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HomeMy WebLinkAbout08-41850 LAW OFFICES OF : IN THE COURT OF COMMON PLEAS OF PETER J. RUSSO, P.C. : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. DOCKET NO.2008- q 'S c Zvi l ftr"- DAVID BURKEY Defendant CIVIL PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Please enter a Judgment against Defendant, David Burkey, and in favor of Plaintiff, Law Offices of Peter J. Russo, P.C., in the amount of $2,181.56. Respectfully submitted, Elizabeth J. Saylor, Esquire q Law Offices of Peter J. Russo, P.C. Date: 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 591-1755 COMMONWEALTH OF PEN VANIA rni INTV C7F• CHI Mag. Dist. No.: 09-3-04 MDJ Name: Hon. THOMAS A. PLACEY Address: 104 S SPORTING HILL RD MECHANICSBURG, PA Telephone: (717 ) 761-8230 17050 NOTICE JUDGMENT/TRANSCRIPT IVIL CASE PLAINTIFF: NAME and ADDRESS rLAW OFFICES OF PETER J. RUSSO 5006 E. TRINDLE RD. APT/STE 100 MECHANICSBURG, PA 17050 L J VS. DEFENDANT: NAME and ADDRESS rBDSI:EY, DAVID 8 W. PINE ST. ENOLA, PA 17025 L J LAW OFFICES OF PETER J. RUSSO 5006 E. TRINDLE RD. APT/STE 100 Docket No.: CV-0000120-08 MECHANICSBURG, PA 17050 Date Filed: 2/20/08 THIS IS TO NOTIFY YOU THAT: Judgment: OR PLAZATIF;F 5/27/08 (Date of Judgment) _ .. , Judgment was entered for: (Name) LAW OFFICES OF PETER J. RUSSO ® Judgment was entered against: (Name) BUREEY, DAVID in the amount of $ 2.181.5 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 $ Amount of Judgment $ 1,687.14 Judgment Costs $ 89.56 Interest on Judgment $- 0452 Attorney Fees $ .00 Total $ 2,181.56 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 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 TQENTER T E,JUDGMENT4WTHE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME ;PROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE'MAGISTERIAL DISTRICT JUDGE,. 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. 'CPS Date I certify that this is a 'all 1-(]/% Date My commission expires first Monday of January, 2010 Magisterial District Judge containing the judgment. , Magisterial District Judge SEAL AOPC 315-07 DATE PRINTED: 5/27/08 1:39:00 PM () rv ° o t3 .?,.? ? 00 ? ? t? :? a- ` = ? ? - cy ? 1. ?` „? ? ? N `?'] ?? 7-k? ?? 1 IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Law Offices of Peter J. Russo, P.C. ( ) Confessed Judgment (X) Other File No. OK- 1 CIv? V. Amount Due $2,181.56 David Burkey Atty's Comm. Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) All property including but not limited to furniture, desks, computers, televisions printer, cash which is located at 8 W. Pine Street, Enola, PA 17025. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of N/A County, for debt, interest and costs, as above, directing attachment against the above-names garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list) V And all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. Date: 4(.1 dg Signature: Print Name: lizabeth J. Say or, squire Address: 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: 717-591-1755 Supreme Court ID No. 200139 .? vlj N C?1 C l/? O 1 v p ?' . ? CZ ?t C ?? ? ? was WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-4185 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LAW OFFICES OF PETER J. RUSSO, P.C. Plaintiff (s) From DAVID BURKEY, 8 W. PINE STREET, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PROPERTY INCLUDING BUT NOT LIMITED TO FURNITURE, DESKS, COMPUTERS, TELEVISIONS, PRINTER, CASH WHICH IS LOCATED AT 8 W. PINE STREET, ENOLA, PA 17025. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$2181.56 L.L.$.50 Interest Atty's Comm % Due Prothy $2.00 Atty Paid $53.75 Other Costs Plaintiff Paid Date: JULY 14, 2008 (Seal) C R. Long, P no By: Deputy REQUESTING PARTY: Name ELIZABETH J. SAYLOR, ESQUIRE Address: 5006 E. TRINDLE ROAD, SUITE 100, MECHANICSBURG, PA 17050 Attorney for: PLAINTIFF Telephone: 717-591-1755 Supreme Court ID No. 200139 y R. THOMAS KLINE Sheriff EDWARD L.SCHORPP Solicitor of (Cumber, OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 08/15/08 RONINY R. ANDERSON Chief Deputy JQDY S. SMITH Real Estate Sergeant Law Offices of Peter J. Russo, PC / vs n David B. Burkey Writ No. 2008-4185 Civil Tai Property Claim Determinatici CI; _ N Dear Sir, Reference is made to Property Claim dated August 5, 2008, entered by Kelli R. Burkey, pertaining to Writ of Execution No. 2008-4185 Civil Term, Law Offices of Peter J. Russo, PC -vs- David B. Burkey. R. Thomas Kline, Sheriff, has determined that the claimant, Kelli R. Burkey, in the above mentioned property claim, is the owner of the property set forth therein. _yL d Tho as .Kline, Sheriff B cc Elizabeth Saylor, Atty for Pltff David B. Burkey, Deft. Kelli R. Burkey, Claimant PROPERTY CLAIM In the Court of Common Pleas of Cumberland County, Pennsylvania CIE, S- a= Writ No. ??0 7 VS () TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA The property listed below and levied upon in this case is not the property of the defendant, but is t?e property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY lFk VALUE -21-)- OZ) ' (12) NESS / c ;ten -2&0, 01) cot Vim. L y°.? .CQ) E CLAIMANT OBTAINED E TO THE PROPERTY AS FOLLOWS: %-UULILve&&l LU.UUG11"U 2zz,??r being duly swo according to law, deposes and says that the above fist in the property claim are 96rrect and true. TV o d subscrib to before me y of U4:F CLAtl DIA A. BREWBAKER, NOTARY PUBLIC Carlisle Born. Cumberland County Commis w i h ? ? R cJ 5 - J(it? 8?u1 i'S r P, ?,?Ls 6,j ILL r r4o, ?( I tq m (L ?P Cog „,r? g,Lp?.ddMS 6A 4s 7'? s? Vol a s ?? ,?2s &V ld-V y/J, h E :1 d S - Onv BGOI la' , 4A } 3 t _.5Z:__d-2) _ v v- 75' do h ! d S - ?f3 9001 l 4 lH = , . SO - 6q) F1W W-j2?1 ?, (,-jz? L &d In PSR) 3A) I ?ld ? Ar,c,Gri??i1r71?,???-S ME :1 d S- 900 8041 w Vol f1CIJt' R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per Pennsylvania Rules of Court 3206 Property Claim. Sheriff's Costs: Advance Costs: 150.00 Sheriff's Costs: 77.87 Docketing 18.00 $ 72.13 Poundage 1.53 Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 08/27/08 Mileage 15.00 Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee Postage .84 TOTAL $ 77.87 ? ?,, q- //. 0 8 So Answers; ?OR as in , G OMA % ?0? pop CK7 By Claudia A. Brew, a Z I :b V S I Mr 8081 V0 ij- a. V nom-- G5 G4q ?(, „ c d/q3 ?? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-4185 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LAW OFFICES OF PETER J. RUSSO, P.C. Plaintiff (s) From DAVID BURKEY, 8 W. PINE STREET, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PROPERTY INCLUDING BUT NOT LIMITED TO FURNITURE, DESKS, COMPUTERS, TELEVISIONS, PRINTER, CASH WHICH IS LOCATED AT 8 W. PINE STREET, ENOLA, PA 17025. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$2181.56 Interest Atty's Comm % Atty Paid $53.75 Plaintiff Paid L.L.$.50 Due Prothy $2.00 Other Costs Date: JULY 14, 2008 (Seal) 140t'4? C s R. Lo ono By: Deputy REQUESTING PARTY: Name ELIZABETH J. SAYLOR, ESQUIRE Address: 5006 E. TRINDLE ROAD, SUITE 100, MECHANICSBURG, PA 17050 Attorney for: PLAINTIFF Telephone: 717-591-1755 Supreme Court ID No. 200139 LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russp, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso(a-)pjrlaw.com Attorneys for Plaintiff LAW OFFICES OF : IN THE COURT OF COMMON PLEAS OF PETER J. RUSSO, P.C. : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . V. DOCKET NO. 2008-4185 DAVID BURKEY . Defendant CIVIL LAW OFFICES OF : IN THE COURT OF COMMON PLEAS OF PETER J. RUSSO, P.C. : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. DOCKET NO. 2009-1579 KELLIBURKEY . Defendant CIVIL PETITION FOR CONSOLIDATION AND NOW, COMES the above-named Plaintiff who petitions this Court to consolidate the two above listed actions and in support thereof avers as follows: 1. Plaintiff, The Law Offices of Peter J. Russo, P.C., is a Pennsylvania Professional Corporation doing business in the Commonwealth of Pennsylvania with its principle place of business at 5006 E. Trindle Road, Suite 100, Mechanicsburg, PA 17050. 2. Defendants are David Burkey and Kelli R. Burkey, who have a mailing address of 8 W. Pine Street, Enola, PA 17025. 3. Defendants are married. 4. Plaintiff and Defendants entered into a written Fee Agreement regarding legal services. The Fee Agreement is attached hereto and incorporated herein as Exhibit A. 5. Despite repeated attempts of Plaintiff, Defendants refused to remit payment to Plaintiff per the Fee Agreement. 6. On or around February 20, 2008, Plaintiff filed a District Justice action against Defendant David Burkey. 7. On or around May 27, 2008, the Honorable Judge Thomas A. Placey entered a Judgment for the Plaintiff and Against Defendant David Burkey in the amount of Two Thousand One Hundred Eighty One Dollars and Fifty Six Cents ($2,181.56). 8. On or around July 14, 2008, Plaintiff filed a Writ of Execution and Entry of Judgment against defendant David Burkey in the amount of Two Thousand One Hundred Eighty One Dollars and Fifty Six Cents ($2,181.56). 9. On or around August 5, 2008, Defendant Kelli Burkey filed a Property Claim pertaining to the Writ of Execution. 10. On or around August 13, 2008, Plaintiff filed a District Justice action against Defendant Kelli Burkey regarding the legal services rendered. 11. On or around February 10, 2009, the Honorable Judge Thomas A. Placey entered a Judgment for the Plaintiff and Against Defendant Kelli Burkey in the amount of Two Thousand Four Hundred and Forty Four Dollars and Eighty Nine Cents ($2,444.89). 12. On or around July 17, 2009 Plaintiff filed an Entry of Judgment against Defendant Kelli Burkey in the amount of Two Thousand Four Hundred and Forty Four Dollars and Eighty Nine Cents ($2,444.89). 16. Plaintiff believes both parties are joint and severable liable for the amount owed under the agreement. WHEREFORE, Plaintiff requests that this Honorable Court consolidate both actions under one docket for purposes of collecting the judgment that, is owed to the Plaintiff. Resnectfullv sub LAW OFFICE-S-OF PETERTRUSSO, P.C. Peter J. Russo, Esquire Attorney I.D. No. 72897 Elizabeth J. Saylor, Esquire Attorney I.D. No. 200139 Attorneys for Plaintiff 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 VERIFICATION I,}?r verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. Dated: '1 23 Oq I .l SS© Print Title: AftMf-\f Signature EXHIBIT A Lain Offices fices Of Peter J. Russo, P. C. ATTORNEYS AT LAW 3800 Market Street, Camp Hill, PA 17011 Phone: (717) 591-1755 Fax: (717) 591-1756 Peter J. Russo, Esquire Scott A. Stein, Esquire John N. Papoutsis, Esquire Elizabeth J. Saylor, Esquire GENERAL LITIGATION FEE A GREEMENT Dear Client, This is to confirm our conversation, at which time we discussed the following legal concern: and whether this office would represent you in connection with these matters. The following explanation of our billing procedures is intended to supply you with general information regarding payment for your legal representation and to confirm the arrangements for payment of your legal fees. An effective attorney-client relationship is based upon complete understanding and mutual respect and it is therefore important that you review the contents of this letter carefully and call me if you have any questions. The current charges for my time are $165.00 per hour for out of court time and $185.00 for actual court time. The charge for legal assistants, paralegals and law clerks is $75.00 per hour. The minimum billing unit for any work done is .17 hours, or ten minutes. No additional charge is made for secretarial and clerical services. We agree to bill you at these rates through December 31 of this year. All services rendered after that time will be charged at the rates then in effect. Costs, for which you will be charged separately, include reimbursement for out-of-pocket expenses such as filing fees, process server fees, travel expenses, transcripts, printing costs, toll telephone charges, postage, computer assisted research, and, on occasion, fees for investigators, appraisers or accountants although such persons will usually be hired by you if their services are in accordance with the attached schedule. required. Fees for specific cost charges are jao, uired before any work can be undertaken on A non refundable retainer of $1,5is req your behalf. Your bal ll not fall be 100.00 at any given time. CLIENT'S INITIALS I Client's Initials L Page One of Four Page Two of Four General Litigation Fee Agreement All evidentiary and appellate court appearances are billed at a minimum of four (4) hours computed at the regular hourly rate of the attorney representing you or the actual time spent at the proceeding when more than four hours is required. All other charges are computed on the basis of time expended in providing you with legal advice and representation. If you require representation at a trial or hearing, it will be necessary for you to deposit an additional retainer equal to twice the actual court time anticipated. This requirement is necessary because evidentiary court appearances are time intensive for the attorney and preclude the undertaking of other work for an extended period of time, not only during the actual hearing, but in the period of advance preparation as well. Most evidentiary proceedings require two to three hours of preparation time for each hour of scheduled court time. If complex questions of fact or law are involved, this time can increase substantially. It is not possible to estimate in advance the total charges for your legal work since the amount of time required is dependent upon the circumstances of your personal situation. We cannot finance your litigation and it is therefore necessary that you make payment as bills are rendered. Prompt payment in full for services rendered is vital to our ability to efficiently provide legal services to all clients. Your statements will itemize all charges for services, costs and expenses consistent with client confidentiality. If you have any questions concerning any time of charge it is your responsibility to bring that item to our attention within thirty days of the date of the statement. Because investigation of billing inquiries is time consuming and burdensome to office operations and unfairly increases cost of representation to other clients, we must charge a search expense of $50 per hour for staff personnel for the investigation of any billing inquiry made after thirty days. Attorney time for such inquiries will be billed at regular hourly rates. Like other creditors, we will impose finance charges of 18 percent per annum as permitted by law on amounts unpaid after 30 days, as well as charges for any time involved in collection. In the event that your account must be referred to outside counsel for collection, attorneys' fees of twenty percent of the outstanding balance will be charged to you. All payments received on account for fees billed will be credited first to the most recent charges on your account. You will at all times have the right to terminate our services upon written notice to that effect. We will at all times have the right to terminate our services upon written notice to that effect in the event that you fail to cooperate with us in any reasonable request, to timely pay the monthly statements in full as submitted, to replenish the retainer, or if we determine in our reasonable discretion that to continue our services to you woi -6 be unethical or impractical.. Client's Initials _IQ / Page Two of Four Page Three of Four General Litigation Fee Agreement There are many roads to the same destination; some are long and arduous and others are direct and easy. One of your most important considerations in deciding between various courses or action, or inaction, should always be the expense involved and this is based upon the amount of time which must be expended. We will attempt to represent you in the most time efficient manner possible and will, from time to time, suggest things that you can do to minimize your legal expenses. The following are some suggestions which have proved helpful to other clients and we would like to share them with you. We encourage you to adopt these procedures because they not only minimize expenses but, even more importantly, tend to produce a better ultimate result: 1. Avoid unnecessary telephone calls. If you have a question or information which can wait, make a note of it so that you can cover several items in one personal or telephone conference. 2. Leave messages. If you need to impart information which need not be discussed immediately, either leave the information with the secretary who answers the telephone or send a note. All of the attorneys in this office spend considerable amounts of time in court and we are therefore frequently unable to speak with you on the telephone when you call. I will attempt to return your telephone calls as soon as I reasonably can do so. In many situations, you should ask to speak with a legal assistant who can answer many factual questions for you and can relay information to me. Every employee in this office is bound to hold confidential any information received form a client. However, ONLY an attorney may give you legal advice. 3. Read everything. You will receive copies of all documents and letters concerning your legal business which are either sent or received. You should maintain your own file which will duplicate the one which we are keeping. This will enable you to refer to the documents as necessary and will provide you with a permanent record of your case. 4. Make notes. Write everything down: questions, information, lists of pros and cons, everything. If you do, you will avoid repetition and you will not overlook anything important. 5. Ask questions. You must be in a position to make informed and intelligent decisions. The only dumb question is the one you fail to ask. While we cannot guarantee a particular result, you may be assured that we will utilize the resources and expertise of this office to your best advantage. If you wish us to represent you, such representation will begin upon receipt by us of the enclosed copy of this letter, signed by you and your retainer payment. You should retain the original of this letter for your own records. Client's Initial ,i /[JD3 __ Page Three of Four Page Four of Four General Litigation Fee Agreement If you do not wish to retain counsel at this time, you may arrange to be seen on a consultation basis at the same hourly rate, with the understanding that our representation of you does not begin until your retainer has been received. Again, should you have any questions or concerns, please feel free to contact me. Very truly yours, Law Offices of Peter J. Russo, have read the foregoing four pages and underst d the terms aL4conditions of this ment and they are acceptable to me. My signature herein is my express acknowledgment and acceptance of the terms of this Agreement. s: ? ient Date: CERTIFICATE OF SERVICE I hereby certify that I have on this day served a true and correct copy of the Motion for Consolidation, upon the following person, in the manner indicated: Service by US FIRST CLASS MAIL: David Burkey 8 W. Pine Street Enola, PA 17025 Pro se Defendant Kelli Burkey 8 W. Pine Street Enola, PA 17025 Pro se Defendant DATE: --l 2-310 .0?? v I Amber L. Southard, Paralegal 2 0 0 9 . tir 24 P a 12 ' 5- '1 LAW OFFICES OF : IN THE COURT OF COMMON PLEAS OF PETER J. RUSSO, P.C. : CUMBERLAND COUNTY, ]PENNSYLVANIA Plaintiff V. DOCKET NO. 2008-4185 ?? DAVID BURKEY Defendant CIVIL LAW OFFICES OF : IN THE COURT OF COMMON PLEAS OF PETER J. RUSSO, P.C. : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. DOCKET NO. 2009-1579 KELLI BURKEY Defendant CIVIL RULE TO SHOW CAUSE AND NOW, this 7-9? day of , 200SI a Rule to Show Cause is issued for Defendants to show cause as to why the Petitioner's Request for Consolidation should not be granted a+ a hParin? +., ?A ===c:Q a !`•imhai^lanrl County ----; in 166 C e?xtcem'er?ieenb er BY THE COURT, Distribution List: zt-lizabeth J. Saylor, Esquire The Law Offices of Peter J. Russo, P.C. 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Attorney for Plaintiff ./ David and Kelli Burkey 8 W. Pine Street Enola, PA 17025 Pro se Defendants C.o I*" 7/z9 j0q ?`i FiLEL' ;`? I?; ARY 2009 JUL 29 AN 10: 2 C LAW OFFICES OF : IN THE COURT OF COMMON PLEAS OF PETER J. RUSSO, P.C. : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. DOCKET NO. 2008-4185 DAVID BURKEY Defendant CIVIL TO: CURTIS R. LONG, PROTHONOTARY OF SAID COURT PRAECIPE TO SATISFY AND DISCONTINUE JUDGMENT Kindly discontinue the above captioned Civil Action and mark as paid in full and satisfied. Respectfully submitted, Date: LAW OF OF PETER J. RUSSO, P.C. Peter J. Russo, Esquire Attorney I.D. No. 72897 Elizabeth J. Saylor, Esquire Attorney I.D. No. 200139 Attorneys for Plaintiff 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 LAW OFFICES OF : IN THE COURT OF COMMON PLEAS OF PETER J. RUSSO, P.C. : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. DOCKET NO. 2008-4185 DAVID BURKEY Defendant CIVIL CERTIFICATE OF SERVICE I, Amber L. Southard, hereby certify that I am on this day serving a copy of the Praecipe to Enter Judgment upon the person(s) and in the manner indicated below: Service by US REGULAR MAIL: David Burkey 8 W. Pine Street Enola, PA 17025 DATE: Q j5 U i A yjy&?k Amber L. Southard, Paralegal FED._f.r,; :,,.JCo- CF THE F'R;.? '-j :'}',QTARY 2009 SE? 16 PH 2: 2 4