HomeMy WebLinkAbout14-3219 . P1. 1; 3
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LVANI;A
BLUE WATER CONSTRUCTION SERVICES INC
VS.
COMPLETE PROPERTY SERVICES LLC
No. 14-646-2-
1, Marianne R. Sutton Prothonotary of the Court of Common Pleas of Berks
County, Pennsylvania, do hereby certify that the above and following pages
contain a true copy and correct transcript of the docket entries, which form
the whole record. Judgment has been entered and certified in favor of the
Plaintiff, BLUE WATER CONSTRUCTION SERVICES INC, and
against Defendant, COMPLETE PROPERTY SERVICES LLC, in the
amount of$6,396.50.
In Testimony Whereof, I have hereunto set my hand and affixed the seal of
said Court at Reading, PA, this 22nd day of May, 2014.
Marianne R. Sutton
Prothonotary of Berks County
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05/22/2014 Berks County Civil Court Docket Summary Page 1 of 1
Docket Number: 14 6162
Judge: Filed: 05/07/2014
SubType: Magisterial D.J. Transcript
Attorney(s)
BLUE WATER CONSTRUCTION SERVICES INC Boyer, Mahlon J
***VS***
COMPLETE PROPERTY SERVICES LLC
Date Summary
05/07/2014 Magisterial D.J. Transcript-$6,396.50 by MDJ Kowalski on 03/28/14
05/07/2014 Praecipe to enter judgment
05/07/2014 Notice and copies issued to all parties
05/15/2014 Exemplified Judgment to Cumberland County, PA
5/22/2014 Berks County Civil Court Information System RptCostLedgers.rpt
Cost Ledgers Page 1 of 1
Docket Number: 1406162 Judge:
Case Type: Judgment
Case SubType: Magisterial D.J. Transcript
Case Date Party Description Paid Due Recorded Collected
05/07/2014 MAGISTERIAL D.J. TRANSCRIPT 39.00
05/15/2014 EXEMPLIFIED JUDGMENT TO 26.50
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cn OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS OF BERKS COUNTY, PENNSYLVANIA
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TO: Complete Property Services, LLC —+ N �,o
P.O. Box 543 n -'
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New Kingston, PA 17072 -
RE: BLUE WATER CONSTRUCTION
SERVICES, INC.,
Plaintiff
vs.
COMPLETE PROPERTY
SERVICES, LLC,
Defendant
NO: IL _ � Ito
You are hereby notified in accordance with Pennsylvania Supreme Court Rule#236 and that
judgment has been entered on a District Justice Transcript and entered to No. I4.-6161- against
the Defendant,Complete Property Services, Inc.concerning Civil"Su�"' on 5 PT
2014 in the sum of$6,396.50, plus costs.
MARIANNE: R SUTTON PP*114W sj,,�
By:
DepQ Prothonotary
czar �
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crt Mahlon J. Boyer, Esquire `-�sc�n Q:rrn
` Bin aman, Hess, Cobientz&. Bell, P.C.
Attorney I.D.No. 91094 0 z
N Treeview Corporate Center r C=:<
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Suite 100, 2 Meridian Boulevard -�� ' `-*'
Wyomissing, PA 19610 x rn
(610) 374-8377 Attorney for Plaintiff
BLUE WATER CONSTRUCTION IN THE COURT OF COMMON PLEAS
SERVICES, INC., BERKS COUNTY, PENNSYLVANIA
Plaintiff CIVIL ACTION -LAW
VS.
NO.
COMPLETE PROPERTY
SERVICES, LLC,
Defendant ASSIGNED TO:
,ro THE PROTHONOTARY:
Kindly enter judgment on the District Justice Transcript for the Plaintiff and against the
Defendant for the total amount of$6,396.50, plus costs.
Respectfully submitted,
BINGAMAN,HESS, COBLENTZ& BELL, P.C.
By:
Mah on J. Boye , squire
Attorney I.D. #91094
Attorney for Plaintiff
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Mahlon J. Boyer, EsquireLn
Bingaman, Hess, Coblentz& Bell, P.C. orrio
Attorney I.D. No. 91094 n-X
N Treeview Corporate Center �c t C5o
Suite 100, 2 Meridian Boulevard �—��' `n
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Wyomissing, PA 19610 z M
(610) 374-8377 Attorney for Plaintiff
BLUE WATER CONSTRUCTION IN THE COURT OF COMMON PLEAS
SERVICES, INC., BERKS COUNTY, PENNSYLVANIA
Plaintiff CIVIL ACTION -LAW
VS.
NO.
COMPLETE PROPERTY
SERVICES, LLC,
Defendant ASSIGNED TO:
CERTIFICATION OF ADDRESSES
I,MAHLON J.BOYER,ESQUIRE,hereby certifies that the following addresses are true and
correct to the best of my knowledge:
Complete Property Services, LLC
P.O. Box 543
New Kingston, PA 17072
Defendant
Mahlon J. Boyer, Esquire
Bingaman Hess
Treeview Corporate Center
2 Meridian Blvd., Suite 100
Wyomissing, PA 19610
Attorney for Plaintiff BINGAMAN, HESS,COBLENTZ& BELL, P.C.
By: 1��/ A ,
Mahlon J. Boyer, squire
Attorney I.D. 491094
Attorney for Plaintiff
;COMMONWEALTH OF PENNSYLVANIA CIVIL COMPLAINT
COUNTY OF BERKS 3 0
PLAINTIFF: NAME AND ADDRESS T"M 4=
Mag_Dist.No.: 23-2-03 [ BLUE WATER CONSTRUCTIt x 6*• o
SERVICES, INC.
N DJ Name: Phyllis Kowalski 1800 Friedensbur Road ==xC-' r �n
Address: 10 Fairlane Road g X=C= J
f' Reading,PA 19606 P.O. Box 3557 �-i
[ Reading, PA 19606 >c� 10 "im
N Telephone: (610)779-5137 o�
VS. c D _nn
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DEFENDANT: NAME AND ADDRESS - rn
( COMPLETE PROPERTY SERVICES,
LLC ]
17 Parker Spring Avenue
( Carlisle, PA 17013 ]
Docket No.: �� — {0
Date Filed:l
AMOUNT DATE PAID
FILING COSTS $J4A'•SQ
SERVING COSTS$ (Q Ua
TOTAL $ 158-56
TO THE DEFENDANT: The above named plaintiff(s)asks judgment against you for$6,228.00
together with costs upon the following claim (Civil fines must include citation of the statute
or ordinance violated):
On or about April 26, 2013 and May 2, 2013, the Plaintiff, Blue Water Construction Services, Inc. billed the
Defendant, Complete Property Services, LLC for work performed at two separate locations on behalf of Defendant. The
work was performed and invoices were submitted in the amount of$6,428.00. The Defendant made one partial payment
of$200.00 thus admitting its liability for the amounts owed, but has failed and refused to pay the remaining obligation. As
the invoices were not paid, the Plaintiff demands judgment in the amount of$6,228.00 plus interest and costs of suit.
I, Mahlon J. Boyer, Esquire, attorney for Plaintiff, Blue Water Construction Services, Inc. verify that the facts set
forth in this complaint are true and correct to the best of my knowledge, information, and belief. This statement is made
subject to the penalties of Section 4904 of the Crimes Code (18 PA. C.S. §4904) related to unsworn falsification to
authorities.
(Signa ure of Plainti or Au or ed Agent)
Plaintiff's
Attorney: Mahlon J. Boyer. Esquire Address: Two Meridian Boulevard Suite 100
Telephone: (610)_374-8377 WVornissinq, PA 19610
IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, NOTIFY THIS OFFICE IMMEDIATELY AT THE
ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS
YOU DO, JUDGMENT WILL BE ENTERED AGAINST YOU BY DEFAULT.
If you have a claim against the plaintiff which is within district justice jurisdiction and which you intend to
assert at the hearing, you must file it on a complaint form at this office at least five (5) days before the
date set for the hearing. If you have a claim against the plaintiff which is not within district justice
jurisdiction, you may request information from this office as to the procedures you may follow. If you are
disabled and require assistance, please contact the Magisterial District office at the address
above.
f
COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil
COUNTY OF BERKS a Case
r
Mag. Dist. No: MDJ-23-2-03 Blue Water Construction Services, Inc.
+-' MDJ Name: Honorable Phyllis J. Kowalski V
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Address: 101 airlane Road Complete Property Services, LLC
N
m Reading,PA 19606
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Telephone: 610-779-5137
Mahlon John Boyer, Esq. Docket No: MJ-23203-CV-0000010 2014
Bingamen Hess ET AL Case Filed: 112t3L$ 4 M
2 Meridian Blvd Ste 100 >M
Wyomissing, PA 19610-3202 D� 3C o
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Disposition Summary (cc-Cross Complaint) x' In
Docket No Plaintiff D endan Disposition -%spwltion Date
MJ-23203-CV-0000010-2014 Blue Water Construction Complete Property Services,LLC Default Judgment for Plaintiff 03128/2014
Services,Inc.
Judgment Summary
Participant JointlSeveral Liability Individual Liability Amount
Blue Water Construction Services,Inc_ $0.00 $0.00 $0.00
Complete Property Services.LLC $0.00 $6,396.50 $6,396.50
Judgment Finding ('Post Judgment)
In the matter of Blue Water Construction Services, Inc. vs. Complete Property Services, LLC on MJ-23203-CV-0000010-2014, on
3/2812014 the judgment was awarded as follows:
Judgment Component Joint/§gyral Liability. Individual Liability Deposit Applied AalQvnt
Civil Judgment $0.00 $6,228.00 $6,228,00
Costs $0.00 $168.50 $168.50
Grand Total: $6,396.50
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH
THE PROTHONOTARYICLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF
JUDGMENT/TRANSCRIPT 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.
r!rr F + e
Date Magisterial District Judge Phyllis J.Kowalski
certify that this is a true and correct copy of the record o (he procee in contain a lu gment. `
Date Mag J I District Judge
MDJS 315 Page t of 2 Printed:04/30/2014 1:47:30PM
a
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
2014
Complete Property Services, LLC
P.O. Box 543
New Kingston, PA 17071
RE: Blue Water Construction Services, Inc. vs. Complete Property Services,
LLC
Dear Sir/Madam:
Blue Water Construction Services, Inc. this date has entered judgment against
you in the Court of Common Pleas of Cumberland County, Pennsylvania, in the amount
of $6,396.50, together with interest and costs of this action.
This judgment was entered to No. - 2, a�9 Cumberland County
Court of Common Pleas.
Prothonotary
Court of Common Pleas
Cumberl Co , P1 ylvania
.By: r;
eputy Prothonotary f
Mahlon J. Boyer, Esquire
Bingaman, Hess, Coblentz& Bell, P.C.
Attorney I.D. No. 91094
Treeview Corporate Center
Suite 100, 2 Meridian Boulevard
Wyomissing, PA 19610
(610) 374-8377 Attorney for Plaintiff
BLUE WATER CONSTRUCTION IN THE COURT OF COMMON PLEAS
SERVICES, INC., OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff CIVIL ACTION -LAW
VS.
NO. �� � Iot Zvi
COMPLETE PROPERTY
SERVICES, LLC,
Defendant ASSIGNED TO:
CERTIFICATION OF ADDRESSES
I, MAHLON J. BOYER, ESQUIRE, hereby certifies that the following addresses are true
and correct to the best of my knowledge:
Complete Property Services, LLC
P.O. Box 543
New Kingston, PA 17072
Defendant
Mahlon J. Boyer, Esquire
Bingaman Hess
Treeview Corporate Center
2 Meridian Blvd., Suite 100
Wyomissing, PA 19610
Attorney for Plaintiff BINGAMAN,HESS, COBLENTZ & BELL,P.C.
By:
MaAloA J. Boyer, giquire
Attorney I.D. #91094
Attorney for Plaintiff
Mahlon J. Boyer, Esquire
Bingaman, Hess, Coblentz & Bell, P.C.
Attorney I.D. No. 91094
Treeview Corporate Center
Suite 100, 2 Meridian Boulevard
Wyomissing, PA 19610
(610) 374-8377
HE PRO PRO THOHO TA :
20111 JUN -5 PH 3: 0
CUMBERLAND COUNTY
PENNS YLVANIA
Attorney for Plaintiff
BLUE WATER CONSTRUCTION
SERVICES, INC.,
Plaintiff
VS.
COMPLETE PROPERTY
SERVICES, LLC,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION -LAW
NO. 14-3219
ASSIGNED TO:
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
P.R.C.P. 3101 to 3149
TO THE PROTHONOTARY: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER.
(1) Directed to the Sheriff of Cumberland County, Pennsylvania;
(2) against Complete Property Services, LLC, Defendant;
(3) and against Members 1st Credit Union;
(4) and index this writ
(a) against , Defendant(s) and
(b) against , Garnishee(s)
as a lis pendens against the real property of the Defendant in the name of the Garnishee as follows:
Levy and attach all property of the Defendant, Complete Property Services, LLC, located and in the possession of
Member's 1s1 Credit Union, Garnishee
P.R.C.P. 2958
Date Judgment Entered:
Judgment by:
Date Notice of Judgment:
Amount Due:
Date: 4/4 lig
COA Ts- c)Ci tet?& OCk61.
'1C1 . 00 Me 0
31.50 \`
`la 5b 1'
May 28, 2014
Default
May 28, 2014
$6,396.50
By:
BINGAMAN, HESS, COBLENTZ & BELL, P.C.
Mahlon J. Boyer, squire
Attorneys for Plaintiff
f),S
e,t_413 Sao
gca)(Dci
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THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PA
DAVID D. BUELL, PROTHONOTARY
One Courthouse Square • Suite100 • Carlisle, PA • 17013
(717) 240-6195
www.ccpa.net
BLUE WATER CONSTUCTION SERVICES, INC.
Vs.
COMPLETE PROPERTY SERVICES, LLC
WRIT OF EXECUTION
(Pa R.C.P. 3252)
NO 14-3219 Civil Term
CIVIL ACTION — LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs against COMPLETE PROPERTY SERVICES, LLC, P.O. BOX
543, NEW KINGSTOWN, PA 17072 Defendant (s)
(1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein;
(2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of
MEMBERS 1sT CREDIT UNIONGARNISHEE(S), as garnishee, LEVY AND ATTACH ALL PROPERTY OF
THE DEFENDANT LOCATED AND IN THE POSSESSION OF MEMBERS 1sT CREDIT UNION, 1711
SPRING ROAD, CARLISLE, PA 17013 (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.
1
(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 $6,396.50 Plaintiff Paid
Interest Law Library 5.50
Attorney's Comm. % Due Prothonotary $2.25
Other Costs
Attorney Paid $101.50
Date: 6/05/14
(Scat)
'PiaJL
David D. Buell, Prothonotary
Deputy
REQUESTING PARTY:
Name : MAHLON J. BOYER, ESQUIRE
Address: BINGAMAN, HESS, COBLENTZ & BELL, P.C.
TREEVIEW CORPORATE CENTER
SUITE 1.00, 2 MERIDIAN BLVD.
WYOMISSING, PA 19610
Attorney for: PLAINTIFF
Telephone: 610-374-8377
Supreme Court ID No. 91094
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
2
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff 'i THE ' f t O I d O h Li
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
omct F Tl .FRWWF
20111 J. H 10 All !3: f-; _f
CUMBERLAND COUNT Y
PENNSYLVANIA
Blue Water Construction Services, Inc.
vs.
Complete Property Services, LLC
Case Number
2014-3219
SHERIFF'S RETURN OF SERVICE
06/09/2014 10:35 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded
all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control
of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton
Township, Carlisle, PA 17015, Cumberland County, by handing to Denise Harman, Branch Manager,
personally three copies of interrogatories together with three true and attested copies of the Writ of
Execution and made the contents there of known to her.
The writ of execution and notice to defendant was mailed on June 10, 2014»Complete Property Services,
LLC, PO Box 543, New Kingstown, PA 17072.
June 09, 2014
(c) CountySuite Sheriff, Te;eosoft, Inc.
CLINE, DEPUTY
SO ANSWERS,
RONNY R ANDERSON, SHERIFF
Mahlon J. Boyer, Esquire
Bingaman, Hess, Coblentz & Bell, P.C.
Attorney I.D. No. 91094
Treeview Corporate Center
Suite 100, 2 Meridian Boulevard
Wyomissing, PA 19610
(610) 374-8377 Attorney for Plaintiff
BLUE WATER CONSTRUCTION IN THE COURT OF COMMON PLEAS
SERVICES, INC., OF CUMBERLAND COUNTY.
PENNSYLVANIA
Plaintiff CIVIL ACTION -LAW
vs.
• NO. 14-3219
COMPLETE PROPERTY •
SERVICES, LLC, •
Defendant ASSIGNED TO:
AND
•
MEMBER'S 15' FEDERAL CREDIT .
UNION,
Garnishee
PRAECIPE TO DISSOLVE GARNISHMENT
TO THE PROTHONOTARY:
Kindly dissolve the garnishment against Members 1St Credit Union in the above-
referenced docket number.
BINGAMAN, HESS, COBLENTZ & BELL, P.C.
By: // �.,G��y/�'
Mahl n J. Boyd' Esquird
Attorneys for Plaintiff
Date: June 23, 2014
X71195