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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 ~fl& .... llJ 8 rr,~ g ~ -v l) pr:::: .-1- (') ...., B = ~ c: = ~. ..,- riOI .'-. ,.,.. :rJ- -0 r;;~ ~;; .~ ~ :x> f] -ni-n ~ ".) w .~ ..' 0 ~.:: ;? - = C ::;i:. -~.. :;~ - .. ...\ ::::_1 N ~ -< 'J, ---::: (?~~ E- !J; r." ~ ~ );r~ i? ~~ ~ t ? 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 ~~~~~ ~~~oP.7f~ Gods.' <1/'17. ~I JIP.oo 1.00 y~ (?~ j:)cL I). -/-it ( COI 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 r:J..o..f -;1 '. w "'""^ ~l. - -- ~ - V proth~~ot;;:;~ IJ oA. day of ~ J- A.D. this L.t-~ 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 . (') ....., 0 C_? C C' ." -;';0" ....- -r C ~. ~ !T, , :;i:::- rnp -: -nrTl ~~ -flu v:o ~::)tS C'~: f ::;1' -,', .' -u gf$~ :"; -" ( , ~ 'PC c~_ ~ ____I 2. -';-0 ::2 "'. ~:;,~J 0' .< ., 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 r~ ';;-? C) c'. C::7 -n ~~~;: .1.- -<.. :::~., -0 DATE OF NOTICE: May 18, 2004 1,.C IMPORTANT NOTICE: [''-:' ....- - - -~ 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 /J ..~ 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 ('::\ U). \",,,:) Cl (C) '.'.':--:'1 ..0 ,; .'~ -yt 't1l ~ 0" :.,1 \) f \1 \) (.^') - -- ~ r .. CAJ -.::J l U \) ~ -- .~ -c:. w ~ ,,1 ~ -ti m b if' QJ t:-- \'-,::.. ~ ~ ~ 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