HomeMy WebLinkAbout06-0255COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND 9916--
Ma9 Dist. No..
09-3-04
MDJ Name. Hon.
THOMAS A. PLACEY
Adorers. 104 S SPORTING HILL RD
MECHANICSBURG, PA
Telephone (717) 761-8230 17050
BENT CREEK LIMITED PARTNERSHIP
5351 JAYCEE AVENUE
HARRISBURG, PA 17112
THIS IS TO NOTIFY YOU THAT:
-- Judgment:
® Judgment was entered for:
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
FBENT CREEK LIMITED PARTNERSHIP
5351 JAYCEE AVENUE
HARRISBURG, PA 17112
L
VS.
J
DEFENDANT: NAME and ADDRESS
rSCHRHIBER, MARK
102 MILL WOOD DRIVE
(PARENTS ROME)
LHALIFAE, PA 17032 J
DocketNo.: CV-0000557-05
Date Filed: 10/12/05
err
nRFAULo JUDGMENT DT.TF - -.?
(Name) ARLI'1 s'RRRiC T TllITTRT) DARTNRR QATT+
® Judgment was entered against: (Name) ACA7tRTARR maA>Ir
in the amount of $ '>357 - DO on
? Defendants are jointly and severally liable.
? Damages will be assessed on;
? This case dismissed without prejudice.
? Amount of Judgment Subject to
Attachment/42 Pa.C.S. § 8127 $
E:j Portion of Judgment for physical
damages arising out of residential
lease $
(Date of Judgment) T 2/DR/05
(Date & Time)
Amount of Judgment $
0
3,235.0
Judgment Costs $ 122.00
Interest on Judgment $ .00
Attorney Fees $
0
.0
Total $ 3,357.00
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total --
$ ----------
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PR071-16NOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT 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 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.
I? Date "! • Magisterial District Judge
Ice it at this is a true add Corr of the p(oceedings containing the judgment.
12 CJ Date A Magisterial District Judge
My commission expires first Monday of January, 2010 . SEAL
AOPC 315-05 DATE PRINTED: 12/08/05 10:02:39 AM
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Bent Creek Limited Partnership
5351 Jaycee Avenue
Harrisburg, PA 17112
Plaintiff
Vs
Mark Schreiber
102 Mill Wood Drive
Halifax, PA 17032
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND, COUNTY, PENNSYLVANIA
NO. 06-255
CIVIL ACTION - LAW
PETITION FOR A RULE TO SHOW CAUSE WHY AN ORDER
GRANTING WAGE ATTACHMENT SHOULD NOT ISSUE
AND NOW, comes the Plaintiff, Bent Creek Limited Partnership, 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, Mark Schreiber and the Defendant's employer, Harmon Stoves, 352
Mountainhouse Road, Halifax, PA 17032, in support thereof avers as follows:
1. This matter arises out of a dispute concerning a residential lease.
2. Judgment was entered against the Defendant by District Justice Thomas A. Placey,
Magisterial District 09-3-04 on December 8, 2005 in the amount of $3,235.00, Docket
Number CV-0000557-05. Post judgment costs increased this amount to $3,357.00, which
is shown on the certified judgment.
3. The District Justice Judgment was filed with this Court on January 11, 2006, under Docket
Number 06-255 Civil Term.
4. Reasonable attempt has been made to contact and make payment arrangement to satisfy
Judgment Docket Number CV-0000577-05. No response was received from defendant.
5. The Defendant is currently employed at Harmon Stoves, 352 Mountainhouse Road,
Halifax, PA 17032.
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
rile to show cause against both the Defendant, Mark Schreiber and his current employer,
Harmon Stoves, 352 Mountainhouse Road, Halifax, PA 17032.
Date: /5
Respectfully Submitted:
,Pietro Leone Attorney, PA Bar #85127
5351 Jaycee Avenue
Harrisburg, PA 171 t2
(717)657-5729
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving Plaintiff's Petition For A Rule To Show Cause: Why
An Order Granting Wage Attachment Should Not Issue upon the person and in the manner
indicated below, which service satisfies the requirement of Pa. R.C.P. 440: Service by certified
mail, addressed as follows:
Mark Schreiber
102 Mill Wood Drive
Halifax, PA 17032
Date: I - 1 4? - 116
Respectfully Submitted,
y: Pietro Leone, Attorney
PA Bar #85127
5351 Jaycee Avenue
Harrisburg, PA 17112
717-657-5729
COMMONWEALTH OF PENNSYLVANIA
~ COUNTY OF: CUMBERLAND 66
Mag. Dist. Nor.
09-3-04
a
MDJ Name- Han.
THOMAS A,. PLACEY
Addfe5s 104 S SPORTING HILL RD
MECHANICSBURG, PA
Telephone (717) 761-8230 17050
BENT CREEK LIMITED PARTNERSHIP
5351 JAYCEE AVENUE
HARRISBURG, PA 17112
THIS IS TO NOTIFY YOU THAT:
-- Judgment
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADORESS
FBENT CREEK LIMITED PARTNERSHIP
5351 JAYCEE AVENUE
HARRISBURG, PA 17112
L J
vs.
DEFENDANT: NAMEand ACORESS
?SCHRSIBSR, MARK
102 MILL WOOD DRIVE
(PARENTS HOME)
LHALIFA%, PA 17032
7
?g Judgment was entered for: (Name)
® Judgment was entered against: (Name) S CHEZIHE,s, mARx
in the amount of $ 3, 357 _ nn on:
? Defendants are jointly and severally liable.
Damages will be assessed on:
? This case dismissed without prejudice.
Amount of Judgment Subject to
Attachment/42 Pa.C.S. § 8127 $
? Portion of Judgment for physical
damages arising out of residential .
lease $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS.tkFTER 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.
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 CF 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.
12' `O Z5 Date Magisterial District Judge
I ce Ify that this is a true a d Corr of the p oceedings containing the judgment.
1'2 0?j Date 14 1 , Magisterial District Judge
V 11
My commission expires first Monday of January, 2010 . SEAL
AOPC 315-05 DATE PRINTED: 12/08/05 10:02:39 AM
(Date of Judgment) 12IngIn5
(Date & Time) _
Amount of Judgment $ 3,235.00.
Judgment Costs $ 122.00
Interest on Judgment $ .00
Attorney Fees $ .00
Total $ 3,357.00
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total --
$ ----------
i
._
-,
Bent Creek Limited Partnership
5351 Jaycee Avenue
Harrisburg, PA 17112
Plaintiff
V.
Mark Schreiber
102 Mill Wood Drive
Halifax, PA 17032
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
06-255 CIVIL
ORDER OF COURT
AND NOW, this 1" day of March, 2006, upon consideration of the foregoing
petition, IT IS HEREBY ORDERED AND DIRECTED that:
1. A rule is issued upon the defendant to show cause why the plaintiff is not
entitled to the relief requested;
2. The defendant will file an answer to this petition on or before March 24, 2006;
3. The petition shall be decided under Pa.R.C.P. No. 206.7;
4. If the Defendant files an answer to this Rule to Show Cause, and the answer
raises disputed issues of material fact, an evidentiary hearing shall be held on the 3rtl
day of April, 2006, at 2:30 p.m. in Courtroom No. 5 of the Cumberland County
Courthouse. If no answer to the Rule to Show cause is filed by the required date, the
requested Wage Attachment will be granted.
5. Notice of entry of this order shall be provided to all parties by the Petitioner.
By the Court,
„\ -? L
M. L. Ebert, Jr.,
Pietro Leone, Esquire
Attorney for Plaintiff p
Mark Schreiber
Defendant
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Bent Creek Limited Partnership
5351 Jaycee Avenue
Harrisburg, PA 17112
Plaintiff
Vs
Mark Schreiber
102 Mill Wood Drive
Halifax, PA 17032
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND, COUNTY, PENNSYLVANIA
NO. 06-255
CIVIL ACTION -LAW
PLAINTIFF'S MOTION TO MAKE RULE ABSOLUTE
AND NOW, Pursuant to Pennsylvania Rule of Civil Procedure 206.7, Plaintiff, Bent
Creek Limited Partnership, hereby files this Motion to make Rule Absolute, and in
support of same avers as follows:
1. On February 15, 2006, 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 March 1, 2006, this Honorable Court issued a Rule to Show Cause with a
return on or before March 24, 2006.
3. The Defendant has not answered the Rule.
4. 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,
Harmon Stoves, 352 Mountainhouse Road, Halifax, PA 17032, as well as all current or
subsequent employers.
Respectfully Submitted:
Date: - 6 6
Pietro Leone, Attorney
PA Bar #85127
5351 Jaycee Avenue
Harrisburg, PA 17112
(717) 657-5729
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 of Pa. R.C.P.
440: Service by certified mail, addressed as follows:
Mark Schreiber
102 Mill Wood Drive
Halifax, PA 17032
Harmon Stoves
352 Mountainhouse Road
Halifax, PA 17032
Respectfully Submitted,
Date: ( 3 " 0 (0
By: Pietro Leone, Attorney, PA Bar #85127
5351 Jaycee Avenue, Harrisburg, PA 17112
717-657-5729
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ECEIVED APR 07ltml
Bent Creek Limited Partnership IN THE COURT OF COMMON PLEAS
5351 Jaycee Avenue CUMBERLAND, COUNTY,
PENNSYLVANIA
Harrisburg, PA 17112
Plaintiff
Vs NO. 06-255
Mark Schreiber
102 Mill Wood Drive CIVIL ACTION - LAW
Halifax, PA 17032
Defendant
ATTACHMENT ORDER
AND NOW, this ?1? day of o 2006, upon consideration of the
foregoing Petition for A Rule to Show Why An Order Granting Wage Attachment Should Not
Issue, no response being filed by the Defendant, Mark Schreiber, and the Defendant's employer,
Harmon Stoves, 352 Mountainhouse Road, Halifax, PA 17032, it is hereby ORDERED AND
DECREED as follows:
1. The Defendant's current employer, Harmon Stoves, 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 $3,357.00.
3. The Defendant's current employer, Harmon Stoves, 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 Bent Creek Limited Partnership 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, PA 17112.
oar
So Ordered, By the Court
nn io?
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Bent Creek Limited Partnership
5351 Jaycee Avenue
Harrisburg, PA 17112
Plaintiff
Vs
Mark Schreiber
102 Mill Wood Drive
Halifax, PA 17032
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND, COUNTY, PENNSYLVANIA
NO. 06-255
CIVIL ACTION - LAW
Praecipe for Re-Issue of Writ of Attachment of Wages, Salary or Commissions
To the Prothonotary:
Re-Issue a Writ to Attach Wages, Salary or Commissions in the above matter
(1) The Plaintiff Triple Crown Corporation was issued a judgment on the Defendant dated December 8, 2005,
Plaintiff then petitioned the court to issue an order dated April 3, 2006 to the Defendant's Employer to
attach the Defendants wages.
(2) The Plaintiff now respectfully requests that the Defendant's present employer Herre Bros. attach the
Defendants wages.
Date: f ,.'n0? '` -
Pietro Leone, Attorney, PA r 485127
5351 Jaycee Avenue
Harrisburg, PA 17112
(717)657-5729
v ?
Bent Creek Limited Partnership
5351 Jaycee Avenue
Harrisburg, PA 17112
Plaintiff
Vs
Mark Schreiber
102 Mill Wood Drive
Halifax, PA 17032
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND, COUNTY, PENNSYLVANIA
NO. 06-255
CIVIL ACTION - LAW
ATTACHMENT ORDER
AND NOW, this 'k" day of , 2007, upon consideration of the foregoing
Petition for A Rule to Show Why An Order Granting Wage Attachment Should Not Issue, no response
being filed by the Defendant, Mark Schreiber, and the Defendant's employer, Herre Bros, Inc, 4417
Valley Road, Enola, PA 17025, it is hereby ORDERED AND DECREED as follows:
1. The Defendant's current employer, Herre Bros., 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 $3,357.00 less payments of $590.48 leaving a balance due
of $2,766.52.
3. The Defendant's current employer, Herre Bros., 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 Bent Creek Limited Partnership 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, PA 17112.
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So Ordered, By the Court
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Bent Creek Limited Partnership
5351 Jaycee Avenue
Harrisburg, PA 17112
Plaintiff
Vs
Mark Schreiber
102 Mill Wood Drive
Halifax, PA 17032
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND, COUNTY, PENNSYLVANIA
NO. 06-255
CIVIL ACTION - LAW
Praecive for Re-Issue of Writ of Attachment of Wages, Salary or Commissions
To the Prothonotary:
Re-Issue a Writ to Attach Wages, Salary or Commissions in the above matter
(1) The Plaintiff Triple Crown Corporation was issued a judgment on the Defendant dated December 8, 2005,
Plaintiff then petitioned the court to issue an order dated April 3, 2006 to the Defendant's Employer to
attach the Defendants wages.
(2) The Plaintiff now respectfully requests that the Defendant's present employer Herre Bros. attach the
Defendants wages.
Date: l - ?-3 O/V /V-Pietro Leone, Attorney, PA Alf "05127
5351 Jaycee Avenue
Harrisburg, PA 17112
(717)657-5729
clc?
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Bent Creek Limited Partnership IN THE COURT OF COMMON PLEAS
5351 Jaycee Avenue CUMBERLAND, COUNTY, PENNSYLVANIA
Harrisburg, PA 17112 :
Plaintiff
Vs NO. 06-255
Mark Schreiber :
102 Mill Wood Drive CIVIL ACTION - LAW
Halifax PA 17032
Defendant
Praecipe to Enter Appearance for Plaintiff
1. Kindly enter the appearance for Mark X. DiSanto, Attorney, PA Bar #51090.
To: Court of Common Pleas Prothonotary
? --ZO -off
Date
Mark X. DiSanto, PAS
5351 Jaycee Avenue
Harrisburg, PA 17112
717-657-5729
111.-/-
Fit D-1 -I
CAF TI 'F P,,-,; 2909 APR 23 PH 2: 3 2
Bent Creek Limited Partnership
5351 Jaycee Avenue
Harrisburg, PA 17112
Plaintiff
Vs
Mark Schreiber
102 Mill Wood Drive
Halifax PA 17032
Defendant
1. Judgment is paid in full.
2. Please satisfy this judgment.
To: Court of Common Pleas Prothonotary
4 - 2'?- Oq
Date
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-255
CIVIL ACTION - LAW
Praecipe to Satisfy Judgm
Mark X. DiSanto, PA-1
5351 Jaycee Avenue
Harrisburg, PA 17112
717-657-5729
1090
FILIE-I-O"r GE -TA
F.
THE 2009 APR 23 PH 2: 3 2