The URL can be used to link to this page

Home My WebLink About13-0886IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CLAREMONT NURSING AND REHABILITATION CENTER, Plaintiff, v. TIMOTHY S. FILBURN, and ANNE FILBURN, Defendants. CIVIL ACTION No. 13-886 PRAECIPE FOR JUDGMENT TO THE PROTHONOTARY: Please enter judgment in favor of Plaintiff and against Defendants, Timothy S. Filburn and Anne Filburn, for want of an answer. X Assess damages as follows: Debt $29,711.71 Interest from 10/31/2011 @ 6% per annum $9,062.05 Attorney's Fees and Costs $4,182.89 TOTAL $42,956.65 X I verify that the foregoing assessment of damages is for specified amounts alleged to be due and is calculable as a sum certain. 507809v1 1 awA 6 Ko.soratk cl_ik• \03V -t W)i\e& X Pursuant to Pa.R.C. 237 (notice of praecipe for final judgment or decree), I certify that a copy of this Praecipe has been mailed to each party who has appeared in the action or to her Attorney of Record. X Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intent to file this Praecipe was mailed or delivered to the parties against whom judgment is to be entered and to their Attorney of Record, if any, after default occurred and at least ten (10) days prior to the date of the filing of this Praecipe and a copy of the Notice was sent to the Defendants via Certified Mail, Return Receipt Requested and via First Class Mail, postage prepaid. The envelope forwarded via Certified Mail to Ann Defendant Filburn has been returned to our office. The copy of the Notice of Intent to file this Praecipe forwarded by First Class Mail to Defendant Anne Filburn has not been return to our office. Dated: A�- 2d/ NOW, VL -r< , D.. By: LATSHA DAVIS & MCKENNA, P.C. Steven M. Montresor Attorney I. D. No. 74244 1700 Bent Creek Blvd., Suite 140 Mechanicsburg, PA 17050 (717) 620-2424 smontresor@ldylaw.com Attorneys for Plaintiff, Claremont Nursing and Rehabilitation Center , 2015, JUDGMENT IS ENTERED AS ABOVE. David D. Buell 1st Deputy of Prothonotary 7‘)By: Civil Division 14 507809v1 2 PLEASE REPLY TO: WRITER'S E-MAIL: LAT SHA DAVIS & McKENNA ATTORNEYS AT LAW Mechanicsburg smontresor@ldylaw.com December 2, 2014 Via Certified Mail, Return Receipt Requested and Rev alar 'flail Mr. Timothy S. Filbum 1000 Claremont Road Carlisle, PA 17013-8805 Re: CLAREMONT NURSING & Resident: Timothy S. Filburn Our File No.: 449-12 Dear Mr. Filburn: #7013 2630 0000 6720 3972 IA1BI1 N`A'TION CENTER Enclosed you wil.1 find a Notice. of Default Judgment in the above -referenced matter. As set forth therein, if you fail to respond to Claremont Nursing and Rehabilitation Center's Complaint within ten (10) days of the date of the Notice, judgment will be entered against you. Having been thusly advised, please govern yourself accordingly. Sincerely, Steven M. Montresor SMMlskl Enclosure cc: Mrs. Anne Filburn Lynette McCulloch,. Manager of Budget & Finance Patricia Thompson, Business Office Manager 1700 Trent Creek Boulevard, Suite 140 ° Mechanicsburg, PA 17050 • (717) 620-2424 ' FAX (717) 620-2444 350 Eagleview Boulevard, Suite 100 ° Exton, PA 19341 • (610) 524-8454 • FAX (610) 524-9383 3000 Atrium Way, Suite 251 • Mt. Laurel, NJ 08054 ° (856) 231-5351 ° FAX (856) 231-5341. Maryland Telephone: (410) 727-2810 503589v1 ND OMP1 hf15: EbTIO • Complete hems 1; 2, and 3. Also complete item 4 if Restricted Delivery is desired, a Print your name and address on the reverse so that we can return the card to you. • Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: trir. 1-;„;0-4 s' ,firf�il�ir?} iOot 044- 6,t, ' .i&d.,.a" ear-% ive. 7'A t 7 0 AI - 8t.5'" coM+�irrars s�ia"oN ncttrr f , Cdc4ressee C. Date bf Delivery 0. Is delivery address differe If YES, enter delivery add 3. Service Type kr.ipti Certified Mall* 0 Priority Mall Express"' D Registered 0 Return Receipt for Merchandise t 0 Insured Mail 0 Collect on Delivery 4. Restricted Delivery? (Extra Fee) 0 Yes 2, Article dumber (ilansferfrom serV1cerare) 7013 2630 0000 6720 3972 PS Form 3811. July 2013 Domestic Return Receipt Steven M. Montresor Attorney ID #74244 Latsha Davis & McKenna, P.C. 1700 Bent Creek Boulevard, Suite 140 Mechanicsburg, PA 17050 Tele: (717) 620-2424; Fax: (717) 620-2444 Attorneys for Plaintiff, Claremont Nursing smontresor@ldylaw.com and Rehabilitation Center IN THE COURT OF COMMON PLEAS CUM. I3ERLANI) COUNTY, PENNSYLVANIA CLAREMONT NURSING AND REHABILITATION CENTER, Plaintiff, v. TIMOTHY S. FILBURN, and ANNE FILB URN, Defendants. CIVIL ACTION N'o. 13-886 DATE OF NOTICE: December 2, 2014 IMPORTANT NOTICE TO: Timothy S. Filburn 1000 Claremont Road Carlisle, PA 17013-8805 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 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. 503571v1 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 ELIGIBLEPERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 (717) 249-3166 Steven M. Montresor 2 CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the foregoing Notice of Default Judgment was served by certified, return receipt, and first-class United States mail, postage prepaid, upon the following: Dated: 1,2 • Timothy S. Filbum 1000 Claremont Road Carlisle, PA 17013-8805 Ann Filburn 419 Hickory Ridge Road Newport, PA 17074 3 Steven M. Montresor PLEASE REPLY TO: WRITER'S E-MAIL: LATSH A DAVIS & McKENNA ATTORNEYS AT LAW Mechanicsburg smontresor@Idylaw.com December 2, 2014 Via Certified Mail, Return Receipt Requested and Regular Mail Mrs. Anne Filburn 1075 Keystone Way Newport, PA 17076 47013 2630 0000 6720 3989 Re: CLAREMONT NURSING & 1 EHABFLI TATION CENTER Resident: Timothy S. Filburn Our File No.: 449-12 Dear Mrs. Filburn: Enclosed you will find a Notice of Default Judgment in the above -referenced matter. As set forth therein, if you fail to respond to Claremont Nursing and Rehabilitation Center's Complaint within ten (10) days of the date of the Notice, judgment will be entered against you. Having been thusly advised, please govern yourself accordingly. Sincerely, Steven M. Montresor SMIvI/skl. Enclosure cc: Mr. Timothy S. Filburn Lynette McCulloch, Manager of Budget & Finance Patricia Thompson, Business Office Manager 1700 Bent Creek Boulevard, Suite 140 6 Mechanicsburg, PA 17050 ° (717) 620-2424 • FAX (717) 620-2444 350 Eagleview Boulevard, Suite 100 • Exton, PA 19341 • (610) 524-8454 • FAX (610) 524-9383 3000 Atrium Way, Suite 251. • Mt. Laurel, NJ 08054 • (856) 231-5351. ' FAX (856) 231-5341 Maryland Telephone: (410) 727-2810 503587v1 Steven M. Montresor Attorney ID #74244 Latsha Davis & McKenna, P.C. 1700 Bent Creek Boulevard, Suite 140 Mechanicsburg, PA 17050 Tele: (717) 620-2424; Fax: (717) 620=2444 smontresor@ldylaw.com Attorneys for. Plaintiff, Claremont Nursing and Rehabilitation Center IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CLAREMONT NURSING AND REHABILITATION CENTER, Plaintiff, v. TIMOTHY S. FILBURN, d ANNE FILBURN, Defendants. CIVIL ACTION No, 13-886 DATE OF NOTICE: December 2, 2014. IMPORTANT NOTICE TO: Ann Filburn 419 Hickory Ridge Road Newport, PA 17074 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 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. 503577v1 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. Cumberland County Bar Association. 32 South Bedford Street Carlisle, PA 170.13 1-800-990-9108 (717) 249-3166 Steven M. Montresor 2 CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the foregoing Notice of Default Judgment was served by certified, return receipt, and first-class United States mail, postage prepaid, upon the following: Dated: Timothy S. Filburn 1000 Claremont Road Carlisle, PA 17013-8805 Ann Filburn 419 Hickory Ridge Road Newport, PA 17074 3 Steven M. Montresor