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Home My WebLink About01-0049CQMMO/~W~EALTH OF PENNSYLVANfA NOTICE OF APPEAL FKOM DISTRICT JUSTICE JUDGMENT NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. Th~ ~ck will be ~ ONLY ~en this ~fi~ is ~uimd u~ P~ ~.J~ ~ I[ ~ll~t ~LAI~NT (S~ ~, RO. Rd.R NO. ~ ~e of A~oI, w~ mccad by t~ District Justice, will ~ as a 1001(6) in ~ti~ ~e Ois~ict J~tice, he ~PERSEDEAS ~ ~ i~t ~ posses~ in this cas~ FILE A COMPLAINT withi~ twe~ (20) da~ after filing his NOTICE of A~EAL. S~tu~ ~ ~t~y ~ ~ty PRAEClPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of lento to be used ONLY when appellant was DEFENDANT (see Pa. R.C,I~R No. 1001(7) in act/on before D/strict Justice. IF NOT USED, detach from copy of notice of appeal to be served ul~on appellee). Enter rule upofl w ~ - i '" - ~ , oppe~See(s), to fi~ a comp~int in ~ ~ {Common Pleas NG ~ J~ ,/-/(~ ~.it),.'L )wlthintweflty(20)doysofterserviceofruleor..~uffer entry of.judgmem~f_no~pm_~ (l) You am notified that a rule is hereby eMered upon you to file a compJaint in this appeal within twenty (20) days after the date of service of this rub upon you by persorral service or by ce-tiffed or reglstemcl mail (2) If you do not file o complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of this ~ if service was by ~il is the d~te of r~iling. COURT FILE TO BE FILED WITH PROTHONOTARY PROOF OF SERVICE OF NOTICE OF APPEAL AND' RULE TO FILE COMPLAINT (~'h~ poo¢ ef ~rvae ~¢¢US T ~E F-!L£F) WI £HfN TEN ~0) L)A YS AFTE~ hfir~[~ ~t ~ notice o ~pea~ ~hec~ ~p~;~ic~ble box~ COUNT~ OF ; ~s AFFiDAViT: ~ereby swe~r o~ affirm that ~ served ............ 19 ....... ~'~ by person~.l service [ by (certified) (register d) mai~ sendeY's receipt 6ttached hereto {5~gi~ature of alfian~ COMMONWEALTH OF PENNS"Y[ VANIA COUNTY OF: CUMBERLAND GAYLE A. ELDER ~,~s~ 507 N. YORK ST. MECHANI CSB~{G, PA (717) 766 -4575 17055 JOSEPH HEWITT 600 W.WA~%*UT STREET PALMYRA, PA 17078 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 7-KNAUER & ASSOCIATES, 41lA E.MAIN STREET MECHANICSBURG, PA 17055 VS. F-HEWITT, JOSEPH 600 W.WALNUT STREET PALMYRA, PA 17078 Docket No.: CV- 0000324- 00 Date Filed: 10/04/00 THIS IS TO NOTIFY YOU THAT: Judgment: [~_~ Judgment was entered for: (Name) [X~ Judgment was entered against: (Name)_ RRWITT, ,TO.~RPR Date: in the amount of $ __--3 ,._t61 _ 14 on: E] Defendants are jointly and severally liable. Damages will be assessed on: This case dismissed without p.Cejudice. Amount of Judgment Subject to Attachment/Act 5 of 1996 $ Levy is stayed for days or L~ generally stayed. Objection to levy has been filed and hearing will be held; Place: (Date of Judgment) (Date & Time) Amount of Judgment $ 3,294.64 Judgment Costs $ 66.50 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 3,361.14 Post Judgment Credits Post Judgment Costs Certified Judgment Total $ $ Time: 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, ~.E. AS, CIVIL DIVISION, YOU MUST INCLUDE A DOPY OFTHIS NOTICE OF JUDGMEbFF/TRANSC~PClSFORM WITH YOUR NOTICE OF APPEAL. -'. ....... - ..... "" --/' ' /7>/"/':'-.-. ~(/t. 6 '~C:Date ' / '?': ~' t(,..:tf/"r-: ::."::.., ' District Justice cert fy t~at th~s ~s a true and correct copy of thc_~'ecord/5~i~e j~roc~Jmgs containing the-judgment. ,/' . . ,, My commission exoires first Monda:, of January, 2006 SEAL AOPC 315-99 PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proo! O! se vice MU$7 BE F/LED WITHIN TEN (10) DAYS AFTER filing the notice of appeal, Check applicable boxes) AFFIDAVIT: ~ hereby ~wear or affirm that t served ~/ ~' L ~ {"~ a copy of the Not~ce of Appeal Comm~ P~eas No, ~ / ~ ~ ~_, upon the Distdct Justice des~gnaled there~n on {d~te 0¢ se¢~/ce~ _¢ / ' O~ ~ ~. ~0 / , [~ by persor~al service ~ by (certified) (registered] mail se~der'~ ~/~ ~ , ~_ ~ by person'at ser¢ice ~by (certified) (registered) mai~, sender's receipt attached hereto [? ar, d further that I serv'~d the Rule to File a Complaint accom panying the above Notice of Appeal upon the appellee(s) to whom the Rt~¢~) was addressed or~ ~-¢ ~ ' ..... 1"'9,,~_, [.~ by personal service~by (certified) (registered) k OMMONWEALTH Of PENNSYLVANIA COURT Of COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL DISTRICT JUSTICE JUDGMENT NOTICE OF APPEAL Notice is given that the al:hoellant has filed in the above Court of Common I~ec~s an appeal from the judgment rendered by the District Justice on the clate and in the case mentioned below. CV 19 LT 19 This block will be signed ONLY when this notation is required under Pa. R.CJ~.J.P. Nc~ 100BB. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case Signature of Prothonotary ~ Deputy If appe#a~t was CLAIMANT (see Pa. R.C.P,J.P. No. 1001 (6) in aCtic~rt before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after __ filing his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa, R.C.P.J.P. No. 7001(7) in action betore District Justice. IF NOT USED, detach from copy ot no~ce of appeal to be served upon appellee). PRAECIPE: To Prothonotary : " i>- , ,~ ./ . IComme. Pleas t,~ RULE: To , appe#ea(s), to file a complaint in this appeal W"I [,~., ~?~ ~.~ ) within twenty {20) days after service of rule o~ suffer entry of iudgrnont of~n~.l~OS- age~ i. (1) You are notified that cs rule is hereby e~tered upon you to file a complaint in this epped within twenty {20) days after the date of service of this rule u~ you I:~ (2) If you da not file a c~*:w~i~in this time, e..-IU~NT,:. OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of Ser~ce/°~i~,, rule if service, wes by'raeil~s the date of mailing. COURT FILE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KNAUER & ASSOCIATES, L.S.C Plaintiff V. JOSEPH A. HEWITT Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY No. 01-49 Civil Term JURY TRIAL DAMANDED NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without fiffther notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other fights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 NOTICIA Le han demaandado a usted en la corte. Si usted quieie defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persoa o por abogado y archivar en la corte enforma escrita sus defensas o sus objections a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importanted para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 Respectfully submitted, Date: March 2, 2001 DAVID W. KNAUER, L.S.C. v . au r, Esqmre Attorney for the Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 KNAUER & ASSOCIATES, L.S.C Plaintiff JOSEPH A. HEWlTT Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY No. 01-49 Civil Term JURY TRIAL DAMANDED COMPLAINT 1. The Plaintiff Knauer and Associates is a corporation organized and doing business under the laws of the Commonwealth of Pennsylvania with an address of 41 lA East Main Street, Mechanicsburg, Pennsylvania 17055, an assignee of David W. Knauer P.C. 2. The Defendant Joseph A. Hewitt is an adult individual with an address of 600 West Walnut Street, Palmyra, Pennsylvania 17078. 3. The Plaintiff and its assignor provided legal services for the Defendant for several matters including but not limited to representing him in a will contest with respect to the Estate of Bessie A. Wolfersberger and matters involving Tuscorora Township, Perry County, Pennsylvania. 4. The Plaintiff and its assignor and the Defendant agreed that the representation would be on an hourly basis. 5. The Plaintiff rendered to the Defendant bills totaling $9,563.15, to wit: a.) February 19, 1998 bill for services rendered with respect to the Estate of Bessie A. Wolfersberger in the amount $5,482.50; b.) February 19, '1998 bill for services rendered with respect to zoning and other matters involved with Tuscarora Township in the amount of $1,190.15; c.) March 25, 2000 bill for services rendered with respect to the Estate of Bessie A. Wolfersberger in the amount of $2,485.50; d.) January 26, 2001 bill for services rendered with respect ot the Estate of Bessie A. Wolfersberger in the amount of $405.00 The Plaintiff has marked as exhibits "A" through "D", attached hereto and incorporated herein by reference thereto true and correct copies of the aforesaid bills. 6. The Plaintiff provided to the Defendant a recapitulation of the bills, showing the amount of the bills and the funds paid. The Plaintiff marks as Exhibit "E", attaches hereto and incorporated herein by reference thereto true and correct copies of the aforesaid recapitulation. 7. The Defendant paid $6,050.00, leaving a balance owed of $3,108.15. 8. The Plaintiff made demand on the Defendant to pay the remaining outstanding bills by letters dated February 14, 2000, March 25, 2000, May 24, 2000 and August 28, 2000. The Plaintiff has marked as Exhibit "F" through 'T' and incorporated herein by reference thereto true and correct copies of the aforesaid letters. 9. In addition to the aforesaid bills, the Plaintiff also performed additional services between February 7, 2000 and August 28, 2000 in the amount of $405.00 bills. 10. The Defendant refused to pay the aforesaid unpaid balance of the 11. The Plaintiff and its assignor's bills were the usual, customary, and reasonable charges the Defendant agreed to pay. 12. The Plaintiff is entitled to payment of the unpaid balance of the bills. WHEREFORE, the Plaintiff demands judgment in its favor and against the Defendant in the amount of $3,513.15 with interest on the unpaid balances and costs of suit. Date: March 2, 2001 Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. Da vi~l'T/~/. '~dauer, 'Esquire Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 VER'IFICATION Subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to ,=uthorities, we hereby certify that the facts in the ~'oregoing pleading ere true and correct to the best of our information and belief. KNAUER & ASSOCIATES, L.S.C Plaintiff JOSEPH A. HEWITT Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY No. 01-49 Civil Term JURYTRIALDAMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 2nd day of March, 2001, serve a true and correct copy of the within document on all counsel of record by United States mail, first class, prepaid addressed as follows: Joseph A. Hewitt 600 West Walnut Street Palmyra, PA 17078 Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790