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PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS)
P.R.C.P. 3101 to 3149
CIVIL
TRI-BORO CONSTRUCTION COURT OF COMMON PLEAS OF THE
COUNTY OF Cumberland
SUPPLIES, INC.
Plaintiff COMMONWEALTH OF PENNSYLVANIA
VS.
Judgment and Writ No. 99-5003
CUMBERLAND SERVICES, -INC.
Defendant PRAECIPE FOR WRIT OF EXECUTION
(MONEY JUDGMENT)
To the Prothonotary: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of Cumberland County, Pennsylvania
(2) against CUMBERLAND-.SERVICES, INC-._..._.....---. -------------- __........ .............. ........ --...................
(3) and against _...-..
(4) and index this writ
(a) against -------- .CUMBERLAND_SERVICES,..--INC --------- -
(b) against
__...._..._ .... - Defendant(s);
._ _...._...... Garnishee(s);
....... ...... -.....................
.. Defendant(s) and
_ ................... ............ --
........_........_ .Garnishee(s),
as a lis pendens against the real property of the defendant(s) in the name of the Gamishee(s) as follows:
(Specifically describe property) °
(5) Amount due $--7.............
Interest from September 3, 1999 ......... 501..81
Total ._8.,_398.14 Plusc sts.
Dated .._.JaAU.?..y 7' 2.000 --
ornery for PloinH$(a)
er, le S Lord, LP
NOTE 139 E. Philadelphia Street
Yo k, PA 17403
Under paragraph (1) when the writ is directed to the sheriff of anot?ier county as authorized by Rule 3103(b), the county
should be Indicated.
Under Rule 3103(c) a writ issued on a transferred Judgment may be directed only to the sheriff of the county in which issued.
Paragraph (3) above should be completed only if a named garnishee is to be included in the writ.
Paragr aph (4)(a) above should be completed only if indexing of the execution in the county of issuance, is desired as autho.
rized by Rule 3104(a). When the writ issues to another county indexing is required as of course in that county by the prothonotary. f4.
See Rule 3104(b).
Paragraph (4) (b) should be completed only if real property in the name of a garnishee is attached and indexing as alts
pendens is desired. See Rule 3104(c). -t;
•A description of eDeclfle property to be levied upon or attached may be set forth in the oneelno or Ineluded by exhibit attached. a?'?
January 7, 2000
T0; R. Thomas Kline
Sheriff
Cumberland County Courthouse
SIR:
There will be placed in your hands for service a Writ (Order) of
Execution styled as follows:
TRI-BORO CONSTRUCTION SUPPLIES, INC. PLAINTIFF vs.
CUMBERLAND SERVICES, INC.
DEFENDANT.
No. 99-5003
INSTRUCTIONS
If Writ of Execution, state what shall be seized and levied upon.
If Real Estate, attach five (5) copies of description together with
the location of premises. In all services, give full information as
to parties to be served with addresses, etc.
All vehicles, equipment, supplies, tools, at defendant's place of
business. 3 South 40th Street, Camp Hill, PA 17011.
WAIVER OF WATCHMAN
Any deputy sheriff levying upon or attaching any property under within
writ may leave same without a watchman, in custody of whomever is found.
in possession, after notifying person of such levy or attachment, with-'
out liability on the part of such deputy or the sheriff to any plaintiff
herein for any loss, destruction or removal o a suc XProty before,
sheriff's sale thereof.
TORN' FOR P NTIFF
139 E. Philadelphia St.
ork PA 17403
7175 845-1524
TELEETHONE NUMBER
IN THE COURT OF COMMON PLEAS OF
CIVIL DIVISION
TRI-BORO NNSTRUCIION AND
SUPPLIES, INC.
Plaintiff
VS. File No. 99-5003
CUMBERLAND SERVICES, INC. CIVIL AMON - LAW
Defendant
PRAECIPE FOR JUDGMENT
Enter Judgment in favor of Plaintiffnd against:
Defendant - (timberland Services, Inc. c- 4.0
rr y
for want of an answer to Complaint
c: Co
( XX ) DAsse ebtss damages as follows: 7,896.33
<' ------------------------
Interest from September 3, 1999 ---. $$ 167.44 ti
Attorney's Commission---------------------
TOTAL -------------------- --------------------- $ 8.063.77
( xx ) I certify that the foregoing assessment of damages is for specified amounts alleged to
be due in the complaint and is calculable as a sum certain from the complaint.
( xx ) Pursuant to Pa.R.C.P. 237 (Notice of praecipe for final judgment or decree), I certify
that a copy of this praecipe has been mailed to each other party who has appeared in the action or to
his/her Attorney of Record.
( xt ) Pursuant to Pa.R.C.P. 237.1, 1 certify that written notice of the intention to file this
praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her
Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing
of this praecipe and a copy of the notice is attached.
OATE: I?4, Signature
Print Name: John D. Mill , 4ir
Attorney for: Plaintiff
Address: 139 East Philadelphia St. York, PA
17403
Telephone: (717) 845-1524'
Supreme Court ID No.: 25753
NOW, CJ CLj;F, /? , 19?'9 , JUDGMENT IS ENTERED AS ABOVE.
Prothonotary/Clerk, Civll' Islon
by: ??:. r, ooJ
Deputy
" UNTY, PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
YORK COUNTY, PENNSYLVANIA
TRI-BORO CONSTRUCTION NO. 99-5503
SUPPLIES, INC.
VS.
CUMBERLAND SERVICES, INC.
CERTIFICATE OF SERVICE
AND NOW, this the 7th day of January, 2000, I, John D. Miller, Jr., Esquire, hereby
certify that I have this date served a copy of the Praecipe for Writ of Execution in the above
captioned matter by first class regular mail.
Cumberland Services, Inc.
3 South 40th Street
Camp Hill, Pennsylvania 17011
BY:
hn D. M er, Jr., Esqui e
Miller, Pool & Lord, LL
139 East Philadelphia Street
York, PA 17403
(717) 845-1524
Supreme Court I.D. #63062
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PENNSYLVANIA NOTICE OF APPEAL
JUDICIAL DISTRICT
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS Na
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.
12(-6iau; Cti ,. S va,s
Cv 19- 00001?(,-?9
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This block will be signed ONLY when this notation is required under Pa R.CP.J.P. Na [FILE f I t was CLAIMANT (see Pa. R.C.P,JP. No.
10080,
This Notice of Appeal, when received by the District Justice, will operate as a 001(6) in action before District Justice, he MUST
SUPERSEDEAS to the judgment for possession in this case.
A COMPLAINT within twenty (20) days a/ter
Ring his NOTICE of APPEAL.
signature or Prothonotary or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prothonotary (]
Enter rule upon 11l. 2 V 6 i S,JPp( I) appellee(s), to file a complaint in this appeal
Name of appellees)
(Common Pleas No IT ) within twenty (20) days after service of rule or ff try of judgment of non pros.
-,,;i7G?3Gv erm _
are of appellant or his aftm,ey a agent
RULE: To I I I ` lX J (?I r1J S /?fltf 7 (?/ , appellee(s).
Nanw of appollee(s) (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 if service was by mail is the date of mailing.
Date: 19CQ. ?1.LYZ M t' ?PYYImncJ )?!
Stnmh of Ranarotery or [)!poly
COURT FILE TO BE FILED WITH PROTHONOTARY
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COMMONWEALTH OF PENNSYLVANIA; j
COtlNTV nF• CUMBERLAND
70-
09-2-01
DJ Nam Nan
PAULA P. CORREAL
A° iai' EAST WING - COURTHOUSE
1 COURTHOUSE SQUARE
CARLISLE, PA
Tai.^.,(717) 240-6564 17013-0000
CUMBERLAND SERVICES INC.
3 SOUTH 40TH ST.
CAMP HILL, PA 17011
THIS IS TO NOTIFY YOU THAT:
Judgment:
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: CIVIL. CASE
NAME am ADDRESS
rTRI-BORO CONSTRUCTION SUPPLIES INC,
435 LOCUST ST.
P.O.BOX 8
LDALLASTOWN, PA 17313 J
Vs.
DEFENDANT: NAME aW ADDRESS
rCUMBERLAW. SERVICES INC.
3 SOUTH 40TH ST.
CAMP HILL, PA 17011
L J
DocketNo.: CV-0000276-99
Date Filed: 6/03/99
® Judgment was entered for: (Name) PRT _nngn rnNC rJr_TTn ` gnppT TRq
Fx? Judgment was entered against: (Name) cmmnFgr.Anrn cr;gVr _FS rh*
in the amount of $ Rq(, .33 on
? Defendants are jointly and severally liable.
? Damages will be assessed on:
? This case dismissed without prejudice.
(Date of Judgment) 7/11 g/9q
(Date & Time)
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
Total
Amount of Judgment Subject to
Attachment/Act 5 of 1996 $
Levy is stayed for days or ? generally stayed.
? Objection to levy has been filed and hearing will be held:
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 COURT OF COMMA PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF Tt 13-WOTIC F JUDG,NIENT/Tji'AN$CRIPT FORM WITH YOUR NOTICE OF APPEAL.
7/19/99 Date salstr c't!'J 9tice
I certify that this is a true an" cor ect co y of the re ord o •t erproceedin s containirj lhQ•j1tAg?rienti;p??
?J 1?
7/19/99 Date ?_ /? .1/? ( i "? ?° Distract: ustice
My commission expires first Monday of January, 2000 % 131E/{L x(
AOPC 315-99 4.• )`#
Post Judgment Credits
Post Judgment Costs
Certified Judgment Total
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COMMONWEALTH OF PENNSYLVANIA NOTICE OF APPEAL
COURT OF COMMON PLEAS
FROM
JUDICIAL DISTRICT
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS Na _ 500,3 <' yl l )PrYrl
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 _
ADaRESS OF APPELLANT
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CITY
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DATE OF J Nl THE ASE Of (wlm,iN
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51GNA E OF APPELLANT 0ry ATTOa EY AGENT
CV 19
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This block will be signed ONLY when this notation is required under pa. R.C.P.J.F. No. (f 1 t was CLAIMANT (see Pa. R.C.P.J.P. No.
10088.
This Notice of Appeal, when received by the District Justice, will operate as a 001(6) in aCtl0I' before District Justice, he MUST
SUPERSEDEAS to the judgment for possession in this case FILE A COMPLAINT within twenty (20) days after
filing his NOTICE of APPEAL.
Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see N. R.C.P.J.P. No. 1001(7) in action before District Justice..
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prothonotary
Enter rule upon
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appellee(s), to file a complaint in this upped
Namo or appellee(s)
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(Common Pleas Na L? t? 1 ) within twenty (20) days after service of rule of r "try of judgment of non pros.
tore Of appellant a his atfomey or agent
RULE: To co oppellee(s).
Name of appellee(s)
(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 4 service was by mail is the date of nailing.
Daft: 19q.
of Roaaoagy a Deputy
AOPC 312-84 COURT FILE
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COMMON'RF LTfi G' PENNSYLVANIA
COUNTY"OF.._?LL?27!/?-/. ?tCLL? ..- -.
AFFIDAVIT: I hereby r.rreor ....:L....
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?nd further Iha? I •^.ved fhr Pof•.r to f I. ' -rori ••
- 'T q', cr"'n . the chD _ N_.ticu of Appeal upon the appolieo(s) to,
whom the Rule was addressed on _._._ C. _' ly= _--_ _ __ _ p? ?C t1 h... r,r onal servica EFFY (cortified) (regislerod)
mall, sender's receipt attached hereto.
SWORN'1' (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS.-16-_DAY OF 12 (A c u,-; T-- ?? 1'.
St.g'nneturte Off ffidel before whom Ofid,,ft was mad,
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MY commission expires on , 19_
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whom the Rule was oddressed [I by pcr:oncl service (?y (cortified)(registered)
mail, sender's receipt attached hereto.
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS DAY OF ' uw ; 17 19
S/ynature of lolal before whom affidavit was made
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
TRI-BORO CONSTRUCTION
AND SUPPLIES, INC.,
Plaintiff
VS.
CUMBERLAND SERVICES, INC.,
Defendant
NO. 99-5003
CIVIL TERM
CIVIL ACTION - LAW
NOTICE TO DEFEND
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 (20) 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 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.
.i,
NAME: LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
ADDRESS: CUMBERLAND COUNTY COURTHOUSE
1 COURTHOUSE SQUARE
CUMBERLAND, PENNSYLVANIA 17013
PHONE: (717) 240-6200
hall.collect
AVISO
USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse
de las quejas expuestas en las paginas siguientes, debe tomar action dentro de veinte
(20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar
comparecencia escrita en persona o por abogado y presentar en la Corte por escrito sus
defensas o sus objeciones a [as demandas en su contra.
Se le avisa que si no se defiende, la caso puede proceder sin usted y Ia Corte
puede decidir en su contra sin mas aviso o notification por cualquier dinero reclamado
en la demanda o por cualquier otra queja o compensation reclamados por el
Demandante. USTED PUEDE PERDER DINERO, O PROPIEDADES U OTROS
DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED
NO TIENE O CONOCES UN ABOGADO, VAYA O LLAME A LA
OFICINA EN LA DIRECCION ESCRITA ABAJO PARA
AVERIGUARDONDE PUEDE OBTENER ASISTENCIA LEGAL.
NAME: LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
ADDRESS: CUMBERLAND COUNTY COURTHOUSE
1 COURTHOUSE SQUARE
CUMBERLAND, PENNSYLVANIA 17013
PHONE: (717) 240-6200
hall.collect
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
TRI-BORO CONSTRUCTION NO. 99-5003
AND SUPPLIES, INC.,
Plaintiff
VS.
CIVIL TERM
CIVIL ACTION - LAW
CUMBERLAND SERVICES, INC.,
Defendant
COMPLAINT
AND NOW, to wit, this 3rd day of September, 1999, comes the Plaintiff, TRI-
BORO CONSTRUCTION AND SUPPLIES, INC., by its attorneys Miller, Poole &
Lord, LLP, by John D. Miller, Jr., Esquire, and files the following:
1. TRI-BORO CONSTRICTION AND SUPPLIES, INC., is a Pennsylvania
business corporation with its principal place of business located at 435 Locust Street,
P.O. Box 8, Dallastown, York County, Pennsylvania 17313.
2. Defendant, CUMBERLAND SERVICES, INC., is a corporation
organized under the laws of the Commonwealth of Pennsylvania with its principal
place of business located at 3 South 4011, Street, Camp Hill, Cumberland County,
Pennsylvania, 17011.
hall.collect
3. On or about April 8,1998, Defendant applied for and received a credit
account, being No. 76900 for the acquisition of supplies and equipment.
4. Based upon and relying on Defendant's application, Plaintiff extended
credit to Defendant via Account No. 76900.
5. On or about June 6,1998, Defendant rented and took possession of
scaffolding and various accessories at a monthly rate of rent.
6. By reason of Defendant's initial rental and subsequent retention of said
equipment. Defendant owes to Plaintiff the amount of $7,778.48, which amount
includes interest to July 19, 1999 at a rate of 1.5% per month which was clearly state
on all statements to Defendant, plus costs, to date, of $117.85 for a total of $7,896.33.
7. Defendant, after reasonable demand, via invoicing and otherwise, has
failed and/or refused to pay the balance outstanding on account with Plaintiff.
COUNTI
TRI-BORO CONSTRUCTION AND SUPPLIES, INC. vs. CUMBERLAND SERVICES,
INC.
Account Stated
8. Paragraphs 1-7 set out above are incorporated herein by reference.
9. Defendant, Cumberland Services, Inc., is liable to Plaintiff on an
account stated in the amount of $7,896.33, plus interest from July 19, 1999.
hall.collect
WHEREFORE, Plaintiff prays for judgment in its favor and against the
Defendant, Cumberland Services, Inc., in the amount of $7,896.33 together with
interest and costs of suit.
COUNT II
TRI-BORO CONSTRUCTION AND SUPPLIES, INC. vs. CUMBERLAND
SERVICES, INC.
Contract
10. Paragraphs 1-9 set out above are incorporated herein by reference
thereto.
11. Defendant, Cumberland Services, Inc. is liable to Plaintiff in the amount
of $7,896.33 under its contract to purchase goods and materials from Plaintiff.
WHEREFORE, Plaintiff demands judgment against Defendant, Cumberland
Services, Inc., in the amount of $7,896.33 together with interest and costs of suit.
COUNT III
TRI-BORO CONSTRUCTION AND SUPPLIES, INC. vs. CUMBERLAND
SERVICES, INC.
Unjust Enrichment
12. Paragraphs 1-11 set out above are incorporated herein by reference
thereto.
13. Defendant, Cumberland Services, Inc., has been unjustly enriched by
reason of the receipt of equipment and goods without paying therefore.
hall.collect
14. By reason of Defendant's unjust enrichment, the Defendant is liable to
the Plaintiff in the amount of $7,896.33.
WHEREFORE, Plaintiff demands judgment against, Defendant, in the amount
of $7,896.33 together with interest and costs of suit.
Date: [ -q /
Respectfully submitted,
MILLER and POOLE, LLP
York, PA 17403
(717) 845-1524
Sup. Ct. I.D. No. 25753
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John D. Miller, Jr., Esquire
139 East Philadelphia Street
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QNSWORN VERIFICATION
The foregoing document is based upon information which has been gathered
by me or my counsel in the preparation of this law suit. The language of the
document is that of counsel and not my own. I have read the document and to the
extent that the document is based upon information which I have given to counsel, it
is true and correct to the best of my knowledge, information and belief.
This statement and verification are made subject to the penalties of 18 Pa.
C.S.A. Section 4904 relating to unsworn falsification to authorities, which provides that if
I knowingly make false averments, I may be subject to criminal penalties.
Date: 9-3-," - ?
hall.collect
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
TRI-BORO CONSTRUCTION NO. 99-5003
AND SUPPLIES, INC.,
Plaintiff
VS.
CIVIL TERM
CIVIL ACTION - LAW
CUMBERLAND SERVICES, INC.,
Defendant
CERTIFICATE OF SERVICE
AND NOW, this 7th day of September, 1999, I, John D. Miller, Jr., Esquire hereby
certify that I have, this date, served a copy of the Complaint, in the above captioned
matter, by depositing a copy of the some in the United States Mail, postage prepaid
addressed to the following:
Richard A. Lade, President
CUMBERLAND SERVICES, INC.
3 South 40th Street
Camp Hill, PA 17011
Respectfully Submitted,
MILLER, POOLE & LORD, LLP
3efm D. Miller, Jr., Eslq I
139 East Philadelphia Street
York, PA 17403
(717) 845-1524
Sup. Cf. I.D. No. 25753
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
TRI-BORO CONSTRUCTION
AND SUPPLIES, INC.,
Plaintiff
VS.
CUMBERLAND SERVICES, INC.,
Defendant
TO: Richard A. Lane, President
CUMBERLAND SERVICES, INC.
3 South 40th Street
Camp Hill, PA 17011
DATE OF NOTICE: September 30, 1999
NO. 99-5003
CIVIL TERM
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 (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.
NAME: LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
ADDRESS: CUMBERLAND COUNTY COURT HOUSE
1 COURTHOUSE SQUARE
CUMBERLAND, PENNSYLVANIA, 17013
PHONE: (717) 240-6200
John D. M r, Jr., Es uir
Attorney for Plaintiffs
139 East Philadelphia Street
York, PA 17403
Sup. Ct. I. D. No. 25753
(717) 845-1524
I CERTIFY THAT A COPY OF THIS NOTICE HAS BEEN SENT BY ORDINARY MAIL ON THE DATE
ABOVE GIVEN TO EACH OF THE NAMED DEFENDANTS AND/OR DEFENDANT'S ATTORNEY OF
RECORD AS OF THE DATE THEREOF. A
Jo n D. Miller, Jr.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
TRI-BORO CONSTRUCTION NO. 99-5003
AND SUPPLIES, INC.,
Plaintiff
Vs. CIVIL ACTION - LAW
CUMBERLAND SERVICES, INC.,
Defendant DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this 301h day of September, 1999, I, John D. Miller, Jr., Esquire hereby
certify that I have, this date, served a copy of the Ten Day Notice, in the above
captioned matter, by depositing a copy of the same in the United States Mail, postage
prepaid addressed to the following:
Richard A. Lane, President
Cumberland Services, Inc.
3 South 401h Street
Camp Hill, PA 17011
Respectfully Submitted,
MILLER, POOLE & LORD,1LLLP
I. A
Jolin D. Milldf, Jr:, Mquire v
139 East Philadelphia Street
York, PA 17403
(717) 845-1524
Sup. Ct. I.D. No. 25753
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IN THE COURT OF COMMON PLEAS OF " &NTY, PENNSYLVANIA
CIVIL DIVISION
TRI-BORO ODNSTRUCfION AND
SUPPLIES, INC.
Plaintiff
Vs.
File No. 99-5003
CUMBERLAND SERVICES, INC. CIVIL AMON - LAW
Defendant
PRAECIPE FOR JUDGMENT
Enter Judgment in favor of PlaintiffIlDetaxle=nd against:
Defendant - Cumberland Services, Inc.
for want of an- answer to Complaint
( 1Dt ) Assess damages as follows: 7,896.33
Debt -------------------------------------------- $
Interest from September 3, 1999 ---- $ 167.44
Attorney's Commission--------------------- $ 0.00
TOTAL------------------------------------------ $ 8,063.77
( xx ) I certify that the foregoing assessment of damages is for specified amounts alleged to
be due in the complaint and is calculable as a sum certain from the complaint.
( xx ) Pursuant to Pa.R.C.P. 237 (Notice of praecipe for final judgment or decree), I certify
that a copy of this praecipe has been mailed to each other party who has appeared in the action or to
his/her Attorney of Record.
( lot ) Pursuant to Pa.R.C.R 237.1, 1 certify that written notice of the intention to file this
praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her
Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing
of this prraaecipe and? /a copy of? the notice is attached.
DATE:l ei /'1 Signature 1
Print Name: John D. Mill , Jr.
Attorney for:
Address: 139 East Philadelphia St.
Telephone: (717) 845-1524-
Supreme Court ID No.: 25753
NOW, OcL?:? /9' /9 i 9 19 JUDGMENT IS ENTERED AS ABOVE.
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Prothonotary/Clerk, C it ivision
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by: L?d r[ oa .,
Deputy s:M
Plaintiff
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. [pgg 17{ Cumberland County
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TRI-BORO CONSTRUCTION
AND SUPPLIES, INC.
No.
99-5003
V5.
CUMBERLAND SERVICES, INC.
CIVIL`ACTION - LAW
PRAECIPE TO REMOVE
To the Prothonotary:
( ) Please mark the above captioned action
OR
Please mark the above captioned judgment or lien settled and satisfied.
Term,
LLD
Supreme Court No. 25753 139 East Philadelphia Street
York, PA 17403
(717) 845-1524
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R. Thomas Kline, Sheriff, who being duly sworn according
to law, states this writ is returned SATISFIED.
Sheriff's Costs:
Docketing $ 18.00
Poundage 157.93
Law Library .50
Prothonotary 1.00
Service 9.30
Surcharge 10.00
Levy 20.00
$ 2TT.73
Sworn and subscribed to before me
This i7" day of }ha t?
2000, A.D.? ?? C 7?-cv'/ iPs«f
Prn°t notary
GiD
Advance Costs: $216.73
Sheriff's Costs: 216.73
$ 0.00
So AnSiie A G-aGur?
R. Thomas Kline, Sheriff
BY 6 CLc ?
De ty Sheriff
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 99-5003 CIVIL 19 _
(:OUNTY OF CUMBERLAND) CIVIL ACTION -LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due Tri-Boro Construction Supplies, Inc.
PLAINTIFF(S)
from Cumberland Services, Inc., 3 South 40th Street, Camp Hill, PA 17011
(1) You are directed to levy upon the property of the defendant(s) and to sell All vehicles, equipment,
supplies tools at defendant's place of business. 3 South 40th Street, Camp
Hill, PA 17011
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) Ifpropertyofthedefendant(s)notlevieduponansubjecttoattachmentisfoundinthepossessionofanyoneother
than a named garnishee, you are directed to notify hinvher that he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due__ $7,896.1L.L. $.50
Interest from Sept. 3, 1999 - $501.81 Due Frothy $1.00
Ally's Comm -% Other Costs
Arty Paid $71.75
Plaintiff F
Date: January 11, 20^u0 Curtis R. Long
REQUESTING PARTY:
Name hn Mi 11 Pr Tr Fcq
Address: Miller, Poole & Lord, LLP
139 E. i a
Vnrk,, PL 174n3
Attorney for:pl ni nti ff _
Telephone: 717-845-1524
Prothonotary, Civil Division
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DeputySupreme Court ID No. 63062