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HomeMy WebLinkAbout10-3115GREATFUL STATE, a Pennsylvania general partnership, KEVIN RYCKIS, SURIA RYCKIS and DONOVAN RYCKIS, Plaintiffs V. KEVIN TAYLOR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOCKET NO. /( - 3//5- b 'v, i PRAECIPE TO TRANSFER AND ENTER JUDGMENT To the Prothonotary: Pursuant to Pa.R.C.P. 3002, please enter judgment on behalf of Plaintiff Greatful State, Kevin Ryckis, Suria Ryckis and Donovan Ryckis and against Defendant Kevin Taylor in the amount of $4,827.22 plus fees and costs. A judgment was previously entered by Franklin County Court of Common Pleas as endorsed by the certified docket entries attached hereto and made a part hereof as Exhibit A. Sincerely, SALZMANN HUGHES, P.C. Date: 51121"16 E. Lee Stinnett II, Esquire Attorney I.D. No. 307128 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 (717) 249-6333 FAX: (717) 249-7334 Attorney for Plaintiff -, CV LL) ,.. C .? x a h, U ,?qj 9ge COMMONWEALTH OF PENNSYLVANIA, SS. COUNTY OF FRANKLIN 1, Linda L. Beard, Prothonotary of the Court of Common Pleas in and for said County, do hereby certify that the foregoing is a full, true and correct copy of the whole record of the case therein stated, wherein .. GREATFUL STATES a PA general, ,pal?nership=KEVIN, RYCKIS_,, , SURIA, RYCKIS, ,& , DONOVAN .RYCKIS Plaintiff, and ...... X9VIN..TAMOR ...................................... Defendant, so full and entire as the same remains of record before the said Court, as No. C?0097;M7 . IN TESTIMONY WHEREOF„ I have hereunto set my hand and affixed the seal of said Court, this December 15, 2009, , , , , Prothonotary I DOUGLAS W. HERMAN , .. President Judge of the Court of Common Pleas of the 39th Judicial District, Franklin County Branch, do certify that Linda L. Beard, Prothonotary, by whom the annexed record, certificate and attestation were made and given, and who, in her own proper handwriting, thereunto subscribed her name and affixed the seal of the Court of Common Pleas of said County, was at the time of so doing and now is Prothonotary in and for said County in the Commonwealth of Pennsylvania, duly commissioned and qualified; to all of whose acts, as such, full faith and credit are and ought to be given, as well in Courts of Judicature as elsewhere, and that the said record, certificate and attestation are in due form of law and made by the proper office ......... .. President Judge COMMONWEALTH OF PENNSYLVANIA, SS. COUNTY OF FRANKLIN I, Linda L. Beard, Prothonotary of the Court of Common Pleas of the 39th Judicial District, Franklin County Branch, do hereby certify that the Honorable ...... DOUGLAS , W., ,HERMAN bywhom the foregoing attestation was made, and who has hereunto subscribed his name, was at the time of making thereof and still is President Judge of the Court of Common Pleas, in and for said County, duly commissioned and qualified; to all whose acts, as such, full faith and credit are and ought to be given, as well in Courts of Judicature as elsewhere. IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the seal of said Court, this .... a??' . , , day of . pAggT?er , , . , , .. A.D. 119.2009 ... x.J ................... Prothonotary ro .? :ra :tzj fyD c. M CD : b ZI 0-1 Fah o tj 171 'TJ b o o .00 :Ln 0 v til O /ro C G y :I-h m ft rt :M m :P O H m H O n b :o H :N co m .m ' l Y . W W F4 0 00 Z 'M tZI -cc H z:w C? qd • p H• 13140121.520^° Franklin County Prothonotary's Office PYS510 Civil Case Print 2009-02773 GREATFUL STATE PARTNERSHIPS (vs) KEVIN TAYLOR Reference No..: Case Type.....: D J APPEAL Judgment...... .00 Judge Assigned: WALSH RICHARD J Disposed Desc.: ------------ Case Comments ------------- Pages , 1 Filed......... 6/24/2009 Time.......... 3:49 Execution Date 0/00/0000 Jury Trial.... Disposed Date. 0/00/0000 Higher Crt 1.: Higher Crt 2.: ******************************************************************************** General Index Attorney Info GREATFUL STATE PARTNERSHIPS PLAINTIFF SCHELLHASE ADAM R 254 STONEHOUSE ROAD MARTINEAU DAVID H CARLISLE PA 17013 118 WALNUT STREET APARTMENT 201 WAYNESBORO PA 17268 RYCKIS KEVIN PLAINTIFF SCHELLHASE ADAM R MARTINEAU DAVID H RYCKIS SURIA PLAINTIFF SCHELLHASE ADAM R MARTINEAU DAVID H RYCKIS DONOVAN PLAINTIFF SCHELLHASE ADAM R MARTINEAU DAVID H TAYLOR KEVIN DEFENDANT 36 BURNT HOUSE ROAD CARLISLE PA 17015 Judgment Index Amount Date Desc TAYLOR KEVIN 4,827.22 11/17/2009 JUDGMENT ******************************************************************************** * Date Entries ******************************************************************************** 6/24/2009 NOTICE OF APPEAL FROM DISTRICTS JUSTICE JUDGMENT WITH PRACIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE WITH ALL COPIES RETURNED TO APPELLANT FILED. ------002 Image page(s) exist(s) for this entry ---------------- _ _ ___ -------------------- _ 7 06/2009 PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT FILED. --001-Image page(s) exist(s) for this entry -------------------- _________ ------------------------------- 7 16/2009 COMPLAINT FILED WITH COPIES RETURNED TO ATTY SCHELLHASE. 024 Image page(s) exist(s) for this entry ------------- - _ _ --------------- ----- _ ___ 8/05/2009 LETTER OF RESPONSE OF DEFENDANT KEVIN TAYLOR FILED. (FACSIMILIE) -003-Image page(s) exist(s) for this entry --------------------- ---------------- ___ 8/31/2009 PLAINTIFFS PRELIMINARY OBJECTIONS TO DEFENDANTS RESPONSE TO PLAINTIFFS COMPLAINT WITH COPIES FILED AND COPY SENT TO ATTORNEY. -_-_-006 Image page(s) exist(s) for this entry ------------------ ------------------------ 9/03/2009 ORDER UPON CONSIDERATION OF PLAINTIFFS' PRELIMINARY OBJECTION ISSUING A RULE UPON THE DEFENDANT TO SHOW CAUSE FILED. BY RICHARD J WALSH JUDGE. ---001-Image-page(s)-exist(s) for this entry 9/03/2009 NOTICE OF ENTRY OF ORDER OR DECREE PURSUANT TO PA R.C.P NO 236 ------------------------------------------ NOTIFICATION. THIS DOCUMENT HAS BEEN FILED IN THIS CASE. PROTHONOTARY FRANKLIN COUNTY PA. ADAM R SCHELLHASE ESQ VIA REGULAR MAIL. KEVIN TAYLOR/DEFENDANT VIA REGULAR MAIL. ---------- _ _ _ 10/21/2009 MOTION TO MAKE RULE ABSOLUTE FILED AND SENT UPSTAIRS. 006 Image page(s) exist(s) for this entry 13114012152CO9 Franklin County Prothonotary's Office Pa e 2 PYS510 Civil Case Print g 2009-02773 GREATFUL STATE PARTNERSHIPS (vs) KEVIN TAYLOR Reference No..: Filed........: 6/24/2009 Case Type...... D J APPEAL Time.......... 3:49 Judgment...... 00 Execution Date 0/00/0000 Judge Assigned: WALSH RICHARD J Jury Trial.... Disposed Desc.: Disposed Date. 0/00/0000 ------------ Case Comments Higher Crt 1.: Higher Crt 2.: 10/28/2009 ORDER DATED OCT 27 2009 UPON CONSIDERATION OF MOTION MAKING THE RULE ABSOLUTE AND DEFENDANTS RESPONSE TO PLAINTIFF'S COMPLAINT IS HEREBY STRICKEN AND DEFENDANT IS HEREBY DIRECTED TO FILE AN ANSWER TO PLAINTIFF'S COMPLAINT WITHIN 10 DAYS AFTER THE DATE OF THIS ORDER FILED. BY RICHARD J WALSH JUDGE. ---001-Image-page(s)-exist(s)-for this entry 10/28/2009 NOTICE OF ENTRY OF ORDER OR DECREE PURSUANT TO PA R.C.P NO 236 NOTIFICATION. THIS DOCUMENT HAS BEEN FILED IN THIS CASE. PROTHONOTARY FRANKLIN COUNTY PA. DAVID H MARTINEAU ESQ VIA REGULAR MAIL. KEVIN TAYLOR/DEFENDANT VIA REGULAR MAIL. 11/17/2009 PRAECIPE FOR ENTRY OF JUDGMENT OF DEFAULT AGAINST THE DEFENDANT IN ---------------------------------------------------- THE AMOUNT OF $4,827.22 INCLUDING LAWFUL INTEREST, COSTS AND ATTORNEY FEES FILED. -010-Image-page(s)-exist(s) for this entry 11/17/2009 NOTICE OF ENTRY OF JUDGMENT SENT VIA REGULAR MAIL TO DEFENDANT(S). 001 Image page(s) exist(s) for this entry - - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - - - * Escrow Information * Fees & Debits Be?E ******************************q*Ba****P#m***/Ad'******E*d'*Ba******************* DJ APPEAL DISC 5.00 5.00 .00 DJ APPEAL JCP 10.00 10.00 .00 DJ APPEAL TAX .25 .25 APPEAL-AUTO FEE 5.00 5.00 ..00 00 JUDGMENT/PRAE 14.00 14.00 .00 APPEAL D J 60.00 60.00 .00 ------------------------ ------------ 94.25 94.25 .00 ******************************************************************************** * End of Case Information ******************************************************************************** LINDL. BEAR !"?! R Y GREATFUL STATE, a Pennsylvania IN THE COURT OF COMMON PLEAS OF general partnership, KEVIN RYCKIS, FRANKLIN COUNTY, PENNSYLVANIA SURIA RYCKIS and DONOVAN RYCKIS, V. /KEVIN TAYLOR, CIVIL ACTION - LAW Plaintiffs 117i) DOCKET NO. 2009-2773 ` 1 Defendant JURY TRIAL DEMANDS DCFA TO THE PROTHONOTARY: y .., C) r O O C:7 -4 E) W .0 - - - - v D 3> --? ?; "` .?? ? v Please enter judgment of default in favor of the Plaintiff, GREATFUL STATE, KEVIN RYCKIS, SURIA RYCKIS and DONOVAN RYCKIS, and against the Defendant, KEVIN TAYLOR, for Defendant's failure to plead to the complaint in this action within the required time. The complaint contains a notice to defend within 20 days from the date of service thereof. Defendant was served with the complaint on or about July 16, 2009, and Defendant's answer was due to be filed on or about August 5, 2009. Attached hereto as Exhibit "A" is a copy of Plaintiffs Certificate of Service certifying; service of the Complaint. Attached hereto as Exhibit "B" is the Court's Order of October 27, 2009 striking Defendant's response to Plaintiffs' Complaint and directing Defendant to file an Answer within ten (10) days. Also attached as Exhibit "C" is a copy of Plaintiff's written Notice of Intention to File a Praccipe for Entry of Default Judgment, which I certify was mailed by regular mail to the Defendant at its last known address on or about November 4, 2009, which is at least ten (10) days prior to the filing of this Praecipe. Please assess damages in the amount of $4,827.22, being the amount demanded in the complaint, including lawful interest from the date of filing, costs and attorney fees. SALZMANN, HUGHES & FISHMAN, P.C. By: Awl Adam R. Schel lase, Esquire Attorney I.D. No. 82468 David H. Martineau, Esquire Attorney I.D. No. 84127 354 Alexander Spring Road, Suite I Carlisle, PA 17015 (717) 249-6333 November 17, 2009 Attorneys for Plaintiff LJ?D.4 L.:.BEA RD, PR 7i`KX ¢ ,{RY EXHIBIT "A" CER'T'IFICATE OF SERVICE OF COMPLAINT CERTIFICATE Or SERVICE I, Adam R. Shellhase, Esquire, hereby certify on the day of.July 2009, 1 served a true and correct copy of the foregoing Complaint upon Defendant by depositing the same in the United States mail, first class, postage prepaid, addressed as follows; Kevin Taylor 36 Burnt House Road Carlisle, PA 17015 Adam R. Sh llhase, Esquire EXHIBIT "B" ORDER OF OCTOBER 27, 2009 CERTIFICATE OF SERVICE I, David H. Martineau, Esquire, hereby certify on the 4°i day of November 2009, I served a true and correct copy of the foregoing Notice upon Defendant by depositing the same in the United States mail, fist class, postage prepaid, addressed as follows: Kevin Taylor 36 Burnt House Road Carlisle, PA 17015 David H. Martineau, Esquire V GREATFUL STATE, a Pennsylvania general partnership, KEVIN RYCKIS, SURIA IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA RYCKIS and DONOVAN RYCKIS, CIVIL ACTION - LAW Plaintiffs DOCKET NO. 2009-2773 KEVIN TAYLOR, Defendant JURY TRIAL DEMAND D ORDER AND NOW, this 2-7 day of 2009, upon consideration of the Plaintiff's Preliminary Objection to Defendant's Response to Plaintiffs Complaint and Motion to Make Rule Absolute, it is ORDERED that: 1. This Courts Rule of September 3, 2009 is hereby made absolute; and 2. Defendants response to Plaintiffs Complaint filed August 5, 2009 is hereby stricken; and 3. Defendant is hereby directed to file an Answer to Plaintiffs Complaint within ten (10) day after the date of this Order. I& A' ap ?ozq. BY THE COURT: Inv? -A# J. f-.1 TEST A T- UE. V!0PY AR}" UN.JDA L.'BBARA. PROPHO.N©'r EXHIBIT "C" NOTICE OF INTENT TO FILE DEFAULT JUDGMEN'C PURSUANT TO Pa.R.C.P. 237.1(a) SALZMANN HU GRES,RCe Attorneys at Law EXPERIENCE • INTEGRITY • INNOVATION 79 St. Paul Drive • Chambersburg, PA • 17201 .(717)263-2121 • Fax: (717) 263.0663, 354 Alexander Spring Road • Suite I • Carlisle, PA • 17015 • (717) 249.6333 • Fax: (717) 249.7334 239 E. Main St. • Waynesboro, PA • 17268 (717) 762-3170 Fax: (717) 762.0988 105 N• Front St. • Suite 401 • Harrisburg, PA 17101 .(717) 234-6700 • Fax: (717) 249-7334 'Please reply to Carlisle Office November 4, 2009 Kevin Taylor 36 Burnt House Road Carlisle, PA 17015 '`' i l.. Re: Greatful State, et al. v. Taylor Franklin County Civil Action-Docket No. 2009-2773 Mr. Taylor: Enclosed for service is an Important Notice of Greatful State's intent to seek default judgment and a copy of the Order issued by The Court of Common Pleas of Franklin County. Sincerely, SALZMANN HUGHES, P.C. David H. Martineau Enclosure ?C??ll4?ntr;lliu in Lllu irrun?cttt.?l, L.:nd Use, Municipal, Real Est,lte, Corporate, Estate Planning andndministration, and General Civil Liu.,,,aiol ATTORNEYS G. Bryan Salzmann, Esq. James D. Hughes, Esq. Adam R. Schellhase, Esq. Charles E. Zaleski, Esq. Thomas J. Finucane, Esq. Eileen C. Finucane, Esq. Stephen E. Patterson, Esq. LeRoy S. Maxwell Jr., Esq. Nancy H. Meyers, Esq. Ann F. DePaulis, Esq. Patricia R. Brown, Esq. William W. Thompson, Esq. Melissa K. Dively, Esq. Rebecca R. Hughes, Esq. Susann B. Morrison, Esq. Laura Rebecca Ables, Esq.' David H. Martineau, Esq. Kurt E. Williams, Esq. Samuel E. Wiser, Jr., Esq. George F. Douglas, III, Esq. Donald E. LeFever, Esq. 'Also Admiticd to Georgia Bar :-°ar: WWW. SALZMANNHUGHEsS.COM _.n._. .. GREATFUL STATE, a Pennsylvania general partnership, KEVIN RYCKIS, SURIA RYCKIS and DONOVAN RYCKIS, Plaintiffs V. KEVIN TAYLOR, Defendant IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOCKET NO. 2009-2773 ?'" JURY TRIAL DEMANDEI9- To: KEVIN TAYLOR Date of Notice: November 4, 2009 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS O + +ICE 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 FE E OR NO FEE. Pennsylvania Lawyer Referral Service Pennsylvania Bar Association 100 South Street P.O. Box 186 Harrisburg, PA 17108 Telephone No. (800 -7375 David H. Martineau, Esquire Salzmann Hughes, P.C. 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 (717) 249-6333 Attorney for Plaintiffs CERTIFICATE OF SERVICE I, Adam R. Schcllhase, Esquire, hereby certify on the 17`x' day of November 2009, I served a true and correct copy of the foregoing Praecipe to Enter Default Judgment upon Defendant by depositing the same in the United States mail, first class, postage prepaid, addressed as follows: Kevin Taylor 36 Burnt House Road Carlisle, PA 17015 Adam It. Schellhase, Esquire r ,?kmvng the Ptarbs anb praretbingS enrolled in the Court of Common Pleas in and for the .................... County of Franklin in the Commonwealth of Pennsylvania, to No. ...?t?009-2773 is contained the following: #2009-2773 COPY OF . . . . .. ...................... DOCKET ENTRY GREATFUL STATE, a Pennsylvani gerneral partnership, KEVIN RYCKIS,SURIA RYCKIS and DONOVAN RYCHIS, Plaintiff VS. SEE ATTACHED KEVIN TAYLOR, Defendant SVIOV3 IN3I3 MO SVIOV3 3HMS NIOM3 IsaxaINI ZZ'LZ8`i7$ 60OZ LT AON £LLZ-600Z# sIxOMI MVAONOQ QNV sIxoml Villas `sIxO)L2I NIAHx `dTgsaau3jua TP.zauaO yd E quam'8pnf iTnvjaa 2IOUVI NIAUx `alvis afialvaag ,LNCIOIHV .LN3D oanf MV3A WH31 ON N3I'I 30 331,LNIV'Id .LNVQN3S3a 30 3.LVQ 32IIIZVN s3IxZAI:g X3(INI LNgW'DUflf GREATFUL STATE, a IN THE COURT OF COMMON PLEAS Pennsylvania general partnership, OF CUMBERLAND COUNTY, KEVIN RYCKIS, SURIA PENNSYLVANIA RYCKIS and DONOVAN RYCKIS, CIVIL ACTION - LAW Plaintiffs 3l/S ?l l/i v. DOCKET NO. KEVIN TAYLOR, Defendant NOTICE OF FILING JUDGMENT TO: Kevin Taylor You are hereby notified that on May 12, 2010, the following judgment has been entered against you in the above-captioned case. $4,827.22 plus interest and costs Date: 5 /a Prothonotary I hereby certify that the names and addresses of the proper person to receive this notice are as follows: Defendants: Kevin Taylor 36 Burnt House Road Carlisle, PA 17015 Creditor/Plaintiff: Greatful State Partnerships 254 Stonehouse Road Carlisle, PA 17013 I hereby certify that the precise address as to Plaintiff and last known address as to Defendant are correct as set forth above. E. Lee Stinnett II, Esquire Counsel for Plaintiff GREATFUL STATE, a Pennsylvania IN THE COURT OF COMMON PLEAS OF general partnership, KEVIN RYCKIS, CUMBERLAND COUNTY, PENNSYLVANIA SURIA RYCKIS and DONOVAN RYCKIS, CIVIL ACTION - LAW Plaintiffs V. DOCKET NO. 2010-3115 KEVIN TAYLOR, Defendant -, rnw .w PRAECIPE TO SATISFY AND DISCONTINUE -C -0i1f D .. cn -n C:) y TO THE PROTHONOTARY: , - ? Plaintiff, Greatful State Partnership, hereby advises the Prothonotary of Cumberland County that the above captioned matter against Defendant, Kevin Taylor, has been satisfied and hereby requests that the judgment against the Defendant, Kevin Taylor be marked satisfied. David H. Martineau, Esquire Attorney ID No. 84127 Salzmann Hughes, P.C. 354 Alexander Spring Road, Suite 1 Carlisle, PA 17015 (717) 249-6333 May 11, 2012 Attorney for Plaintiff CERTIFICATE OF SERVICE I, David H. Martineau, Esquire, hereby certify on the I lth day of May 2012, I served a true and correct copy of the foregoing document upon Defendant by depositing the same in the United States mail, first class, postage prepaid, addressed as follows: Kevin Taylor 36 Burnt House Road Carlisle, PA 17015 -- ?10e, David H. Martineau, Esquire