HomeMy WebLinkAbout08-0148f
RAY E. JACOBS
Plaintiff
V.
CRIDER EXCAVATING, INC. t/d/b/a
CRIDER'S EXCAVATING, INC.,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. DS ' ?'?S CIVIL TERM
CIVIL ACTION - LAW
PRAECIPE TO ENTER JUDGMENT
To Curtis R. Long, Prothonotary:
Kindly enter judgment in favor of the Plaintiff and against the Defendant on the attached
Notice of Judgment dated November 27, 2007, rendered following a District Justice hearing
before the Honorable Robert V. Manlove, and no timely Appeal having been filed.
IRWIN & McKNIGHT
Date: January , 2008
AV go
Dou s G. filler, Esquire
Supreme Court I.D. No. 83776
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
ttorney for Plaintiff
COMMONW9ALTH of PENNSYLVANIA NOTICE OF JUDGMENT/TRANSCRIPT
CniINTY OF- CUMBERLAND CIVIL CASE
N
r
PLAINTIFF: NAME and ADDRESS
rJACOBS, RAY s
3 iNSBATLAND DR
MECHANICSBVBG, PA 17050
L J
VS.
DEFENDANT: NAME and ADDRESS
rCRIDBR EXCAVATING INC/AIKA,CRIDBB'97
555 ' BOSLER AVE
LEMOYNE, PA 17043
L_ J
BAY E. JACOBS
3 WHEATLAND DR Docket No.: CV-0000380-07
MECHANICSBURG, PA 17050 Date Filed: 10/16/07
THIS IS TO NOTIFY YOU THAT:
,. Judgment: DEFAULT JUDGIKENT PLTF (Date of Judgment) 11/27/07
?i
Judgment was entered for: (Name) JACOBS, BAY 8
® Judgment was entered against: (Name) CRIDER EXCAVATING INC/AKA CRIDER- S
1 702 0
In the amount of $
F Defendants are jointly and severally liable.
Damages will be assessed on Date & Time
This case dismissed without` prejudice.
Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127
Portion of Judgment for physical damages arising out of
residential lease $
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 DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON PLEAS AND NO, FURTHER PROCESS MAY BE'ISSUED BY THE MAGISTERIAL DIS*t+rrtJb'fYGL-.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
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CERTIFICATE OF SERVICE
I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy
of the Praecipe to Enter Judgment upon the persons indicated below by first class United States
mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below:
Crider Excavating, inc.
555 Bosler Avenue
Lemoyne, PA 17043
Date: January ?, 2008 IRWIN & McKNIGHT
Y
Douglas G. iller, Esquire
Supreme Court I.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Attorney for Plaintiff
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RAY E. JACOBS,
Plaintiff
V.
CRIDER EXCAVATING, INC. t/d/b/a
CRIDER'S EXCAVATING, INC.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08 - 0148 CIVIL TERM
CIVIL ACTION - LAW
PLAINTIFF'S MOTION TO COMPEL
ANSWERS TO DISCOVERY
AND NOW, comes the Plaintiff, Ray E. Jacobs, by and through his attorneys, Irwin &
McKnight and files the following Motion:
1. On or about October 16, 2007, Plaintiff filed a District Justice Complaint,
initiating this action.
2. Judgment was entered for the Plaintiff on November 27, 2007.
3. On or about March 24, 2008, Plaintiff in this matter served upon the Defendant
Interrogatories and Request for Production of Documents in Aid of Execution. The
Interrogatories and Request for Production of Documents is attached hereto and incorporated
herein by reference as Exhibit "A".
4. Defendant did not respond the discovery requests attached hereto as Exhibits "A".
5. On or about May 5, 2008, counsel for Plaintiff wrote to Defendants requesting
responses to the outstanding discovery requests. A true and correct copy of the said
correspondence is attached hereto and incorporated herein as Exhibit "B."
6. To date, Defendants have not filed answers or objections to either the Request for
Production of Documents or the Interrogatories.
7. The information sought in these discovery requests is essential to the Plaintiff in
order to effectively move this matter forward.
8. Defendant's willful failure to respond in any manner to Plaintiffs discovery
warrants the entry of sanctions. Additionally, Plaintiff has incurred attorney's fees in the
preparation of this Motion and will incur additional fees for his legal counsel to attend a hearing
with regard to the within Motion.
WHEREFORE, Plaintiff Ray E. Jacobs respectfully requests that this Honorable Court:
a. Enter an Order directing that Defendant respond to the Request for Production of
Documents and Interrogatories or face additional sanctions under the
Pennsylvania Rules of Civil Procedure;
b. Compel Defendant to pay Plaintiff's reasonable attorney's fees relating to the
filing of this Motion to Compel; and
C. Any other relief this Court deems reasonable and just.
Respectfully submitted,
IRWIN & MCKNIGHT
Dou as G filler, Es ire
Supreme Court ID Number: 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, PA 17013
(717) 249-2353
Dated: May 30, 2008 Attorney for Plaintiff
2
EXHIBIT "A"
RAY E. JACOBS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 08 - 0148 CIVIL TERM
CRIDER EXCAVATING, INC. t/d/b/a :
CRIDER'S EXCAVATING, INC., : CIVIL ACTION - LAW
Defendant
INTERROGATORIES PROPOUNDED ON BEHALF OF PLAINTIFF TO DEFENDANT
AND REQUEST FOR PRODUCTION OF DOCUMENTS IN AID OF EXECUTION -
FIRST SET
TO: CRIDER EXCAVATING, INC. t/d/b/a
CRIDER'S EXCAVATING, INC.
555 BOSLER AVENUE
LEMOYNE, PA 17043
We are enclosing herewith Interrogatories propounded by Plaintiff to be answered by
Defendant, in writing, under oath, within thirty (30) days from the date of service hereof, with
the request that a copy of the answers be served upon counsel for Plaintiff, all in accordance with
Pennsylvania Rules of Civil Procedure 1930.5 and 4001 et seg. The Answers shall be inserted in
the space provided. If there is insufficient space to answer an interrogatory, the remainder of the
answer shall follow on a supplemental sheet clearly identified with reference to the questions
being answered.
These shall be deemed to be continuing interrogatories. If, you, or anyone acting in your
behalf, learn of any further information not contained in these answers, you shall promptly
furnish that information to the undersigned by supplemental answers.
For questions that request production of Documents, this request is made pursuant to
Pa.R. C. P. No.4009 and you are requested to produce a copy of the mentioned documents with
the understanding that the undersigned shall reimburse you for copying cost.
IRWIN & McKNIGHT
By: ??? )? JAL
Douglas . Mil er, Esquire
60 West Pomfret Street
Carlisle, PA 17013
(717) 249-2353
Attorney for Plaintiff,
Ray E. Jacobs
Date: March ?, 2008
2
DEFINITIONS
A. "Defendant" unless otherwise specified, shall mean the Defendant answering the
these discovery requests.
B. "Document" or "documents" means all writings of any kind, including, without
limitation, the originals and all non-identical copies, whether different from the originals be
reason of any notation made on such copies or otherwise including, without limitation,
correspondence, memoranda, notes, diaries, statistics, letters, telegrams, minutes, contracts,
reports, studies, checks, statements, receipts, returns, summaries, pamphlets, books, interoffice
and inter-office communications, notations of any conversations (including, without limitation,
telephone calls, meetings, and other communications), bulletins, printed matter, computer
printouts, teletypes, telefax, invoices, worksheets, graphic or oral records or representations of
any kind (including, without limitation, photographs, charts, graphs, microfiche, microfilm,
videotapes, recordings and motion pictures), electronic, mechanical or electric records or
representations of any kind (including, without limitation, tapes, cassettes, discs, recordings and
computer memories), and all drafts, alterations, modifications, changes and amendments of any
of the foregoing.
C. The word "communication" as used in the following Requests shall mean any
transmission of information by oral, written, pictorial or otherwise perceptible means, including, but
not limited to, telephone conversations, letters, telegrams, and personal conversations.
D. "Person" means both natural persons and non-natural persons, such as
corporations, partnerships, agencies, and any other legal entity.
E. As used herein, "corporation," "company," or "entity" shall mean any
corporation, partnership, sole proprietorship, company, entity, or business operation.
F. "Rely" means to use as a source of information in answering interrogatories.
G. "You" or "yours" means the Defendant and/or all corporations, partnerships,
companies, businesses, sole proprietorships, or other legal entities that Defendant owns or in
which it has a controlling interest, and any employee, agent, servant, or independent contractor
of Defendant.
H. "Indentify" or "identity" used in reference to an individual or person means to
state his full name, present business and private addresses and telephone numbers, his present or
alst known occupation, his employer, and employer's address. When used in reference to a
corporation, company, entity, or institution, it means to state its full name and present address
and telephone numbers, any fictitious names under which it operates, and the present owners,
officers and directors thereof with their current addresses. When use in reference to a document
or communication, it means to state the date, author, type of document or communication (e.g.
letter, memorandum, telegram, chart, etc.) or any other means of identifying it, its present
location, and the name and address of its custodian. If any such document or communication
was, but is no longer, in your possession or subject to your control, state what disposition was
made of it and who presently has possession of it.
INTERROGATORIES AND REQUESTS FOR DOCUMENTS
1. BUSINESS
A. State the full name, all business addresses for the past three (3) years and tax
identification number of Defendant:
B. Identify the stockholders, directors, and officer of the Defendant during each of
the past three (3) years:
C. Identify the number of shares of Defendant, the par value of shares held by each
stockholder, any restrictions on the transfer or shares, the market or repurchase
value of the shares held by each stockholder, all documents relating to the
purchase and ownership of stock in the corporation, and attach copies of all
documents relating to the incorporation of Defendant, any amendments thereto,
and any bylaws and stockholder agreements:
2
2. PERSONAL PROPERTY
If you own or have any interest or security in any equipment, inventory, goods,
motor vehicles, or any other tangible or intangible personal property, identify the
following:
A. A complete description of the personal property and type of interest held:
B. Date of Purchase:
C. Estimated present value:
D. Its present location:
E. Identify any personal property disposed of within the last three (3) years, its value
and whether you received compensation for its sale or disposal:
3
3. INCOME
A. State the gross taxable income for both Federal and State tax returns for the years
20072 2006, and 2005. Provide financial statements for the past three (3) years
documenting the nature and amount of income derived.
B. State your present average monthly income from all sources, and identify the
source.
4. Have you at any time with the past three (3) years received any income, dividends, or return
of capital from any corporation or other entity in which you have a ownership interest? If so,
identify each such corporation or entity and describe your interest therein.
4
Itemize all income benefits, cash and non-cash, not already included in your Answers to any
preceding Interrogatory, such as, but not limited to, income from commissions, annuities,
investments, bank interest, dividends, etc.
For each, please list the following:
A. Source of the benefit:
B. The basic terms and amounts:
C. Please furnish copies of any documents regarding the benefit.
6. As to each checking, savings or investment account maintained by you or in which you
have power of signature set forth:
A. The name and address of the banking or other financial institution:
B. The account number:
C. The name(s) under which the account is or was maintained:
D. The amount in the account presently.
5
7. As to any real estate in which you now have or have had an interest within the past three
(3) years, whether individually, jointly, or otherwise, set forth:
A. Its address:
B. Purchase price:
C. Name and address of grantor or grantors
D. If not presently owned, the date the property was sold, the purchaser, and the
amount received by virtue of the sale:
E. If presently owned, the name and address of present holders of encumbrances and
a description of and amount of each present encumbrance:
6
F. If presently owned, a list of all improvements made to the property, since date of
acquisition, giving date improvement was made, nature of improvement, and
costs thereof.
G. Whether any portion of purchase price is still due by way of note, bond,
mortgage, or in any other manner and the amount yet owed:
H. The estimated fair market value of each parcel of real property:
I. Whether you leased any real estate and the amount of rents received:
8. Does or has any corporation, partnership, joint venture, sole proprietorship, or other
entity referred to in preceding Interrogatories, or have you individually or with anyone
else, now hold or have held any interest in any real interest at any time during the past
three (3) years? (Interest in real property as used herein shall mean any interest,
equitable or legal, whether or not of record, whether or not expressed in writing, whether
contingent or vested, whether executory or not, and shall include any property interest
which may now be under agreement or option.)
7
9. If your Answer to the preceding Interrogatory is in the affirmative, state fully:
A. The name and address of the entity or individual(s) in whose name the property is
titled:
B. The address and legal description of the property:
C. The market value of the property:
D. The identity of any appraisal of the property, including the date thereof and the
identity of the appraiser:
10. Does or has any corporation, partnership, joint venture, sole proprietorship, or entity
referred to in the preceding Interrogatories, or have you individually or with anyone else,
leased or rented any property or part of such property to any person within the past three
(3) years? (Property shall be defined as previously noted.)
8
11. If your Answer is in the affirmative, state fully:
A. The name and address of the entity or individual(s) in whose name the property is
titled:
B. The address and legal description of the property:
C. The name and address of the lessee or tenant:
12. Have you, or has anyone on your behalf, conveyed or transferred any interest in any real
estate to anyone within the last five (5) years? If so, as to each conveyance or transfer
identify the description of the real estate, the interest conveyed or transferred, the identity
of the person to whom the interest was transferred, the consideration received, the reason
for the conveyance or transfer, and the fair market value of the interest.
13. Identify all bond and savings and loan association accounts, time deposits, certificates of
deposit, savings bonds, treasury notes, savings clubs, thrift plans, money market funds,
investment accounts and checking accounts in your name or in the name of any
corporation, partnership, joint venture, sole proprietorship, or other entity referred to in
the preceding Interrogatories.
9
14. For each item identified in Interrogatory 13, please state;
A. The location of the account or other item:
B. The account number or other identifying number:
C. The present balance therein or value of any other item:
D. Name and address of each co-owner or person authorized to draw on the account:
E. The identity of any custodian of a passbook, certificate, etc.:
15. Have you kept any other books, records or written memorandum of your income and
business affairs? If so, please identify and attach a copy to your answer.
10
16. Do you have any safe deposit box or other similar storage facility in your name (either
individually or jointly with another individual or entity), in the name of any entity in
which you have any ownership or other involvement, or in which you have contained
personal property with a value in excess of $100.00? If so, as to each such box or facility
identify the name of the institution in which you rent or maintain the safe deposit box or
facility, the number under which it is rented, the name under which such safe deposit box
or facility is rented, and the contents.
17. Identify any interest in any patent, patentable invention, copyright, copyrightable
material, or royalty, listing the type of property, nature of the interest, and dollar amount
or value of the interest.
18. Identify any uncollected debts, accounts receivable, or other monies due to you, listing
the identity of the debtors, the date that the debt was created, the remaining amount due,
the date the debt is due, and the terms of repayment. Please attach any document which
creates, evidences, or refers to the debt.
11
19. Identify any unsatisfied judgments of record in your favor in any action or any such
judgments pledged or promised to be assigned to you, listing the identity of the judgment
debtor, the location where the judgment is filed (including court caption, court term, and
number), the assignor of the interest, and the nature and status of the judgment as well as
any execution proceedings.
20. Identify any security interest in or lien upon any property, real or personal, listing the
description of the property, present owner of the property, nature of the security interest
or lien, amount of the security interest or lien, and the date when the interest was
acquired. Please attach any document which relates to the security interest or debt.
21. Identify any right, interest, financial advantage or prospect thereof under any contract,
insurance or other claim, cause of action, or pending lawsuit in any court, listing the
identity of the interest, the other party or parties involved, the known or estimated value,
and the nature and current status of the contract, claim, cause of action, or lawsuit.
12
22. Identify any title insurance, casualty insurance, collision insurance, life insurance, or
other insurance against loss or damage to property, listing the type of policy, the issuer,
the amount of coverage, and the real or personal property that is insured. Please attach
any document which creates, evidences, or refers to the insurance coverage.
23. Identify any interest in any other assets not already disclosed in previous Interrogatories
herein.
24. Identify any tangible or intangible interest in personal property greater than $100.00 that
you have sold, assigned, given, or traded to any person or entity within the last three (3)
years, specifically listing the type of property or interest, the identity of the person to
whom the property or interest was transferred, the date of transfer, the consideration
received for each transfer, the reason for each transfer, and the fair market value of the
interest at the time of your transfer.
13
25. Identify any federal, state, or local tax owed by you, listing the taxing authority, period
for which taxes are due, and the amount of taxes due.
26. Identify any federal, state, or local tax refund owed to you, listing the taxing authority,
period for which taxes are due to you, and the amount of the refund.
27. Identify any pending or threatened suits, actions, legal proceedings, or claims of any kind
against you, listing the type of pending or threatened proceeding, the name of the other
party or claimant, the nature of the pending or threatened proceeding, the known or
estimated value of the claim, and the current status of the suit, action, proceeding, or
claim.
14
28. Other than the judgment in this case, identify any judgments on record against you or any
company or entity in which you have an interest, listing the name of the suit, action, or
legal proceeding (including the title, court caption, court term, and number), the amount
of the judgment, date in which the judgment was entered, the name of the individual or
entity in whose favor the judgment exists, and whether any payment have been made on
account thereof, either by you or by any third party, person, or entity for you.
29. Identify any other liabilities or obligations not already disclosed.
Respectfully submitted,
IRWIN & McKNIGHT
Douglas .Miller, AEsuquirce
Supreme Court I.D. # 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, PA 17013-3222
(717) 249-2353
Attorney for Plaintiff
15
VERIFICATION
I, the undersigned, hereby verify that the statements made herein are true and correct to
the best of my knowledge, information and belief. I understand that false statements herein
made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification
to authorities.
By:
Date:
A true and correct copy of the within Answers was served to Douglas G. Miller,
Esquire Irwin & McKnight 60 West Pomfret Street Carlisle Pennsylvania 17013 this
day of 52008.
By:
EXHIBIT "B"
LAW OFFICES
IRWIN & McKNIGHT
WEST POMFRET PROFESSIONAL BUILDING
60 WEST POMFRET STREET
ROGER B. IRWIN CARLISLE, PENNSYLVANIA 17013-3222
MARCUS A. McKNIGHT. III
DOUGLAS G. MILLER (717) 249-2353
STEPHEN L. BLOOM FAX (717) 249-6354
MATFHEWA. McKNIGHT WWW,IRWINMCKNIGHT.COM
May 5, 2008
CRIDER EXCAVATING, INC.
555 BOSLER AVENUE
LEMOYNE, PA 17043
HAROLD S. IRWIN (1925-1977)
HAROLD S. IRWIN, JR. (1954-1986)
IRWIN, IRWIN & IRWIN (1956-1986)
IRWIN, IRWIN & MCKNIGHT (1986-1994)
IRWIN, MckVIGHT & HUGHES (1994-2003)
IRWIN & McKNIGHT (2103- )
RE: RAY E. JACOBS v. CRIDER EXCAVATING, INC. t/d/b/a CRIDER'S
EXCAVATING, INC.
DOCKET NO.: 08-0148
Dear Sir or Madam:
We have not received any response or Answers to the Interrogatories forwarded to you on
March 24, 2008. The purpose of this letter is to advise that if we do not receive a response by
Friday, May 9, 2008, we will be proceeding with further legal action against you for failure to
respond to the Interrogatories which may include penalties imposed by the Court as well as
reimbursement of all attorney fees incurred in our collection efforts.
I look forward to receiving your responses. Thank you for your prompt attention to this
matter.
Very truly yours,
IRWIN & McKNIGHT
Douglas G. Miller
DGM:tds
cc: Ray Jacobs
CERTIFICATE OF SERVICE
I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy
of the Praecipe to Enter Judgment upon the persons indicated below by first class United States
mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below:
Crider Excavating, Inc.
555 Bosler Avenue
Lemoyne, PA 17043
Date: June 2, 2008 IRWIN & McKNIGHT
Douglas Miller, Esquire
Supreme Court I.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Attorney for Plaintiff
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'JUN 0 s 2000,
RAY E. JACOBS9 . IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 08 - 0148 CIVIL TERM
CRIDER EXCAVATING, INC. t/d/b/a :
CRIDER'S EXCAVATING, INC., : CIVIL ACTION - LAW
Defendant
ORDER
AND NOW, this 41' day of -Tv-.- , 2008, upon
consideration of the foregoing Motion to Compel Answers to Plaintiff's requests for discovery, it
is hereby ordered and directed that the Defendants comply with the Plaintiff's Motion and
provide answer to said discovery requests within 30 days of this Order, or be subject to
sanctions as provided in the Pennsylvania Rules of Civil Procedure.
BY THE COURT:
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RAY E. JACOBS,
Plaintiff
V.
CRIDER EXCAVATING, INC. t/d/b/a
CRIDER'S EXCAVATING, INC.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08 - 0148 CIVIL TERM
CIVIL ACTION - LAW
MOTION TO MAKE RULE ABSOLUTE
AND NOW comes the Plaintiff, Ray E. Jacobs, by and through his attorney, Douglas G.
Miller Esquire, of the law firm of Irwin & McKnight, and respectfully requests this Honorable
Court make absolute the Rule to Show Cause and in support thereof avers as follows:
1. On June 4, 2008, the Honorable Kevin A. Hess signed a Rule to Show Cause in
this case, said Rule returnable 30 days from service upon the parties.
2. The Rule was served upon the Defendant, Crider Excavating, Inc. t/d/b/a Crider's
Excavating, Inc. on or about June 9, 2008 at 555 Bosler Avenue, Lemoyne, PA
17043. Said mail was not returned and no forwarding address was provided to
the undersigned.
3. There is no attorney of record for the Defendant.
4. No objection to Plaintiff's Motion to Compel Answers to Discovery have been
made.
5. Defendants were required to show cause, if any, by July 4, 2008.
6. To date, no response to the Rule to Show Cause has been filed by the Defendant.
2
WHEREFORE, Petitioner moves that this Honorable Court make the Rule Absolute and
grant the requested relief contained in the Petition.
Respectfully submitted,
IRWIN & MCKNIGHT 'A-z' Dated: August 7, 2008 0--,
A?L -
Douglas Miller, Esquire
Supreme Court I.D. 83776
60 West Pomfret Street
Carlisle, PA 17013
(717) 249-2353
3
CERTIFICATE OF SERVICE
I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy
of the Praecipe to Enter Judgment upon the persons indicated below by first class United States
mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below:
Crider Excavating, Inc.
555 Bosler Avenue
Lemoyne, PA 17043
Date: August 7, 2008 IRWIN & McKNIGHT
i Azn?
Douglas G. ' er, Esquire
Supreme Court I.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Attorney for Plaintiff
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AUG 0 B 2008/n
v?
RAY E. JACOBS, IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 08 - 0148 CIVIL TERM
CRIDER EXCAVATING, INC. t/d/b/a :
CRIDER'S EXCAVATING, INC., : CIVIL ACTION - LAW
Defendant ,
ORDER OF COURT
AND NOW, this / day of August, 2008, upon consideration of the Plaintiff's
Petition to Make Rule Absolute, it is hereby Ordered and Decreed that the Rule issued June 4,
2008, is hereby made absolute and the following relief requested is hereby ordered:
a. Defendant is ordered to produce all documents requested in Plaintiff's Request for
Production of Documents in Aid of Execution;
b. Defendant is ordered to answer all Interrogatories set forth in Plaintiff's
Interrogatories in Aid of Execution;
C. Defen ant is ordered to pay Plaintiff' asonable attorney's ees r d to
filin of th of on to in el ' the o of $ 00 0 w' in 30 days of
da of 's Order.
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