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HomeMy WebLinkAbout05-5566 The Law Firm of May & May, P.c. Robert C. May, Esquire 10# 65602 4330 Carlisle Pike CampHill,PA 17011 717-612-0102 717-612-0103 (Fax) &d-c ~ CAREY ASSOCIATES, me., 542 Bridge Street New Cumberland, PA 17070, Commonwealth of Pennsylvania Plaintiff, v. JOHN P. LEISEY and CAROL A. LEISEY, 153 Tory Circle Enola, PA 17025, County of Cumberland Defendants. Docket No. 0)-- 6"j-G ~ ~ PRAECIPE FOR ENTRY OF APPEARANCE, TRANSFER OF JUDGMENT, ASSESSMENT OF DAMAGES, AND VERIFICATIONS OF ADDRESS, VALIDITY, AND NONMILITARY SERVICE $8,709.00 Judgment Due Interest at 6% from 8/25/05 Costs TO THE PROTHONOTARY: Enter my appearance for the plaintiff in the above matter; enter judgments in favor of plaintiff against defendants on the duly authenticated copy of the judgment contained in the docket entries hereto attached, entered in the jurisdiction noted therein, and assess damages as follows: + + Pursuant to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, I verify that: (I) the precise last known addresses ofthe plaintiff and defendants are as listed above; (2) said judgment was entered in the said jurisdiction in said amount with costs and interest due as noted, no part of which has been paid (except as noted) and which are valid, enforceable, and unsatisfied; (3) and defendants are over 18 years of age and not in the military service of the United States or its allies or otherwise within coverage of the Soldiers and Sailors Relief Act of 1940, as amended, and have civilian occupations. ~ JSt~ c . 1'171!J1/ Robert C. May, Esquire ~ JUDGMENT SO ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GNE UNDER PA. iV.P.236. , ]n \!roe Q[ourt of Q[ommon ~lea~ of 1lBaupoin Q[ountp, ~enn~pllJania Carey Associates Ine VS. No. 2005-CV-2802-CV John P Leisey Carol A Leisey CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT I, the undersigned Prothonotary of the Court of Common Pleas of Dauphin County, Pennsylvania, do hereby certify that the attached is a full, true and correct copy ofthe docket entries in the above captioned case. JUDGMENT $8709.00 Sheriff $67.00 Attorney Due $3.00 Plaintiff Paid $121.00 Prothy. Due $8.75 This record $17.50 I further certify that judgment was entered in favor of CAREY ASSOCIATES, INC. and against JOHN P. and CAROL A. LEISEY on AUGUST 25, 2005 in said case in the amount of $8,709.00 lln tEtlltimonr Wl)trtof. I have hereunto set my hand and affixed the seal of the Court, on Tuesday, October 11, 2005. ) . c? 0-/ . (1j~rJ orn_-Y-Q.Iu/)')Q.., Protho~otary BY:c&..~~~... ~""...~ ~~~.~ Deputy Dauphin County Complete Case History Case: 2005-CV-2802-CV Carey Associates 'nc vs. John P Leisey, etal. _~..... r VI. I/~UU5 ime: 09:12 AM age 1 of 2 Filed: Subtype: 717/2005 Civil Comment: Judge History Date 7/7/2005 Judge No Judge, Payments May & May :xemplified Record May, Robert C (attorney for CarE Miscellaneous Receipts Receipt Date 90654 10/11/2005 Plaintiff Name: Address: Receipt 90654 17.50 84094 87721 Physical File: Y Date 10/11/2005 7/712005 8/25/2005 Exemplified Record Carey Associates Inc Phone: Home: Employer: Litigant Type: Comment: !l.ttorneys May, Robert C lefendant Name: Leisey, John P Address: Phone: Home: Employer: Litigant Type: Comment: Work: Appealed: N Reason for Removal Current Type Miscellaneous Civil Filing Civil Filing Total 17.50 Sum: SSN: DOB: Sex: Send notices: Y (Primary attorney) Send Notices Work: SSN: DOB: Sex: Send notices: Y User: SKOVACH Amount 17.50 105.00 16.00 138.50 17.50 Register of Actions 7/7/2005 New Civil Case Filed This Date. Plaintiff: Carey Associates Inc Attorney of Record: Robert C May Filing: Complaint Paid by: May, Robert C (attorney for Carey Associates Inc) Receipt number: 0084094 Dated: 7/7/2005 Amount: $105.00 (Check) 7/22/2005 Complaint: Sheriffs Return filed stating service was completed. So answers J.R. Lotwick, Sheriff. John P Leisey Assigned to Dauphin Co Sheriffs Office Service fee $67,00 Served 7/22/2005 Complaint: Sheriffs Return filed stating service was completed. So answers J.R. Lotwick, Sheriff. Carol A Leisey Assigned to Dauphin Co Sheriffs Office Service fee $0.00 Served 7/22/2005 10 Day Notice filed Filing: Judgment Paid by: May, Robert C (attorney for Carey Associates Inc) Receipt number: 0087721 Dated: 8/25/2005 Amount: $16.00 (Check) Default Judgment is entered in favor of Plaintiff and against Defendants in the amount of $8,709.00 for failure to answer Plaintiffs Complaint. See Praecipe & Notice filed. Copies of All Documents mailed. uarc: 10/41/2005 Time: 09:12 AM Page 2 of2 Defendant Name: Address: Phone: Employer: Litigant Type: Comment: 8/12/2005 8/25/2005 ludgment Order date 08/25/2005 Comment: Dauphin County Compiete Case History Case: 2005-CV-2802-CV Carey Associates Inc vs. John P Leisey, etal. User: SKOVACH Leisey, Carol A SSN: DOB: Sex: Home: Work: Send notices: Y No Judge, No Judge, No Judge, No Judge, No Judge, No Judge, No Judge, No Judge, In Favor Of Plaintiff 8709.00 Disposition 08/25/2005 Open Judgment Default Carey Associates Inc Leisey, Carol A leisey, JoM P ::)r~~~< \ \ ~'S . reby certify that the foregoing is a ! and correct IY tt ~riginal filed. k,,~ . ^) ..,,""~, honotary/Clerk of Courts . Plaintiff: Defendant: __ V"'- ~ .S0 2~ ~ ~:..\ ~.~\ .....' ~ .--- ~ --' ,,1>-. r<':' _r1 ~~ - ,. . .--." .,. ~ G , c- c.- '- \" s y N C. '-", q ........-., ~\ - ~ The Law Firm of May & May, P.c. Robert C. May, Esquire ID# 65602 4330 Carlisle Pike Camp Hill, PA 17011 717-612-0102 717-612-0103 (Fax) ;tt~ff C /fIllv(. CAREY ASSOCIATES, INe., 542 Bridge Street New Cumberland, P A 17070, Commonwealth of Pennsylvania Plaintiff, v. JOHN P. LEISEY and CAROL A. LEISEY, 153 Tory Circle Enola, PA 17025, County of Cumberland Defendants. Docket No. (;f) - 5)~~ ~ PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue a Writ of Execution in the above matter directed to the Sheriff of Cumberland County; Against John P. Leisey and Carol A. Leisey, defendants; and Index this Writ against John P. Leisey and Carol A. Leisey, defendants; Judgment Due: Interest to Date from 8/25/05: Costs Paid (prothonotary): Sheriff: Statutory: Costs Due: $ 8,709.00 The Sheriff should be instructed to execute against household goods and personal property of the defendants at the address for the defendants set forth above. &.1~ C .1/Inf.. Ro ert C. May, squIre ~~ ~. <;?f \ S? - ~ ~~ --- ,...j~ G~ 'Y y- oN '-"'\ --l - u'- ~ Cl '<:l'. ".. o -:...) -I ~ @ C' ,-\ ?'-v d' - .,.;. <....5"\ 0-'S U'-\ ~, 6 - -------- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5566 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAREY ASSOCIATES, INC. Plaintiff (s) From JOHN P. AND CAROL A LEISEY, 153 TORY CIRCLE, ENOLA I'A 17025. (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY AGAINST HOUSEHOLD GOODS AND PERSONAL PROPERTY. (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 gamishee(s) 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: (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 heishe has been added as a garnishee and is enjoined as above stated. Amount Due $8,709.00 Interest FROM 8/25/05 Atty's Comm L.L. $.50 % Due Prothy $ 1.00 Other CostsDAUPHIN CO COSTS - $199.75 Atty Paid $35.00 Plaintiff Paid Date: OCTOBER 27, 20205 (Seal) c~~ Prothonotary By: Deputy REQUESTING PARTY: Name ROBERT C. MAY, ESQ. Address: 4330 CARLISLE PIKE CAMP HILL PA 17011 Attorney for: PLAINTIFF Telephone: (717) 612-0102 Supreme Court ID No. 65602 ~l ,I "\ CAREY ASSOCIATES, INC. PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY v. NO. 2005-5566 JOHN P. LEISEY and CAROL A. LEISEY, DEFENDANTS CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please strike the judgment without prejudice and remove the complaint without prejudice as to Defendant John P. Leisey, but leave the judgment and complaint as to Carol A. Leisey, on account that unbeknownst to Plaintiff or Plaintiffs counsel, John P. Leisey, but not Carol A. Leisey, filed for bankruptcy two days prior to the filing of the complaint. Accordingly, the judgment entered on August 25, 2005, must be amended so that John P. Leisey is removed from the general docket, judgment index and papers filed of record, which shall now read: CAREY ASSOCIATES, INC., Plaintiff v. CAROL A. LEISEY, Defendant The prothonotary is authorized to change the records, dockets, index and other papers so as to conform to the above. Respectfully Submitted: THE LAW FIRM OF MAY & MAY, P.C. 4330 Carlisle Pike Camp Hill, Pennsylvania 17011 (717) 612-0102 Attorneys for Plaintiff (_~t By: obert C. May, Esquire Identification No.: 65602 DATED: January II, 2006 c_ ....:J i:-i c.; fn CERTIFICATE OF SERVICE I, Robert C. May, Esquire, an attorney with The Law Firm of May & May, P.C., hereby certify that I have served a true and correct copy of the foregoing PRAECIPE, on behalf of the Plaintiff, Carey Associates, Inc., to the following individual by depositing a true and correct copy of the same in the United States mail, postage prepaid, first class mail, addressed as follows: John M. Hyams, Esquire CUNNINGHAM & CHERNICOFF, P.C. P.O. Box 60457 Harrisburg, P A 17106-0457 ROBERT C. MAY, ESQUIRE Dated: January 11, 2006 ~ .,tC AJAJ! Signatur : \--ej,1 1/ ICfiv Robert C. May, Esquire /I ~~ --- <i)::!. -S;o ~ ~ ~'0 c----. h""> I..N ;:-t: ~~ ~ 'ii' u'\ ." C=' C) (.,,~ --~ (c.~ C') c~~ (J1 (,.;"; ~. -, c;<, R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL -', -...... c...,j ("--""; C.: c",; l.)) fi:...,. '/5# t01', " c,' I II II .~t. ~ 18.00 1.28 Advance Costs: 150.00 Sheriff s Costs 65.18 84.82 .50 1.00 14.40 Refunded to Atty on 06/29/06 30.00 65.18 / Cf- 7//)5/1J~ So Answers' ~~-.,~~ R. Thomas Kline, Sheriff BY~ u..uA: "- ~~V c ~ ~ t"' (' \ It 1: , ,,:)! &"U I. ~ ck.- 7f'fc.,,:> 'i R.t.,. J 'J 97 3 'f WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5566 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAREY ASSOCIATES, INC. Plaintiff (s) From JOHN P. AND CAROL A LEISEY, 153 TORY CIRCLE, ENOLA P A 17025. (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY AGAINST HOUSEHOLD GOODS AND PERSONAL PROPERTY. (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 of the 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 he/she has been added as a garnishee and is enjoined as above stated. Amount Due $8,709.00 Interest FROM 8/25/05 Atty's Comm L.L. $.50 % Arty Paid S?\l fro Plaintiff Paid Date: OCTOBER 27, 20205 COSTS - $199.75 (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name ROBERT C. MAY, ESQ. Address: 4330 CARLISLE PIKE CAMP HILL P A 17011 Attorney for: PLAINTIFF Telephone: (717) 612-0102 Supreme Court ID No. 65602