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Home My WebLink About05-1868 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CO"NGRESS FINANCIAL CORP. Plaintiff No. OS - Jf(."f C,u~L EJLnt vs. IDEAL CARDS, INC. CIVIL ACTION Defendant PRAECIPE FOR ENTRY OF JUDGMENT AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY, CUMBERLAND COUNTY: Pursuant to the Pennsylvania Rule of Civil Procedure 3002, kindly file and index the a ached certified docket entries and judgment previously entered in the United States District Court or the Middle District of Pennsylvania. in an action captioned CONGRESS FINANCIAL CORP. vs. IDEAL CARDS, INC., at docket no. 1 :04-CV-02219-CCC, and assess damages in favor of the PI intiff, CONGRESS FINANCIAL CORP., and against the Defendant, IDEAL CARDS, INC., as follows: Amount of Foreign Judgment Interest (from December 8, 2004 to March 21, 2005 at statut<:>ry of 6% per annum) 271,500.96 TO BE ADDED TOTAL 771 ,500 96 Dated: March 21, 2005 AMATO AND MARGLE, P.C. BY~ Ronald Amato, Atty 10 #32323 Michael Kennedy, Atty 10 #72412 Michael Lessa, Atty 10 #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 Attorney File # 2042118 Damages assessed and judgment enlered ~s abovi< C AA JJu1 ,:1 DeA/] PROTHONOT ARY V~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CONGRESS FINANCIAL CORP. No. oS' - If~P Cw.J Plaintiff 8L~ vs. IDEAL CARDS, INC. CIVIL ACTION Defendant AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF NORTHAMPTON Ronald Amato, Esquire, being duly sworn according to law, deposes and says that h is the attorney for Plaintiff, CONGRESS FINANCIAL CORP., is authorized to make this affidavit on its behalf; and that, to the best of his knowledge, information and belief: 1. The name of the judgment debtor is IDEAL CARDS, INC. 2. The last known post office address of the judgment debtor is 3617 Simpson Ferr Road, CAMP HILL PA 17011. 3. The name of the judgment creditor is CONGRESS FINANCIAL CORP. 4. The last known post office address of the judgment creditor is 1133 Avenue of the Americas, New York, NY 10036. 5. The judgment in favor of Plaintiff, CONGRESS FINANCIAL CORP., and gainst Defendant, IDEAL CARDS, INC., entered in the total sum of 271,500.96 in the United States istrict Court for the Middle District of Pennsylvania County, is valid, enforceable, and unsatisfied as f this date; March 21, 2005. SWORN TO AND SUBSCRIBED BEFORE ME THIS '10 DAY OF .,AA,.'<<l.. \...., , 2005. (9~ ~ Gh Not~y Publi ~c~ - Ronald Amato NOTARIAL SEAL GEOFFRE"I' G SCHOENECK Notary Public HANOVER TOWNSHIP, NORTHAMPTON CNTV My Commission EJplres Mar 29, 2008 Pennsylvania Middle District Version 2.3 - Docket Report Page I of2 r ATYADM,CLO ED,HBG U.S. District Court Middle District of Pennsylvania (Harrisburg) CIVIL DOCKET FOR CASE #: 1:04-cv-02219-CCC Internal Use Only Congress Financial Corp. v. Ideal Cards, Inc. Assigned to: Honorable Christopher C. Conner Demand: $75000 Cause: 28: 1332 Diversity-Other Contract Plaintiff Congress Financial Corp. Date Filed: 10/08/2004 Jury Demand: None Nature of Suit: 190 Contract: ( ther Jurisdiction: Diversity represented by Michael Kennedy Amato & MargIe, P.C. 107 North Commerce Way Bethlehem, P A 18017 (610) 866-0400 LEADAITORNEY AITORNEY TO BE NOTICED Michael Lessa Amato & MargIe, P.C. 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 LEAD AITORNEY AITORNEY TO BE NOTICED c.rtfIed from Dsie Lffr "21~~ Ronald Amato Amato & Margie, P.c. 107 North Commerce Way Bethlehem, PA 18017-8930 610-866-0400 LEAD AITORNEY AITORNEY TO BE NOTICED V. Defendant Ideal Cards, Inc. Date Filed 10/08/2004 # \OJ1 Docket Text COMPLAINT - N/C to cnsl.; no jury trial demanded. (Filing fee $1 0, Receipt Number III 141884) (Attachments: # 1 Exhibit(s) # 2, Civil Cover Sheet #.:2 Receipt)Gc) (Entered: 10/08/2004) https://ecf.pamd.circ3.dcnlcgi-binlDktRpt.pl?355416880902354-L _280_0-1 03/1 /2005 Pennsylvania Middle District Version 2.3 - Docket Report Pa ge 2 of 2 . ] :J/Q8/2004. " SPECIAL ADMISSION FORM SENT to Michael Kennedy, E qu ire. (jc) (Entered: 10/08/2004) 10/08/2004 " SPECIAL ADMISSION FORM SENT to Michael Lessa, Esqui e. (jc) (Entered: 10/08/2004) 10/08/2004 " SUMMONS ISSUED as to defendant. (jc) (Entered: 1O/08/200~IJ 10112/2004 ~Z ORDER Re: Case Assignment and Procedures. Signed by Judge Christopher C. Conner on 10112/04. (jc) (Entered: 10/12/2004) 11/19/2004 ",5 SUMMONS Returned Executed upon Ideal Cards, Inc. on 10/24 2 004, answer due 11/15/2004. (jc) (Entered: 11/22/2004) 11/22/2004 ":2 Praecipe For Entry of Default against the defendant, Ideal Cards, I nc. (Attachments: # 1 Proposed Default)(pw, ) (Entered: 11/22/2004 11/22/2004 "1 Praecipe For Enl1y of Default Judgment and Assesment of Dam a es. (Attachments: # 1 Proposed Order)(pw,) (Entered: 11122/2004) 12/08/2004 ~Q Clerk's ENTRY OF DEFAULT as to Ideal Cards, Inc. for failure o plead or otherwise defend. Signed by Deputy Clerk on 12/8/04. (pw, ) ( ntered: 12/08/2004) 12/08/2004 "7 DEF AUL T JUDGMENT in favor of Plaintiff against Ideal Cards Inc. in the amount of$271,500.96.signed by Peter Welsh on 12/8/04. (p ", ) (Entered: 12/08/2004) https://ecf.pamd.circ3 .dcn/cgi-binlDktRpt.pl?35 5416880902354-L _280_0-1 03 II /2005 UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA CONGRESS FINANCIAL CORP. Plaintiff No. I:CV-Q4-2219 vs. IDEAL CARDS, INC. Defendant ORDER ENTERING DEFAULT JUDGMENT AND NOW, this'..... day of Pc.c.c""''-.... , 2004, pursuant to the Praecipe for Default filed by Plaintiff, with verified statement, it appearing Defendant has not appeared in the action within twenty (20) days after service of the Summons and Complaint, judgment is her by entered in favor of Plaintiff and against the Defendant, IDEAL CARDS, INC., as follows: Amount claimed in complaint Interest (from September 29, 2004 at Statutory 6 % per annum) $270,015.87 1,485.08 TOTAL $271,500.95 <::. )... u.... '-. J. ; COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVA IA CIVIL ACTION - LAW CONGRESS FINANCIAL CORP. Plaintiff No. O~ - IFbi CI ~ L ~'tiL~ vs. IDEAL CARDS, INC. CIVIL ACTION Defendant NOTICE OF JUDGMENT Please be advised that the above-named Plaintiff, CONGRESS FINANCIAL CO P., has transferred to the Court of Common Pleas of Cumberland County, Pennsylvania, a j dgment entered against you in the United States District Court for the Middle District of Penns lvania. Said judgment being entered in the Court of Common Pleas of Cumberland County, Penns lvania, to the above civil action number against the above named defendant(s) in the am unt of 271,500.96 .<lis /I..jJ,..day of Apfl...~L ,2005. COUNTY Per: If you have any questions concerning the above, please contact the u e gned. AMATO AND MARGLE, P.C. By: .~) ~~ Ronald Amato, Atty ID #32323 Michael Kennedy, Atty ID #72412 Michael Lessa, Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (610) 866-0400 \-> ~ 'c~ ~ jU 9 ~ \) - -- "0 \) ( \' ~ ""<;) ~ lv ~.) "5 ...c F t ty ~ 1- .. F :c:> ~ t- () c-:~ ~'" ."" ,- ~j (i:' ~;.c) .s=- "-'. ~.t~ .-f 3. .-> ,;;:;" ~ ~ -.' -;P - - o '1""\ -' :t-n (" e~ _~r-\:' ~1:_1 ~? 9\(:~ ~:f, :.;\ 1,.-..;.('") ~~~?\,"ri -.Z" ~~ ..." :;;;; <.f! <.n <==' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN A CIVIL ACTION - LAW C'ONGRESS FINANCIAL CORP. Plaintiff No. 05-1868 Civil vs. IDEAL CARDS, INC. PRAECIPE FOR WRIT EXECUTION (MONEY JUDGMENT) Defendant(s) To the Prothonotary - Cumberland County: ISSUE A WRIT OF EXECUTION IN THE BOVE MATTER. (1) Directed to the Sheriff of Cumberland County, for debt, interest and costs up n the following described property of the defendant(s) All cash on hand or in the ossession of the defendant s accounts receivables furniture furnishin s e ui ment inventor tools vehicles electronic e ui ment an and all other ersonal ro ert belon in to the bove- named defendantlsl. (2) against IDEAL CARDS. INC., Defendant(s) (3) and against................ ............... .........Garnishee(s) (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(s) in the name of the Garni heels) as follows:(Specifically describe the property) (5) Amount Due Statutory Interest From April 11, 2005 $ 271,500.96 $ 5,627.66 Less Payment Costs Poundage $ 0.00 $ $ Total $ 277,128.62 AMATO AND MARGLE, P.C. By: Ronald Amato Attorney I.D. No. 32323 Attorneys for Plaintiff Date:April 13. 2005 Attorney File#: 2042118 s ~ ~ ~ b -r: ~ w ~ f':.::) - k ;,t. f'"" v lrt ~. c tJ t ~ -lQ. ,..., C) W r::-,' ...... c~~":l -rl "'Is ~ ~ () ~ ,;'J1 ~ :--. ~ & B d () () l".) 0- () co ,... I I f -J ~~, {:} - . r r::JF- - , , r;? ~ , () ~~ ("0 (.-;J . ~ - , ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN -~ CIVIL ACTION - LAW CONGRESS FINANCIAL CORP. Plaintiff No. 05-1868 Civil vs. IDEAL CARDS. INC. CIVIL ACTION Defendant(s) CERTIFICATION OF DEFENDANT(s\ ADDRESS FOR SERVICE I do certify that the precise last known address of the within named defendant(s} s the address provided below, and request that the Sheriff serve the above named defendant s\ at: 3617 Simpson Ferry Road CAMP HILL PA 17011 Dated:April 13. 2005 AMATO AND MARGLE, P.C. By: ~-c9 Ronald Amato Attorney 1.0. No. 32323 Attorneys for Plaintiff Attorney File #:2042118 WRIT OF EXECUTION and/or ATTACHMENT . . COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-1868 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CONGRESS FINANCIAL CORP., Plaintiff (s) From IDEAL CARDS, INC., 3617 SIMPSON FERRY ROAD, CAMP HILL, PA 17011 (I) You are directed to levy upon the property of the defendant (s)and to sell ALL CASH ON HAND OR IN THE POSSESSION OF THE DEFENDANT(S), ACCOUNTS, RECEIVABLES, FURNITURE, FURNISHINGS, EQUIPMENT, INVENTORY, TOOLS, VEHICLES, ELECTRONIC EQUIPMENT, ANY AND ALL OTHER PERSONAL PROPERTY BELONGING TO THE ABOVE-NAMED DEFENDANT(S). (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 fro paying any debt to or for the account of the defendant (s) and from delivering any property of the defenda (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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $271,500.96 Interest FROM 4/11/05 - $5,627.66 Atty's Conun % Atty Paid $37.50 Plaintiff Paid Date: APRIL 20, 2005 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) By: Deputy REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone: 610-866-0400 Supreme Court 1D No. 32323 '~"'~ ~,\.-~~,,::;., ' ~-. ,. .-;r) 1/:i7:;-; .f R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee Postage TOTAL $ 18.00 2550.00 .50 1.00 11.10 20.00 2600.60 Sworn and Subscribed to before me This/g-::' day~ YI1AJ 2005 A.D. L~u- Q)w /e~. , ~ Pr honotary , Advance Costs: Sheriffs Costs: 2600.60 2600.60 $ 000.00 Refunded to Atty on 05117/05 ~~~~ R. Thomas Kline, Sheriff B~f!faif!Ifre\vb~JbctL/ (), l.r, '- "-, "'", ..., q I :01 V I G tJd\! IDOl ~ ':Jiij ;}!j .~ . <'Ii! 'i/J ';\1:,: j~nrJhS -~; " ". ' .. ',', j '. .~j ~~ \ ..:J :,:d \ 51) l , Ctt'191Dt F2./.u/' 'f.l. 3f WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-1868 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CONGRESS FINANCIAL CORP., Plaintiff (s) From IDEAL CARDS, INC., 3617 SIMPSON FERRY ROAD, CAMP HILL, PA 17011 (I) You are directed to levy upon the property of the defendant (s)and to sell ALL CASH ON HAND OR IN THE POSSESSION OF THE DEFENDANT(S), ACCOUNTS, RECEIVABLES, FURNITURE, FURNISHINGS, EQUIPMENT, INVENTORY, TOOLS, VEHICLES, ELECTRONIC EQUIPMENT, ANY AND ALL OTHER PERSONAL PROPERTY BELONGING TO THE ABOVE-NAMED DEFENDANT(S). (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 ofthe defendant (s) or otherwise disposing thereof; (3) Ifproperty 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 helshe has been added as a garnishee and is enjoined as above stated. Amount Due $271,500.96 Interest FROM 4111105 - $5,627.66 Ally's Comm % Atty Paid $37.50 Plaintiff Paid Date: APRIL 20, 2005 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R, LONG (Seal) Prothonotary 2 ~ '-...J3v:-~ ~ " . '//./J,~ Deputy REQUESTING PARTY: Name RONALD AMATO, ESQUIRE Address: 107 NORTH COMMERCE WAY BETHLEHEM, PA 18017 Attorney for: PLAINTIFF Telephone: 610-866-0400 Supreme Court ID No. 32323 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CONGRESS FINANCIAL CORP. Plaintiff No. 05-1868 Civil vs. IDEAL CARDS, INC. CIVIL ACTION Defendant(s) PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY OF CUl\fBERLAND COUNTY: Please satisfy the judgment entered in the above-captioned case. AMATO AND MAR?LE}y- By: ~ t/ ./;~ << Rcthald Amato, Esq., Atty ID #32323 Michael J. Kennedy, Esq., Atty 10 #72412 Michael R. Lessa, Esq., Atty ID #88617 Attorneys for Plaintiff 107 North Commerce Way Bethlehem, PA 18017 (6101866-0400 c , ,-.'""'