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Home My WebLink About10-4229-, John J. McNally, III, Esquire Attorney I.D. #52661 Thomas, Thomas & Hafer, LLP P. O. Box 999 Harrisburg, PA 17108-0999 (717)237-7116 t?F P~~ ~~dQTAAY ?01~ JtIN ~4 PM ! ~ 2~ ~. ALFRED BURTNETT and JANET, BURTNETT Plaintiffs ~. HUTCH HOMES, INC. and JAMES W. HUTCHINSON, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. ~ o - yaa9 C~~~~ tax ~^ CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS. To: Prothonotary Kindly issue a Writ of Summons on behalf of Plaintiffs, against Defendants, Hutch Homes, Inc. and James W. Hutchins Date: and Janet Burtnett, THOMAS & ~iAFER LLP 305 ~orth Front Strom Harrisburg, PA 17108 (717)237-7116 Attorneys for Plaintiff SUMMONS IN CIVIL. ACTION TO: Hutch Homes, Inc. James W. Hutchinson 414 South York Street Mechanicsburg, PA 17055 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED AN ACTION AGAINST YOU. Date:_ ~ /ay/io Prothonotary/Clerk, Civil Division by: ~4a.oo PD AYh/ e~ tsgyga e~` a~lyz~8 Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 1=1±_`'~- ~ '': - Sheriff -- T~ ~=-- G . -,, lY' tits' of ~~a~n6tr ~. Jody S Smith ~'°~ f"'~~0 , „ Chief Deputy Z~ I ~ ~'-'~ ~ ~ i~i7 ~%~ ~ c' ,r Richard WStewart - Solicitor ~~ ~.G ~~ -~~ _~:ar~~ ~~r.~ ~~~ w ~ ,. ,~ ,'~ti ., Alfred C Burtnett vs. Case Number Hutch Homes Inc (et al.) 2010-4229 SHERIFF'S RETURN OF SERVICE 07/08/2010 09:08 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 8, 2010 at 2108 hours, she served a true copy of the within Writ of Summons, upon the within named defendant, to wit: James W. Hutchinson, by making known unto himself personally, at 414 S. York Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. (N" AM A COBAUGH, DEPUTY 07/08/2010 09:08 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 8, 2010 at 2108 hours, she served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Hutch Homes, Inc., by making known unto James Hutchinson, Owner of Hutch Homes, Inc. at 414 S. York Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents an at the same time handing to him personally the said true and correct cop of the same. A A DA COBAUGH, DEPU SHERIFF COST: $53.44 July 09, 2010 SO ANSWERS, ... I RON R ANDERSON, SHERIFF (cj CountySuite She~iYf, Teleosoft. Inr.. THOMAS, THOMAS & HAFER, LLP John F. Yaninek, Esquire I.D. No. 55741 (717) 441-3952 jyaninekQtthlaw.com P. O. Box 999 Harrisburg, PA 17108-0999 Counsel for Plaintiffs C OF K33E .i l i','0 H C!40TAFY 'JU IRERLANO COUNTY rjC.-S'fp.*S r R f :*N W Lute ?I1 ALFRED and JANET BURTNETT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. HUTCH HOMES, INC. and JAMES W. HUTCHINSON, NO. 10-4229 CIVIL TERM Defendants JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a Default Judgment in the amount of $55,000.00 against the Defendant Hutch Homes and in favor of the Plaintiffs, Alfred Burtnett and Jane Burtnett in the above- captioned matter pursuant to Pa.R.C.P. 1037(b), for the failure to plead to the Complaint filed in this action within the required time. The Complaint was served upon Defendant by first class mail on or about February 8, 2011. A copy of the Notice to Defend, served with the Complaint, is attached as Exhibit "A". Undersigned counsel for the Plaintiffs hereby certifies that pursuant to Pa.R.C.P 237.1(a) (2) (ii), a written Ten-Day Notice of the intention to file this Praecipe for Entry of Default Judgment was served via certified mail upon Defendant on March 2, 2011. A copy of said notice, which was sent after the failure to plead to the Complaint, and sent more than ten days prior to the date of filing this Praecipe, is attached as Exhibit "B". ais jugaoa Nbb c.t Wat led Respectfully submitted, Thomas, Thomas & Hafer, LLP By: F. Y ' ek, squire A Attorney ID #5574"L Counsel for Plaintiffs Date: April 1, 2011 ?CYN'??? THOMAS, THOMAS & HAFER, LLP John J. McNally, III, Esquire I.D. No. 52661 (717) 237-7116 jmcnally@tthlaw.com John F. Yaninek, Esquire I.D. No. 55741 (717) 441-3952 jyaninek@tthlaw.com P. 0. Box 999 Harrisburg, PA 17108-0999 Counsel for Plaintiffs ALFRED and JANET BURTNETT, Plaintiffs V. HUTCH HOMES, INC. and JAMES W. HUTCHINSON, Defendants r-ILED-OFFICE OF THE PRO,rHONOTARY ?CfIFE??? ??1l? ?8 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-4229 CIVIL TERM JURY TRIAL DEMANDED TO: Hutch Homes, Inc. and James W. Hutchinson 6580 Greenan Drive, Avalon, New Jersey 08202 NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NOTICE 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. Belford Street Carlisle, PA 17013 Telephone (717) 249-3166 ?x???? THOMAS, THOidIAS & HAFERLLP Attorneys At LaNN PH Street Address: 305 North Front Street, Flan-isburg, PA 17101 Mailing Address: P.O. Box 999, Harrisburg, PA 17108 Plione: 717337.7100 Fax: 717.237.7105 John F. Yaninek (717) 441-3952 jyaninek@tthlazo. cone March 2, 2011 Via Certified Mai',' Hutch Homes, Inc. 414 South York Street Mechanicsburg, PA 17055 Re: Alfred and Janet Burtnett 7?. Hutch Homes, Inc., et al. Docket No. 10-4229 (Cumberland Co.) Our File No. 863-00990 Dear Sir/ Madam: Enclosed, constituting service upon you, please find a 10-Day Notice of Default in the above-captioned matter. As indicated in the attached Notice, we will be filing an Entry of Default judgment against you in the Cumberland County Court of Common Pleas within 10 days of the date of the attached Notice. Thank you for your attention to this matter. Very truly yours, THOMAS, THOMAS & HAFER, LLP By: hn F. Yaninek JFY:ak Enclosure 915107.1 Baltimore Bethlehem Harrisburg Philadelphia Pittsburgh Wilkes-Barre www.tthIaw.com ¦ Complete Items 1, 2, and 3. Also complete Item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return-the card to-you-- M Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Lnc. L-H 4 S . yor1? ?- 1-1 z ArlicJs Number 7009 2250 (Transfer from service tabs!} A. ig slurs ? Agent ? Addressee 8. Received by (Printed Name) C. Date of Delivery D. Is delivery address different from if YES, enter defnrery address ? Nd> ., 3. Service Type LO'Certified Man ?SQS ? Express Mar 1 Registered ? Return Receipt for Merchandise ? insured mail ? G.O.D. 4. Restricted Deliveryt (afra Fee) p Yes 0000 3824 7016 Ps Form 3811, February 2004 Domestic Return Receipt 102596.02-M-1640 THOMAS, THOMAS & HAFER, LLP John J. McNally, III, Esquire I.D. No. 52661 (717) 237-7116 jriic1ia11y@tthlaw.coni " John F. Yaninek, Esquire I.D. No. 55741' (717) 441-3952 jyaninek@.tdllaw.com . P. O. Box 999 Harrisburg; PA 17105-0999 Counsel for Plaintiffs ` ALFRED and JANET BURTNETT, Plaintiffs V. HUTCH HOMES, INC. and JAMES W. HUTCHINSON, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-4229 CIVIL TERM JURY TRIAL DEMANDED IMPORTANT NOTICE To: Hutch Homes, Inc. 414 South York Street Mechanicsburg, PA 17055 Date of Notice: March 11, 2011 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES AND OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FORM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST 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. y L, _ Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 800-990-9108 Respectfully submitted, Thomas, Thomas & Hafer, LLP By: L.----- McN y ,:Esquire I. . No. 526 1 John F. Yaninek, Esquire PA Attorney ID #55741 Counsel for Plaintiffs Date: March 11, 2011 ?? •0.i y I CERTIFICATE OF SERVICE I. Angela ?A. ,Kelly, an employee of Thomas, Thomas & Hafer, LLP, do hereby. certify that I sent a true and correct copy of the foregoing document, on all parties of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Hutch Homes 414 South York Street Mechanicsburg, PA 17055 James W. Hutchinson 414 South York Street Mechanicsburg, PA 17055 THOMAS, THOMAS & HAFE ; LLP !We A. Kelly Date: March 11, 2011 CERTIFICATE OF SERVICE I, Angela A. Kelly, an employee of Thomas, Thomas & Hafer, LLP, do hereby certify that I sent a true and correct copy of the foregoing document, on all parties of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Hutch Homes James W. Hutchinson 414 South York Street 414 South York Street Mechanicsburg, PA 17055 Mechanicsburg, PA 17055 THOMAS, THOMAS & HAFER, LLP/ Ang l . Kelly Date: April 1, 2011 927947.1 THOMAS, THOMAS & HAFER, LLP John F. Yaninek, Esquire I.D. No. 55741 (717) 441-3952 jyaninekQtthlaw.com P. O. Box 999 Harrisburg, PA 17108-0999 Counsel for Plaintiffs Gb I`E i'2 T.-6014OTARY !r _7 1 : 0? ".'? McAAND COUNTY E N 1SYLVANIA ALFRED and JANET BURTNETT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. HUTCH HOMES, INC. and JAMES W. HUTCHINSON, Defendants NO. 10-4229 CIVIL TERM JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF DEFAULT TUDGMENT TO THE PROTHONOTARY: Please enter a Default Judgment in the amount of $55,000.00 against the Defendant James W. Hutchinson and in favor of the Plaintiffs, Alfred Burtnett and Jane Burtnett in the above-captioned matter pursuant to Pa.R.C.P. 1037(b), for the failure to plead to the Complaint filed in this action within the required time. The Complaint was served upon Defendant by first class mail on or about February 8, 2011. A copy of the Notice to Defend, served with the Complaint, is attached as Exhibit "A". Undersigned counsel for the Plaintiffs hereby certifies that pursuant to Pa.R.C.P 237.1(a)(2)(ii), a written Ten-Day Notice of the intention to file this Praecipe for Entry of Default Judgment was served via certified mail upon Defendant on March 2, 2011. A copy of said notice, which was sent after the failure to plead to the Complaint, and sent more than ten days prior to the date of filing this Praecipe, is attached as Exhibit "B". C'UA 1u. oo i?d 04_? e ke 1(01W21 iz#95710 9 MA u U1M„ lp-A Respectfully submitted, Thomas, Thomas & Hafer, LLP By: o Wiek re A A . Counsel for Plaintiffs Date: April 1, 2011 ??? THOMAS, THOMAS & HAFER, LLP John J. McNally, III, Esquire I.D. No. 52661 (717) 237-7116 jmcnally@tthlaw.com John F. Yaninek, Esquire I.D. No. 55741 (717) 441-3952 jyaninek@tthlaw.com P. 0. Box 999 Harrisburg, PA 17108-0999 Counsel for Plaintiffs ALFRED and JANET BURTNETT, Plaintiffs V. HUTCH HOMES, INC. and JAMES W. HUTCHINSON, Defendants 01 THE F'ROTHOH TARy CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-4229 CIVIL TERM JURY TRIAL DEMANDED TO: Hutch Homes, Inc. and James W. Hutchinson 6580 Greenan Drive, Avalon, New Jersey 08202 NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NOTICE 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. Belford Street Carlisle, PA 17013 Telephone (717) 249-3166 ???'' THOMAS, THOMAS & HAFERLLP Attorneys At Law Street Address: 305 North Front Street, Harrisburg, PA 17101 Mailing Address: P.O. Box 999, Harrisburg, PA 17108 Phone: 717 237.7100 Fax 717 237.7105 Joh77 F. Yatzinek (717) 441-3952 jyaninek@tth1aw.co7i7 March 2, 2011 Via Certified Mail James W. Hutchinson Hutch Homes, Inc. 414 South York Street Mechanicsburg, PA 17055 Re: Alfi-ed and Janet Bitrtnett v. Hutcli Homes, Inc., et X. Docket No. 10-4229 (Cumberland Co.) Our File No. 863-00990 Dear Mr. Hutchinson: Enclosed, constituting service upon you, please find a 10-Day Notice of Default in the above-captioned matter. As indicated in the attached Notice, we will be filing an Entry of Default Judgment against you in the Cumberland County Court of Common Pleas within 10 days of the date of the attached Notice. Thank you for your attention to this matter. Very truly yours, THOMAS, THOMAS & HAFER, LLP G By: of n F. Yaninek JFY: ak Enclosure 915089.1 Baltimore Bethlehem Harrisburg Philadelphia Pittsburgh Wilkes- Barre www.tthlaw.com ¦ Complete Items 1, 2, and 3. Also complete A. n item 4 if Restricted Delivery is desired. i ? Agent ¦ Print your name and address on the reverse ? Addresses so that we can return the card to you. B. R 'ved by (Printed Name) C. Date 2elivery ¦ Attach. th' to the back of the mailpiece, or on tWW if space permits. - -- - -- --- - - - - -- 7. Article Ad ed to - - -- - - _ D. IIs delivery f. YES, enter drew below 1 r 414 } ICS ?-?? V S. Service Type 13110ertifred Mail ? Express. Mail ? Registered ? Return Receipt for Merchandise . ` ? Insured mail O c.o.D. r 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article 7009 2250 000Q 3824 7009 PS Fort 3811, February 2004 Domestic Retum Receipt 1025e5-024A-1540 i THOMAS, THOMAS & HAFER, LLP f ohn J. McNally, III, Esquire I.D. No. 52661 (717) 237-7116 jmcnally@ltl-law.com John F. Yaninek, Esquire I.D. No. 55741 (717) 441-3952 jyaninek®tthlaw.com P. O. Box 999 Harrisburg, PA 17108-0999.. Counsel for Plaintiffs ALFRED and JANET BURTNETT, Plaintiffs V. HUTCH HOMES, INC. and JAMES W. HUTCHINSON, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-4229 CIVIL TERM JURY TRIAL DEMANDED IMPORTANT NOTICE To: James W. Hutchinson 414 South York Street Mechanicsburg, PA 17055 Date of Notice: March 11, 2011 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES AND OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FORM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST 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. i I h Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 800-990-9108 Respectfully submitted, Thomas, Thomas & Hafer, LLP By: 0N. McN Ily, Esquire o. 5266 John F. Yaninek, Esquire PA Attorney ID #55741 Counsel for Plaintiffs Date: March 11, 2011 L. CERTIFICATE OF SERVICE I, Angela A. Kelly, an employee of Thomas, Thomas & Hafer, LLP, do hereby certify that I sent a true and correct copy of the foregoing document, on all parties of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Hutch Homes James W. Hutchinson 414 South YorkStreet.:.' .::' .. 414 South York Street , :. Mechanicsburg, PA 17055 Mechanicsburg, PA 17055 Date: March 11, 2011 THOMAS, THOMAS & LLP 915076.1 CERTIFICATE OF SERVICE I, Angela A. Kelly, an employee of Thomas, Thomas & Hafer, LLP, do hereby certify that I sent a true and correct copy of the foregoing document, on all parties of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Hutch Homes 414 South York Street Mechanicsburg, PA 17055 Date: April 1, 2011 James W. Hutchinson 414 South York Street Mechanicsburg, PA 17055 THOMAS, THOMAS & HAFER, LLP Angela . Kelly 927949.1 THOMAS, THOMAS & HAFER, LLP John F. Yaninek, Esquire I.D. No. 55741 (717) 441-3952 jyaninek@tthlaw.com P. O. Box 999 Harrisburg, PA 17108-0999 I1-0, I= IC.E ?T oNOTAFI t. 11 15 PM 12'. 51 !-!tlC,ERL AND COUNT`` T1 °? L?? Counsel for Plaintiffs ALFRED and JANET BURTNETT, Plaintiffs V. HUTCH HOMES, INC. and JAMES W. HUTCHINSON, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 10-4229 CIVIL TERM JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve Subpoenas with a copy of the subpoenas attached thereto was served upon the Defendants. 2. A true and correct file copy of the Notice of Intent, including copies of the proposed subpoenas, are attached to this Certificate as Exhibit "A." 3. Twenty (20) days have passed and Defendant has not objected to the service of the subpoenas. 4. The subpoenas which will be served are identical to the subpoenas attached to the Notice of Intent. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP By: t%? ?AAttorney F. Ya k, Esquire D #55741 Date: August 12, 2011 Counsel for Plaintiffs THOMAS, THOMAS & HAFER, LLP John F. I aninek, Esquire I.D. No. 55 741 (717) 441-3952 jyaninek@tthlaw.com P. 0. Box 999 Harrisburg, PA 17108-0999 Counsel for Plaintiffs ALFRED and JANET BURTNETT, Plaintiffs v. HUTCH HOMES, INC. and JAMES W HUTCHINSON, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 10-4229 CIVIL TERM JURY TRIAL DEMANDED NOTICE OF INTENT TO :'SERVE SUBPO.ENA TO: James W. Hutchinson and Hutch Homes, Inc. 414 South York Street 414 South York Street Mechanicsburg, PA 17055 Mechanicsburg, PA 17055 Plaintiffs, Alfred Burtnett and Janet Burtnett, intend to serve subpoenas identical to the ones that are attached to this Notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to these subpoenas. If no objection is made, the subpoenas will be served. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP Date: July 21, 2011 By: o F. Yaninek, Esquire Attorney ID #55741 Counsel for Plaintiffs E771 ALFRED and JANET BURTNETT, I1\1 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANLA Plaintiffs v. HUTCH HOMES, INC. and JAMES Viz HUTCHINSON, NO. 10-4229 CI 71L TERM JURY TRIAL DEMANDED Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO.' Members First Federal Credit Union PO Box 40 Mechanicsburg, PA 17055 'Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: all banking- records, loan documents, and anv other records pertaining to James W. Hutchinson and Hutch Homes, Inc.. from Januarv 1. 2009 to the present at: Thomas Thomas & Hafer LLP 305 North Front Street. 6t', Floor. PO Box 999, Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost, of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA IATAS ISSUED AT THE REQUEST OF THE FOLLOIATING PERSON: Name: John F. Yaninek, Esquire Address: 305 North Front Street, 6th Floor, Harrisburg, PA 1.7101 Telephone: 717-237-7100 Supreme Court ID #55711 BY THE COURT: Prothonotary, Civil Division Date: Deputy Seal of the Court ALFRED and JANTET BURTNETT, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V, HUTCH HOMES, INC. and JAMES W. HUTCHINSON, NO. 10-1229 CB71L TERM Defendants JURY, TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 T0: Bank of America 525 North Tryon Street Charlotte, NC 28255 VATithin twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: all banking records loan documents. and anv other records Pertaining to James W. Hutchinson and Hutch Homes, Inc. of Mechanicsburg Pennsylvania from January 1. 2009 to the present at: Thomas Thomas & Hafer LLP 305 North Front Street, 6t" Floor. PO Box 999, Harrisburz. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost, of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA VATAS ISSUED AT THE REQUEST OF THE FOLLWATING PERSON: Name: John F. Yaninek, Esquire Address: 305 North Front Street, 611, Floor, Harrisburg, PA 17101 Telephone'. 717-237-7100 Supreme Court ID #55741 BY THE COURT: Prothonotary, Civil Division Date: Deputy Seal of the Court ALFRED and JANET BURTNETT, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PEI\TNSYLVTANIA Plaintiffs v. HUTCH HOMES, INC. and JAMES W. HUTCHINSON, NO. 10-4229 CT\rIL TERM Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 T0: MetroBank 3801 Paxton Street Harrisburg, PA 17111 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: all banking records, loan documents, and anv other records pertaining to James W. Hutchinson and Hutch Homes, Inc.. relative to account number 0538218116 from Januarv 1 2009 to the present at: Thomas Thomas & Hafer. LLP. 305 North Front Street. 611, Floor, PO Box 999, Harrisburg, PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the parts- making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought, If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA VITAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: John F. Yaninek, Esquire Address: 305 North Front Street, 611' Floor, Harrisburg, PA 17101 Telephone: 717-237-7100 Supreme Court ID #55741 BY THE COURT: Prothonotary, Civil Division Date: Deputy Seal of the Court ALFRED and JANET BURTNETT, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs N'. HUTCH HOMES, INC. and JAMES W. HUTCHINSON, N0. 10-4229 CIVIL TERM Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PNC Financial Services Group 600 Grant Street Mail Stop P6-PUSX-36-1 Pittsburgh, PA 15219 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: all banking records, loan documents, and anv other records pertaining to James W Hutchinson and Hutch Homes, Inc.. relative to account number ending in 0824 from January 1 2009 to the present at: Thomas Thomas & Hafer LLP 305 North Front Street. 61h Floor. PO Box 999, Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at, the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: John F. Yaninek, Esquire Address: 305 North Front Street, 6th Floor, Harrisburg, PA 17101 Telephone: 717-237-7100 Supreme Court, ID #55741 BY THE COURT: Prothonotary, Civil Division Date: Deputy Seal of the Court CERTIFICATE OF SERVICE I, Angela A. Kelly, an employee of Thomas, Thomas & Hafer, LLP, do hereby certify that I sent a true and correct copy of the foregoing Notice of Intent to Serve Subpoenas on all parties of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Hutch Homes, Inc. 414 South York Street Mechanicsburg, PA 17055 Date : July 21, 2011 James W. Hutchinson 414 South York Street Mechanicsburg, PA 17055 THOMAS, THOMAS & HAFER, LLP tnD - An ela . Kelly g70296.1 CERTIFICATE OF SERVICE I, Angela A. Kelly, an employee of Thomas, Thomas & Hafer, LLP, do hereby certify that I sent a true and correct copy of the foregoing Certificate Prerequisite on all parties of record by placing a copy of the same in the United States first-class mail, postage prepaid, addressed as follows: Hutch Homes, Inc. James W. Hutchinson 414 South York Street 414 South York Street Mechanicsburg, PA 17055 Mechanicsburg, PA 17055 THOMAS, THOMAS & HAFER, LLP Mn Lal I / A,nge a A. Kelly _ Date= August 12, 2011 978368.1