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HomeMy WebLinkAbout14-0238 } PRO t JAS 1 FP' 2: 53 PENNSYLVANIA r� Steven M. Montresor Attorney ID Number 74244 Latsha Davis & McKenna, P.C. 1700 Bent Creek Boulevard, Suite 140 Mechanicsburg, PA 17050 Telephone: (717) 620 -2424 Facsimile: (717) 620 -2444 Attorneys for Plaintiff, Claremont Nursing and smontresor @ldylaw.com Rehabilitation Center IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CLAREMONT NURSING AND REHABILITATION CENTER, Plaintiff �@ V. No. �� V ALICE M. KOWATCH and GARY KOWATCH, Defendant PRAECIPE FOR ENTRY OF APPEARANCE AND TRANSFER OF JUDGMENT TO THE PROTHONOTARY: Kindly enter our appearance on behalf of Plaintiff, Claremont Nursing and Rehabilitation Center, in the above matter; and enter judgment in favor of Plaintiff Claremont Nursing and Rehabilitation Center and against Defendants Alice M. Kowatch and Gary Kowatch in accordance with the attached certification of judgment of Docket No. MJ- 09201 -CV- 0000063 -2013 of Ci 3432870 VV� Al Y Magisterial District Court No. MDJ- 09 -2 -01, the Honorable Paul M. Fegley, and index the judgment against Defendant in the amount of $4,768.50. Pursuant to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, I verify that: 1. the precise address of Plaintiff is Claremont Nursing and Rehabilitation Center, 1000 Claremont Road, Carlisle, Pennsylvania, 17013; 2. the precise last known address of Alice M. Kowatch, Defendant is 1000 Claremont Road, Carlisle, Pennsylvania, 17013; 3. the precise last known address of Gary Kowatch, Defendant is 1901 Sawmill Court, Frederick, Maryland 21702; 4. that said judgment was entered in the said jurisdiction in said amount with costs and interest due as noted, no part of which has been paid (except as noted) and which is valid, enforceable and unsatisfied; and 5. that Defendants are over 18 years of age and not in the military service of the United States or its allies or otherwise within coverage of the Soldiers and Sailors Relief Act of 1940, as amended, and has a civilian occupation. Respectfully submitted, LATSHA DAVIS & McKENNA, P.C. Date: By: / Steven M. Montresor Attorney I.D. No. 74244 1700 Bent Creek Boulevard, Suite 140 Mechanicsburg, PA 17050 Phone: (717) 620 -2424 Fax: (717) 620 -2444 Attorneys for Plaintiff, Claremont Nursing and Rehabilitation Center 343287v1 2 r V-1 t COMMONWEALTH OF PENNSYLVANIA Notice Of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case M Mag. Dist. No: MDJ- 09 -2 -01 Claremont Nursing & Rehab Ctr MDJ Name: Honorable Paul M Fegley V. Address: 2260 Spring Road Suite 3 Alice M Kowatch, Gary Kowatch Carlisle, PA 17013 Telephone: 717- 218 -5250 Claremont Nursing & Rehab Ctr Docket No: MJ- 09201 -CV- 0000063 -2013 1000 Claremont Rd Case Filed: 7/8/2013 Carlisle, PA 17013 Disposition Summary (CC - cross compiaint) �— - Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09201 -CV- 0000063 -2013 Claremont Nursing & Rehab Ctr Alice M Kowatch Default Judgment for Plaintiff 11/19/2013 MJ- 09201 -CV- 0000063 -2013 Claremont Nursing & Rehab Ctr Gary Kowatch Default Judgment for Plaintiff 11/19/2013 Judgment Summary Participant Joint/Several Liability Individual Liability Amoun Alice M Kowatch $4,768.50 $0.00 $4,768.50 - Claremont Nursing & Rehab Ctr $0.00 $0.00 $0.00 Gary Kowatch $4,768.50 $0.00 $4,768.50 Judgment Finding ( *Post Judgment) In the matter of Claremont Nursing & Rehab Ctr vs. Alice M Kowatch; Gary Kowatch on MJ- 09201 -CV- 0000063 -2013, on 11/19/2013 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $4,540.00 $0.00 $4,540.00 " Costs $228.50 $0.00 $228.50 Grand Total: $4,768.50 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 COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR 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. ll 4�3 Date Magisterial District Judge Paul certify that this is a true and correct copy of the record of the proceed i ming t o /u gment � 1 -- eGu "-\ N�Z� I Date Magisterial Dist ict Judge MDJS 315 Page 1 of 2 Printed: 01/03/2014 12:27:43PM Claremont Nursing & Rehab Ctr Docket No.: MJ- 09201 -CV- 0000063 -2013 V. Alice M Kowatch, Gary Kowatch 'r PRO 186�j 0 TAR Participant List CUR �'n 2: AAFO CO, 53 V,gPI Y Plaintiff(s) Claremont Nursing & Rehab Ctr 1000 Claremont Rd Carlisle, PA 17013 Defendant(s) Alice M Kowatch 1000 Claremont Road Carlisle, PA 17013 Gary Kowatch 1901 Sawmill Court Frederick, MD 21702 MDJS 315 Page 2 of 2 Printed: 01/03/2014 12:27:43PM IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CLAREMONT NURSING AND REHABILITATION CENTER, Plaintiff V. No. �T3 ALICE M. KOWATCH and GARY KOWATCH, Defendant RULE 236 NOTICE OF ENTRY OF JUDGMENT TO: Alice M. Kowatch 1000 Claremont Road Carlisle, PA 17013 AND NOW THIS day of , 2014, pursuant to Pa.R.C.P. 236 of the Supreme Court of Pennsylvania you are hereby notified that Judgment by Transfer from Magisterial District Court No. MDJ 09 -2 -01 in the Commonwealth of Pennsylvania, County of Cumberland in the amount of $4,768.50 has been entered in favor of the Plaintiff, CLAREMONT NURSING AND REHABILITATION CENTER, and against Defendant, ALICE M. KOWATCH. The following parties are entitled to receive notice under Pa. R.C.P. 236(a)(2). Alice M. Kowatch 1000 Claremont Road Carlisle, PA 17013 IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL LATSHA DAVIS & McKENNA, P.C. at this telephone number: (717) 620 -2424. Prothonotary 343287v1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CLAREMONT NURSING AND REHABILITATION CENTER, Plaintiff V. No. ALICE M. KOWATCH and GARY KOWATCH, Defendant RULE 236 NOTICE OF ENTRY OF JUDGMENT TO: Gary Kowatch 1901 Sawmill Court Frederick, MD 21702 AND NOW THIS _ day f 2014 pursuant o y , p t t Pa.R.C.P. 236 of the Supreme Court of Pennsylvania you are hereby notified that Judgment by Transfer from Magisterial District Court No. MDJ 09 -2 -01 in the Commonwealth of Pennsylvania, County of Cumberland in the amount of $4,768.50 has been entered in favor of the Plaintiff, CLAREMONT NURSING AND REHABILITATION CENTER, and against Defendant, GARY KOWATCH. The following parties are entitled to receive notice under Pa. R.C.P. 236(a)(2). Gary Kowatch 1901 Sawmill Court Frederick, MD 21702 IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL LATSHA DAVIS & McKENNA, P.C. at this telephone number: (717) 620 -2424. Prothonotary 343287v1