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HomeMy WebLinkAbout06-5601Steven E. Grubb, Esquire (I.D. #75897) GOLDBERG KATZMAN, P. C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161; (717} 234-6808 (facsimile) Counsel for Claimant ALEX R. SZELES, INC., Claimant v. THADDEUS RZEPELA, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. [~ -- SSG( PRAECIPE TO ENTER JUDGMENT To the Prothonotary, Please enter judgment in favor of Alex R. Szeles, Inc. in the amount of $4,772.93, plus interest and costs as they continue to accrue, and against Thaddeus Rzepela. This judgment is being transferred from the Dauphin County Court of Common Pleas, docket no. 2006-NT-2717. A certified copy of the docket entries, including a certification of the amount of judgment is attached hereto. GOLD~RG KATZMAI~I. ~C. Dated: September 25, 2006 By: ~ ~ .. St en E. Grubb, Esquire Attorney I. D. No. 75897 320 Market Street, Strawberry Square P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717} 234-4161 Attorneys for Claimant 139385.1 1 , ~tt ~~je t~ourt of ~011Y11YDtt ~Cea~ of ~au~~j%n ~uuritp, ~enr~~plbania Alex R Szeles Inc VS. No. 2006-NT-2717- Thaddeus Rzepela West Shore Vacuum Company CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT I, the undersigned Prothonotary of the Court of Common Pleas of Dauphin County, Pennsylvania, do hereby certify that the attached is a full, true and correct copy of the docket entries in the above captioned case. I further certify that judgment was entered in favor of Alex R. Szeles Inc and against Thaddeus Rzepela and West Shore Vacuum Company on June 7, 2006 in said case in the amount of $4772.93 stn ~egtimnnp ~Ijereof, I have hereunto set my hand and affixed the seal of the Court, on Monday, September 18, 2006. ~e> . Prothon tary By: Deputy JUDGMENT $4772.93 Interest from 4/24/06 Plaintiff Paid $23.00 Prothy. Due $10.00 This record $20.00 DJ Cost $149.01 Date: '9/1'8/2006 'Time: 03:59 PM Page 1 of 2 Filed: 6/7/2006 Dauphin County Complete Case History Case: 2006-NT-2717- Alex RSzeles Inc vs. Thaddeus Rzepela, etal. Physical File: Y Comment: Status History Pending Judge History Date Judge 6/7/2006 No Judge, Payments Alex R Szeles Inc (plaintiff) Goldberg Katzman Exemplified Record Miscellaneous Receipts Receipt Date 114787 9/18/2006 Plaintiff Appealed: N Reason for Removal Current Receipt Date Type 107418 6/7/2006 Civil Filing 114787 9/18/2006 Miscellaneous 20.00 Exemplified Record Name: Alex R Szeles Inc Address: Phone: Home: Employer: Litigant Type: Comment: Defendant Name: Address: Phone: Employer: Litigant Type: Comment: Rzepela, Thaddeus 350 Market St. Lemoyne Home: 6/7/2006 Work: PA 17043 Work: User: LBECHTEL Amount 23.00 20.00 Total 43.00 20.00 Sum: 20.00 SSN: DOB: Sex: Send notices: Y SSN: DOB: Sex: Send notices; Y Date: `9/rt8/2006 Dauphin County 'Time: 03:59 PM Complete Case History Page 2 of 2 Case: 2006-NT-2717- Alex RSzeles Inc vs. Thaddeus Rzepela, etal. Defendant Name: West Shore Vacuum Company SSN: Address: 350 Market St DOB: Lemoyne PA 17043 Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Register of Actions 6/7/2006 New Civil Case Filed This Date. No Judge, Filing: Judgment - DJ Paid by: Alex R No Judge, Szeles Inc (plaintiff) Receipt number: 0107418 Dated:6/7/2006 Amount: $23.00 (Check) Transcript of Judgment from the Docket of No Judge, Michael J. Smith, District Justice 4/24/06. Judgment for $4772.93 Entered At 8:43 a.m. Stephen E. Farina, Prothonotary District Justice Costs $149.01 Judgment Order date In Favor Of Disposition Judgment 06/07/2006 Plaintiff 06/07/2006 Open DJ Judgment Comment: 4772.93 Plaintiff: Alex R Szeles Inc Defendant: Rzepela, Thaddeus West Shore Vacuum Company q- ~~-oc~ I hereby certify that the foregoing is a true and c rrect co q#kthejoriginal filed. Protho otary/Clerk of Court User: LBECHTEL CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have served a true and correct copy of the foregoing Praecipe to Enter Judgment on the person or persons listed below by U.S. Mail, as follows: Thaddeus Rzepela 350 Market Street Lemoyne, PA 17043 GOLDBERG KATZMAN, P.C. DATE: September 25, 2006 By: . teven E. Grub , squi 139385.1 n ~ ~~#' b d -~. w 0 -~' C7 ° ~- C~, ;s „~ ~,~` _ "t7 ~ ~ `. -'~ { 1 '..i ~~, = N ~~ "-~ :.~; r~ 4 ~ IlV THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: ^ Confessed Judgment ALEX R . SZELES , INC . ~ ®O~~ File No. 2006-05601 v, :Amount Due $ 4, 7 7 2 . 9 3 THADDEUS RZEPELA :Interest Accruing from 6/7/06 at the legal rate, Atty's - 1:84.38 a s o f his writing Costs r (01/28/07) 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 Cumber 1 a n d County, for debt, interest and costs, upon the following dcscnbed property of the defendant (s) Real property located at 350-352 Market Street, Lemoyne, PA. The legal description of the Real Property is attached hereto. 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 garnishce(s). ^ (Indicate) Index this writ against the ganushee (s) as a defendant(s) described in the attached exhibit. Date Q / - 3 0 - C~ `~ Signature: Print Name: Address: lis pendens aga' t re estate f Steven E, rubb o erg atzman, PC 5-29 ~l.ar-ket St p-0. Box 1268 Harrisburg, PA 17108-1268 Attomeyfor: Claimant Alex R. Szeles, Inc. Telephone: 717 / 2 3 4 - 4161 Supreme Court ID No: 7 5 8 9 7 ~-' ~- C i r., ~ ~ ~ ~ ~ ,r~ ,~, o ~ ~_ _:~;~~,~ t .~a ~ __~ ~ s ~ -- ~~~ X01/30/2007 12:27 FAX 717 234 6808 GOLDBERG KATZMAN ~ GKS CARLISLE f~002/002 ~. ' ~ ... Know all ~Vlen by these Presents 'ILat I, R. Thomas !Cline SbedH ~ ~ ~°lY °f Cum6eelead is tbs Slate of f'enaryhania, for and is eoarderatioa of tfic aum of _~10~ • 000.40 One Hundred Thousand ---------------------------~--------~----;~t,~ bo a'1e IsLaad paid, do Lee~seael and eenvey W Thaddeus RzepelEt, Nia heirs and asaigne •, , ALL THAT CEPTAIN let of 1..d .ia.1. in uc Bal~eneia a • s..aa~+• cau~be~ad ~ nA~ . ~ ~ ~ibd u . yd de , y ~ BtaS/O 1.e1 Np, l l9 is • I~u o[ Liuu toiow~ • Plt of ltaKh R;v„le. Ido. S Wd oil br ~ H ~~N . e u0 R i ~ Iteoaide~~ OAka, Clanbalald cou~r : plan soak lia. ~, f+-ee. 1 i R 12 Slid tat pto. 119 fianls • IO k+ef a rip Soeti~am e~ of IdYi~el 511011, Y la9d o5a in Nld' ,• (~~ Yd Ci1Ad• ~'~ 111e M1M 1 rlidlh 1!0 k~et b • x0 kr +~1da { agar, p RIaR11e0 b rlid ' • i~ ~ Ater .ne .l r di • ol. e , ~ ppe v ~ e 1. NAVMO Ibe~n eredd ahw ra~•yr eenmle~fal: Eep~ god ~ ~1eLel~od pb a G k1~w~n u ]~]]Z ~ . 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WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N006-5601 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Alex R. Szeles, Inc. Plaintiff (s) From Thaddeus Rzepela (1) You are directed to levy upon the property of the defendant (s)and to sell Real property located at 350-352 Market Street, Lemoyne, PA. See legal description . (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 $4,772.93 L.L.$.50 Interest Accruing from 6/7/06 at the legal rate, $184.38 as of this writing (01/28/07) Atty's Comm Atty Paid $37.50 Plaintiff Paid Due Prothy $1.00 Other CostsDauphin Co. Costs $182.01 Date: January 30, 2007 (Seal) REQUESTING PARTY: Name Goldberg Katzman, PC Steven E. Grubb,Esq. Address: 320 Market St., P.O. Box 1268 Harrisburg, PA 17108-1268 Attorney for: Alex R. Szeles, Inc. Telephone: 717/234/4161 C s R. Long, onot By: Deputy Supreme Court ID No. 75897 ALEX R. SZELES, INC., Claimant v. THADDEUS RZEPELA, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-05601 NOTICE OF SALE PURSUANT TO RULE 3129.2(c) TO: DEFENDANT THADDEUS RZEPELA 350 Market Street Lemoyne, PA 17043 Property located at 350-352 Market Street, which is held in the name of Thaddeus Rzepela, will be sold on June 13, 2007 at the Cumberland County Courthouse, to satisfy the judgment entered June 7, 2006 in the amount of $4,772.93, plus interest, plus all costs. A notice directed to all parties-in-interest and claimants that a schedule of distribution will be filed by the Sheriff on the date specified by the Sheriff, not later than thirty (30) days after sale, and that distribution will be made in accordance with the schedule, unless exceptions are filed thereto within ten (10) days after the filing of the schedule. Respectfully submitted, Dated: January 30, 2007 GOLDB TZ , P.C. By: S en E. Grubb, quire (I. D. No. 75897) 320 Market Street, P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Claimant 142565.1 ('~ N tY' ~ "' 4 ~ -v `+`1 T ..W ~~ .. ~ " ' ~:~ ~~, ., -}~ - _.__.. "' - C _ ALEX R. SZELES, INC., Claimant v. THADDEUS RZEPELA, Respondent 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-05601 AFFIDAVIT PURSUANT TO RULE 3129.1 Alex R. Szeles, Inc., plaintiff in the above action, by and through its counsel, Goldberg Katzman, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at 350-352 Market Street, Lemoyne, PA (The Real Property to be sold is described on the Exhibit attached hereto.) 1. Name and address of owner(s) or reputed owner(s): Name: Address: Thaddeus Rzepela 350 Market Street Lemoyne, PA 17043 2. Name and address of defendant(s) in the judgment: Name: Address: Thaddeus Rzepela 350 Market Street Lemoyne, PA 17043 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: None, other than above-referenced claimant. 142564.1 4. Name and address of the last recorded holder of every mortgage of record: None. Name and address of every other person who has any record lien on the property: None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: None. I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. GOLDBERG TZM , P.C. ~' Dated: January 30, 2007 By: to .Grubb, Esquire . D. No. 75897) 320 Market Street, P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Claimant 142564.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN th On this, the 3C? day of January, 2007, before me, a notary public, the undersigned officer, personally appeared Steven E. Grubb, Esquire, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Affidavit and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. N RY P BLIC ( AL) COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL JENNIFER L. BOLTZ, Notary Public City of Harrisburg, Dauphin County ~~ .3Il.2IIU9 142564.1 ('~ N ~.~ -~ W~~` m~? _ _ c, _..7 .. - .~ ~y~ .. .~,a i i :~ ~~-{ ,v r~i '.,~ti r Steven E. Grubb, Esquire (I.D. #75897) GOLDBERG KATZMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161; (717) 234-6808 (facsimile) Counsel for Claimant ALEX R. SZELES, INC., Claimant v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-5601 THADDEUS RZEPELA, Respondent PRAECIPE TO SETTLE. DISCONTINUE AND END WITH PREJUDICE TO THE PROTHONOTARY: Please mark the above-captioned case as paid in full and discontinued with prejudice, terminating the above-captioned matter in its entirety. Respectfully Submitted, GOLDBE KATZMAN, P.C. ~y: S en E. Grubb, Esquire (I. D. No. 75897) 320 Market Street P.O. BOX 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Plaintiff Dated: Apri124, 2007 146559.1 +- .~. CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have served a true and correct copy of the foregoing Praecipe to Discontinue on the person or persons listed below by U.S. Mail, as follows: Thaddeus Rzepela 350 Market Street Lemoyne, PA 17043 GOLDB G KATZM , P C. DATE: Apri124, 2007 By: ven E. Grubb, squire C? ~' p ~w ~ ~ ~ `` ~ ~ -..~ ~ ~ , :~ r "-- _ rv - ~ ` - ` .sx Yy C ;+ ~' i~. ~ ~ ` ~ wt Alex R. Szeles, Inc. VS Thaddeus Rzepela In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-5601 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Steven E. Grubb. Sheriffls Costs: Docketing $30.00 Poundage 103.55 Advertising 15.00 Law Library .50 Prothonotary 1.00 Mileage 15.36 Levy 15.00 Surcharge 20.00 Share of Bills 16.17 $ 216.58 So Answers; ~' `~ R. Thomas Kline, Sheriff BY ~ ~ ~ < ^yVl~(,~~ Real Estate Se eant ,~1.5°~a9 t,~ ~,5q Iga~O P~ ~ .•, r~ ALEX R. SZELES, INC., IN THE COURT OF COMMON PLEAS Claimant CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2006-05601 THADDEUS RZEPELA, Respondent AFFIDAVIT PURSUANT TO RULE 3129.1 Alex R. Szeles, Inc., plaintiff in the above action, by and through its counsel, Goldberg Katzman, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at 350-352 Market Street, Lemoyne, PA (The Real Property to be sold is described on the Exhibit attached hereto.) 1. Name and address of owner(s) or reputed owner(s): Name: 2. 3 Address: Thaddeus Rzepela 350 Market Street Lemoyne, PA 17043 Name and address of defendant(s) in the judgment: Name: Address: Thaddeus Rzepela 350 Market Street Lemoyne, PA 17043 Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: None, other than above-referenced claimant. 142564.1 i, `.~ 4. Name and address of the last recorded holder of every mortgage of record: None. 5. Name and address of every other person who has any record lien on the property: None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: None. I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. GOLDBERG TZM , P.C. Dated: January 30, 2007 By: --- te .Grubb, Esquire . D. No. 75897) 320 Market Street, P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Claimant 142564.1 .-- i . COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN th On this, the 3~~ day of January, 2007, before me, a notary public, the undersigned officer, personally appeared Steven E. Grubb, Esquire, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Affidavit and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. N RY P LIC ( AL) COMMONWEAL7M t9~ rENNSYLVANIA NOTARIAL SEAL JENNIFER L. BOLTZ, Notary Public City of Harrisburg, Dauphin County r„~ mi~~inn . nirae May_3Il.2UU9. _ __ _.. 142564.1 ti ALEX R. SZELES, INC., Claimant v. THADDEUS RZEPELA, Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-05601 NOTICE OF SALE PURSUANT TO RULE 3129.2(c) TO: DEFENDANT THADDEUS RZEPELA 350 Market Street Lemoyne, PA 17043 Property located at 350-352 Mazket Street, which is held in the name of Thaddeus Rzepela, will be sold on June 13, 2007 at the Cumberland County Courthouse, to satisfy the judgment entered June 7, 2006 in the amount of $4,772.93, plus interest, plus all costs. A notice directed to all parties-in-interest and claimants that a schedule of distribution will be filed by the Sheriff on the date specified by the Sheriff, not later than thirty (30) days after sale, and that distribution will be made in accordance with the schedule, unless exceptions are filed thereto within ten (10) days after the filing of the schedule. Respectfully submitted, GOLDBE TZ , P.C. By: S ~ en E. Grubb; -quire (I. D. No. 75897) 320 Market Street, P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Claimant Dated: January 30, 2007 142565.1 ,. . ALL THAT CERTAIN lot of land situate in the Borough of Lemoyne, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEING Lot No. 119 in a Plan of Lots known as a Plan of North Riverton No. S, as laid out by R.H. Hummel Estate, which said Plan is duly recorded in the Recorder's Office, Cumberland County in Plan Book No. 1, Pages 11 & 12. Said Lot No. 119 fronts 40 feet on the Southern line of Market Street, as laid out in said Plan and extends back the same width 150 feet to a 20 feet wide alley, as by reference to said Plan, it will more fully and at large appear. HAVING thereon erected a two and one-half story commercial building and a detached garage. BEING known as 350-352 Market Street, Lemoyne. BEING the same premises which R. Thomas Kline, Sheriff of the County of Cumberland, in the State of Pennsylvania by deed dated September 2, 1992, and recorded October 14, 1992 in the Office of the Recorder of Deeds in and far Cumberland County, Pennsylvania, in Deed Book X, Volume 35 at Page 1080, et seq., granted and conveyed unto Thaddeus Rzepela. SEIZED, taken in execution and to be sold as the property of Alfred E. Quigley, and Charlotte K. Quigley, Judgment debtors and real owners. 143981. I WRIT OF EXECUTION and/or ATTACHMENT r ~, .y COMMONWEALTH OF PENNSYLVANIA) N006-5601 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Alex R. Szeles, Inc. Plaintiff (s) From Thaddeus Rzepela (1) You are directed to levy upon the property of the defendant (s)and to sell Real property Located at 350-352 Market Street, Lemoyne, PA. See legal description . (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 $4,772.93 L.L.$.50 Interest Accruing from 6/7/06 at the legal rate, $184.38 as of this writing (01/28/07) Atty's Comm Atty Paid $37.50 Plaintiff Paid Due Prothy $1.00 Other CostsDauphin Co. Costs $182.01 Date: January 30, 2007 (Seal) C s R. Long, onota By: Deputy REQUESTING PARTY: Name Goldberg Katzman, PC Steven E. Grubb,Esq. Address: 320 Market St., P.O. Box 1268 Harrisburg, PA 17108-1268 Attorney for: Alex R. Szeles, Inc. Telephone: 717/234/4161 Supreme Court ID No. 75897 m Real Estate Sale # 46 On February 21, 2007 the Sheriff levied upon the defendant's interest in the real property situated in Lemoyne Borough, Cumberland County, PA Known and numbered as 350-352 Market Street, Lemoyne, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 21, 2007 By: fp Real Estate Sergeant 0~ ~Z c! I - b3.J ldQl