HomeMy WebLinkAbout07-0113COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND Q7 - Ili
Mag. Dist. No.:
09-1-01
MDJ Name: Hon.
CHARLES A. CLEMENT, JR
Address: 400 BRIDGE ST
OLDS TOME COMMONS -SUITE 3
NEW CUMBERLAND, PA
Telephone: (717 ) 774-5989 17070
CT REHABILITALTION LP
100 GEORGETOWN ROAD
MECHANICSBURG, PA 17050
THIS IS TO NOTIFY YOU THAT:
Judgment: DEFAULT JUDGMENT PLTF
(Date of Judgment)
11/03/06
Judgment was entered for: (Name) CT REHABILITALTION LP
Judgment was entered against: (Name) SCOTT, MARC ANTHONY
in the amount of $ 2,010.41-
F1 Defendants are jointly and severally liable.
Damages will be assessed on Date & Time
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 $
Amount of Judgment $ 1,919.91
Judgment Costs $ 90.So
Interest on Judgment $ •
Attorney Fees $ .00
Total $ 2,010.41
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
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.
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.
- 3 2000 Date
I certify that this is a true an orrect co y of the
IEC 2 1 2006 Date ,
My commission expires first Monday of January, 2008
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
r
7
CT REHABILITALTION LP
100 GEORGETOWN ROAD
MECHANICSBURG, PA 17050
L J
VS.
DEFENDANT: NAME and ADDRESS
rSCOTT, MARC ANTHONY
4242 CARLISLE PIKE APT/STE 222
CAMP HILL, PA 17011
L J
Docket No.: CV-0000547-06
Date Filed: 10/03/06
Magisterial District Ju
gs containing the judgment.
, Magisterial District Judge
SEAL
AOPC 315-06
DATE PRINTED: 11106106 12:04:00 PM
? o
? l C-i
? o
x?
1-16
CT Rehabilitation LP
5351 Jaycee Avenue
Harrisburg, PA 17112
Plaintiff
Vs
Marc Anthony Scott
4242 Carlisle Pike, Suite 222
Camp Hill, PA 17011
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND, COUNTY, PENNSYLVANIA
NO. 07-113
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, Marc Anthony Scott and the Defendant's employer, Coverall Cleaning Concepts, 4242
Carlisle Pike, Suite 222, Camp Hill, PA 17011, 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 November 3, 2006 in the amount of $1,919.91, Docket
Number CV-0000547-06. Post judgment costs increased this amount to $2,010.41, which
is shown on the certified judgment.
3. The District Justice Judgment was filed with this Court on January 5, 2007, under Docket
Number 07-113 Civil Term.
4. Reasonable attempt has been made to contact and make payment arrangement to satisfy
Judgment Docket Number CV-0000547-06. No response was received from defendant.
5. The Defendant is currently employed at Coverall Cleaning Concepts, 4242 Carlisle Pike,
Suite 222, Camp Hill, PA 17011.
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.
s- - >
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, Marc Anthony Scott and his current
employer, Coverall Cleaning Concepts, 4242 Carlisle Pike, Suite 222, Camp Hill, PA
17011.
Respectfully Submitted:
Date: l? 0-7
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:
Marc Anthony Scott
4242 Carlisle Pike, Suite 222
Camp Hill, PA 17011
Respectfully Submitted,
Date: _ ??-
By: Pietro Leone, Attorney
PA Bar #85127
5351 Jaycee Avenue
Harrisburg, PA 17112
717-657-5729
COMMONWEALTH OF PENNSYLVANIA ii
COUNTY OF: CUMBERLAND
Mag. Dist. No.:
09-1-01
MOJ Name: Han.
CHARLES A. CLEMENT, JR
Address: 400 BRIDGE ST
OLDE TOWER COMMONS -SUITE 3
NEW CUMBERLAND, PA
Telephone: (717 ) 774-5989 17070
CT REHABILITALTION LP
100 GEORGETOWN ROAD
MECHANICSBURG, PA 17050
THIS IS TO NOTIFY YOU THAT:
Judgment: DEPAULT JvDGKIENr PLTF
(Date of Judgment) 11103106
® Judgment was entered for: (Name) CT REHABILITALTION LP
® Judgment was entered against: (Name) SCOTT, MARC ANTHONY
in the amount OT $ 2.010.4
F] Defendants are jointly and severally liable.
Damages will be assessed on Date & Time
This case dismissed without prejudice.
Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127
F1 Portion of Judgment for physical damages arising out of
residential lease $
Amount of Judgment $ 1,919.91
Judgment Costs $ 90.50
Interest on Judgment $ • 0
Attorney Fees $ .90
Total $ 21010.41
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
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.
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.
- A tUU5 Date
I certify that this is a true an orrect co y of the re of
IEC 2 1 2006 Date
My commission expires first Monday of January, 2008
NOTICE OF JUDGMENT/TRANSCRIPT
e&4 CIVIL CASE
PLAINTIFF: NAME and ADDRESS
rCT REHABILITALTION LP
100 GEORGETOWN ROAD
MECHANICSBURG, PA 17050
L
vs.
J
DEFENDANT: NAME and ADDRESS
rSCOTT, MARL ANTHONY
4242 CARLISLE PIKE APT/STE 222
CAMP SILL, PA 17011
L_ J
Docket No.: CST-0000547-06
Date Filed: 10/03/06
Cn
-
- o.
C
Magisterial Dis lct J[;ge ?M
-c
?s containing the judgment.
, Magisterial District Judge
SEAL
AOPC 315-06
DATE PRINTED: 11106106 12:04:00 PM
C=l
?Y( tel.' = r
? t ??
CT Rehabilitation LP
5351 Jaycee Avenue
Harrisburg, PA 17112
Plaintiff
Vs
Marc Anthony Scott
4242 Carlisle Pike, Suite 222
Camp Hill, PA 17011
Defendant
JAN 18 MAW
IN THE COURT OF COMMON PLEAS
CUMBERLAND, COUNTY, PENNSYLVANIA
NO. 07-113
CIVIL ACTION - LAW
RULE TO SHOW CAUSE
AND NOW, this day of 2007, 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, Marc Anthony Scott, and his current employer,
Coverall Cleaning Concepts, 4242 Carlisle Pike, Suite 222, Camp Hill, PA 17011, to
show cause why the petitioner is not entitled to the relief requested;
2. the respondent shall file an answer to the petition within 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, 4242 Carlisle Pike, Suite
222, Camp Hill, PA 17011.
o
o"
By the CAUrt:
P I f 1"..r.. - n,7n
611 .01 HV 6? NIF LODZ
OTTIJ
CT Rehabilitation LP
5351 Jaycee Avenue
Harrisburg, PA 17112
Plaintiff
Vs
Marc Anthony Scott
6765 Huntington Street
Harrisburg, PA 17111
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND, COUNTY, PENNSYLVANIA
NO. 07-113
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. There has been no prior judge involvement, except for Ruling by District
Justice Clement.
2. Concurrence of opposing counsel was sought but was not obtained due to the
Defendant's lack of appearance at the November 3, 2006 hearing.
3. On January 11, 2007, Plaintiff, CT Rehabilitation LP, filed a Petition for A
Rule to Show Cause Why an Order Granting Wage Attachment Should Not
Issue.
4. On January 26, 2007, this Honorable Court issued a Rule to Show Cause with
a return within 20 days of service.
5. The Defendant has not answered the Rule.
6. 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,
Mark X. DiSanto, Attorney, PA Bar #51090 Page 1 of 2
Triple Crown Corporation, Inc. Plaintiffs Motion to Make Rule Absolute
Coverall Cleaning Concepts, 6765 Huntington Street, Harrisburg, PA 17111, as well as
all current or subsequent employers.
Date: V0 " ? 'Q`)
Mark X. DiSanto, Attorney, PA Bar 951090
Triple Crown Corporation, Inc.
Respectfully Submitted:
?JWA44 L'Ic
Mark DiSant , orney
PA Bar #51090
5351 Jaycee Avenue
Harrisburg, PA 17112
(717) 657-5729
Page 2 of 2
Plaints 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:
Marc Anthony
6765 Huntington Street
Harrisburg, PA 17111
Coverall Cleaning Concepts
6765 Huntington Street
Harrisburg, PA 17111
Respectfully Submi
Date: ?6 ` ? - o-)
By: Mark X. U
PA Bar #51090
Attorney,
5351 Jaycee Avenue, Harrisburg, PA 17112
717-657-5729
Mark X. DiSanto, Attorney, PA Bar #51090 Page I of I
Triple Crown Corporation, Inc. Certificate of Service
c': ?,
?:, .??)
?-?, 'r'i
r-? --f
r__, .'T T1
E ? .
? ;";
_i?'•,
..J ...i
:• i
?_ -,?
., _-R
.t:" .`?7
r`?: -?G
CT Rehabilitation LP
5351 Jaycee Avenue
Harrisburg, PA 17112
Plaintiff
Vs
Marc Anthony Scott
6765 Huntington Street
Harrisburg, PA 17111
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND, COUNTY, PENNSYLVANIA
NO. 07-113
CIVIL ACTION - LAW
Aµeuoea
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. There has been no prior judge involvement, except for Civil Ruling by District
Justice Clement on November 3, 2006 and Rule to Show Cause by Judge Hess
on January 26, 2007.
2. Concurrence of opposing counsel was sought but was not obtained due to the
Defendant's lack of appearance at the November 3, 2006 hearing.
3. On January 11, 2007, Plaintiff, CT Rehabilitation LP, filed a Petition for A
Rule to Show Cause Why an Order Granting Wage Attachment Should Not
Issue.
4. On January 26, 2007, this Honorable Court issued a Rule to Show Cause with
a return within 20 days of service.
5. The Defendant has not answered the Rule.
6. 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
Mark X. DiSanto, Attorney, PA Bar #51090
Triple Crown Corporation, Inc.
Page 1 of 2
Plaints Motion to Make Rule Absolute
1
Not Issue and GRANT a wage attachment against the Defendant's current employer,
Coverall Cleaning Concepts, 6765 Huntington Street, Harrisburg, PA 17111, as well as
all current or subsequent employers.
Date: ? 0 - [ S ' 0-)
Mark X. DiSanto, Attorney, PA Bar #51090
Triple Crown Corporation, Inc.
Respectfully Submitted:
Mark DiSanto, Attorney
PA Bar #51090
5351 Jaycee Avenue
Harrisburg, PA 17112
(717) 657-5729
Page 2 of 2
Plaintigs Motion to Make Rule Absolute
C3 N
Q O
C 'n
M:n
--{
r-
t'_' -r1
C>-. 8
J
Sw
,' - e " w ? OCT - 81007,oi
CT Rehabilitation LP IN THE COURT OF COMMON PLEAS
5351 Jaycee Avenue CUMBERLAND, COUNTY, PENNSYLVANIA
Harrisburg, PA 17112
Plaintiff
Vs NO. 07-113
Marc Anthony Scott
6765 Huntington Street CIVIL ACTION - LAW
Harrisburg, PA 17111
Defendant
ATTACHMENT ORDER
AND NOW, this ZS' day of 0-4--i-l' , 2007, 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, Marc Scott. The Defendant's employer is Coverall Cleaning Concepts, 6765 Huntington Street,
Harrisburg, PA 17111. 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 $2,010.41.
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.
So Ordered, By the Court
Mark DiSanto, Attorney, PA Bar #51090 Page 1 of 1
Triple Crown Corporation, Inc. Attachment Order
f j,_„ 1 7
S i Ji d S;130 LODZ
?'Hi JO