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HomeMy WebLinkAbout06-1243 J, SCOTT WATSON, p,c. BY: J, SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff DREXEL UNIVERSITY 32,d & Chestnut Streets Philadelphia, P A 19107 CUMBERLAND COUNTY COURT OF COMMON PLEAS v, ()&, - J..)Lp, Cu->~L~~ ROBERT S. EPPLEY, JR. 1131 Pine Road Carlisle, P A 17013 PRAECIPE Kindly docket the attached Judgment in the amount of$1 ,426.21 in favor of Plaintiff, Drexel University, and against the Defendant, Robert S. Eppley, Jr., for execution purposes only. ~,.;-........" --~ ~ /(~// J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff . COMMONWEALTH OF PENNSYLVANIA COUNTY OF PHILADELPHIA PHILADELPHIA MUNICIPAL COURT LOUIS J. PRESENZA, PRESIDENT JUDGE CERTIFICATION OF JUDGMENT 1~199-05-17-01486 II PLAINTIFF(S) DEFENDANT(S) Drexel University 32nd & Chestnut Street Philadelphia, PA 19104 Robert S, Eppley, Jr, 1131 Pine Road Carlisle, PA 17013 THIS IS TO NOTIFY YOU THAT: [JIJUDGMENT: For Plaintiff by Default I [JIJUDGMENT WAS ENTERED IN FAVOR OF: Drexel University I [J I JUDGMENT WAS ENTERED AGAINST: Robert S, Eppley, Jr, I [J I IN THE AMOUNT OF: $1,426,21 II DATE OF JUDGMENT: May 16, 2005 I I AMOUNT OF JUDGMENT II $1,426,21 I I JUDGMENT COSTS II I I INTEREST OF JUDGMENT II I I A lTORN EY FEES II I I TOTAL II $1,426,21 I I POST JUDGMENT CREDITS II I I POST JUDGMENT COSTS II I CERTIFIED JUDGMENT II $1,426,21 I TOTAL ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENTS BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY OF THE COURT OF COMMON PLEAS, CIVIL DIVISION, YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT FORM WITH YOUR NOTICE OF APPEAL, CERTIFIED FROM THE RECORD ON: BY: JOSEPH H. EVERS PROTHONOTARY OF PHILADELPHIA COUNTY ZX35 MCV1 99-05-17-14860 SC 400 DISPOSED ISSUE AMT, FEE INCIDENT A/DF i360,71 13 SC TYPE COMERCIAL PAPER M,V, ---- NEXT HEARING ----- ******** PLAINTIFF I~FORMATION DREXEL UNIVERSI TY 32ND & CHESTNUT ST PHILA. PA 19104 ~';:"I,'1("le * 1'1; * ******** DEFENDANT INFORMATION EPPLEY ROBERT 1131 PINE RD CARLISLE PA 17013 1'r1'r*"C"C'f(* S ATTY 077687 COPPERTHWAITE WILLIAM C 0 U R T ACT I V I T Y HEARING #01 07/12/99 4A JUDG 379 BLASI DISP 60-NO SERVICE RELISTMENT 03/02/05 HEARING #01 05/16/50 00 JUDG 273 PRESENZA FINE+COST 1426,21 JUDG FOR PL DISP 61-JUDG FOR PL DEFLT 1426,21 *** PRESS ENTER FOR PAGE 1 INFORMATION P/1 J, SCOTT WATSON, p,c. BY: J. SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff DREXEL UNIVERSITY 32nd & Chestnut Streets Philadelphia, P A 19107 CUMBERLAND COUNTY COURT OF COMMON PLEAS v. ROBERT S. EPPLEY, JR, 1131 Pine Road Carlisle, PA 17013 AFFIDAVIT OF NON-MILITARY SERVICE, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND The undersigned, being duly sworn according to law, deposes and says that the Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions ofthe Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; that Defendant, Robert S. Eppley, Jr., is over eighteen (18) years of age, and resides at 1131 Pine Road, Carlisle, Pennsylvania 17013. -----. ,.,'"" -- ') G-.~' J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS j,ilT!, DAY OF COMMONWEALT~ OF PENNSYLVANIA NOTARIAL SEAL ] BRYAN W. SCHULTZ. Notary Public Concord Twp., Delaware Count My Commission Expires June 10, :r006 NOTARY J. SCOTT WATSON, p,c. BY: J, SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff DREXEL UNIVERSITY 32"d & Chestnut Streets Philadelphia, PA 19107 v. ROBERT S. EPPLEY, JR. 1131 Pine Road Carlisle, P A 17013 CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT 1,1. Scott Watson, Esquire, hereby certifies that the debt in the above matter is valid, enforceable and unsatisfied to date, SWORN TO AND SUBSCRIBED BEFORE ME THIS Z vi rh DAY OF NOTARY -......---,:..-.-~) ------ /-/-- - -' ;-"2 ) ~. L___?-----..___ J, SCOTT WATSON, ESQUIRE Attorney for Plaintiff COMMONWEAL Tt-I OF PENNSYLVANIA NOTARIAL SEAL J BRYAN W. SCHULTZ, Notary Public Concord Twp., Delaware Count My Commission Expires June 10, ~OO6 J. SCOTT WATSON, P,C. BY: J, SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff DREXEL UNIVERSITY 32"d & Chestnut Streets Philadelphia, PA 19107 CUMBERLAND COUNTY COURT OF COMMON PLEAS v. ROBERT S, EPPLEY, JR. 1131 Pine Road Carlisle, P A 17013 AFFIDAVIT I, 1. Scott Watson, Esquire hereby certifies that the name and the last krlown address of Plaintiff and Defendant are as stated below: Plaintiff: Drexel University 32"d & Chestnut Streets Philadelphia, P A 19107 Defendant: Robert S. Eppley, Jr. 1131 Pine Road Carlisle, P A 17013 L~7'5'---) J, SCOTT WATSON, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 2'1 11, DAY ;;lV/1 ? ,/ COMMONWEAL TI-' OF PENNSYLVANIA NOTARIAL SEAL BRYAN W. SCHULTZ, Notary Publil: Concord Twp., Delaware County Mv Commission Expires June 10, 2006 OF NOTARY J. SCOTT WATSON, P.c. BY: J, SCOTT WATSON, ESQUIRE Identification Number 41060 24 Regency Plaza Glen Mills, Pennsylvania 19342 (610) 358-9600 Attorney for Plaintiff DREXEL UNIVERSITY 32nd & Chestnut Streets Philadelphia, PA 19107 v. BRYAN FURLAN 585 Highland Street Steelton, P A 17113 CUMBERLAND COUNTY COURT OF COMMON PLEAS AFFIDAVIT OF NO APPEAL I, ], Scott Watson, Esquire, hereby certifies that the District Court judgement in the above matter was not appealed into a higher court to date, SWORN TO AND SUBSCRIBED BEFORE ME THIS 2...JTh DAY OF hili/Ar j 2005. ,/~ NOTARY .~.-.. .._--~, ' ,~------), "/ ,-,) ..~ L. . J. SCOTT WATSON, ESQUIRE Attorney for Plaintiff ~~ (.) -t4 (-" 1'~ ~ .. \) ~..,_.. . .~l \) \ --- 9J ( -, \' --:t C> C" ~ ~ -J 0 <-0 i- ~ j \l If=- .. ~ V1. .-< \lS ~ B (.~ ~ ~ -r-- ---.r... OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY TO: Robert S, Eppley, Jr. 1131 Pine Road Carlisle, PAl 70 13 DREXEL UNIVERSITY 32nd & Chestnut Streets Philadelphia, P A 19107 CUMBERLAND COUNTY COURT OF COMMON PLEAS v, ROBERT S. EPPLEY, JR, 1131 Pine Road Carlisle, P A 17013 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. !!'7 t ' ; . PRofHO~ I JUDGMENT BY DEF AUL T ~ MONEY JUDGMENT JUDGMENT IN REPLEVIN JUDGMENT FOR POSSESSION If you have any questions concerning this Judgment, please call J. Scott Watson. Esquire at 6 I 0-358-9600 . ,.~ . " .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: DREXEL UNIVERSITY 32nd & Chestnut Streets Philadelphia, PA 19107 ( ) Confessed Judgment ( X) Other vs, ROBERT S. EPPLEY, JR. 1131 Pine Street Carlisle, PA 17013 File No, Amount Due 06-1243 1,426,21 Interest from 78.74 5/16/05 Atty's Comm Costs 20.00 TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended, Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) All contents of Defendant's residence, including but not limited to all furniture, clothing, jewelry, electronic equipment, electrical appliances, kitchen utensils, silverware, televisions, tools and any other property subject to levy. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s), o (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. ~~~' Signature: ~ ~ Date Print Name: Address: J. Scott Watson, Esquire Attorney for: 24 Regency Plaza Glen Mills, PA Plaintiff 19342 Telephone: 610-358-9600 Supreme Court 10 No.: 41060 (over) .-' Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR,C,P, No, 3129). If lengthy persenalty list, supply four copies of list. To index writ, file separate praecipe with writ. ~ ::.;... ~ ~ ~ 1".. t} ~ ~ !:t. .~ ~ ~~ () ~ L d ~ V( '? 0 () (') '" -- c.: <=> ~ ~ () = ~ l:>- e 0 D- <- "'" ~ '1:1""",- ::rz: nlX:t i 'lrtr :> t'- I I ) Z::r, -< Z'; 6" (- enS I f\ >-J f) ~U -<';' CD ~ -t: ~ r .... ~f> " .... PC' -0 " !:tr- 7~ ' ~2 ::rz: t5 [ . ~ :z ~ , , fJ:::) ,~ - 'V"f:. N -< ~ ' ~""'- ~' ('""0. . WRIT OF EXECUTION and/or ATTACHMENT .)~' , COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1243 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY, To satisfy the debt, interest and costs due DREXEL UNIVERSITY, Plaintiff (s) From ROBERT S, EPPLEY, JR., 1131 PINE STREET, CARLISLE, PA 17013 (I) You are directed to levy upon the property of the defendant (s)and to sell ALL CONTENTS OF DEFENDANT'S RESIDENCE, INCLUDING BUT NOT LIMITED TO ALL FURNITURE, CLOTIDNG, JEWELRY, ELECTRONIC EQUIPMENT, ELECTRICAL APPLIANCES, KITCHEN UTENSILS, SIL VERW ARE, TELEVISIONS, TOOLS AND ANY OTHER PROPERTY SUBJECT TO LEVY . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follow", 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $1,426,21 Interest FROM 5/16/05 - $78.74 Atty's Comm % Atty Paid $37,50 Plaintiffpaid Date: MAY 8, 2006 L.L. $,50 Due Prothy $1.00 Other Costs ~TIS . (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name J, SCOTT WATSON. ESQUIRE Addres", 24 REGENCY PLAZA GLEN MILLS, PA 19342 Attorney foro PLAINTIFF Telephone: 610-358-9600 Supreme Court ID No. 41060 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 .88 .50 1.00 4.40 20.00 44.78 /$,.;,1' _ "'<.<t....,. ~ , ,.,f.< ,,," ,.'..~ ~" Advance Costs: 150.00 Sheriffs Costs: 44.78 $ 105,22 Refunded to Atty on 05/31/06 + t/uJOL, ./ So Answers; ~ -~ .,.-- ~ ,i' " ~t!LTh as Klin~, She~ i' / g (l,11.J1~ ~cW B dhtA~rewbaker .1Ji..,-::~ BZ'8 V . 0 J A VN 900l 'Vel A Hili G '! ,. , .:J:J I & ::nH; if/I' ~/o1 dl ~] g ~; ,~:.. I .", r 1:1... /1, ., I: .' I. ':> '\) t.k. :iLl .J. 0, <{ ~. I 7'1 J-"/ L WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1243 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DREXEL UNIVERSITY, Plaintiff (s) From ROBERT S. EPPLEY, JR" 1131 PINE STREET, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL CONTENTS OF DEFENDANT'S RESIDENCE, INCLUDING BUT NOT LIMITED TO ALL FURNITURE, CLOTHING, JEWELRY, ELECTRONIC EQUIPMENT, ELECTRICAL APPLIANCES, KITCHEN UTENSILS, SIL VERW ARE, TELEVISIONS, TOOLS AND ANY OTHER PROPERTY SUBJECT TO LEVY, (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) 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 him/her that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $1,426,21 Interest FROM 5/16/05 - $78.74 L.L. $,50 Atty's Comm % Atty Paid $37,50 Plaintiff Paid Date: MAY 8, 2006 Due Prothy $1.00 Other Costs (7 . ~TIS ,L (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name J, SCOTT WATSON, ESQUIRE Address: 24 REGENCY PLAZA GLEN MILLS, P A 19342 Attorney for: PLAINTIFF Telephone: 610-358-9600 Supreme Court ID No, 41060