OF CUMBERLAND, Plaintiff _ NO. 2013- 5�7Gc`v�� V. CIVIL ACTION —LAW DIMITRI ZOZOS, Defendant Confession of Judgment NOTICE OF ENTRY OF JUDGMENT PURSUANT TO Pa.R.C.P. 236 NOTICE is hereby given that a judgment in the above - captioned matter was entered against you on May , 2013. PROTHON TAR By. (Deputy) Prothonotary If you have any questions concerning the above, please contact: Keith O. Brenneman, Esquire Snelbaker & Brenneman, P. C. 44 W. Main Street Mechanicsburg, PA 17055 LAW OFFICES (717) 697 -8528 SNELBAKER & Assistant Solicitor, Cumberland County BRENNEMAN, F.C. SHERIFF'S OFFICE OF CUMBERLAN-p (Cp Ronny R Anderson Sheriff Jody S Smith Chief Deputy 'U MBERLAND COUNTY Richard W Stewart ASIA Solicitor EQFT� SVERIr= ' P 1 Commonwealth of Pennsylvania, ex rel. County of Cumberland Case Number vs. Dimitri Zozos 2013-2527 SHERIFF'S RETURN OF SERVICE 0512012013 03:48 PM-Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint for Confession of Judgment,Warrant of Attorney for Judgment, Notice of Entry of Judgment and Notice under Pa.R.C,P. 2958.1 by handing a true copy to a person representing themselves to be Rhea Karvangelos, daughter of defendant,who accepted as"Adult Person in Charge"for Dimitri Zozos at 4 Nita Court, Silver Spring, Mechanicsburg, PA 17070, RYAN BURGETT, DEPUTY---' SHERIFF COST: $39.76 SO ANSWERS, r� May 24, 2013 RON R ANDERSON, SHERIFF (.0 CountySuite Sheriff,Teleocoft.Inc. THE ?_013M Y -9 PM 12,' 22" CUMBERLAND U)Urin­v PENNSYLVANIA Keith O. Brenneman, Esquire 44 West Main Street I echanicsburg,PA 17055 vi (717)697-95228 Attorney ID#47077 'apH County Assistant Solicitor, Cumbei COMMONWEALTH OF IN THE-C'GURT OF COMMON PLEAS OF PENNSYLVANIA, ex rel. COUNTY CUMBERLAND CINTY, PENNSYLVANIA OF CUMBERLAND, Plaintiff NO. 2013 —2527 V. CIVIL ACTION— LAW DIMITRI ZOZOS, Defendant Confession of Judgment PRAECIPE To the Prothonotary: Please mark the judgment entered in the above matter satisfied as having been entered in error. Date: May 9, 2013 By:__ Keith O. Brenneman, Esquire Snelbaker& Brenneman, P. C. 44 W. Main Street Mechanicsburg, PA 17055 (717) 697-8528 Assistant Solicitor, Cumberland County LAW OFFICES SNELBAKER& BRENNEMAN, P.C.