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HomeMy WebLinkAbout09-1887 L] FARLES\Clients\12532 McCarron\12532.Lpra3.revival Christopher E. Rice, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Attorney I.D. No. 90916 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs MARTHA SHELLY and LINDA EWING, Plaintiffs V. STERMAC, LLC and STEVEN McCARREN, Defendants and LINDA M. EWING and DONALD G MARINKOV, Terre-tenants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,, PENNSYLVANIA NO. 2007-6918 CIVIL TERM CIVIL ACTION - EQUITY PRAECIPE FOR WRIT OF REVIVAL To the Prothonotary: Please issue a Writ of Revival of Judgment Lien entered at Cumberland County Docket Number 2007-6918 and enter it in the judgment index against Martha K. Shelly, Plaintiff, and Linda M. Ewing and Donald G. Marinkov, Terre-Tenants, in the amount of $50,000.00, plus interest from August 1, 2008. MARTSON LAW OFFICES Date: 546- Of By. 0,4 4 5. ?-•- Christopher E. Rice, Esquire MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs FAFHMNClimta\12532 McCarrcnN12532.1.writofirAval Christopher E. Rice, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Attorney I.D. No. 90916 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs MARTHA SHELLY and LINDA EWING, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. STERMAC, LLC and STEVEN McCARREN, Defendants and LINDA M. EWING and DONALD G. MARINKOV, Terre-tenants NO. 2007-6918 CIVIL TERM : CIVIL ACTION - EQUITY WRIT OF REVIVAL TO: MARTHA SHELLY, LINDA EWING, and DONALD G. MARINKOV. (1) You are notified that Defendant Stermac, LLC has commenced a proceeding to revive the Judgment entered at Cumberland County Docket Number 2007-6918. (2) Defendant Stermac, LLC claims that the amount due and unpaid is $50,000.00, plus interest from August 1, 2008. (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 Defendants may 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. 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 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Date: /y/. 71 ?Od . Jed. urtis R. Ond County rothonotary CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Praecipe for Writ of Revival was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: David A. Baric, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 MARTSON LAW OFFICES By: t , 0.? M Price Ten ast High Street Carlisle, PA 17013 (717) 243-3341 Dated: 3 /02-S, O /V v v D s - s +"` _ Syl ' G FARLES\Ciients\12532 McCarten\12532.Las Christopher E. Rice, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Attorney I.D. No. 90916 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs MARTHA SHELLY and LINDA EWING, Plaintiffs V. STERMAC, LLC and STEVEN McCARREN, and Defendants LINDA M. EWING and DONALD G. MARINKOV, Terre-tenants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 1887 CIVIL TERM : CIVIL ACTION - EQUITY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Writ of Revival in the above captioned matter was mailed to Martha K. Shelly, Linda Ewing, and Donald Marinkov, 447 Wileman Road, Lynch Station, VA 24571, by certified mail, restricted delivery, return receipt requested. Attached are copies of the Post Office return receipts signed by Martha Shelly, Linda Ewing and Donald Marinkov. Sworn to and subscbed before me this 30day of April, 2009. N ublic MARTSON LAW OFFICES Christopher E. Rice, Esquire Attorney I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 By. (2_1? 511- COMMONWEALTH OF PENNSYLVANIA NOMM Seal Mary M. Pem Nohry Pdit come am, cumbakwid COU* Ownbobn En*a AU& 14 2011 Member, PennsylVfnls;G_* it fbn of Nobfts ¦ Cora ft b m 1, Z and 9. Also oompiste A. 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(Babe" 7008 1140 0001 6163 4255 10260549-WISO Ln Ln ti ir S m PI e _o A Postage CerMed Fee r•a C3 Retum R eceipt Fee p (Endorserna MRsqutred) C3 Restricted Deevery Fee C3 (EndorsemeM RequWod) S sa TOW Pcetege & Fees r-I Sent C3 C3 3iieer, A or PO Bar Mo. -------------•--__ CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Certificate of Service was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Martha K. Shelly 447 Wileman Road Lynch Station, VA 24571 Ms. Linda Ewing 447 Wileman Road Lynch Station, VA 24571 Mr. Donald Marinkov 447 Wileman Road Lynch Station, VA 24571 David A. Baric, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 MARTSON LAW OFFICES A A `!. Q By Ma . Price Ten Efast High Street Carlisle, PA 17013 (717) 243-3341 Dated: ?/3olo 7 ?-AQ'I 2009' R 30 P,ki ", : i' Christopher E. Rice, Esquire Attorney I.D. No. 90916 Jacob M. Theis, Esquire Attorney I.D. No. 208631 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717)243-3341 Attorneys for Plaintiffs MARTHA SHELLY and LINDA EWING, Plaintiffs V. STERMAC, LLC and STEVEN McCARREN, Defendants and LINDA M. EWING and DONALD G. MARINKOV, Terre-Tenants TO: MARTHA SHELLY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009 - 1887 CIVIL TERM CIVIL ACTION - EQUITY NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the day of May, 2009, the following Judgment was entered against you in the above-captioned action: judgment in the amount of $50,000.00, plus interest from August 1, 2008, for failure to file a response to Defendants' Writ of Revival. Date: A'// Q/05P X00344 P thonotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Martha Shelly 447 Wileman Road Lynch Station, VA 24571 Christopher E. Rice, Esquire Attorney I.D. No. 90916 Jacob M. Theis, Esquire Attorney I.D. No. 208631 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs MARTHA SHELLY and LINDA EWING, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. STERMAC, LLC and STEVEN McCARREN, Defendants and LINDA M. EWING and DONALD G MARINKOV, Terre-Tenants : NO. 2009 - 1887 CIVIL TERM : CIVIL ACTION - EQUITY TO: LINDA M. EWING, as Terre-Tenant NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the day of May, 2009, the following Judgment was entered against you in the above-captioned action: judgment in the amount of $50,000.00, plus interest from August 1, 2008, for failure to file a response to Defendants' Writ of Revival. Date: ' 9/aF C44"6z e rothono I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Linda M. Ewing 447 Wileman Road Lynch Station, VA 24571 Christopher E. Rice, Esquire Attorney I.D. No. 90916 Jacob M. Theis, Esquire Attorney I.D. No. 208631 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717)243-3341 Attorneys for Plaintiffs MARTHA SHELLY and LINDA EWING, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. STERMAC, LLC and STEVEN McCARREN, Defendants and LINDA M. EWING and DONALD G. : NO. 2009 - 1887 CIVIL TERM : CIVIL ACTION - EQUITY MARINKOV, Terre-Tenants TO: DONALD G. MARINKOV, as Terre-Tenant NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the _1_94_Uay of May, 2009, the following Judgment was entered against you in the above-captioned action: judgment in the amount of $50,000.00, plus interest from August 1, 2008, for failure to file a response to Defendants' Writ of Revival. Date: ' Pr thonotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Donald G. Marinkov 447 Wileman Road Lynch Station, VA 24571 FARLEWlients\12532 McCarten\12532.1.pradefauh Christopher E. Rice, Esquire Attorney I.D. No. 90916 Jacob M. Theis, Esquire Attorney I.D. No. 208631 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs MARTHA SHELLY and LINDA EWING, Plaintiffs V. STERMAC, LLC and STEVEN McCARREN, Defendants and LINDA M. EWING and DONALD G MARINKOV, Terre-Tenants TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 - 1887 CIVIL TERM CIVIL ACTION - EQUITY PRAECIPE Enter default judgment in the above-captioned action in favor of Defendants and against Plaintiff Martha Shelly and Terre-tenants in the amount of $50,000.00, plus interest from August 1, 2008, for failure to file a response to Defendants' Writ of Revival. I do hereby certify that a written notice of intention to file this Praecipe was mailed to the Plaintiff Martha Shelly and Terre-Tenants at the address(es) indicated thereon, on May 7, 2009, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. Date: S -16. 07 MARTSON LAW OFFICES By. 5- /L--- Christopher E. Rice, Esquire Attorney I.D. No. 90916 Jacob M. Theis, Esquire I.D. Number 208631 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendants F RLES\Clients112532 McCarten\12532.1.I0day.default.writo@evival Christopher E. Rice, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Attorney I.D. No. 90916 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs MARTHA SHELLY and LINDA EWING, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. STERMAC, LLC and STEVEN McCARREN, Defendants and LINDA M. EWING and DONALD G. MARINKOV, Terre-tenants NO. 2009 - 1887 CIVIL TERM CIVIL ACTION - EQUITY IMPORTANT NOTICE TO: Martha K, Shelly DATE OF NOTICE: May 7, 2009 447 Wileman Road, Lynch Station, VA 24571 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. . 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. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 MARTSON LAW OFFICES By: (??A C Christopher E. Rice, Esquire I. D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendants Date: S- 7 -- 6 FAFILFS\Clients112532 McCamenU2532. 1.10day.defauh.writofrevival Christopher E. Rice, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Attorney I.D. No. 90916 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs MARTHA SHELLY and LINDA EWING, Plaintiffs V. STERMAC, LLC and STEVEN McCARREN, Defendants and LINDA M. EWING and DONALD G. MARINKOV, Terre-tenants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009 - 1887 CIVIL TERM CIVIL ACTION - EQUITY IMPORTANT NOTICE TO: Linda Ewing DATE OF NOTICE: May 7, 2009 447 Wileman Road, Lynch Station, VA 24571 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. 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. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 MARTSON LAW OFFICES Christopher E. Rice, Esquire I. D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendants Date: 5--7^07 FAFILEWhents\12532 McCatnn\12532.I.I0day.default.wtito&evival Christopher E. Rice, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Attorney I.D. No. 90916 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs MARTHA SHELLY and LINDA EWING, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. STERMAC, LLC and STEVEN McCARREN, Defendants and LINDA M. EWING and DONALD G MARINKOV, Terre-tenants : NO. 2009 - 1887 CIVIL TERM : CIVIL ACTION - EQUITY IMPORTANT NOTICE TO: Donald Marinkov DATE OF NOTICE: May 7, 2009 447 Wileman Road, Lynch Station, VA 24571 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. 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. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 MARTSON LAW OFFICES By: C Christopher E. Rice, Esquire I. D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendants Date: - d Christopher E. Rice, Esquire Attorney I.D. No. 90916 Jacob M. Theis, Esquire Attorney I.D. No. 208631 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs MARTHA SHELLY and LINDA EWING, Plaintiffs V. STERMAC, LLC and STEVEN McCARREN, Defendants and LINDA M. EWING and DONALD G MARINKOV, Terre-Tenants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 - 1887 CIVIL TERM CIVIL ACTION - EQUITY AFFIDAVIT AS TO MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he has authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and belief, Plaintiff Martha Shelly and Terre-Tenants are not in the military service of the United States of America, that he has knowledge that the said Plaintiff and Terre-Tenants are now living at: 447 Wileman Road, Lynch Station, VA 24571. Said Plaintiff and Terre-Tenants' place of employment is unknown. Sworn to and subscribed before me this L& day of May, 2009. Not,lry 1blic Christopher E. Rice, Esquire COMMONWEALTH OF PENNSYLVANIA N011M i Seat Mary M. Pltoe, N0Wy PLW Cafte 8m, CufterNmd C *^ My Cammt Mm E)q*a Aug. 18, 2011 M mW, Pennsylvania Assoeladon of Nohriss Christopher E. Rice, Esquire Attorney I.D. No. 90916 Jacob M. Theis, Esquire Attorney I.D. No. 208631 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs MARTHA SHELLY and LINDA EWING, Plaintiffs V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 - 1887 CIVIL TERM STERMAC, LLC and STEVEN McCARREN, Defendants and LINDA M. EWING and DONALD G MARINKOV, Terre-Tenants : CIVIL ACTION - EQUITY COMMONWEALTH OF PENNSYLVANIA ) SS COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, attorneys for the Defendants in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, notice of intention to enter default judgment against Plaintiff Martha Shelly and Terre-Tenants was given to them by mail on May 7, 2009. (36 /' ?- /'?' Christopher E. Rice, Esquire Sworn to and subs bed before me this _a day of May, 2009. l& , Oatc e;`, Not blic COMMONWEALTH OF PENNSYLVANIA Nolafi Seal Mary M. Pk% Nobry PLM came am, ow"law 0=* My CMW WM EVM Au9.1l k 2011 Member, Peww*eNe Meodetlon of CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Martha Shelly 447 Wileman Road Lynch Station, VA 24571 . Ms. Linda Ewing 447 Wileman Road Lynch Station, VA 24571 Mr. Donald Marinkov 447 Wileman Road Lynch Station, VA 24571 MARTSON LAW OFFICES LA -) LA BY• M . Price Ten Mt High Street Carlisle, PA 17013 (717) 243-3341 Dated: f 9 / OF THE H09 MAY 19 AH1 S; 4 8 eK? ? to?C? FZ.? ?. S3oy