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HomeMy WebLinkAbout02-0801Johnson, Duffle, Stewart & Weidner By: Mark C. Duffle I.D. No. 75906 301 Market Street P. O. Box 109 Lcrnoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff ERIN CAREY, Plaintiff V. CHRIS CUSSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA .o. -eol CIVIL ACTION - LAW PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Please transfer and enter judgment according to the Notice of Judgment entered by the Honorable Thomas A. Placey on March 26, 2001, a copy of which is attached hereto, the time for appeal having expired, and assess damages in favor of the Plaintiff and against the Defendant as follows: Amount of Award $4,913.50 Costs $ 118.50 Total $5,032.00 Dated: :153959 Damages assessed as above: //~ Prothonotary (~ - Date: %L~ Respectfully submitted, · JOHNSON, DUFFLE, STEW~IDNER Attorney I.Bb~. 75906 301 Market ~reet P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 Attorneys for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERr,AND Mag. Oist. No,: 09-3-04 DJ Name: Hon. THOMAS A. PLACEY Address: 104 S. SPORTING HILL P,D. MECHANICSBUKG, PA re~eph;,,: (717) 761-8230 17050 ERIN CAREY 1810 NORTH ONION ST MIDDLETOWN, PA 17057 CIVIL CASE PLAINTIFF: NAME and ADDRESS FCAEEY, ERIN NOTICE OF JUDGMENT/TRANSCRIPT 1810 NORTH ONION ST MIDDLETOWN, PA 17057 VS. DEFENDANT: UCUSSON, 6280 CARLISLE PIKE',. LOT 204 ~.tECHANICSBURG, PA 17050 Docket No.: C~. 0000018- 01 Date Filed: 1/08/01 THIS IS TO NOTIFY YOU THAT: Judgment: ~ Judgment was entered for: (Name) ~ Judgment was entered against: (Name) FOR i"".A'~*I~: 'l~'g T'KT in the amount of $ on: Defendants are jointly and severally liable· Damages will be assessed on: . This case dismissed Without PrejudiCe. Amount of Judgment Subject to Attachment/Act 5 of 1996 $ Levy is stayed for days or ~--~ generally stayed. Objection to levy has been filed and hearing will be held: d'rmTS (Date of Judgment) (Dateay!me) .. Amount of Judgment , Judgment Costs Interest on Judgment Attorney Fees Total Post Judgment Credits Post Judgment Costs Certified Judgment Total $ 118:50 $. $ .00 $ 5,032.00 Date: Time: Place: 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 NQ~E OF JUDGI~T~RIPT FORM WITH YOUR NOTICE OF APPEAL. J/~ ~/~ Date. I certify that this is a true ar~ c~e record of the pr~ceedings~ntaining the judgment ~'~/~ ~)/~0/ Dat~"""~-- =' ,, l -/~ / /~ ' District Justice My commission expires first Monday of J~ 200~ SEAL AOPC 315-99 ERIN CAREY CHRIS CUSSON PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 314-9 Etc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Writ No. Term, 20 No. t'5~l_ ~ ?0[ Term, 20 vs. Amount Due .$ 4.913.50 Interest From Attorney's Com. Costs .$ 118.50 TO THE PROTHONOTARY OF SAID COURT: Please issue WRIT OF EXECUTION in the above matter, (1) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) Against Chris Cusson 6280 Carlisle Pike. Lot 204. Mechanicsburg. PA 17055 Defendant (s); (3) ' and against Mellon Bank. 2 W. Main Street. Mechanicsburg. PA 17055 (4) and index this writ (a) against Chris Cusson 6280 Carlisle Pike. Lot 204. Mechanicsburg. PA 17055 Garnishee (s); Defendant (s) and (b) against Mellon Bank. 2 W. Main Street. Mechanicsburg. PA 17055 Garnishee (s), as a lis pendens against the real property of the Defendant (s) in the name of the Garnishee (s) as follows: (Specifically describe property) Real property owned by Defendant, known and numbered as 6280 Carlisle Pike, Lot 204, Mechanicsburg, PA 17055. Levy, attach, and sell all personal property of Defendant at said location, including all furniture, automobiles, electronic equipment, and all other moveable personal property located at 6280 Carlisle Pike, Lot 204, Mechanicsburg, PA. Attach all funds and accounts of the Defendant, CHRIS CUSSON, on deposit with MEI.LON BANK, 2 W. Main Street, Mechanicsburg, Pennsylvania, 17055. Date:(5) Exemption~_ / ~FfO .9._has (not) been waived. ~~''"~ C / '~~ / Attorney f~P~intiff (s) 153961 NOTE Under paragraph (1) when the ~vrit is directed to the sheriff of another county as authorized by Rule 3 103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment maybe directed only to the sheriffof the county in which issued. Paragraph (3) above should be completed only ifa named garnishee is to be included in the writ. Paragraph (4) (a) should be completed only if indexing of the execution in the county of issuance, is desired as authorized by Rule 3104(a). When the writ issues to another county indexing is required as of course in that county by the prothonotary. See Rule 3104(b). Paragraph 4 (b) should be completed only if real property in the name of a garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ERIN CAREY VS. CHRIS CUSSON Plaintiff(s), Defendant(s), VS. MELLON BANK, N.A., Garnishee. writsl No. 02-801 Praecipe for Appearance Code: 200 Execution Filed on Behalf of Garnishee, Mellon Bank, N.A. Counsel of Record for this Party: Daniel S. Bemheim, 3d, Esquire Attorney ID No. 32736 Silverman Bernheim & Vogel Two Penn Center Plaza Suite 910 Philadelphia, PA 19102 (215)-636-4468 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE TO: Office ofthe Prothonota~ One CouAhouse Square CouAhouse Cadisle, PA 17013-3387 Sir: Kindly enter my appearance on behalf of Garnishee, Mellon Bank, N.A. Daniel S. Bernheim, 3d, Esquire Silverman Bemheim & Vogel Two Penn Center Plaza Suite 910 Philadelphia, PA 19102 writsl Certificate of Service I, Daniel S. Bernheim, 3d, hereby certify that a true and correct copy of this Praecipe for Appearance has been served upon the following by depositing it in the U. S. Mail, postage prepaid, this ~ day of ~ ~ ,2002. Mark C Duffie, Esquim 301 Manet Street P OBox 109 Lemoyne PA 17043-0109 Daniel S. Bernheim, 3d, Esquire writsl SHERIFF'S RETURN - GARNISHEE CASE NO: 2002-00801 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND CAREY ERIN VS CUSSON CHRIS And now BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, at 0013:00 Hours, on the 1st day of March , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , CUSSON CHRIS , in the hands, possession, or control of the within named Garnishee MELLON BANK 4101 CARLISLE PIKE CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to MARCY CRANDY (TELLER/ MANAGER) personally 3 true and attested copies of the within WRIT OF EXECUTION and made the contents thereof known to Her . Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 R. Thomas Kj~ne . /] Sheriff of/C~mberlanc] 00 00 0000 By y /~ / /I t/~ _ Dep~ty~S~eri f f / this 7~ day of~/h~ _~:L A.D. Prc~t~onotary So answers: Sworn and subscribed to before me WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-801 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COLrNTY: To satisfy the debt, interest and costs due ERIN CAREY, PLANTIFF(S) From CHRIS CUSSON, 6280 CARLISLE PIKE, LOT 204, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant(s) and to sell LEVY, ATTACH, AND SELL ALL PERSONAL PROPERTY OF DEFENDANT AT SAID LOCATION, INCLUDING ALL FURNITURE, AUTOMOBILES, ELECTRONIC EQUIPMENT AND ALL OTHER MOVEABLE PERSONAL PROPERTY LOCATED AT 6280 CARLISLE PIKE, LOT 204, MECHANICSBURG, PA (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of ATTACH ALL FUNDS AND ACCOUNTS OF THE DEFENDANT, CHRIS CUSSON, ON DEPOSIT WITH MELLON BANK, 2 W. MAIN STREET, MECHANICSBURG, PA 17055 GARNISHEE(S) as follows: and to notify the gamishee(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 aitachment 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 $4,913.50 Interest Atty's Comm % Arty Paid $32.25 Plaintiff Paid Date: FEBRUARY 14, 2002 REQUESTLNG PARTY: Name MARK C. DUFFIE, ESQUIRE Address: 301 MARKET STREET P.O.BOX 109 LEMOYNE, PA 17043-0109 L.L. $.50 Due Prothy $1.00 Other Costs $118.50 CURTIS R. LONG Prothonotary, Civil Division Attorney for: PLAINTIFF Telephone: 717-761-4540 Supreme Court ID No. 75906 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing 18.00 Poundage 2.32 Advertising Law Library .50 Prothonotary 1.00 Mileage 17.96 Misc. Surcharge 30.00 Levy 60.00 Post Pone Sale Garnishee 9.00 118.76 Advance Costs: 150.00 Sheriff's Costs: 118.76 31.26 Refundedto Attyon 10/11/02 Swom and Subscribed to before me this 15~ day of 0e~-.f~ 2002 A.D. (~, t~. ~ tl~~ protffonfoiary So Answers; R. Thomas Kline, Sheriff PRAEC1PE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P. 3101 to 314-9 Etc. ERIN CAREY CHRIS CUSSON VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Writ No. _(20_ - aOO I Term, 20 No. Term, 20 Amount Due ~$ 4,913.50 Interest From Attorney's Com. : Costs $. 118.50 TO THE PROTHONOTARY OF SAID COURT: (1) (2) Chris Cusson Directed to the Sheriff of Against (3) and against (4) and index this writ (a) against Please issue WRIT OF EXECUTION in the above matter, Cumberland County, Pennsylvania; 6280 Carlisle Pike. Lot 204. Mechanicsburg. PA 17055 Chris Cusson 6280 Carlisle Pike. Lot 204. Mechanicsburg. PA 17055 Defendant (s); Garnishee (s); Defendant (s) and (b) against Garnishee (s), as a lis pendens against the real property of the Defendant (s) in the name of the Garnishee (s) as follows: (Specifically describe property) Real property o~vned by Defendant, known and numbered as 6280 Carlisle Pike, Lot 204, Mechanicsburg, PA 17055. Levy, attach, and sell all personal property of Defendant at said location, including all Jhrniture, automobiles, electronic equipment, and all other moveable personal property located at 6280 Carlisle Pike, Lot 204, Mechanicsburg, PA. (5) Date: : 153961 ~2 Exemption has (not) been waived. Attorney for~ltintiff (s) NOTE t Jn der paragraph (1) when the writ is directed to the sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued. Paragraph (3) above should be completed only ifa named garnishee is to be included in the writ. Paragraph (4) (a) should be completed only if indexing of the execution in the county of issuance, is desired as authorized by Rule 3104(a). When the writ issues to another county indexing is required as of course in that county by the prothonotary. See Rule 3104(b). Paragraph 4 (b) should be completed only if real property in the name of a garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c) WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-801 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ERIN CAREY, Plaintiff (s) From CHRIS CUSSON, 6280 CARLISLE PIKE, LOT 204, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY, ATTACH, AND SELL ALL PERSONAL PROPERTY OF DEFENDANT AT SAID LOCATION, INCLUDING ALL FURNITURE, AUTOMOBILES, ELECTRONIC EQUIPMENT, AND ALL OTHER MOVEABLE PERSONAL PROPERTY LOCATED AT 6280 CARLISLE PIKE, LOT 204, MECHANICSBURG, PA. (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 $4,913.50 L.L. Interest Atty's Comm % DueProthy $1.00 AttyPaid $163.51 Other Costs Plaintiff Paid Date: DECEMBER 18, 2002 (Seal) CURTIS R. LONG Prothonot~ Deputy ~ - REQUESTING PARTY: Name MARK C. DUFFIE, ESQUIRE Address: JOHNSON, DUFFIE, STEWART & WEIDNER 301 MARKET STREET P.O.BOX 109 LEMOYNE, PA 17043-0109 Attorney for: PLAINTIFF Telephone: 717-761-4540 Supreme Court ID No. 75906 R. Thomas Kline, Sheriff, who being duly sWorn according to law, states this writ is returned STAYED, DUE TO TCY, no action taken in six months. Sheriff's Costs: Docketing $ 18.00 Poundage 1.12 Advertisivg Law Library Prothonotary 1.00 Mileage 6.90 Misc. Surcharge 30.00 Levy Post Pone Sale Garnishee TOTAL. $ 57.02 Advance Costs: 150.00 Sheriff's Costs: 57.02 92.98 Refunded to Atty on 9/09/03 Sworn and Subscribed to before me this /6 ~ day of ~ 2003 A.D. Proth~t~/~ ~d'g~% ~ So Answers;..