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HomeMy WebLinkAbout12-4085 F:T1LES\Clients\7619 Dickinson College\7619.Collections\7619C.Current\7619C.188 Lippy\7619C.188.pra.revival. 21de Christopher E. Rice, Esquire I.D. No. 90916 ` 1 -0-0 F!( - '?a`? ?t' MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER E ?" 'PRO T?IOlw`Ci MARTSON LAW OFFICES 2012 JUN Z9 AM 11: 0 Ten East. High Street Carlisle, PA 17013 CUM A, COUNTY (717) 243-3341 VANIA Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 12 - -((68S CIVIL ACTION - LAW JASON M. ZIPPY, Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE FOR WRIT OF REVIVAL TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Issue a Writ of Revival of Judgment entered in the Court of Common Pleas of Cumberland County, Pennsylvania, to No. 2003-3259 on October 29, 2003, and index it in the judgment index against Jason M. Lippy, 129 North Carlisle Street, Apt. 2, Greencastle, PA 17225, in the amount of $4,968.36 which consists of $4,266.93 as principal and $600.00 as attorney fees, costs of suit and interest accruing at 5% from the date of judgment, as provided by law. MARTSON LAW OFFICES By: 4 Christopher E. Rice I.D. 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 r 23 THAT PURPOSE. \? ? ? ?. 50 ?os? a. ? nn ?3 3 . sue, PrL. lgg S'S. sC,> eK?' 7sI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DICKINSON COLLEGE Vs. JASON M. LIPPY 129 NORTH CARLISLE STREET APT. 2 GREENCASTLE-, PA 17225 TO: JASON M. ZIPPY CIVIL ACTION LAW No 12-4085 CIVIL TERM WRIT OF REVIVAL You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the judgment entered to No. 03-3259 Civil Term The Plaintiff claims that the amount due and unpaid is $4968.36 with interest from OCTOBER 29, 2003. You are required within twenty (20) days after service of this Writ to file an answer or otherwise, plead to this Writ. If you fail to do so, Judgment of revival will be entered. Costs $ 160.50 PD ATTY $ 2.25 DUE CO. Date . JUNE 29, 2012 (Seal) CHRISTOPHER RICE, ESQUIRE Attorney for the Plaintiff MARTSON LAW OFFICES TEN EAST HIGH STREET CARLISLE, PA 17013-3093 I.D. # 90916 717-243-3341 .?, e- z David D. Buell, Prothonotary i Deputy F FII ~ ~ !icros,,f ~- Diekin_con (nlle~e~?011 CollectionsVGl9CCun=nP7( 19C IBR Lippyl7619C 188 pra reissue recicabide Christopher E. Rice, Esquire I.U. No. '90916 MARTSON DF~ARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten l ast High Street Carlisle, PA 17013 (7171 24=~3-3341 Attorney;; for Plaintiff DICKINSON COLLEGE, Plaintiff v. JASON ~~1. LIPPY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND CC-UNTY, PENNSYLVANIA NO. 12 - 4085 CIVIL ACT10N - I=.AW JURY TRIAL OF TWELVI DEMANDED PRAECIPE TO REISSUE WRIT OF REVIVAL TO THE PROTHONOTARY: Please reissue the Writ of Revival in the above-referenced matter. MARTSON LAW OFFICES ,) By: `.' Christopher E. Rice _.,~~ ,:; I.D. 90916 c~ rti ~" `o ~-, _^~ r Ten Fast High Street ~-, ~ c ~-~ r~-" Carlisle. PA 17013-3093 '~z`° -- (717) 243-3341 _--~ .~ . :~c: ~. ~--, c3 W,~ Date: ;'C J.y /~~~ Attorneys for Plaintiff' ~~-c~~ ~ ~=,= 'l A~ _. .~.a ~. 'T'HIS IS A DEBT COLLECTING FIRM ATTEMP'CING TO COLLECT A DEBT FOR DICKINSON COLLEGE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. r ~~ ~ ~ ~ 2G 3.2 q ~~ ~. ~2~~ F:\FILES\Clients\7619 Dickinson Col lege\7619.Collections\7619C.Current\7619C.188 Lippy\7619C.188.as.wpd/tde Christopher E. Rice, Esquire I.D. No. 90916 FILED-Ofd ' MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER OF THE PROTNONOtAR'> MARTSON LAW OFFICES 20tl APR 25 ►M 3: 17 Ten East High Street Carlisle, PA 17013 CUMDERLANO COURTY (717) 243-3341 PENNSYLVANIA Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12 - 4085 CIVIL ACTION - LAW JASON M. LIPPY, Defendant JURY TRIAL OF TWELVE DEMANDED AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) . SS. COUNTY OF CUMBERLAND ) I hereby certify that the Re-issued Writ of Revival in the above captioned matter was personally served upon Defendant at 99 Brentwood Street, Martinsburg, West Virginia. Attached is the Return of Service form signed by the Berkeley County Sheriff's Office. MARTSON LAW OFFICES By. CfX1, S". I - Christopher E. Rice, Esquire Attorney I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Sworn to and subscribed before me this day April, 2013. CAMMONWEALTH OF PENNSYLVANIA r Notarial Seal Mary M.Price,Notary Public LcaHisle Boro,Cumberiand county N ar Ub 11 C ommission Expires Aug.18,2015 ME ,PENNbYLVANIA TdAN OF Wg#ME6 THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR DICKINSON COLLEGE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. .. r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DICKINSON COLLEGE Vs. CIVIL ACTION LAW C' -S___ __ _ .___ No 12-4085 CIVIL TERM Re 4 r WRIT OF REVIVAL I TO: JASON M. LIPPY You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the judgment entered to No. 03-3259 Civil Term The Plaintiff claims that the amount due and unpaid is $4968.36 with interest from OCTOBER 29, 2003. You are required within twenty (20) days after service of this Writ to file an answer or otherwise, plead to this Writ. If you fail to do so, Judgment of revival will be entered. Costs$ 160.50 PD ATTY $ 2.25 DUE CO. David D. Buell, Prothonotary Date JUNE 29, 2012 5 of W Berkeley qty (Seal) How �-- 5erved �..�� ;wt-ionFhip Date - CHRISTOPHER RICE, ESQUIRE c Sheriff Attorney Attorney for the Plaintiff uunGy, f;�, ;air MARTSON LAW OFFICES Deputylr rooe TEN EAST HIGH STREET Unit CARLISLE, PA 17013-3093 I.D. # 90916 SignaturU COF'IY'FROM RE+C OgMI 717-243-3341 x.24'13' 1711", and hefe�uyn�to�s1-et my nand l ' Sw v ti FAF1LES\Client0619 Dickinson Col lege\7619.Collections\7619C.Current\7619C.188 Lippy\7619C.188.pra.default3.wpd/tde Christopher E. Rice, Esquire I.D. No. 90916 a�r' � CIF THE PRO 'F`��' '"- MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES ZG 13 SEP 24 PH 3; 2 4 Ten East High Street C'UMBEhLAND COUNTY' Carlisle, PA 17013 (717) 243-3341 PENNSYLVANIA Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2012-4085 CIVIL ACTION - LAW JASON M. LIPPY, Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO THE PROTHONOTARY: Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant Jason M. Lippy,in the amount of 4,968.36 which consists of$4,266.93 as principal and $600.00 as attorney fees, costs of suit and interest accruing at 5% from the date of judgment as provided by law,prayed for in the Complaint for Defendant's failure to file an answer to Plaintiff's Complaint. I do hereby certify that a written notice of intention to file this Praecipe was mailed to the Defendant at the address indicated thereon, on July 8, 2013, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTSON LAW OFFICES By: ,P1,4 5.--- �-• Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 16 jo, Attorneys for Plaintiff Dated: 9-a-`f— �� ow �� oa,3 ti ` FTILES\Clients\7619 Dickinson College\7619.Collections\7619C.Cuueno7619C.188 Lippy\7619C 188.10daynoticelwpdAde Christopher E. Rice, Esquire 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. 2012-4085 CIVIL ACTION - LAW JASON M. LIPPY, Defendant JURY TRIAL OF TWELVE DEMANDED IMPORTANT NOTICE TO: Jason M. Lippy Date: July 8, 2013. 99 Brentwood Street,Martinsburg,WV 25404 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 Christopher E. Rice, Esquire Christopher E. Rice, Esquire 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. 2012-4085 CIVIL ACTION - LAW JASON M. LIPPY, Defendant JURY TRIAL OF TWELVE DEMANDED 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,the Defendant above named is not in the military service of the United States of America, that he has knowledge that the said Defendant is now living at: 99 Brentwood Street, Martinsburg, WV 25404. Said Defendant's place of employment is unknown. Christopher E. Rice, Esquire Sworn to and subscri ed before me this 621/X day of agid2tjJ42 , 2013. No ary ublic COMMONWEALTH OF PENNSYLVANIA Notarial Seat Mary M.price,Notary Public Carlisle Boro,Cumberiand IBt,2015 t 1Y GAtiitrlfleo Aug. M BER, �, pS ATJON OF NOTARIES y Christopher E. Rice, Esquire 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. 2012-4085 CIVIL ACTION - LAW JASON M. LIPPY, Defendant JURY TRIAL OF TWELVE DEMANDED 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 the Defendant was given to him by mail on July 9, 2013. Christopher E. Rice, Esquire Sworn to and su�b,s/c'gbed n ` before me this"A6 day of J ' 2013. N 4ad Public COMMONWEALTH OF PENNSYLVANIA Notarial seal Mary M,Price,Notary Public carlisie Boro,Cumberland county My Commisslon Expires Aug.18,2015 MEMBER,PENNSY V. NIA ZMATION 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 for Default Judgment was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Jason M. Lippy 99 Brentwood Street Martinsburg, WV 25404 MARTSON LAW OFFICES By V, M Price Tenl It' High Street Carlisle, PA 17013 (717) 243-3341 Dated: /P�/13 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 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. 2012-4085 CIVIL ACTION - LAW JASON M. LIPPY, Defendant JURY TRIAL OF TWELVE DEMANDED TO: JASON M. LIPPY, DEFENDANT NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on September ;2 V , 2013, the following Judgment was entered against you in the above-captioned case:Judgment in the amount of 4,968.36 which consists of$4,266.93 as principal and$600.00 as attorney fees,costs of suit and interest accruing at 5%from the date of judgment as provided by law,prayed for in the Complaint for Defendant's failure to file an answer to Plaintiff's Complaint. Date: 4`,2 i1//3 w Prot r onotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: Jason M. Lippy 99 Brentwood Street Martinsburg, WV 25404