Loading...
HomeMy WebLinkAbout07-1882IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DENNIS FRANCIS BISHOP 341 Walton Street Lemoyne, PA 17043 Plaintiff V. JACK E. LOVE 434 Linton Hill Road Duncannon, PA 17020 Defendant § CIVIL ACTION - LAW DOCKET NO.: 0'7 - I (i Kd- c? ul I f ( rl" PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Writ of Summons in the above captioned action. A Writ of Summons shall be issued and forwarded to the Attorney for Plaintiff, Brian K. Zellner, 2933 North Front Street, Harrisburg, PA 17110. Date: S-- D-) dn 16 Brian K. Zellner, Esquire Supreme Court I.D. #59262 Capozzi & Associates, P.C. 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 Attorneys for Plaintiff c? o C? Q -n -c, I (e Fz O Q IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DENNIS FRANCIS BISHOP 341 Walton Street Lemoyne, PA 17043 Plaintiff v. JACK E. LOVE 434 Linton Hill Road Duncannon, PA 17020 Defendant CIVIL ACTION - LAW DOCKET NO.: 0 ? - I Sf )- G: r' I -f-c"L WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: YOU ARE HEREBY NOTIFIED THAT THE ABOVE - NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Date: P?!4 5, I W7 s- I Prothonotary D/ Deputy DENNIS FRANCIS BISHOP, COURT OF COMMON PLE?S CUMBERLAND COUNTY, A Plaintiff, V. No. 07-1882 CIVIL ACTION - LAW JACK E. LOVE, Defendant. NOTICE You have been sued in court. If you wish to defend against the claims set forth in pages, you must take action within twenty (20) days after the complaint and notice entering a written appearance personally or by attorney and filing in writing with th defenses or objections to the claims set forth against you. You are warned that if yc so the case may proceed without you and a judgment may be entered against you b, without further notice for any money claimed in the complaint or for any other claii requested by the Plaintiffs. You may lose money or property or other rights import e following re served, by courtyour z fail to do the court i or relief nt to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU ONOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMAON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE A LE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFF R LEGAL SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE. CUMBERLAND COUNTY COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200 Le had demandado a usted en la corte. Si usted quiere defenderse de estas demanda expuestas en las paginas siguientes, usted tiene viente dias de plazo al particular de la i a de a demanda la notificication. Hace falta ascentar una comparencia escrita o en persona o con ab gado y entregar a la corte en forma escrita sus defenses o sus objeciones a las demandas en ontra de su persona. Se adviso que si usted no tiene defiende, la corte tomara medidas y puede ontinuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la coorte puede d idir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta dema da. Usted puede perder dinero o sus propiedades y otros direchos importantes para usted. LLEVE ESTA DEMANDA A SU ABOGADO IMMEDIATAMENTE, SI NO ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL S VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE ASISTENCIA LEGAL. CUMBERLAND COUNTY COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200 Date: $ S1 By: & {c -21? Brian K. Zellner, Esquire Attorney I.D. # 59262 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 Attorney for Plaintiff O, "-ION SE 2 DENNIS FRANCIS BISHOP, Plaintiff, V. JACK E. LOVE, Defendant. COMPLAINT 1 2. 3 4. 5. COURT OF COMMON LEAS CUMBERLAND COUN Y, PA No. 07-1882 CIVIL ACTION - LAW The Plaintiff, Dennis Francis Bishop, is an adult individual with an add ss of 341 Walton Street, Lemoyne, PA 17043. The Defendant, Jack E. Love is an adult individual with an address of 3 3 Walton Street, Lemoyne, PA 17043. The Plaintiff, Dennis Francis Bishop, is the owner of the property locate at 341 Walton Street, Lemoyne, PA 17043. On September 27, 2006, the Plaintiff entered into a written contract with the Defendant for the removal and replacement of the roofs on the Plaintiff two story and single story garages. See attached hereto as Exhibit "A" the tten contract dated September 27, 2006. The Plaintiff paid the Defendant Eleven Thousand ($11,000.00) Dollars 6. The Defendant began work on September 28, 2006. 7. The Defendant did not complete the work despite repeated requests by tt Plaintiff. 8. The Plaintiff suffered severe water damage to the inside of the two story arage as a result of the Defendant's failure to complete the work. See attached he to as Exhibit "B" the water damage assessment performed by Capitol Area Ho e Inspections, Inc. 9. On March 30, 2007, the Plaintiff hired another roofing contractor to c plete the work. See attached hereto as Exhibit "C" a copy of the contract entere into by the Plaintiff to complete the work. 10. The Plaintiff was required to pay Eleven Thousand Eight Hundred ($1 ,800) Dollars to have the work completed by another roofing contractor. 11. The Plaintiff will have to pay Twelve Thousand Three Hundred Nine - Three ($12,293) Dollars to have the water damage repaired. See attached as xhibit "D" the damage estimate from Crawford & Company. DENNIS FRANCIS BISHOP V. JACK E. LOVE BREACH OF CONTRACT 12. The Plaintiff incorporates by reference hereto paragraphs 1 through 11 s if more fully set forth herein. 13. The Plaintiff and the Defendant had a written contract for the removal d replacement of the roofs on the Plaintiff's two story garage and one sto garage. 14. The Defendant agreed to perform the work for Twelve Thousand ($12,00.00) Dollars. 15. The Plaintiff paid Eleven Thousand ($11,000.00) Dollars to the 16. The Defendant breached his contract with the Plaintiff by not completing the work. 17. As a result of the Defendant's breach of contract, the Plaintiff suffered damages as aforementioned. WHEREFORE, the Plaintiff demands judgment and damages in his against the Defendant in an amount greater than $35,000. DENNIS FRANCIS BISHOP V. JACK E. LOVE NEGLIGENCE and 18. The Plaintiff incorporates by reference hereto paragraphs 1 through 17 asl?f more fully set forth herein. 19. The Defendant had a duty to perform the work in a good and manner. 20. The Defendant breached this duty by failing to complete the work and by to use the proper materials to install the roof on the two-story garage. 21. The Defendant was negligent. 22. As a result of the Defendant's negligence, the Plaintiff suffered aforementioned. WHEREFORE, the Plaintiff demands judgment and damages in his fa against the Defendant in an amount greater than $35,000. Date: ?-l j fl' n as and Brian K. Zellner, sq Attorney for the Pl ini Attorney Id No. 5 6, Capozzi & Associ es 2933 North Front e Harrisburg, PA 17 10 (717)233-4101 VERIFICATION do hereby verify that the facts provided in fore oing Complaint are true and correct to the best of my knowledge, informatio?i.ead lief. I understand that any false statements therein are subject to the penalties contai d in Title 18 of the Pennsylvania Consolidated Statutes Section 4904 relating to unswo falsification to authorities. Date: S I ,, 07 `x4l 1 14 ?? e;+ a ?q?4'ro -MQ MEMBER Home Inspections Keith Rutherford March 28, 2007 Mr. Frank Bishop 341 Walton Street Lemoyne, PA RE: Water damage assessment and recommendations Mr. Bishop, Inc. Capitol Home Inspections, Inc. was hired by you to perform a water damage assessment inspection and report for the garage at the above noted address. That inspection was performed on March 24, 2007. The pictures of some of the findings were emailed to you and to Mr. Brain Zellner of Capozzi Associates. Those pictures were sent with a list of the areas and the findings pertaining to those particular areas. This is a report on the general findings and possible concerns and recommendations of the visual inspection of the garage. At the time of the inspection, it should be noted that there had been a period of recent rain. 'There were areas that showed that the roof of the garage had active leaking. The exterior roofing of the garage was only partially completed. There were noted areas that did not have any covering what so ever on the roof. Tar paper was all that was there. The peak caps were also noted to be only partially finished. The condition at the time of the inspection indicates that there is damage to the existing interior of the garage, areas that had been finished with drywall. There is extensive staining noted throughout the interior of the 2nd floor. The moisture meter used indicated that most of the staining noted was active. The base percentage taken with the meter was around 10%, taken on an apparent dry section of finished drywall. Many of the stains were reading in excess of 35%, which indicates active moisture intrusion. There were no noted stains at your original inspection in these areas per the report. All the stained areas should be considered damaged areas. The north side of the garage has noted falling drywall and insulation. These areas were wet at the inspection. There was noted very dark staining in these areas, leading to the conclusion that there had been a continuous intrusion of moisture. The issue arises that these dark stained areas could indicate a possible mold or mold related condition. These areas are suggested to be further evaluated by an expert who is familiar with `these types of circumstances. The pictures provided indicate active leaking onto the wood floor. The issue here is that there could be damage to the existing wooden flooring, since the leakage -3ppears to be an ongoing condition. There were signs of past staining in these areas, along with the active stains noted. The attic (or 3rd floor) had noted stains in areas where the ceiling iad been partially finished. There were noted areas of falling drywall and insulation. This :ondition also appears to be an ongoing situation. If this condition has occurred since the eported start of the roofing project, there is the possibility that mold or mold related issues nay be present here as well. All the perimeter walls of the 2nd floor were extensively note to :ontain past and active stains at the inspection. If these walls are insulated, the issue arises to Page 2 the possibility of damage to the areas concealed by the drywall. This could be insulation, or possibly structural components such as headers, wall framing, window and door framing, etc. It should be advised that these areas also be further evaluated to determine the conditions existing behind the finished drywall areas. Since this appears to be an issue that has had possible continuous moisture intrusion, damage could be evident that is not noticeable during a visual non-invasive inspection provided by Capitol Home Inspections, Inc. In conclusion, please be advised that it is suggested that all areas affected by the moisture intrusion, whether active or not during the inspection, should be further evaluated for the possible issues noted. This condition does not appear to be a one time activity and done. Some areas have noticeable damage occurring at the time of the inspection. I would also suggest that the work performed by the contractor hired by you be evaluated. There could be possible integrity issues pertaining to the work completed that may not be readily viewable during a visual inspection. If I can be of further assistance, or if any follow-up or added explanations are needed, please do not hesitate to contact me. Thank you for contacting Capitol Home Inspections, Inc. Sincerely, Keith Rutherford Capitol Home Inspections, Inc. MEMBER PROFESSIONAL SERVICE WITH A PERSONAL TOUCH INVOICE FOR SERVICES RENDERED DATE: March 24, 2007 PROPERTY ADDRESS: 341 Walton St. Lemoyne, PA CLIENT: Bishop, Frank INSPECTIONS PERFORMED: Water damage inspection, pictures, and report: 4.5 HRS @ $110/HR Amount Due Please Remit Payment To: Capitol Home Inspections, Inc. 5701 Cricket Lane Harrisburg, PA 17112 $465.00 $465.00 Payment is due 30 days from date of this invoice unless noted otherwise. ?4Y?,lo Home Inspections '' ??? ??, # of a es fl /111?/", 1? 7 ' j I 7, 7 proposal Submitted To: - Job Name Job # ?ddress ?" Job Location G C.7 C,YJ ? / ( Date Date of Pfarr?- 'hone # Fax # grspgeet ',: ca c ccG S Q. ?- VtA 4C I 0 om L Y fe propose hereby to furnish material and tabor complete in accordance with the above specifications for the sutra of: f Off !r c.>=C -1 t t1 Doll s th payment to be made as follows: t --94A=k2 6d-° c Anp- y aft" or deviation from ificatkms involving extra costs be Respectfully Kuted only upon written order, and will become an extra charge over and we the estimate. All agreements contingent upon strikes, accidents, or delays submitted fond our control. Note - this proposal may be withdrawn by us if not accepted within days. .mot !aiCCeptmut of jropooai- 4?p r above prices, specifications and conditions are satisfactory and are Signature ,by accepted. You are authorized to do the work as specified. ments will be made as ou med above. 7 ,P _ F e of Acceptance Signature 4-j?' All ,3819 MADE IN USA ~ 4 1 We hereby submit specifications and estimates for. C)C1 l Crawford and Company po box 1540 Mectamicsburg Pa 17055 717 469 0469 steve, jsaheUaQuscmwco.com Insured: BISHOP DIRMS Horne: (717) 264-5065 Property: 341 WALTON ST LEMOYNE, PA 171043-2027 Home., 341 WALT'ON ST LEMOYNE, PA 17043-7027 Claim Rep.: Steve Isabella Business:. po box 1548 catn*ll, PA 1,7055 FstkWor. Steve Isabella Business: po;box 1-548 csmphill, PA 17055 Cellular: (717) 343-3312 Business: U - Husinesa: (717) 469-0"9 Busin.ew (717) 469-1469 Gal m Number Policy Number Type of Loss Deanctlbk 3401481. Other $0.00 Dates; Date Contacted: 0410412007 Date of Loss: 10120120M Date Inspected, 04111/2007 Price:List;. PAHA4H713: Restoration/SeivicelRtrooW Estimate; DISHOi', bENNUS Client Code' 7$05 Date Reoeive& 04/04/2007 Date Etatwxk 0410412007 Branch-File: 65 85-1026419 Client Name: USAA NOTICE :. This is. a repair eatimatc only. The insurance policy may contain provisions that will reduce any past that aught be made-This. is not authorlxat on to. repair. AtltIzoriaation: to repair or guarantee ofpaynkm atttlst come. from the owner of the property. No adjuster or appraiser has the authority to authorize repair or guarantee payment. The insurer amwnes no responsibility for the quality of repairs that troaybe made. T6 39Vd 3SVSI SLV069VLIL 5E:9T L00Z/TT/00 Crawford and Company po box 154'8 Ntechaaicsburg Pa 17055 717 469 0469 steve_isabella@uscrawco.com lul DE I"ION Roam: werlmhop O"E S Main Level 1104.00 SF Walls 2054.00 SCE Walls & Ceiling 105.56 SY Flooring 138.00 LF Coil. Perimeter QUANTITY UNrr COST Ceiling >Elidght: 8' 950.00 SF Ceiling 950.00 SF Floor 139.00 LF Floor Perimeter RCV DEPREC. AC's' R&R Oak flooring - 42 common - no 270.00 SF 8.72 2,354.40 0.00 2,354.40 finish S=& stub sW,1wood. fR*or 950.00 SF 2.92 2,774.00 1,387;00 1,387.00 l1> & Rem Cxarage sob. - lower 3.00 PA 53.61 160.83 0.00 16043 unit, • R&R Batt iumdation - 6" - R19 600.00 SF 1.05 630.00 126.00 504.00 R&R Shmdtiuig.- wafarboard - 1/7 600.00 SF 1135 810.00 405.00 405.00 Room Totata: wwbkop 6,729.23 11918.00 4,811.23 M -rr -? Room: barb Ceftag Hdgliit: 8' s• I 206.67 SP Walls 41.67 SF Ceiling m 248.33 SF Walls & Ceiling 41.67 SF Floor I I IT s•42' . 4.63 SY Flooring 25.83 LF Floor Perimeter 25.83 LF Ccil. Perimeter DESCRIPTION QUANTITY U IT COST RCV Dl8p"C. ACV Detach & Rnsa Toilet LOG EA 142,24 142.24 0:00 142.24 Detach & Reset Sink - single 1.00 EA 87.54 87.54 0.00 87.54 Deuoh & Rcact Utiaal - wall hung 1.00'FA 206.02 206.02 0.00 206.02 Detaclt & Resat Cabinetry - uppor 2.00 LF 45.85 91.70 0.00 91.70, (wall) units R&R Sheathing - wafmtoard -1 /2" 248.33 SF 1.35 335.25 167.63 167.62 Sand and seal wood flour 41.67 SF 2.92 121.68 60.84 60.84 Roam. Taub: hack 98x.43 238;47 755.96 BISHOP-J)ENMS 04/1112007 Page: 2 ze 39vd 3aVSI 6LOO69VLIL 9E :9Z IeOZ/1100 Crawford and Company po box 1548' Medumieaburg,h 17055 117 469 0469 steve_isabella@Ocraweo.com i- - - - ,r a-- -- --' Room: storage Crating Hdpbt: 8' 1 'r 292.00 $F Walls 75.00 SF Ceiling 367.00 SF Walla & Ceiling 75.00 SF Floor 833 SY Flooring 36.50 LF Floor Perimeter 36.50 LF Ceil. Padmoter DESCRUTIDN' QUANTM UNIT COST RcV DEPRIBC. ACV R&R Sheathing - waferboard - 112" 367.00 SF 1.35 495,45 247.73 247.72 Sand and seal wood floor 75.00 SF 2.92 219.00 109.50 109.50 Detach A Uset Cabinetry - lower 4.OD LF 53,61 214.44 O.OD 214.44 (base) units - uffity (un&ished) Roors Totals: storage Roma: attic 1281.33 $F Walls 2522.08 SF walls &. Ceiling 137.86 SY Flooring 160.17 LF Ceil. Perimeter 92&99 357.23 571.66 DESCRIPT" QUANTITY UNIT COST Cat tg Jugh" 8' 1240.75 SF Coifing 1240.75 SF Floor 160.17 IF Floor Perimeter RCV DEPREC. ACV RdtR Batt inaulaticm - 6" -1tI9 1,240.75 SF 1.05 1,302.79 260.$6 1,042.13 MR Sheathing - waferboard -1/2" 1,281.33 SF 1.35 1,729.80 864.91 864.89. Roam ToW*- attic 3,03259 1,125.47 1,907.12, .i Roam: Dobris Rme'val DESCRII]MON QUANTITY UNIT COST RCV DEPREC. ACV 'star load - App=. 40 yards, 7- 1.00 EA 547.98 547.98 0.00 547.98 8 tma of'dalnris BISHOP_D1 NMS W11/2009 Page: 3 EO 39tid 3aVSI szVO69vt1i 9E:9I a@Z/iL/bO Crawford and Company po box 1548 Mechanicsbwg PR 17055 717 469 0469 ste"jsabeua@ucr&wco.com CONTMMD - Debris. Removal DFSCIUMON QUANMY UNIX COST RCV DEPREC. AC'V' Room Totals: Debris Removal 54798 0:00 547.95 Area Itesas Total: Mail Level 12,223.12 3A29A7 8.593.95 Line Item Totals: B15I'Il7P„DIS 12X3,12. 3,629.17 8,993.95 Grand T*W Areas: 2,884.00 SF Walls 2,307.42 SF Ceiling 5,191.42 SF Walls and Ceiling 2,307.42 SF Floor 256.38 SY Flooring 360.50 LP Floor perimeter 0:00 3F Long WaH 0.00 SF Short Wall 360.50. LF Ceit. Perimeter 2,307.42 Floor Area 2,42050 Total Area 2,884.00 interior. Wail Area 2,533.33 Exterior Wall Area 316.61 Exterior Perimeter of Walls. 0.00 Surface Area 0.00 Number of Sgaams 0.00 Total Perimeter Length 0.00 Total Ridge Length 0.00 Total Hip Length BTSHOR'-PENNIS 04/1 i/Z)07 Pago, 4 h8 39Vd 39VSI GZV069VLTL 9£:9T L80Z/TL/V0 Crawford and Company pobox 1548; Meehwiesborg Fa 17055 71 7 469 0469 swve_mbetla')auscrawco.com Summary for Qtlber Line Item Total 12,223.12 Material Sales Tax ® 6.000'% x 2,840.56 170.43 Subtotal 12,393.35 Replacement Coat Value 12,393.55 Lcss DeMeiatson (3,668.73) Actual Caab Value 8,724.82 Net Claim 8,724.82 Total` Recovcrablo Depreciation 3,668.73: 'Nct Claim if Depreciation is Recovered 12,393.55 Steve Isabella Note- Slight variances may be fout<d within report secdcros due to rounding. BISHOP?.DENNIS 0411112087 Page: 5 50 39ad 39VSI 6LV069VLTL 96:9T L002:/Tr/V0 Crawford and Company pn boa 1548 Mechanicsburg Pa 17055 717 469 0469 steve_isabella@uscrawco.com Recap by Room Esllmate; BISHOP-DENN6S Area; Male 1eve1 workshop bath storage attic Debrb Renwal Area 8vbWal; Main level Subtotal of Arena Total Now: Slight variances may be found within report sections due to re=dina. BISHOP-DBNNIS 6,7N.53 55.050/6. 994.43 8:050/0 92&" 7.6 84 3,032.59 24-81% 547:95 4.4V/i 15,223.12 190."% 12,223.12 100:00'/. 12,223.12 100."% 44/11/2007 Pagc: 6 9e 30dd 3810SI 6LV0690LIL 5c'9I L00Z/TL/t70 Crawford and Company po boa L.548 Mechanicsburg Pa 17055 717 469 0469 stevejaabellaa@wr. awco.c= Rasp by Category with Depreciation O&P Items - RCV D rec. ACV CAVONZ 'RY 4".". 46LW GENERAL DEMOLMON 2,383.51 566.42 1,817.04 FLOOR COVERMG - WOOD 5,042.46 1, 57.34. 3:485.14 rRANUNG & ROUGH CARMTRY 2,421.76 1,210." 1,210.87 INSVILATION - 1,47Zt60 294,5.2 IA78:06 PL[l'MMMG 435.Sb Subtotal 12,223:12 Material Saks Tgx a@ 6.0006% 17043 O&P Itows Subtotal 1"93.55 Graced Total 12,393.55 Note: Slight variances may be found wiftn report sections due to rounding. BISHOP_DE"US 4399.80` 3,629.17 8,593.95 AM 130.87 3,668.73 8,714.82 3.668:73 8;724:82' 04/11/2007 Page: 7 L0 :39Vd 3aVSI SLV069VLIL 5E:91 teoz/TT/vo 04/11/2007 16:35 7174690479 ow 0 b ISABB PAGE- 08 V w 1 o 06 I n ^? - ? T `T1 nl co ?` t I d ? ? ! r C D te ` `r G CD 3 CCD 4 Ok CD CD CD N Q CD O V o C/3 CD Q n m o CO, CD r CD o d . o I (o a d N H Z Q 4 Q n O Q ?Q 1 o(D 0 Sol. a t cn cD Q CD 3 0 Cv Z b- ell G S ,Qh ss. 'PM CA C.) 0 m ? C -ra G I113', a ? z z n rn c r. co W DENNIS FRANCIS BISHOP, Plaintiff, V. JACK E. LOVE, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 07-1882 CIVIL ACTION - LAW Defendant. PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter judgment against Defendant Jack E. Love and in favor of the Plaintiff in the amount of $35,093.00. The Defendant Jack E. Love has failed to plead to the Complaint. I hereby certify that a written notice of intention to file this Praecipe was mailed to the Defendant Jack E. Love on June 18, 2007. I have attached a copy of the Notice to this Praecipe. More than 10 days have elapsed since the Notice was mailed and the Defendant Jack E. Love has failed to plead. Date: ?' z ) n1 Brian K. Zellner, Esquire Attorney for the Plaintiff Attorney Id. No. 59262 Capozzi & Associates, P.C. 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 P ? ?_?' F ??y ..? v y O Q N r :`? ;`? -'['i . C?; ? ? ?. t_-- C: " ? --r? 11'2 ?-= s- _,3 r?+' ...?? S n „ y ? + '? t? ? ??... ? ..,..` + y fi ? ?? ?Tl ?; ?? . . ? ? ;? ?? f DENNIS FRANCIS BISHOP, Plaintiff V. JACK E. LOVE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW : No. 07-1882 RULE 236 NOTICE OF ENTRY OF JUDGMENT NOTICE OF DEBTOR'S RIGHTS TO: Jack E. Love, Defendant You are hereby notified that on dabi 11, 2007, judgment was entered against you in the sum of Thirty-Five Thousand, Ninet3,--Three and 00/ 100 ($35,093.00), plus post judgment interest, cost of suit and reasonableattorney's fees. DATE: 7/11/07 3 o Pr thonotary YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CANGET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 I hereby certify that the name and address of the proper person to receive this Notice under Pa. R. Civ. 236 is: Jack E. Love 343 Walton Street Lemoyne, Pa 17043 Date: BrianK. Zellner, Esquire Attorney I.D. No.: 59262 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 Attorney for Plaintiff {t3?_ 4 ? t.- cl M/ DENNIS FRANCIS BISHOP, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff, V. JACK E. LOVE, Defendant To: Jack Love 343 Walton Street Lemoyne, PA 17043 Date of Notice: June 18, 2007 No. 07-1882 CIVIL ACTION - LAW 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 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. CUMBERLAND COUNTY COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200 Date: Brian K. Zellner, Esquire Attorney for the Plaintiff Attorney Id. No. 59262 Capozzi & Associates 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 c? N C ? -rt c... ? ?? --? °?= ,__ ?;? _ _ ?. T? sr. , ?- , W _. ? ,,-? ?; ?? _ ?v y - » f "_ s ?i*+ ? ? : C:J ? R .l v DENNIS FRANCIS BISHOP, Plaintiff V. JACK E. LOVE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 07-1882 WITHDRAWAL OF APPEARANCE Please withdraw my appearance in the above-captioned matter on behalf of Plaintiff. Date: September 28, 2007 Brian K. Zellner, Esquire Attorney I.D. No.: 59262 Capozzi and Associates, P.C. 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 ENTRY OF APPEARANCE Please enter my appearance in the above-captioned matter on behalf of Plaintiff. Please direct all future correspondence regarding this mater to the undersige. .1 / // Date: September 28, 2007 n few ise ann, Esquire Attome . : 87441 Capozzi and Associates, P.C. 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 CERTIFICATE OF SERVICE I hereby certify that I caused a true and correct copy of the foregoing document to be served via First Class U.S. Mail, postage prepaid, addressed as follows: Jack E. Love 343 Walton Street Lemoyne, Pa 17043 September 28, 2007 Brian K. Zellner, Esquire Attorney I.D. No.: 59262 Capozzi and Associates, P.C. 2933 North Front Street Harrisburg, PA 17110 (717) 233-4101 ?~ 1. :mil •?.' ?-? `?? ?,y "?'? 1 M1 , .. ?'y ?.. .......i ?r ' ..y ?. .., _ 5,.? 7 4 1 • _.?? r '^?