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Home My WebLink About01-4283 LAW OFFICE OF PATRICK LAUER 2108 Market Street Camp Hill, PA 17011 Plaintiff V. LEE & SARA V ANASDLEN 16 Hill Road P. O. Box 636 Carlisle, P A 17013 Defendant TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0\ - 4:lfJ c,u~l c,-~ PRAECIPE Please enter Judgment in the amount of $437.50, plus costs, against Lee and Sara Vanasdlen as per the attached Notice of Judgment/Transcript Civil Case. Date: l \ I C' \"'>1 C" ... (~ nf/ '., ... '.. . .."\. " -. By:.\'( t ~\0 ... :t J.,(}\ Charles Rector, Esquire 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY 6F: CUMBERLAND 09-3-02 NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 'rAw OFFICE OF PATRICK LAUER I 2108 MARKET STREET CAMP HILL, PA 17011 L ~ Mag. Dist. No.. OJ Name: Hon. HELEN B. SHULENBERGER Address P.O. BOX 155 27 W. BIG SPRING AVENUE NEWVILLE, PA Telephone (717) 776 - 3187 17241 VS. CHARLES RECTOR, ESQ. 1104 FERNWOOD AVENUE APT.# 203 CAMP HILL, PA 17011-6912 DEFENDANT: NAME and ADDRESS lVANASDLEN, LEE, ET AL. 16 HILL ROAD CARLISLE, PA 17013 L Docket No,: CV- 0000056 - 01 Date Filed: 4/18/01 I ATTORNEY FOR PLAINTIFF : ~ THIS IS TO NOTIFY YOU THAT: Judgment; __,DEFAUL'l' JUD.GMENT_..PL'J'~_____._.______________ [i] Judgment was entered for: (Name) T.AW OFFTCR OF PA'1'RTCK T.ATTRR [i] Judgment was entered against: (Name) VANASDT.RN', T.ER in the amount of $ 437 ~O on; (Date of Judgment) ~/2q/01 D Defendants are jointly and severally liable. D Damages will be assessed on; D This case dismissed without prejudice, (Date & Time) Amount of Judgment Subject to Attachment! Act 5 of 1996 $ Amount of Judgment $ 385.00 Judgment Costs $ 52.50 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 437.50 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ D o D Levy is stayed for days or D generally stayed. Objection to levy has been filed and hearing will be held: I:::. 11 Place I 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 THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COpy OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. .,! .... date /' , District Justice I certify that this is a true and correct copy of the record of the proceedings containing the judgment. 1'-"3--0) Date ~ (? ~~ , District Justice My commission expires tirst Monday at January, AOPC 315-99 2006 SEAL COMMONWEALTH OF PENNSYLVANIA CCiUNTY 6F: CUMBERLAND .. . 09-3-02 NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 'rAw OFFICE OF PATRICK LAUER \ 2108 MARKET STREET CAMP HILL, PA 17011 L ~ Mag. Dls!. No.. . DJ Name: Hon. HELEN B. SHULENBERGER Address P.O. BOX 155 27 W. BIG SPRING AVENUE NEWVILLE, PA Telephone (717) 776-3187 17241 VS. CHARLES RECTOR, ESQ. 1104 FERNWOOD AVENUE APT.# 203 CAMP HILL, PA 17011-6912 DEFENDANT: NAME and ADDRESS fVANASDLEN, LEE, ET AL. 16 HILL ROAD CARLISLE, PA 17013 L Docket No,: CV- 0000056 - 01 Date Filed: 4/18/01 \ ATTORNEY FOR PLAINTIFF ~ THIS IS TO NOTIFY YOU THAT: Judgment: .__~~__._~~ _DE.F.AI1LT..-J!lDf'2.MENT PLTF [iJ Judgment was entered for: (Name) T.AW OFFTCF. OF PATRTCK T.ATT~R [i] Judgment was entered against: (Name) VANASDT.F.'N, SARA in the amount of $ 417 ~O on: (Date of Judgment) ~ I?q 101 .. .. D D D o D D Defendants are jointly and severally liable, (Date & Time) Amount of Judgment Subject to Attachment/Act 5 of 1996 $ Amount of Judgment $ 385.00 Judgment Costs $ 52.50 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 437.50 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ Damages will be assessed on: This case dismissed without prejudice. Levy is stayed for days or D generally stayed, Objection to levy has been filed and hearirigWill be held: I Date Time: 11 Place ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/S~ERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COpy OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. t.. """// hate I. ,; , District Justice I~Gerti~ that this Is a tru~orrect ccpy of the record of the proceedings containing the judgment. ~ '/ ~ QI Date g ~FJv' ~ , District Justice My commission expires first Monday of January, 2006 SEAL AOPC 315-99 LAW OFFICE OF PATRICK LAUER 2108 Market Street Camp Hill, PA 17011 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : NO. 01-4283 CIVIL TERM LEE & SARA V ANASDLEN 16 Hill Road Carlisle, P A 17013 Defendant : CIVIL JUDGMENT PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, (1) directed to the Sheriff of Cumberland County; (2) against Lee & Sara Vanasdlen, Defendants; and (3) against , Garnishee; (4) and index this writ (a) against Lee & Sara Vanasdlen. Defend~n~s...... ....J... , ~ 40'1 aveL 'aLL~~ ?,~~. (b) against , Garnishee, as a lis pendens against real property of the Defendant in name of Garnishee as follows: NI A (5) Amount of Judgment Attorney Fees Total $ 437.50 $ 150.00 $ 587.50 (plus costs) Date:1\n \0\ (' t.. ~. /~ .f :t . .. ',\, \-..J - ~ .... BY: ~l\..,' 0 \::Xd.-U{ Charles Rector, Esquire ID# 39121 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 - ~ ~ ~~ ~ :f4.~ '2 8 '( ~ r ""6Q. ~ W \\.~-" _ )l"J. ~ . . ~. ~l cg V) 8 \ I . " , ~~ ~ ~~ ~Ef - +- t.;[ \ .F-~ ~~~ f v -- -- <..-\ ~ .::::::Y 0" t,',J <:) ~ ..... ? LAW OFFICE OF PATRICK LAUER: IN THE COURT OF COMMON PLEAS 2108 Market Street CUMBERLAND COUNTY, PENNSYLVANIA Camp Hill, PA 17011 Plaintiff/Petitioner v. LEE & SARA V ANASDLEN 16 Hill Road Carlisle, PA 17013 Defendants/Respondents ~ AND NOW, this1!1 day of NO. 2<1gg ~J 2000 oj - 4:13'3 E , 2001, upon consideration of Plaintiff's Motion to Direct Sheriff to Bre and Enter Premises and to Effect Personal Property Levy, a Rule is hereby issued upon Respondents to show cause, if any, why the requested relief should not be granted. RULE RETURNABLE ten (10) days following service of this Rule upon Respondent. BY THE COURT: J. ~ ~ 0').\,0 I , ,,'I,,",\C,.r'\-::!" \h\".:.t\ \/'\:)\''''j.l'>(-''"-~ J' ,I' .' ~c".,\.""<l \ ,.,'r"........l(." ,.(""..,' ,'(."~\ t..... 1',:)',\ 'I. .) . ::0 \ :r, J d ~d~,;}j.L-. 1 .,,; ---------.-. \ _, "", I. f' (; d,'):::> ~~ \,) LEE & SARA V ANASDLEN 16 Hill Road Carlisle, P A 17013 Defendants MOTION TO DIRECT THE SHERIFF TO BREAK AND ENTER PREMISES TO EFFECT PERSONAL PROPERTY LEVY AND NOW, comes the Plaintiff, Law Office of Patrick Lauer, by and through their attorney, Charles Rector, Esquire, and files the within Motion to Direct the Sheriff to Break and Enter to Effect Personal Property Levy: 1. Plaintiff is a judgment creditor of the Defendants in the above-matter. 2. A Writ of Execution was issued by the Prothonotary of this Court and delivered to the Sheriff, whose deputy was refused admittance to the premises to conduct the levy in obedience of said Writ of Execution. 3. The Sheriffs office advised counsel for Plaintiff on August 14, 2001, that unless the Sheriff is Ordered by the Court to break and enter the said premises, the Sheriff will be unable to make a valid levy by viewing the personal property, Defendant will be enabled to obstruct the lawful process of this Court via its Writ of Execution and Plaintiff will be frustrated in its efforts to enforce its judgment. 5. The refusal to admit the deputy Sheriff was a willful, vexatious, dilatory and obdurate attempt to obstruct the service of the lawful process of this Court. 6. Plaintiffs counsel has expended two hours in preparing, filing and attending to this Motion and counsel's ordinary, usual and customary hourly rate for the same is $150.00. WHEREFORE, Plaintiff respectfully urges this Court to Order the Sheriff of Cumberland County to break and enter Defendants' premises as soon as possible for the purpose of conducting a personal property levy and award $300.00 attorney's fees to Plaintiff as costs. RESPECTFULLY SUBMITTED, \ ~ Cl\C1\~( Charles Rector, Esquire 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Attorney for Plaintiff Date: ~ CERTIFICATE OF SERVICE IJ ~ I, Charles Rector, Esquire, do hereby certify that on the '1 day of September, 2001, I caused a true and correct copy ofthe within Motion to be served upon the following individuals by depositing same in first class, United States mail, postage paid, in Camp Hill, Pennsylvania: Lee & Sara Vanasdlen 16 Hill Road Carlisle, PA 17013 Date 9/4Jo) fi n/J" /5' By: ~ W~ Charles Rector, Esquire 1104 Femwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 (A "" ~ + U\ o r. . i w vJ -t: ~ S Cl . ..,