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HomeMy WebLinkAbout10-5582 1o Ausa6 ? n 3' 34 FOND WIM Defendants. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1b-55$A 0, ivii-Temr10 WELLS FARGO BANK N.A., a National Banking Association Plaintiff, vs. THEODORE HILL and KIMBERLY HILL, JURY TRIAL DEMANDED CIVIL DIVISION NO.: 05-04395 PRAECIPE FOR WRIT OF REVIVAL Filed on behalf of Plaintiff WELLS FARGO BANK, a National Banking Association Counsel of Record for This Party: Anthony S. Posa, Esquire PA I.D. # 89777 Payne, Welsh & Klingensmith 105 Penn Plaza. Turtle Creek, PA 15145 FIRM #658 (412)823-8100 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK N.A., a National Banking Association CIVIL DIVISION NO.: 10 -5b8a 01 v i 1'Tet,6- Plaintiff, vs. THEODORE HILL and KIMBERLY HILL, Defendants. PRAECIPE FOR WRIT OF REVIVAL TO THE PROTHONOTARY: Kindly issue a Writ of Revival of lien of judgment entered at the Court of Common Pleas of Cumberland County at No. 05-04395 and enter it in the judgment index against Defendants, Theodore Hill and Kimberly Hill, in the amount of $22,773.43 with ongoing post judgment interest thereon from October 17, 2005 *M.oo Po Jkrr/ 2 C>O CBF 110 OO N5,6 U q. 00 Respectfully submitted, Payne, Welsh & Klingensmith, P.L.L.C. j41. 50 - P6 AT rBy: ntho S. sa, Esquire Pa. I.D. No. 89777 412. 60 " 0#&515547 P-V.a117371 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK N.A., ) CIVIL DIVISION a National Banking Association ) NO.: 05-04395 PRAECIPE FOR DEFAULT Plaintiff, ) JUDGMENT Filed on behalf of Plaintiff WELLS FARGO BANK, a National vs. ) Banking Association ) THEODORE HILL and KIMBERLY ) HII,L, Counsel of Record for This Parry: Defendants. ) REBECCA KEATING LEVENTOPOULOS PA I.D. # 90439 Payne, Welsh & Klingensmith r , 105 Penn Plaza. © Turtle Creek, PA 15145 rc_-. ._, T FIRM #658 (412)823-8100 JURY TRIAL DEMANDED ) THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK N.A., a National Banking Association ) CIVIL DIVISION NO.. Plaintiff, vs. ) THEODORE HILL and KIMBERLY ) HILL, ) Defendants. ) PRAECIPE FOR DEFAULT JUDGMENT TO: Cumberland County Prothonotary I Courthouse Square Carlisle, PA 17013 Kindly enter judgment in favor of the Plaintiff and against the above named Defendants in the amount of $22,773.43, plus costs and interest. An Important Notice was served upon Defendants on September 29, 2005 and is hereby attached as Exhibit ,A,,. Respectfully Submitted, Payne, Welsh do Klingensmith, Date: By: Rebecca Keating Leven poulos Pa. I.D. No. 90439 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK N.A., a National Banking Association Plaintiff, vs THEODORE HILL and KIMBERLY HILL, Defendants. JURY TRIAL DEMANDED CIVIL DIVISION NO.: 05-04395 IMPORTANT NOTICE Filed on behalf of plaintiff WELLS FARGO BANK, a National Banking Association Counsel of Record for This Party: REBECCA KEATING LEVENTOPOULOS PA I.D. # 90439 Payne, Welsh & Klingensmith 105 Penn Plaza , Turtle Creek, PA 15145 FJRM #658 (412)823-8100 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK N.A., a National Banking Association Plaintiff, vs. THEODORE HILL and KIMBERLY HILL, Defendants. CIVIL DIVISION NO.: TO: Kimberly Hill 162 Ken Lin Drive Carlisle, PA 17013 DATE OF NOTICE: 1-- 2- `'I - 4 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OF BY ATTORNEY AND FILE IN WRITING WITH THE COURT 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 FORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 DATE: ?" Zq?-'O? • Rebecca Keating Leventopoulo , sq. Attorney for Plaintiff CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within IMPORTANT NOTICE was served by U.S. Mail, first class, postage prepaid, upon the following; Kimberly Hill 162 Ken Lin Drive Carlisle, PA 17013 Theodore Hill 162 Ken Lin Drive Carlisle, PA 17013 DATE Rebecca Keating Leventopoulo , Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK N.A., a National Banking Association Plaintiff, vs. THEODORE HILL and KIMBERLY HILL, Defendants. JURY TRIAL DEMANDED CIVIL DIVISION NO.: 05-04395 IMPORTANT NOTICE Filed on behalf of Plaintiff WELLS FARGO BANK, a National Banking Association Counsel of Record for This Party: REBECCA KEATING LEVENTOPOULOS PA I.D. # 90439 Payne, Welsh & Klingensmith 105 Penn Plaza Turtle Creek, PA 15145 FIRM #658 (412)823-8100 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. EXHIBIT r. .; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK N.A., a National Banking Association CIVIL DIVISION NO.. Plaintiff, vs. THEODORE HILL and KIMBERLY HILL, Defendants. TO: Theodore Hill 162 Ken Lin Drive Carlisle, PA 17013 DATE OF NOTICE: J1-124 -0,55, IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OF 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. Lawyers Referral Service O' Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 DATE: ( /) - Rebecca Keating Leventopoulos Pa. I.D. No. 90439 Attorney for Plaintiff CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within IMPORTANT NOTICE was served by U.S. Mail, first class, postage prepaid, upon the following: Kimberly Hill 162 Ken Lin Drive Carlisle, PA 17013 Theodore Hill 162 Ken Lin Drive Carlisle, PA 17013 DATE Rebecca Keating Leventopoulos, Esquire CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within PRAECIPE FOR DEFAULT JUDGMENT was served by U.S. Mail, first class, postage prepaid, upon the following: Kimberly Hill 162 Ken Lin Drive Carlisle, PA 17013 Theodore Hill 162 Ken Lin Drive Carlisle, PA 17013 DATE Rebecca Keating Leventopoul s, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., a National Banking Association Vs. THEODORE HILL and KIMBERLY HILL 162 Ken Lin Drive Carlisle, PA 17013 CIVIL ACTION LAW No 10-5582 CIVIL TERM WRIT OF REVIVAL TO THEODORE HILL and KIMBERLY HILL You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the judgment entered to No. 05-4395 Civil Term The Plaintiff claims that the amount due and unpaid is $22,773.43 with interest from 10/17/05. 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 $ 141.50 PD ATTY $ 2.00 DUE CO David D. Buell, Prothonotary Date 8/26/10 (Seal) ANTHONY S. POSA, ESQUIRE - #89777 Attorney for the Plaintiff PAYNE, WELSH & KLINGENSMITH, PLLC 105 PENN PLAZA TURTLE CREEK, PA 15145 412-823-8100 Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~p1V Ot 4~i[3pbrr{,~~~ Jody S Smith Chief Deputy "~ ~, .. Richard W Stewart ''_ Solicitor F~~~ crr~;r s~F~~FF Wells Fargo Bank, NA Case Number vs. Theodore Hill (et al.) 2010-5582 SHERIFF'S RETURN OF SERVICE 09/28/2010 09:00 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 28, 2010 at 2100 hours, he served a true copy of the within Writ of Revival, upon the within named defendant, to wit: Kimberly Hill, by making known unto herself personally, at 162 Ken Lin Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $49.40 September 29, 2010 ~~ NOAH CLINE, DEPUTY SO ANSWERS, • RON R ANDERSON, SHERIFF ~ ~ ~ ~ ~-;~~~ r~ ` ~~ g-~-i-?"~ ,.~~_ r=~ wry. ~ c g --{ r._ ~ ~ t~ ~~> ~? ~ -ate ~/ v`~.. ~.n~ l ~ s Vie= "73 ~ ~ 3 ~-~~y~ lam" [ y 7 :i p+p- _.__I f f ~"1 ~~-e ~~ ~ ^ S ~ (ri CountySufte 7hen8~. Tei2osoff. Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~l~tr ~~ ~etiN~rh/,y~~~ ~: ," .3, . 1. F«e,r~ -,.G g~.~~iF~ TNT' P40~'N~ ~'~ ~ R, z~roncr 118 P~ ~: ~~~ ~tJ?~iBER(,A~D Cp~~-~~~ ~ ~~~~ ~P•~~~ ~;~E Wells Fargo Bank, NA vs. Theodore HiIF (et al.) Case Number 2010-5582 SHERIFF'S RETURN OF SERVICE AMENDED 09/28/2010 09:00 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 28, 2010 at 2100 hours, he served a true copy of the within Writ of Revival, upon the within named defendant, to wit: Kimberly Hill, by making known unto herself personally, at 162 Ken Lin Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. .~-i~~~` NOAH CLINE, DEPUTY 10/15/2010 03:45 PM -Jason Vioral, Sergeant, who being duly sworn according to law, states that on October 15, 2010 at 1545 hours, he served a true copy of the within Writ of Revival, upon the within named defendant, to wit: Theodore Hill, by making known unto himself personally, at The Cumberland County Sheriffs .Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. 4~~ DEPUTY SHERIFF COST: $49.40 October 15, 2010 ~~~ RON R ANDERSON, SHERIFF ~cj CouniySuite Sheriff. Teleo50ft. h?c. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK N.A., a National Banking Association v. THEODORE HILL and KIMBERLY' HILL, Defendant. CIVIL, DIVISION NO.: 10-5582 Fined on Behalf of: WELLS FARGO, Plaintiff. Counsel of Record For This Party: PETER J. PAYNE, ESQUIRE Pa. I. D. # 68902 Peter J. Payne & Associates 105 Penn Plaza Turtle Creek, PA 151.45 (412) 823-8100 THIS LAW FIRM IS ATTEMPTING TO COLLECT A DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P>=;NNSYLVANIA WELLS FARGO, ) CIVIL DIVISION Plaintiff, ) No.:10-5582 v. THEODORE BILL and KIMBERLY HILL, Defendant. ) PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter Peter J. Payne, Esquire and Peter J. Payne & Associates appearance on behalf of the Plaintiff, Wells Fargo Bank, N.A., in the above- captioned matter. Respectfully submitted, PET1~;R J. PAYNE & ASSOCIATES By: Date: __=_ ' ~~ Feter J. Wayne, Esquire PA LD. #68902 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO, Plaintiff, v. THEODORE HILL and KIMBERLY HILL, :Defendant. CIVIL, DIVISION No.: 10-5582 CERTIFICATE OF SERVICE I hereby certify that a true and. correct copy of the within PRAECIPE TO ENTER APPEARANCE was served by U.S. Mail, first class, .postage prepaid, upon the following: Kimberly Hill 162 Ken Lin Drive Carlisle, PA 17013 ~~, ;° , ~ , DATE Theodore Hi l 162 Ken Lin Drive Carlisle, PA 17013 ~~ ~' 1 ,,. Peter J. Payne, Esquire r ~ .. ~.,, + r, ~~ ;IiJ ~ ~:'~~,! [N THE C(;iURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK N.A., a National Banking Association u. THEODORI=; HILL and KIMBERLY HILL. Defendant. CIVIL DIVISION NO.: IO-5582 Code: PRA>E;CIPE FOR ENTRY OF JUDGMENT OF REVIVAL UPON DEFAULT Fined on Behalf of: WELLS FARGO, Plaintiff. Counsel of Record For This Party: PETER J. PAYNE, ESQUIRE P.a. L D. # 68902 Peter J. Payne & Associates 105 Penn Plaza Turtle Creek, PA 15145 (412) 823-8100 THIS LAW FIRM IS ATTEMPTING TO COLLECT A DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSF, C~.~ ~i~q ,~ a Saco?~ ~~,~ ~,,,\ed IN THF, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO, Plaintiff, V. THEODORE HILL and KIMBERLY HILL.. Defendant. C'IVII. DIVISION No.: ~f;•5-995 PRAECIPE TO ENTER JUDGMENT OF REVIVAL UPON DEFAULT To The Prothonotary: Enter Judgment of Revival iri favor of Plaintiff Wells Fargo, and Against Defendant Theodore Hill and Kimberly Hill, and for failure to file an answer and otherwise plead to the Writ of Revival within twenty days of service thereof, and assess damages as follows: Original (Revived} Judgment $22,773.43 Costs $~ Interest from October 17, 2005 $~ Attached as Exhibit "A" is a copy of Plaintiff's written notice of intention to file Praecipe for Entry of Default Judgment which I certify was mailed. by regular mail (or delivered) to the defendant at his or her last known address and to his or her attorney of record on October 26, 2010. which is at least ten days prior to the filing of this Praecipe. Dated: ~_% ,~ ~r, , ~ ~~ BY~_ Peter J., ayne Attorney for Plaintiff Pa. I.D. No. 68902 Judgment of Revival Entered and Damages Assessed as Above IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO, Plaintiff, V. THEODORE HILL and KIMBERLY HILL, Defendant. CIVIL DIVISION No.: (5 i C' ~ S d' CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within PRAECIPE .FOR ENTRY OF JUDGMENT OF REVIVAL UPONDEFAULT was served by Li.S. Mail, first class, postage prepaid, upon the following: e ,.\ ~ --` DATE Kimberly Hill 162 Ken Lin L)rive Carlisle, PA 1'7013 Theodore Hill 162 Ken Lin L)rive Carlisle, PA 1'7013 Peter J. Payne, Esquire ~ , ; ~ _ _ ~ ~~ - ~ '.~:_'; P , 0~2/ 004 ~" ~ ~!F P~0 UN~r~O~~ U t t~ , 2oia ocr 2~ r~j~ 2: 3 r cu~~~~a $~ ~~~ auttr ,, r;~p, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS .FARGO BANK N.A., a National Banking Association Plaintiff, CIVIL DIVISION NO„ OS-04395 NOTICE OF INTENTION TO FXLE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT OF REVIVAL V5. THEODORE HILL and KIMBERLY HILL, Defendants. Filed on behalf of Plaintiff WELLS FARGO BANK, a National Banking Association Counsel of Record for This Party: ANTHONY S. POSA, ESQUIRE PA I.D, # $9777 Payne, Welsll & Klingensmith 105 Perm Plaza Turtle Cxeek, PA 15145 FIRM #65$ (412)823-8100 JURY TR[AL DEMANDED ) TINS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. EXHIBIT IN '~'H:1~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK N.A., a National Banking Association CIVIL DIVISION 'KO.. Plaintiff, vs. THEODORE HILL and KIMBERLY HILL, Defendants. IMPORTANT NOTICE YUU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WIT>EI><N TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. L' awyer Referral Service 4`h Floor, Cumberland County Courthouse CnrlIsle, PA 17013 (71'~ 240-6200 DATE: - U ~r .... ~,^.. Anthony S. Posa, Esquire Attorney for Plaintiff 7•rnFr-,,,,~ ~ _ - ^4~n0e IN THIS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO $ANK N.A., a National Banking Association Plaintiff, CIVIL DIVISION ENO.. vs. ) TFIEODC)RE HILL and KIMBERLY ) HILL, ) Defendants. ) CERTTFZCATE OF SERVICE I hereby certify that a true and correct copy of the within NOTICE OF INTENTION TO FILE PI2AECIPE FOR ENTRY OF 1,7EFAULT NDGIVIENT OF REVIVAL was served by 1J.S. Mail, first class, postage prepaid, upon the following: Kimberly Hill 162 Ken Lin Drive Carlisle, PA 17Q13 Theodore Hill 162 Ken Lin Drive Carlisle, PA 17G13 DATE ~r~~~ Anthony S. Posa, Esquire