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Home My WebLink About11-2586w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, V. HEATHER RAISIG and, BRIAN COOK, Plaintiff, Pi' 2.0 CIVIL DIVISION ' t3ERL AIN0 COUNT" pEN"JSYLVANIA No.: 2011-2586 Defendants. WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of Plaintiff, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, in the above-captioned matter. Dated: ly S.*'vart C`.'GrawfN, Esquire ''PA Supreme Court M. # 202188 223 North Monroe Street Media, PA 19063 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Plaintiff, STATE FARM MUTUAI. AUTOMOBILE INSURANCE COMPANY, in the above-captioned matter. Respectfully submitted, WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY L Travis L. McElhane} , squire PA Supreme Court I. D. # 204023 Two Gateway Center, Suite 1450 Pittsburgh, PA 15222 / Aa Dated: _'- ? ? CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing PRAECIPE FOR WITHDRAWAL/ENTRY OF APPEARANCE was served upon the following party by first class mail, postage prepaid, this day of April, 2012, to the following: Heather Raisig 536 N. West Street Carlisle, PA 17013 (Defendant) Brian Cook 536 N. West Street Carlisle, PA 17013 (Defendant) Travis L. McElh ey squire Counsel for Plain z IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL CIVIL DIVISION - ARBITRATION AUTOMOBILE INSURANCE - _ e - COMPANY, No.: 2011-2586 Plaintiff, vs. PLAINTIFF'S PRAECIPE FOR y? - DEFAULT JUDGMENT PURSUANTR c ,` HEATHER RAISIG TO Pa.R.C.P. 1037(b) and BRIAN COOK, - ` Defendants. Filed on behalf of Plaintiff Counsel of Record for this Party: Travis L. McElhaney, Esquire PA I.D. #204023 Christopher P. Deegan, Esquire PA I.D. #85635 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY, LLP Firm #594 Two Gateway Center 14`h Floor Pittsburgh, PA 15222 Telephone: (412) 281-4541 Fax: (412) 281-4547 a? a ?? Sb ?l aN? 2- ol -7 9 7/ ?\(b ?U %I-led IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, vs. HEATHER RAISIG and BRIAN COOK, Defendants. CIVIL DIVISION -- ARBITRATION No.: 2011-2586 PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT PURSUANT TO Pa.R.C.P. 1037(b) To the Prothonotary: Kindly enter judgment in favor of plaintiff State Farm Mutual Automobile Insurance Company and against defendants Heather Raisig and Brian Cook for failure to file an Answer or otherwise respond in the above-captioned action within twenty (20) days of the date of service of the Complaint, and assess plaintiff's damages against defendant in the amount of $3,561.64. I certify that a written notice of intention to file this praecipe was mailed to defendant after the default had occurred and at least ten (10) days before the date of the filing of this praecipe. A copy of this notice is attached. I further certify that the defendant is not in active military service. The undersigned verifies that the statements of fact in the Praecipe are true and correct and are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsifications to authorities. Respectfully submitted, Dated: 1 /30 ((-Z- GALLAGHER SIMPSON STAPLETON WEBER FIRES & NEWBY LLP 11? k4 ?, Travis L. McElhane squire Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, vs. HEATHER RAISIG and, BRIAN COOK, Defendants. TO: Heather Raisig 536 N. West Street Carlisle, PA 17013 Date of Notice: April 13, 2012 CIVIL DIVISION No.: 2011-2586 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 (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 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP „ Travis L. McElhan Counsel for Plainti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, vs. HEATHER RAIS IG and, BRIAN COOK, Defendants. TO: Brian Cook 536 N. West Street Carlisle, PA 17013 Date of Notice: April 13, 2012 CIVIL DIVISION No.: 2011-2586 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 (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 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 WEBER GALLAGHER SIMPSON STAPLETON FIRE & NEWBY LLP - 4t4? Travis L. McElhaney Esquir Counsel for Plaintif IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION -- ARBITRATION No.: 2011-2586 Plaintiff, VS. HEATHER RAISIG and BRIAN COOK, Defendants. AFFIDAVIT OF NON MILITARY SERVICE The undersigned, being duly sworn, according to law, deposes and says that the Defendant (s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; That Defendant, Heather Raisig, age unknown, has a place of residence at 536 North West Street, Carlisle, Pennsylvania 17013. Travis L. McElhaney, uire Attorney for Plaintiff Attorney I.D.# 204023 Two Gateway Center, Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 Phone: (412) 281-4541 Swor}4?t,o,, and subscribed before me thi l ..day of April, 2012 A.D. r --N?o a_ry Fib ??? !,s-atary P?ablic ! Crts 's gihe+, Coun:y 12013 4 err 'r ?': of Notaiies IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION -- ARBITRATION No.: 2011-2586 Plaintiff, vs. HEATHER RAISIG and BRIAN COOK, Defendants. AFFIDAVIT OF NON MILITARY SERVICE The undersigned, being duly sworn, according to law, deposes and says that the Defendant (s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; That Defendant, Brian Cook, age unknown, has a place of residence at 536 North West Street, Carlisle, Pennsylvania 17013. Travis L. McElhane squire Attorney for Plaintiff Attorney I.D.# 204023 Two Gateway Center, Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 Phone: (412) 281-4541 Swo to and subscribed before me thhday of April, 2012 A.D. ?F1 OF PE N!S`(LVANIA Notaria! ZS,-,@1 fsani € 9 L W011011"15, Notary Publie City of Pr hr [rah, > Isnghr ny Gourity rp mrn is i k:'xE: r f ,mob, t 1 24 i_3 Yv?es per ! , ri'an::, su rjan ,f Motaro2s CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing Plaintiff's Praecipe for Default Judgment Pursuant to Pa.R.C.P. 1037(b) was served upon the following defendant by Certified U.S. Mail, postage prepaid, this day of April, 2012, to the following: Heather Raisig 536 North West Street Carlisle, PA 17013 Brian Cook 536 North West Street Carlisle, PA 17013 r VVYI Vk, Travi L. McElhaney, E ire Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, vs. HEATHER RAISIG and BRIAN COOK, Defendants. To: Heather Raisig 536 North West Street Carlisle, PA 17013 CIVIL DIVISION -- ARBITRATION No.: 2011-2586 236 NOTICE NOTICE IS GIVEN THAT A JUDGMENT IN THE BOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. David D. Buell Prothonotary IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: l Travis L. McElhaney, squire PA I.D. No.: 204023 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Two Gateway Center - Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 (412) 281-4541 t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION -- ARBITRATION No.: 2011-2586 Plaintiff, VS. HEATHER RAISIG and BRIAN COOK, Defendants. To: Brian Cook 536 North West Street Carlisle, PA 17013 236 NOTICE NOTICE IS GIVEN THAT A JUDGMENT IN T AB C NED M ER HAS BEEN ENTERED AGAINST YOU. s)y 1a IF YOU HAVE ANY QUESTIONS CONTACT: David D. Buell Prothonotary CONCERNING THE ABOVE, PLEASE ITras L. McEI aney, E6/ire PA I.D. No.: 204023 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Two Gateway Center - Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 (412) 281-4541 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL ) CIVIL DIVISION - ARBITRATION AUTOMOBILE INSURANCE ) COMPANY ) No.: 2011-2586 Civil Term a , Plaintiff, ?" ) M 6V ?-- vs. -W m ) =7r. C r-- Q> HEATHER RAISIG ) -? And BRIAN COOK, Defendants. ) - AFFIDAVIT I, Travis L. McElhaney, Esquire, do hereby certify that the judgment entered against above named defendant, Heather Raisig, was the result of a motor vehicle accident that on or about November 27, 2010. I also verify that the statements in this Affidavit are true and correct. I understand false statements herein are made subject to the penalties of 18 Pa. C.S.A.§ 4904 relating Unsworn Falsification to Authorities. Date: 12- Sworn to and Subscribed before me this /3/Aday of JWy 2012 A.D. Notarial Seal Denise M. Williams Nota'Y Public City 0i ittsburgh, Allegheny county ev Commission Expires Feb. 11, 2013 Travis L. McElhan, squire PA I.D. No.: 204023 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Two Gateway Center - Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 (412) 281-4541 *a all 01 . AD A`MV aAs 80(0( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL ) CIVIL DIVISION - ARBITRATION AUTOMOBILE INSURANCE ) COMPANY, ) No.: 2011-2586 Civil Term Plaintiff, I vs . HEATHER RAISIG ) .. And BRIAN COOK, ) , Defendants. ) 1 C-, ::9 == AFFIDAVIT 1 I, Travis L. McElhaney, Esquire, do hereby certify that the judgment entered against tl e I above named defendant, Brian Cook, was the result of a motor vehicle accident that occurred ?n or about November 27, 2010. I also verify that the statements in this Affidavit are true and correct. I understand false statements herein are made subject to the penalties of 18 Pa. C.S.A.§ 4904 relating Unsworn Falsification to Authorities. Date: 13 2 Sworn to and Subscribed before me this/3#--day 2012 A.D. of ply Notarial Seal Denise M. Williams, Notary Public City of Pittsburgh, Allegheny County 7v Commission Expires Feb., 2013 Trav s L. McElhane squire PA I.D. No.: 204023 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Two Gateway Center - Suite 1450 603 Stanwix Street Pittsburgh, PA 15222 (412) 281-4541 $595 1 CON MR &17sc Arr/