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Home My WebLink About12-1217SHAW CONTRACT FLOORING SERVICES, INC. D/B/A SPECTRA CONTRACT FLOORING 1351 Eisenhower Blvd. Harrisburg, Pennsylvania 17111 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, 7 c vs. CIVIL ACTION NO. ?? h; CONSTRUCTION SERVICES UNLIMITED,' N) LLC CIVIL ACTION - LAW r- v 1103 d Street, Suite 200 New Cumberland, Pennsylvania 17070 yC Defendant. PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: r-% C'y Pursuant to Pa.R.Civ.P. 3002, please enter on the Judgment Docket of the Court of Common Pleas of Cumberland County, Pennsylvania, judgment in favor of Shaw Contract Flooring Services. Inc. d/b/a Spectra Contract Flooring and against Construction Services Unlimited, LLC in the amount of $23,992.30, together with continuing interest of 8% per annum. A certified copy of the docket entries and a certification of the judgment entered in the Court of Common Pleas of Dauphin County is attached hereto and marked as Exhibit A. QLL _ L__ B a . Downey (PA 59891) Justin G. Weber (89266) PEPPER HAMILTON LLP 200 One Keystone Plaza North Front and Market Streets t 3 S-0 C411 P. O. Box 1 181 Harrisburg, PA 17108-1 181 (717) 255-1155 Date: February 24, 2012 Attorneys for Plaintiff Q # ?- ?? S Shaw Contract Flooring Services, Inc. d/b/a Spectra Contract Flooring In 19be Court of Common VYeao of 30aupbin Countp, 3pennop1bania Shaw Contract Flooring Services Inc Spectra Contract Flooring No. 2011-CV-10055-CV VS. Construction Services Unlimited CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT I, the undersigned Prothonotary of the Court of Common Pleas of Dauphin County, Pennsylvania, do hereby certify that the attached is a full, true and correct copy of the docket entries in the above captioned case. I further certify that Judgment was entered in favor of Shaw Contract Flooring Services, Inc. d/b/a Spectra Contract Flooring, and against Construction Serivices Unlimited, LLC. on February 10, 2012 in said case in the amount of $23,992.30. 3n Teotimonp Wbereof, I have hereunto set my hand and affixed the sea f Te Court, on Thursday, February 16, 2012. OOPES OFD. DOCUMENTS WAND SHAW CONTRACT FLOORING SERVICES, INC. DB/A SPECTRA CONTRACT FLOORING 1351 Eisenhower Blvd. Harrisburg, Pennsylvania 17111 Plaintiff, vs. CONSTRUCTION SERVICES UNLIMITED, LLC 110 3`d Street, Suite 200 New Cumberland, Pennsylvania 17070 Defendant. IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION NO.2011-CV-10055-CV CIVIL ACTION - LAW ? .v x --+-n r n r n 2i c -*r c a Ao ern;, C:3 rM ,.4 w ro NOTICE OF ENTRY OF JUDGMENT To: Construction Services Unlimited, LLC 110 3ra Street, Suite 200 New Cumberland, Pennsylvania 17070 Pursuant to the requirements of Pa. R.C.P. No. 236, you are hereby notified that on FEB 10 3012 , 2012, judgment by default was entered against you in the amount of $23,992.30, together with continuing interest of 8% per year. FEB-1 1012 Date: Prothonotary Counsel for Plaintiff certifies that the names and addresses of the proper party/person to receive this notice is: Construction Services Unlimited, LLC 110 3rd Street, Suite 200 Fc New Cumberland, Pennsylvania 17070G 8 16 2012 1 hereby certify that the, foregoing to a true and correct copy of the original filed. Prothon tary SHAW CONTRACT FLOORING IN THE COURT OF COMMON PLEAS OF SERVICES, INC. DB/A SPECTRA DAUPHIN COUNTY, PENNSYLVAN IA CONTRACT FLOORING 1351 Eisenhower Blvd. Harrisburg, Pennsylvania 17111 Plaintiff, vs. CIVIL ACTION NO.2011-CV-10055-CV CONSTRUCTION SERVICES UNLIMITED, LLC CIVIL ACTION - LAW 110 3rd Street, Suite 200 0 New Cumberland, Pennsylvania 17070 Defendant. rn ors - f-nm - nc >c -0 PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE PROTHONOTARY: co Please enter judgment of default in favor of Plaintiff Shaw Contract Flooring Services, Inc. d/b/a Spectra Contract Flooring and against Defendant Construction Services Unlimited, LLC, for defendant's failure to plead to the complaint in this action within the required time. The complaint contained a notice to defend. Defendant was served with the complaint on October 27, 2011, and Defendant's answer was due on November 16, 2011. Attached as Exhibit A is a copy of plaintiff's Notice of Intention to File Praecipe for Entry of Default Judgment, which I certify was mailed by regular mail to the defendant at its last known address on November 22, 2011, which is at least 10 days prior to the filing of this Praecipe. Defendant attempted to file an answer but that answer was stricken by the Court by order dated January 25, 2012. Please assess damages in the amount of $23,992.30, together with continuing interest of 8% per annum, as requested in the complaint. 4 BriaLg/Downey (PA 59891) Justin G. Weber (PA 89266) PEPPER HAMILTON L,LP 100 Market Street, Suite 200 Post Office Box 1181 Harrisburg, PA 17108-1181 717.255.1155 717.238.0575 (Fax) downeyb@pepperlaw.com webedg@pepperlaw.com Attorneys for Plaintiff Shaw Contract Flooring Services, Inc. d/b/a Date: February 10, 2012 Spectra Contract Flooring EXHIBIT A Atian P. Downey (PA 59891) Justin G. Weber (PA 89266) PEPPER HAMILTON LLP Suite 200, 100 Market Street P.O. Box 1181 Harrisburg, PA 17108-1181 717.255.1155 717.238.0575 Fax downeyb@pepperlaw.com webedg@pepperlaw.com SHAW CONTRACT FLOORING SERVICES, INC. DB/A SPECTRA CONTRACT FLOORING 1351 Eisenhower Blvd. Harrisburg, Pennsylvania 17111 ( Attorneys for Plaintiff Shaw Contract Flooring Services, Inc. IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA Plaintiff, VS. CIVIL ACTION NO.2011-CV-10055-CV CONSTRUCTION SERVICES UNLIMITED, LLC CIVIL ACTION -- LAW 110 3rd Street, Suite 200 New Cumberland, Pennsylvania 17070 Defendant. NOTICE OF INTENTION TO FILE -c PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT - ` 4-"M u s z t TO: Construction Services Unlimited, LLC zCI) o c3Frn z 114 3`d Street, Suite 240 z' vc?rn New Cumberland, Pennsylvania 17070 w 4 F Date of Notice: November 22, 2011 co IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITI-I THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTE{ 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. N15202060 vi YOU SHOULD TAKE THIS NOTICE TO A 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 CAN PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE. PENNSYLVANIA LAWYER REFERRAL SERVICE Pennsylvania Bar Association 100 South Street, P.O. Box 186 Harrisburg, PA 17108 (800) 692-7375 (PA only) or (717) 238-6715 Respectfully submitted, 4?4- Date: November 22, 2011 Briar( Downey (PA 59891) Just1 G. Weber (PA 89266) PEPPER HAMILTON LLP Suite 200, 100 Market Street P.O. Box 1181 0 Harrisburg, PA 17108-1181 717.255.1155 i 717.238-0575 Fax downeyb@pepperlaw.com webers g@pepperlaw.com Attorneys for Plaintiff Shaw Contract Flooring Services, Inc. d/b/a Spectra Contract Flooring °om =-n n caFm rn °o n #15202060 VI CERTIFIgATE OF SERVICE I hereby certify that on February 10, 2012, I served a copy of the foregoing Praecipe for Entry of Default Judgment on Defendants by United States mail, first class postage prepaid, addressed as follows: Construction Services Unlimited, LLC 1103 d Street, Suite 200 New Cumberland, Pennsylvania 17070 Justin eber (PA 89266) -o c .V c? a I-nm. m °«rn D C) r< C "v 3 AC3s?p C? Date: 2/16/2012 Time: 11:39 AM Page 1 of 3 Filed: Subtype: Comment: Physical File: Y Appealed: N Status History Pending 10/21/2011 Pending / Judgment 2/10/2012 Judge History Date Judge Reason for Removal 10/21/2011 No Judge, Administrative 1/24/2012 Turgeon, Jeannine Current Payments Receipt Date Type Pepper Hamilton 262677 10/21/2011 Civil Filing 268866 2/10/2012 Civil Filing 269216 2/15/2012 Civil Filing 269251 2/16/2012 Miscellaneous Exemplified Record 26.25 User: AREDMOND Amount 145.50 23.25 37.75 26.25 Total 232.75 Miscellaneous Receipts Receipt Date 269251 2/16/2012 Exemplified Record Plaintiff Name: Shaw Contract Flooring Services Inc Address: Phone: Home: Work: Employer: Litigant Type: Comment: Attorneys Weber, Justin G (Primary attorney) Plaintiff Name: Spectra Contract Flooring Address: Phone: Home: Employer: Litigant Type: Comment: Attorneys Weber, Justin G Dauphin County Complete Case History Case: 2011-CV-10055-CV Shaw Contract Flooring Servces Inc, etal. vs. Construction Services Unlimited 10/21/2011 Civil Work: 26.25 Sum SSN: DOB: Sex: Send notices: Y Send Notices SSN: DOB: Sex: Send notices: Y (Primary attorney) Send Notices 26.25 Date: 2/16/2012 Dauphin County User: AREDMOND Time: 11:39 AM Complete Case History Page 2 of 3 Case: 2011-CV-10055-CV Defendant Name: Address: Phone: Employer: Litigant Type: Comment: Shaw Contract Flooring Servces Inc, etal. vs. Construction Services Unlimited Construction Services Unlimited Home: Work: Attorneys PRO SE, (Primary attorney) Register of Actions 10/21/2011 New Civil Case Filed This Date. Plaintiff: Shaw Contract Flooring Services Inc Attorney of Record: Justin G Weber Plaintiff: Spectra Contract Flooring Attorney of Record: Justin G Weber Filing: Complaint Paid by: Pepper Hamilton Receipt number: 0262677 Dated: 10/21/2011 Amount: $145.50 (Check) For: Construction Services Unlimited (defendant) Debt Collection: Other Complaint filed. AOPC MONTHLY CIVIL COURT STATISTICAL REPORT DATA 10/27/2011 Complaint: Sheriffs Return filed stating service was completed. So answers J.R. Lotwick, Sheriff. to Construction Services Unlimited on 10/27/2011; Assigned to Dauphin Co Sheriffs Office. Service Fee of $50.00. Cumberland County Sheriffs Costs; $60.94 11/29/2011 Defendant's answer to plaintiffs complaint, filed. Defendant: Construction Services Unlimited Attorney of Record: PRO SE 12/30/2011 Motion to strike answer of Construction Services Unlimited, LLC., filed. 1/23/2012 Certificate of Readiness for Pretrial Motion filed by counsel for plaintiff(s). 1/24/2012 Judge assigned to case. 1/25/2012 Upon consideration of Plaintiff Shaw Contract Flooring Services, Inc.'s Motion to Strike Answer of Construction Services Unlimited, LLC, Plaintiffs Motion to Strike is GRANTED and Construction Services Unlimited LLC's Answer is STRICKEN. Construction Services Unlimited, LLC shall file an Answer through counsel within 10 days of the date of this order or Plaintiff may proceed pursuant to Pa.R.C.P. 1037(b). See ORDER, filed. Copies Dist. 01/25/12 SSN: DOB: Sex: Send notices: Y Send Notices No Judge, No Judge, No Judge, No Judge, No Judge, No Judge, No Judge, No Judge, No Judge, No Judge, Turgeon, Jeannine Turgeon, Jeannine Date: 2/16/2012 Dauphin County Time: 11:39 AM Complete Case History Page 3 of 3 Case: 2011-CV-10055-CV Shaw Contract Flooring Servces Inc, etal. vs. Construction Services Unlimited Register of Actions 2/10/2012 Filing: Judgment Paid by: Pepper No Judge, Hamilton Receipt number: 0268866 Dated: 2/10/2012 Amount: $23.25 (Check) For: Spectra Contract Flooring (plaintiff) AOPC MONTHLY CIVIL COURT No Judge, STATISTICAL REPORT DATA ; CIVIL OTHER Default Judgment is entered in favor of No Judge, Plaintiff and against Defendant(s) Construction Services Unlimited, LLC in the amount of $23992.30, together with continuing interest of 8% per annum, as request in the complaint for failure to answer Plaintiffs Complaint. See Praecipe & Notice filed. Copies of all documents mailed. 2/15/2012 Filing: Writ of Execution Paid by: Pepper Turgeon, Jeannine Hamilton Receipt number: 0269216 Dated: 2/15/2012 Amount: $37.75 (Check) For: Spectra Contract Flooring (plaintiff) 2/16/2012 Miscellaneous Payment: Exemplified Turgeon, Jeannine Record Paid by: Pepper Hamilton Receipt number: 0269251 Dated: 2/16/2012 Amount: $26.25 (Check) Judgment Order date In Favor Of Disposition Judgment 02/10/2012 Plaintiff 02/10/2012 Open Default Comment: 23992.30 Plaintiff: Shaw Contract Flooring Services Inc Spectra Contract Flooring Defendant: ConstructicpAPririr U ilimit d ttl 2012 1 hereby certify that the foregoing is I \ true and correct copy of the original l e User: AREDMOND Prothonotary/Cie '-'Wdw.1144k? CERTIFICATE OF SERVICE I hereby certify that on February 24, 2012, 1 served a copy of the foregoing Praecipe to Enter Judgment on Defendant by United States mail, first class postage prepaid, addressed as follows: Construction Services Unlimited, LLC 1103 d Street, Suite 200 New Cumberland, Pennsylvania 17070 Jus G. Weber (PA 89266) SHAW CONTRACT FLOORING SERVICES, INC. D/B/A SPECTRA CONTRACTFLOORING 1351 Eisenhower Blvd. Harrisburg, Pennsylvania 17111 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, VS. CIVIL ACTION NO./ )- _ /2„1 2,17 c4V I CONSTRUCTION SERVICES UNLIMITED, LLC CIVIL ACTION - LAW 110 3d Street, Suite 200 New Cumberland, Pennsylvania 17070 Defendant. NOTICE OF ENTRY OF JUDGMENT To: Construction Services Unlimited, LLC 1103 d Street, Suite 200 New Cumberland, Pennsylvania 17070 Pursuant to the requirements of Pa. R.C.P. No. 236, you are hereby notified that on F b r?,-rJ 17 , 2012, judgment by default was entered against you in the amount of $23,992.30. together with continuing interest of 8% per year. Date: _ ?-- ------- ------- Prothonotary Counsel for Plaintiff certifies that the names and addresses of the proper party/person to receive this notice is: Construction Services Unlimited, LLC 110 3rd Street, Suite 200 New Cumberland, Pennsylvania 17070