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Home My WebLink About11-8858SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith .SAN 20 AM 8: Chief Deputy 21 Richard W Stewart CUMBERLAND i oUfli'' Solicitor F r. P T?E PENNSYL14NIA State Farm Automobile Insurance Company vs. B's Automotive Sales and Service Case Number 2011-8858 SHERIFF'S RETURN OF SERVICE 11/29/2011 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: B's Automotive Sales and Service, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Schuylkill County, Pennsylvania to serve the within Complaint and Notice according to law. 01/09/2012 12:03 PM - Schuylkill County Return: And now January 9, 2012 at 1203 hours I, Joseph Groody, Sheriff of Schuylkill County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: B's Automotive Sales and Service by making known unto Brian Buchunsky, adult in charge for B's Automotive Sales and Service at 430 E. Railroad Street, Pottsville, Pennsylvania 17901 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 January 17, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (o) Coi 'ySu`te Shenff, "(eleosefi. inn e Wed Jan 11, 2012 10:59AM PAGE: 1 SHERIFF'S DEPARTMENT OF SCHUYLKILL COUNTY SCHUYLKILL COUNTY COURT HOUSE POTTSVILLE, PENNSYLVANIA 17901 (570) 622-5570 ** A F F I D A V I T O F R E T U R N DEPUTIZED FROM CUMBERLAND COUNTY PLAINTIFF: STATE FARM AUTOMOBILE INSURANCE COMPANY ETAL COURT NUMBER 2011-8858 V S FILED BY WEBER,GALLAGHER, SIMPSON,STAPLE DEFENDANT: B'S AUTOMOTIVE SALES AND SERVICE TYPE OF PAPER CIVIL ACTION SERVING NUMBER 68015 PEOPLE: PRO FILE DATE 11/28/2011 EXPIRATION 12/28/2011 SHF RECEIVED 11/28/2011 ------------- ------------- ----------------- DEP RETURNED 01/11/2012 ---------------------- (P E 0 P L E T O ------------------- B E S E R V E D) ------------------ --------- ------------------- NAME ADDRESS 1 ADDRESS -------------------- ------------ 2 CITY ST ZIP DEPUTY Service for -------- -------- B'S AUTOMOTIVE SALES 430 E RAILROAD STREE ------------ ---- POTT ---------------- SVILLE -- ----- PA ------------------ CHAPLICK, S (A T T E M P T S A T S E R V I C E) SEQ DATE --- ------- TIME SERVED TO ADDRESS 1 --- ----- --------------- - --- --- ADDRESS 2 CITY ST ZIP MILES COST 1 01/09/2 ---_--------- - -- 012 12:03 BRIAN BUCHUNSKY 430 RAILROAD ST ------ -------- ---------- - -- POTTSVILLE -- ----- PA 17901 ----- ------------ MINIM 11.10 * REMARKS : SERVICE MADE BY DEPUTY CHAPLICK, S ------------ Total 11.10 Total Mileage Charge for all Services 11.10 .Wed Jan 11, 2012 10:59AM SHERIFF'S DEPARTMENT OF SCHUYLKILL COUNTY SCHUYLKILL COUNTY COURT HOUSE POTTSVILLE, PENNSYLVANIA 17901 (5701 622-5570 ** A F F I D A V I T O F R E T U R N ** I hereby CERTIFY and RETURN that service was made by handing a TRUE and ATTESTED COPY to : PAGE: 2 BRIAN BUCHUNSKY (A.P.I.C) ON 430 RAILROAD ST 01/09/2012 POTTSVILLE PA at 12:03 SWORN and subscribed be'ore me this _ t4-k _ SO ANSWERS day of r ?? \ (Deputy Sheriff) G (Pr onota (Sheriff of Schuylkil County) End - of - Return (X-432-2011) y f 9 .. ?J 2;,1,2 FE93 23 P 1 * 23 '010MBERLAMD CGUN T Y PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Plaintiff, vs. B'S AUTOMOTIVE SALES AND SERVICE,, Defendant. CIVIL DIVISION - ARBITRATION No.: 11-8858 Civil PLAINTIFF'S PRAECIPE FOR DEFAULT JUDGMENT PURSUANT TO Pa.R.C.P. 1037(b) 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 14th Floor Pittsburgh, PA 15222 Telephone: (412) 281-4541 Fax: (412) 281-4547 Qr,,A ???o• ?? a? Ck 30-?5? a-??ya$ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY., Plaintiff, vs. B'S AUTOMOTIVE SALES AND SERVICE, Defendant. CIVIL DIVISION - ARBITRATION No.: 11-8858 Civil 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 defendant B's Automotive Sales and Service 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 $1,287.25. 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, WEBER GALLAGHER SIMPSON STAPLETON FgX.iS & NEWBY LLP /? Jl Travis L. McElhaney, s ire Dated: 7- ! ?`O / 1 Counsel for Plaintiff 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION - ARBITRATION No.: 11-8858 Civil Plaintiff, vs. B'S AUTOMOTIVE SALES AND SERVICE, Defendant. TO: B's Automotive Sales and Service 430 E. Railroad Street Pottsville, PA 17901 Date of Notice: February 6, 2012 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP Travis L. McElhaney, Esq Counsel for Plaintiff I 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'16_ day of February, 2012, to the following: B's Automotive Sales and Service 430 E. Railroad Street Pottsville, PA 17901 Travis L. McElhaney, s ire Counsel for Plaintiff i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, CIVIL DIVISION - ARBITRATION No.: 11-8858 Civil Plaintiff, vs. B'S AUTOMOTIVE SALES AND SERVICE, Defendant. To: B's Automotive Sales and Service 430 E. Railroad Street Pottsville, PA 17901 236 NOTICE NOTICE IS GIVEN THAT A JUDGMENT IN THE OVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. VOW a1a ..?wx?..f u David Buell Prothonotary IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Travis L. McElhane Es ure 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