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Home My WebLink About05-3063 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CmmEllLAlID Mag. Dist. No. 09-1-01 MDJ Name: Harl. CHAllLES A. CLBIDD1T, JR Address' 400 BRJ:DGE ST OLDE TOWRB CODORS -SUJ:TE 3 IIBW cmmBllLAllD, PA Telephone: (717 ) 774-5989 17070 CT VRRaRILJ:TALTJ:OR LP 5351 JAYCEE AVE BARRJ:SBURG, PA 17112 THIS IS TO NOTIFY YOU THAT: Judgment: [!J Judgment was entered for: ?u) 05 - 3U,,) C;,;J t;~ NOTICE OF JUDGMENTfTRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rcT RBBABJ:LJ:TALTJ:OR LP I 5351 JAYCEE AVE BARRJ:SBURG, PA 17112 L ~ VS. DEFENDANT: 'TJ:DORS, PAUL 427 BRJ:DGE STREBT IIBW CmmERLAJlD, PA L NAME and ADDRESS I 17070 ~ . Docket No.: CV-0000193-05 Date Filed: 4/07/05 DEl!'AULT J1JI)fDI'InI'I' PLTl!' (Name) C"I' 'RlUURTT,T...aT,...Tn1ll T, 1> [!J Judgment was entered against: (Name) TT_n1ll8 _ PaUL ill the amount of $ 786 !i~ on: o Defelldants are joilltly and severally liable. o Damages wiil be assessed 011: o This case dismissed without prejudice. O Amoullt of Judgmellt Subject to Attachmellt/42 Pa.C,S. 98127 $ o Portion of Judgment for physical damages arising out of residential lease $ (Date of Judgment) !i/06/0!i . . (Date & Time) Amount of Judgment $ 698.03 Judgment Costs $ 88.50 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 786.53 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 3D DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL OIYISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTfTRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT 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 MAYBE 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. MAY - 6 2005 D ate ~- , Magisterial District Judge I certify that this is a true a UN - 72005 Date My commission expires first Monday of Jalluary, 2008 Aope 315-05 DATB PRJ:RTIm: 5/09/05 Magisterial District Judge SEAL 1:37:35 PM t (") g Q. ~ ~ C <J' ...... ~ z. .,~., <- ::r.;-n ~ -ace c:: 0'F;; \ Q}~,:'" ,.: :g~ ~ " ~-"> ~ 7', - " :.,.. --- '!2 .:;- S u-, \ I:- "'1 :r:~, v- .J> r: \ "'" ,,~ ~ C)B ,:: l. 10 ~i~:, 2'::rn l", - 9 L... v C? () ~ \. .';;;; ?fi " u:> ...( OJ ;.<:; \.., '\ l Ii'" ~'1 , }; ~ . ....... -C:, , r c:. ~:ff "\ ~ ~ l:- ff ~ " ~ '\: "" '" c~ ,. J7YL In the Court of Common Pleas Cumberland County, Pennsylvania CT Rehabiliation LP 5351 Jaycee Avenue Harrisburg, P A 17112 Plaintiffs Docket No.: Writ No,: Amount Due: Principal: Interest to Clerk's Cost: Sheriff's Cost: Total (as of v, Paul Timmons 427 Bridge Street New Cumberland, PA 17070 Defendant 05-3063 civil term $ $ 786.53 $ $ $ ) $ PETITION FOR A RULE TO SHOW CAUSE WHY AN ORDER GRANTING WAGE ATTACHMENT SHOULD NOT ISSUE AND NOW, comes the Plaintiff, CT Rehabilitation LP, and hereby petitions the Honorable Court to issue a Rule to Show Cause as to why relief in the instant Petition should not be granted upon the Defendant, Paul Timmons and the Defendant's employer, Professional Drive Resources, Inc., 427 Bridge Street, New Cumberland, P A 17070, in support thereof avers as follows: I. This matter arises out of a dispute concerning a residential lease. 2, Judgment was entered against the Defendant by District Justice Charles A. Clement Jr., Magisterial District 09-1-01 on May 6, 2005 in the amount of$698.03, Docket Number CV-0000193-05, Post judgment costs increased this amount to $786.53, which is shown on the certified judgment. 3. The District Justice Judgment was filed with this Court on June 14,2005, under Docket Number 05-3063 Civil Term. 4. Reasonable attempt has been made to contact and make payment arrangement to satisfy Judgment Docket Number CV-0000193-05. No response was received from defendant, 5. The Defendant is currently employed at Professional Drive Resources, Inc., 427 Bridge Street, New Cumberland, P A 17070. U_--l 6. Pursuant to 42 Pa, C.S,A. Section 8127, the Plaintiff is entitled to garnish 10% of the net wages per pay period of the Defendant, this judgment debtor-tenant, 7. The Plaintiff requests that this Court issue an order attaching the wages of the Defendant to satisfy the judgment, as permitted by 42 Pa, C,S.A. Section 8127. 8. Copies of the District Justice Judgment and the proposed attachment order are attached hereto. 9. WHEREFORE, the Plaintiff hereby requests that the Honorable Court issue the proposed rule to show cause against both the Defendant, Paul Timmons and his current employer, Professional Drive Resources, rnc" 427 Bridge Street, New Cumberland, P A 17070, Respectfully Submitted: ,1l-J-1- \')5 ~~c~ Mark X, DiSanto Attorney, P A Bar #51090 5351 Jaycee Avenue Harrisburg, PA 17112 (717)657-5729 Date: o c.: "" C":;;J ';;:::-1 ~, C) -1-1 -,,,,, C..... < I (,,'0 -,., r-:? Ln CT REHABILITATION LP, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW PAUL TIMMONS, Defendant NO, 05-3063 CIVIL TERM ORDER OF COURT AND NOW, this 21st day of November, 2005, upon consideration of the Plaintiffs Petition for a Rule To Show Cause Why an Order Granting Wage Attachment Should Not Issue, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted, RULE RETURNABLE within 20 days of service, BY THE COURT, Mark X. DiSanto, Esq, 5351 Jaycee Avenue Harrisburg, PA 17112 Attorney for Plaintiff Paul Timmons 427 Bridge Street New Cumberland, P A 17070 Defendant, pro se 1(- J~- 6) (!~ .~-L yts" :rc ~ .<' 1,1 '(J -)~} " (, t.. l' cr', :;'\...1 ------- . -....,- ... CT Rehabilitation LP 5351 Jaycee Avenue Harrisburg, P A 17112 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA Vs NO. 05-3063 Paul Timmons 427 Bridge Street New Cumberland, P A 17070 Defendant CNIL ACTION - LAW PLAINTIFF'S MOTION TO MAKE RULE ABSOLUTE AND NOW, Pursuant to Pennsylvania Rule of Civil Procedure 206.7, Plaintiff, CT Rehabilitation LP, hereby files this Motion to make Rule Absolute, and in support of same avers as follows: 1. On October 27,2005, Plaintiff, Bent Creek Limited Partnership, filed a Petition for A Rule to Show Cause Why an Order Granting Wage Attachment Should Not Issue. 2. On November21, 2005, this Honorable Court issued a Rule to Show Cause with a return within 20 days of service. 3. The Defendant had made payments totaling $300.00. 4. The Defendant has stopped making payments and has a current balance due of $486.53. 5. Pursuant to Pa. R.C.P. 206.7, when a Rule is not answered, the averments of fact may be deemed admitted and the court shall enter an appropriate order. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant its Petition For a Rule to Show Cause Why An Order Granting Wage Attachment Should Not Issue and GRANT a wage attachment against the Defendant's current employer, CDL Consultants, LLC, 427 Bridge Street, New Cumberland, P A 17070, as well as all current or subsequent employers. Pietro Leone, Attorney Triple Crown Corporation, Inc, Page 1 of2 Plaintiff's Motion to Make Rule Absolute ~ " Respectfully Submitted: Date: /..:J5 - e" fA rI j Pietro Leone, Attorney PA Bar #85127 5351 Jaycee Avenue Harrisburg, PAl 7112 (717) 657-5729 ----... Pietro Leone, Attorney Triple Crown Corporation, Inc, Page 2 of2 Plaintiff's Motion to Make Rule Absolute 1....,'. , CERTIFICATE OF SERVICE I hereby certify that I am this day serving Plaintiff s Motion to Make Rule Absolute upon the person and in the manner indicated below, which service satisfies the requirement ofPa. R.C.P. 440: Service by certified mail, addressed as follows: Paul Timmons 427 Bridge Street New Cumberland, P A 17070 CDL Consultants, LLC 427 Bridge Street New Cumberland, P A 17070 Respectfully Submitted, Date: 1;~5-0(d ~ d --;;J ~ By: Pietro Leone, Attorney, PA Bar #85127 5351 Jaycee Avenue, Harrisburg, P A 17112 717-657-5729 Pietro Leone. Attorney Triple Crown Corporation, Inc, Page 1 ofl Certificate of Service ,. ~... eJ Q ~~ ~i ~ ' ~.. b! g~ ; ~ i , I CT Rehabilitation LP 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff V ~HE\VED AUG 082006 ,f IN THE COURT OF COMMON PLEitS' CUMBERLAND, COUNTY, PENNSYLVANIA '"-- .... . Vs NO, 05-3063 Paul Timmons 427 Bridge Street New Cumberland, P A 17070 Defendant CIVIL ACTION - LAW ATTACHMENT ORDER AND NOW, this ~ day of f+. "0' ' 2006, upon consideration of the foregoing Petition for A Ru1e to Show Why An Order Granting Wage Attachment Shou1d Not Issue, no response being filed by the Defendant, Paul Timmons, The Defendant's employer is, CDL Consu1tants, LLC, 427 Bridge Street, New Cumberland, P A 17070, It is hereby ORDERED AND DECREED as follows: 1. The Defendant's current employer, CDL Consultants, LLC, and all subsequent employers of the Defendant are hereby ORDERED to garnish the wages of the Defendant in the amount of 10% of his net wages per pay period until the judgment in this matter is marked satisfied, 2. The amount of the judgment is $786.53. Payments in the amount of $300,00 brings the final amount due to $486.53, 3, The Defendant's current employer, CDL Consultants, LLC, and all subsequent employers of the Defendant are hereby ORDERED to send checks, for each pay period of the Defendant, in the amount specified in paragraph I above, and made payable to Triple Crown Corporation agent for CT Rehabilitation LP to the Office of the Prothonotary at One Courthouse Square, Carlisle, PA 17013, who will then record the amount paid in the docket of this matter and then forward the checks to Triple Crown Corporation, 5351 Jaycee Avenue, Harrisburg, P A 17112, So Ordered, By the Court Pietro Leone, Attorney Triple Crown Corporation, Inc. Page I ofl Attachment Order VINI/AlASNN3d AlNnm fJU';i"'I:G8~no 62 :01 WV II 50V 900l Al:WlONOH1OOd :ilHl :/0 3GI:Ho-a311:J .. ~ CT Rehabilitation LP 5351 Jaycee Avenue Harrisburg, P A 17112 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA Vs NO. 05-3063 CD L Consultants 427 Bridge Street New Cumberland, PA 17110 Defendant CIVIL ACTION - LAW PLAINTIFF'S MOTION FOR CONTEMPT OF COURT 1. On July 25, 2006, Plaintiff, CT Rehabilitation LP, filed for an Attachment Order against Defendant Paul Timmons. 2. On August 10, 2006, this Honorable Court issued an Attachment Order to the Defendant's current employer CDL Consultants. (Exhibit A) 3. On October 17, 2006 a letter was sent to the Defendant's employer stating that a Motion for Contempt of Court will be filed for non-compliance. 4. As of the date of this motion the Defendant has not complied. 5. The Plaintiff is respectfully requesting a hearing be scheduled for resolution of this matter. Respectfully Submitted: Date: I~ ~ If- {}/J ~;7;;/~ Pietro Leone, Attorney, PA Bar #85127 5351 Jaycee Avenue, Harrisburg, PA 17112 717-657-5729 Pietro Leone, Attorney Triple Crown Corporation, Inc. Page 1 of 1 Motionfor Contempt of Court -- . CT Rehabilitation LP 5351 Jaycee Avenue Harrisburg, PAl 7112 Plaintiff R ':' (' C ,. r- n f" r., n }' "(1('1'1 IN THE COURT OF COMMON PLEA'S - ~ - "- -- "V V v J';"Oy CUMBERLAND, COUNTY, PENNSYLVANIA Vs NO. 05-3063 Paul Timmons 427 Bridge Street New Cumberland, P A 17070 Defendant CIVIL ACTION - LAW AND NOW, this ~ day of ,2006, upon consideration of the foregoing Petition for A Rule to Show Why An Order Granting W a ~ttachment Should Not Issue, no response being filed by the Defendant, Paul Timmons. The Defendant's employer-is, CDL Consultants, LLC, 427 Bridge Street, New Cumberland, P A 17070. It is hereby ORDERED AND DECREED as follows: 1. The Defendant's current employer, CDL Consultants, LLC, and all subsequent employers of the Defendant are hereby ORDERED to garnish the wages of the Defendant in the amount of 10% of his net wages per pay period until the judgment in this matter is marked satisfied. 2. The amount of the judgment is $786.53. Payments in the amount of$300.00 brings the final amount due to $486.53. 3. The Defendant's current employer, CDL Consultants, LLC, and all subsequent employers of the Defendant are hereby ORDERED to send checks, for each pay period of the Defendant, in the amount specified in paragraph 1 above, and made payable to Triple Crown Corporation agent for CT Rehabilitation LP to the Office of the Prothonotary at One Courthouse Square, Carlisle, P A 17013, who will then record the amount paid in the docket of this matter and then forward the checks to Triple Crown Corporation, 5351 Jaycee Avenue, Harrisburg, PA 17112. So Ordered, By the Court 15/ d. My ~Luv. i. Pietro Leone. Attorney Triple Crown Corporation, Inc, Page 1 of 1 Attachment Order CT REHABILITATION LP, Plaintiff v. PAUL TIMMONS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 05-3063 CIVIL TERM ORDER OF COURT AND NOW, this 3rd day of January, 2007, upon consideration of Plaintiffs Motion for Contempt of Court, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE at a hearing scheduled for Tuesday, February 13,2007, at 3: 15 p.m., in Courtroom No.1, Cumberland County Courthouse, Carlisle, Pennsylvania. l!f p\e. c.f'Owt.1 Co-f 2ie.h.v Lt::une, .t:sq. -5-351 Jaycee Avenue Harrisburg, P A 17112 Attorney for Plaintiff Paul Timmons 427 Bridge Street J New Cumberland, PA 17070 Defendant, pro se vCDL Consultants 427 Bridge Street New Cumberland, P A 17007 :rc BY THE COURT, V\NVA1ASNN3d AlNnrD (N\1lH3a~ Of: :2 WeI *1- NVr tOOl AtlV10NOH10tld 3HJ. :10 3Ol:Ho-<131ld CT REHABILITATION LP, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. PAUL TIMMONS, Defendant CIVIL ACTION - LAW NO. 05-3063 CIVIL TERM ORDER OF COURT AND NOW, this 13th day of February, 2007, upon consideration of Plaintiff's Motion for Contempt in the above-captioned matter and following a hearing at which the Plaintiff presented evidence in support of its motion, and at which neither Paul Timmons nor his company, CDL Consultants, appeared, Paul Timmons and CDL Consultants are hereby adjudicated in contempt and an attachment is issued for the production In court of Paul Timmons, said attachment to be executed during regular business hours only. By the Court, J. ill oL Jr., J. Pietro Leone, Esquire 5351 Jaycee Avenue Harrisburg, PA 17112 Attorney for Plaintiff Paul Timmons 427 Bridge Street New Cumberland, PA Pro Se 17070 t~~ .:1..).tJ.07 Q-. CDL Consultants 427 Bridge Street New Cumberland, PA 17070 :lfh \1 J !\j\/jYl)\S >,Ji~4:J(! 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