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Home My WebLink About12-0150F. TILES\Clients\7619 Dickinson College\7619.Collections\7619.C. Current\401 Jonas\7619C.401.pra.reinstate Christopher E. Rice, Esquire _ THE TNON4`?ti`` Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALL hpR 25, ' AM ' MARTSON LAW OFFICES T E t Hi h S CDi?T?r ERLAND en as g treet CUN18 1414SYLVNNIA Carlisle, PA 17013 PE (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2012 - 150 DIANA B. JONAS, CIVIL ACTION - LAW Defendant PRAECIPE To the PRothonotary: Please reinstate the Complaint in the above-referenced matter. MARTSON LAW OFFICES By: (fir ?i Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: Attorneys for Plaintiff THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR DICKINSON COLLEGE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. F:\FILES\Clients\7619 Dickinson College\7619.Collections\7619C.Current17619C.401 Jonas\7619C.401as Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff -mot _ r? s _ cp LK DICKINSON COLLEGE, Plaintiff V. DIANA B. JONAS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2012 - 150 CIVIL ACTION - LAW PROOF OF SERVICE AND COST OF SERVICE To the Prothonotary: Attached is the Affidavit of Service indicating Defendant was served with the Complaint on May 7, 2012, at a cost of $65.00 for service. This is a debt collecting firm attempting to collect a debt for Dickinson College. Any information obtained will be used for that purpose. MARTSON LAW OFFICES Date: r' Christopher E. Rice, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA I AFFIDAVIT OF SERVICE *131776* Index no : 2012-150 Date Index Number Purchased: 01/13/2012 Plaintiff(s): DICKINSON COLLEGE Defendant(s): DIANA B. JONAS STATE OF NEW YORK COUNTY OF NASSAU ss.: GARY CARDI, the undersigned, being duly sworn, deposes and says that I was at the time of service over the age of eighteen and not a party to this action. I reside in the STATE OF NEW YORK. On 05/05/2012 at 1:16 PM, I served the within NOTICE AND COMPLAINT on DIANA B. JONAS at 451 CENTRE ISLAND ROAD, OYSTER BAY, NY 11771 in the manner indicated below: SUITABLE AGE: By delivering a true copy of said documents to Maria Jonas, FAMILY MEMBER, a person of suitable age and discretion. Said premises is defendant's place of residence within the state. On 05/07/2012, deponent enclosed a copy of above mentioned documents to DIANA B. JONAS at said defendant's Actual Place of Residence, at 451 CENTRE ISLAND ROAD, OYSTER BAY, NY, 11771 in a 1 st Class postpaid properly addressed envelope not indicating that the mailing was from an attorney or concerned legal action and marked "Personal and Confidential" in an official depository under the exclusive care and custody of the United States Post Office. Comments: RECIPIENT SIGNED DEPONENT'S WORK ORDER SHEET FOR DOCUMENTS A description of the defendant, or other person served on behalf of the defendant is as follows: Sex Color of skin/race Color of hair A e height Wei ht Female White Brown 60 5" 0"-5" 3" 100-1301bs Other Features: Your deponent asked the above mentioned recipient whether the defendant was active in the military service and received a negative reply. Upon information and belief I have; being based on the conversations and observations above narrated, defendant is not active in the military service. Sworn to and subscribed before me 05/07/2 - - C Dominique Suazo Notary Public, State of N York O 1 SU6223278 Qualified in Nassau Commission expires, JUN 7,2014 X A:Ecu-Serve Ltd. 1600 Stewart Avenue, Suite 308 Westbury,NY 11590 516.565.2228 PRO SE Atty File#: RECEIVED A E ' _ `` ivi AR "For The Accuracy In Due Process You Des ve" Bill To Martson Law Offices 10 East High Street Carlisle, PA 17013 Invoke Date Invoice # 5/8/2012 137900 Client # 131776 Index # - Accu-Serve 150-2012 Description Amount DICKINSON COLLEGE VS DIANA B JONAS NOTICE AND COMPLAINT Diana B. Jonas Serve 65.00 Paid check #25497 for $65.00 on 4/26/12 Accu-Serve, Ltd. 1600 Stewart Avenue Terms Due on receipt Total $65.00 Suite 308 Westbury, NY 11590 Tel: (516) 565-2228 Fax: (516) 565-2248 F WILES\Clients\7619 Dickinson College\7619.Collections\7619C.Current\7619C.401 Jonas\7619C.401.pra.default.wpd Christopher E. Rice, Esquire L Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER f; ` Ali t, MARTSON LAW OFFICES Ten East High Street ;Li NiEic RL A.) Carlisle, PA 17013 PENNSYLVANIA (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2012 - 150 DIANA B. JONAS, : CIVIL ACTION - LAW Defendant PRAECIPE TO THE PROTHONOTARY: Please enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant Diana B. Jonas in the amount of$2,301.68, plus interest accruing at 5% per annum thereafter,collection and attorneys'fees in the amount of$500.00 and costs of suit for failure to file an Answer to Plaintiffs Complaint. I do hereby certify that written notice of intention to file this Praecipe was mailed to Diana Jonas on June 18, 2012, which date is subsequent to the date default occurred and at least ten(10) days prior to the date of this Praecipe. MARTSON LAW OFFICES By: C16 l� Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: (p/ //[_ Attorneys for Plaintiff 4-16.31' Pika4 16141415 F FILESVClients V7619 Dickinson CollegeA7619 CollectionsV7619CCurrentA7619C 401 Jonas\7619C.401.10daynotice Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2012 - 150 DIANA B. JONAS, : CIVIL ACTION - LAW Defendant IMPORTANT NOTICE TO: Diana B. Jonas Date: June 18, 2012 451 Centre Island Road, Oyster Bay,NY 11771 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITTEN 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 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. This is a debt collecting firm attempting to collect a debt for Dickinson College Any information obtained will be used for that purpose. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 MARTSON LAW OFFICES r1 By: t` Christopher E. Rice, Esquire Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2012 - 150 DIANA B. JONAS, : CIVIL ACTION - LAW Defendant AFFIDAVIT AS TO MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he has authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and belief,Defendant Diana B.Jonas, above named is not in the military service of the United States of America, that he has knowledge that the said Defendant's last known address is: 451 Centre Island Road,Oyster Bay,NY 11771. Said Defendant's place of employment is unknown. C-R'4 c /C-. Christopher E. Rice, Esquire Sworn�t,/o. and subscribed before me this02' day of June, 2014. N. aviPublic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Mary M.Price,Notary Public Carlisle Boro,Cumberland County My Commission Expires Aug.18,2015 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES F.\FILES\Clients\7619 Dickinson College\7619.Collections\7619C.Current\76I9C.401 Jonas\76 19C.401.pra.default.wpd Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2012 - 150 DIANA B. JONAS, : CIVIL ACTION - LAW Defendant COMMONWEALTH OF PENNSYLVANIA ) : SS COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY&FALLER,attorneys for the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, a notice of intention to enter default judgment against Defendant Diana B. Jonas, was given to her by mail on June 18, 2012. 4 5 / Christopher E. Rice, Esquire Sworn to and subscribed before me thispalk day of June, 2014. �� - Gtr No . 1'ublic COMMONWEALTH OF PENNSYLVANIA_ Notarial Seal Mary M.Price,Notary Public Carlisle Boro,Cumberland County My Commission Expires Aug.18,2015 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER,hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Diana B. Jonas 451 Centre Island Road Oyster Bay,NY 11771 MARTSON LAW OFFICES By ,C;),A,tc-e) M . Price 10 ast High Street Carlisle, PA 17013 Dated: fr,t/bg- This is a debt collecting firm attempting to collect a debt for Dickinson College. Any information obtained will be used for that purpose. Christopher E. Rice, Esquire Attorney I.D.No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2012 - 150 DIANA B. JONAS, : CIVIL ACTION - LAW Defendant TO: DIANA B. JONAS NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the - day of June, 2014,the following Judgment was entered against you in the above-captioned action:judgment in the amount of$2,301.68,plus interest accruing at 5% per annum thereafter, collection and attorneys' fees in the amount of$500.00 and costs of suit for failure to file an Answer to Plaintiffs Co plai . imad Date: / Prothonotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Diana B.Jonas 451 Centre Island Road Oyster Bay,NY 11771