HomeMy WebLinkAbout01-05254IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption: n L ~ ` ( )Confessed Judgment
a~ ( ve.Sfn 2e'~
( )Other
File No. O ~ S Z ~`)
vs. AmountDue~ Z n(o4,~D
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TO THE PROTHONOTARY IOFTHE SAID COURT:
Atty's Comm
Costs
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 ems,-~~e~~~.~ County,
for debt, interestQQa11lInd costs, upotln the following described property of the defendant(s)
R I1 t1P!~S ni... \ 4~rnna r~V
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 garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date _ tt Mara. Zn02 Signature: //~~,,
Print Name: ~A e L. (5/u£sEn~ Ee>° Y
Address: Sri /"E.dcN ~~fti .~,a~~
[Sq.e~~N~2t ~i4 f73z
Attorney for:
Telephone: (ZI`1~ `~$~-S~ t^7
Supreme Court ID No.:
(over)
Notes: If real property, supply six copies of description including improvements and an original and copy of
affidavit of ownership (PaR.C.P. No. 3129).
If lengthy personalty list, supply four copies of list.
To index writ, file separate praecipe with writ.
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NOTICE OF APPEAL
FROM
JUDICIAL DISTRICT
DISTRICT JUSTICE JUDGMENT
( ~ COMMON PLEAS No ~/+, ~ `p.-y l /~
NOTICE OF APPEAL '~ 7
Notice is given }hat the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the
date and in tlfe case mentioned• below _
en~5 .
rnw~. Ha}. rvax wt rvwmc u ux
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$'q-61 Cracy ~-- QVeSC'~`Dect'y ,~ \"C~Cr f ~IC~T~1~t[~ 1~f'~So_n~_
cvl9 ~f.~oo ~y0-o
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10088.
This Notice of Appeal, when received by the District Justice, will operate as a
SUPERSEDERS ro the,judgment fw possession in this case
Signature of othonotary or Deputy
'Y' -vim t u.<ti IF-~ tn.-7
li apps lant was CLAIMANT (see Pa. R.C.P.JP. 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 section o/ form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.JP. No. 1001(7) in action before Disbict Justice.
IF NOT USED, detach from copy of notice of appeal [o be served upon appellee).
PRAECIPE: To Pmthawtary
Enter rule upon `JUf' y +"" "` lJ e5@ nbQ CC' y , appellee(s), to file a complaint in this appeal
~/" " ""Name o/ appelleets)
(Common Pleas Na o ~' So`2S~/~) within twenty (20) days after service of \ule or suffer entry of judgment of non pros
RULE: To LT~~ y L. V( ~1 ~Se n 0e C c ~ , appellee(s).
Name of appellpe(s)
of appellant or hS attorney w agem
(1) You ore notified that a rule is hereby entered upon you ro file a comploiM in this appeal within twenty (20) days after the date of
service of this rule upon you by personal service a by certified or registered mail
(2) N you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU.
(3) TThe daM of service of this rule if service was by mail is the date of mailing
Date: ~(~,'l~. /n• ,T~°~~ .'"~ ~ FtonrondaryorDewN
roacs,a-a. COURT PILE TO BE FILED WITH PROTHONOTARY
_ _
~w .:. ,.. ~ ~. -.~ .~,~.~-: ~ ~ xau _ pkM
~~CB~F i~~ ~5t€ t~F ~~~~ f ~RP~A~ ANA ~dlL~ 'T~ ~1LE ~~~i1PLA9NT
(Tixis °~eoof of sertr7~e AP~US f` v~ ~rt.F'Li iN7Tt~ti?V TEPf (tOj DRYS RFTEA fittng the notlea of apAeat. Check appticabte boxes]
t~sarw~crf~wr~,~ ray ray €>~ntr~yE u~eatea
~~F6C?~'E`~"a ih~ar~Lvsweart;r~iffrl~°,'P~a;!ser4~c#
€~.~ a oaPY c>f 9:h~~ ~?oFic+a w? kp?aoat, f,'or~:~rr~lrn ;'leas lVo...~__._._._....___.~. , neon fhe 6lstrfct Justice designated Lhereln on
(a'ai~e o€u~rcv.`oey ..~__...v.._._.___._._....._.~.._.~ L7 by personal sere€oe (~ by (certified} {regis#ered} mai;, sender`s
;eceip# sttE=ched heratrt. an=~ :pon The ~ppellee, Enema) _ -_, on
_~_.___m_~~. , t3_~_.._. C~ by {aersanal service C-J by (certified} {registered} mail, sender's receipt attached hereto.
C1 andfurther 4hatiseruec3 the Mute to Fila t~Complah74 aocom parrylrtg the above Notice of Rppeal upon the appellee{s}to whom
the F?iele vvas addressed rn ~_._.___.,_._. ~...~ , fig-----, ~ by personal servioe ~ by {certified} (registered)
mail, sarder's reoeip# a:tachecf raereto_
~vvvrtrv {~,I; ;r~r~~ca> rtrv ~ sr.ra>~;f~r;l~zru ~t~~~A~ ~I~
~ryrlature of olitcla} ba€are :~hcro aiAdavfi was mane
Tl215 OI OffG1131
Phy commission ~+Kplres on ~~.~..__._.___.~.__..._._ . i~
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f,- , `,"COMMONWEALTH OF PENNSYLVANIA
..VUIV ~ T Vr: ~-vr,,.,ua~a+eaa~u
09-3-03
DJ Name: Hon.
SUSAN R. DAY
address: 229 MILL STREET, BOX 167
MT. HOLLY SPRINGS, PA
Te~epnone:(717) 486-7672 17065
PSTSR PSTSINIS, DEF. 1
5872 MOLLY PITCHER HWY.
SHIPPSNSBURG, PA 17257
THlS IS TO NOTIFY YOU THAT:
Judgment:
^X Judgment was entered for:
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: CIVIL CASE
NAME antl ADDRESS _
~QUESSNBSRRY, GARY L
502 N. BALTIMORE AVE.
MT. HOLLY 3PRINGS, PA 17065
L
VS
J
DEFENDANT: NAME andnooaESs
rPSTSINIS, PSTSR & VASILRI, ST AL. ~
5872 MOLLY PITCHER HWY.
SHIPPSNSBURG, PA 17257
L J
DocketNo.: CV-0000190-01
Date Filed: 6/21/01
(Name) QIIESF.NiiRRRY~ (~ARy T.
Judgment was entered against: (Name) pRTRTNT4 PRTRR & VASTL.KT
in the amount of $ 2 tn6a _ ~ n on:
Defendants are jointly and severally liable.
Damages will be assessed on:
This case dismissed without prejudice.
^ Amount of Judgment Subject to
AttachmenUAct 5 of 1996 $_
Levy is stayed for days or ^ generally stayed.
Objection to levy has been tiled and hearing will beheld:
Date: Place:
Time:
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 GOURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS t~071S,E OF JUDGMENT/T,PIANSC~QT FORM WITH YOUR NOTICE OF APPEAL.
$ 9 -CJ) Date
I certify that this is a true end Correct copy of the
My commission expires first Monday of January,
Date
District Justice
of the proceedings containing the judgment.
2004
(Date of Judgment) R/~9/m
(Date & Time)
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
Total
Posi Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
District Justice
SEAL
AOPC 315-99
WILLIAM P. DOUGLAS, ESQUIRE
ATTY. I.D. # 37926 a
DOUGLAS, DOUGLAS & DOUGLAS
27 W. HIGH ST.
POB 261
CARLISLE PA 17013
TELEPHONE 717-243-1790
ATTORNEY FOR PLAINTIFF
GARY L. QUESENBERRY, INC. IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
V.
CIVIL ACTION -LAW
PETER & VASILIKI PETSINIS NO.Ol-5254 CIVIL TERM
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST
THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE
ACTION WITHIN TWENTY DAYS AFTER THIS COMPLAINT AND NOTICE
ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR
BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR
DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU.
YOU ARE WARNED THAT IF YOU FAIL TO DO SO, THE CASE MAY
PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST
YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY
CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF
REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY
OR OTHER RIGHTS IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
Cumberland County Lawyer Referral Service
2 Liberty Avenue
Carlisle, PA 17013
Telephone 717-249-3166
Dated: ~ - a~ - ~ ~
DOUGLAS, DOUGLAS & DOUGLAS
B -
Attorney for Plaintiff
t.
COMPLAINT
1. The Plaintiff, Gary L. Quesenberry, Tnc., is a Pennsylvania
corporation with a place of business at 502 North Baltimore
Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania.
2. The Defendants, Peter and Vasiliki Petsinis, are adult individuals
residing at 5872 Molly Pitcher Highway, Shippensburg,
Pennsylvania, 17257.
3. On or about July 13,1998, the Defendants signed a promissory note
in favor of the Plaintiff, Gary L. Quesenberry, Inc., in the amount of
$2,000.00. A copy of the note is attached hereto and made a part
hereof.
4. To date the Plaintiff has made demand upon the Defendants to pay
said note, and the Defendants have failed and refused to do so.
The Plaintiff hereby makes demand of the payment of $2,000.00 on
said promissory note.
WHEREFORE, it is prayed that judgment be entered in favor of the
Plaintiff, Gary L. Quesenberry, Inc., and against the Defendants in an
amount requiring compulsory referral to arbitration together with
interest, fees, and costs of suit.
DOUGLAS, DOUGLAS & DOUGLAS
By ~ \
William P. Douglas, Esquire
Attorney for Plaintiff
27 West High Street
Carlisle, PA 17013
717-243-1790
• F a-, ~
AFFIDAVIT
I hereby swear or affirm that the foregoing is true and correct to the best of my
knowledge and/or information and belief.
This is made subject to the penalties of 18 Pa.C.S.§ 4904 relating to unsworn
falsification to authorities.
Gary . Q ese berry
Pres' ent
:..
.. ..
PROMISSORY NOTE
$2,000.00
Date: July 13, 1998
For value received, the undersigned Peter Petsinis and Vasilild Petsinis (collectively the "Promisor") each as
principal, jointly and severally, promise to pay to the order of Gary L.t2uesenberry, Inc (the "Payee"), at 502 N.
Baltimore Ave., Mt. Holly Springs, PA 17065, (or at such other place as the Payee may designate in writing) the
sum of $2,000.00 with no interest.
Unpaid principal after the Due Date shown below shall accrue interest at a mte of 12.00 percent annually until
paid.
The unpaid principal shall be payable on demand. All payments on this Note shall be applied first in payment of
accrued interest and any remainder in payment of principal.
The Promisor promises to pay a late chazge of $10.00 for each installment [hat remains unpaid more than 5
day(s) after its due date. This late charge shall be paid as liquidated damages in lieu of actual damages, and not
as a penalty.
The Promisor reserves the right to prepay this Note (in whole or in part) prior to the Due Date with no
prepayment penalty.
If any payment obligation under this Note is not paid when due, the Promisor promises to pay all costs of
collection, including reasonable attorney fees, whether or not a lawsuit is commenced as part of the collection
Process.
If any of the following events of default occur, this Note and any other obligations of the Promisor to the Payee,
shall become due immediately, without demand or notice:
1) the failure of the Promisor to pay the principal and any accrued interest in full on or before the Due Date;
2) the death of the Promisors) or Payee(s);
3) the filing of banlwptcy proceedings involving the Promisor as a Debtor;
4) the application for appointment of a receiver for the Promisor;
5) the malting of a general assignment for the benefit of the Promisor's creditors;
6) the insolvency of the Promisor; or
7) the misrepresentation by the Promisor to the Payee for the purpose of obtaining or extending credit.
~ e .. ~ • , d
if any of the above defaults apply to one Promisor, all Promisors shall be deemed in default of this Note
regardless of whether all Promisors are directly involved in the default.
If any one or more of the provisions of this Note are determined to be unenforceable, in whole or in part, for
any reason, the remaining provisions shall remain fully operative.
All payments of principal and interest on this Note shall be paid in the legal currency of the United States.
Promisor waives presentment for payment, protest, and notice of protest and nonpayment of this Note.
No renewal or extension of this Note, delay in enforcing any right of [he Payee under this Note, or assignment by
Payee of this Note shall affect the liability of the Promisor. All rights of the Payee under this Note are
cumulative and may be exercised concurrently or consecutively at the Payee's option.
This Note shall be construed in accordance with the laws of the State of PA.
Signed this ~_ day of _f~ ~ ~ 19 ~~r~ at
Peter Petsinis
sy:
Peter
Vasilild Petsinis
By: 7-A 5 ! ~ I Kl ~ ~ i S /~!//S
Vasilild Petsinis
ASSIGNMENT
For value received, the above Note is assigned and transferred to
(City)
(State/province)
(Country)
("Assignee") of
-2-
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14. .
OF RENNSTLVANIA
:OURT GF COMMON
JUDICIAL DISTRICT "
ITICE OF APt`EAL
FROM
DISTRICT JUSTICE JUDGMENT
I COMMON PLEAS Na ~ a~., _ ~r~~.,~, , ~;~~,X~r
r NOTICE" OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleds an appeal from the judgment rerdered by the District Justice on the
dat°e~and in:tlie case mentioned below: \
fQr~@P ~ \ICiS~t'~~s 1~C'..'PSt~j$ r
DAME ~A,PPELIAM - - -
'~ ~y. '~ f ~ ~~ 4 ` ` , MAa. asr. Na~ oe ruME of o~.
..,,~,..,., ....v~~.,.,., an __
STATE ZP CODE
~w°$'~ ~ ~'?i of $ ~i ~ ~c e r 4~~w SF.; e~~bV r P~ ' ,°s ~ ~ --~x
Dk~E -0IM3MENT , - ' IN THE CASE OF (Mai,RM) ~ ~
...._._ ~ ,~ \'~~2r r", CtS't' 1° 1~'~'r'n,s~,5, 'gip)
ev19 ao~~ 190-~09 s
„= .> ~:_.
this bock wilt be signed ONLY when this"notation is required under, Pa. R.C.P.JJ'. Na
10088. p ~ r . ,' .i~,a, ,
This ~~aloficg ~of gp•peal, when received by the District Justice, will,rdJperate as a
SIIPERSEDE~S.ro Elie judgment for possession in this case.
,_, Signature of Prothonotary or Deputy -
(see Pa. R.C.P.JP. No.
1001(6) in actiorj p¢re,~istrict Justice, he MUST
FILE A COMPLAINT within twenty (20) days after
filing his NQTICE of APPEAL.
:~ -
{;,P(i:AECIPE'TO:ENTER RULE TO FILE COMPLAINT AND`RULE TO FILE
(This section of /orm to,'be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.JP. No. 4001(7) in action before District Justiee.
IF=NqT USED; detixct lT~fiim copy of notice of appeal [0 6e served upon appellee).
PRAECIPEs ,~""~R~ho/wrory
~.
""`~ Eller ri))e upon ~ ~'"• "~-- ~~ - - ~ appellee(s), ro file a complaint in this appeal
Name o/ appellee(sJ - -
(Common Plecs No. ~ f r -~"~~ ~~ ~~ )within twenty (20) days after service o le or suffer entry of judgment of non proz
~,. i p~. }~ ~ Si of appeNant a his attorney w agent
.RULE. To ,v_ '~~`,~y "~,- t„K V~"`~e/'1 ~?~st'c ~ .appall (5)•
-NameM?/ agxtleets)~ `
*p
... ~~~
' O ~ ;ate it rule is here entered u n ou ro file a com aIM' ih this a
1 "f~u n~, bY; po y pl ' ppeal within twenty (20) days after the date ,of
s~vj~e of thlule`tu 1'~d~~,,,,, 'p'ersonal service or by certified or registered moil.
¢~~ M you.<da nOR file`a.com{}laint within this time, a JUDGMENT OF NON PROS' WILL t3E; ENTERED AGAINST YOU.
` (3) Tfl~sdipfe of service of this rule if service was by mail is the date of mailing'
#xr ,~ mil .6Y~iQ- ~~~. Jk~i.~s~Hr
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AOPC312'80 COURT FILE
db~E4+~€"sga '4:ca' a u w......e _._. .. a may. .. va <,~_._ f ~,e: ., x1:,~ .ivau.aa~bPa~kswamwsz. nmaw_sm. w;met6~zxs~re'~~4~anntrtlLeesiXr~ttx.Are3eurRw»dwvsewevia.-~.*,~.n.
~~C3~3F ~F S~R~~~~ ~F ~~T6E {~F APPEAL At+l~ EiCIL~ T~ F4LE ~!~8VI~1~l#~PlT
{This proof of service MUST 7~E FILED Wt7NtrV TEN (70) DAYS AFTER firing Phe noriea of appeah Cftsck applicable boxes}
047~+9ANCSNwERL'rM Of rrEPIN~Vt.VANiA
~4U45dTY 4}P LV 1'72C~`i+~ _.___~_,___._~..~ ; ss
AFFB~AlPBT; I he=reby swear or affirm t?gat I ser~rad _
~ a r=opy of the ~4otEee or Ap~:~eai, Gomm+~n Pleas IVo. ~ i ~ 5'~3 ~ ~' ;upon the Caistrrct Justice designated therein on
(dare of setvdco} ~~'}~.~._ ~ o i ~ C] by personal service ~ by (certified} (registered} mall, sender's
receipt aitaeied hereto, ark aeon the appellee, (name) ~~~~+ e5e.. ~ECC7 , on
s~y~~~ , 19.~.__...._ C.~ lay personal service ~ 6y (certified} {registered) mail, sender's receipt attached hereto.
imp and further tnat9served the N=.ale to FiieaComplaint accompanying the above Notice of Appeal upon the appeltee(s}to whom
the Ru€e was addressed an _.n__w _...___._- , 19®..._., [] by personal service Q by {certified} {registered)
!nail, sender's reoelpt attached t~ereso. ~~ ~J _ `~
5Yv (~ (,~l('FjN€tiAECt} A~Ct SUBSCRIEiECt i3tFORE h9E~Ly`'- T
TH3S ~~l/ ~...__._ 2>AY OF ~ ,~~
.wign3tur9 of of+iCiaf bQforfr Y+hOm efirtl2vA waS !~3fi6 ~~~~~~
?~~,~,-l h~~~/...Y~--
Signature of aftiant
titre of oNicf-.~7 ~~~
~
NOTA
My comm}saian expiros on _ ~~~,~ N
®ry ~
ublic
Carlisle, Cumberland County Ca
~
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My Commission Expires Nov
28
2000 ~ "n
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WILLIAM P. DOUGLAS, ESQUIRE
ATTORNEY I.D. 37926
DOUGLAS, DOUGLAS, & DOUGLAS
27 W. HIGH ST.
P,O.BOX 261
CARLISLE, PA. 17013
TELEPHONE 717-243-1790
ATTORNEY FOR PLAINTIFF
GARY L. QUESENBERRY, INC.
VS.
PETER & VASILIIQ PETSINIS
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNA.
CIVIL ACTION LAW
NO.Ol-5254 CIVIL TERM
Praecipe to Enter Default Tud~ment
This is to certify that on October 1, 2001 a copy of the complaint in the
above captioned matter was served upon the defendants by first class postage
pxepaid U.S. Mail. This is to further certify that on January 31, 2002, the attached
Notice of Default was sent to Peter and Vasiliki Petsinis at their address at 5872
Molly Pitcher Highway, Shippensburg, PA 17257, in accordance with Pa. R.C.P.
237.1.
Please enter a default judgment against Peter and Vasiliki Petsinis in the
amount of $2,000.00 for their failure to enter an appearance or file a written
answer to the complaint.
William P. Douglas, Esqui
February 19, 2002
WILLIAM P. DOUGLAS, ESQUIRE
ATTY. I.D. # 37926
DOUGLAS, DOUGLAS & DOUGLAS
27 W. HIGH ST.
POB 261
CARLISLE PA 17013
TELEPHONE 717-243-1790
ATTORNEY FOR PLAINTIFF
i~~~z
._ ~ ,
GARY L. QUESENBERRY, INC.
V.
PETER & VASILIIQ PETSINIS
To:
Peter and Vasiliki Petsinis
5872 Molly Pitcher HighwaX
Shippensburg~ PA-17257
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
CIVIL ACTION -LAW
NO.Ol-5254 CIVIL TERM
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A
WRITTEN APPEARANCE'PERSOIVALLY 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 DAYS
FROM THE DATE OF:'THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITIiOUT A HEAI21NG 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 FIlVD OUT WHERE YOU CAN GET HELP.
Legal Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
DOUGL S, DOU & D GLAS
By
Attorney for Plaintiff
27 West High Street
P.O. Box 261
Carlisle, PA 17013
717-243-1790
Date: January 31, 2002
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