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HomeMy WebLinkAbout03-2752TRAVELERS INSURANCE CO., Successor: In-Interest to RELIANCE INSURANCE : One Tower Square : Hartford, CT 06183 : and : EAST CAROLINA BANK, 1422 Carolina Avenue Washington, NC 27889 Plaintiffs JEFFREY WALTMAN, 30 Dogwood Lane Blackwood, NJ 08012 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR WRIT OF REVIVAL. To: Prothonotary Issue writ of revival of judgment entered to No. 98-1828 and index it in the judgment index against Jeffrey Waltman in the amount of $58,797.31, with interest · S~ from April 2, 1998, together with attorney fees and court costs. McNEES WALLACE & NURICK LLC Date: June 11, 2003 Kimberly M. Colonna I.D. No. 80362 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108 (717)232-8000 Attorneys for Plaintiffs IN THE COURT OF COMMON PLEAS TRAVELERS INSURANCE CO., Successor: CUMBERLAND COUNTY, PENNSYLVANIA In-Interest to RELIANCE INSURANCE : COMPANY, and EAST CAROLINA BANK, Plaintiffs JEFFREY WALTMAN, 30 ~D ~ BLACK%gOOD, NJ 08012 Defendant NO. 03-2752 CIVIL TEI~I WRIT OF REVIVAL To: JEFFREY WALTMAN, Defendant You are notified that the Plaintiffs have commenced a proceeding to revive and continue the lien of the judgment entered to No. 98-1828. The Plaintiffs claim that the amount due and unpaid is $58,797.31, with interest from April 2, 1998, together with attorneys' fees and costs. You are required within twenty (20) days after service of this Writ to file an answer or otherwise plead to this Writ. If you fail to do so judgment of revival will be entered. COSTS: $189.65 Pd Arty $1.00 Co. Date: JUNE 12, 2003 KIMBERLY M. COIDBRqA, ESQUIRE 100 PINE STR~'£ p.O.BOX 1166 HARRISBURG, PA 17108 717-232-8000 I.D.# 80362 CURTIS R. LONG Prothonotary TRAVELERS INSURANCE CO., Successor: IN THE COURT OF COMMON PLEAS In-Interest to RELIANCE INSURANCE COMPANY, and EAST CAROLINA BANK, Plaintiffs JEFFREY WALTMAN, Defendant CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2752 Civil AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: : SS: COUNTY OF DAUPHIN : Charmaine Y. O'Hara, being duly sworn according to law, deposes and says: She is a competent adult employed as a Paralegal with the law finn of McNees Wallace & Nurick LLC, attorneys for Plaintiffs in the above-captioned action. Pursuant to Pa.R.Civ. P. No. 3028 and 402(a), she served a Writ of Revival upon the Defendant, at 30 Dogwood Lane, Blackwood, NJ 08012, by certified mail, return receipt requested. Said remm receipt is attached hereto and shows a date of delivery of June 18, 2003. Sworn to and subscribed before me thiso/O day of June, 2003 ,~ BR..EN?,. J. LANDIS~ Notary Public ! Har~$1?~g., PA_ Dau~hln C~unty · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the f~ont if space permits, 1. Article Addressed 3. Se eType  fled Mail I-] Express Mail stered I-I Return Receipt for Merchandise [] Insured Mail I;3 C.O.D. 4. Restricted Deliver? (Extra Fee) [] Yes 2. Article Nurnbe~ PS F~ 381 1, ~ust 2~1 ~tic Rmurn ~ 102595~)2-M-1035 TRAVELERS INSURANCE CO., Successor: IN THE COURT OF COMMON PLEAS h-Interest to RELIANCE INSURANCE COMPANY, and EAST CAROLINA BANK, Plaintiffs JEFFREY WALTMAN, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-2752 Civil PRAECIPE TO ENTER JUDGMENT OF REVIVAL To: Prothonotary Enter judgment of revival, upon default, against the Defendant in the amount of $58,797.31, together with interest from April 2, 1998 and with attorneys' fees and costs. McNEES WALLACE & NURICK LLC By I.D. No. 80362 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108 (717)232-8000 Date: July 0 [ , 2003 Attorneys for Plaintiffs TRAVELERS INSURANCE CO., Successor: IN THE COURT OF COMMON PLEAS In-Interest to RELIANCE INSURANCE COMPANY, and EAST CAROLINA BANK, Plaimiffs JEFFREY WALTMAN, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-2752 Civil CERTIFICATION OF MAILING OF NOTICE OF INTENT I certify that on July 8, 2003, a Notice of Intent was mailed to the Defendant. Attached hereto and marked Exhibit A is a true and correct copy of the Notice of Intent mailed to the Defendant. Attached hereto and marked Exhibit B is a Certificate of Mailing evidencing the transmittal of the Notice to the Defendant. i Colonna I.D. No. 80362 McNees Wallace & Nurick LLC 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108 (717)232-8000 TRAVELERS INSURANCE CO., Successor: 1N THE COURT OF COMMON PLEAS In-Interest to RELIANCE INSURANCE : CUMBERLAND COUNTY, PENNSYLVANIA COMPANY, and EAST CAROLINA BANK, Plaimiffs : NO. 03-2752 Civil JEFFREY WALTMAN, Defendant IMPORTANT NOTICE To: Date of Notice: Jeffrey Waltman, Defendant July 8, 2003 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. McNEES WALLACE & NURICK LLC KimbSrly M. Colonna 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108 (717)232-8000 Attorneys for Plaintiffs Exhibit A U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE--POSTMASTER Received From; O n e Pi4~ee° ffc rfc~ ~yym e ~;d~ ~ c~:n Blackwood, NJ 08012 PS Form 3817, Mar, 1989 GPO : 1993 Exhibit B TRAVELERS INSURANCE CO., Successor: IN THE COURT OF COMMON PLEAS In-Interest to RELIANCE INSURANCE : CUMBERLAND COUNTY, PENNSYLVANIA COMPANY, and EAST CAROLINA BANK, Plaintiffs JEFFREY WALTMAN, Defendant : NO. 03-2752 Civil NOTICE OF ENTRY OF JUDGMENT To: JEFFREY WALTMAN, Defendant You are hereby notified that on July ,2003, judgment of revival was entered against you in the amount of $58,797.31, together with interest from April 2, 1998 and with attorneys' fees and costs. Date: July .2S/., 2003 I hereby certify that the name and address of the proper person to receive this Notice is: Jeffrey Waltman 30 Dogwood Lane, Blackwood, NJ 08012 y M. Colonna McNEES WALLACE & NURICK LLC