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Home My WebLink About02-1380 09-3-02 oa - I:JPC> <21'Q~ L '--rS2..~ NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 'KNupp & KODAK, P.C. I P. O. BOX 11848 407 N. FRONT STREET ~ISBURG, PA 17108-1848 ~ VS. COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Dist. No.: OJ Name: Hon HELEN B. SHULENBERGER Address: P.O. .BOX 155 27 W. BIG SPRING AVENUE NEWVILLE, PA Telephone (717) 776-3187 17241 DEFENDANT: NAME and ADDRESS IoITZLER, MONICA 536 GRAHMS WOODS ROAD CARLISLE, PA 17013 L Docket No.: CV- 0000152 - 01 Date Filed: 10/11/01 I ~ . KNUPP & KODAK, P.C. P. O. BOX 11848 ' 407 N. FRONT STREET HARRISBURG, PA 17108-1848 THIS IS TO NOTIFY YOU THAT: Judgment: 00 Judgment was entered for: (Name) 00 Judgment was entered against: (Name) DEFAULT JUDGMENT PLTF ~pp & ~nn~~, p ~ DTT7.T.RR, MONTCA in the amount of $ '>,A::\A qA on: (Date of Judgment) (Date & Time) 1/?q/O? . o Defendants are jointly and severally liable. o . D This case dismissed without prejudice. Amount of Judgment Judgment Costs . Interest on Judgment -. Attorney Fees Total 5,737.98 101.00 .00 .00 5,838.98 Amount of Judgment Subject to Attachment/Act 5 of 1996 $ D D D Post Judgment Credits $ Post Judgment Costs $ Levy is stayed for days or D generally stayed. ------------ ------------ Certified Judgment Total $ Objection to levy has been filed and hearing will be held: Date: Place: Time: , .' . ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER 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 JUDGMENTITRANSCRIPT FORM WITH'YOUR NOTICE OF APPEAL . ". .- . - I certify that this is a true and correct' copy of the record of the proceedings containing the judgment. ~ ~ - CQ Date , District Justice . District Justice' My commission expires first Monday of January, AOPC 315-99 2006 SEAL { ~ i ~ - ~ (') = C) C 1'0 -'1 "-.) s:: :J: 0'1\ ~(C ::.~ _::1 .......... _lrn :::0 "1 :~D f ~ ~~:X~. 'f"._- ~ vi~: N ;.-T; -0 0 .'':9 ~ ~ ~c; -:i(~ ?:: -0 .i~ j ~ -,.;: -...- -.1 ~~~~ J -c: ~ '-' IV' :z: --I i'0 ~i"::'- - =< 5::J g: eJl -< ~Oft IATTORNIY FOR PlAINTlFIi ~ CAPOZZI & ASSOCIATES, P.c. By: Donald R. Reavey, Esquire Attorney I.D. No. 82498 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 Attorneys for the Plaintiff, Joyner Sports Medicine Institute, Inc. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JOYNER SPORTS MEDICINE INSTITUTE,INC. Plaintiff CIVIL ACTION LAW No. 02-1380 CIVIL TERM v. JOSE DOMINGUEZ, P.T. Defendant PETITION FOR A STATUS CONFERENCE AND NOW, comes the Plaintiff, by and through its Counsel, Capozzi and Associates, P.C., and for it Petition for a Status Conference states as follows: 1. The Complaint in this matter was filed on April 12, 2002 alleging that Jose Dominguez, P.T had, among other things, breached the "Non-Competition Clause" of his employment agreement with the Plaintiff by opening a competing business within one mile of the Plaintiff's facility. 2. On June 6, 2002, the Plaintiff answered the Defendant's written Interrogatories. The deposition of the Defendant took place on June 13, 2002, and the deposition of a representative of the Plaintiff took place on June 18, 2002. 3. Some settlement negotiations have taken place between the parties since June of2002, however, to date, the parties have been unable to amicable resolve this matter. 4. The Petitioner believes that conducting a status conference will aid in establishing a schedule for setting this matter for trial and to determine where the parties stand with regard to settlement. 5. Plaintiff has attempted to contact Counsel for the Plaintiff by telephone regarding this matter, but the calls were not returned. Accordingly, Plaintiff must assume that the Defendant would oppose setting this matter for a status conference. WHEREFORE, the Plaintiff respectfully requests that this Honorable Court issue a rule to show cause, in the proposed form, why this matter should not be scheduled for a status conference, or in the alternative should this Honorable Court believe that it may set this matter for a status conference without the need for a rule, the Plaintiff would respectfully request that this Honorable Court enter an Order in the proposed form scheduling the same. Respectfully submitted, CAPOZZI & ASSOCIATES, P.C. Date: ')/, r/tJ7 BY:~~~-- - Donald R. Reavey, Esquire Attorney ID No. 82498 2933 North Front Street Harrisburg, PAl 711 0 (717) 233-4101 Fax (717) 233-4103 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JOYNER SPORTS MEDICINE INSTITUTE, INC. Plaintiff CIVIL ACTION LAW No. 02-1380 CIVIL TERM v. JOSE DOMINGUEZ, P.T. Defendant AFFIDAVIT OF SERVICE I Karen Fisher, an employee of Capozzi & Associates, P.C. hereby certify that I have this 5th day of January 2004 served a copy of the Motion for a Status Conference, upon the following parties, or their counsel, in this proceeding via first class U.S. Mail: Kathryn L. Simpson, Esquire Mette, Evans & Woodside 3401 North Front Street PO Box 5950 Harrisburg, PA 17110 I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. e.s. 94904 relating to unsworn falsification to authorities ;;;Z. en L. Fisher, \<\ssistant Capozzi & Asso'a ,P.C. 2933 North Front Street Harrisburg, Pennsylvania 17110 Telephone: (717) 233-4101 ~'< 0 --: .-< "" ~:~ J-- 5:':: ::<J i-,} N C) 'T1 --;< r11 :;] r- -::-1(''1 ;~y ~;~j ~~) -n (.,,) .-;( , [, '" ., KNUPP, KODAK & IMBLUM, P.C. Plaintiff : In the Court of COMMON PLEAS of : Cumberland County, Pennsylvania v. NO. 02-1380 MONICA DITZLER CIVIL DIVISION - LAW Defendant(s) PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned Judgment as settled and satisfied in full. TO CUMBERLAND County Prothonotary Dated: April 22. 2005 ~ --.--.. Robert D. Kodak Attorney for Plaintiff Attorney I.D. No. 18041 Q r;; -1(=7 d~r~-: ;:.:::.;" 0;-':- r.::L. ~c 4C :);> -" ~;.:.:: ~ -, -- ,..., = = <.n "'" -0 :::0 N 0" o '-n ~.:D ..,.,tn -,)0 ?--.1. :::4 C) ~r:"; '):n ~'''' (") (~~,rn s: :n :..;: -0 ::It w Ul W