HomeMy WebLinkAbout07-0132COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CMMERLAND ?7 -
I Mag. Dist. No.:
09-1-01
MDJ Name: Hon.
CHARLES A. CLEMENT, JR
Address: 400 BRIDGE ST
OLDS TONNE COMMONS -SUITE 3
NEW CUMBERLAND, PA
Telephone: (717 ) 774-5989 17070
CT REHABILITALTION
100
GEORGETOWN ROAD
NECHANICSBURG, PA
LP
17050
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF
® Judgment was entered for: (Name)
(Date of Judgment)
CT REHABILITALTION LP
11/29/06
® Judgment was entered against: (Name) BAER, WALTER/JENNIFER
in the amount of $ 1, 484.5
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 $ 1,397.00
Judgment Costs $ 87. 50
Interest on Judgment $ .00
Attorney Fees $ .00
Total $ 1,484.50
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 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.
NOV 2 9 2006 Date
I certify that this is a true and correct copy of
4N - 2 20237 - Date 1,0
My commission expires first Monday of January, 2008
NOTICE OF JUDGMENT/TRANSCRIPT
D CIVIL CASE
PLAINTIFF: NAME and ADDRESS
r
CT RRHABILITALTION LP
100
GEORGETOWN ROAD
LMECHANICSBDRG, PA 17050 J
VS.
DEFENDANT: NAME and ADDRESS
rBASR, WALTER/JENNIFER
4968
NORTH SUSQUEHANNA TR
LYORR, PA 17406 J
Docket No.: CV-0000559-06
Date Filed: 10/10/06
Magisterial District Judge
containing the judgment.
, Magisterial District Judge
SEAL
AOPC 315-06
DATE PRINTED: 11/29/06 2:05:00 PM
c. -
V
CT Rehabilitation LP IN THE COURT OF COMMON PLEAS
5351 Jaycee Avenue CUMBERLAND, COUNTY, PENNSYLVANIA
Harrisburg, PA 17112
Plaintiff
Vs NO. 07-132
Walter Baer Jr.
4968 Susquehanna Trail. CIVIL ACTION - LAW
York, PA 17406
Defendant
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, Walter Baer Jr. and the Defendant's employer, United Rentals, 940 Cornwall Road,
Lebanon, PA 17042, 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 29, 2006 in the amount of $1,397.00, Docket
Number CV-0000559-06. Post judgment costs increased this amount to $1,484.50, which
is shown on the certified judgment.
3. Payments in the amount of $300.00 brings final amount due to $1,184.50.
4. The District Justice Judgment was filed with this Court on January 8, 2007, under Docket
Number 07-132 Civil Term.
5. There has been no prior judge involvement, except for Ruling by District Justice Clement
(see attached).
6. Defendant is pro-se.
7. Given Defendant is pro-se, concurrence of opposing counsel cannot be obtained.
8. Reasonable attempt has been made to contact and make payment arrangement to satisfy
Judgment Docket Number CV-0000559-06. Defendant made three payments in the amount
of $100.00 each. Last payment was made on April 9, 2007.
9. The Defendant is currently employed at United Rentals, 940 Cornwall Road, Lebanon, PA
17042.
10. 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.
11. 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.
12. Copies of the District Justice Judgment and the proposed attachment order are attached
hereto.
13. WHEREFORE, the Plaintiff hereby requests that the Honorable Court issue the proposed
rule to show cause against both the Defendant, Walter Baer Jr. and his current employer,
United Rentals, 940 Cornwall Road, Lebanon, PA 17042.
Respectfully Submitted:
Date: C - ?,J 7__ ?0 0
Zietro Leone Attorney, A 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:
Walter Baer Jr.
4968 Susquehanna Trail
York, PA 17406
Respectfully Submitted,
Date: CD " d7- o??00 7
'/0 '7 '-, --?
k, IB y: Pietro Leone, Attorney
PA Bar #85127
5351 Jaycee Avenue
Harrisburg, PA 17112
717-657-5729
'NWEALTH OF PENNSYLVANIA NOTICE OF JUDGMENT/TRANSCRIPT
a -Y OF: CUMBERLAND p7- )3 CIVIL CASE
ag. Dist. No.: PLAINTIFF: NAME and ADDRESS
09-1-01 FCT REHABILITALTION LP
MDJ Name: Hon. 100
CHARLES A. CLEMENT, JR GEORGETOWN ROAD
Address: 400 BRIDGE ST PCHANICSBURG, PA 17050
J
OLDS TOWNE COMMONS -SUITE 3 vs.
NEW CUMBERLAND, PA DEFENDANT: NAME and ADDRESS
Telephone: (717 ) 774-5989 17070 FBAER, WALTER/ JENNIFER
4968
NORTH SUSQUEHANNA TR
LYORR, PA 17406 J
CT RBHABILITALTION LP
100 Docket No.: CV-0000559-06
GEORGETOWN ROAD Date Filed: 10110106
MECHANICSBURG, PA 17050
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF (Date of Judgment) 11/29/06
® Judgment was entered for: (Name) CT REHABILITALTION LP
® Judgment was entered against: (Name) BAER, WALTER/JENNIFER
in the amount of $ 11 484.5
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
$
Portion of Judgment for physical damages arising out of
residential lease $
Amount of Judgment $ 1,397.00
Judgment Costs $ 87.50
Interest on Judgment $ .00
0
Attorney Fees $ .0
ITotal $ 1,484.50
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 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 MAGIST IALP,6STRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE J{GMegg MFILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT-Qf&OR PPAA'YS SUILL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. t.,.
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NOY 2 9 2006 Date u'? , Magisterial District Judge
I certify that this is a true and correct copy of
Date ojn? 1 .
roceedings containing the judgment.
My commission expires first Monday of January, 2001
L. , Magisterial District Judge
SEAL
AOPC 315-06
DATE PRINTED: 11/29/06 2:05:00 PM
rfi
C_ i 'yj
CT Rehabilitation LP IN THE COURT OF COMMON PLEAS
5351 Jaycee Avenue CUMBERLAND, COUNTY, PENNSYLVANIA
Harrisburg, PA 17112
Plaintiff
Vs NO. 07-132
Walter Baer Jr.
4968 Susquehanna Trail. CIVIL ACTION - LAW
York, PA 17406
Defendant
RULE TO SHOW CAUSE
AND NOW, this day of 200 ,upon consideration of the
foregoing Petition For A Rule To Show use 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, Walter Baer Jr., and his current employer, United
Rentals, 940 Cornwall Road, Lebanon, PA 17042 to show cause why the petitioner is
not entitled to the relief requested;
2. the respondent shall file an answer to the petition within o v 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, United Rentals, 940 Cornwall Road, Lebanon, PA
17042.
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CT Rehabilitation LP IN THE COURT OF COMMON PLEAS
5351 Jaycee Avenue CUMBERLAND COUNTY, PENNSYLVANIA
Harrisburg, PA 17112
Plaintiff
Vs NO. 07-132
Jennifer Baer Jr.
4968 Susquehanna Trail =
York, PA 17406 CIVIL ACTION - LAW
Defendant
Praecipe to Enter Appearance for Judgment
1. Kindly enter the appearance for Mark X. DiSanto, Attorney for the plaintiff - PA Bar #51090.
To: Court of Common Pleas Prothonotary
?•Z3.O8?
Date
1 Y?1
Mark X. DiSanto, PA Bar #51090
5351 Jaycee Avenue
Harrisburg, PA 17112
717-657-5729
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,ice
CT Rehabilitation LP
5351 Jaycee Avenue
Harrisburg, PA 17112
Plaintiff
Vs
Jennifer Baer Jr.
4968 Susquehanna Trail
York, PA 17406
Defendant
1. Judgment is paid in full.
2. Please satisfy this judgment.
To: Court of Common Pleas Prothonotary
? -z 6-o8'
Date
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-132
CIVIL ACTION - LAW
Praecipe to Satisfy Judgment
(A
Mark X. DiSanto, PA Bar #51090
5351 Jaycee Avenue
Harrisburg, PA 17112
717-657-5729
' ? l j
CT Rehabilitation LP
5351 Jaycee.Avenue
Harrisburg, PA 17112
Plaintiff
Vs
Walter Baer Jr.
4968 Susquehanna Trail
York, PA 17406
Defendant
1. Judgment is paid in full.
2. Please satisfy this judgment.
To: Court of Common Pleas Prothonotary
5-ak-0%
Date
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-132
CIVIL ACTION - LAW
Praecipe to Satisfy Judgment
Mark X. DiSanto, A Bar #51 0
5351 Jaycee Avenue
Harrisburg, PA 17112
717-657-5729
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CT Rehabilitation LP IN THE COURT OF COMMON PLEAS
5351 Jaycee Avenue CUMBERLAND, COUNTY, PENNSYLVANIA
Harrisburg, PA 17112
Plaintiff
Vs NO. 07-132
Walter Baer Jr.
4968 Susquehanna Trail CIVIL ACTION - LAW
York, PA 17406
Defendant
Praecipe to Enter Appearance for Plaintiff
1. Kindly enter the appearance for Mark X. DiSanto, Attorney, PA Bar #51090.
To: Court of Common Pleas Prothonotary
5 - ZA •O-S
Date
Al ALd
Mark X. DiSanto, A Bar #51090
5351 Jaycee Avenue
Harrisburg, PA 17112
717-657-5729
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