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Home My WebLink About03-0869COMMONWEALTH OF PENNSYLVANIA I - COURT OF COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. NAME[ O{~r APP~EI_I. AN~r ALFRED WILLIAMS, SR. 19119 fDefendent) Sr. Docket No.:CV-0000001-03 419 W. Hotter Street Philadelphia, Pa. 2/7/03 [ Kenneth E. Stoner, Jr. vs. Alfred W$~.liams, TA 20 LT 20 [Christophe: B. McOowan, Esquire - ID#88744 This block will be signed ONLY when this notation is required under Pa. R.C.P.J.P. No. 1008B. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case. Signature of Prothonotary or Deputy If appellant was Claimant (see Pa. R.C.P.J.P. No. 1001(6) in action before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NO TICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This ~ect/on of form to be used ONLY when appel/ant was DEFENDANT(see Pa. R.C.P.J.P. No. 1001(7) /n act/on before D/strict Justice. /F NO T USED, detach from copy of not/ce of appeal to be served upon appellee). PRAECIPE: To Prothonotary Enter rule upon Kenneth E. (Common Pleas No. ~-~ -- eO/eq Stoner, Jr. , appellee(s), to file a complaint in this appeal / ~.~of appellee(s) ~/O'.~ ~. /~'~ithin twenty (20) days after service of rule or suffer entry of judgment of non pros. ~g at e o appel/ant or his attorney or agent RULE: To Kenneth E. Stonerr Jr. ,appellee(s) Christopher B. McGowan, Esquire Name of appel/ee(s) Marks, O'Neill, O'Brien & Courtney 1880 JFK Blvd., Suite 1200 Philadelphia, Pa. 19103 (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of this rule-i~ service waS,~b¥ mail is the date of mailing. j · ' ~ Si~.~,ture of Prothon~ar~lor AOPC 312-84 COURT FILE TO BE FILED WITH PROTHONOTARY PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FIL ED WITHIN FI VE (5) DA YS AFTER firing the notice of at)pea/. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; ss AFFIDAVIT: I hereby swear or affirm that I served [] a copy of the Notice of Appeal, Common Pleas No. , upon the District Justice designated therein on (date of service) , 20 , [] by personal service [] by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) , on , 20__ [] by personal service [] by (certified) (registered) mail, sender's receipt attached hereto. whom the Rule was addressed on , 20 mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND S~'~RIB~ED B'EF~RE ME THIS DAY OF , 20 and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to ,' ~ by p'ersonal ser,cice ~ b~y (certified) (registered) Signature of affiant Signature of official before whom affidavit wes made Title of official My commission expires on ,2O E,LL,E No,910 02/12 '03 12:48 ID:NYSRWB FA×:5183583363 PAGE 1 09-3-05 DJ Nllme; Non, ~"'"' 50'7 (73.7) 766'4575 17055 419 W.HOHTT~ ST PHILADELPHIA, PA 19119 T~IS IS TO NOTIFY YOU THAT: Judgmerlt: 914 COCKLIN ~IC~B~G, PA 17055 DE FENDANT: N~E ,~ ADORES& 419 W. HORT~ PHI~EL~, PA 19119 L Docket No.: C'V'-0000001-03 Date Flied: 12/31/02 Judgment was entered for: (Name) .... Judgment was entered against: (Name) W1'LTJ~ In the amount of $ ~:_.~4 _ no on: E~ Defendants are Jointly end severally liable. [~-] Damages will be assessed on: [~ This case dismissed without prejudice, (Date of Judgment) (Date & Time) Amount of Judgment Subject to [~ AttachmentJAct 5 of !996 $, A.N.Y PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAY8 AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE ~'R~THONOTARYICLERK OF THE COURT OF COMMON PLEAS, C~'ViL DIVISION, YOU' .... -- MUgT INCLUDE A COPY OF THIS NOTICE OF JUDGMENTFrRANIICRIPT FORM WITH YOUR NOTIOE OF APPEAL. EXOEPT Aa OTHERWIISE PROVIDED IN THE RULE8 OF CIVIl. PROCEDURE FOR DISTRICT JUBTICEa, IF THE JUDGMENT HOLDER",.· ELECT8 TO ENTER THE JUDGMENT IN THE OOURT OF COMMON PLEAE, ALL FURTHER PROOESe MUST COME FROM THE*O.*~URT OF OOMMON PLEA9 AND NO FURTHER PROCE88 MAY BE IgBUED BY THE DleTRICT JUSTIOE. * . .'v. UNLiie~ THE JUDGMENT le ENTERED IN THE COURT OF COMMON PLEAB, ANYONE INTEREeTED IN TI~E JU*DQMEI~r A REQU~S'T FOR ENTRY..OF ~ATII~FAC'I:ION WITH THE DIBTRICT JUSTICE IF THE JI~DGMENT I~EETOR PAYS*IN I~ULL,*$ETYL,'E~'; ....... ,'..t '" . ';.,. '0:"":; ,.,'pl..,, *. .....,~ ,:;.;' ', ." . " . . .~":'..',,.=~,".'* ,:.~,,.~.~a~,,.,,.,,*~.*'. , . . · ,'~.~. ..,.SL~,.~T',:;'~,' :.: . + ,. ,....,, .~ ..... ~, :.. ,'./..'~: .' .~..., ;.., . * ..... ' '- "" ... · ,' ..,~ !"'" ...... :.t,' ~:~.' .,~.::,,,:.',~,~,~.t~:j,t. *';i'~;'.":,...' ,, ':;-'..' t'' ~, .e... ,',... :,,, . .~.h. '" C.':.,''" ~' ,~, .. ~..., · .,~ .. ...... ,. ,~ .............. ~.,.~. ~ ....... ~, a; .:~.h ',*':/?l'~ ~.' ' ' . - ' ' - ' ' . . .' .' .. {a,~.'. '.a'. ,:-.~.* :..':,: ,-.. , !~ tt,~. ~f *, .. ., k',r%;:... . /':. : ."=..';' ;','; ,,'".~' '{.~'~.' .... '.!~.':: ~.".':'~.~'."~':" ' 4~,", . i '"~, ,x... . · ' ~ ,~. ,m , ..~ '*' ........... ~ .. '.-. I~'~"-'.,' ,~.., v .:.-.., ,- ....... ~.: "~.' :~"' ~,r"*; '. ~ ~7'". ~ ..... ' "" '"' '''f~ '" ' ..., ... :.. '* ...... ......, ....... , ..,,..,.,,,.,, ...::..:....,, ..... ;t: ;"'":"," ".:"."h.;' ' ..,,L:.:f,..,~ ,.;..~.:,. :....,~ ,....,;,...:~...,;~, ~" 'L%.",'. ,k~,4' , ',:,'.:,',.,'.., ~,~",' , ,,'~, · .:~:p, .: ..:.,~.. ~.;- ..,,, .~ :... ........ . .... ..; ......... ,'~,~)f~l~?... j, :".?';,. ¥';:;~ .,.5:.~,,~' 1~...,.......::,.... .., ........ · ~.~4,,.. ,.,:~:,, r....!.¥.:. :. .... '., ..... ' ..... ' .,,. :,, . : . ... , '.; . - . ;1.. .. ,:'.-: ..... ...,,, .' . ;;, '.., "": "~ .' ., '.. 'Date ' ' ..... '*" · .... :.',",:'., ;, ' :' · ,' D!strlgt.;J~tice ' "":': ''~ -.v-.. Post Judgment Credits Post Judgment Costs $~_______ Certified Judgment Total $ My commission expires first Monday of January, 2006 . AOPC 31,5-03 SEAL Am'o~n-i-~f Judgment $~ Judgment Costs $ 7.9.00 Interest on Judgment $ . .00 Attorney Fees $~ Total $_~ COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. NOTICE OF APPEAL Notice is given that;tbi~ app.e, llant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and i~-'i~ ~ase merit pried below. .... ,..o.",.,_: · . . .. .............. . .......... ~.,.~ Philadel hia Pa. . uer r~ ;..~[ed ~1~ Sr. Docket No. ~CV-O000001-03 LT 20 ~"'~- ?'~ ~;'- This block will be signed ONLY when this notation is required under Pa. /f appel/ant was Claimant (~e Pa. R.C.P.J.P. R.C.P.J.P. No. 1008B. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case. Signature of Prothonotary or Deputy No. 1001(6) in action before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This sect/on of form to be used ONLY when appel/ant was DEFENDANT (see Pa. R.C.P.J.P. No.' 1001(?) in act/on before D/strict Just/ce. IF NOT USED, detach from copy of notice of appeal to be served upon appellee). PRAECIPE: To Prothonotary ' Enter rule upon ~lVarne of appellee(s) appellee(s), to file a comXplaint in this appeal (Common Pleas No.. O.~ -- G~/~ - ~4"/~J~thin twenty (20)days after service of rule or suffer entry of judgment of non pros. ~ '"" -' / Signature Of appellant or bis ~ttorney or a~n~ Harks, O'N~il,l~' ~O'B~ien & Courtney ~880 JFK Blvd., SUi[e 1200 .,_. Philode~hia~ Pa. 19103 (1) You are notified that a rule is hereby entered upon you to file a complaint in m,s appea{w,t~[~ twenty (20) service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within ~is time, a J~OG~E~T O~ ~O~ PHOS WILL SE E~TEHEO AG~i~ST (3) The date of service of this ru{e if service was by mai{ is the date of mailing. ' AOPC 312-84 COURT FILE: PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FIL ED WI THIN FI VE (5) DA YS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF Philadelphia AFFIDAVIT: I hereby swear or affirm that I served a copy 9J--tJ~Notice of Appeal, common PleaS No. 03-86_______~9 , upon the District Justice designated therein on [] (date 'f~ervice~ 3/5/03 ,20 _, [~] by personal service ~] by (certified) (registered) mail, sender's receip~d hereto, and upon the appellee, (name) Kenneth Stoner ~ Jr o , on 3/6/03 , 20~ [~] by personal service [] by (certified) (registered) mail, sender's receipt attached hereto. [] and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom the Rule was addressed on 3/6/03 ,20~ mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME Sign~_u_rTof offi~ial~before Who~B~ffida~it w, aS made ~t~;fo°frnfi~'ia;sion ex'~es one, 20~ _. , [~ by personal service ~ by (certified) (registered) Signature of affia.~ r'rl ru Postage r-~ Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees ~, 50 Postmark I Recipi,~t's N~e (P~ea. se Prin~le~ be completed by mailer) ' ...................................... Postage, Ce~ified Fee Ret.rn Receipt Fee I ~ P~mark ' Restricted DeliveW Fee Total Postage & Fees r' ........ ~;~YS~ '* '~-~ .... ,' o ;;'-;-~ ............. f---~:~--: .................. ¢ · ................................. ~ ...... · Complete iter~ 1, 2, and 3. Aisc complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that We can return the ard t · Attach this card to .... ~. o you. ~,~u Dali( of the mailpiece, or on the front if Space P~'mits 1. Article Addressed to: ~ :f by (P/ease Print C/early) C. Signature ' D. Is delivery address different from item 1~ r3 Addressee If YES, enter defivery address below: I-3 No {~,~Jertified Marl [] Express Marl [] Registered [] Insured Mail ~ Return Receipt for Merchandise C.O.D. 4. Restricted Deliver? (Extre Fee) [] Yes ................... ~- i '- ; 95-00-M.0952 · Print SO · reverse 1;:' or on the mailpiece, Kenneth E. StOner, Jr. 914 Cocklin Street Mechanicaburg, Pa. 17055 Marl ~ Receipt for Merchandise Service D°mestlCReturnReceipt ~ ~'~1~.-- ~q~L~ MARKS, O'NEILL, O'BRIEN, & COURTNEY, P.C. BY: CHRISTOPHER McGOWAN, ESQUIRE IDENTIFICATION NO. 88744 1880 JFK BOULEVARD, SUITE 1200 PHILADELPHIA, PENNSYLVANIA 19103 (215) 564-6688 ATTORNEY FOR DEFENDANT Alfred Williams file # 736-69408 Kenneth E. Stoner plaintiff VS. Alfred Williams defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL DIVISION March TERM, 2003 No. Order to Settle Discontinue and End TO THE PROTHONOTARY: Kindly mark the above-captioned mater Settled, Discontinued and Ended. Re~ectfull~' submitted, 'Kenneth E. Stoner Plaintiff Christop[er McGowan, Esquire Attorney for Defendant Alfred Williams PH047042.1 MARKS, O'NEILL, O'BRIEN, & COURTNEY, P.C. BY: CHRISTOPHER McGOWAN, ESQUIRE IDENTIFICATION NO. 88744 1880 JFK BOULEVARD, SUITE 1200 PHILADELPHIA, PENNSYLVANIA 19103 (215) 564-6688 ATTORNEY FOR DEFENDANT ALFRED WILLIAMS SR. file # 736-69408 KENNETH E. STONER plaintiff VS. ALFRED WILLIAMS, SR. defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL DIVISION DECEMBER TERM, 2002 NO. 2003-869 PRAECIPE TO ENTER JUDGMENT OF NON PROS TO THE PROTHONOTARY: Kindly enter a Judgment of Non Pros in the above-captioned matter for Plaintiff's failure to comply with a Rule to File a Complaint. In support thereof, Defendant Alfred Williams, Sr. relies upon the attached Affidavit. MARKS, O'NEILL, O'BRIEN & COURTNEY, P.C. Ch McGowan, ESQUIRE Attorney for Defendant Alfred Williams, Sr. PH047042.1 AFFIDAVIT IN SUPPORT OF DEFENDANTS' PRAECIPE TO ENTER A JUDGMENT OF NON PROS I, Christopher McGowan, ESQUIRE, being duly sworn according to law, depose and say: 1. I am an attorney in the Law Firm of MARKS, O'NEILL, O'BRIEN,& COURTNEY P.C., and am familiar with the facts and circumstances of this matter. 2. On or about February 7, 2003, a default judgement was entered in this case in favor of the plaintiff Kenneth E. Stoner by District Justice Gayle A. Elder. 3. On or about February 26, 2003, Christopher McGowan, Esquire, of MARKS, O'NEILL, O'BRIEN & COURTNEY, P.C., filed a Notice of Appeal on behalf of Alfred Williams, Sr., along with a Preacipe to Issue a Rule to File a Complaint. 5. A Rule to File a Complaint was entered upon the Plaintiff on or about the same day, February 26, 2003. 6. Defendant, Alfred Williams, Sr., through his attorneys, caused said Rule to be served upon Plaintiff on or about March 3, 2003. 7. More than twenty (20) days have passed since service of the Rule to File a Complaint was effected upon plaintiff and plaintiff has not filed a complaint. See Exhibit "A", a true and correct copy of defendant's transmittal letter to plaintiff enclosing said Rule to File Complaint. See attached Exhibit "B", a true and correct copy of the Rule to File a Complaint. See Exhibit "C", a true and correct copy of the Notice of Intent to File Praecipe for Judgment of Non Pros. PH047042.1 8. More than ten (10) additional days have passed since service of the Notice of Intent to File a Praecipe to Enter a Judgment of Non Pros was effected upon plaintiff and plaintiff still has not filed a complaint. 9. Defendant, Alfred Williams, Sr., now file this Praecipe for Entry of Judgment of Non Pros. MARKS, O'NEILL, O'BRIEN & COURTNEY, P.C. Christopher McGo , ESQUIRE an Attorney for Defendant Alfred Williams, Sr. SWORN AND SUBSCRIBED BEFORE ME 2003 PH047042.1 EXHIBIT "A" PH047042.1 BUCKS COUNTY OFFICE SUITE 106 10 SOUI~ CLIINTON STREET DOYLESTOWN, PA 18901 (267) 880-3696 FAX (267) 880-0545 MONTGOMERY COUNTY OFFICE 411 CHERRY STREET NORRISTOW~, PA 19401 (610) 277-7601 DELAWARE OFFICE 913 NORTH MARKET STREL~, sUITE 800 WILMIIqGTON, DE 19801 (302) 658-6538 FAX: (302) 658-6537 ~La. RKS, O'NEILL, O'BRIEN & COURTNEY, P.C. ATTORNEYS AT LAW SUITE 1200 1880 JOHN F. KENNEDY BOULEVARD PHILADELPHIA, PA 19103 (215) 564-6688 FAX: (215) 564-2526 March 3, 2003 NEW JERSEY OFFICE SUITE 300 COOPER RIVER WEST 6981 NORTH PARK DRIVE ~,n~SA~, NJ 08109 (856) c~3-4~00 FAX (856) 663-4439 PITTSBURGH OFFICE SUITE 3200, GULF TOWER 707 GRANT STREET PrYrSBURGH, PA 15219 (412) 391-6171 FAX: (412) 391-8804 CHRISTOPHER B. MCGOWAN M~nber PA Bar cmcgow~nt~moodaw, oom Kenneth E. Stoner, Jr.' 914 Cocklin Street Mechanicsburg, Pa. 17055 Kenneth E. Stoner, Jr. vs. Alfred Williams, Sr. Docket No.:03-869 Our File No.: 736-69408 Dear Mr. Stoner: Enclosed please Defendant, Alfred Williams, Sr. Notice of Appeal in the above referenced matter. Please note that a Rule is hereby entered upon you to file a Complaint in this appeal within twenty (20) days upon receipt of this letter. Should you have any questions, please feel free to contact the undersigned. Very truly yours, MARKS, O'NEILL, O'BRIEN & COURTNEY, P.C. C'~risto~her. B. McGowan CBM/imi Enclosure Certified Mail-Return Receipt Requested/No. 7000 0600 0028 3162 3994 EXHIBIT "B" PH047042.1 COMMONWEALTH OF PENNSYLVANIA ' COURT OF COMMON PLEAS [ FROM , JUDICIAL DISTRICT I DISTRICT JUSTICE JUDGMENT .. NOTICE O.F APPEAL .., '~ Notice is given that the appellant has filed in the above Court of 'Common Pleas an appeal, from the judgment rendered by 'the District Justice on the date and in the case mentioned below. NAMI[ OF APPI[L.I.,ANT I ?/?,~.~ . .~.,.. ~.,~,,.,..~.~... ~,.,,,~,~'~,.'; .~.. -~,~:~.,~-~.,~', I TA 20 This block will be signed .ONLY when this notation is required Under ~a. - If appel(ant was Claimant (see Pa. R.C.P.J.P. R.C.P.J.P. No. 1008B. This Notice of Appeal, when received by .the District Justice~ will operate as a SUPERSEDEASto the judgment for possession in this case. SignatUre of Pr~th;notary or 'Deputy No. 100.~(~) /n act/on before D/strict Just/ce, he MUST FI.LE A COMPLAINT wi.~,in twenty. (20) days after filing his NOTICE of APP~AL · " ........ '-'" ........... "P-R'AEC'ilSE' TO'-':ENTE'R RULE: "TO "FI L'E COMPLAINT'AND 'Ru-kE;'"TO FI I~E :';; .... : ', L. ,- (This sect/on of ·form to be used..ONL Y when appellant Was DEFENDANT (see Pa. R.C.P.J.P. No.. 1001(7) in act/on before.D/strict JustiCe~ IF NOT USED, detach from copy of not/ce of appeal to be served upon appellee). PRAECIPE: To Prothonotary Enter rule upon ~9'n~:c~h ~. (Common Pleas No. (,i',) .... - / q*~.~;~,- ~- appellee(s), to file a complaint in this appeal .......... I~an~ o'f appellee(s) 4 ""' · / ._,~' . ) w~thin twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or his attorney or agenr RULE: 'To, ~' .... ~, ~. ~,-~,~,,;.- T.~- ........ ~ ~' appellee(S) ~ ~' . C~'~Cop[~e~'~ ~cGo',~a,~.~ iESCJt;,,iT~ Name o f appellee(s) ~e Tk5 ~ 0 * ~e ~. [ ! , 0 p ~J r J.e 13 & C0133~ ~ 11e ~ ~880 '3¥K Blvd.., Suite t200 (1) You are notified that a rule is hereby entered upon you to file a complaint in tnfs appeal w~tmn twenty/zul oays a~er the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. Date: (3) The date of service of this rule if service was by mail is the date of mailing. AOPC 312-84 COPY TO P~E SERVED ON-APPELLEE EXHIBIT "C" PH047042.1 MARKS, O'NEILL, O'BRIEN, & COURTNEY, P.C. BY: CHRISTOPHER McGOWAN, ESQUIRE IDENTIFICATION NO. 88744 1880 JFK BOULEVARD, SUITE 1200 PHILADELPHIA, PENNSYLVANIA 19103 (215) 564-6688 ATTORNEY FOR DEFENDANT Alfred Williams file # 736-69408 Kenneth E. Stoner plaintiff VS. Alfred Williams defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL DIVISION March TERM, 2003 No. 03-896 NOTICE OF PRAECIPE TO ENTER JUDGMENT NON PROS To: Kenneth E. Stoner, plaintiff Date of Notice: April 9, 2003 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO FILE A COMPLAINT IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR RIGHT TO SUE THE DEFENDANT AND THEREBY LOSE 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 2 Liberty Avenue Carlisle, Pa. 17013 1-800-990-9108 By: MARKS, O'NEILL, O'BRIEN & COURTNEY, P.C. Ch r McGowan, ESQUIRE Attorney for Defendant, Alfred Williams, Sr. PH047042.1 VERIFICATION I, Christopher McGowan, Esquire, verify that I am the attorney for defendant, Alfred Williams, Sr., and that the statements made in the foregoing are true and correct to the best of my knowledge,information, and belief. The undersigned understands that the statements herein are made subject to the penalties 18 PA. C.S.A. §4904 relating to unsworn falsification to authorities. MARKS, O'NEILL, O'BRIEN & COURTNEY, P.C. Christopher McGowan, ESQUIRE Attorney for Defendant Alfred Williams, Sr. PH047042.1 CERTIFICATE OF SERVICE I hereby certify that services of a true and correct copy of the within matter was served on all parties of record by first-class mail, postage prepaid. MARKS, O'NEILL, O'BRIEN & COURTNEY, P.C. Christopher McGowan, ESQUIRE Attorney for Defendant Alfred Williams, Sr. PH047042.1 CERTIFICATION OF NOTICE OF INTENT TO FILE PRAECIPE FOR JUDGMENT OF NON PROS I, Christopher McGowan, Esquire, certify pursuant to Pennsylvania Rule of Civil Procedure 237.1(2) that I served via first-class mail a written notice of intention to file a praecipe to enter judgment of non pros on all parties of record on the ~T~ day of April, 2003. MARKS, O'NEILL, O'BRIEN & COURTNEY, P.C. Christopher McGowan, ESQUIRE Attorney for Defendant Alfred Williams, Sr. PH047042.1