HomeMy WebLinkAbout02-1421IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK MID-ATLANTIC, L.P.
Plaintiff
VS.
JOHN M. LUCIDON and ROSAMARIA
O. LUCIDON i/t/a PARADISE
LANDSCAPING & CONSTRUCTION
Defendant
No, O,~--
CIVIL ACTION
NOTICE OF JUDGMENT
(XX)
()
NOTICE IS HEREBY GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED
MATTER HAS BEEN ENTERED AGAINST THE ABOVE-NAMED DEFENDANT(s)
IN THE AMOUNT OF $ ON ~ ~ 2002.
A COPY OF ALL DOCUMENTS FILED WITH THE PROTHONOTARY OF
CUMBERLAND COUNTY IN SUPPORT OF THE WITHIN
JUDGMENT IS/ARE ENCLOSED.
PROTHONOTARY - CUMBERLAND COUNTY
Per:
If you have any questions concerning the above, please contact the undersigned.
AMATO AND M'ARGLE, P.C. ~
Ronald Amato
Attorney I.D. No. 32323
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK MID-ATLANTIC, L.P.
Plaintiff
VS.
JOHN M. LUCIDON and ROSAMARIA
0. LUCIDON i/t/a PARADISE
LANDSCAPING & CONSTRUCTION
Defendant
No.
CIVIL ACTION
PRAECIPE FOR TRANSFER OF JUDGMENT
TO THE PROTHONOTARY, CUMBERLAND COUNTY:
Kindly enter judgment in favor of Plaintiff and against the above-named defendant(s),
pursuant to Pa.R.C.P.D.J. No.402(D), for failure of defendant(s) to appeal, within 30 days, a
judgement entered February 20, 2001 against the above-named defendant(s) before
Philadelphia Municipal Court, as set forth in the transcript of judgment, which is attached
hereto. Assess damages as follows:
Judgment Amount
Post Judgment Interest
(from February 20, 2001 to March 18, 2002
at 6% per annum)
Payments
2,922.88
181.93
120.00
Total
$2,984.81
Dated: March 18, 2002
2003399
AMATO AND MARGLE, P,C,
Ronald Amato
Attorney I.D. No. 32323
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK MID-ATLANTIC, L.P.
Plaintiff
VS.
JOHN M. LUCIDON and ROSAMARIA
O. LUCIDON i/t/a PARADISE
LANDSCAPING & CONSTRUCTION
Defendant
: CIVIL ACTION
:
:
:
CERTIFICATION OF ADDRESSES
I do certify that the precise last known address of the within named plaintiff is:
2560 Renaissance Blvd.
KING OF PRSA,PA 19406
I do certify that the precise last known address of the within named defendant is:
1910 Spring Road
CARLISLE PA 17013-1155
AMATO AND MARGLE, P.C. ~
By: ~
Attorney I.D. No. 32323
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK MID-ATLANTIC, L.P.
Plaintiff
VS.
JOHN M. LUCIDON and ROSAMARIA
O. LUCIDON i/t/a PARADISE
LANDSCAPING & CONSTRUCTION
Defendant(s)
: No. ~-
:
:
:
:
: CIVIL ACTION
:
.,
:
:
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF NORTHAMPTON:
The undersigned, being duly sworn, according to law, deposes and says that the
Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or
otherwise within the provisions of the Soldiers and Sailor' Civil Relief Act of Congress of
1940 as amended;
That John M. Lucidon is over 18 years of age, resides at 1910 Spring Road,
CARLISLE PA 17013-1155 and is employed as Paradise Landscaping & Construction.
That Rosamaria O. Lucidon is over 18 years of age, resides at 1910 Spring Road,
CARLISLE PA 17013-1155 and is employed as Paradise Landscaping & Construction.
Sworn to and subscribed
before me this ~r~ day
of N~6v~2002 A.D.
NOTARY'I~UBLIC
ZT3B MCV1 00-12~22-23760 SC 116 DISPOSED
ISSUE AMT. FEE INCIDENT
~8~44.38 33
******** PLAINTIFF INFORMATION
YELLOW BOOK MID ATLANTIC L P
1300 MORRIS DR
WAYNE. PA 19087
ATTY 032323 AMATO
RONALD
A/DF
SC TYPE OTHER ~3~q
M.V. NEXT HEARING .....
******** DEFENDANT INFORMATION
LUCIDON JOHN
1910 SPRING RD
CARLISLE PA 17012
COURT ACTIVITY
HEARING #01 02/20/01 4A JUDG 379 BLASI DISP 61-JUDG FOR PL DEFLT
FINE+COST 2922.88 JUDG FOR PL 2922.88
PRESS ENTER FOR PAGE 1 INFORMATION
P/1
JUDGMENT CERTIFIED IN T~E A~OU~T OF $ 2922.88 COgT IHCLUDED
~lql:D m0mTHE RECAP oN , -
JOSEPH H. EVEI~~
PROTHONOTARY OF RHtLADELPHIA COUNTY
,,,:, .....
ZT3B MCV1
ISSUE AMT.
2844.38
00-12-22-23761 SC 116 DISPOSED
FEE INCIDENT
33
A/DF
SC TYPE OTHER
M.V. NEXT HEARING .....
******** PLAINTIFF INFORMATION *******
YELLOW BOOK MID ATLANTIC L P
1300 MORRIS DR
WAYNE. PA 19087
ATTY 032323 AMATO
RONALD
******** DEFENDANT INFORMATION *******
LUCIDON ROSAMARIA 0
1910 SPRING RD
CARLISLE PA 17012
COURT ACTIVITY
HEARING #01 02/20/01 4A JUDG 379 BLASI DISP 61-JUDG FOR PL DEFLT
FINE+COST 2922.88 JUDG FOR PL 2922.88
*** PRESS ENTER FOR PAGE 1 INFORMATION
P/1
JOSEPH H. EVERS
PROTHONOTARY OF PHILADELPHIA COUNTY
ZT3B MCV1 00-12-22-23762 SC 116 DISPOSED
ISSUE AMT. FEE INCIDENT
2844.38 33
A/DF
SC TYPE OTHER
M.V. NEXT HEARING
******** PLAINTIFF INFORMATION *******
YELLOW BOOK MID ATLANTIC L P
1300 MORRIS DR
WAYNE. PA 19087
ATTY 032323 AMATO
RONALD
******** DEFENDANT INFORMATION *******
LANDSCAPING & C ONSTRCUTIO N
1910 SPRING RD
CARLISLE PA 17012
COURT ACTIVITY
HEARING #01 02/20/01 4A JUDG 379 BLASI DISP 61-JUDG FOR PL DEFLT
FINE+COST 2922.88 JUDG FOR PL 2922.88
PRESS ENTER FOR PAGE 1 INFORMATION
P/i
JOSEPH H. b'V£FI8
PROTHONOTARY OF: PH, ILADSJ. PH~A COUNTY
Signature . Plaintiff/Attorney
'~~" .... '~Rsbert~ . a , rn~nzs ra~ve ~dge
YELLOW BOOK HID-ATLAETIC,
LoPe
1300 Morris Drive
~ayne, PA 19087
p/e!ntiff(s)
Signature
JOHN ti. LUCIDON and ROSAHARIA
0. LUCIDON i/t/a PARADISE
LANDSCAPING & CONSTRUCTION
1910 Spring Road
1.CASECONTINUEDTO
DATE ROOM
PLArNTIFF DEFENDANT
[] APPFJ~RED [] DID NOT APPEAR [] APPEARED ~'~ DiD NOT APPEA~
JUDGE
2. CASE CONTINUEDTO
DATE ROOM
JUDGE
3. CASE CONTINUED TO
DATE ROOM
[] APPEARED [] Olo NOT APPEAR [] APPF~EO [] DID NOT AppEAR
JUDGE
TRIAL DISPOSITION
PLAINTIFF ~ ATTY NO
[] Appeared ~ Did Not Appear
o~o []
DEFENDANT I ATTY NO
[] Appeared [] Did Not Appear I
No Service- Dismissed WITHOUT Prejudice 083 [] Withdrawn with Prejudice
080 [] Judgment by Agreement (see Remarks) 084 [] Case Settled, Discontinued, and Ended
081 [] Judgment for Defendant by Default COURTNO
082 ~ i Withdrawn from Court List without Prejudice (will be relisted upon
receipt of letter from either party)
055 [] Venue transfer within the Commonwealth - transfer to
[] Case transferred to
085
Common Pleas Court
091 ~ Case to be consolidated with
-- County. S.C.
D~TE [ JUDGE
-- '/~/ ~ PLAINTIFF ATTY
peared E~ Did Not Appear ~7,/~.' Jf ~] Appeared ~ot AppearI
061, ~gment for Plaintiff by Default A 070 ~ Judgment for Defendant
~0~ pl~ from plus
PM./¢-~, 071 ~ Judgment for Defendant as
Plaintiff in Counterclaim
Judgment for Plaintiff *~OUN~
plus interest from plus
A.M. COSTS 072 Judgment for Plaintiff as a
Time of judgment P.M. Defendant on Counterclaim
REMARKS
DATE JUDGE
03-7(Page2) COURT RECORD DISPOSITION
~ ~_~ Jr~g~za, ?rest~u~ge
x~-~.~ Robert S. Blasi, Administrative Judge
YELLOW BOOK MID-ATLANTIC,
L.P.
1300 Morris Drive
Wayne, PA 19087
Plaintiff(s)
JOHN M. LUCIDON and ROSAMARIA
O. LUCIDON i/t/a PARADISE
LANDSCAPING & CONSTRUCTION
1910 Spring Road
[]P_Ca~A.~ S fF~/iC]E7 0 1 3 - 1 1 5 5 Oe~n~ant(~
SERVICE ADDRESS (INFORMATION) if other than above
DATE OF ACCIDENT LICENSE PLATE NO
[] MOTOR VEHICLE CASE - Defendant License Information
OPERATOR - DATE OF BIRTH DEFENDANT - OPERATOR NO OWNER - DATE OF BIRTH OWNER - OPERATOR NO
TO THE DEFENDANT: The above named plaintiff(s) ask judgment in this Court against you for $^~ 2 8 4 4.3 8plus court costs upon the following claim:
S
At the special instance and request of Defendant,
Plaintiff provided advertising in its publication known as
"The Donnelley Directory". After applying all proper
credits, there remains a principal balance due of
$2,000.00, as set forth in the attached statement of
account. As provided in the~ attached advertisement
contract, Plaintiff is also entitled to interest on the
above amount from 04/12/00 to 12/11/00 at the agreed rate
of 18% per annum totalling $239.:67 and its attorneys fees
in the amount of $604.71, for a total, of $2,844.38, which,
despite demand by Plaintiff, remaims due. Defendant was
required to forward all payments to Plaintiff in
Philadelphia establishing a proper basis for venue in this
county. Lucas Enterprises~ Inc. vs. Paul C. Harmon, Inc.,
417 A.2d 720 (1980).
~ NOTICE TO DEFEND FILED
~L FOR P~INTIFFIA~Y ID NO., NAME & ADDRESS
I Amato and Margle. P.C.,
COMMONWEALTH OF PENNSYLVANIA
!.COUNTY OF PHILADELPHIA ss
~ Rona!d Amatc
depose and say that the facts set fo~th in this complaint
are true and correc~ and ackno.~-~e that I am subject
to the penalt~es~,~ 1~. P.S~3~ relating to Unsworn
Falsification rti
S~gnat~e Plaintiff/Attorney Date
ZIP CODE
Ronald Amato, ID#32323
7 N. Co,nme~u~ Way, B~Lhleh~m,
SUMMONS to the defendant: You are
hereby ordered to appear at a hearing sched-
uled as follows:
Atty File #
2003399
PrincipalAmount
$ $2 nnn nn
Interest at 1 8 %
from O/'/1 2,/0f3
$ $2Rq.67
Attorney's Fee:
$ $604,71
Otherl
TOTALS $2~844.38
PLUS COURT COSTS
PHONE
F~. .... 7
(610)
CITACION - Al Demandado: Por la
presente, usted esta dirijido a presentarse a
la siguiente vista an;
Courtroom4- ~. Feb. 20, 2001
Fourth Floor, 34 South 11th Street 12: 3 0 p m
IMPORTANT NOTI.CE TO THE DEFENDANT
You have been sued in court. If you wish to defend against the claims set
forth you must appear at the date time and place as shown You are warned
that if you fail to appear, the case may proceed without you and a judgment
may be entere~ against you by the Court without further notice for any money
claimed in the complaint or for any other claim or relief requested by the
plamtdf. You may lose money or property or other rights important to yo~
THE MUNICIPAL COURT COMPLIES WITH THE AMERICANS WITH DISABILITIES
ACT WHICH REQUIRES THAT ALL COURT SERVICES AND FACILITIES BE
ACCESSIBLE TO PERSONS WITH DISABILITIES ON AN EOUAL BASIS TO THOSE
WfTHOUT DISABILITIES. IF YOU HAVE ADISABILITY. AND REQUIRE REASONABLE
ACCOMMODATIONS TO FILE A CLAIM, PARTICIPATE 1N A MUNICIPAL COURT
PROCEEDING, OR USE ANY SERVICE PROVIDED BY THE COURT, PLEASE CALL 686-7986
REQUESTS FOR REASONABLE ACCOMMODATIONS MUST BE MADE AT LEAST THREE
BUSINESS DAYS BEFORE ANY HEARING OR WITHIN THREE BUSINESS DAYS AFTER
SERVICE (DELIVERYI OF THE NOTICE OF HEARING. WHICHEVER IS LATER
03-7 trey 2/00)
NOTA IMPORTANTE PARA EL ACUSADO
Usted ha sido demandado en corte Si usted desea defenderse contra las auejas due
aparecen en contra suya debe usted apelar el did, la hora y sitio que se senalo Usted esta
advertido due si no comparece, el caso puede cotinuar sin su presencla y una querella
puede sar pues[a en contra suya por la corte sin ninguna notificacion, por dinero reclamado.
0 pot alguna otra queja requierda pot el demandante Usted puede perrier dinero, prop~edad
u otros derechos importantes para usted
LA CORTE MUNICIPAL CUMPLE CON EL DECRETO DE AMERICANOS INCAPACITADOS
{AMERICANS WITH DISABILITIES ACT) ESTE DECRETO REQUIERE QUE TODOS LOS SER-
VIClOS Y FACILIDADES DE CORTE SEAN ACCESIBLE A PERSONAS INCAPACITADAS. AL IGUAL
QUE PERSONAS NO INCAPACITADAS SE USTED ESTE INCAPACITADO Y NECESITA
ACOMODACIONES RAZONABLES. PARA PODER RADICAR UNA DEMANDA, PARTICIPAR EN ALGUN
PROCEDIMIENTO O UTILIEAR SERVICIOS EN LA CORTE MUNICIPAL POR FAVOR LLAME AL TELEFONO
686-7986 pARA SOLICITAR ACOMODACIONES RAZONABLES D~BELLAMAR POR LO MENDS TRES DIAS
DE TRABAJO ANTES DE SU AUDIENCIA O DENTRO DE TRES DIAS DESPUES DE RECIBIR SU CITA
SEOUN LO QUE OCURRA PRIMERO
COURT RECORD-ENTER DISPOSITION ON PART 2
IN THE COURT OF C~3MMON PLEAS OF CUMBERLAND COUNTY, PEN~ISYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK MID-ATLANTIC, L.P. :
_.
Plaintiff :
:
vS. '
..
JOHN M. LUClDON and ROSAMARIA :
O. LUClDON i/t/a PARADISE :
LANDSCAPING & CONSTRUCTION :
:
Defendant(s) :
To the Prothonotary - Cumberland County: ISSUE
MATTER.
No. 02-1421 Civil
PRAECIPE FOR WRIT
EXECUTION
(MONEY JUDGMENT)
A WRIT OF EXECUTION IN THE ABOVE
(1) Directed to the Sheriff of Cumberland County, for debt, interest and costs upon the
following described property of the defendant(s) All cash on hand or in the possession of the
defendant(s), accounts receivables, furniture, furnishings, equipment, inventory, tools,
vehicles, electronic equipment, any and all other personal property belonging to the above-
named defendant(s).
(2) against JOHN M. LUCIDON and ROSAMARIA O. LUCIDON i/t/a PARADISE LANDSCAPING
& CONSTRUCTION, Defendant(s)
(3) and against ........................................ Garnishee(s)
(4) and index this writ
(a) against .................................. Defendant(s) and
(b) against ....................................... Garnishee(s)
as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s)
as follows:(Specifically describe the property)
(5) Amount Due $ 2,984.81
Statutory Interest
From March 22, 2002
Less Payment
Costs
Poundage
Total
$ 1.46
2,986.27
Date:March 25, 2002
Attorney File#: 2003399
AMATO AND M~GLE, P.C.~
By: .J~
Ronald Amato
Attorney I.D. No. 32323
Attorneys for Plaintiff
IN THE COURT OF CbMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK MID-ATLANTIC, L.P.
Plaintiff
VS.
JOHN M. LUCIDON and ROSAMARIA
O. LUCIDON i/Ua PARADISE
LANDSCAPING & CONSTRUCTION
Defendant(s)
No. 02-1421 Civil
WRIT OF EXECUTION
(MONEY JUDGMENTS)
WRIT OF EXECUTION
TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA
To satisfythejudgment, interest and cost against JOHN M. LUCIDON and ROSAMARIA
O. LUCIDON i/t/a PARADISE LANDSCAPING & CONSTRUCTION, Defendant(s);
(1) You are directed to levy upon the property of the defendant(s) and to sell his, her
(or their) interest therein; (Inquisition and Exemption Laws (are) (are not) waived.
(2) You are also directed to attach the property of the defendant not levied upon in the
possession of ....................
..................................................... Garnishee(s)
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 and subject to attachment is found
in the possession of anyone other than the named garnishee(s), you are directed to notify him
that he has been added as a garnishee and is enjoined as above stated.
Amount Due
Statutory Interest
From March 22, 2002
2,984.81
1.46
Less Payments
Costs
Poundage
Total
DATED
(SEAL)
By
2,986.27 plus add'l costs
Prothonotary - Cumberland County
Court of Common Pleas, Cumberland County
Attorney File#: 2003399 Deputy
IN THE COURT OF C'OMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK MID-ATLANTIC, L.P.
Plaintiff
VS.
JOHN M. LUCIDON and ROSAMARIA
O. LUCIDON i/t/a PARADISE
LANDSCAPING & CONSTRUCTION
Defendant(s)
: No. 02-1421 Civil
:
:
_.
:
: CIVIL ACTION
:
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:
:
CERTIFICATION OF DEFENDANT(s) ADDRESS FOR SERVICE
I do certify that the precise last known address of the within named defendant(s) is the
address provided below, and request that the Sheriff serve the above named defendant(s) at:
1910 Spring Road
CARLISLE PA 17013-1155
Dated:March 25, 2002
AMATO AND MARGLE, P.C.
By: ~
Ronald Amato
Attorney I.D. No. 32323
Attorneys for Plaintiff
Attorney File #:2003399
IN THE COURT OF C~)MMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK MID-ATLANTIC, L.P.
Plaintiff
VS.
JOHN M. LUCIDON and ROSAMARIA
O. LUCIDON i/Ua PARADISE
LANDSCAPING & CONSTRUCTION
Defendant(s)
No. 02-1421 Civil
CIVIL ACTION
WAIVER OF WATCHMAN
To the Sheriff:
Any deputy sheriff levying upon or attaching any property under the within writ may
leave same without a watchman, in custody of whomever is found in possession, after
notifying person of levy or attachment without liability on the part of such deputy or the
sheriff to any plaintiff herein for any loss, destruction or removal of any such property before
the sheriff's sale thereof.
Dated: March 25, 2002
Attorney File #: 2003399
AMATO AND MARGLE, P.C~
Ronald Amato
Attorney I.D. No. 32323
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK MID-ATLANTIC, L.P.
Plaintiff
VS.
JOHN M. LUCIDON and ROSAMARIA
O. LUCIDON i/t/a PARADISE
LANDSCAPING & CONSTRUCTION
Defendant
: No. 02-1421 Civil
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:
: CIVIL ACTION
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:
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WRIT OF EXECUTION NOTICE
THIS PAPER IS A WRIT OF EXECUTION. IT HAS BEEN ISSUED BECAUSE THERE IS A
JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD OR TAKEN TO
PAY THE JUDGMENT. YOU MAY HAVE LEGAL RIGHTS TO PREVENT YOUR PROPERTY
FROM BEING TAKEN. A LAWYER CAN ADVISE YOU MORE SPECIFICALLY OF THESE
RIGHTS. IF YOU WISH TO EXERCISE YOUR RIGHTS, YOU MUST ACT PROMPTLY.
THE LAW PROVIDES THAT CERTAIN PROPERTY CANNOT BE TAKEN. SUCH
PROPERTY IS SAID TO BE EXEMPT. THERE IS A DEBTOR'S EXEMPTION OF $300. THERE
ARE OTHER EXEMPTIONS WHICH MAY BE APPLICABLE TO YOU, A SUMMARY OF SOME
OF THE MAJOR EXEMPTIONS ARE LISTED ON THE NEXT PAGE. YOU MAY HAVE OTHER
EXEMPTIONS OR OTHER RIGHTS.
(1)
(2)
IF YOU HAVE AN EXEMPTION, YOU SHOULD DO THE FOLLOWING PROMPTLY:
FILL OUT THE ATTACHED CLAIM FORM AND DEMAND FOR A PROMPT
HEARING
DELIVER THE FORM OR MAIL IT TO THE SHERIFF'S OFFICE AT THE
ADDRESS NOTED.
YOU SHOULD COME TO COURT READY TO EXPLAIN YOUR EXEMPTION. IF YOU DO
NOT COME TO COURT AND PROVE YOUR EXEMPTION, YOU MAY LOSE SOME OF YOUR
PROPERTY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
(717) 240-6200
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT~, PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK MID-ATLANTIC, L.P.
Plaintiff
VS.
JOHN M. LUCIDON and ROSAMARIA
0. LUCIDON ilt/a PARADISE
LANDSCAPING & CONSTRUCTION
Defendant(s)
: No. 02-1421 Civil
_.
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CIVIL ACTION
:
:
.
CLAIM FOR EXEMPTION
To the Sheriff:
I, the above-named defendant, claim exemption of property from levy or attachment:
(1) From my personal property in my possession which has been levied upon,
(a) I desire that my $300 statutory exemption be
_(i) set aside in kind (specify property to be set aside
in kind):.
_(ii) paid in cash following the sale of the property
levied upon; or
(b) I claim the following exemption (specify property and
basis of exemption):
(2) From my property which is in the possession of a third party, I claim the following
exemptions:
(a) my $300 statutory exemption: in cash; in
kind(specify property): ;
(b) Social Security benefits on deposit in the amount of
$ ;
(c) other (specify amount and basis of exemption):
I request a prompt court hearing to determine the exemption. Notice of the hearing should be
given to me at
(Address) (Telephone Number)
I verify that the statements made in this Claim for Exemption are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §
4904 relating to unsworn falsification to authorities.
Date:
Defendant
THIS CLAIM TO BE FILED WITH THE OFFICE
OF THE SHERIFF OF CUMBERLAND COUNTY:
South Hanover Street, Carlisle, PA 17013
717-240-6195
MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW
1. $300.00 STATUTORY EXEMPTION
2. BIBLES, SCHOOL BOOKS, SEWING MACHINES, UNIFORMS
AND EQUIPMENT
3. MOST WAGES AND UNEMPLOYMENT COMPENSATION
4. SOCIAL SECURITY BENEFITS
5. CERTAIN RETIREMENT FUNDS AND ACCOUNTS
6, CERTAIN VETERAN AND ARMED FORCES BENEFITS,
7. CERTAIN INSURANCE PROCEEDS
8. SUCH OTHER EXEMPTIONS AS MAY BE PROVIDED BY LAW
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
YELLOW BOOK MID-ATLANTIC, L.P.
Plaintiff
VS.
JOHN M. LUCIDON and ROSAMARIA
O. LUCIDON i/t/a PARADISE
LANDSCAPING & CONSTRUCTION
Defendant(s)
: No. 02-1421 Civil
: CIVIL ACTION
PRAECIPE TO SATISFY JUDGMENT
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please satisfy the judgment entered in the above-captioned case.
AM:ATO AND M~RGLE,
Attorney I.D. No. 32323
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
R. Thomas Kline, Sheriff, who being duly sworn according to law, states
thi~ writ is returned STAYED.
Sheriffs Costs:
Docketing $ 18.00
Poundage 59.69
Advertising
Law Library .50
Prothonotary 1.00
Mileage 3.45
Misc.
Surcharge 30.00
Levy 20.00
Post Pone Sale
Garnishee
132.64
Advance Costs: 1'50.00
Sheriffs Costs: 132.64
17.36
Refunded to Atty on 8/21/02
Sworn and Subscribed to before me
This/_~ day of~~_~
2002 A.D. ~
So Ansv/ers.., t,,'".~.
R. Thomas Kline, Sheriff
By ~.[/~c't '-~qgt_O~oc(_~
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 02-1421 Civil
COUNTY OF cUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND cOUNTY:
To satisfy the debt, interest and costs due YELLOW BOOK MID-ATLANTIC, L.P., Plaintiff (s)
From JOHN M. LUCIDON AND ROSAMARIA O. LUCIDON I/T/A PARADISE LANDSCAPING
& CONSTRUCTION, 1910 SPRING ROAD, CARLISLE, PA 17013-1155
(1) You are directed to levy upon the property of the defendant (s)and to sell ALL CASH ON HAND
OR IN THE POSSESSION OF THE DEFENDANT(S), ACCOUNTS RECEIVABLES,
FURNITURE, FURNISHINGS, EQUIPMENT, INVENTORY, TOOLS, VEHICLES,
ELECTRONIC EQUIPMENT, ANY AND ALL OTHER PERSONAL PROPERTY BELONGING
TO THE ABOVE-NAMED DEFENDANTS ·
(2) You are also directed t° attach the pr°perty °f the defendant(s) n°t levied up°n in the p°ssessi°n
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the gam/shee(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 propertyof the defendant(s) n°t levied up°n an subject t° attachment is f°und in the p°ssessmn
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 $2,984.81
Interest FROM MARCH 22, 2002 - $1.46
Atty's Corem %
Atty Paid $33.00
Plaintiff Paid
Date: MARCH 28, 2002
REQUESTING PARTY:
Name RONALD AMATO, ESQUIRE
Address: AMATO AND MARGLE, P.C.
107 NORTH COMMERCE WAY
BETHLEHEM, PA 18017-8930
Attorney for: PLAINTIFF
Telephone: 610-866-0400
Supreme Court ID No. 32323
L.L. $.$0
Due Prothy $1.00
Other Costs
CURTIS R. LONG
Prothonotary, Civil Division