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Home My WebLink About13-1369 F iLED-Oi FILE. OF THE PROTHONOTARY 2013 MAY 13 AM !!= 25 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FRY COMMUNICATIONS, INC Plaintiff No. 13-1369 vs. AFFIDAVIT OF SERVICE OF COMPLAINT AS TO COOL BLUE COMPANY, LLC ONLY ROBERT FINE COOL BLUE COMPANY, LLC Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James P. Valecko, Esquire PA. I.D.#79596 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#9615170 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FRY COMMUNICATIONS, INC Plaintiff No. 13-1369 vs. ROBERT FINE COOL BLUE COMPANY, LLC Defendants AFFIDAVIT OF SERVICE OF COMPLAINT Before me, the undersigned authority, personally appeared James P. Valecko, Esquire, who, being duly sworn according to law, deposes and says that on March 20, 2013, he did cause to be sent to Defendant, Cool Blue Company, LLC, Plaintiff's Complaint by Certified Mail, Return Receipt requested, directed to the Defendant at its last known address of 2100 M Street NW#170-242, Washington, DC 20037, and that on March 22, 2013 Defendant did receive said Certified Mail as evidenced by Plaintiff's Receipt for Certified Mail which is attached hereto, marked as Exhibit "1" and made a part hereof. Service is deemed to be perfected as of March 22, 2013. WELTMAN, WEINBERG & REIS CO., L.P.A. By. James . V ecko, Esquire PA. I.D.#79 96 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#9615170 Sworn to and subsc 'led before me this day nas::�- COMMONWEALTH OF PENNSYLVANIA Notarial Seal NOTARY POEICIC Wendy L.Gault,Notary Public City of Pittsburgh,Allegheny County My Commission Explres July 15,2014 Member.PennsVlvanla Associatlon of Notaries V ' 1 'COMPLETE SECTION ON DELIVERy • Complete items 1,2,and 3.Also complete A. Signature item 4 if Restricted Delivery is desired. r • Print your name and address on the reverse X—_ gent so that we can return the card to you. Addressee . ■ Attach this card to the back of the mailpiece, B. Received by(Printed Name) C. e�f livery or on the front if space permits. e o 1. Article Addressed to: D. Is delivery address different from item 1 ❑ es If YES,enter delivery address below: ❑No -2100 ST /VG,/ :�f17G—2z,�� W�SLIlJ1�-fO�l �C rZ�37 3. Service Type Certified Mail ❑Express Mail ❑Registered ❑Return Receipt for Merchandise / ❑Insured Mail ❑C.O.D. 2. Article Number 4. Restricted Delivery?(Extra Fee) 13 Yes (Transfer from service label) 7 012 2920 0 0 01 650? 2 5 5 6 PS Form 3811,February 2004 Domestic Return Receipt 102595-02-M-1540 v V c R IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION C; FRY COMMUNICATIONS,INC ,- C Plaintiff Co rn -� VS. Civil Action No. 13-1369 r1s ROBERT FINE �G —0 v—.i COOL.BLUE COMPANY,LLC p N G Defendants PRAECIPE FOR DEFAULT JUDGMENT AS TO COOL BLUE COMPANY LLC ONLY TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant,Cool Blue Company,LLC above named, in the default of an Answer, in the amount of$14,851.03 computed as follows: Amount claimed in Complaint $13,351.03 Less Payments/Adjustments Made -$0.00 Attorneys'fees $0.00 TOTAL $14,851.03 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN,WEINBERG&REIS CO.,L.P.A. By: James P.Vale ko,Esquire PA I.D.#79596 Weltman,Weinberg&Reis Co.,L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh,PA 15219 (412)434-7955 WWR#9615170 Plaintiffs address is: c/o Weltman,Weinberg&Reis Co.,L.P.A., 1400 Koppers Building,436 7`t'Avenue,Pittsburgh,PA 15219 And that the last known address of the Defendant is:2100 M Street NW#170-242,Washington,DC 20037 A- a Ot C)C> u IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION FRY COMMUNICATIONS,INC Plaintiff CASE#: 13-1369 ROBERT FINE COOL BLUE COMPANY,LLC Defendants TO: IMPORTANT NOTICE Cool Blue Company, Llc 2100 M Street Nw#170-242 Washington,Dc 20037 Date of Notice: 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 DAYS FROM THE DATE OF THHIS 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 (717)249-3166 WELTMAN, WEINBERG&REIS CO., L.P.A. James P. alecko, Esquire P.A.I.D.#7 596 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 WWR#9615170 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION FRY COMMUNICATIONS,INC Plaintiff VS. Civil Action No. 13-1369 ROBERT FINE COOL BLUE COMPANY,LLC Defendants NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx)Defendant ( )Garnishee You are hereby notified that the following Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of$14,851.03 plus costs. ( ) Trespass Judgment in the amount of$ plus costs. ( ) If not satisfied within sixty(60)days,your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation,.Bureau of Traffic Safety,Harrisburg,PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary V By. PROTHONOTARY(OR DEPUTY) Cool Blue Company,.LLC 2100 M Street NW#170-242 Washington,DC 20037 Plaintiff's address is: c/o Weltman,Weinberg&Reis Co.,L.P.A., 1400 Koppers Building,436 7"'Avenue,Pittsburgh,PA 15219 1-888-434-0085 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James P. Valecko, Esquire Attorney for Plaintiff(s) I.D. No. 79596 436 Seventh Ave, 1400 Koppers Bldg Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File# 9615170 FRY COMMUNICATIONS, INC. Plaintiff Cumberland County Court of Common Pleas VS. No. 13-1369 CIVIL c� ROBERT FINE w � COOL BLUE COMPANY, LLC M C= rn- Defendant( s) p o --I c) PRAECIPE TO REINSTATE COMPLAINT ° -� QT'S C-) ter; z TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned matter as to Robert Fine only. WELTMAN, WEINBERG& REIS CO., L.P.A. BY James PYValecko, Esquire Attornet for Plaintiff a�� t THE PRO THON TARY 2013 JUL 22 PM 2, S f CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION FRY COMMUNICATIONS,INC Plaintiff No. 13-1369 VS. AFFIDAVIT OF SERVICE OF COMPLAINT IN CIVIL ACTION ROBERT FINE COOL BLUE COMPANY, LLC Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James P.Valecko,Esquire PA. I.D.479596 WELTM.AN, WEINBERG &.REIS CO.,L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh,.PA 15219 (412)434-7955 WWR49615170 { IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FRY COMMUNICATIONS,INC Plaintiff No. 13-1369 vs. ROBERT.FINE COOL BLUE COMPANY,LLC Defendants AFFIDAVIT OF SERVICE OF COMPLAINT IN CIVIL ACTION BEFORE ME,the undersigned authority, personally appeared James P. Valecko,Esquire,who according to law deposes and says that a copy of the Complaint in Civil Action has been served on the Defendant,Robert Fine. On or about June 16,2013,A.Adam Detective Agency,Inc., served a true and correct copy of the Complaint in Civil Action on Defendant,.Robert Fine,at 1.318 22nd St Nw, Apt 201, Washington,Dc 20037 by serving Defendant,Robert Fine,personally. Said Affidavit of Service is attached as Exhibit"I". WELTMAN, WEINBERG &REIS, CO.,L.P.A. James ecko,Esquire PA I.D. #79 96 WELTMAN, WEINBERG& REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#96151.70 Sworn to and subscri ed before me this day o 203 zf�� cmy MMONWEALTH OF PENNSYLVANIA NO Y P LIC i Nmnal Seal Wendy L Gault,Notary Public city of i tsburgh,Allegheny County Commisslon ExpM]uly 15,2014 member,Penns*anla ASsodation of Notaries h WASHINGTON.DC AFFIDAVIT OF SERVICE COUNTY OF: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION Civil Action No.13-1369 Civil FRY COMMUNNICATION,INC. et.Al Plaintiff VS. ROBERT FINE COOL BLUE COMPANY,LLC et Al Defendant SERVICE OF PROCESS ON ROBERT FINE "', (NQ ME c�NTITY SERVED) ' NAME OF SERVER M I dl�1 ry -e-v"e,-r\ UNDERSIGNED,BEING DULY SWORN,DEPOSES AND SAYS THAT HE/SHE AT TIME OF SERVICE,WAS OVER THE AGE OF TWENTY AND WAS NOT A PARTY TO THIS ON. DATE OF SERVICE: THAT ON THEI-DAY OFJ UY►e.- 2013 AT Ob O"CLOCK-T. M. PLACE OF SERVICE: AT 1318 22ND . STREET NW, APT'. 201 IN THE CITY OF WASNINGTON STATE OF DC 20037 THE UNDERSIGNED SERVED THE ANNEXED PAPERS, DOCUMENTS SERVE REINSTATED COMPLAINT in CIVIL ACTION PERSON SERVED A TRUE AND CORRECT COPY OF THE AFORESAID PAPERS WERE SERVED AND METHOD ON THE ABOVE-NAMED PARTY OR WITNESS IN THE FOLLOWING OF SERVICE ER: BY PERSONALLY DELIVERING THEM INTO THE HANDS OF THE PERSON TO BE SERVED. (SUBSTITUTE)BY LEAVING A COPY AT HIS/HER USUAL PLACE OF ABODE WITH SOME PERSON OF SUITABLE AGE AND DISCRETION THEN RESIDING THERIN,TO WIT: _ BY DELIVERING THEM TO AN OFFICER OR MANAGING AGENT WHOSE NAME AND TITLE IS: _ I INFORMED SAID PERSON OF THE CONTENTS THEREIN,IN COMPLIANCE WITH STATE STATUTES. DESCRIPTION OF �� PERSON RECEIVING SEX �/ SKIN COLOR ' " HAIR COLOR B I Atk DOCUMENTS: FACIAL HAIRYOAGE HEIGHT (0 WEIGHT ZZ.0 PROOF OF DUE AND _ AFTER DUE AND DILIGENT EFFORTS,UNDERSIGNED WAS DILIGENT ATTEMPT UNABLE TO EFFECT SERVICE. FACTS INDICATING DEFENDANT IS AVOIDING SERVICE ARE: MILITARY To the best of my knowledge and belief,said person was Not Engaged in the United States Military at the time of service. CALIFORNIA LAW REQUIRES DATES OF SERVICE TIMES ADDRESS REASON FOR 3 ATTEMPTS BEFORE ATTEMPTED ATTEMPTED ATTEMPTED NON SERVICE SUBSITUTE SERVICE CAN BE MADE SIGNATURE I verify that the statements ade in this Affidavit are true and OF SERVER correct.I understand that f se statements herein are made subject to pen hies of 8'Isa C.S. .s 4904 relating to un sworn falsification al es.horj �v es. 2013 2013 NAV&OF SERVER (date) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL.DIVISION FRY COMMUNICATIONS,INC ' ` ua Plaintiff a vs. Civil Action No. 13-1369 CIVIL )> C) ; C. O ROBERT FINE COOL.BLUE COMPANY,LLC C , C:) j Defendants 4 co ;,._a PRAECIPE FOR DEFAULT JUDGMENT AS TO ROBERT FINE ONLY TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant,Robert Fine above named, in the default of an Answer, in the amount of$14,851.03 computed as follows: Amount claimed in Complaint $13,351.03 Less Payments/Adjustments Made -$0.00 Attorneys'fees $1,500.00 TOTAL $14,851.03 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. Wql.D.#�795 EINBERG&REIS CO., L.P.A. B Jo,Esquire P Weltman,Weinberg&Reis Co.,L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh,PA 15219 (412)434-7955 WWR#9615170 Plaintiffs address is: c/o Weltman,Weinberg&Reis Co.,L.P.A., 1400 Koppers Building,436 7`h Avenue,Pittsburgh,PA 15219 And that the last known address of the Defendant is: 1318,22 nd St NW,Apt 201, Washington,DC 20037 6�p 0,0 Tyo bet Mack-2 S IN THE COURT OF COMMON.PLEAS CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION FRY COMMUNICATIONS,INC Plaintiff CASE#: 13-1369 ROBERT FINE COOL BLUE COMPANY,LLC Defendants IMPORTANT NOTICE TO: Robert Fine 1318 22nd St Nw,Apt 201 Washington,Dc 20037 Date of Notice: 7116//S 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 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 (717)249-3166 WELTMAN, WEINBERG&REIS CO.,L.P.A. ' By: Matthew D. Urban, Esquire �- P.A.I.D.#90963 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 W WR#9615170 IN THE COMMON PLEAS COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION FRY COMMUNICATIONS,INC Plaintiff Civil Action No. 13-1369 CIVIL VS. NON-MILITARY AFFIDAVIT ROBERT FINE COOL BLUE COMPANY,LLC Defendants The undersigned is the duly authorized agent and/or attorney for the Plaintiff in the within matter and states as follows: Affiant states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, Robert Fine is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the DMDC does not possess any information indicating that the below individual is in the military service: Robert Fine 131.8 22nd St NW, Apt 201 Washington,DC 20037 Affiant further states that the averments contained herein are true and correct to the best of Affiant's knowledge, information and belief and that these averments are made subject to the penalties of 18 Pa C.S.A. §4904 relating to unsworn falsification to authorities. Af pant Department of Defense Manpower Data Center Results as of:Jul-29-201310:00:29 SCRA 3.0 State Report Pursuant to Servicenaembers Civil Relief Act •ti Last Name: FINE First Name: ROBERT Middle Name: Active Duty Status As Of: Jul-29-2013 On Active Duty On Active Duty Status Date Active Duty Start Dale Active Outy End Date Status Service Component NA NA ,r. -. ' No NA This response reflects the individuate active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA - NA — No NA This response reflects"a, the'Individual left active duty"status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA .NA. - No NA This response reflects whether the individual c'his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION FRY COMMUNICATIONS,INC Plaintiff vs. Civil Action No. 13-1369 CIVIL ROBERT FINE COOL BLUE COMPANY,LLC Defendants NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx)Defendant ( )Garnishee You are hereby notified that the following Order or Jud ent was entered against you Cn (xx) Assumpsit Judgment in the amount of$14,851.03 plus costs. ( ) Trespass Judgment in the amount of$ plus costs. ( ) If not satisfied within sixty(60)days,your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation,Bureau of Traffic Safety,Harrisburg,PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) . Default ( ) Verdict ( ) Arbitration Award Prothonotary 4 I . P 1 By: C? PROTHONOTARY(OR DEPUTY) Robert Fine 1318 22nd St NW, Apt 201 Washington,DC 20037 Plaintiffs address is: c/o Weltman,Weinberg&Reis Co.,L.P.A., 1400 Koppers Building,436 7'"Avenue,Pittsburgh,PA 15219 1-888 7434-0085 e 1 L �yy'3 yn r�i 2[3 13 SEP 30 PH 12: 14 9 CUMBERLAND COUI `. PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FRY COMMUNICATIONS, INC Plaintiff No. 13-1369 CIVIL vs. PRAECIPE FOR EXEMPLIFIED RECORD ROBERT FINE COOL BLUE COMPANY, LLC Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#09615170 S i4. Po err t &I13(.31s3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FRY COMMUNICATIONS, INC Plaintiff No. 13-1369 CIVIL vs. ROBERT FINE COOL BLUE COMPANY, LLC Defendant PRAECIPE FOR EXEMPLIFIED RECORD TO THE PROTHONOTARY: Kindly provide an exemplified record in order to transfer the judgment entered in the above captioned case to Washington D.C. WELTMAN, WEINBERG & REIS CO., L.P.A. By: ✓��'--�� William T Molczan, quire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#09615170