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HomeMy WebLinkAbout08-2790I COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL FROM 411361, DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. 0 $_ d- 71.0 etk; <<'r` 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 Dis- trict Justice on the date and in the case mentioned below. NAME OF APPELLANT n MAG. DIST. NO. OR NAME OF D.J. ADDRESS OF APPELLANT CITY STATE ZIP CODE /(to KEto Btti r, rl'4_ ucFV ( th14CF6kr- 11014 / (??/,/ 14- 3-0e IN 1 Ht cASt OF (YLAnV JIFF) w? --( (LEstc)k4r( OW, CLAIM NO. CV YEAR 0000004-040 LT YEAR This block will be signed ONLY when this notation is required under PA. R.C.P.J.P. No. 1008B. This notice of Appeal, when received by the District Justice, will operate as A SUPERSEDEAS to the Judgment for possession in this case. OF APPELLANT OR HLIVATTORNEY OR AGFNT --'A' M CS _ W" ?4 B i44 >ES If appellant was Claimant (see PA R.C.P.J.P. No. 1001(6)) in action before district Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. ogna re o roor ve" I 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 (Common Pleas No. Name of appellee(s) appellee(s), to file a complaint in this appeal within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or his attorney or agent RULE: To , appellee(s) Name of appellees) (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 UPON PRAECIPE. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: Year Signature of Prothonotary or Deputy White - Prothonotary Copy Green - Court File Copy Yellow - Appellant's Copy Pink - Appellee Copy Gold - D. J. Copy Proth. - 76 PROOFOF NICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filling the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; ss AFFIDAVIT: I hereby swear or affirm that I served ? a copy of the Notice of Appeal, Common Pleas No. , upon the District Justice designated therein on (date of service) , year 0 by personal service Qby (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name , on year _, ri by personal service [:] by (certified) (registered) mail, sender's receipt attached hereto. and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appeUee(s) to whom the Rule was addressed on , year , [] by personal service [:]by (certified) (registered) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF , YEAR Signature of Afliant C cN-? Q Signature of official before whom al idavit was made ; -Tj ?v ni nil I-''i're 1-. .- r^- Title of official fit. My commission expires on year rv -o W _ Iv? " COMMONWEALTH. OF PENNSYLVANIA COUNTY ciF<'G1113*RLAM Meg. Dom. No.: 09-1-OZ MW Name: Nw. ROJMT -v. •><ii3JMOn fd 1901 BTATZ BT cam SILL, PA Tee. (717) 761-0583 17011=0008 MWIM 1 MWTORATI00T am =c 140 =W.. =ITAM BLV. CKLLPONT,. PA 18410 ..NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE I'i AINTIFF: ' NAME and ADDRESS Ain L MYORATION savc INC 140 Balf1 Iml'TA BLV CRALM% Rr, . P7! 18914 L J VS. DEFENDANT: NAM and ADDRESS rD>OPSm B&TTY >f[ 1 , 530 Ham. AVZ LMINOT», PA 17043 L J Docket No.: CV-0000004-08 Date Filed: 1/10/08 Rama THIS IS TO NOTIFY YOU THAT. oil ` "` Judgment: P D -(Date of Judgment) 4/03/08 Judgment was entered for (Name) UNP=), BST >H? Judgment was entered against: (Name) = 1 Y><STOB??Ion . mtvc me in the amount of $ • 0 Defendants are jointly and severally liable. Damages will be assessed on Date & Time ? This case dismissed without prejudice. . D Amount of Judgment Subject to Attachmentt42 Pa.C.S. § 8127 0 Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ .00 Judgment Costs $. oil Interest on.Judgment $ Attorney Fees $ Total $ .00 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY RUNG A NOTICE OF APPEAL WITH THE PROTHONOTARYICLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMEN rITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. . EXCEPT AS OTHERWISE PROVIDED N 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 DISTRICT JUDGE _ . UNLESS THE JUDGMENT IS ENTERED N THE COURT OF COMMON PLEAS, ANYONE WrETISTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE F THE JUDGMENT SETTLES, OR OTHERWISE COMPLIES wnw THE JUDGMENT. s APR 0.7 2008 I PdWtbat this Is a Date My commission expires first Monday-of January, 2012 AOPC 315-07 vm , Magisterial District Judge .1 Qgv",JLv the proceedings containing the judgment. , Magisterial District Judge SEAL m?TZ PREM >m: 4/03/08 2:05 oo Pu U.S. Postal Service, U.S. Posta ca ? (Domestic Only; No Insurance Coverage Provided) M1 (Domestic Coverage Provided) .o For delivery information visit our website at www.usps-corno m .D N Postage $ Co Postage $ 0 Certified Fee ° Certified Fee O Return Receipt Fee Postmark (Endorsement Required) Here ° ° Return Receipt Fee Postmark (Endorsement Required) Here ° O Restricted Delivery Fee (Endorsement Required) O ° Restricted Delivery Fee (Endorsement Required) U"1 rij Total Postage & Fees S r"u Total Postage & Fees $ . ° Sent To cJe?GE rtA6r xr V, t4 c art= ti T=- --------------- .A Sent To E 1ty ° N ---- ------ -- Street, Apt No.; °' - - --- -------•---•----- or PO Box No. ^ ?i0 S rArE sr• i r -- p r - Street, Apt No.; or PO Box No. 14Vt4AVA CL---; t/t ----- -- - --° -- ••°° --------- -- --- ------ - ----------- - - ^° °-- ° -• - ° ° °° ° ° ^ City State. Z/P Gacuo ??? /?4r?a ? City State, Z/P+4 AektaYuE PA ('(o1-f3 Pft" OF WIN OP 110 110E AP L AND RUCK TO ft& i rr (This proof of service MUST BE FNM WITHN TEN 0 0) DAYS AFTER ffffr ig the rfoltbe d 4*" Cho* 00f I I b'd boon) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ss AFFIDAVIT: I hereby swear or affirm that I served a copy of the Notice of Appeal, Common Pleas No. © p -" 02 7 ?Q C W1 t. 7 rAK the Dlie W nO domed therein on (dated service) 1/" 3 o yW.A-009 by personal swvios toss (revered) mom, sender's receipt attached hereto, and upon the sppedee, (name VIM W on --kit fry . . q^ 3() year -2-06 P. 0 by personal service by (certified) (MOdered) MIA. sender's TraNpt attadred hereto. 0 and further that I served the Rule to File a complaint accompanying the above Notice of Appeal upon the 'v whom the Rule was addressed on , year , 0 by personal servbe Ejbyy *srti6ed) (raooereid) mail, sender's receipt attached hereto. SWORN (AFFIPMED) AND StIBSCRISED BEFORE ME p. THIS 55yy? DAY OF 71 a-v- YEAR JLW o . ddaatd w•am aNNlavAt was erterA•J dAAI•nt Tins of o" r r My commission eipires on _6JLA r.a a? -a 3 N ,f: ca f COMMONWEALTH Q'PENNSYLVANIA COURT OF COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL FROM ?? . DISTRICT JUSTICE JUDGMENT 7- COMMON PLEAS No. C-1 - ? / ` e( e (,"" I 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 Dis- trict Justice on the date and in the case mentioned below. NAME OF APPELLANT ' MAG. DIST. NO. OR NAME OF D.J. /_Y1 ?4."_ I g ;I_D A4-T'I ca K. ? ?t21/I c t ? 4-wC. • I 0 ?-- / - 6>.?_ ADDRESS OF APPELLANT CITY STATE ZIP CODE DATE OF JUDGMENT IN THE CASE OF (PLAINTIFF) (DEFENDANT) _ a /'?e VK - ( (E (,)&AT't 0W, VS. TT IM ' 1 C r l q- ow /? CLAIM NO. l „? ?Q Q ® f , O r SIGNATURE OF APPELLANT OR TTORNEY OR AGENT CV YEAR LT YEAR -Il4'liY) ? al. This block will be signed ONLY when this notation is required under PA. R.C.P.J.P. No. 1008B. If appellant was Claimant (see PA R.C.P.J.P. . This notice of Appeal, when received by the District Justice, will operate as No. 1001(6)) in action before district Justice, he A SUPERSEDEAS to the Judgment for possession in this case. MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. A 0 ono or uwur/ _J PRAECIP TO EIN-R RULE TO FILE COMKAINT AWD, 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 , appellee(s), to file a complaint in this appeal Name of appellee(s) (Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or his attorney or agent RULE: To Name of appellee(s) appellee(s) (1) You are notiftd that a"rulo is geroby e1t®rg0;upon you to file a complaint in this appeal within twenty(20) days after the dote of seflifc? of this,rule i4myap b# 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 UPON PRAECIPE. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: Year Signature of Prothonotary or Deputy White - Prothonotary Copy Green - Court File Copy Yellow - Appelant's Copy Pink - Appellee Copy Gold - D. J. Copy Proth. - 76 Track & Confirm Search Results Label Receipt Number. 7006 2150 0000 7638 6788 Home I H@ID I Sfan In Track & Confirm FAQs Status: Delivered Track & Confirm Your item was delivered at 12:26 PM on May 2, 2008 in CAMP HILL, PA Enter Label/Receipt Number. 17011. 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Redder d DsAvery9 P5drw Feel O yes 70062150 0000 7638 6771 PS Form 3811, February 2004 orafnnec Ream Reoslryc tam 02 M teat C c- C= d as E:- 24 w ABRAHAM LAW OFFICES 45 East Main Street, Hummelstown, PA 17036 (717) 566-9380 MARK-1 RESTORATION SERVICE, INC.: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY. PENNA. V. : NO. 08 - 2790 CIVIL TERM BETTY M. UMPHED : CIVIL ACTION - LAW Defendant 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 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 the 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Court Administrator 4d' Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 MARK-1 RESTORATION SERVICE, INC.: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNA. V. : NO. 08 - 2790 CIVIL TERM BETTY M. UMPHED : CIVIL ACTION - LAW Defendant COMPLAINT AND NOW, comes Plaintiff, Mark-1 Restoration Service, Inc., by and through its attorney, James W. Abraham, Abraham Law Offices, Hummelstown, Pennsylvania, and files the following: 1. Plaintiff, Mark-1 Restoration Service, Inc., is a New Jersey corporation in good standing, with offices in Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, Betty M. Umphed, is an adult individual who currently resides at 530 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania. 3. Plaintiff is in the business of providing restorative construction services to properties damaged by fire, flood or by other similar means. 4. In November and December of 2006, Plaintiff provided restoration services to Defendant at Defendant's property, located at 530 Hummel Avenue, Lemoyne, Pennsylvania (hereinafter "the Property") as the Property was damaged from a vehicle accident in which a vehicle struck and damaged the porch area of the Property. 5. The Property was insured at the time for the aforesaid damage through Defendant's insurance carrier, Donegal Insurance Company (hereinafter "Donegal") 6. At all relevant times hereto, Donegal was acting in the capacity of the authorized agent of Defendant pursuant to the insurance policy terms and conditions which provided insurance coverage for the damage to the Property. 7. Plaintiff provided Donegal and therefore Defendant, with three (3) estimates for the restoration services for the damage to the Property, including but not limited to, emergency services and repairs, which totaled $4,424.14. A true and correct copy of the summary, "re-cap" pages of each estimate are attached hereto as Exhibit "A". 8. Subsequently, Plaintiff credited Defendant for items which could not be repaired during the cold weather and the final amount due for the restoration services performed was reduced to $3,829.38. 9. On December 12, 2006, Plaintiff provided Donegal a revised estimated amount for the restoration services actually performed in the amount of $3,829.38, and provided a copy of said estimate as well to Defendant, which amount was approved by Donegal and therefore by Defendant; and Donegal issued an insurance check to Defendant, dated June 18, 2007, which check covered the restoration services provided by Plaintiff, in the amount of $3,738.87. A true and correct copy of the Donegal insurance check is attached hereto as Exhibit B". 10. Despite the fact that Defendant received the aforesaid Donegal insurance check for payment of the restoration services provided by Plaintiff, Defendant has refused to submit payment to Plaintiff for the services rendered. 11. At all relevant times hereto, Plaintiff was in complete compliance with any and all agreements for the services provided to Defendant and performed all services in a proper and workmanlike manner in accordance with industry standards. 12. Defendant is in material breach of the agreement for the services provided by Plaintiff in accordance with the aforesaid estimate and credits, as Plaintiff restored the Property, however, Defendant has refused to pay Plaintiff for its restoration services, despite the fact that Donegal issued the aforesaid insurance check to Defendant for payment to Plaintiff for the amount due and/or for the majority of the amount due, less Defendant's deductible, which according to Defendant's insurance policy, is Defendant's responsibility to pay. 13. Plaintiff submits that Defendant's refusal to submit the insurance proceeds to Plaintiff is without merit and constitutes an intentional and deliberate act on the part of Defendant to deprive Plaintiff of the insurance proceeds; and Defendant's blatant and unjustified refusal to release the insurance proceeds to Plaintiff entitles Plaintiff to sanctions and/or damages in the form of payment of Plaintiff's attorney fees which Plaintiff is forced to incur by continuing the litigation against Defendant in order to recover the amount(s) owed to Plaintiff by Defendant. WHEREFORE, Plaintiff respectfully requests Your Honorable Court to enter judgment in favor of Plaintiff and against Defendant in the amount of $3,829.38, plus continuing interest, plus attorney fees in the amount of Two Thousand Five Hundred ($2,500.00) Dollars, which fees are continuing, as well as any other relief the Court may deem proper. Respectfully submitted: -'s - James W. Abraham, Esq. Abraham Law Offices 45 East Main Street Hummelstown, PA 17036 (717) 566-9380 Attorney for Plaintiff, Mark-I Restoration Service, Inc. DATE: 5/19/08 VERIFICATION I, Patrick Lister, on behalf of Mark-1 Restoration Service, Inc., the undersigned, hereby verify and confirm that I have reviewed the foregoing document and the statements made therein are true and correct to the best of my knowledge, information and belief. I further understand that any false statements made herein are subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unworn falsification to authorities. DATE: wmk?5--- Patrick Lister Mark-1 Restoration Service, Inc. I IT «??? '-Marlf RESTORATION SERVICE, ionsts in Reconstruction & Cleaning - Property Loss Estimating 7921 Dyson Road, Harrisburg, PA 17111 717-561-1255 Fax 717-561-1277 ????????? ?? COLLISION $0.00 bmrcd: Betty U Home: (717) 763-9675 Property 530 Humm 1 Ave Lomonye, A 17043 Claim Rep.: Kris H Business: (717) 656-6422 Business: PO Box 43 Lwla, PA 7540-0435 Estimator. Bob Blacki 11 Business: (717) 561-1255 Business: 7921 Rd Hwrisburf, PA. I71 I i Company. Larry Business: (717) 426-1931 Business: 1195 River Mattietta, P 17547 Company: Marls 1, Inc Business: (717) 561-1255 Business: 7921 Grar Da Rd Hwrisbu% PA 17111 Date of Loss: 0927/06 Date Received: 09/27/06 Date Inspected: 0927/06 ` - Date EMrcd: 10/02/06 Price List: P with Service Charges F In Estimate: 2006-I 843 Estimate for repairs A: T k? rtW 4 (-E 3 .2.2 q 109 Lafayette Street 1 New Britaln Blvd. 8 Bartles Comer Road, Suite 103 laverside, NJ 08075 halfont, PA 18914 Menftton, NJ 08822 856/7649700 267-695-1100 908/806,4103 _- Mark 1 tors ' Service, Inc. 7921 Gray Rd Harrisburg P 17111 717-561-125 717-561-12 Fax O&P Items I Too DeRm % GENERAL DEMOLITION 3126$ 10.63% FLOOR COVERING - CARP 24336 7.61% FLOOR COVERING - 82.32 2m% PERMITS AND FEES 225.0f 6.98`/. FRAM04G & ROUGH Y 3S8.S6 11.13% MASONRY 1,066.90 33.07/. PAIlVTING 7 249.06 7.73% SOFFIT, FASCIA, & 74.56 231% WINDOWS-WOOD 19.88 6.61% SabloW 2,663.28 82.63'X. MahrW Sales Tax @ 6.000% 22.55 0.70% Ova @ 10.00% 268.58 833% Profit @_ 10.00'16 _ 268.58 8.33Y. 2006-10-02-0843 1 1 10/09/2006 Page: 6 RESTORATION SERVICE, NC in Reconsfrucilon do Cleaning • Property Loss Esfimafing Grayson Road, Harrisburg, PA 17111 717-561-1255 Fax 717-561-1277 ????????? COLLISION s o-.00 Instued: Betty U he&2 Home: (717) 763-9675 Property: 530 H Ave I emor? PA 17043 Claim Rep.: Kris Business: (717) 656-6422 Business: PO Boa 4 5 Leola, PA 17540-043 Estimator. Bob B b Busimeas: (717) 561-1255 Business: 7921 Rd PA 17111 Cam: Larry Gro Bush ms: (717) 426-1931 Business: 1193 Rd MarW P 17.547 Company Mark I Alm 'ces Inc Bushes: (717) 561-1255 Business: 7921 Rd Hanris* . A 17111 I Dace of Loss: 09/.27/06 Date Receive& 0927/06 Dace Inspected: 09/27/06 Dace 1 MMIed' lOMM Price List: P 1 with Service Charges F in Fie: 2006-10-02 3 2 Cement estim ate for sd' va1 oZ (? o SST ?? ('rM ? SF, 0 2 109 Lafayette Street 140 New Britain Blvd. 8 Barttes Corner Road, Suite 103 Riverside, NJ 08075 C t, PA 18914 Hwftton, NJ 08822 ^^ 856/764-9700 67.695-1100 CM Al I(Mu RJ;5 nAA_n, M E--. Mark 1 ratios Service, Inc. R Gmys?x MA 17111 Rd 2 5 717-561-12, Fax O&P Itms Total DWbrs % AUSONRY "IAS 8333% SobloW 661.611 8333`G Overhead @ 10.00% 66.17 8.331/c profit a 10.00% 66.17 8311% 200640-02-0843-2 1 I M2006 Page. 5 4 r I ionsts in Reconstruction & Cleaning Property Loss Esfima ong RESTORATION SERVICE, NC. 7 1 Grayson Road, Harrisburg, PA 17111 717-561-1255 Fax 717-561-1277 2???7?'!7? COLLISION Home: (717) 763-%75 Insured: Betty 7,77043' Property: 530 H I APA Claim Rap.: Kris Business: (717) 656-6422 Business: PO Box 4 5 Loma, PA 17544-043 Estimator: Bob B ell Business: (717) 561-1255 Business: 7921 Rd PA 17111 Company: Larry GrO Business: (717) 426-1931 Business: 1195 Riv Rd Marietta, 17547 Company: Mar1c I Inc Business: (717) 561-1255 Business: 792, Rd PA 17111 $0.00 Date of Loss: 09/27/06 Date Received: 09/27106 Date Inspected: 09r27/06 Date Entared: IOWM Price List: P Rasoorsrti I with Service Cis F F FsGonr ate: 2006-10-02 O for euwmwv service I Z" •?s Tf m Arz 4 tf 4 7, ! 3 109 Lafavette Street Riverside, W 08075 856/7649700 A..A%AnAA-airu c^ v 140 New Britain Blvd. 8 kdes Corner Road, Sulte 103 Chalfont, PA 18914 Flemington, NJ 08822 267-695-1100 908/8064103 radio Service, Mark 1 *Coto Non-O P ItEsms 7921 G Rd A1711i 71?-561-i SS 717-561-? Fax TOW Dollars % 2006-10-02-0843-EMG I I 10/0712006 Page: 5 IIBMI `? l111IRY/dK M f Macim munjou. Ili CO. ' DONEG4L ?rx 24 ad= Folk ,arum n"Lum }?;, 3,r=a.a7 w,?e••?? art w.aga. ' ? sarrx a Lipp a-? ? .,rjrwx ." t .?DOOi98L9O?? rO1.330i6Oi?: Ui4•0?9L?" ?00043T38$4,? i r M30?8?, ? _ ??? BAFIK AALT?? 1'?1 ? ? 56 XIM3 am 4 0 CA GK 2 CDoeatlon 140791 t 19s Z $38.87 sJ UMPH BE 4330160 20070838298001 OMM Camtrd - t Prinrod MM ACCORD IMAX AGUM ConW Pik! 1 CERTIFICATE OF SERVICE I, James W. Abraham, Esquire, the undersigned, hereby certify that I have served a true and correct copy of the foregoing document by first class mail upon the following persons at the following address on the date stated below: Betty M. Umphed 530 Hummel Avenue Lemoyne, PA 17043 DATE: 5/19/08 James W. Abraham, Esq. c s? ,' Johnson, Duffle, Stewart & Weidner By: Edmund G. Myers I.D. No. 20558 Attorneys for Defendant 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 MARK-1 RESTORATION SERVICE, INC., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V. NO. 08-2790 BETTY M. UMPHED, CIVIL ACTION - LAW Defendant PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter the appearance of the undersigned on behalf of Defendant, Betty J. Umphred, in the above-captioned matter. JOHNSON, DUFFIE, STEWART & WEIDNER BY: b Edmund G. Myer Date: June 12, 2008 335590 K'7 ? t"' ? ?t: ?' ?-- -?er? _ -? T°: ?. ??--' ?- N a? -- " t "? ?'"'? C.J'3 G Johnson, Duffle, Stewart & Weidner By: Edmund G. Myers I.D. No. 20558 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 MARK-I RESTORATION SERVICE, INC., Plaintiff V. BETTY M. UMPHED, Defendant ACCEPTANCE OF SERVICE CIVIL ACTION - LAW The undersigned hereby accepts service of the Complaint as of June 11, 2008, on behalf of the Defendant, Betty J. Umphred (identified as "Umphed" in the Complaint). JOHNSON, DUFFIE, STEWART & WEIDNER BY: ?LA'b?j' Edmund G. Mye s Date: June 12, 2008 Attorneys for Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, : PENNSYLVANIA NO. 08-2790 :335589 ? C>? .. ? cs? ,..a ? ? ? ?? ?a : -c?? .-? r? ry S ??F??? Yjry ? Y _ r? (~l {??? r .. _, ?I^.. S ? . _ i? F _" r? ?'? ???? ? ?? ? ??? ? . ABRAHAM LAW OFFICES 45 East Main Street, Hummelstown, PA 17036 (717) 566-9380 MARK-1 RESTORATION SERVICE,, INC.: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNA. V. BETTY M. UMPHRED Defendant : NO. 08 - 2790 CIVIL TERM : CIVIL ACTION - LAW PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY: Please mark the above-captioned action settled, discontinued and terminated. Respectfully submitted: James W. Abraham, Esquire Abraham Law Offices 45 East Main Street Hummelstown, PA 17036 Attorney for Plaintiff, Mark-1 Restoration Service, Inc. Respectfully submitted: Z"Jtg? Edmund G. Myers, Esquire Johnson Duffie 301 Market Street PO Box 109 Lemoyne, PA 17043 Attorney for Defendant, Betty M. Umphred DATE: 42--70 - OP DATE: /24n1w 7i