HomeMy WebLinkAbout04-1922
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
ERIE INSURANCE EXCHANGE, as subrogee
for LEE W. GODSHALL and
SANDRA K. SHORTRIDGE
Plaintiff
Civil Action - Law
vs.
No. 0'1 - /q~d-.... Ci(.)~L '-r~
ERIN DOOLITTLE and MICHAEL BLOUNT,
Defendants
PRAECIPE FOR WRIT OF REVIVAL
TO THE PROTHONOTARY OF SAID COURT:
Issue Writ of Revival of Judgment entered to No. 97-4166 and index it in the Judgment Index
against MICHAEL BLOUNT, Defendant in the amount of $2,521.14 with interest from July
31, 1997.
GRIFFITH, STRICKLER, LERMAN
SOL YMOS & CALKINS
I . .
By: ~... :: M~.
Krist; . Gohu, Esquire
Supre e Court LD. #84738
110 South Northern Way
York,PA 17402
Telephone No. (717) 757-7602
Attorney for Plaintiff
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WRIT OF REVIVAL
TO: Michael Blount, Defendant
1805 Suncrest Drive
Carlisle, Pennsylvania 17013
(1) You are notified that the Plaintiff has commenced a proceeding to revive and
continue the lien of the judgment entered to No. 97-4166
(2) The Plaintiff claims that the amount due and unpaid is $2,521.14 with interest
from July 31,1997.
(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 ofRevivaI will be entered.
DATE: {).pn \ l. ;~ (')( :J..OOlf
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2004-01922 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ERIE INSURANCE EXCHANGE
VS
BLOUNT MICHAEL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named DEFENDANT
BLOUNT MICHAEL
but was
unable to locate Him in his bailiwick. He therefore returns the
WRIT OF REVIVAL
, NOT FOUND , as to
the within named DEFENDANT
, BLOUNT MICHAEL
1805 SUNCREST DR
CARLISLE, PA 17013
DEFENDANT HAS NOT LIVED AT GIVEN ADDRESS FOR
OVER ONE YEAR.
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
18.00
3.45
5.00
10.00
.00
36.45
S~~~
R. Thomas Kline
Sheriff of Cumberland County
GRIFFITH STRICKLER LERMAN
05/11/2004
Sworn and subscribed to before me
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this
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ERIE INSURANCE EXCHANGE, as subrogee
for LEE W. GODSHALL and
SANDRA K. SHORTRIDGE
Plaintiff
Civil Action - Law
vs.
No. 04-1922 Civil Term
ERIN DOOLITTLE and MICHAEL BLOUNT,
Defendants
NOTICE OF INTENTION TO ENTER DEFAULT JUDGMENT
TO: Michael Blount
1805 Suncrest Drive
Carlisle, P A 17013
DATE OF NOTICE: May 18,2004
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 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, 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 SERVIES TO ELIGffiLE PERSON AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, P A 17013
1-800-990-9108
GRIFFITH, STRICKLER, LERMAN,
SOL MOS & CALKINS
BY: ~
I A. GOHN, ESQUIRE
Attorney for Plaintiff
Supreme Court LD. #84738
110 South Northern Way
York, Pennsylvania 17402
Telephone: (717) 757-7602
IN THE COURT OF COMMON PLEAS OF CUMBlii:RLAND COUNTY, PENNSYLVANIA
ERIE INSURANCE EXCHANGE, as subrogee
for LEE W. GODSHALL and
SANDRA K. SHORTRIDGE
Plaintiff
Civil Action - Law
vs.
No. 04-1922 Civil Term
ERIN DOOLITTLE and MICHAEL BLOUNT,
Defendants
CERTIFICATE OF SERVICE
AND NOW, this Jj'1tI day of May, 2004, I, Kristi A. Gohn, Esquire, a member of the
firm of GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS, hereby certify that I
have, this date served a copy of the NOTICE OF INTENTION TO ENTER DEFAULT
JUDGMENT by United States Mail, addressed to the party or attorney of record as follows:
Michael Blount
1805 Suncrest Drive
Carlisle, P A 17013
GRIFFITH, STRICKLER, LERMAN,
SOL YMOS & CALKINS
By KR1S~t%o~
Supreme Court I.D. #84738
Attorney for Plaintiff
110 South Northern Way
York, PA 17402
(717) 757-7602
.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ERIE INSURANCE EXCHANGE, as subrogee
for LEE W. GODSHALL and
SANDRA K SHORTRIDGE
Plaintiff
Civil Action - L w
vs.
No.
04-1922 ivil Term
ERIN DOOLITTLE and MICHAEL BLOUNT,
Defendants
PRAECIPE FOR ENTRY
OF DEFAULT JUDGMENT
TO THE PROTHONOTARY:
ENTER JUDGMENT of Revival in the above case for failure to file an answer 0 otherwise plead to the
Writ of Revival within twenty (20) days of service thereof
in favor of Plaintiff, Erie Insurance Exchange, as subrogee for Lee W. Godshall an Sandra K. Shortridge
and against Defendant, Michael Blount
in the sum of$2,521.14 with interest from July 31, 1997 plus interest, costs of suit nd attorney's fees
Total: $2,521.14 with interest, plus costs of suit and attorney's fees
A ey for Plaintiff
KRIST! A. GORN, ESQ IRE
(1..'?f)( L J I
tenor of the above statement.
, 2005 Judgment entered by the Prothonotary . s day according to the
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ERIE INSURANCE EXCHANGE, as subrogee
for LEE W. GODSHALL and
SANDRA K. SHORTRIDGE
Plaintiff
Civil Action - J;,aw
I
vs.
No. 04-192 Civil Term
ERIN DOOLITTLE and MICHAEL BLOUNT,
Defendants
NOTICE OF INTENTION TO ENTER DEFAULT JUD MENT
TO: Michael Blount
1805 Suncrest Drive
Carlisle, P A 17013
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DATE OF NOTICE: May 18, 2004
1,.C
IMPORTANT NOTICE:
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YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO NTER AWRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN TING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SE FORTH AGAINST
YOu. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE F THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A ARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORT ANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONC . IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FO TH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRIN A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OF
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES
LEGAL SERVIES TO ELIGIBLE PERSON AT A REDUCED FEE OR
CE MAY BE ABLE
HAT MAY OFFER
FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
1-800-990-9108
GRIFFITH, STRICKLER, L
SOL YMOS & CAL
I
t( J./\VL.
BY: r' '?l/l:M!1c.
KlU8rIA.GOfEN,E QUIRE
Attorney for Plaintiff
Supreme Court I.D. # 4738
110 South Northern ay
York, Pennsylvania I 402
Telephone: (717) 757 7602
I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ERIE INSURANCE EXCHANGE, as subrogee
for LEE W. GODSHALL and
SANDRA K SHORTRIDGE
Plain tiff
Civil Action - I1aw
vs.
No. 04-1922 Civil Term
ERIN DOOLITTLE and MICHAEL BLOUNT,
Defendants
CERTIFICATE OF SERVICE
AND NOW, this ~ day of May, 2004, I, Kristi A. Gohn, Esq ire, a member of the
firm of GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS hereby certify that I
have, this date served a copy of the NOTICE OF INTENTION TO NTER DEFAULT
JUDGMENT by United States Mail, addressed to the party or attorney ofr cord as follows:
Michael Blount
1805 Suncrest Drive
Carlisle, P A 17013
GRlFFITH, STRICKLER, LE
SOLYMOS & CAL S
By:
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ERIE INSURANCE EXCHANGE, as subrogee
for LEE W. GODSHALL and
SANDRA K. SHORTRIDGE
Plaintiff
Civil Action - L w
vs.
No.
04-1922 ivil Term
ERIN DOOLITTLE and MICHAEL BLOUNT,
Defendants
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
ss:
COUNTY OF YORK
Kristi A. Gohn, Esquire, being duly sworn according to law, deposes and ays that she is counsel
for Erie Insurance Exchange, as subrogee for Lee W. Godshall and Sandra K. S ortridge, in the above-
captioned matter; that she personally knows the Defendant, Michae] Blount, is 0 er the age of 18 years;
and that he resides at ]805 Suncrest Drive, Carlisle, Pennsylvania 17013 and t he is employed as an
unknown at unknown.
Kristi A. Gohn, Esquire, further avers that the Defendant is not in the Mi itary Service or in any
branch of the Armed Forces of the United States or its Allies or otherwise withi the provisions of the
Soldiers' and Sailors' Civil Relief Act of Congress of ] 940 and its Amendments.
GRIFFITH, STRICKLER, LE
SOL YMOS & CALKINS
By: .I\,vt. .
KRIST 1/.-. GORN, ESQUI
Supreme Court I.D. # 84378
Attorney for Plaintiff
]]0 South Northern Way
York, Pennsylvania 17402
Te]ephone: (7]7) 757-7602
Sworn to and subscribed
before me thi,,)~ay
of Mil/." tz ,2005
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u-Y-;( c?t-t"" , ru;U
NOTARY PUELI
My Commission Expires:
._"v'''";VI'~~\fl;,\!:'h IY= t-'ENi'~3YLV;,;~,.
Notarial Seal
Catl1erine N. Byerts. Noiary Public
Springellsbury Twp.. YOI1< County
My Commission Expires July 21. 20117
Member, Pennsy1var:ia ,A.ssocialion Of Notaries
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ERIE INSURANCE EXCHANGE, as subrogee
for LEE W. GODSHALL and
SANDRA K SHORTRIDGE
Plaintiff
Civil Action - L w
vs.
No. 04-1922 ivil Term
ERIN DOOLITTLE and MICHAEL BLOUNT,
Defendants
TO THE PROTHONOTARY:
( X) Notice is hereby given that a WDGMENT in the abo -captioned matter has
been entered against you in the amount of $2,521.14 plus interest from July 3 I, 997, costs of suit and
attorney's fees on (YG,JtL?" 7/ ,2005.
( X) A copy of all documents filed with the Prothonotary in support of the within udgment is enclosed.
Prothonotary Civil Div.
~./
.BY:
~
If you have any questions regarding this Notice, please contact the filing party:
TELEPHONE NO:
KRISTI A. GO , ESQUIRE
110 S. Northern ay
York, Pennsylva ia 17402
(717) 757-7602
NAME:
ADDRESS:
(This Notice is given in accordance with Pa.R.C.P.236)
Notice sent to:
Michael Blount
1805 Sun crest D ve
Carlisle, P A 17013