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Home My WebLink About02-5290 DESSEN, MOSES & SHEINOFF s¥: DAVID S. DESSEN, ESQUIRE IDENTIFICATION NO. 1 7 6 2 7 1814 CH ESTNUT STREET PHILADELPHIA, PA 19103 (2~ 5) 564-5600 ATTORNEY FOR Plaintiff ENTERPRISE RENT-A-CAR 3 Crossgate Drive, Suite 201 Mechanicsburg, PA 17050 VS. MATTHEW J. HODGE 425 Northwest Street Carlisle, PA 17013 CUMBERLAND COUNTY COURT OF COllrnl40N PLF_,A~ CIVIL DIVISION TERM, CIVIL ACTION - COMPLAINT NOT)CE LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 Phone: 717-249-3166 circumstances; C. circumstances; d. f. CIVIL ACTION - COMPLAINT 1. Plaintiff, Enterprise Rent-A-Car, is a business with an address of 3 Crossgate Drive, Suite 201, Mechanicsburg, PA 17050. 2. Defendant, Matthew J. Hodge, is an adult individual who resides at 425 Northwest Street, Carlisle, PA 17013. 3. On or about November 26, 2000, Defendant, Matthew J. Hodge operated a motor vehicle rented from Plaintiff, Enterprise Rent-A-Car in such a negligent manner as to be involved in an accident causing substantial damage to the vehicle owned by Plaintiff, Enterprise Rent-A-Car, in the amount of $10,660.05. See attached Exhibit "A." 4. The accident was caused solely by the negligence of Defendant, Matthew J. Hodge, which included: a. failing to have said automobile under proper and adequate control; operating said automobile at an excessive rate of speed under the failing to make proper and adequate observation of existing failing to make proper and adequate reaction to the existing circumstances; failing to use due care under the cimumstances; and being otherwise careless and negligent. 5. Although demand for payment has been frequently made, Defendant has refused and continues to refuse to pay same. WHEREFORE, Plaintiff demands judgment in its favor and against Defendant, Matthew J. Hodge, in the amount of $10,660.05, plus costs. DESSEN, MOSES & SHEINOFF DAVID S. DESSEN, ESQUIRE Attorney for Plaintiff 0--3/29/01 TUE 15:25 FAX 717 795 7278 ENT.RAC #$799 Counter Ticket Enterprise Rent-A-Car 3 Cressgate Drive ~echar~J csburg, PA 17355 Date: 11/26/00 UniE% PT7417 Cust~ 999999 Ref ~ D10283 Operatou: WLG Debtor: MatLhew Hodg( Damage (ACV EvaluatioD} Appraisal fee Towing, Storage & Misc- Expe~se Ach~%n % st retire Costs L, oss Of Use Dimi_nJshment o:' value Salvage NaiveE Deducti] ~le Policy Deducti )lo subEotal Sales Tax Tohal Due Amount 11,585.{}5 .00 75.00 .00 ~00 .00 .00 1,000.00- .00 $10,660.05 .00 $10,660.05 This invoice is payable upon receipt Please detach and submit with payment RemJ t Te: EnterpriSe Nent-A-'laz 3 Cressgate Dr. Ste 201 Mechanjcsb~rg, PA 17055 GPBR 5710 Invoice% DX5710283 Cust~ 999999 Total Due 10,660.05 Pe~oun'k Remitted $ VERIFICATION DAVID S. DESSEN, hereby certifies that he is the attorney for Plaintiff in the within action, and that the facts set forth in the foregoing Civil Action - Complaint are true and correct to the best of his knowledge, information and belief. I understand that statements made herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unswom falsifiction to authorities. DATE: DAVID S. DESSEN SHERIFF'S RETURN - REGULAR CASE NO: 2002-05290 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ENTERPRISE RENT-A-CAR VS HODGE MATTHEW J DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HODGE MATTHEW J the DEFENDANT at 2038:00 HOURS, at 425 NORTH WEST STREET CARLISLE, PA 17013 MERVIN J HODGE SR, GR3INDFATHER on the 19th day of November , 2002 by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this ~_ day of A.D. - /p~ofhonok~r~-,,~/'~'~ So Answers: R. Thomas Kline 11/20/2002 DESSEN MOSES SHEINOFF ~Deput~ Sheriff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ENTERPRISE RENT-A-CAR 900 North Hanover Street Carlisle PA 17013 VS. Case No. 02-5290 MATTHEW J. HODGE 425 Northwest Street Carlisle PA 17013 PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a default judgment in favor of Plaintiff, Enterprise Rent-A-Car, and against Defendm~t, Matthew J. Hodge, in the amount orS 10,660.05, tbr failure to answer or otherwise respond to the Civil Action - Complaint filed with the Court on October 31, 2002. 1. The Complaint was served upon the Defendant on November 19, 2003, by the Sheriff of Cumberland County. The Defendant did not respond to the Complaint. 2. A copy of the Notice of Intention to Take Default Judgment was served upon Defendant on December 16, 2002, by regular mail. Pursuant to the Notice, Defendant had ten (10) days in which to answer the Complaint. The ten days have expired. David S. Dessen, Esquire DESSEN, MOSES & SHEINOFF 1 g 14 Chestnut Street Philadelphia, PA 19103 Phone: (215) 496-2910 Attorney I..D. No. 17627 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ENTERPRISE RENT-A-CAR 900 North Hanover Street Carlisle PA 17013 VS. Case No. 02-5290 MATTHEW J. HODGE 425 Northwest Street Carlisle PA 17013 PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY: Enter judgment in favor of Plaintiff and against Defendant fbr want of an answer. (xxx) Assess Damages as follows: Debt TOTAL $10,660.05 $10,660.05 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IF FOR SPECIFIC AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 David S. Dessen ESQUIRE 1814 Chestnut Street, Phila., PA 19103 Phone: (215) 496-2910 Attorney I.D. No. 17627 Attorney for Plaintiff This Defendant, $ day of , judgment is entered in favor of Plaintiff and against by default fbr want of an answer and damages assessed at the sum of as per the above certification. Prothonotary, Cumberland County DESSEN, MOSES& SHEINOFF BY: David S. Dessen IDENTIFICATION NO. 17627 1814 CHESTNUT STREET PHILADELPHIA, PA 19103 (215) 564-5600 ATTORNEY FOR PLAINTIFF ENTERPRISE RENT-A-CAR 3 Crossgate Drive, Suite 201 Mechanicsburg, PA 17050 COURT OF COMMON PLEAS CUMBERLAND DIVISION vs. NO. 02-5290 MATTHEW J. HODGE 425 Northwest Street Carlisle PA 17013 DATE OF NOTICE: December 16, 2002 NOTICE OF INTENTION TO ENTER JUDGMENT BY DEFAULT TO: MATTHEW J. HODGE 425 Northwest Street Carlisle PA 17013 AVISO IMPORTANTE USTED ESTA EN REBELDIA PORQUE HA FALLADO EN TOMAR LA ACCION EXIGIDA DE SU PARTE EN ESTE CASE. A MENOS DE QUE USTED ACTUE DENTRO DE DIEZ DIAS DE LA FECHA DE ESTE AVISO, SE PEUDE REGISTRAR UNA SENTENCIA CONTRA USTED, SI EL BENEFICIO DE UNA AUDIENCIA Y PUEDE PERDER SU PROPIEDAD O DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE AVISO A UN ABODADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO Y NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, DEBE COMMUNICARSE CON LA SIGUIENTE OFICINA PARA AVERGUAR DONDE PUEDE OBTENER AYUDA LEGAL. Lawyer Referral Service Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 71%24%3166 DESSEN, MJDS/F~ &~SHEINOFF David S. Dessen, Esquire Attorney for Plaintiff DESSEN, MOSES& SHEINOFF BY: David S. Dessen IDENTIFICATION NO. 17627 1814 CHESTNUT STREET PHILADELPHIA, PA 19103 (215) 564-5600 ENTERPRISE RENT-A-CAR 3 Crossgate Drive, Suite 201 Mechanicsburg, PA 17050 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND DIVISION vs. NO. 02-5290 MATTHEW J. HODGE 425 Northwest Street Carlisle PA 17013 DATE OF NOTICE: December 16, 2002 NOTICE OF INTENTION TO ENTER JUDGMENT BY DEFAULT TO: MATTHEW J. HODGE 425 Northwest Street Carlisle PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 717-249-3166 DESSEN, MOSES & SHEINOFF David S. Dessen, Esquire Attorney for Plaintiff ENTERPRISE RENT-A-CAR 900 North Hanover Street Carlisle PA 17013 VS. MATTHEW J. HODGE 425 Northwest Street Carlisle PA 17013 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Case No. 02-5290 AFFIDAVIT OF SERVICE OF TEN (10) DAY NOTICE COMMONWEALTH OF PENNSYLVANIA: ss COUNTY OF PHILADELPEtIA : I, David S. Dessen, ESQUIRE, being duly sworn according to law, depose and say that I served a copy of the attached Ten (10) Day Notice of Intention to Enter Judgment upon the Defendant by regular mail on the date set fbrth thereon. David S. Dessen, Esquire DESSEN, MOSES & SHEINOFF 1814 Chestnut Street Philadelphia, PA 19103 Phone: (215) 496-2910 Attorney I..D. No. 17627 SWORN TO AND SUBSCRIBED befbre methis ~ ~ ;d day of ~(~C~WCCOw' ,t~, 2003 / /, NOTARY PUI~LIC- i 'NOTARIAL SEAL ' I DOLORES BAYER Notary Public Oily of Ph~_~ia, Phila. County _ Igl~, P.,OiI~8~ ~ ~r '~ 7 2003 ENTERPRISE RENT-A-CAR 900 North Hanover Street Carlisle PA 17013 VS. MATTHEW J. HODGE 425 Northwest Street Carlisle PA 17013 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Case No. 02-5290 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: ss COUNTY OF PHILADELPHIA : 1. David S. Dessen. ESQUIRE, being duly sworn according to law, depose and say that I am authorized to take this Affidavit fbr and on behalf of Plaintiff; that Def'endant(s) is/are individuals(s), more than eighteen (18) years of age; and that Defendant(s) is/are not in the Armed Forces of the United States of America or its Allies, or otherwise within the pervue of the Soldiers' and Sailors' Civil Relief Act of 1940, as amended. David S. Dessen, Esquire '"'" DESSEN, MOSES & SHEINOFF 1814 Chestnut Street Philadelphia, PA 19103 Phone: (215) 496-2910 Attorney I..D. No. 17627 SWORN TO AND SUBSCRIBED belbre me this ~ ~ c4. day of ~~'L~ ,2003 ~ NOTARY / NOT.~RIAL SEAL J DOLORES BAYER Notary Pub / City of Philadelphia Pt~ la. Ooui~ty ~ Commission Exp!m? ~ove__ml~r OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ENTERPRISE RENT-A-CAR 900 North Hanover Street Carlisle PA 17013 VS. MATTHEW J. HODGE 425 Northwest Street Carlisle PA 17013 NOTICE Case No. 02-5290 Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. 7 Judgment by Default Money Judgment Judgment in Replevin Judgment lbr Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: David S. Dessen AT THIS TELEPHONE NUMBER: (215) 496-2910 C~ C~ r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PARKTON ENTERPRISES, INC. and DAVID A. KRULAC and DIANE E. KRULAC, husband and wife CIVIL DIVISION No.: 02-5473 Plaintiff, ISSUE NUMBER: VS. ORLANDO TORRES, JR. and ANAILDA MALAVE, TYPE OF PLEADING: PRAECIPE FOR DEFAULT JUDGMENT (Ejectment) Defendants. FILED ON BEHALF OF: Family Mortgage Service Corporation No. 19 Plaintiff I Hereby certify that the last known address of Defendant(s) is/are: 705{~r~ 'd Road COUNSEL OF RECORD FOR THIS PARTY: Scott A. Dietterick, Esquire Pa. I.D. #55650 JAMES, SMITH, DURKIN & CONNELLY LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PARKTON ENTERPRISES, 1NC. and : DAVD A. KRULAC and DIANE E. KRULAC, : Husband and wife, Plaintiffs, VS. ORLANDO TORRES, JR. and ANA1LDA MALAVE, Defendants. CIVIL DIVISION NO.: 02-5473 PRAECIPE FOR DEFAULT JUDGMENT IN EJECTMENT FOR POSSESSION OF THE REAL PROPERTY TO: PROTHONOTARY SIR/MADAM: Please enter a default judgment in ejectment in the above-captioned case in favor of Plaintiff and against Defendants, Orlando Torres, Jr. and Anailda Malave., for possession of the premises known as 705 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011. JAMES, SM~ELLY By: /~,./ /.,//~"V [/ Scott A. ~ie/teri~X'~ire ~ Attorney for{Plaintiff PA I.D. #55650 P.O. Box 650 Hershey, PA 17033 (717) 533-3280 LLP AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Scott A. Dietterick, Esquire, attorney for and authorized representative of Plaintiffwho, being duly sworn according to law, deposes and says that the Defendants are not in the military service of the United States of America to the best of his knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies. Scott A. Die~~efi~ Swom to and subscribed before me this~/oL~day of ~'~C~(FA~) 7 Notary Public My Commission Expires: ,2003. UW EtSTO , a um, COUNr , ,a NOTAN MICHELLE ELsie ...... U~.,C HUMMELSTOWN, ~AU~HIN COUNTY, PA | MY COMMI~S ON ~XPIRES JUNE 9, 20~ NOTA~ · CNELLE ELLiL~: -~! NUMMELSTOWN. DAUPHIN COUN~ MY COUMISSION EXPtRE8 JUNE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PARKTON ENTERPRISES, 1NC. and DAVID A. KRULAC and DIANE E. KRULAC, Husband and wife, : CIVIL DIVISION : : : Plaintiffs, : NO.: 02-5473 : : VS. ORLANDO TORRES, JR. and ANAILDA MALAVE, Defendants. : NOTICE OF ORDER, DECREE OR JUDGMENT TO: Orlando Torres, Jr. ( ) Plaimiff (XXX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ~. ( ) A copy of the Order or Decree is enclosed, or (XXX) The judgment is as follows: judgment in ejectment for possession of the premises known as 705 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011. Deputy ~ 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PARKTON ENTERPRISES, INC. and DAVD A. KRULAC and DIANE E. KRULAC, Husband and wife, CIVIL DWISION VS. Plaintiffs, : NO.: 02-5473 : : ORLANDO TORRES, JR. and ANAILDA MALAVE, Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Anailda Malave ( ) Plaintiff (XXX) Defendant ( ) Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ( ) A copy of the Order or Decree is enclosed, or (XXX) The judgment is as follows: judgment in ejectment for possession of the premises known as 705 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011. Deputy SHERIFF'S RETURN - REGUL~TM · CASE NO: 2002-0547~ F COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PARKTON ENTERPRISES INC VS TORRES ORLANDO JR ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon TORRES ORLANDO JR the DEFENDANT , at 1958:00 HOURS, on the 20th day of November , 2002 at 705 ERFORD ROAD CAMP HILL, PA 17011 by handing to ORLANDO TORRES JR a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this day of A.D. Prothonotary So Answers: R. Thomas Kline 11/21/2002 JAMES SMITH DURKIN CONNELLY ' ) ' Deput~z SHERIFF'S RETURN - REGULAR ,CASE NO: 2002-05475 ~ COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PARKTON ENTERPRISES INC VS TORRES ORLANDO JR ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon MALAVE ANAILDA the DEFENDANT , at 1958:00 HOURS, on the 20th day of November , 2002 at 705 ERFORD ROAD CAMP HILL, PA 17011 by handing to ANAILDA MALAVE a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this day of A.D. R. Thomas Kline 11/21/2002 JAMES SMITH DURKIN CONNELLY By: .- ~.~..~_,.,..~ l ~_~ ~Deputy Sheriff Prothonotary IN THE COURT OF COMMON PLEAS OF CUlVlBERLAND COUNTY, PENNSYLVANIA PARKTON ENTERPRISES, INC. and DAVID A. KRULAC and DIANE E. KRULAC, Husband and wife, Plaintiffs, VS. ORLANDO TORRES, JR. and ANAILDA MALAVE, Defendants. CIVIL DIVISION NO.: 02-5473 IMPORTANT NOTICE TO: Orlando Torres, Jr. 705 Erford Road Camp Hill, PA 17011 DATE OF NOTICE: January 9, 2003 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAIl,ED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. W YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PARKTON ENTERPRISES, INC. and DAVD A. KRULAC and DIANE E. KRULAC, Husband and wife, Plaintiffs, VS. ORLANDO TORRES, JR. and ANAILDA MALAVE, Defendants. CIVIL DIVISION NO.: 02-5473 AVISO IMPORTANTE A. Orlando Torres, Jr. FECHA DEL AVISO: January 9, 2003 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABA JO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYIJDA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 JAMES, SMITH DATE: t O~ BY: Scot . ,~~Y LLP )~"'~tq~, Esquire PA I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 FIRST CLASS U.S. MAIl,, POSTAGE PREPAID (717) 533-3280 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PARKTON ENTERPRISES, INC. and DAVD A. KRULAC and DIANE E. K.RULAC, Husband and wife, CIVIL DIVISION VS. Plaintiffs, ORLANDO TORRES, JR. and ANAILDA MALAVE, NO.: 02-5473 Defendants. IMPORTANT NOTICE TO: Anailda Malave 705 Erford Road Camp Hill, PA 17011 DATE OF NOTICE: January 9, 2003 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAIl.ED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. iF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PARKTON ENTERPRISES, [NC. and DAVID A. KRULAC and DIANE E. KRULAC, Husband and wife, Plaintiffs, VS. CIVIL DIVISION NO.: 02-5473 ORLANDO TORRES, JR. and ANAILDA MALAVE, Defendants. : AVISO IMPORTANTE A. Anailda Malave FECHA DEL AVISO: January 9, 2003 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QLrE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CA.BO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone (717) 249-3166 (800) 990-9108 JAMES, SMI~NNELLY LLP DATE:' /I/(~3 BY: __ Scott 4-~sq~re PA I.D. #55650 Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033 FIRST CLASS U.S. MAIL, POSTAGE PREPAID (717) 533-3280 . ~aint!ff: VS. Defendant: ~,ALTH OF PENNSYLVANIA ,-COMMON PLEAS ENTERPRISE RENT-A-CAR 900 North Hanover Street Carlisle PA 17013 MATTHEW d. HODGE 425 N West Street Carlisle PA 17013 MONEY JUDGMENT CASE NO. 02-5290 (Applicable to real estate and personal property) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County: (1) against (2) against MATTHEW ,I. HODGE 425 N West Street, Carlisle PA 17013 defendant(s) and (33~';AMOUNT DUE INTEREST from January 27, 2003 (Costs to be added) ..................... 30-195 garnishee(s) $10,660.05 .$799.06 Attorney(sg for Plainttff(s) ,~ 2,: ~MONWEALTH OF PEN2N.$YLVAN!A COURT OF COMMON PLEAS Plaintiff: VS. Defendant: ENTERPRISE RENT-A-CAR 900 North Hanover Street Carlisle PA 17013 MATTHEW J. HODGE 425 N West Street Carlisle PA 17013 MONEY JUDGMENT CASE NO. SC~02-5290 Vqrit of Execution TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against: MATTHEW J. HODGE, defendant(s) (1) You are directed to levy upon the property of the defendant(s) and to sell defendant's(s') interest therein: 425 N West Street, Carlisle PA 17013 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of as garnishee(s) (specifically describe property) and to notify garnishee(s) that (a) (b) an attachment has been issued: the garnishee(s) is (are) enjoined from paying any debt to or for the account of the defbndant(s) and f~om delivering any property of the defendant(s) or otherwise disposing thereof. (3) If property of the defendant(s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee(s), you are directed to notify him (them) that he (they) has (have) been added as garnishee(s) and (are) enjoined as above stated. REAL DEBT INTEREST from January 27, 2003 COSTS PAID: Prothonotary .................................. $ Sheriff ............................................ $ Statutory ......................................... $ COSTS DUE PROTHY ................ $ 30-196 (Rev. 9/95) $10,660.05 .$799.06 CURTIS R. LONG, Prothonotary Court of Common Pleas By Date Clerk David S. Dessen, Esquire 1814 Chestnut Street, Philadelphia, PA 19t 03 o~0 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-5290 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ENTERPRISE REBT-A-CAR Plaintiff(s) From MATTHEW J. HODGE, 425 N. WEST ST., CARLISLE PA 17013. (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON THE PROPERTY AT ABOVE ADDRESS. (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 formd 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 $$10,660.05 Interest FROM 1/27/03 -- $799.06 Atty's Corem % Atty Paid $108.45 Plaintiff Paid Date: JULY 6, 2004 (SeaO REQUESTING PARTY: Name DAVID S. DESSEN, EQUIRE Address: 1814 CHESTNUT ST. PHILADELPltlA PA 19103 Attorney for: PLAINTIFF Telephone: (215) 496-2902 Supreme Court 1D No. 17627 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Deptity QJ R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee TOTAL 18.00 1.27 .50 1.00 3.70 20.00 20.00 $ 64.47 Advance Costs: 150.00 Sheriff's Costs: 64.47 $ 85.53 Refunded to Arty on 07/26/04 Sworn and Subscribed to before me This Cgv dayof(~,,~t_~ 2004 A.D.~'~. (~) ~.~. ~o~~ · l-~'othonotary So Ans~vers~ ~'~ R. Thomas Kline, Sheriff Claudia A. Brewbaker