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:
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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
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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~.~~~~
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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: $67.50
July 19, 2010
SO ANSWERS,
~~
RON R ANDERSON, SHERIFF
(c) CountySuits Sheriff, Teleosott. Inc.
GREGORY R. HESS, and
TOINETTE L. HESS,
Plaintiffs
v.
H. DANIEL BEIGH, and
ONEIDA H. BEIGH,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-4101
Defendants
ACCEPTANCE OF SERVICE
I accept service of the Writ of Revival.
Date: ~l Zl ~ °
f
H. Daniel Beigh
Defendant
2300 Foxfire Circle
Mechanicsburg, PA 17055
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1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
C3REGORY R. HESS aad
TOINETTE L. HESS
Vs. CIVIL ACTION LAW
H. DANIEL BEIC}H
2300 Foxfire Circle
Mechanecsburg, PA 17055
ONEIDA H. BEIOH
31 Woodmyre Lane
Enola, PA 17025
No 10-4101 CIVIL TERM
WRIT OF REVI AL
TO H. DANIEL BEICiH aad
ONEIDA H. BEIQ~H
You are notified that the Plaiatiff has commenced a proccedeng to revive and contitwe the lien of
~ lit entered to
No. 046509 Civet Term
The Plaintiffclaimstpat the amount due and unpaid is 550,000.00 with interest fi~om 3/17/2000.
You are required within twenty (20) days after service of this Writ to file an answer or otherwise,
Plead to this Writ. If you Bail to do so, Judgment of revival will be errtered.
Costs S 269.90 PD ATTY
~ 3.00 DUE CO
D. Bell, thonotuy
Date 6/17/10
(S~) ~Pat3'
JOHN G. MILADOVIC, ESQUIRE
Attorney for the Plaintiff
BECKLEY dt MADDEN
2I2 NORTH THIRD STRp,ET
PO BOX i 1998
HARRISBURG, PA 17108
717-233-7691
GREGORY R HESS, and : IN THE COURT OF COMMON PLEAS OF
TOINETI'E L. HESS, :CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
v. o
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H. DANIEL BEIGH, and- .~aoo p~„s t3trole, Mew, M- mass '~ IS
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ONEIDA H. B$IGH, - 81 k~oaidmyrs: Lane, En~el0. l~ pis. ,
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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
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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
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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
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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