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Home My WebLink About03-6042HUNTER'S RIDGE HOMEOWNERS' ASSOCIATION PLAINTIFF VS. KUNJAL K. PATEL, KUNDRA K. PATEL, AND KIRAN PATEL, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NOTICE 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 1F 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 THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER IMPORTANT RIGHTS. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 or (800) 990-9108 New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff Date: November 17, 2003 HUNTER'S RIDGE HOMEOWNERS' ASSOCIATION PLAINTIFF VS. KUNJAL K. PATEL, KUNDRA K. PATEL, AND KIRAN PATEL, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COMPLAINT 1. Plaintiff, Hunter's Ridge Homeowners' Association is a Pennsylvania non-profit corporation with a mailing address of P.O. Box 454, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant Kunjal K. Patel is an adult individual owning a unit in the Hunter's Ridge Development known as 1740 Josiah Chowning Way, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Defendants Kundra K. Patel and Kiran Patel are adult individuals located at 1740 Josiah Chowning Way, New Cumberland, Cumberland County, Pennsylvania 17070 who may have acquired either a legal or equitable ownership interest in the unit from Kunjal K. Patel. 4. All unit owners are responsible to pay to the Plaintiff certain monthly fees and special assessments on a timely basis. 5. Since February 1, 2003 Defendant has paid a total of $160.00 towards the following monthly fees and assessments due the Plaintiff as follows: Amount Date $ 75.00 March 2003 Monthly Fee $ 75.00 April 2003 $ 75.00 May 2003 $ 75.00 June 2003 $ 75.00 July 2003 $ 75.00 August 2003 $ 75.00 September 2003 $ 75.00 October 2003 $ 75.00 November 2003 $ 75.00 December 2003 $ 50.00 Late Fees for 10 months at $5.00 Per Month $800.00 Subtotal $160.00 Payments From 2/1/03 to Present $640.00 Total Due Plaintiff Exclusive of Attorneys' Fees and Court Costs 6. Plaintiff has the right to accelerate all payments for the balance of the calendar year in the event of serious delinquency. 7. Plaintiff has the right to recover attorneys' fees and court costs as set forth in Exhibit "A". At the time of filing this Complaint the attorneys' fees are $187.50. WHEREFORE, Plaintiffrespectfully requests this Honorable Court to enter judgment in its favor and against the Defendants in the amount of $827.50 plus other court costs, interest of 6%, Plaintiffs actual counsel fees above $187.50 and other relief as the Court deems just. Date: November 17, 2003 Respectfully submitted, ~ven H6v0ell, E~'qff~re J619 Bridge Street New Cumberland, PA 17070 (717) 770~ 1277 Supreme Court I.D. 62063 Attorney for Plaintiff VERIFICATION I hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unswom falsification to authorities. I am authorized as the Treasurer of the Hunter's Ridge Homeowners' Association to execute this document on behalf of the corporation. BY: ~ /-~ v Katie Gipple, Trea§u~er Hunter's Ridge Homeowners' Association Date: Jj_//~ CC .3 the books and records of the Association, may prepare, certify, and execute statements of unpaid assessements in accordance with Sections 6.10 and 11.5.2 of the Declaration. The Asso- ciation may charge a reasonable fee for preparing statements of unpaid assessments. ARTICLE V Maintenance 5.1. Maintenance Responsibilities. The maintenance, repair and replacement responsibility for Units and Common Area shall be carried out by the Association and the Unit Owners in accordance with the provisions of Article V of the Declaration, and as set forth in Exhibit A to these Bylaws. ARTICLE VI Compliance and Default 6.1. Relief. Each Unit Owner shall be governed by, and shall comply with, all of the terms of the Declaration, these Bylaws, and the Rules and Regulations, as any of the same may be amended from time to time. In addition to the remedies pro- vided in the Declaration, a default by a Unit Owner to comply with any provisions of the Project Documents shall entitle the Association, acting through its Board or the Managing AgeDt, to the following relief: (a) Additional Liability. Each Unit Owner shall be liable for the expense of all maintenance, repair or replace- ment rendered necessary by his act, neglect or carelessness or the act, neglect or carelessness of his tenants, guests, invitees or licensees, but only if and to the extent that such expense is not fully covered by the proceeds of insurance carried by the Association. Such liability shall include any increase in casualty insurance premiums occasioned by improper use, misuse, occupancy or abandonment of any Unit or its appur- tenances. Nothing contained herein, however, shall be con- strued as modifying any waiver by any insurance company of its rights of subrogation. (b) Costs and Attorney's Fees. In any proceedings aris- ing out of any alleged default by a Unit Owner, the prevailing party shall be entitled to recover the costs of such proceeding 15 - and such reasonable attorney's fees as may be determined by the court. (c) No Waiver of Rights. The failure of the Associa- tion, the Board or of a Unit Owner to enforce any right, provision, covenant or condition which may be granted by the Declaration, these Bylaws, the Board, or the Rules and Regu- lations shall not constitute a waiver of the right of the Association, the Board or the Unit Owner to enforce such right, provision, covenant or condition in the future. All rights, remedies and privileges granted to the Association, the Board or any Unit Owner pursuant to any term, provision, covenant or condition of the Declaration, these Bylaws, or the Rules and Regulations shall be deemed to be cumulative and the exercise of any one (1) or more thereof shall not be deemed to constitute an election of remedies, nor shall it preclude the party exercising the same from exercising such other privileges as may be granted to such party by the Declaration, these Bylaws, or the Rules and Regulations or at law or in equity. (d) Abating and Enjoining Violations by Unit Owners. The violation of any of the Rules and Regulations adopted by the Board, the breach of any Bylaw contained herein or the breach of any provision of the Declaration, shall give the Board the right, after Notice and Hearing, in addition to any other rights: (a) to enter the Unit in which, or as to which, such violation or breach exists and summarily to abate and remove, at the expense of the defaulting Unit Owner, any struc- ture, thing or condition that may exist therein contrary to the intent and meaning of the provisions hereof, and the Board shall not thereby be deemed guilty in any manner of trespass; (b) to levy fines pursuant to Section 6.2 below; and/or (c) to enjoin, abate or remedy by appropriate legal proceedings, either at law or in equity, the continuance of any such breach. 6.2. Fine for Violation. By resolution, following Notice and Hearing, the Board may levy a fine of up to $25.00 per day for each day that a violation of the Project Documents persists after such Notice and Hearing, but such amount shall not exceed that amount necessary to insure compliance with the rule er order of the Board. 6.3. Late Charges and Interest on Delinquent Assessments. Any assessment not paid within five (5) days after its due date shall accrue a late charge in the amount of five percent (5%1 of the overdue assessment in addition to interest at th~ rate of fifteen percent (15%) per annum or such other rate as may be determined by the Board, shall constitute the personal 16 - SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-06042 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HUNTERS RIDGE HOMEOWNERS ASSOC VS PATEL KUNJAL K ET AL R. Thomas Kline duly sworn according to law, inquiry for the within named DEFENDANT PATEL KUNJAL K unable to locate Him in his bailiwick. ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and but was He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , NOT FOUND , as to , PATEL KUNJAL K 1740 JOSIAH CHOWNING WAY NEW CUMBERLAND, PA 17070 DEPENDANT IS CURRENTLY LIVING AT NAPERVILLE, IL 60565-6173 1333 MODAFF ROAD APT C8 Sheriff's Costs: Docketing 18.00 Service 12,42 Not Found 5.00 Surcharge 10.00 .00 45.42 R. Thomas Kline Sheriff of Cumberland County STEVEN HOWELL 12/08/2003 Sworn and subscribed to before me SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-06042 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HUNTERS RIDGE HOMEOWNERS ASSOC VS PATEL KUNJAL K ET AL R. Thomas Kline duly sworn according to law, inquiry for the within named DEFENDANT PATEL KUNDRA K unable to locate Her COMPLAINT & NOTICE ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and in his bailiwick. but was He therefore returns the the within named DEFENDANT , NOT FOUND , as to PATEL KUNDI~A K 1740 JOSIAH CHOWNING WAY NEW CUMBERLAND, PA 17070 DEFENDANT IS CURRENTLY LIVING AT 1333 MODAFF ROAD APT C8 NAPERVILLE, IL 60565-6173. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 21.00 So answers;~.- . ~ ..... - ..... R. Thomas~kl ine Sheriff of Cumberland County STEVEN HOWELL 12/08/2003 Sworn and subscribed to before me SHERIFF'S RETURN - NOT FOUND CASE NO: 2003-06042 P COMMONTWEALTH OF PENNSYLVANIA COL~TY OF CUMBERLAND HUNTERS RIDGE HOMEOWNERS ASSOC VS PATEL KUNJAL K ET AL R. Thomas Kline duly sworn according to law, says, that he made inquiry for the within named DEFENDANT PATEL KIRA_N unable to locate Him in his bailiwick. COMPLAINT & NOTICE ,Sheriff or Deputy Sheriff, who being a diligent search and but was He therefore returns the the within named DEFENDANT PATEL KIR3kN , NOT FOUND , as to 1740 JOSIAH CHOWNING WAY NEW CUNBERLAND, PA 17070 DEFENDANT IS CURRENTLY LIVING AT 1333 MODAFF ROAD APT C8 NAPERVILLE, IL 60565-6173. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 21.00 R. Thomas k~ine Sheriff of Cumberland County STEVEN HOWELL 12/08/2003 Sworn and subscribed to before me HUNTER'S RIDGE HOMEOWNERS' ASSOCIATION PLAINTIFF VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- 6042 CIVIL TERM KUNJAL K. PATEL, KUNDRA K. PATEL, AND KIRAN PATEL, DEFENDANTS CIVIL ACTION - LAW TO: KUNJAL PATEL APARTMENT C8 1333 MODAFF ROAD NAPERVILLE IL 60565-6173 KUNDRA PATEL APARTMENT C8 1333 MODAFF ROAD NAPERVILLE IL 60565-6173 KIRAN PATEL APARTMENT C8 1333 MODAFF ROAD NAPERVILLE IL 60565-6173 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. Cumberland County Bar Association Lawyer's Referral Service 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Date: January 28, 2004 Respectfully submitted, BY: ~~ Supreme Court I.D. 62063 Attorney for Plaintiff Certificate of Service I hereby certify that on the date set forth below a tree and correct copy of the foregoing document was served upon all interested parties or counsel of record via postage prepaid, first class United States Mail addressed as follows: KUNJAL PATEL APARTMENT C8 1333 MODAFF ROAD NAPERVILLE IL 60565-6173 KUNDRA PATEL APARTMENT C8 1333 MODAFF ROAD NAPERVILLE IL 60565-6173 KIRAN PATEL APARTMENT C8 1333 MODAFF ROAD NAPERVILLE IL 60565-6173 Date: January 28, 2004 BY: Nlevafi/I~o~ell, ~sq~ir e 9 Bridge Street ew Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff HUNTER'S RIDGE HOMEOWNERS' ASSOCIATION PLAINTIFF VS. KUNJAL K. PATEL, KUNDRA K. PATEL, AND KIRAN PATEL, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- 6042 CIVIL TERM CIVIL ACTION - LAW CERTIFICATE OF SERVICE OF COMPLAINT ON OUT OF STATE DEFENDANTS I hereby certify that each of the Defendants was served with a Certified Copy of a Complaint endorsed with a Notice to Defend in the following manner. 1. On December 8, 2003 the Sheriff of Cumberland County was unable to make service on each of the Defendants as shown on Exhibit "A" because they resided out of state at Apartment C8, 1333 ModaffRoad, Naperville, IL 60565-6173. 2. On December 12, 2003 in accordance with Pennsylvania Rule of Civil Procedure 403 (1) each of the Defendants was mailed by postage prepaid, first class United States Mail (Certified, Restricted Delivery, Return Receipt) a true and correct copy of the Complaint endorsed with a Notice to Defend as shown on Exhibit "B". 3. On December 22, 2003 each of the envelopes was returned marked "Refused" and in accordance with Pennsylvania Rule of Civil Procedure 403 (1) each of the Defendants was mailed by postage prepaid, first class United States Mail (Certificate of Mailing USPS Form 3817) ) a tree and correct copy of the Complaint endorsed with a Notice to Defend as shown on Exhibit "C". 4. Service by ordinary mail is complete if the mail is not returned to the sender within fifteen (15) days of mailing and as of January 28, 2004 none of the envelopes mailed on December 22, 2003 have been returned to Steven Howell, Esquire.//'-------~_ ~J-J/~f ~,,~ BY: /~'7 _~'...,,/~ /3(~ven Howell, Esquire / 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff Date: January 28, 2004 ~.sHERIFF'S RETURN - NOT FOL~D CASE NO: 2003-06042 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HUNTERS RIDGE HOMEOWNERS ASSOC VS PATEL KIINJAL K ET AL R. Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named DEFENDANT PATEL KUNJAL K unable to locate Him COMPLAINT & NOTICE ,Sheriff or Deputy Sheriff, who being search and in his bailiwick. but was He therefore returns the , NOT FOUND , as to the within named DEFENDANT , PATEL KUNJAL K 1740 JOSIAH CHOWNING WAY NEW CUMBERLDJqD, PA 17070 DEFENDANT IS CURRENTLY LIVING AT 1333 MODAFF ROAD APT C8 NAPERVILLE, IL 60565-6173 Sheriff's Costs: Docketing 18.00 Service 12.42 Not Found 5.00 Surcharge 10.00 45.42 SO answers: R. Thomas Ktine Sheriff of Cumberland County STEVEN HOWELL 12/08/2003 Sworn and subscribed to before me this day of A.D. Prothonotary ..~ SHERIFF'S RETURN - CASE NO: 2003-06042 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NOT F O~k%? HUNTERS RIDGE HOMEOWNERS ASSOC VS PATEL KUNJAL K ET AL Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named DEFENDANT PATEL KUNDRA K unable to locate Her in his bailiwick. He therefore ,Sheriff or Deputy Sheriff, who being search and but was returns the COMPLAINT & NOTICE , NOT FOUND as to the within named DEFENDANT , PATEL KUNDRA K 1740 JOSIAH CHOWNING WAY NEW CUMBERLAND, PA 17070 DEFENDANT IS CURRENTLY LIVING AT 1333 MODAFF ROAD APT C8 NAPERVILLE, IL 60565-6173. Sheriff's Costs: Docketing 6.00 Service .00 Not Found '5.00 Surcharge 10.00 .00 21.00 SO answer~.;~ '_ ..........~ R. Thoma~'Kline Sheriff of Cumberland County STEVEN HOWELL 12/08/2003 Sworn and subscribed to before me this day of A.D. Prothonotary ~SHERIFF'S CASE NO: 2003-0604~' P COMMONTWEALTH OF PENNSYLV~NIA COUNTY OF CUMBERLAND RETURN - NOT FOI.~D HUNTERS RIDGE HOMEOWNERS ASSOC VS PATEL KUNJAL K ET AL Ro Thomas Kline duly sworn according to law, inquiry for the within named DEFENDANT PATEL KIRAN ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and unable to locate Him in his bailiwick. but was He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT PATEL KIRAN 1740 JOSIAH CHOWNING WAY NEW CUMBERLAND, PA 17070 DEFENDANT IS CURRENTLY LIVING AT 1333 MODAFF ROAD APT C8 NAPERVILLE, IL 60565-6173. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 .00 21.00 So answers: '' R. Thomas k~line Sheriff of Cumberland County STEVEN HOWELL 12/08/2003 Sworn and subscribed to before me this day of A.D. Prothonotary I ~Gwl~ E ~ I A L U S E S lA E log I A L S E New cumberland, PA 170,70 7003 0500 0001 6563 0242 APARTMENT C8 1333 MODAFF ROAD Attorney at Law 6q9 Bridge Street New Cumberland, PA 17070 7002 2410 0006 7111 0309 KUNJAL APARTMENT C8 0000 7002 2410 0006 7111 0163 KIRAN PATEL APARTMENT C8 1333 MODAFF ROAD U,S, POSTAL SERVICE CERTIFICATE OF MAILIN~ MAY BE USED FOR DOMESTIC AND iNTERNATIONAL MAIL, DOES N PROVIDE FOR INSURANCE-POSTMASTER Received From: PS Form 38~7, Mar. 1989 V.~, POSTAL S~.WCE C~'~i"iCATE OF MAILING' Received From: PS Form 38~, Mar. 1989 t ~[ / U,S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT d PROVIDE FOR INSURANCE--POSTMASTER ~ ~ )f '"'"~,.... c,,~,," /,~ Ilk/?~P~( ~...~.~ ~1, HUNTER'S RIDGE HOMEOWNERS' ASSOCIATION PLAINTIFF VS. KUNJAL K. PATEL, KUNDRA K. PATEL, AND KIRAN PATEL, DEFENDANTS 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ' NO. 03 - 6042 CIVIL TERM CIVIL ACTION - LAW PRAECIPE TO ENTER A DEFAULT JUDGMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter a default judgment against the Defendants Kunjal K. Patel, Kundra K. Patel and Kiran Patei for their failure to file any response to the Complaint. A Complaint was served on December 22, 2003. I HEREBY CERTIFY THAT a Notice of Intention to Take a Default Judgment was served on January 28, 2004 and filed January 29, 2004. I HEREBY CERTIFY THAT A COPY OF THIS NOTICE OF INTENTION TO TAKE A DEFAULT JUDGMENT WAS ALREADY FILED OF RECORD ON JANUARY 29, 2004 WITH THE PROTHONOTARY AS SHOWN ON THE ATTACHED TIME STAMPED COPY. No response having been filed or served, please enter a default judgment against the Defendants for $937.72 as shown below: Principal Due Plaintiff $418.12 (Unpaid Dues/Expenses) Legal Fees $502.50 (See Exhibit "A" of Complaint) Interest of $,15 Per Diem 11/18/03 $ 17.10 (114 Days 11/18/04 - 3/12/04) TOTAL DUE PLAINTIFF $937.72 As of 3/12/04 Plus Court Costs Respectfully submitted, J619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff Date: March 12, 2004 HUNTER'S RIDGE HOMEOWNERS' ASSOCIATION PLAINTIFF VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03 - 6042 CIVIL TERM KUNJAL K. PATEL, KUNDRA K. PATEL, AND K/RAN PATEL, DEFENDANTS CIVIL ACTION - LAW TO: KUNJAL PATEL APARTMENT C8 1333 MODAFF ROAD NAPERVILLE IL 60565-6173 KUNDRA PATEL APARTMENT C8 1333 MODAFF ROAD NAPERVILLE IL 60565-6173 KIRAN PATEL APARTMENT C8 1333 MODAFF ROAD NAPERVILLE IL 60565-6173 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE 1N 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. Cumberland County Bar Association Lawyer's Referral Service 2 Liberty Avenue Carlisle, PA 17013 Respectfully submitted, BY: /~~ .~ven Howell, Esquire ,~619 Bridge Street // New Cumberland, PA 17070 / (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff Date: January 28, 2004 Certificate of Service 1 hereby certify that on the date set forth below a tree and correct copy of the foregoing document was served upon all interested parties or counsel of record via postage prepaid, first class United States Mail addressed as follows: KUNJAL PATEL APARTMENT C8 1333 MODAFF ROAD NAPER¥ILLE IL 60565-6173 KUNDRA PATEL APARTMENT C8 1333 MODAFF ROAD NAPERVILLE IL 60565-6173 KIRAN PATEL APARTMENT C8 1333 MODAFF ROAD NAPERVILLE IL 60565-6173 Date: January 28, 2004 BY: J 619 Bridge Street a/ New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff U,S, POSTAL SERVICE CERTIFICATE OF MAILING MAY SE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR ~ ..................... S teven Howe~ Attorney At Law 619 Bridge Street New Cmnberland, PA 17070 PS Fo~ 3817, Janua~2001 AL SERV CE CERTIFICATE OF MAILING U.S. pOST ~ew C~erland, PA 17070 O.e pi~e of ordina~ mall a~res"d t°: U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOME$'~IC AND INTERNATIONAL MAIL, DOES NOT - -- Steven Howell PROVIDE FOR ir ~0c~lv.~ Ftc A~orney At Law 619 Bridge S~eet ~ New C~eAan& PA 17070 HUNTER'S RIDGE HOMEOWNERS' ASSOCIATION PLAINTIFF VS. KUNJAL K. PATEL, KUNDRA K. PATEL, AND KIRAN PATEL, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03 - 6042 CIVIL TERM CIVIL ACTION - LAW PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please satisfy as PAID IN FULL the judgment entered in this case against all the Defendants. BY:Respectfully .~,~ submitted, /,8~t~ven Howell, l~sc~ire J 619 Bridge,' Street / New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney fi)r Plaintiff Date: April 27, 2004