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HomeMy WebLinkAbout06-3114COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND z%-311 Mag. Dist. No.. 09-1-01 MDJ Name: Ron. CHARLES A. CLEMENT, JR Address. 400 BRIDGE ST OLDS TGMTS COMMONS -SUITE 3 NEW CUlD3ERLAMD, PA Telephone: (717) 774-5989 17070 CT REHABILITALTION LP 5351 JAYCEE AVE HARRISBURG, PA 17112 THIS IS TO NOTIFY YOU THAT: Judgment: ® Judgment was entered for: (Name) ® Judgment was entered against: (Name) in the amount of $ 1 , 942 _ nn. on: ? Defendants are jointly and severally liable. El Damages will be assessed on: El 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 $ Judgment Total $ PT J J ,- ---- ---- ANYPAWN HAS THE RIGHT TQ.APPEAL.WITHIN 30 DAYS.AFTER THE ENTRY OF JUDGr ENTRY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVI DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR OTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGIST RIAL 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 ISSU D 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 :NVITH THE DISTRICT JUDGE IF.- E MAGISTERIAL JUDGMENT DEBTOR PAYS. IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. A Date Ma^%Iat bWrict dujge I certif_:2 at this is a true a m of the re f th roc s c ntpira g ttie )udgment.. % :1 t: M Y - 0? Date IclaZjisterial District Judge My commission expires first Monday of January, 2008 . AOPC 315-05 DATE PRINTED: 4/04/.06 3:24:33 PM NOTICE / PLAINTIFF: rCT REHA 5351 JA HARRISB L DEFENDANT: rSTRICSL 444 PON CAMP HI L VIL CASE NAME and ADDRESS ALTION LP AVE PA 17112 Vs. NAME and ADDRESS MOSLEY, CHERISE DRIVE PA 17011 Docket No.: "-0000101-06 Date Filed: 3/03/06 (Date of Judgnent) 4-110a/ne (Date & Mime) Total of Judgment nt Costs on Judgment r Fees Post judgment Credits $ Post udgment Costs $ SEAT V ?V z.i: to ror r r. 1'C-. ^v 3 ,C fC'7 m x N, CT Rehabilitation LP 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Cherise Strickland-Mosby 444 Powell Drive Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA NO. 06-3114 CIVIL ACTION - LAW PETITION FOR A RULE TO SHOW CAUSE WHY AN ORDER GRANTING WAGE ATTACHMENT SHOULD NOT ISSUE AND NOW, comes the Plaintiff, CT Rehabilitation LP, 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, Cherise Strickland-Mosby and the Defendant's employer, Coverall Cleaning Concepts, 1017 Mumma Road, Suite 101, Wormleysburg, PA 17043, 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 Charles A. Clement, Jr., Magisterial District 09-1-01 on April 3, 2006 in the amount of $1,851.50, Docket Number CV-0000101-06. Post judgment costs increased this amount to $1,942.00, which is shown on the certified judgment. 3. The District Justice Judgment was filed with this Court on May 31, 2006, under Docket Number 06-3114 Civil Term. 4. Reasonable attempt has been made to contact and make payment arrangement to satisfy Judgment Docket Number CV-0000101-06. No response was received from defendant. 5. The Defendant is currently employed at Coverall Cleaning Concepts, 1017 Mumma Road, Suite 101, Wormleysburg, PA 17043. 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 rule to show cause against both the Defendant, Cherise Strickland-Mosby and her current employer, Coverall Cleaning Concepts, 1017 Mumma Road, Suite 101, Wormleysburg, PA 17043. Respectfully Submitted: Date: /?3 '?(' 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 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: Cherise Strickland-Mosby 444 Powell Drive Camp Hill, PA 17011 Date: 6'A ' 66 Respectfully Submitted, y: Pietro Leone, Attorney PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 717-657-5729 f ti COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND AL-Ifl-? Mag. Dist. No.: 09-1-01 MDJ Name: Hon. CHARLES A. CLEMENT, JR Address: 400 BRIDGE- ST OLDS TOWNE COMMONS -SUITE 3 NEW CUMBERLAND, PA Telephone: (717 774-5989 17070 CT REHABILITALTION LP 5351 JAYCEE AVE HARRISBURG, PA 17112 ,,JNOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: CIVIL CASE NAME and ADDRESS FCT REHABILITALTION LP 5351 JAYCEE AVE HARRISBURG, PA 17112 L VS. DEFENDANT: NAME and ADDRESS F-STRICKLAND-MOSLEY, CHERISE 444 POWELL DRIVE CAMP HILL, PA 17011 THIS IS TO NOTIFY YOU THAT: Judgment: Fil Judgment was entered for: (Name) ® Judgment was entered against: (Name) in the amount of $ i ,-942_ _ 00 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 $ (Date of Judgment) 4.103/x6 (Date & Time) 1 Amount of Judgment $ 1,851.50 Judgment Costs $ 90.50 Interest on Judgment $ .00 Attorney Fees $ .00 Total . $ 1, 942.00 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ J 7 J ANI-P AR'IW I IAS THE RIGHT TQAPPEAL..WITHIN SC DAYSAFTER THE ENTRY OF JUDGIMIENT 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 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. APR - 3 2006 Date ; Maki terial District Mudge t. I certify that this is a true a co rect cop of the re o f the roc s contaiLitng ,hE judgment. M Y - 4 2006 Date - Magisterial District Judge My commission expires first Monday of January, 2008 . SEAL . . A (')Pr'. . 1 J% A 10%e 13 . 0) A . 12 nv L Docket No.: CV-0000101-06 Date Filed: 3/03/06 n ?. a.- " CT Rehabilitation LP 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Cherise Strickland-Mosby 444 Powell Drive Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA NO. 06-3114 CIVIL ACTION - LAW RULE TO SHOW CAUSE AND NOW, this day of 2006, upon consideration of the foregoing Petition For A Rule To Show Cause Why An Order Granting Wage Attachment Should Not Issue, it is hereby ORDERED and DECREED as follows: 1. a rule is issued upon the Defendant, Cherise Strickland-Mosby, and her current employer, Coverall Cleaning Concepts, 1017 Mumma Road, Suite 101, Wormleysburg, PA 17043, to show cause why the petitioner is not entitled to the relief requested; 2. the respondent shall file an answer to the petition within A days of service; 3. the petition shall be decided under Pa. R.C.P. No. 206.7. 4. notice of the entry of this order shall be provided to all parties and to the current employer of the Defendant, Coverall Cleaning Concepts, 1017 Mumma Road, Suite 101, Wormleysburg, PA 17043. 0 >? ? ? `. `? r l11 ? ?.`? i r ?, „? ?;,.? ?. .; ? -;.. ?..:J ;: -1 ?: CT Rehabilitation LP 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Cherise Strickland-Mosby 444 Powell Drive Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA NO. 06-3114 CIVIL ACTION - LAW PLAINTIFF'S MOTION TO MAKE RULE ABSOLUTE AND NOW, Pursuant to Pennsylvania Rule of Civil Procedure 206.7, Plaintiff, CT Rehabilitation LP, hereby files this Motion to make Rule Absolute, and in support of same avers as follows: 1. On June 26, 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 July 5, 2006, this Honorable Court issued a Rule to Show Cause with a return within 20 days of service. 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, Coverall Cleaning Concepts, 1017 Mumma Road, Suite 101, Wormleysburg, PA 17043, as well as all current or subsequent employers. Pietro Leone, Attorney Page 1 of 2 Triple Crown Corporation, Inc. Plaintiffs Motion to Make Rule Absolute Respectfully Submitted: Date: i)j ` ©6 Pietro Leone, Attorney Triple Crown Corporation, Inc. Pietro Leone, Attorney PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 (717) 657-5729 Page 2 of 2 Plaintrs Motion to Make Rule Absolute ti CERTIFICATE OF SERVICE I hereby certify that I am this day serving Plaintiffls 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: Cherise Strickland-Mosby 444 Powell Drive Camp Hill, PA 17011 Coverall Cleaning Concepts 1017 Mumma Road, Suite 101 Wormleysburg, PA 17043 Date: '7-o0- o6 Pietro Leone, Attorney Triple Crown Corporation, Inc. Respectfully Submitted, By: Pietro Leone, Attorney, PA Bar #85127 5351 Jaycee Avenue, Harrisburg, PA 17112 717-657-5729 Page I of I Certificate of Service .0111 •.l r` -71 E i'i?t3 t-S 'ie .,, CT Rehabilitation LP 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Cherise Strickland-Mosby 444 Powell Drive Camp Hill, PA 17011 Defendant ©$ JUL 2 8 2006 IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA NO. 06-3114 CIVIL ACTION - LAW ATTACHMENT ORDER AND NOW, this I A day of , 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, Cherise Strickland-Mosby. The Defendant's employer is Coverall Cleaning Concepts, 1017 Mumma Road, Suite 101, Wormleysburg, PA 17043. It is hereby ORDERED AND DECREED as follows: 1. The Defendant's current employer, Coverall Cleaning Concepts, 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 $1,942.00. 3. The Defendant's current employer, Coverall Cleaning Concepts, 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 CT Rehabilitation LP 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. t? Triple Crown Corporation, Inc. Attachment 1 of] r W SHERIFF'S RETURN - REGULAR CASE NO: 2006-03114 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CT REHABILITALTION LP VS STRICKLAND-MOSLEY CHERISE SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within ATTACHMENT ORDER was served upon COVERALL CLEANING CONCEPTS the WITNESS , at 1535:00 HOURS, on the 18th day of January-, 2007 at 4242 CARLISLE PIKE SUITE 222 CAMP HILL, PA 17011 by handing to SCOTT SCHROTER, REGIONAL DIRECTOR a true and attested copy of ATTACHMENT ORDER together with MOTION TO MAKE RULE ABSOLUTE CERTIFICATE OF SERVICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 24.64 Affidavit .00 Surcharge 10.00 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 01/19/2007 TRIPLE CROWN CORPORATION By: Z/, / ( z -Dep"uty Sheir -f f A. D. CASE NO: 2006-03114 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CT REHABILITALTION LP VS STRICKLAND-MOSLEY CHERISE ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within ATTACHMENT ORDER was served upon COVERALL CLEANING CONCEPTS the WITNESS , at 1737:00 HOURS, on the 31st day of January-, 2007 at 444 PROWELL DRIVE CAMP HILL, PA 17011 CHERISE STRICKLAND by handing to ADULT IN CHARGE a true and attested copy of ATTACHMENT ORDER MOTION TO MAKE RULE ABSOLUTE CERTIFICATE OF SERVICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 11.44 Affidavit .00 Surcharge 10.00 .00 ,/27.44 2-i3-b? 4„ Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 02/01/2007 TRIPLE CROWN CORPORATION By: Deputy S eri f A.D. CT Rehabilitation LP IN THE COURT OF COMMON PLEAS 5351 Jaycee Avenue CUMBERLAND, COUNTY, PENNSYLVANIA Harrisburg, PA 17112 Plaintiff Vs NO. 06-3114 Cherise Strickland-Mosby d/b/a Coverall Cleaning Concepts : 444 Prowell Drive CIVIL ACTION - LAW Camp Hill, PA 17011 Defendant PLAINTIFF'S MOTION FOR CONTEMPT OF COURT 1. On July 24, 2006, Plaintiff, CT Rehabilitation LP, filed for an Attachment Order. 2. On August 1, 2006, this Honorable Court issued an Attachment Order. (Exhibit A) 3. On January 31, 2007 the order was served to Ms. Mosby by Robert Bitner, Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania. 4. As of the date of this motion the Defendant's employer has not complied. 5. The Plaintiff is respectfully requesting a hearing be scheduled for resolution of this matter. Respectfully Submitted: Date: 5- 7 - ;oD7 -iq Y / Z4,e - "L C; 2? Pietro Leone, Attorney, PA Bar #85127 5351 Jaycee Avenue, Harrisburg, PA 17112 717-657-5729 Pietro Leone, Attorney Page I of I Triple Crown Corporation, Inc. Motion for Contempt of Court CT Rehabilitation LP 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Cherise Strickland-Mosby 444 Powell Drive Camp Hill, PA 17011 Defendant Jul 1'uov IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA NO. 06-3114 CIVIL ACTION - LAW ATTACHMENT ORDER AND NOW, this day of , 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, Cherise Strickland-Mosby. The Defendant's employer is Coverall Cleaning Concepts, 1017 Mumma Road, Suite 101, Wormleysburg, PA 17043. It is hereby ORDERED AND DECREED as follows: 1. The Defendant's current employer, Coverall Cleaning Concepts, 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 $1,942.00. 3. The Defendant's current employer, Coverall Cleaning Concepts, 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 CT Rehabilitation LP 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. Pietro Leone, Attorney Page 1 of I Triple Crown Corporation, Inc. Attachment Order CT Rehabilitation LP IN THE COURT OF COMMON PLEAS 5351 Jaycee Avenue CUMBERLAND, COUNTY, PENNSYLVANIA Harrisburg, PA 17112 Plaintiff Vs NO. 06-3114 Cherise Strickland-Mosby 444 Powell Drive CIVIL ACTION - LAW Camp Hill, PA 17011 Defendant PLAINTIFF'S MOTION TO MAKE RULE ABSOLUTE - AND NOW, Pursuant to Pennsylvania Rule of Civil Procedure 206.7, Plaintiff; CT Rehabilitation LP, hereby files this Motion to make Rule Absolute, and in support of same avers as follows: L On June 26, 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 July 5, 2006, this Honorable Court issued a Rule to Show Cause with a return within 20 days of service. 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, Coverall Cleaning Concepts, 1017 Mumma Road, Suite 101, Wormleysburg, PA 17043, as well as all current or subsequent employers. Pietro Leone, Attorney Page 1 of 2 Triple Crown Corporation, Inc. Plaintiff's Motion to Make Rule Absolute Respectfully Submitted: Date: " ?Z( ?06 u , Pietro Leone, Attorney PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 (717) 657-5729 Pietro Leone, Attorney Triple Crown Corporation, Inc. Page 2 of 2 Plaintiff's Motion to Make Rule Absolute 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: Cherise Strickland-Mosby 444 Powell Drive Camp Hill, PA 17011 Coverall Cleaning Concepts 1017 Mumma Road, Suite 101 Wormleysburg, PA 17043 Date: 7- ?Y-ob Pietro Leone, Attorney Triple Crown Corporation, Inc. Respectfully Submitted, Y By: Pietro Leone, Attorney, PA Bar #85127 5351 Jaycee Avenue, Harrisburg, PA 17112 717-657-5729 Page I of I Certificate of Service 1Z,t'J 1 V ?LV - 1,VJ.;?`T V 11G7.1?. NO: 2006-03114 P .:OMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLANp CT REHABILITA.LTION LP VS STRICKLAND-MOSLEY CHERISE ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within ATTACHMENT ORDER was served upon COVERALL CLEANING CONCEPTS the WITNESS at 1737:00 HOURS, on the 31st day of January-, 2007 at 444 PROWELL DRIVE CAMP HILL, PA 17011 by handing to CHERISE STRICKLAND ADULT IN CHARGE a true and attested copy of ATTACHMENT ORDER together with MOTION TO MAKE RULE ABSOLUTE CERTIFICATE OF SERVICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 11.44 .00 10.00 .00 27.44 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 02/01/2007 TRIPLE CROWN CORPORATION By: Deputy S eri f A. D. Ste` . ? ? ?...? '' ? ?? '[pl t. ?+ ?f .Jl ?5? F ':.i .. -? MAY 10 2007 CT Rehabilitation LP IN THE COURT OF COMMON PLEAS 5351 Jaycee Avenue CUMBERLAND, COUNTY, PENNSYLVANIA Harrisburg, PA 17112 Plaintiff Vs NO. 06-3114 Cherise Strickland-Mosby d/b/a Coverall Cleaning Concepts 444 Powell Drive CIVIL ACTION - LAW Camp Hill, PA 17011 Defendant ORDER AND NOW, having heard the above captioned matter a hearing is scheduled for month, at me Mme /1-16 /Allefore this Honorable 3. Court. 2A t6 : Inh / ddd P/ Pietro Leone, Attorney Page I of 1 ?ple Crown Corporation, Inc. Order for Motion for Contempt of Court hecise _3?ri dlatA - f OAY 90 :1 Ii<d h € M LOOZ A iVli,V14Vi U.? `Jd "Hi 40 CT Rehabilitation LP 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Cherise Strickland-Mosby 444 Powell Drive Camp Hill, PA 17011 Defendant CIVIL ACTION - LAW PLAINTIFF'S MOTION TO WITHDRAW CONTEMPT OF COURT AND NOW, Pursuant to Pennsylvania Rule of Civil Procedure 206.7, Plaintiff, CT Rehabilitation LP, hereby files this Motion to Withdraw Contempt of Court, against the Defendant's current employer, Coverall Cleaning Concepts. Submitted: Date: -4.0 7 IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA NO. 06-3114 Pietro Leone, Attorney PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 (717) 657-5729 T -TI CT Rehabilitation LP 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Cherise Strickland-Mosby 444 Powell Drive Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA NO. 06-3114 CIVIL ACTION - LAW AMENDED PLAINTIFF'S MOTION TO WITHDRAW CONTEMPT OF COURT AND NOW, Pursuant to Pennsylvania Rule of Civil Procedure 206.7, Plaintiff, CT Rehabilitation LP, hereby files this Motion to Withdraw Contempt of Court, against the Defendant's current employer, Coverall Cleaning Concepts. There has been prior judge involvement, a Civil Ruling by District Justice Charles A. Clement, Jr., docket number CV-0000101-06 and an Attachment Order by Judge Guido, docket number 06-3114 Civil Term. Concurrence of opposing counsel was sought but was not obtained due to the Defendant's lack of appearance at the April 3, 2006 hearing for the Civil Judgment CV-0000101-06. Concurrence was also not obtained on the filing of the Rule to Show Cause Order number 06- 3114 Civil Term. Date: 9,d- 07 Respectfully Submitted: Pietro Leone, Attorney PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 (717) 657-5729 C car c : .. ._'' t.. ? rn a JUL 112001! CT Rehabilitation LP IN THE COURT OF COMMON PLEAS 5351 Jaycee Avenue CUMBERLAND, COUNTY, PENNSYLVANIA Harrisburg, PA 17112 : Plaintiff Vs NO. 06-3114 Cherise Strickland-Mosby 444 Powell Drive CIVIL ACTION - LAW Camp Hill, PA 17011 Defendant ORDER AND NOW, this day of k^rx , 2007, upon consideration of the foregoing Motion for Contempt of Court, it is hereby ORDERED AND DECREED the contempt of court order shall be withdrawn. U :C Wd L- MV fooz 30 PD-a- q CT Rehabilitation LP IN THE COURT OF COMMON PLEAS 5351 Jaycee Avenue CUMBERLAND, COUNTY, PENNSYLVANIA Harrisburg, PA 17112 : Plaintiff Vs NO. 06-3114 Cherise Strickland-Mosley : 444 Powell Drive Camp Hill PA 17011 CIVIL ACTION - LAW Defendant PLAINTIFF'S MOTION FOR CONTEMPT OF COURT 1. On July 28, 2008, Plaintiff, CT Rehabilitation LP, filed for an Attachment Order. 2. On August 1, 2006, this Honorable Court issued an Attachment Order. (Exhibit A) 3. On July 26, 2006 the order was served to Kim Wagner by Certified Mail (Exhibit B) 4. As of the date of this motion the Defendant's employer has stopped complying with the order. Payments have stopped. Last payment received on March 12, 2008. 5. The Plaintiff is respectfully requesting a hearing be scheduled for resolution of this matter. Date: q-1 5 Respectfully Su Att6mey for Judgment Creditor-Landlord Mark X. DiSanto PA Bar #51090 5351 Jaycee Avenue, Harrisburg, PA 17112 717-657-5729 Mark X. DiSanto Attorney Page I of I Triple Crown. Corporation, Inc. Motion for Contempt of Court CT Rehabilitation LP IN THE COURT OF COMMON PLEAS JUL 2 8 5351 Jaycee Avenue CUMBERLAND, COUNTY, PENNSYLVANIA Harrisburg, PA 17112 Plaintiff Vs NO. 06-3114 Cherise Strickland-Mosby 444 Powell Drive CIVIL ACTION - LAW Camp Hill, PA 17011 Defendant ATTACHMENT ORDER 206 ,„? AND NOW, this day of , 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, Cherise Strickland-Mosby. The Defendant's employer is Coverall Cleaning Concepts, 1017 Mumma Road, Suite 101, Wormleysburg, PA 17043. It is hereby ORDERED AND DECREED as follows: The Defendant's current employer, Coverall Cleaning Concepts, 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 $1,942.00. The Defendant's current employer, Coverall Cleaning Concepts, 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 CT Rehabilitation LP 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. Pietro Leone, Attorney Page I of I Triple Crown Corporation, Inc. Attachment Order CT Rehabilitation LP 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs Cherise Strickland-Mosby 444 Powell Drive Camp Hill, PA 17011 Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA PLAINTIFF'S MOTION TO MAKE RULE ABSOLUTE AND NOW, Pursuant to Pennsylvania Rule of Civil Procedure 206.7, Plaintiff,-CT <:- Rehabilitation LP, hereby files this Motion to make Rule Absolute, and in support of same avers as follows: 1. On June 26, 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 July 5, 2006, this Honorable Court issued a Rule to Show Cause with a return within 20 days of service. 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. WI-IEREFORE, 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, Coverall Cleaning Concepts, 1017 Mumma Road, Suite 101, Wormleysburg, PA 17043, as well as all current or subsequent employers. Pietro Leone, Attorney Triple Crown Corporation, Inc. Page I of l Plaintiff's Motion to Make Rule Absolute Date:Y Respectfully Submitted: ietro Leone, Attorney PA Bar #85127 5351 Jaycee Avenue Harrisburg, PA 17112 (717) 657-5729 Pietro Leone, Attorney Triple Crown Corporation, Inc. rage -/ oiz Plaintiff's Motion to Make Rule Absolute 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: Cherise Strickland-Mosby 444 Powell Drive Camp Hill, PA 17011 Coverall Cleaning Concepts 1017 Mumma Road, Suite 101 Wormleysburg, PA 17043 Date: D Pietro Leone, Attorney Triple Crown Corporation, Inc. Respectfully Submitted, By: Pietro Leone, Attorney, PA Bar #85127 5351 Jaycee Avenue, Harrisburg, PA 17112 717-657-5729 Page I of 1 Certificate of Service BSI y"'s L..? r. 01 CD _ a T V (D N N - w ?. a cr'? dc,? o C K D ? C 9 a C D o d a N ' ? G n v N a J N_ 'D .A• N v" 0 X C Z m v Es m tr•. e CO 0 3 co 00 ..1 T C N O A N z0 z n y m m ? 3 ag y ? Oi Q m v 3 m y_ n Cm R m n m ti a C C C C C X x Q u Lf n u 0 N N O C ,.: iLn ' r.. aim r c..n s CT Rehabilitation LP 5351 Jaycee Avenue Harrisburg, PA 17112 Plaintiff Vs vp 2 6 2008 IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, Cherise Strickland Mosley 444 Powell Drive Camp Hill PA 17011 Defendant NO. 06-3114 CIVIL ACTION - LAW ORDER AND NOW, having heard the above captioned atter a hearing is scheduled for day of 00440e^ month, l 3d 440before this Honorable Cou i Oc7`a?t/L ? aao?' i Mark DiSanto Attorney Triple Crown Corporation, Inc. S rdered, By the ourt Page I of 1 Order for Motion for Contempt of Court • T (26V rvowwo-314fOL ;ct,-M)rw sl ?60 - twielo/ Nf, 1 1 Yino 10 :9 Wv Z--1j0 goof dtldi5,- 1 73111 ??f r CT REHABILITATION IN THE COURT OF COMMON PLEAS OF LP CUMBERLAND COUNTY, PENNSYLVANIA 5351 JAYCEE AVENUE HARRISBURG, PA 17112 V. CHERISE STRICKLAND MOSLEY 444 POWELL DRIVE CAMP HILL, PA 17011 NO. 2006 - 3114 CIVIL TERM : CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 30TH day of OCTOBER, 2008, the parties having failed to appear at the scheduled hearing, (October 27, 2008, at 9:30 a.m. ) the Plaintiff s Motion for Contempt is DISMISSED. tro Leone, Esquire L"5351 Jaycee Avenue Harrisburg, Pa. 17112 f,, erise Strickland Mosley 444 Powell Drive Camp Hill, Pa. 17011 :sld y Edward E. Guido, J. >- c y, CD Lr) ?'' N t.1