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HomeMy WebLinkAbout08-6950PENNSYLVANIA STATE EMPLOYEES:IN THE COURT OF COMMON PLEAS CREDIT UNION, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff /~, , i~8 - 10450 l~iv~ l Terw+ vs. . CHARLIE E RINER NO. 03-3716 9'1a Gienco Avg Defendant :CIVIL ACTION -LAW luayr~esbono, va ~d480-3c1a5 pRAECIPE FOR WRIT OF REVIVAL TO THE PROTHONOTARY: Issue Writ of Revival of Judgment entered to Docket No. 03-3716 and index it in the Judgment Index against Defendant, Charlie E Riner in the amount of $16,355.17 with interest and costs from November 17, 2003. VAN ECK & VAN ECK, P.C. By: Melissa L. Van Eck, Esquire P.O. Box 6662 Hamsburg, PA 17112 (717) 540-5406 ID No. 85869 Attorneys for Plaintiff Date: ~ ~ ~ a` `~~ ~ ` V ~ ~ ,~' ~ _~ ' tt~ ~ ~ R, o ~ 01 I X1 0 o Vj ~1-c ° : _, ; r -; = ~ ~ ?7 ~ D ~ ~ Q ~~ 0 ~ :>..~ ; r iT? .i7 ~ ZI ^ T ~ \_ ~ _ .f: - t r ~=~ =-~ ..,. ~~.t . ~ PENNSYLVANIA STATE EMPLOYEES:IN THE COURT OF COMMON PLEAS CREDIT UNION, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff /~ _ vs. CHARLIE E RIMER Defendant NO. 03-3716 CIVIL ACTION -LAW TO THE PROTHONOTARY: ENTRY OF APPEARANCE Please enter the appearance of Melissa L. Van Eck, Esquire, as counsel for Plaintiff in the above action. Respectfully Submitted, VAN ECK & VAN ECK, P.C. Date: C ~ -c~[ _~ By: Melissa L. Van Eck, Esquire ID No. 85869 PO Box 6662 Harrisburg, PA 17112 (717) 540-5406 C'] ^~ '~~a , .~ ~ ~~ ti,i ,i (~y ~.~ t ' , _.i r:. ~ -.,.. ~ ~ ~ s=- .. .L~ _ .. '-'t _~ ~ i `ti PENNSYLVANIA STATE EMPLOYEES:IN THE COURT OF COMMON PLEAS CREDIT UNION, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Og - C~So Civil l~r~- vs. CHARLIE E RIMER NO. 03-3716 Defendant :CIVIL ACTION -LAW WRIT OF REVIVAL TO: Charlie E Riner 972 Glencoe Avenue Waynesboro, VA 22980-3025 (1) You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the Judgment entered to Docket No. 03-3716. (2) The Plaintiff claims that the amount due and unpaid is $16,355.17 with interest from November 17, 2003. (3) You are required within twenty (20) days after service of this writ to file an answer or otherwise plead to this writ. If you fail to do so Judgment of revival in the amount claimed by the plaintiffmay be entered without a hearing and you may lose your property or other important rights. 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. C0~ ~ ~ doe.~5 Po grrY Cumberland County Bar Association a.oo ~uE. ~p 32 S Bedford Street Carlisle, PA 17013 (800) 990-9108 Date: //~dy/p8 Pr onotary By: Deputy ,;~,: ~, . BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 U-~t~r~;i`c ?Nr P~,i; } ~i~O~AE?Y Zdl~Mt~R A~I!!~ 3~ i'ENPvS~! UhUiA 08-6950 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff v. CHARLIE E. RIMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 08-6950 PRAECIPE TO WITHDRAW/ENTER APPEARANCE Kindly withdraw the appearance of Melissa L. Van Eck, Esquire as counsel for Pennsylvania State Employees Credit Union and enter the appearance of Shawn M. Long, Esquire as counsel for Pennsylvania State Employees Credit Union, regarding the above- captioned matter. Papers may be served at the address set forth below. BARLEYS YDER LLC By: haven M. Long, squire Court I.D. 83774 126 East King Street Lancaster, PA 17602-2893 717.299.5201 Date: VAN ECK & VAN ECK, P.C. By: z Melissa L. Van Eck, squire Court I.D. 85869 7810 Allentown Blvd., Suite B P.O. Box 6662 Harrisburg, PA 17112 717.540.5406 Date: 2853408-1 08-6950/ 03-3716 V U 0 C T V ?3 3 L: "} t•r BARLEY SNYDER LLC Shawn Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 Attorneys for Plaintiff (717) 299-5201 Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. CHARLIE E. RINER, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Revival No. 08-6950 No. 03-3716 CIVIL ACTION LAW PRAECIPE TO REISSUE WRIT OF REVIVAL TO THE PROTHONOTARY: Kindly reissue the Writ of Revival in the above matter. By: 3019179-1 BARLEY SNYDER LLC Shawn M. Long, E uire Court I.D. No. 837R4 Attorneys for Pl ntiff, Pennsylvania State Employees Credit Union 126 East King Street Lancaster, PA 17602-2893, (717) 299-5201 A ) 4 11L c ?asl I to 08-6950/ 03-3716 'I?._ED-OF EISE OF TV,E ? ROTHONOTAR'i ?: 2011 iA1125 Fill E1%IiSY BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. CHARLIE E. RINER, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Revival No. 08-6950 No. 03-3716 CIVIL ACTION LAW PRAECIPE TO REISSUE WRIT OF REVIVAL TO THE PROTHONOTARY: Kindly reissue the Writ of Revival in the above matter. BARLEY SNYDER LLC Sha M. Long, Esquire C/ni I.D. No. 83774 Attorneys for Plaintiff Pennsylvania State Employees Credit Union 126 East King Street Lancaster, PA 17602 (717) 299-5201 ?oot?Q 00+ to, 3019179-1 c a ?"? 08-6950/03-3716 t tU-{3FI 61 4j FIE PROTHONOTAWt BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 2011 APR -- I PM 1: 33 1'1. MBERLAND COUNTi' PENNSYLVANIA Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. CHARLIE E. RIMER, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Revival No. 08-6950 No. 03-3716 CIVIL ACTION LAW AFFIDAVIT OF SERVICE The undersigned KELLY CUNNEEN, PARALEGAL doth depose and say that a true and correct copy of the reinstated Writ of Revival in the above captioned matter was sent to the below listed Defendant by certified, return receipt requested and regular, first class mail. The original Receipt are attached hereto: Charlie E. Riner 12 Riner Lane Verona, VA 24482 The statements set forth in this affidavit are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: March 29, 2011 BARLEY SNYDER LLC By: JhLt LUA-Ag? Kelly nneen, Paralegal 126 East King Street Lancaster, PA 17602 (717) 399-1528 3175156-1 SERVICE OTHER THAN BY VIRGINIA SHERIFF Case No 08-6950 Commonwealth of Virginia VA. CODE 8.01-296; 8.01-320; 8.01-325 Hearing Date: Attorney: Shawn M. Long Cumberland County, Pennsylvania [X] Common Pleas Court .................................................................................................. Pennsylvania State Employees Credit Union v. Charlie E. Riner .....................................................................................VAn re: Charlie E. Riner .......................................................................................................................................... is the name and address of the person upon whom service of the following is to be made. [XI Praecipe to Reissue Writ of Revival/Writ of Revival 1, the undersigned, swear/affirm that: I [ ] I am an official or an employee of an official who is authorized to serve process of type described in the attached Proof of Service and my title and bailiwick are: OR [X] I am a private process server: Charles D. Sheffer Jr. Shenandoah Civil Service LLC NAME 80 B Woodlee Road_ Staunton, VA- 24401 (540)245 0143 ADDRESS AND TELEPHONE NUMBER 2. I am not a party to, or otherwise interested in, the subject matter in controversy in this case. 3. I am 18 years of age or older. 4. 1 served, as shown below, the above-named person upon whom service of process was to be made with copies described above. • Date and time of service: 02-18-11 4:38pm • Name/Place of service: Charlie E. Riner, 12 Riner Lane, Verona, VA STREET ADDRESS, CITY AND STATE • Method of service: [X] Personal Service: [ ] Being unable to make personal service, a copy was delivered in the following manner: (] Delivered to family member (not temporary sojourner or guest) age 16 or older at usual place of abode of party named above after giving information of its purport. List name, age of recipient, and relation of recipient to party named above. List name, age of recipient, and relation of recipient to party ...................................... [ ] Place of Business Personally Served: [ ] Letter mailed on: [ ] Posted on front door or such other d to be the main entrance of usual place of abode (other authori'71 t not foul d). [ ] Not Found / 7?? ?-1 02-18-11 DATE SIGNATURE OF PERSO SER Name (print or type) Charles D Sheffer, Jr. State of Virginia [X] City [ ] County of Staunton Subscribed and sworn to/affirmed before me this day by Charles D Sheffer, Jr. , 02-18-11 DATE NOT. Jody Lee Barb Commcnwea th cf Virginia Nota rry P tlic Commission No 7315998 `", =i My Ccm 'ss cn Ex ires 6/30/2014 08-6950/03-3716 -Gi-OFFICE ROTNONO fAR)` X011 Arr'R -1 PM 1: 33 CUMBERLAND COUNT PENNSYLVANIA BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. CHARLIE E. RINER, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Revival No. 08-6950 J No. 03-3716 CIVIL ACTION LAW PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, Pennsylvania State Employees Credit Union and against Defendant, Charlie E. Riner for want of an answer in the amount of $16,355.17 plus interest and costs of suit. (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( ) Pursuant to Pa. R.C.P. 237 (notice of praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. 31751311 0? 6- ly: 00 Pd 0 k_ 1t g216'7 7e> ?- g-as7 ?S?(1a 08-6950/ 03-3716 (X) Pursuant to Pa. R.C.P. 237. 1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. BARLEY SNYDER LLC Date: 3/301 By: dawn M. Long, Es uire Court I.D. No. 837 4 Attorneys for Plai iff Pennsylvania State Employees Credit Union 126 East King Street Lancaster, PA 17602 (717) 299-5201 NOW, Qoyr , 2011, JUDGMENT IS ENTERED AS ABOVE. Prothonotary/Clerk, Civil Division By: 31751311 08-6950/ 03-3716 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OFFICE OF THE PROTHONOTARY CARLISLE, PA TO: Charlie E. Riner Defendant YOU ARE HEREBY NOTIFIED that Pennsylvania State Employees Credit Union has caused a judgment by default to be entered against you with the Prothonotary of Cumberland County. The judgment was entered on_ to No. 08-6950/ 03-3716 with the Court of Common Pleas of Cumberland County - Civil Division. The judgment is in the amount of $16,355.17 plus costs of suit. PROTHONOTARY By: '74 ut rk 31751311 08-6950/ 03-3716 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. CHARLIE E. RINER, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Revival No. 08-6950 No. 03-3716 CIVIL ACTION LAW AFFIDAVIT THAT THE DEFENDANT IS NOT IN THE MILITARY SERVICE, PURSUANT TO "SOLDIERS AND SAILORS" CIVIL RELIEF ACT OF 1918, RE-ENACTED 1940 The undersigned, Shawn M. Long, Esquire, doth depose and say that Charlie E. Riner, the Defendant is not in the Military or Naval Service, based on the following facts: Age of Defendant is unknown; Present place of employment is unknown; Last known place of Residence is 12 Riner Lane, Verona. VA 24482 as of the date of this affidavit. ADDITIONAL FACTS, if any. The statements set forth in this affidavit are made subject to the penalties of 18 Pa. C.S., §4904, relating to unsworn falsification to authorities. BARLEY SNYDER LLC By: Shawn M. Long, Esc Attorneys for Plainti Court I.D. No. 8377, 126 E. King Stree Lancaster, PA 1 602 717.299.5201 31751311 08-6950/ 03-3716 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. CHARLIE E. RIMER, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Revival No. 08-6950 No. 03-3716 CIVIL ACTION LAW AFFIDAVIT OF SERVICE Kelly Cunneen, Paralegal, doth depose and say that she served a true and correct copy of the 10-Day Default Notice upon Charlie E. Riner at 12 Riner Lane, Verona, VA 24482 by regular mail on March 15, 2011 at 5:00 p.m. The statements set forth in this Affidavit are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: March 15, 2011 BARLEY SNYDER LLC ? By: ?ku I ka - Kelly Cu en, Paralegal 126 East King Street Lancaster, PA 17602-2893 717.299.5201 31613871 08-6950/ 03-3716 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. CHARLIE E. RINER, Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Revival No. 08-6950 No. 03-3716 CIVIL ACTION LAW To: Charlie E. Riner Date of Notice: March 15, 2011 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. 31613871 08-6950/ 03-3716 YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 BARLEY SNYDER LLC By: v hawn M. Long, Esquire Court I.D. No. 83774 Attorneys for Plaintiff Pennsylvania State Employees Credit Union 126 East King Street Lancaster, PA 17602 (717) 299-5201 31613871