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Home My WebLink About14-1460 t =;! D-01 F r=fC _ _ a i�= f 1'l� ilk P +,li Mli PAR 12 PH i2. 24 CUI McBE-P%LAND COUNTY PENINSYLVANIA John S. Kundrat, Esquire Kundrat & Associates 107 Boas Street Harrisburg, PA 17102 Attorney ID No. 24958 Telephone: 717-232-3755 Fax: 717- 232 -9608 kundrat- associates@pa.net FIVE -STAR INTERNATIONAL, LLC : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff :No. 14- 14�od �tv 1 m V. FOXTROT TRUCKING, LLC and EDWARD D. FOX, JR., Individually Defendants : CIVIL ACTION - LAW PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter judgment in favor of Plaintiff and against Defendants Foxtrot Trucking, LLC and Edward D. Fox, Jr., Individually, in the amount of $2,912.79 together with interest compounded monthly at the rate of 1.5 %, from October 31, 2013, and legal fees plus costs to be determined. 31. a5 Po ATTV 0-f 5q la fe:l 5 I hereby certify that the name and last known address of the proper person against whom judgment should be entered under Pa.R.C.P. 236 is: Foxtrot Trucking, LLC and Edward D. Fox, Individually 926 Nixon Drive Mechanicsburg, PA 17055 Respectfully submitted, KUNDRAT & ASSOCIATES By _, 14h� YAn S.ikundrat, Esquire Attorney for Plaintiff Dated: March 6, 2014 COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUN rY OF DAUPHIN Case Mag. Dist. No: MDJ- 12 -2 -02 Five -Star International, LLC MDJ Name: Honorable Kenneth A. Lenker V. Address: 102 Agnes Street Foxtrot Trucking, LLC, Edward D Fox, Jr., Harrisburg, PA 17104 Individually Telephone: 717- 939 -6996 John S. Kundrat, Esq. Docket No: MJ- 12202 -CV- 0000252 -2013 Kundrat & Associates Case Filed: 12/13/2013 107 Boas St Harrisburg, PA 17102 Disposition Summary _(cc- cross complaint) - - Docket No Plaintiff Defendant Disposition Disposition Date MJ- 12202 -CV- 0000252 -2013 Five -Star International, LLC Edward D Fox, Jr., Individually Default Judgment for Plaintiff 01/22/2014 MJ- 12202 -CV- 0000252 -2013 Five -Star International, LLC Foxtrot Trucking, LLC Default Judgment for Plaintiff 01/22/2014 Judgment Summary Participant Joint/Several Liability Individual Liability Amount r Edward D Fox, Jr., Individually $2,912.79 $0.00 $2,912.79 Five -Star International, LLC $0.00 $0.00 $0.00 Foxtrot Trucking, LLC $2,912.79 $0.00 $2,912.79 Judgment Finding ( * Post Judgment) _ In the matter of Five -Star International, LLC vs. Foxtrot Trucking, LLC; Edward D Fox, Jr., Individually on MJ- 12202 -CV- 0000252 -2013, on 1/22/2014 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $2,793.29 $0.00 $2,793.29 Costs $119.50 $0.00 $119.50 Grand Total: $2,912.79 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. Date Magisterial District Judge Kenneth A.'Lenker certify that this is a true and correct copy of the record of the proceedings co aMing the judgment. 02/24/2014 Date agisterial District Judge r• MDJS 315 Page 1 of 2 Printed: 01/22/2014 11:32:55AM r a • . A `�i/e -Star International, LLC Docket No.: MJ- 12202 -CV- 0000252 -2013 V. Foxtrot Trucking, LLC, Edward D Fox Jr., 9 Individually Participant List V Plaintiff(s) Five -Star International, LLC 1810 South 19th Street Harrisburg, PA 17104 ' Defendant(s) Edward D Fox, Jr., Individually . 926 Nixon Drive - - Mecha,nicsburg, PA 17055 ' Foxtrot Trucking, LLC 926 Nixon Drive Mechanicsburg, PA 17055 Complainant's Attorney(s) John S. Kundrat, Esq. Kundrat & Associates 107 Boas St Harrisburg, PA 17102 ♦ ♦ M J MDJS 315 Page 2 of 2 Printed: 01/22/2014 11:32:55AM OFFICE OF PROTHONOTARY Stephen E. Farina Front & Market Streets Prothonotary — Harrisburg, PA 17101 " (717) 780 -6520 CERTIFICATION OF NO APPEAL FROM DISTRICT JUSTICE JUDGMENT DAUPHIN COUNTY, PENNSYLVANIA V'Q : DISTRICT JUSTICE DOCKET NUMBER l aa OD- ry - Asa -��3 PLAINTIFF V. �oX�i�c� TuC,k�►�c1 DEFENDANT : ............................................................................. ............................... As of the date certified below, the following action has been taken on the above- referenced appeal: There has been no appeal taken to the Court of Common Pleas () The following party has taken an appeal to the Court of Common Pleas: 1 FE9- 2 8 , 20M Date Stephen E. Ilarina, Protho tary 4 Beputy Proth. - 75 John S. Kundrat, Esquire Kundrat & Associates 107 Boas Street Harrisburg, PA 17102 Attorney ID No. 24958 Telephone: 717-232-3755 Fax: 717- 232 -9608 kundrat- associatesg FIVE -STAR INTERNATIONAL, LLC : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. (�Ivl le.rm V. FOXTROT TRUCKING, LLC and EDWARD D. FOX, JR., Individually Defendants : CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE PA.R.C.P. 236 I, JOHN S. KUNDRAT, ESQUIRE, hereby certify that the precise address of Plaintiff is: Five -Star International, LLC 1810 South 19 Street Harrisburg, PA 17104 And certify that the last known address of the within Defendants are: Foxtrot Trucking, LLC and Edward D. Fox, Individually 926 Nixon Drive Mechanicsburg, PA 17055 Respectfully submitted, KUNDRAT & ASSOCIATES By 4,s Att ey for Plaintiff Dated: March 6, 2014 John S. Kundrat, Esquire Kundrat & Associates 107 Boas Street Harrisburg, PA 17102 Attorney ID No. 24958 Telephone: 717- 232 -3755 Fax: 717 - 232 -9608 kundrat- associates(a@pa net FIVE -STAR INTERNATIONAL, LLC : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. V. FOXTROT TRUCKING, LLC and EDWARD D. FOX, JR., Individually Defendants : CIVIL ACTION - LAW NOTICE OF ENTRY OF JUDGMENT TO: Foxtrot Trucking, LLC and Edward D. Fox, Individually 926 Nixon Drive Mechanicsburg, PA 17055 You are hereby notified that on /a / the following judgment has been entered against you in Cumberland County for the above - captioned matter: Judgment in the amount of $2,912.79 together with interest comp) unded monthly at the rate of 1.5 %, from October 31, 2013, and legal fees plus costs to be determined. i Date: rothonotary i d � I hereby certify that the names and last known address of the proper person to receive this notice under Pa.R.Civ.P. 236 is: Foxtrot Trucking, LLC and Edward D. Fox, Individually 926 Nixon Drive Mechanicsburg, PA 17055 KUNDRAT & ASSO IAT S By Jo S. undrat, Esquire Attorney for Plaintiff Dated: March 6, 2014 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANTA CIVIL DIVISION r; PRAECIPE FOR WRIT OF EXECUTION - r,a FIVE-STAR INTERNATIONAL LLC • ❑Confessed Judgment -- Plaintiff MI Other VS. : File No. 14-1460 Civil Term FOXTROT TRUCKING, LLC et al : Amount Due 2,912.79 TI - : Defendant : Interest from 10/31/13 - $204.66 Address: Atty's Comm 926 Nixon Drive Costs Mechanicsburg,PA 17055 TO THE PROTHONOTARY OF THE SAID COURT: 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. Issue writ of execution in the above matter to the Sheriff of Cumberland County County,for debt,interest and costs,upon the following described property of the defendant(s) Foxtrot Trucking,LLC and Edward D. Fox,Individually, 926 Nixon Drive, Mechanicsburg, PA 17055 UL‘) w4 CA, DtrSaft Ct-t-TVIA9e, PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County,for debt,interest and costs,as above,directing attachment against the above-named garnishee(s)for the following property (if real estate,supply six copies of the description;supply four copies of lengthy personalty list) • and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s). ❑ (Indicate)Index this writ against the garnishee(s)as a lis pendens again real estate of the defendant(s)described in the attached exhibit. 7,/ /' Date March 17, 2014 Signature: Print Name: n ' 'K , dr-,Esquire Goya SD ( Address: 107 :oas St Ps Harrisburg, PA 17102 11 Attorney for: Plaintiff pek Telephone: 717-232-3755 Supreme Court ID No: 24958 faD a.; S e"). . So(--4- S4// 3r)34,2,...? THE COURT OF COMMON PLEAS z∎ \\C CUMBERLAND COUNTY PA i o !WIN" DAVID D. BUELL,PROTHONOTARY 0K /1,: I° One Courthouse Square• Suite100 • Carlisle, PA• 17013 •''\ (717)240-6195 www.ccpa.net www.cc iisa P FIVE-STAR INTERNATIONAL LLC Vs. NO 14-1460 Civil Term CIVIL ACTION—LAW FOXTROT TRUCKING,LLC,EDWARD F. FOX,INDIVIDUALLY WRIT OF EXECUTION (Pa R.C.P.3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against FOXTROT TRUCKING, LLC,EDWARD F. FOX, INDIVIDUALLY,926 NIXON DRIVE,MECHANICSBURG,PA 17055 Defendant(s) (1) you are directed to levy upon the property of the defendant(s)and to sell the defendant(s)interest therein; LEVY UPON PERSONAL PROPERTY AT 926 NIXON DRIVE, MECHANICSBURG,PA 17055 . (2) you are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S), as garnishee, (Specifically describe property)and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first$10,000 of each account of the defendant(s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant(s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant(s)with a bank or other financial institution that total$300 or less. If multiple accounts are attached, a total of$300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant(s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant(s)not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due$ 2,912.79 Plaintiff Paid$ Interest$FROM 10/31/13-$204.66 Interest from Attorney's Comm. % Law Library$.50 Attorney Paid$59.75 Due Prothonotary$2.25 Other Costs$ Date: MARCH 20,2014 . David D. Buell,Prothonotary `By: /j i . L /1l" Deputy REQUESTING PARTY: Name :JOHN S. KUNDRAT,ESQUIRE Address: 107 BOAS STREET HARRISBURG,PA 17102 Attorney for: PLAINTIFF Telephone: 717-232-3755 Supreme Court ID No. 24958 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines,uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law L Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ..sROi HO ;. 2J15 JAN 12 P+' 3: 6 I+ CUMBERLAND COUNTY PENNSYLVANIA Five -Star International LLC vs. Foxtrot Trucking, LLC (et al.) Case Number 2014-1460 SHERIFF'S RETURN OF SERVICE 04/02/2014 08:18 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Writ of Execution and Claim for Exemption Form to a person representing themselves to be Jessica Karns, Step -daughter, who accepted as "Adult Person in Charge" for the within named Defendant, to wit: Foxtrot Trucking, LLC at 926 Nixon Drive, Monroe Township, Mechanicsburg, PA 17055, informed person of contents of same and levied upon personal property as directed. The writ of execution and notice to defendant was mailed on April 3, 2014 to Foxtrot Trucking, LLC at 926 Nixon Drive, Mechanicsburg, PA 17050. Copy of levy and writ letter sent to plaintiffs attorney April 3, 2014. 04/02/2014 08:25 PM - Deputy Dennis Fry, being duly sworn according to law, served the requested Writ of Execution and Claim for Exemption Form to a person representing themselves to be Jessica Karns, step -daughter, who accepted as "Adult Person in Charge" for the within named Defendant, to wit: Edward F Fox at 926 Nixon Drive, Monroe Township, Mechanicsburg, PA 17055, informed person of contents of same and levied upon personal property as directed. The writ of execution and notice to defendant was mailed on April 3, 2014 to Edward F. Fox at 926 Nixon Drive, Mechanicsburg, PA 17050. Copy of levy and writ letter sent to plaintiffs attorney April 3, 2014. 01/08/2015 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $86.19 SO ANSWERS, January 08, 2015 RONNY R ANDERSON, SHERIFF Ai 3«" 606 (c) CountySuite Sheriff, Teleosoft. Inc. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suitel00 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net FIVE-STAR INTERNATIONAL LLC Vs. NO 14-1460 Civil Term CIVIL ACTION — LAW FOXTROT TRUCKING, LLC, EDWARD F. FOX, INDIVIDUALLY WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against FOXTROT TRUCKING, LLC, EDWARD F. FOX, INDIVIDUALLY, 926 NIXON DRIVE, MECHANICSBURG, PA 17055 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; LEVY UPON PERSONAL PROPERTY AT 926 NIXON DRIVE, MECHANICSBURG, PA 17055 . (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $ 2,912.79 Interest$ FROM 10/31/13- $204.66 Attorney's Comm. % Attorney Paid $ 59.75 Other Costs $ Date: MARCH 20, 2014 (Seal) REQUESTING PARTY: Name : JOHN S. KUNDRAT, ESQUIRE Address: 107 BOAS STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-232-3755 Supreme Court ID No. 24958 Plaintiff Paid $ Interest from Law Library $ .50 Due Prothonotary $ 2.25 David D. Buell, Prothonotary MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the eal of said Court att C�arlisle, Pa. This 1_LJ G day of CC20 Prothonotary