Loading...
HomeMy WebLinkAbout10-4101GREGORY R. HESS, and TOINETTE L. HESS, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. tG -~lio~ v. H. DANIEL BEIGH, and- .a3oo P'ox~ira eirrle, Mech, P~ I~oSS ONEIDA H. BEIGH, - 31 wood myre: Lane, ~n.efci I ~ oas Defendants ~ivi t IEr'rn PRAECIPE FOR WRIT OF REVIVAL TO THE PROTHONOTARY: n C ~ -° .. 'Ij L"Z_ o L _„> _~ ~ _, - -a =r~ _,., --~~~~, ~, Issue writ of revival of lien of judgment entered in this Court at Docket Number 00-1587 (and revived the first time at Docket Number 04-6509) and enter it in the judgment index against H. Daniel Beigh and Oneida H. Beigh, Defendants, in the principal amount of $50,000.00, with interest at 12.5% per annum, compounded monthly, from March 17, 2000. Dated: loft l~~~b Of Counsel Beckley & Madden 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717) 233-7691 Respectfully submitted, homas A. Beckley ohn G. Milakovic Attorneys for Plaintiffs Q ~aq.oo Pa A'n9 l.5.q~} CBF 3b.14 " 51. a5 " 50.5'7 " o1p• 00 q. o0 S• ~ 4 a~a,ao - Pp A~ er.~ 141.9 ~~dy393(o ~3.0o Aue (~ Nafiee IUs;lew ., i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY R. HESS and TOINETTE L. HESS Vs. H. DANIEL BEIGH 2300 Foxfire Circle Mechanicsburg, PA 17055 ONEIDA H. BEIGH 31 Woodmyre Lane Enola, PA 17025 No 10-4101 CIVIL TERM TO H. DANIEL BEIGH and ONEIDA H. BEIGH CIVIL ACTION LAW 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. 04-6509 Civil Term The Plaintiff claims that the amount due and unpaid is $50,000.00 with interest from 3/17/2000. 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 $ 269.90 PD ATTY $ 3.00 DUE CO vid D. Buell, P othonotary Date 6/17/10 Deputy (Seal) JOHN G. MILADOVIC, ESQUIRE Attorney for the Plaintiff BECKLEY & MADDEN 212 NORTH THIRD STREET PO BOX 11998 HARRISBURG, PA 17108 717-233-7691 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~~~itr of C'u,~M~r~.~~~~ .~ , IL~~"+ 1 '` i~L ?~E r, ,, Jody S Smith Chief Deputy Richard W Stewart SOIICItOr ZQlQJU ~ 30 PIS, !: tip; Gregory R. Hess (et al.) vs. H. Daniel Beigh (et al.) Case Number 2010-4101 SHERIFF'S RETURN OF SERVICE 06/29/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Oneida H. Beigh, but was unable to locate her in his bailiwick. He therefore returns the within Writ of Revival as not found as to the defendant Oneida H. Beigh. Current owner of 31 Woodmyre Lane, Enola, PA 17025 has resided at this location for the past five years and does not know the defendant. 06/29/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: H. Daniel Beigh, but was unable to locate him in his bailiwick. He therefore returns the within Writ of Revival as not found as to the defendant H. Daniel Beigh. Current owner of 31 Woodmyre Lane, Enola, PA 17025 has resided at this location for the past five years and does not know the defendant. SHERIFF COST: $67.50 June 29, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (cj Coun!ySuite Sheriff. Teleoso!t. Inr,. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson '' ~' Sheriff ~' _. ~a~ti~~tr of ~amb,rrJ Jody S Smith '~' ~, m ,~, _ , Chief Deputy ~ ~~ , ~ [ C i ~ , , ..a {q~i~ -~ ~ ~ t .. >~ , „ Richard W Stewart ~'~ ~~~ ~ ~Q ~~ a~ ~~' ~s {v~~ , Solicitor ~~icE , ~HE.~~R~Fi= ~ ~ , i ; . ~~.,, ~~ ~ t. , _ Gregory R. Hess (et al.) Case Number vs. H. Daniel Beigh (et al.) 2010-4101 SHERIFF'S RETURN OF SERVICE A1~JENDED 06/29/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Oneida H. Beigh, but was unable to locate her in his bailiwick. He therefore returns the within Writ of Revival as not found as to the defendant Oneida H. Beigh. Current owner of 31 Woodmyre Lane, Enola, PA 17025 has resided at this location for the past five years and does not know the defendant. 07/16/2010 07:10 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on July 16 2010 at 1910 hours, he served a true copy of the within Writ of Revival, upon the within named defendant, to wit: Oneida H. Beigh, by making known unto herself personally, at 21 Woodmyr ane, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same han n to her personally the said true and correct copy of the same. ~ HARRISON, DEPUTY 07/19/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on July 19, 2010 at 0925 hours, he was unable to serve a true copy of the within Writ of Revival, upon the within named defendant, to wit: H. Daniel Beigh. After several attempts the Writ of Revival has expired. SHERIFF COST: $67.50 July 19, 2010 SO ANSWERS, ~~ RON R ANDERSON, SHERIFF (c) CountySuits Sheriff, Teleosott. Inc. GREGORY R. HESS, and TOINETTE L. HESS, Plaintiffs v. H. DANIEL BEIGH, and ONEIDA H. BEIGH, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-4101 Defendants ACCEPTANCE OF SERVICE I accept service of the Writ of Revival. Date: ~l Zl ~ ° f H. Daniel Beigh Defendant 2300 Foxfire Circle Mechanicsburg, PA 17055 c~ ^; ~ -;~ ~ ~ -~ ``_ ~ ~ ~~ ~: , ^- ,_. ~ 1 ~, °' - W i ~ 7 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C3REGORY R. HESS aad TOINETTE L. HESS Vs. CIVIL ACTION LAW H. DANIEL BEIC}H 2300 Foxfire Circle Mechanecsburg, PA 17055 ONEIDA H. BEIOH 31 Woodmyre Lane Enola, PA 17025 No 10-4101 CIVIL TERM WRIT OF REVI AL TO H. DANIEL BEICiH aad ONEIDA H. BEIQ~H You are notified that the Plaiatiff has commenced a proccedeng to revive and contitwe the lien of ~ lit entered to No. 046509 Civet Term The Plaintiffclaimstpat the amount due and unpaid is 550,000.00 with interest fi~om 3/17/2000. You are required within twenty (20) days after service of this Writ to file an answer or otherwise, Plead to this Writ. If you Bail to do so, Judgment of revival will be errtered. Costs S 269.90 PD ATTY ~ 3.00 DUE CO D. Bell, thonotuy Date 6/17/10 (S~) ~Pat3' JOHN G. MILADOVIC, ESQUIRE Attorney for the Plaintiff BECKLEY dt MADDEN 2I2 NORTH THIRD STRp,ET PO BOX i 1998 HARRISBURG, PA 17108 717-233-7691 GREGORY R HESS, and : IN THE COURT OF COMMON PLEAS OF TOINETI'E L. HESS, :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. o e ~ H. DANIEL BEIGH, and- .~aoo p~„s t3trole, Mew, M- mass '~ IS ~ ~ L ~ ,~ ~ ONEIDA H. B$IGH, - 81 k~oaidmyrs: Lane, En~el0. l~ pis. , €s~ r{ C n Defendants -+ " ~., ~~ S C' _''. -~ ,~ ~~~ PRAECIPE FOR WRIT OF REVIVAL . ti TO 1'1iIE PROTHONOTARY: Issue writ of revival of lien of judgment entered in this Court at Docket Number 00-1587 (and revived the Srst time at Docket Number 04-6509) and eater it in the judgment index against H. Daniel Beigh and Oneida H. Beigh, Defendants, in the principal amount of SS0,000.00, with interest at 12.5% per aamnn, compounded mouthiy, From March 17, 2000. Dated: G~l~~lb ~Y~~ Of Counsel Beckley dt Madden 212 Narth Third Strect ''homes A. Beckley P.O. Box 11998 Harrisburg, PA 17108 (717)233-7691 /~ Q. Milakovic Attorneys for Plaintiffs ~'~ ~4d '~.9~i Nah~e dear +~aA.00 PQ ATTt 51.~1t5 ~. ~ n ~: ~ M 8•~ ~ #-atq.4o - Pa ~Y #3.0o pu4 Co R - GREGORY R. HESS, and TOINETTE L. HESS, Plaintiffs V. H. DANIEL BEIGH, III, and ONEIDA H. BEIGH, Defendants TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. 10-4101 Civil Term : v `-fin 7q ti S> C- ?. _5 rn _ PRAECIPE W Enter judgment in favor of Plaintiffs and against Defendants above-named, for failure of Defendants to file an answer to the writ of revival within twenty (20) days after service thereof, or otherwise to plead in response thereto. Assess Plaintiffs' damages as follows: In the principal amount of $50,000.00, with interest at 12.5% per annum, compounded monthly, from March 17, 2000. It is hereby certified that a notice of intention to file a praecipe for entry of a default judgment was mailed to each Defendant at least ten days prior to the filing of this praecipe and after default occurred. Dated: Of Counsel Beckley & Madden 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717) 233-7691 Respectfully submitted, Thomas A. Beckley John . Milakovic Attorneys for Plaintiffs a4,e-?77 l)o?k .*n?tCfc?C r GREGORY R. HESS, and TOINETTE L. HESS, Plaintiffs E IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-4101 Civil Term V. H. DANIEL BEIGH, and ONEIDA H. BEIGH, Defendants To: H. Daniel Beigh, 2300 Foxfire Circle, Mechanicsburg, PA 17055 (Defendant) Date of Notice: September 2, 2010 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 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 (800) 990-9108 G. Milakovic BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 Attorneys for Plaintiffs 11 GREGORY R. HESS, and TOINETTE L. HESS, Plaintiffs E IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-4101 Civil Term V. H. DANIEL BEIGH, and ONEIDA H. BEIGH, Defendants To: Oneida H. Beigh, 21 Woodmyre Lane, Enola, PA 17025 (Defendant) Date of Notice: August 9, 2010 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 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 (800) 990-9108 /ECKLEY ilakovic & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 Attorneys for Plaintiffs CERTIFICATE OF SERVICE It is hereby certified that a copy of the foregoing document was this day served upon the following persons in the manner below indicated. FIRST CLASS MAIL Mr. H. Daniel Beigh, III 2300 Foxfire Circle Upper Allen Township, PA 17055 Ms. Oneida H. Beigh 21 Woodmyre Lane Enola, PA 17025 Dated: VOt J G. Milakovic .] GREGORY R. HESS, and : IN T11E COURT OF COMMON PLEAS TOINETTE L. HESS, P l a i n t i f f s : CUMSERLAND CXNI -' , PENNSYLVANIA VS. CIVIL ACTION - 10-4101 Civil Term H. DANIEL BEIGH, III; and , ONEIDA H. BEIGH, Defendant S No. To H. Daniel and Oneida H. Beigtue Pendant( s ) You are hereby notified that on 19 , the following Order (Decree) Judgment h been entered against you in the above- captioned case. In favor of Plaintiffs and againtt Defendants in the principal am unt of $50,000.00, with interest at 12.5% per arum, compounded monthly, from March 17 DATE: !Oe lty 7-r - Froth I hereby certify that the name and address'of the proper person(s) to receive this notice is: Mr. H. Daniel Beigh, III Ms. Oneida H. Beigh 2300 F ire irc e e Lane Upper Allen Township,PA 17055 Enola, PA 17025 A H Daniel and (111Pida N_ RPi?h Defendido/a -"' Defendidos/as Por este medio se le esta notificando clue el de ___ _ del 19 , el/la siguiente (orden , I)ecreto_j, (Fa 1lo ha s ido anotado en contra soya en el caso mencionado en el epigrafe• fF,C HA: 11rotanotario Certifico que In si.guiente direccion es la del defendido/a Begun indicada en el certificado de residencia: Mr. H. Daniel Beigh, III Ms. Oneida H. Beigh 2300 F i.re irc e z-L Woodnyre Lane Upper Allen Township, PA 17055 Enola, PA 17025 Abogado del Demandante John G. Milakovic, Esquire Attorney I.D. No. 34843 Beckley & Madden 212 North Third Street Harrisburg, PA 17108 (717) 233-7691 GREGORY R. HESS, and TOINETTE L. HESS Plaintiff, v. H. DANIEL BEIGH, and ONEIDA H. BEIGH, Defendant FILED-OFFICE CIF THE PROTHOPIOTAP,, 2010 DEC 21 PM 1:33 CUMBERLAND Cou?I - PEMNSYI yAm?A- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Docket No. 2010-4101 CIVIL ACTION - LAW PRAECIPE FOR SATISFACTION OF JUDGMENT TO THE PROTHONOTARY: Please mark the lien of judgment in the above-captioned matter SATISFIED of record and DISCONTINUE and END the above-captioned case. Respectfully Submitted, BECKLEY & MADDEN Date: 12-12-0110 B. J G. Milakovic, Esquire Attorney I.D. No. 34843 212 North Third Street Harrisburg, PA 17108 (717) 233-7691 Attorney for Plaintiff GREGORY R. HESS, and IN THE COURT OF COMMON PLEAS OF TOINETTE L. HESS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. Docket No. 2010-4101 H. DANIEL BEIGH, and CIVIL ACTION - LAW ONEIDA H. BEIGH, Defendant CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document was this day served upon the following persons in the manner below indicated: FIRST CLASS MAIL H. Daniel Beigh, III 2300 Foxfire Circle Mechanicsburg, PA 17055 Oneida H. Beigh 31 Woodmyre Lane Enola, PA 17025 Quintina M. Laudermilch, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 Susan E. Good, Esquire Smigel Anderson & Sacks, LLP 4431 North Front Street Harrisburg, PA 17110 Date: / Z Zo//o Jo G. Milakovic, Esquire