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HomeMy WebLinkAbout12-6691 /a - &(pV Oi'vill em IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION Plaintiff vs. NO. 07-143 PRAECIPE FOR WRIT OF REVIVAL Filed on behalf of Plaintiff, PNC Bank, National Association ASHOK A. AGARWAL DBA ASHOKA BOUTIQUE, Defendant Code: Counsel of Record for This Party: Donna M. Donaher, Esquire Pa. I.D. #53165 TUCKER ARENSBERG, P.C. Firm #287 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 Olvd-renw Id - &(OQl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, Plaintiff VS. ASHOK A. AGARWAL DBA ASHOKA BOUTIQUE, Defendant CIVIL DIVISION NO. 07-143 PRAECIPE FOR WRIT OF REVIVAL To: Prothonotary, Cumberland County c kl-) -?3 'r Zrn =0 ? -1 ? -<n w CD. E- --? ?' C _ C- Q z = + -< © r- > 7-7 Kindly issue a Writ of Revival of Judgment entered at Docket No. 07-143 and index it in the judgment index against Ashak A.A„da ?a Agarwal dba Ashoka Boutique, in the amount of $75,650.32 with interest FROM January 8, 2007 of $29,007.93, for a total of $104,658.25. The last known address of the Defendant, Ashok A. Agarwal dba Ashoka Boutique, is 519 Cobbler Ct., Mechanicsburg, Pa 17050. -?4 33.'0 Pp A rN Respectfully submitted, 38.s(. Car IQ. SO TU RENSBE P.C. 7 - q1 p0 ATr BY Donna M. Donaher, Esqu're *a.2.5 Oue C0 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 Attorneys for Plaintiff BANK FIN:442137-1 000011-130972 C# 39W 625 O'28a5a7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION Vs. CIVIL ACTION LAW ASHOK A. AGARWAL d/b/a ASHOKA BOUTIQUE 519 Cobbler Court Mechanicsburg, PA 17050 No 12-6691 CIVIL TERM WRIT OF REVIVAL TO: ASHOK A. AGARWAL d/b/a ASHOKA BOUTIQUE You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the judgment entered to No. 07-143 Civil Term The Plaintiff claims that the amount due and unpaid is $75,650.32 with interest from 1/8/07 of $29,007.93 for a total of $104,658.25. 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 $ 91.56 PD ATTY $ 2.25 DUE CO David D. Buell, Prothonotary Date 10/31/12 (Seal) Deputy DONNA M. DONAHER, ESQUIRE, ID# 53165 Attorney for the Plaintiff TUCKER ARENSBERG, P.C. 1500 One PPG PLace Pittsburgh, PA 15222 412-566-1212 f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, CIVIL DIVISION NO. 2012-6691 Plaintiff PRAECIPE FOR DEFAULT JUDGMENT ON WRIT OF REVIVAL Filed on behalf of Plaintiff, vs. PNC Bank, National Association ASHOK A. AGARWAL DBA ASHOKA BOUTIQUE, F ew Defendants - ' ' Counsel of Record for This Party: Donna M. Donaher, Esquire Pa. I.D. #53165 TUCKER ARENSBERG, P.C. 3 Firm #287 - 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 c�# ?LOP b as ��3�93 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, ) CIVIL DIVISION Plaintiff ) NO. 2012-6691 vs. ) ASHOK A. AGARWAL ) DBA ASHOKA BOUTIQUE, ) Defendant ) PRAECIPE FOR JUDGMENT ON WRIT OF REVIVAL To: Prothonotary, Cumberland County Kindly revive the judgment by default filed in the above-referenced matter for the Plaintiff and against the Defendant, Ashok A. Agarwal dba Ashoka Boutique, for failure to file a responsive pleading, in the amount of$75,650.32, plus costs of suit. Respectfully submitted, --TUCKER ARENSBERG, P.C. i By Ul- Donna M. Donaher, Esquire 1500 One PPG Place Pittsburgh, PA 15222 (412) 566-1212 Attorneys for Plaintiff CERTIFICATION The undersigned hereby certifies that a true and correct notice of intention to enter a default judgment, said notice conforming to Pa. R.C.P. No. 237.1, was sent to defendant(s), by U.S. mail, postage prepaid on the 17th day of January, 2013. A true and correct copy of the notice is attached hereto Attorney for PNC Bank, N.A. TUCKER I ARENSBERG Attorneys IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, ) CIVIL DIVISION Plaintiff ) NO. 2012-6691 vs. ) ASHOK A. AGARWAL ) DBA ASHOKA BOUTIQUE, ) Defendant ) TO: Ashok A. Agarwal dba Ashoka Boutique 2212 Eaglesmoor Lane Enola, Pa 17025 DATE OF NOTICE: January 17, 2013 . IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. 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 NOTI WYER AT-ONCE.--IF--YOITD0-NOT-HAVE-A7 R, --- TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Lawyer Referral Service Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 TUCKER ARENSBERG, P.C. By: Donna.M. Donaher, Esquire Attorney for Plaintiff 1500 One PPG Place Pittsburgh, Pa 15222 BANK FIN:446933 -1000011-130972 (412) 566-1212 Tucker Arensberg,P.C. 1500 One PPG Place Pittsburgh,PA 15222 p.412.566.1212 f.412.594.5619 www.tuckerlaw.com 111 N.Front Street P.O.Box 889 Harrisburg,PA 17108 p.717.234.4121 f.717.232.6802 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, ) CIVIL DIVISION Plaintiff ) NO. 2012-6691 vs. ) ASHOK A. AGARWAL ) DBA ASHOKA BOUTIQUE, ) Defendant ) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF ALLEGHENY ) I, Donna M. Donaher, being duly sworn according to law, hereby depose and say that the Defendant is not a member of the military service of the United States of America to the best of my knowledge, information and belief. O�. Donna M. Donaher, Attorney for PNC Bank, National Association Sworn to and subscribed before me this //4 day of , 2013 Notary Public GOMMONBNEALTH OF PENNSYLVANIA Notarial Seal Matthew G.Friedberg,Notary Public City of Pittsburgh,Allegheny County My Commission Expires June 7,2015 MEMBER,PE TIAN OF NOTARIES BANK FIN:447699-1 000011-130972 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, ) CIVIL DIVISION Plaintiff ) NO. 2012-6691 vs. ) ASHOK A. AGARWAL ) ,DBA ASHOKA BOUTIQUE, ) Defendant ) TO: Ashok A. Agarwal dba Ashoka Boutique 2212 Eaglesmoor Lane Enola, Pa 17025 NOTICE OF ENTRY OF JUDGMENT Please take notice that on ? 2013, a Judgment by Default was entered against you in the court and at docket term and number set forth above. The amount of the Judgment is $75,650.32, pl osts Pro ary, a County BANK FIN:458728-1 000011-130972 c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PNC BANK, NATIONAL ASSOCIATION, ) CIVIL DIVISION Plaintiff ) NO. 2012-6691 vs. ) ASHOK A. AGARWAL ) DBA ASHOKA BOUTIQUE, ) Defendant ) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF ALLEGHENY ) I, Donna M. Donaher, being duly sworn according to law, hereby depose and say that the Defendant is not a member of the military service of the United States of America to the best of my knowledge, information and belief. LA Donna M. Donaher, Attorney for PNC Bank, National Association Sworn to and subscribed befor meth's P day of h 2013 Notary Public C0MM@NML:ffl OF PENNSYLVANIA �' Notarial Seal Colleen O'Toole,Notary Public City of Pittsburgh,Allegheny County My Commission Expires Jan.31,2015 MEMBER,PENNSYLVANIA ASSOCIATION OF NMARI6' BANK FIN:458728-1 000011-130972