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