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Home My WebLink About10-3579RED-OrT E OF THE pRO-,,?OQTAPY 2010 JUN - I PM 2*. 31 --CUutBt,MN Pe"MAM W. Scott Henning, Esquire I.D.#32298 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiffs Fax : (717) 233-3029 E-mail: Henning@HHRLaw.com IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2010 - 3519 &Ivil Ierk Civil Action (XX) Law ( ) Equity JURY TRIAL DEMANDED KATHY J. SHATTO and WEST FAIRVIEW AMERICAN LEGION KENNETH W. SHATTO, her husband POST NO. 984 HOME ASSOCIATION 437 3`d St. a/k/a WEST FAIRVIEW AMERICAN LEGION Enola, PA 17025 POST NO. 984 versus 611 3rd St. Enola, PA 17025 Plaintiff(s) & Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue A Writ of Summons in the above-captioned action. X Writ of Summons Shall be issued and forwarded to ( W. Scott Hennina. Esauire Handler. Henning & Rosenberg. LLP 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Signature 67116m6oO Supreme Court ID No. Name/Address/Telephone No. of Attorney Date: June 1. 2010 Defendant(s) & Address(es) heriff \u *Ra.oo PD AT H C? ? o5a9 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIF (S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. . I (I1 J9 n 0 rP Date: !o I ?l D by. ( ) Check here if reverse is used for additional information PROTHON. - 55 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor +..°~Y~itr of ~rrrr+br~~~~~ ti, i; ~~~ ,t-. ~~t!. E ~~ nE~ z~sa?~~ 7 r I J'" , - ~,F?,r' ZQiO .~'~' r 5 ~ ~ I ~ ~i~ ~~ -~ . v, . ;~ Kathy J. Shatto (et al.) Case Number vs. West Fairview American Legion Post No. 984 2010-3579 SHERIFF'S RETURN OF SERVICE 06/11/2010 Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on June 11, 2010 at 1639 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: West Fairview American Legion Post No. 984 Home Association a/k/a West Fairview American Legion Post No. 984, by making known unto Tammy Patrick, Bartender for The West Fairview American Legion Post No. 984 Home Association at 611 3rd Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF GOST: $41.94 SO ANSWERS, ~~^^ir June 14, 2010 RON R ANDERSON, SHERIFF By MI AE BARRIO DEPUTY SHERIFF ?C) Cour;ry5uite 5her!ff. Te'eesoiT. Inc. MILSTEAD & ASSOCIATES, LLC BY: Patrick J. Wesner, Esquire ID No. 203145 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Beneficial Consumer Discount Company COURT OF COMMON PLEAS DB/A Beneficial Mortgage Co of CUMBERLAND COUNTY Pennsylvania 636 Grand Regency Boulevard Brandon, FL 33510, Plaintiff, Vs. William Nieves a/k/a William Nieves Jr. a/k/a William A. Nieves Jr. 4694 North Pheasant Ridge Trail Lehi, UT 84043, and Pamela Nieves a/k/a Pamela J. Nieves 1902 Princeton Avenue, Camp Hill, PA 17011, Defendants. C"3 r" ca -a • S ? w\J PRAECIPE FOR JUDGMENT, INREM, FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter Judgment, in rem, in favor of Plaintiff and against William Nieves a/k/a William Nieves Jr. a/k/a William A. Nieves Jr. and Pamela Nieves a/k/a Pamela J. Nieves, Defendants, for failure to file an Answer on Plaintiff s Complaint within 20 days from service thereof and for Foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest 5/28/10 through 12/13/10 TOTAL $237,909.34 7,649.56 $245,558.90 I hereby certify that (1) the addresses of the Plaintiff and Defendants are as shown above and (2) that notice has been given in accordance with Rule 237.1. p attached. J. esner, Esquire Attorney tr Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: 12 4Lt-(Q No.: 10-3576 Civil 4P0'WTH40NO6T-ARY %aP 5ZIUL Q? ?a gad ?' ?.ic?`ec? MILSTEAD & ASSOCIATES, LLC BY: Mary L. Harbert-Bell, Esquire ID No. 80763 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Beneficial Consumer Discount Company DB/A Beneficial Mortgage Co of Pennsylvania, Plaintiff, Vs. William Nieves a/k/a William Nieves Jr. a/k/a William A. Nieves Jr. and Pamela Nieves a/k/a Pamela J. Nieves, Defendants. Our file number: 22.12627 COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 10-3576 Civil TO: William Nieves a/k/a William Nieves Pamela Nieves a/k/a Jr. a/k/a William A. Nieves Jr. Pamela J. Nieves 4694 North Pheasant Ridge Trail, 1902 Princeton Avenue„ Lehi, UT 84043 Camp Hill, PA 17011 William Nieves a/k/a William Nieves, Jr. a/k/a William A. Nieves, Jr. 10968 Shilling Avenue, #2124 South Jordan, UT 84095 DATE OF NOTICE: November 3, 2010 William Nieves a/k/a Williar Nieves, Jr. a/k/a William A. Nieves, Jr. 2115 Walnut Bottom Road Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. {00511313} Page I of 2 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 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 BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 717-249-3166 By: Mar j L. Harbe-A- ID No. 80763 Attorney for Plaintiff {00511313} Page 2 of 2 l ¦ MILSTEAD & ASSOCIATES, LLC BY: Patrick J. Wesner, Esquire ID No. 203145 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Beneficial Consumer Discount Company D/B/A Beneficial Mortgage Co of Pennsylvania, Plaintiff, Vs. William Nieves a/k/a William Nieves Jr. a/k/a William A. Nieves Jr., and Pamela Nieves a/k/a Pamela J. Nieves, Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 10-3576 Civil VERIFICATION OF NON-MILITARY SERVICE Patrick J. Wesner, Esquire, hereby verifies that she is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, she has knowledge of the following facts, to wit: 1. that the defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldier' and Sailors' Civil Relief Act of Congress of 1940, as amended, 2. defendant, William Nieves a/k/a William Nieves Jr. a/k/a William A. Nieves Jr., is over 18 years of age and resides at 4694 North Pheasant Ridge Trail, Lehi, UT 84043, 3. defendant, Pamela Nieves a/k/a Pamela J. Nieves, is over 18 years of age and resides at 1902 Princeton Avenue„ Camp Hill, PA 17011. 2k J. yesner, Esquire