HomeMy WebLinkAbout09-7371
CA - T37 I Give ( IErrn
BLUE MT. ANESTHESIA In the Court of COMMON PLEAS of
Plaintiff Cumberland County, Pennsylvania
NO.
V. Revival of NO. 04-4952 CIVIL TERM
WILLIAM S. MCKEEHAN
Defendant : PRAECIPE FOR WRIT OF REVIVAL
TO THE PROTHONOTARY:
Please issue Writ of Revival of lien of Judgment entered at above case number and enter it
in the Judgment Index against:
WILLIAM S. MCKEEHAN
235 SPRINGVIEW ROAD, CARLISLE PA 17013 (CUMBERLAND COUNTY),
and
n/a
n/a
Defendant of
Terre tenant of
in the amount of $ 1,065.00 with interest accruing from the original Judgment date of
September 30, 2004.
TO Cumberland County
Prothonotary
Dated: October 22, 2009
Robert D. Kodak
Attorney for Plaintiff
Telephone: 717Z238-7159
Supreme Court Attorney ID No. 18041
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
BLUE MT. ANESTHESIA ASSOCIATION
Vs.
WILLIAM S. McKEEHAN
CIVIL ACTION LAW
No 09-7371 CIVIL TERM
TO WILLIAM S. McKEEHAN
235 SPRINGVIEW ROAD
CARLISLE, PA 17013
WRIT OF REVIVAL
You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of
the judgment entered to
No. 04-4952 Civil Term
The Plaintiff claims that the amount due and unpaid is $1,065.00 with interest from 9/30/04.
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 will be entered.
Costs $ $48.25 PD ATTY
$ 2.00 DUE CO
Date 10/27/09
(Seal)
ROBERT D. KODAK, ESQUIRE
KODAK & IMBLUM
PO BOX 11848
HARRISBURG, PA 17108-1848
Attorney for the Plaintiff
717-238-7159
ID#18041
lzz'?q?
C is R. Long, P o o ary
Deputy
R Thomas Kline
Sheriff
Ronny R Anderson
Chief Deputy
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
RIM- FIM
OF THE ftTHNOTAflY
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
????? at ?umbrrf?
1009 NOV 18 PM 2' 03
OFFICE OF 'HE S-ERIFF PENNS` LVXJIA
Blue Mt. Anesthesia Association Case Number
vs. 2009-7371
William S. McKeehan
SHERIFF'S RETURN OF SERVICE
11/16/2009 11:45 AM - Jason Vioral, Corporal, who being duly sworn according to law, states that on November 16,
2009 at 1145 hours, he served a true copy of the within Writ of Revival, upon the within named defendant,
to wit: William S. McKeehan, by making known unto himself personally, at 235 Springview Road Carlisle,
Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the
said true and correct copy of the same.
SHERIFF COST: $33.84
November 17, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
(c) CourtySuite Shenff. Teleosoft. Inc.
BLUE MT. ANESTHESIA ASSOC : In the Court of COMMON PLEAS of
Plaintiff :Cumberland County, Pennsylva
NO. 09-7371 CIVIL TERM
v, :Revival of NO. 04-4952 CIVIL TERM _
C o ~~'.
WILLIAM S. MCKEEHAN ~L~ ` .~~
m ~,, a~ T
Defendant WRIT OF REVIVAL ~, ~:.~ ~ n-+r.-T',.
~~, ~;. .,. -r m
r
TO: PROTHONOTARY, COURT OF COMMON PLEAS ~ ^` ..~ -y~
CUMBERLAND COUNTY, PENNSYLVANIA `~' ``
'A
PRAECIPE FOR DEFAULT JUDGMENT of WRIT OF REVIVAL o
Enter judgment in favor of theabove Plaintiff and against the above Defendant(s),
WILLIAM S. MCKEEHAN, named for failure within the required time to plead to the Writ
in the above-captioned case and assess the Plaintiff's damages as follows:
Amount claimed in Plaintiff's Praecipe for Writ of Revival $1,065.00 +
Interest continuing accrual from 9/30/04, at the statutory rate of 6% per annum.
I hereby certify that a written Important Notice of the intent to file this Praecipe was
mailed or delivered to the Defendant(s) and/or his/her Attorney of Record, if any, after the
default occurred and at least ten (10) days prior to the date of the filing of this Praecipe and
a copy of the notice(s) is/are attached.
KODAK & IMB M, P.C.
y .,
~~,.
By -
Robert D. Kodak, Attorney for Plaintiff
DATED: l/l~f/lo
judgment entered and damages assessed e.
Prothonotary $ t~. oo P A A TT/
CY.'a' 83- (08
e~a,3t~~
~o}~, ~Ouke~
LAW OFFICES OF
KODAK &IMBLUM, P.C.
CAMERON MANSION
Robert D. Kodak 407 NORTH FRONT STREET
Gary J. Imblum POST OFFICE BOX 11848
HARRISBURG, PA 17108-1848
www.kodak-imblum.com
December 10, 2009
WILLIAM S MCKEEHAN
235 SPRINGVIEW ROAD
CARLISLE PA 17013
RE:
VS:
Dear Mr. McKeehan:
Blue Mt. Anesthesia Association
William S. McKeehan
Our File No. 30428
No. 09-7371 Civil, Court of Common Pleas
Cumberland County, Pennsylvania
Telephone
717.238.7152
CC~~~
In accordance with Pennsylvania Rules of Civil Procedure 237.1, we are enclosing herewith a
Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the
Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the
Complaint filed against you to the above term and number, nor has any attorney entered an appearance
on your behalf.
Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take
action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office
of the Prothonotary of Cumberland County, Pennsylvania, to enter Judgment against you in the amount
as set forth in said Complaint.
Very truly yours,
RDK/bjh
enclosure
KODAK &IMBLUM, P.C.
Robert D. Kodak
robert.kodak@kodak-imblum.com
cc VALLEY CREDIT SERVICE INC 1966-DOS 11-20-02
PO BOX 2162
HAGERSTOWN MD 21742
BLUE MT. ANESTHESIA ASSOCIATION
Plaintiff
v.
WILLIAM S. McKEEHAN
Defendant
COPY
IN THE COURT OF COMMON
CUMBERLAND COUNTY, PENNSYLVANIA
N0.09-7371 CIVIL TERM
CIVIL ACTION -LAW
IMPORTANT NOTICE
TO: WILLIAM S. McKEEHAN, Defendant(s)
DATE OF NOTICE: December 10.2009
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 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 PRO VIDE YOU
WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
TWO LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
BLUE MT. ANESTHESIA ASSOC
Plaintiff
v.
WILLIAM S. MCKEEHAN
Defendant
To WILLIAM S. MCKEEHAN, Defendant(s)
In the Court of COMMON PLEAS of
Cumberland County, Pennsylvania
NO. 09-7371 CIVIL TERM
Revival of NO. 04-4952 CIVIL TERM
WRIT OF REVIVAL
You are hereby notified that on ~Q~ i ~ , 20 ~~ the following
(Judgment) has been entered against you in the above-captioned case.
DATE:
~~ n i^`
Prothonotary
I hereby certify that the name and address of the proper person(s) to receive this
notice is:
WILLIAM S MCKEEHAN
235 SPRINGVIEW ROAD
CARLISLE PA 17013
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS)
P.R.C.P. 3101 to 3149
BLUE MT. ANESTHESIA ASSOC
Plaintiff
VS
WILLIAM S. MCKEEHAN
235 SPRINGVIEW ROAD
CARLISLE, PA 17013
DEFENDANT(S)
IN THE COURT OF COMMON PLEAS OF
Cumberland COUNTY, PENNSYLVANIA
Writ No. Term 20
No. 2009-737112004-4952 Term 20 09
Amount Due
9/30/04 jdmt $ 1,065.00
Interest from jdmt -4/25/ 12
$.18 per diem ............... $ 497.52
Atty's Commission
5% statutory rate .......... $ 53.25
Costs (to be determined) $
TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE M R; , - s
rr1w A„ -.
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania
(2) against WILLIAM S. MCKEEHAN r.- -tom,
WLC1.Cflµ?(il lllJ?,
(3) and against a ee s ;
?? rs1
(4) and index this writ
(a) against WILLIAM S. MCKEEHAN
Defendant(s) and
(b) against
arnisneeks),
as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows:
(Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy):
LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN
CUMBERLAND COUNTY, INCLUDING BUT NQLT LIMITED TO FURNITURE, JEWELRY, ELECTRONICS, SUPPLIES, ETC.,
*a8.50 a o aTM
(5) Exemption has (not) been waived. / 9.2- s . (?"' S f 0., '
2. sK -
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02, rU - "
Dated 4/23/12
co
ass"
Ter4b. Kodak, Esquire
Box 11848
Harrisburg, PA 17108
(717) 238-7159
Attorney For Plaintiff (s)
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-7371 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BLUE MT. ANESTHESIA ASSOC., Plaintiff (s)
From WILLIAM S. MCKEEHAN, 235 SPRINGVIEW ROAD, CARLISLE, PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL
PROPERTY INCLUDING BUT NOT LIMITED TO FURNITURE, JEWELRY,
ELECTRONICS, SUPPLIES, ETC.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $1,065.00 L. L. $.50
Interest FROM JDMT 4/25/12 - S.18 PER DIEM - $497.52
Atty's Comm5 % $53.25 Due Prothy $2.25
Atty Paid $127.09 Other Costs
Plaintiff Paid
Date: APRIL 26, 2012
David D. Buell, Prothonotary
(Seal)
-,4-. 0 -P --"I /Z
B
_y: -4zd-a
Deputy
REQUESTING PARTY:
Name JEFFREY, L. TROUTMAN, ESQ.
Address: P.O.BOX 11848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7159
Supreme Court ID No. 53984
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
.iy R Anderson
,eriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SJi t ???ik= i S_,,, .
Blue Mt. Anesthesia Association
Case Number
vs.
William S. McKeehan 2009-7371
SHERIFF'S RETURN OF SERVICE
05/02/2012 08:42 PM - Ryan Burgett, Deputy , being duly sworn according to law, states that on May 02, 2012 at 8:42
PM hours, served the requested Writ of Execution and Claim for Exemption Form by "personally" handing
a true and attested copy to a person representing themselves to be the Defendant, to wit: William S.
McKeehan at 235 Springview Road, West Pennsboro Township, Carlisle, PA 17013, informed Defendant
of contents of same. LEVY NOT COMPLETED AT THIS TIME - DEFENDANT REFUSED TO ALLOW
DEPUTIES TO ENTER AND INVENTORY. Letter mailed to defendant 05-04-12.
07/30/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned STAYED. Writ expired.
SHERIFF COST: $48.60
July 30, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
:? ?.S P C,