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Home My WebLink About11-285702-5110 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 PENNSYLVANIA STATE CREDIT UNION, V. NICHOLAS J. GRAYBILL, q$4 M" Late. 4al rl S1ou,vc1, P A M 111 O11 t?iAR -8 P? { ? 1 ? rUMBERLAND COtIt?TY pEWySYLVAI?4A YEES Plaintiff Attorneys for Plaintiff Pennsylvania State Employees Credit Union IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Revival No. 1A Judgment entered on September 3, 2003 No. 02-5110 TO THE PROTHONOTARY: Issue a Writ of Revival of index against Nicholas J. Graybill S ?aq•? 1 ? a? 99.19a CU 6 ,9. So kDo. A) St, ,30 .? 1S.oo ttc? So. So ?? << 9.00' ,e sp y D lea aj+y 314-12381 entered to No. 02-5110 and index it in the judgment in the amount of $18,059.64, plus court costs and interest. Due ?% Shawn Long, Esquir Court I.D. No. 837 4 Attorneys for PI i tiff, Pennsylvania State Employees Cre it Union 126 East King treet Lancaster, PA 17602-2893 (717) 299-5201 'Clctt- 4 ?? 1?3 BARLEY SNYDER LLC By:_'l/ L/ `-? / IN THE COURT OF COM PENNSYLVANIA STATE Vs. NICHOLAS J. GRAYBILI TO NICHOLAS J. GRAY1: You are notified that the PI, the judgment entered to The Plaintiff claims that the You are required within twe plead to this Writ. If you fa: Costs $ 424.40 1?'aL 094- '2 ..a o L c,?,? (a Date 3/8/2011 (Seal) SHAWN LONG, ESQUIRE Attornev for the Plaintiff 126 EAST KING STREET LANCASTER, PA 17602-2893 ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MPLOYEES CREDIT UNION CIVIL ACTION LAW No 11-2857 CIVIL TERM WRIT OF REVIVAL has commenced a proceeding to revive and continue the lien of No. 02-5110 Civil Term mount due and unpaid is $18,059.64 with interest from y (20) days after service of this Writ to file an answer or otherwise, to do so, Judgment of revival will be entered. David D. Buell, Prothonotary Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy FILED-OFFICE C.' THE PROTHONOTARY 2011 MAR 30 PM 2: 27 Richard W Stewart Solicitor CUMBERLAND COUNTY PENNSYLVANIA Pennsylvania State Employees Credit Union vs. Nicholas J. Graybill Case Number 2011-2857 SHERIFF'S RETURN OF SERVICE 03/09/2011 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: Nicholas J. Graybill, but was unable to locate him in hi: bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Writ of Revival according to law. 03/23/2011 Dauphin County Return: And now, March 23, 2011 I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Nicholas J. Graybill the defendant named in the within Writ of Revival and that I am unable to find him in the County of Dauphin and therefore return same NOT FOUND. Tina Allison current resident of 984 Martin Lane, Harrisburg, Pennsylvania 17111 advised Deputies, Nicholas J. Graybill was her daughters exboyfriend from 10 years ago and does not reside at this address. SHERIFF COST: $37.00 March 28, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF rc; CourrySu;te ?he:r,.'f iseie<so?*. li°;; William T. Tully Solicitor Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin PENNSYLVANIA STATE EMPLOYEES CREDIT UNION VS NICHOLAS J GRAYBILL Sheriff s Return No. 2011-T-1181 OTHER COUNTY NO. 20112857 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for NICHOLAS J GRAYBILL the DEFENDANT named in the within WRIT OF REVIVAL and that I am unable to fmd him/her in the County of Dauphin, and therefore return same NOT FOUND, MARCH 23, 2011. 3/23/11 AS PER TINA ALLISON RESIDENT, AT 984 MARTIN LANE, HARRISBURG, PA 17111, DEFT WAS HER DAUGHTERS BOYFRIEND THEY BROKE UP OVER 10 YEARS AGO Sworn and subscribed to before me this 24TH day of March, 2011 -)P*iz COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17, 2014 So Answers, °Sheriff of Dauphin County, Pa. "? m _ GLU By 141 Depu heriff Deputy: KIMBERLY ?ARTO Sheriffs Costs: $58 3/14/2011 J.R. LOTWICK SHERIFF OF DAUPHIN COUNTY COUNTY OF DAUPHIN t HARRISBURG, PA. OFFICAL RECEIPT File # Case Number Document Type 2011-T-1181 WRIT OF REVIVAL Operator: 2555 Primary Defendant: NICHOLAS J GRAYBILL Cash Accounting Rec. Date Cat. Transaction Type Deposit Type Receipt Number Check From 1 Amount 3/14/2011 Deposit County Civil Action-Notice Check 11-139388 BARLEY SNYDER $58.00 Total Number of Rows: 1 Total Paid $58 IRECD. BY 3/14/2011 1:52:13 PM BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. NICHOLAS J. GRAYBILL, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Revival No. 11-2857 Judgment entered on September 3, 2003 No. 02-5110 Defendant VERIFICATION Kelly Cunneen, hereby verifies that on May 20, 2011 service of the Writ of Revival was served by publication upon the Defendant, Nicholas J. Graybill, in accordance with Order of Court dated May 6, 2011 in The Cumberland Law Journal and The Sentinel. Proofs of publication in The Cumberland Law Journal and The Sentinel are attached hereto and marked Exhibit "A". BARLEY SNYDER LLC Dated: June 3, 2011 By: Kelly unne , Paralegal 126 East King Street Lancaster, PA 17602 717.299.5201 C ? rq ZM -A. C 1-- -0m 32381171 EXHIBIT "A" 74 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz May 20, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. a Marie Coyne, fiditor SWORN TO AND SUBSCRIBED before me this 20 day of May, 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law 11-2857 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff vs. NICHOLAS J. GRAYBILL Defendant NOTICE To: NICHOLAS J. GRAYBILL You are hereby notified that on February 18, 2011, Plaintiff, Pennsyl- vania State Employees Credit Union, filed a Writ of Revival endorsed with a Notice to Defend against you in the Court of Common Pleas of Cumber- land Count, Pennsylvania, docketed to No. 11-2857, which has been reinstated, wherein Plaintiff seeks to enforce its rights under its loan documents. Since your current whereabouts are unknown, the Court by Order dated May 6, 2011, ordered notice of said facts and the filing of the Writ of Revival to be served upon you as provided by R.C.P. 430(b). You are hereby notified to plead to the above referenced Writ of Revival on or before 20 DAYS from the date of this publication or Judgment will be entered against you. NOTICE You have been sued in Court. If you wish to defend, you must enter a written appearance personally or by attorney, and file your defenses or objections in writing with the Court. You are warned that if you fail to do so, the case may proceed without you and a Judgment may be entered against you without further notice for the relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NO- TICE 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 INFORMA- TION 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 RE- DUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 (800) 999-9108 SHAWN M. LONG, ESQUIRE BARLEY SNYDER LLC 126 East King Street Lancaster, PA 17602 (717) 299-5201 May 20 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Taclde Cox, Retail Sales Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): May 20, 2011 a Ir7f COPY OF NOTICE OF PUBLICATION =P.,?14hSYLYA NIA' x° Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication ue. ABOUT HIRING AiAWYER , '" IF Y,QU 70}i1FI LfNALY ,{'F ISLl?f.IGEMAY-,a6ABifE?4RO1VE.YOU WIT?i INE'C3?[Mg.Tk7N o E'. C? TNATI1I OFFERMLEGAL SERVICES TO ELaBMFERSONS WWI . REDUCED FEE l?i'NO FEE. . Cumberland County Lawy, Reterrat Service : 32 SoutlEBeAf0M Street Cat", PA 17043 80173999-9108 -, _ Shawn M. Long, Esquire BARLEY SNYDER LLIt - 126E l(1ng Street Lancaster, PA 17802. Sworn to a d subscribed before me this 2-T-'' FYI 2O I l . Notary Public My commission expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH. CUMBERLAND CNTY My Commission Expires Jan 27. 2014 11-2857 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 c ? ?y zM c ?? -. X X r- r cnr- N c:? C= C- ) Cz -' tl Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. NICHOLAS J. GRAYBILL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Revival No. 11-2857 Judgment entered on September 3, 2003 No. 02-5110 PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, Pennsylvania State Employees Credit Union and against Defendant, Nicholas J. Graybill for want of an answer in the amount of $18,059.64 plus interest and costs of suit. (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( ) Pursuant to Pa. R.C.P. 237 (notice of praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record.. * 14.00 PJO A-r Y pto2&a/98 32674641 11-2857 (X) Pursuant to Pa. R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. Date: -, ?zt (1 BARLEY SNYDER LLC By: SOawn M. Long, quire Court I.D. No. 83 74 Attorneys for Plaintiff Pennsylvania State Employees Credit Union 126 East King Street Lancaster, PA 17602 (717) 299-5201 NOW, QUIM o2j , 2011, JUDGMENT IS ENTERED AS ABOVE. Prothonot lerk, Civil Division By: Deputy 32674641 11-2857 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY OFFICE OF THE PROTHONOTARY CARLISLE, PA TO: Nicholas J. Graybill Defendant YOU ARE HEREBY NOTIFIED that Pennsylvania State Employees Credit Union has caused a judgment by default to be entered against you with the Prothonotary of Cumberland County. The judgment was entered on to No. 11-2857 with the 7-T Court of Common Pleas of Cumberland County - Civil Division. The judgment is in the amount of $18,059.64 plus costs of suit. PROT ONOTARY By: 32674641 11-2857 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. NICHOLAS J. GRAYBILL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Revival No. 11-2857 Judgment entered on September 3, 2003 No. 02-5110 AFFIDAVIT THAT THE DEFENDANT IS NOT IN THE MILITARY SERVICE. PURSUANT TO "SOLDIERS AND SAILORS" CIVIL RELIEF ACT OF 1918, RE-ENACTED 1940 The undersigned, Shawn M. Long, Esquire, doth depose and say that Nicholas J. Graybill, the Defendant is not in the Military or Naval Service, based on the following facts: Age of Defendant is unknown; Present place of employment is unknown; Last known place of Residence is 984 Martin Lane Harrisburg, PA 17111 as of the date of this affidavit. ADDITIONAL FACTS, if any. The statements set forth in this affidavit are made subject to the penalties of 18 Pa. C.S._ §4904, relating to unsworn falsification to authorities. BARLEY SNYDER LLC By: squire Shawn M. Lotaintiff Attorneys for Court I.D. No. 83774 126 E. King Street Lancaster, PA 17602 717.299.5201 32674641 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff V. NICHOLAS J. GRAYBILL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Revival No. 11-2857 Judgment entered on September 3, 2003 No. 02-5110 VERIFICATION Kelly Cunneen, hereby verifies that on July 1, 2011 service of the 10-Day Notice was served by publication upon the Defendant, Nicholas J. Graybill, in accordance with Order of Court dated May 6, 2011 in The Cumberland Law Journal and The Sentinel. Proofs of publication in The Cumberland Law Journal and The Sentinel are attached hereto and marked Exhibit "A". BARLEY SNYDER LLC -/k/i i &A By: elly Cunnee Paralegal 126 East King Street Lancaster, PA 17602 717.299.5201 Date: July 6, 2011 3267454 1 EXHIBIT "A" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication. of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz July 1, 2011 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice; or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie Coyne, SWORN TO AND SUBSCRIBED before me this 1 day of July, 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law No. 11-2857 PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Plaintiff vs. NICHOLAS J. GRAYBILL, Defendant IMPORTANT NOTICE BARLEY SNYDER LLC 126 East King Street Lancaster, PA 17602-2893 (717) 299-5201 July 1 To: Nicholas J. Graybill You are in default because you have failed to enter a written appear- ance 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 en- tered against you without a hearing and you may lose your property or other important rights. YOU SHOULD TAKE THIS PAPER TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING 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 RE- DUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 (800) 999-9108 SHAWN M. LONG, ESQUIRE I.D. No. 83774 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Jackie Cox, Sales Director, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13f,1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): uT 1y 1, 2011 COPY OF NOTICE OF PUBLICATION s CL O D V W a a - y U O a r k yUy?? 2 Z Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and I Z?" AM me this P1I Notary Public My commission expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commission Expires Jan 27, 2014 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland s W CL z o? U U ? to W } S? 0 LLU? Wa IN ?r y IL U y O a r z Jackie Cox, Sales Director, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SEN'T'INEL on the following day(s): July 1, 2011 COPY OF NOTICE OF PUBLICATION? a Al J z 0 3 00 ¢o G wQF° ?+? 0 iloLL6 z 14V, <¢Z Wn? %8 0 o a U Niot ' irther deposes that he/she is not ° - P1 in the subject matter of the i m° notice or advertisement, and that °k _ Lions in the foregoing statement as lace and character of publication ao 7> i o;q a Rw f d z z Oa W - OW LLLL WU. U Y ON Q~ 0 ,sue } } W W ?m Q Op <WW 159 U o1W ?jf a?U R" 05 l ° U ? W dssion expires: NOTARIAL SEAL BAMBI ANN HECKENDORN Notary Public cIMNLISLE BOROUGH, CUMBERLAND CNTY My Commission Expires Jan 27, 2014 Notary Public