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Home My WebLink About99-07591i _.f v No. 9O'- 701 Civil Term t ?5 i i J Vs. 1 Court of Common Pleas Cumb. Co. 4 i i V 1 I. It i ' i f, 1 f i r? i ? j `1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND 0 `q 09-3-05 DJ Nam: Hon. GAYLE A. ELDER Adroes: 507 N. YORK ST. MECHANICSBURG, PA Telephone: (717 ) 766-4575 ATTORNEY FOR PLAINTIFF : E R. GODFREY ESQUIRE 3211 N FRONT ST PO BOX 5300 HARRISBURG, PA 17110 C THIS IS TO NOTIFY YOU THAT: ` Judgment: ,NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME end ADDRESS rWILLIAMS, DDS, PAUL H 7 3 RACEY COURT SUITE 202 LMECHANICSBURG, PA 17055 J VS. DEFENDANT: NAME end ADDRESS FLEWIS, JAMES, ET AL. 213 RAILROAD AVENUE MECHANICSBURG, PA 17055 L J Docket No.: GV-0000292-99 Date Filed: 10106199 • r DEQgU1,T 1M2GMENT? •TL- ® Judgment was entered for: (Name) WTT T TAmR nnc _,PATTT R ® Judgment was entered against: (Name) T.xwTa, TAmEq in the amount of $ •L, 49 R _ ng, on: ? Defendants are jointly and severally liable. ? Damages will be assessed on: ? This case dismissed without prejudice. E] Amount of Judgment Subject to Attachment/Act 5 of 1996 $- F""] Levy is stayed for days or ? generally stayed. Date: Place: , . Time: (Date of Judgment) 11.409199 (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total Post Judgment Credits Post Judgment Costs Judgment Total ? Objection to levy has been filed and hearing will be held: ANY PARTY HAS,THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE n; OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS,; CIVIL'DIVISION. YOU. s MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH Y,OUR•NOYIC,EbFAPPEAL Date District Justice " r I certify that this is a true and correct copy of the record of the proceedings containing tl . 'n,. Date My commission expires first Monday of January, 4 AOPC 315.99 17055 2002 Try SEAL -`1 I?+ `J J N` LJ .. `, LD L. :i ILL I" L < ' G CD COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND 09-3-05 DJ Name: Hon. GAYLE A. ELDER ' Add` a": 507 N. YORK ST. MECHANICSBURG, PA h TeWpnone t717 766-4575 ` ATTORNEY FOR PLAINTIFF E R. GODFREY ESQUIRE 3211 N FRONT ST PO BOX 5300 HARRISBURG, PA 17110 17055 NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF.• CIVIL CASE NAME and ADDRESS rWILLIAMS, DDS,PAUL H -I 3 KACEY COURT SUITE 202 LMECHANICSBURG, PA 17055 -J DEFENDANT: VS. ' NAME and ADDRESS - 'i rLEWIS, JAMES, ET AL. lt'. 213 RAILROAD AVENUE { MECHANICSBURG, PA 17055 L F tNo.: CV-0000292-99 iled: 10/06/99 THIS IS TO NOTIFY YOU THAT: ':Judgment _DE?AUr.m arm_M?trr rrTF _ ® Judgment was entered for: (Name) Wn-,T,TAMC, _nna __ vnm, sr ® Judgment was entered against: (Name) LxwTa. nxnrrarz in the amount of $ 1,4()t; ns on: Defendants. are jointly and severally liable. Damages will be assessed on: -1 f This case dismissed without prejudice. Amount of Judgment Subject to 'El Attachment/Act 5 of 1996 $ Levy is stayed for days or ? generally stayed. 0 Objection to levy has been filed and hearing will be held: Date: ?FP acei II Time: (Date of Judgment) - I I Ing?gg (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total Post Judgment Credits Post Judgment Costs CertifiedJudgment Total .;435.55 59.5 0 00 . nn $ i 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 COMMON PLEAS, CIVIL DIVI§ION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NC`VICEOF APPEAL. Date --------- ----- Dlsfrict Justice certify that this is a true and correct copy of the record of the proceedings contaimhgjlie judgment: ' Date = '? • District Justice My commission expires first Monday of January, AOPC 315.99 2002 SEAL.. .. ;V n N F' L ! LL L? rn -J ? U 4 Defendants No. 9v . NOTICE OF ORDER, DECREE OR JUDGMENT PAUL H. WILLIAMS, D.D.S., VS. Plaintiff JAMES LEWIS and DENISE LEWIS, TO: James and Denise Lewis 213 Railroad Avenue Mechanicsburg, Pa 17055 You are hereby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on 5a, in accordance with the provisions of Pa. R.C.P. 236. ( ) Decree Nisi in Equity ( ) Final Decree in Equity () Judgment of ( ) Confession ( } Verdict ( ) Default ( ) Non-suit ( ) Non-pros ( ) Arbitration Award ( ) Judgment is in the amount of $ plus costs. ( X ) District Justice transcript of judgment in civil action in the amount of $1,435.55, plus costs for a total of $1,495.05. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Pennsylvania Department of Transportation. By: is/ Gl o' . 7.. Prothonotary ?G If you have any questions regarding this Notice, please contact the filing party. E. Ralph Godfrey, Esquire 3211 N. Front Street Harrisburg, PA 17110 (717) 238-8187 (This Notice is given in accordance with Pa.R.C.P. 236.) Document 8: 165698 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA -47 .p v L d N? s PAUL H. WILLIAMS, D.D.S., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. No. JAMES LEWIS and DENISE LEWIS, Defendants ENTRY OF APPEARANCE Please enter the Appearance of E. Ralph Godfrey, Esquire, as counsel for Plaintiff in the above captioned action. Respectfully Submitted, E. Ralph Godfrey, Esquire METZGER WICKERSHAM 3211 N. Front Street Harrisburg, PA 17110 (717) 238-8187 I.D. No. 77052 Attorney for Plaintiff Date: December 15, 1999 D"umew #: 165698 <,?;'? ?.S?diT TfJa:?. OFFICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY Telephone: Curtis Long (717) 240-6195 Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff: PAUL H. WILLIAMS, D.D.S. versus Defendants: JAMES & DENISE LEWIS Judgment No. CERTIFICATE OF RESIDENCE PA. R. C. P. 236 I, hereby certify that the precise residence of Plaintiff is: Paul H. Williams, D.D.S. 3 Kacey Court Suite 202 Mechanicsburg, Pa 17055 and certify that the last known address of the within defendants is: James and Denise Lewis 213 Railroad Avenue Mechanicsburg, PA 17055 E. RalpPGo METZGER WICKERSHA 3211 N. Front Street Harrisburg, PA 17110 (717)238-8187 Attorney for the Plaintiff Attorney ID# 77052 Document d: 165696 v Y 0 - CV i _ . U PAUL H. WILLIAMS, D.D.S., Plaintiff V. JAMES LEWIS and DENISE LEWIS, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7591 1S RULE AND NOW, this 16 day of t7,^ ? r ? 1 , 2000, upon consideration of the foregoing Motion, it is ORDERED that the parties to this action show cause, if any they have, why this Motion should not be granted. RULE RETURNABLE 2-0 days from the date of service hereof. BY THE COURT: in r -- X45: `c I4' "m: m M 10'Sn: 1 PAUL H. WILLIAMS, D.D.S., Plaintiff V. JAMES LEWIS and DENISE LEWIS, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7591 ORDER AND NOW, this _ day of 2000, upon consideration of Plaintiffs Motion to Compel Discovery, it is hereby ORDERED and DIRECTED that: 1. Defendants are to appear for an oral deposition and bring all of the requested documents; 2. The oral deposition of Defendants shall be conducted on the day of , 2000, at a.m./p.m., at the law office Metzger, Wickersham, Knauss & Erb, P.C., 3211 N. Front Street, Box 5300, Harrisburg, Pennsylvania 17110; 3. Defendants be held in contempt and require to so pay Plaintiff the reasonable expenses of preparing and presenting this Motion in the amount of $150.00; 4. The amount set forth in paragraph "3" shall be added to the judgment amount owed by the Defendants; and 5. such other relief as the Court may deem necessary. BY THE COURT: J. Unnnnent k: 167861.1 PAUL H. WILLIAMS, D.D.S., Plaintiff V. JAMES LEWIS and DENISE LEWIS, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7591 MOTION TO COMPEL AND NOW, this 15th day of February, 2000, comes the Plaintiff, Paul H. Williams, D.D.S., through his attorney, E. Ralph Godfrey , Esquire, and files this Motion To Compel Discovery pursuant to Rule 4019 of the Pennsylvania Rules of Civil Procedure, and in support thereof avers the following: 1. Plaintiff, Paul H. Williams, D.D.S., is an adult individual doing business within the Commonwealth of Pennsylvania with a principal place of business situated at 3 Kacey Court, Suite 202, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendants, James and Denis Lewis, are adult individuals with a last known address of 213 Railroad Avenue, Mechanicsburg, Cumberland County, Pennsylvania. On or about December 21, 1999, a Judgment was entered in favor of Plaintiff and against Defendants in the Common Pleas Court of Cumberland County, Pennsylvania, with respect to the above captioned matter. 4. Thereafter, on or about December 28, 1999, Defendants were properly served with a Notice of Deposition and a Subpoena requesting that Defendants appear for an oral deposition on January 20, 2000, and bring along the requested documents. A true and correct Uocunlent N: 167362.1 i copy of the Notice of Deposition and the Subpoena is attached hereto, incorporated herein and collectively marked as Exhibit "A". 5. The certified letter enclosing the Subpoena was returned to our office with the notation of "unclaimed". A true and correct copy of the unclaimed envelope is attached hereto, incorporated herein and collectively marked as Exhibit "B". 6. The letter that was mailed to the Defendants via regular mail was not returned to our office within fifteen (15) days from the date of mailing and it is presumed that Defendants received this letter and accompanying Subpoena. 7. Despite receiving notice of the time and place of the deposition pursuant to Rule 4007.1 of the Pennsylvania Rules of Civil Procedure, Defendants failed to appear for said deposition. 8. To date, Defendants have not responded to Plaintiffs request for the designated materials or appear for the oral deposition. WHEREFORE, Plaintiff respectfully request this Honorable Court to issue an Order: a. compelling Defendants to appear for oral deposition and bring the requested documents; b. holding Defendants in contempt and requiring Defendants to pay Plaintiff the reasonable expenses incurred in connection with preparing and presenting this Motion in the amount of $150.00; C. The amount set forth in paragraph "b" shall be added to the judgment amount owed by the Defendants; and D", ... enr 4: 167X61.1 d. granting any other relief with regard to Defendants' failure to make discovery as is just and proper. Respectfully Submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Dated: 62/? aU E. Ralph Godfrey, Esquire Attorney I.D. No. 77052 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff 1)ueunn•n111; /6736:.1 Exhibit A PAUL H. WILLIAMS, D.D.S., Plaintiff V. JAMES LEWIS and DENISE LEWIS, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7591 NOTICE OF DEPOSITION UPON ORAL EXAMINATION TO: James Lewis 213 Railroad Avenue Mechanicsburg, Pa 17055 YOU ARE HEREBY NOTIFIED that the undersigned attorneys will take the deposition(s) of James Lewis upon oral examination for the purpose of discovery or for use as evidence in the above action or for both purposes before an officer authorized to take depositions, at 10:00 a.m., on January 20, 2000, at the law offices of Metzger, Wickersham, Knauss, & Erb, P.C., on all discoverable matters or matters which may lead to the discovery of admissible evidence in this action. Notice is hereby given that you are directed to bring to the deposition: ANY AND ALL DOCUMENTS PERTAINING TO YOUR PRESENT FINANCIAL SITUATION, INCLUDING RECENT PAY STUBS, YOUR CHECKING AND SAVINGS ACCOUNT BALANCES, A LIST OF YOU ASSETS, A LIST OF YOUR CREDITORS, AND YOUR TAX RETURNS FOR THE PAST TWO (2) YEARS. Notice is hereby given that you arc required to personally appear at the time and place set #169H61 forth above. If you fail to appear at the aforesaid time and place, sanctions maybe entered against you and judgment maybe entered against you. METZGER, WICKERSHAM,KNAUSS & ERB, P.C. By: E. Ralph Godfrey, Esquire/ PA Court I.D. No. 77052 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717)238-8187 Attorneys for Plaintiff Dated: December28,1999 #168961 CERTIFICATE OF SERVICE AND NOW, this 28th day of December, 2000, I, E. Ralph Godfrey, of Metzger, Wickersham, Knauss & Erb, P.C, attorneys for Plaintiff, hereby certify that I served the foregoing Notice of Deposition and Subpoenas this day by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: James Lewis 213 Railroad Avenue Mechanicsburg, Pa 17055 BY: E. Ralph Godfrey, Vsqui:D? #168861 SUBPOENA TO ATTEND AND TESTIFY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAUL H. WILLIAMS, D.D.S. No. 99-7591 VS. Action in Law JAMES and DENISE LEWIS To: JAMES LEWIS 213 Railroad Avenue, Mechanicsburg, Pa 17055 1. YOU ARE ORDERED BY THE COURT to come to the law office of METZGER, WICKERSHAM, KNAUSS & ERB P.C. 3211 N. Front Street, Harrisburg Pennsylvania, on January 20, 2000 at 10:00 a.m. o'clock to testify on behalf of yourself in the above case, and to remain until excused. * 2. And bring with you the following: Any and all documents pertaining to your present financial situation, including recent pay stubs, your checking and savings account balances, a list of your assets and a list of your creditors, and your tax returns from the past two (2) years, etc. If you fail to attend, or to produce the documents or things required by this subpoena, you may be subject to the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Civil Procedure, including, but not limited to, costs, attorneys fees and imprisonment. Requested by: 11;. Ralph Godfrey; esquire (I.D. #77052), METZGER WICKERSHAM -N. Front Striet,"Harrisburg, PA 17110 (717) 238-8187 Date: I? a9• /999 ''I $y. I ?tuty% Ole , d t rrotnonotary OFFICIAL NOTE: 'fhis Orin of subpoena shall be used whenever a subpoena is issuable, under Rule 234. 1, including hearing in connectiori'With depostibns`and•before arbitrators, masters, commissioners, etc. * To require the productibn of A utneti[s or things in addition to testimony, complete paragraph 2 Do menr N: 166253 PAUL H. WILLIAMS, D.D.S., Plaintiff V. JAMES LEWIS and DENISE LEWIS, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7591 NOTICE OF DEPOSITION UPON ORAL EXAMINATION TO: Denise Lewis 213 Railroad Avenue Mechanicsburg, Pa 17055 YOU ARE HEREBY NOTIFIED that the undersigned attorneys will take the deposition(s) of Denise Lewis upon oral examination for the purpose of discovery or for use as evidence in the above action or for both purposes before an officer authorized to take depositions, at 10:00 a.m., on January 20, 2000, at the law offices of Metzger, Wickersham, Knauss, & Erb, P.C., on all discoverable matters or matters which may lead to the discovery of admissible evidence in this action. Notice is hereby given that you are directed to bring to the deposition: ANY AND ALL DOCUMENTS PERTAINING TO YOUR PRESENT FINANCIAL SITUATION, INCLUDING RECENT PAY STUBS, YOUR CHECKING AND SAVINGS ACCOUNT BALANCES, A LIST OF YOU ASSETS, A LIST OF YOUR CREDITORS, AND YOUR TAX RETURNS FOR THE PAST TWO (2) YEARS. Notice is hereby given that you are required to personally appear at the time and place set #368863 forth above. If you fail to appear at the aforesaid time and place, sanctions maybe entered against you and judgment maybe entered against you. METZGER, WI RSHAM, KNAUSS & ERB, P.C. By: Ral Godfrey, Esqui PA Court I.D. No. 770 3211 North Front Street P.O. Box 5300 Harrisburg,PA 17110-0300 (717)238-8187 Attorneys for Plaintiff Dated: December28, 1999 0168863 CERTIFICATE OF SERVICE AND NOW, this 28th day of December, 2000, I, E. Ralph Godfrey, of Metzger, Wickersham, Knauss & Erb, P.C, attorneys for Plaintiff, hereby certify that I served the foregoing Notice of Deposition and Subpoenas this day by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Denise Lewis 213 Railroad Avenue Mechanicsburg, Pa 17055 BY: E. Ralph Godfrey, E wire #168863 0 To: DENISE LEWIS 213 Railroad Avenue, Mechanicsburg, Pa 17055 SUBPOENA TO ATTEND AND TESTIFY 1. YOU ARE ORDERED BY THE COURT to come to the law office of METZGER, WICKERSHAM, KNAUSS & ERB P.C. 3211 N. Front Street, Harrisburg Pennsylvania, on Januarv20.2001 at 10:00 a.m. o'clock to testify on behalf of yourself in the above case, and to remain until excused. ' 2. I And bring with you the following: Any and all documents pertaining to your present financial situation, including recent pay stubs, your checking and savings account balances, a list of your assets and a list of your creditors, and your tax returns from the past two (2) years, etc. If you fail to attend, or to produce the documents or things required by this subpoena, you may be subject to the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Civil Procedure, including, but not limited to, costs, attorneys fees and imprisonment. Requested by: 1 N. Front (I.D. #77052), METZGER WICKERSHAM PA 17110 (717) 238-8187 i. Date: ?. oz4. 194 ? "' Vly' Ct' ?.zw.e• /t? ?... OFFICIAL NOTE: 1bic-fot hearing in connection wilh4 • To require the production rromonotary oeQ Ahall be used whenever a subpoena is issuable, under Rule 234. 1, including gnd before arbitrators, masters, commissioners, etc. ents or things in addition to testimony, complete paragraph 2 Document N: 1662S4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Exhibit B ?R 1 r 7 "P Ln N h 0^ CO CO Cc a CL 0 0 0 d G t E o0 4 ? X S zm E u_ vx _N ? d H r Q o B 4?yao9, c , ? m n+ c CN vY 44 r VERIFICATION I, E. Ralph Godfrey, Esquire verify that the statements made in the foregoing Motion to Compel Discovery are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. DateJ S /O (J F`.i.^C Document N. 16;362.1 PAUL H. WILLIAMS, D.D.S., Plaintiff V. JAMES LEWIS and DENISE LEWIS, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7591 CERTIFICATE OF SERVICE I, E. Ralph Godfrey, Esquire, do hereby certify that I served on the /5 day of ,fv , 2000, a copy of the Motion to Compel in the above captioned matter first class mail, postage prepaid, upon the following individual: James and Denise Lewis 213 Railroad Avenue Mechanicsburg, PA 17055 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. J By . Ral h God ey, Esquire Attorney I.D. No. 77052 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Te Document #: 167862.1 PAUL }I. WILLIAMS, D.D.S., Plaintiff V. JAMES LEWIS and DENISE LEWIS, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7591 PRAECIPE TO SATISFY.TUDGMENT TO THE PROTHONOTARY: Kindly mark the above referenced Judgment as satisfied in full. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By ?3 E. Ralph Godfrey, Esquire Attorney I.D. No. 77052 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Dated: March 13. 2000 Dncnmav H: 1, 0643.1