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HomeMy WebLinkAbout13-2317 THE CHARTWELL LAW OFFICES, LLP OF THE RROTH0NOlAR`r" Robert J. Murtaugh, Esquire ( #57494) 2013 APR 26 PM 3: 1 970 Rittenhouse Road, Suite 300 Eagleville, PA 19403 CUMBERLAND COUNTY Telephone: (610) 666 -7700 PENNSYLVANIA Facsimile: (610) 666 -7704 Attorneys for Plaintiff, Citizens Bank �� - cx3� 7 CIV t f �°.P ►vl CITIZENS BANK, COURT OF COMMON PLEAS 525 William Penn Place, Suite 2720 CUMBERLAND COUNTY, PA Pittsburgh, PA 15219 i CIVIL ACTION, LAW Plaintiff, No. 2007 -1121 V. R.H. BLACK, INC. d /b /a CUSTOM , PATIO ROOMS OF CENTRAL PA = C= 2550 Bumble Bee Hollow Road ••ate ". =..• co Mechanicsburg, PA 17055 r ''.rn AND �� N ROBERT H. BLACK -< °' ° _ 2250 Bumble Bee Hollow Road Mechanicsburg, PA 17055 c� Defendants. ? PRAECIPE FOR WRIT OF REVIVAL TO THE CLERK/PROTHONOTARY: Kindly issue a Writ of Revival of the Judgment in the above- captioned matter, entered on April 16, 2007, on behalf of the Plaintiff, Citizens Bank, and against the Defendants, R.H. Black, Inc. d/b /a Custom Patio Rooms of Central PA and Robert H. Black in the amount of $1 05,612.54, plus interest from April 16, 2007. THE CHARS WELL LA FICES, LLP O Dated: April 24, 2013 By. / � obert J. Mu ugh�Es ' e 574 4 ,J � , q ( ) M Attorneys f , Citizens nk C lM 38.5 o G3F [/ (0. C>0 �157. D K1 P - "y 4a,a5 due � X8 9738 THE CHARTWELL LAW OFFICES, LLP Robert J. Murtaugh, Esquire ( #57494) 970 Rittenhouse Road, Suite 300 Eagleville, PA 19403 Telephone: (610) 666 -7700 Facsimile: (610) 666 -7704 Attorneys for Plaintiff, Citizens Bank 13-457 OW lTerm CITIZENS BANK, COURT OF COMMON PLEAS 525 William Penn Place, Suite 2720 CUMBERLAND COUNTY, PA Pittsburgh, PA 15219 CIVIL ACTION, LAW Plaintiff, No. 2007 -1121 rn m :Do R.H. BLACK, INC. d /b /a CUSTOM PATIO ROOMS OF CENTRAL PA �� a% c: 2550 Bumble Bee Hollow Road Mechanicsburg, PA 17055 C-) ;' cl AND � � cxa �' �t ROBERT H. BLACK 5 2250 Bumble Bee Hollow Road �. Mechanicsburg, PA 17055 Defendants. WRIT OF REVIVAL To: R.H. BLACK, INC. d/b /a CUSTOM PATIO ROOMS OF CENTRAL PA 2250 Bumble Bee Hollow Road, Mechanicsburg, PA 17055 ROBERT H. BLACK, 2250 Bumble Bee Hollow Road, Mechanicsburg, Pa 17055 (1) You are notified that the Plaintiff, Citizens Bank, has commenced a proceeding to revive the lien of the judgment entered at Docket Number 2007 -1121, in the amount of $105,612.54. (2) The Plaintiff, Citizens Bank, claims that the amount due and unpaid is $105,612.54 with interest from April 16, 2007. (3) 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 in the amount claimed by the Plaintiff may be entered 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 n/ LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED OR NO FEE. c...oSIS : 4 , 167.56 PD ATr/ 01. so DUE co LAWYER REFERRAL SERVICE CUMBERLAND COUNTY 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 240 -2700 Date:.; 1 - ----�— PROTHONOTARY ,DEPUTY Robert J. Murtaugh, Esquire The Chartwell Law Offices, LLP 970 Rittenhouse Road, Suite 300 Eagleville, PA 19403 Attorneys for Plaintiff, Citizens Bank SHERIFF'S OFFICE OF CUMBERLAND COUNTY r ' RonnyR Anderson F/--- r L,c Sheriff TAD�HD��Tb�° JodyS Smith 2013 MAY �� �� � � Chief Deputy ^~^ ''�` = ^ ^' = ^ - Richard VStewart CUMBERLAND COUNTY Solicitor vpqeSRERn� PENNSYLVANIA Citizens Bank vs. Case Number R.H.Bbck. Inc. d/b/e Custom Patio Rooms of Central pA(et o|.) | 2013'2317 SHERIFF'S RETURN OF SERVICE 05/03/2013 O2:47PM'Ronny R Anderson, Sheriff, being duly sworn according to law, states ha made diligent search and inquiry for the within named Defendant to wit: R.H.Black, Inc. d/b/a Custom Patio Rooms of Central PA, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Revival as"Not Found"at 2250 Bumble Bee Hollow Road, Upper Allen, Mechanicsburg, PA 17055. Business has not been located at this address for over 4 years. 05/03/2013 02:47 PM-Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit Robert H. B|ack, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Revival as"Not Found"at 2250 Bumble Bee Hollow Road, Upper Allen, Mechanicsburg, PA 17055. Defendant has not | been et this address in over four years. .SHERIFF COST: $65.30 SO ANSWERS, 6�� � 2--2 1" May 06,.2013 RbNWRANDERSON, SHERIFF'S OFFICE OF CUMBERLAND COUNTY U s. v Ronny RAnderson Sheriff } 0,1 r , r rf#Jody S Smith (m 3: 2 3 Chief Deputy °t , 20. Richard W Stewart �`,1 �`�iBEFi- d0 Solicitor =.4Fic> ��- ({��� SY�d �+�N 4 l i Citizens Bank Case Number vs. 2013-2317 R.H.Black, Inc. d/b/a Custom Patio Rooms of Central PA(et al.) SHERIFF'S RETURN OF SERVICE 05/31/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: R.H.Black, Inc. d/b/a Custom Patio Rooms of Central PA, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Revival as"Not Found"at 1788 North Meadow Drive, Upper Allen, Mechanicsburg, PA 17055. RONALD HOOVER, DEPUTY 05/31/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Robert H. Black, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Writ of Revival as"Not Found"at 1788 North Meadow Drive, Upper Allen, Mechanicsburg, PA 17055. T7 / RONALD HOOVER, DEPUTY SHERIFF COST: $65.30 SO ANSWERS, June 12, 2013 RONR ANDERSON, SHERIFF Shunt 1€:..o>•fi ._.,. SHERIFF'S OFFICE OF CUMBERLAND COUNTY,_Ronny R Anderson °ems :0::::(11.a Sheriff ;�t� i'�iae�J Ct+t1' ' t aaarataa _ 3: e Jody S Smith �v i � }Chief Deputy Richard W Stewart ` l'r'�93ErRICOUSolicitor ,���FE�,}�r-E P NfiANi Citizens Bank vs. Case Number R.H.Black, Inc. d/b/a Custom Patio Rooms of Central PA(et al.) 2013-2317 SHERIFF'S RETURN OF SERVICE 05/28/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: R.H.Black, Inc. d/b/a Custom Patio Rooms of Central PA, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the within Writ of Revival according to law. 05/28/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Robert H. Black, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the within Writ of Revival according to law. 06/05/2013 03:05 PM-The requested Writ of Revival served by the Sheriff of Allegheny County upon Defendant's Father, who accepted for Robert H. Black, at 4560 Battle Ride Road, Oakdale, PA 15071-1708. William Mullen, Sheriff, Return of Service attached to and made part of the within record. 06/05/2013 03:05 PM -The requested Writ of Revival served by the Sheriff of Allegheny County upon Defendant's Father, who accepted for R.H.Black, Inc. d/b/a Custom Patio Rooms of Central PA, at 4560 Battle Ride Road, Oakdale, PA 15071-1708. William Mullen, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $44.46 SO ANSWERS, June 17, 2013 RONINK ANDERSON, SHERIFF ,c:C,ounh/at,to Mont`.To eosof+.. ALLEGHENY COUNTY SHERIFF'S DEPARTMENT 436 GRANT STREET PITTSBURGH, PA 15219-2496 PHONE (412) 350-4700 FAX (412) 350-6388 PETER R. DEFAZIO DENNIS SKOSNIK Sheriff Cumberland Co. Chief Deputy PLAINTIFF: Citizens Bank CASE#: 7 Q7-112 VS. EXPIRES: R.H. Black, Inc. , et al. D SUMMONS/PRAECIPE DEFT.: SEIZURE OR POSSESSION DEFT.: 7 NOTICE AND COMPLAINT DEFT.: N REVIVAL OR SCI FA GARNISHEE: D INTERROGATORIES ADDRESS: 4560 Battle Ridge Road, Oakdale, PA 15071-1708 EXECUTION•LEVY OR GARNISHEE 7 OTHER MUNICIPALITY OR CITY WARD: ATTY: Robert J. Murtaugh, Esquire DATE: May 28 20 13 ADDRESS:970 Rittenhouse Road, Suite 300 ATTY'S PHONE: (61(1) 666-7700 Eagleville, PA 19403 INDICATE TYPE OF SERVICE: 7 PERSONAL gcPERSON IN CHARGE 7 DEPUTIZE J MAIL J POSTED 7 OTHER 7 LEVY 7 SEIZED & STORED NOW: 20 I, SHERIFF OF ALLEGHENY COUNTY PA do hereby deputize the Sheriff of County to execute this Writ and make return thereof according to law NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B.WAIVER OF WATCHMAN-Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment,with out liability on the part of such deputy herein for any loss,destruction or removal of any such property before sheriff's sale therof. Seize,levy,advertise and sell all the personal property of the defendant on the premises located at: MAKE MODEL MOTOR NUMBER SERIAL NUMBER LICENSE NUMBER SHERIFF'S OFFICE USE ONLY I hearby CERTIFY and RETURN that on the day of —1 CA— e_ , 20 , at 3; OS- o'clock,A.M MI Address Above/Address Below, County of Allegheny, Pennsylvania I have served in the manner Described below: /Z. S e-r''r A- Defendant(s) personally served. J Adult family member with whom said Defendant(s) reside(s). Name& Relationship J Adult in charge of Defendant's residence who refused to give name or relationship. Manager/other person authorized to accept deliveries of United States Mail Agent or person in charge of Defendant(s) office or usual place of business. Ether O Parsj -c_r- .T 7-4 Property Posted Defendant not found because: 7 Moved 7 Unknown 3 No Answer 7 Vacant 7 Other 3 Certified Mail 7 Receipt 3 Envelope Returned 7 Neither receipt or envelope retuned:writ expired D Regular Mail Why You are hereby notified that on _ , 19 , levy was made in the case of Possession/Sale has been set for , 20 at o'clock YOU MUST CALL DEPUTY ON THE MORNING OF SALE/POSSESSION BETWEEN 8:30•9:30 A.M. ATTEMPTS Additional Costs Due$ ,This is PETER R. DEFAZIO, Sheriff placed on writ when returned to Prothonotary. Please check BY: before satisfying case. g>fiiMN.ICiN db N6C4tli3HSS+8 t{iNtiAIASNN3d'1139W3W (DEauTV) Affirmed and subscribe• before me tlem N Ae0 sa6ldx•3 uo!ss!wwo0 AN thi day o ,. „_ 20 13 AlunoD Auau6®Iiy'UgJngsn!d Jo RAPIST ICT: I7 2 II Dlignd A�2 ON pJeMpooM ueaf ep / , Was IePePoN �`� '' ' ''`" A VINVA1ASNN3d 30 H11V3MNa1I Qbopy-Sheriff Pink Copy• Attorney 4 Notary ALLEGHENY COUNTY SHERIFF'S DEPARTMENT 436 GRANT STREET PITTSBURGH, PA 15219-2496 PHONE (412) 350-4700 FAX (412) 350-6388 PETER R. DEFAZIO DENNIS SKOSNIK Sheriff Chief Deputy PLAINTIFF: Cumberland Co. r,,,, , ,_- _ C]t�zPns Bank VS. EXPIRES: Robert H. Black, et al. D SUMMONS/PRAECIPE DEFT.: SEIZURE OR POSSESSION DEFT.: D NOTICE AND COMPLAINT DEFT.: a REVIVAL OR SCI FA GARNISHEE: D INTERROGATORIES ADDRESS: 4560 Battle Ridge Road, Oakdale, PA 15071-1708 3 EXECUTION•LEVY OR GARNISHEE OTHER MUNICIPALITY OR CITY WARD: ATTY: Robert .T_ Mnrtaugh, Esquire DATE: May 28 20 13 ADDRESS: 970 Rittenhouse Road, Suite 300 ATTY'S PHONE: (610) 666-7700 Eagleville, PA 19403 INDICATE TYPE OF SERVICE: 3 PERSONAL g7 PERSON IN CHARGE 7 DEPUTIZE 3 MAIL 7 POSTED 3 OTHER 3 LEVY 7 SEIZED & STORED NOW: 20 I, SHERIFF OF ALLEGHENY COUNTY, PA do hereby deputize the Sheriff of County to execute this Writ and make return thereof according to law NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B.WAIVER OF WATCHMAN-Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession,after notifying person of levy or attachment,with out liability on the part of such deputy herein for any loss,destruction or removal of any such property before sheriff's sale therof. Seize,levy,advertise and sell all the personal property of the defendant on the premises located at: MAKE MODEL MOTOR NUMBER SERIAL NUMBER LICENSE NUMBER SHERIFF'S OFFICE USE ONLY I hearby CERTIFY and RETURN that on the day of D—Gt -i , 20 /..1 , at i;o _o'clock,A.M.,I Address Above/Address Below, County of Allegheny, Pennsylvania I have served in the manner Described below: Defendant(s) personally served. Adult family member with whom said Defendant(s) reside(s). Name& Relationship Adult in charge of Defendant's residence who refused to give name or relationship. Manager/other person authorized to accept deliveries of United States Mail Agent or person in charge of Defendant(s) office or usual place of business. Other © j.✓.r{r 1 � -Cis �� ���J C k f � .(� 7 Property Posted Defendant not found because: 0 Moved D Unknown 0 No Answer 7 Vacant O Other 0 Certified Mail >Receipt 0 Envelope Returned 3 Neither receipt or envelope retuned:writ expired D Regular Mail Why You are hereby notified that on , 19 , levy was made in the case of Possession/Sale has been set for , 20 at o'clock YOU MUST CALL DEPUTY ON THE MORNING OF SALE/POSSESSION BETWEEN 8:30-9:30 A.M. ATTEMPTS Additional Costs Due$ ,This is PETER R. DEFAZIO, Sheriff placed on writ when returned to Prothonotary. Please check before satisfying case. COMMONWEALTH OF PENNST A � THE CHARTWELL LAW OFFICES, LLP Robert J. Murtaugh, Esquire (#57494) 970 Rittenhouse Road, Suite 300 Eagleville, PA 19403 Telephone: (610) 666-7700 Facsimile: (610) 666-7704 Attorneys for Plaintiff, Citizens Bank CITIZENS BANK, y COURT OF COMMON PLEAS 525 William Penn Place, Suite 2720 CUMBERLAND COUNTY, PA Pittsburgh, PA 15219 CIVIL ACTION, LAW Plaintiff, No. 2007-1121 -, 3 �z --i V. Revival No. 2013-2317 �- fi- r R.H. BLACK,INC. d/b/a CUSTOM C.) PATIO ROOMS OF CENTRAL PA C) 2550 Bumble Bee Hollow Road _ Xµ Mechanicsburg;PA 17055 �' ' r n AND CO ROBERT H. BLACK - 2250 Bumble Bee Hollow Road Mechanicsburg, PA 17055 Defendants. PRAECIPE PURSUANT TO PA.R.CIV.P. RULE 1037 (a) TO ENTER JUDGMENT BY DEFAULT AND FOR ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Please enter a Judgment by Default in favor of the Plaintiff, Citizens Bank, and against the Defendants, R.H. Black, Inc. d/b/a Custom Patio Rooms of Central PA and Robert H. Black,, pursuant to Pa. R. Civ. P. Rule 1037(a) for their failure to file an answer or other.response to the Writ of Revival which was filed against and served upon them in connection with the above- captioned matter, based upon the attached Certification of Counsel, for the amount due under the 105,sra. subject loan, and assess damages in the amount of$i4?3.9. with interest accruing after April 4+,-tMTat the rate of$14.34 per diem. 6, soft � Per done C�!l w•� ���Q323`1 o fic 2 r!f��Gec✓ . THE CHA LL LAW FFICES, LL Date: July 15, 2013 By: o ert J. Murt h, q it ( 5 494) 0 Rittenhou Road, Suite 300 Eagleville, PA 19403 Telephone: (610) 666-7700 Facsimile: (610) 666-7704 Attorneys for Plaintiff, Citizens Bank THE CHARTWELL LAW OFFICES,LLP Robert J. Murtaugh, Esquire (#57494) 970 Rittenhouse Road, Suite 300 Eagleville, PA 19403 Telephone: (610) 666-7700 Facsimile: (610)666-7704 Attorneys for Plaintiff, Citizens Bank CITIZENS BANK, COURT OF COMMON PLEAS 525 William Penn Place, Suite 2720 CUMBERLAND COUNTY, PA Pittsburgh, PA 15219 CIVIL ACTION, LAW Plaintiff, No. 2007-1121 c-) V. Revival No. 2013-2317 R.H. BLACK, INC. d/b/a CUSTOM ,. r-- PATIO ROOMS OF CENTRAL PA 2550 Bumble Bee Hollow Road , Mechanicsburg, PA 17055 : :Z AND crxr ROBERT H. BLACK 2250 Bumble Bee Hollow Road : Mechanicsburg, PA 17055 : Defendants. CERTIFICATE OF COUNSEL PURSUANT TO PA.R.CIV.P. RULE 237.1 IN SUPPORT OF PRAECIPE PURSUANT TO PA R CIV P RULE 1037 (a) TO ENTER JUDGMENT BY DEFAULT AND FOR ASSESSMENT OF DAMAGES NOW COMES the undersigned counsel of record for the Plaintiff, Citizens Bank ("Citizens Bank"), and pursuant to Pa. R. Civ. P. Rule 237.1, files the following Certificate in Support of its Praecipe to Entry Judgment by Default: 1. On April 26, 2013, Plaintiff commenced the above-captioned action by filing a Writ of Revival ("Writ") against the Defendants, R.H. Black, Inc. d/b/a Custom Patio Rooms of Central PA and Robert H. Black (hereinafter collectively the "Defendants"). 2. On June 5 2013, the Writ was served by having the Sheriff of Cumberland County deputize the Allegheny County Sheriff's Office which hand delivered a true and correct copy y ' upon each Defendant, as noted on the Sheriff's Affidavit of Service. A true and correct copy of the Sheriff's Affidavit of Service is attached hereto, made apart hereof and marked Exhibit"A." 3. On June 26, 2013, after the Defendants failed to file an answer or otherwise plead to Plaintiff's Complaint, the Defendants were served, in accordance with Rule 23 7.1(a)(2)(ii), a Rule 237.5 Notice of Intent to File a Praecipe to Enter Judgment by Default, by regular mail with a United States Postal Service Certificate of Mailing. True and correct copies of the Notice with Certificate of Mailing are attached hereto, made a part hereof and collectively marked Exhibit «B „ 4. As of this date, the Defendants still have not filed any answer or other response to Plaintiff's Complaint. 5. I make this Certification on the basis of my own knowledge, and subject to the penalties for perjury pursuant to 18 Pa. C. S. A. Section 4901 et seq., and false swearing before a notary public, pursuant to 18 Pa. C. S. A. Section 4903, and/or unsworn verification to authorities pursuant'to 18 Pa. C. S. A. Section 4904, as applicable. I am aware that if any of the statements made herein are willfully false, that I am subject to such penalties. THE CH W LL LAW FILES, L P Date: July 15, 2013 By: Ro ert . Murt gh, Es�quiie (# 94) 0 Rittenho e Road, Suite 300 Eaglevi11e P 19403 Telephone: (610) 666-7700 Facsimile: (610) 666-7704 Attorneys for Plaintiff, Citizens Bank EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Al Jody S Smith Chief Deputy Richard W Stewart Solicitor vr'ICE Or HF Pi,=Fr P Citizens Bank vs. Case Number R.H.Black, Inc. d/b/a Custom Patio Rooms of Central PA(et al.) 2013-2317 SHERIFF'S RETURN OF SERVICE 05/28/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: R.H.Black, Inc. d/b/a Custom Patio Rooms of Central PA, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the within Writ of Revival according to law. 05/28/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Robert H. Black, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the within Writ of Revival according to law. 06/05/2013 03:05 PM-The requested Writ of Revival served by the Sheriff of Allegheny County upon Defendant's Father,who accepted for Robert H. Black, at 4560 Battle Ride Road, Oakdale, PA 15071-1708.William Mullen, Sheriff, Return of Service attached to and made part of the within record. 06/05/2013 03:05 PM-The requested Writ of Revival served by the Sheriff of Allegheny County upon Defendant's Father,who accepted for R.H.Black, Inc. d/b/a Custom Patio Rooms of Central PA, at 4560 Battle Ride Road, Oakdale, PA 15071-1708. William Mullen, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $44.46 SO ANSWERS, 6Z �� June 17, 2013 RONK R ANDERSON, SHERIFF (c)CountySulte Sheriff,Teleoso8.Inc. RECEIVED JUN 2 5 2013 EXHIBIT "B " THE CHARTWELL LAW OFFICES,LLP Robert J. Murtaugh,Esquire (#57494) 970 Rittenhouse Road, Suite 300 Eagleville, PA 19403 Telephone: (610) 666-7700 Facsimile: (610) 666-7704 Attorneys for Plaintiff, Citizens Bank CITIZENS BANK, COURT OF COMMON PLEAS 525 William Penn Place, Suite 2720 CUMBERLAND COUNTY,PA Pittsburgh, PA 15219 CIVIL ACTION, LAW Plaintiff, No. 2007-1121 V. Revival No. 2013-2317 R.H. BLACK,INC. d/b/a CUSTOM PATIO ROOMS OF CENTRAL PA 2550 Bumble Bee Hollow Road Mechanicsburg,PA 17055 AND ROBERT H. BLACK 2250 Bumble Bee Hollow Road Mechanicsburg,PA 17055 Defendants. NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT PURSUANT TO RULE 237.1 TO: R.H. BLACK,INC. d/b/a CUSTOM PATIO ROOMS OF CENTRAL PA c/o Robert H.Black, 4560 Battle Ridge Road, Oakdale,PA 15071-1708 ROBERT H. BLACK, 4560 Battle Ridge Road, Oakdale, PA 15071-1708 DATE OF NOTICE: June 26,2013 IMPORTANT NOTICE: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LAWYER REFERRAL SERVICE CUMBERLAND COUNTY 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 TELEPHONE: (717) 240-2700 THE C J, LL LAW OFFICES,LLP Date: June 26, 2013 By: � G"' ert J. ug$;Esquire 7494) 970 RittenhOuse Road, Suite 300 Eagleville,PA 19403 Telephone: 610.666.7700 Facsimile: 610.666.7704 Attorneys for Plaintiff, Citizens Bank UNITED STATE t ' ,yfi ceT pay last aNta atampr or ��' , i�i14 i{.cnuatap■he PIO.ST4L$�RV1 r' This coropentaorMallin prov"a■avld■ncrin im■Nha Pr PITNEY BOWES Thla lom+may 6.va■d fvr domullo and InUmaUanal m 1:• 02 1 P $ 001 -200 1 534 JUN 26 2013 MAILED FROMZiP CODE 19403 45986—Robert J.Murtaugh,Esquire The Chartwell Law Office,LLP 970 Rittenhouse Road,Suite 300 vs A 1194 Z Eagleville,PA 19403 _ d` / postmor Hera R.H.Black,Inc.d/b/a Custom Patio Rooms of Central PA 9 v 19 c/o Robert H.Black 4560 Battle Ridge Road Oakdale,PA 15071-1708 �_�� PS Form 3817,April 2007 PSN 7630-02-000-8066 P��P0.ST'Q T Icate Of� T _ TNE `gB To pry too.■Ilx stamps or R Vr / S"� O Mailing motor postage hers. Thf 611 f ■ p d"P.,ld•rrcr Ih■r nvH rtq b■vrEprvS brid to USPam[of malllnp. ThI p t r�r�ueaya2gld Ggr{raUonal�rhall� 1 9403 ►— MAILED FROM Zip COD 45 6—Robert J.Murtaugh,Esquire The Chartwell Law Office,LLP 970 Rittenhouse Road,Suite 300 Eagleville,PA 19403 ~H ?ASS Postmark Hasa To' Robert H.Black N 2 6 2013 4560 Battle Ridge Road Oakdale,PA 15071-1708 �w PS Form 3817,April 2007. PSN 7630-02-000-8066 THE CHARTWELL LAW OFFICES,LLP Robert J. Murtaugh, Esquire (#57494) 970 Rittenhouse Road, Suite 300 Eagleville, PA 19403 Telephone: (610) 666-7700 Facsimile: (610) 666-7704 Attorneys for Plaintiff, Citizens Bank CITIZENS BANK, COURT OF COMMON PLEAS 525 William Penn Place, Suite 2720 CUMBERLAND COUNTY, PA Pittsburgh, PA 15219 CIVIL ACTION, LAW Plaintiff, No. 2007-1121 V. Revival No. 2013-2317 R.H. BLACK,INC. d/b/a CUSTOM PATIO ROOMS OF CENTRAL PA rz 2550 Bumble Bee Hollow Road ;' = Mechanicsburg, PA 17055 --•1 rn-�Q0 .- AND M ROBERT H. BLACK 2250 Bumble Bee Hollow Road Mechanicsburg, PA 17055 ; a D = . _ Defendants. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF MONTGOMERY BEFORE ME, the undersigned attorney, a Notary Public, personally appeared Robert J. Murtaugh, Esquire, whose identity was known to me or established to my satisfaction, and who, after having been duly sworn according to law, deposes and says as follows: 1. I am over eighteen (18) years "of age, I am currently an attorney in good standing and duly admitted to practice law in the Commonwealth of Pennsylvania; I am an associate at The Chartwell Law Offices, .LLP, and in that capacity, have been retained to represent the Plaintiff, Citizens Bank, in the above-captioned matter, and as such I am duly authorized to make this Affidavit on its behalf. 2. I have responsibility for handling the files and litigation concerning the loan documents and collateral involved in this matter, and 1 am fully familiar with the facts therein described. 3. I have been advised and therefore believe and aver that the Defendant, R.H. Black, Inc. d/b/a Custom Patio Rooms of Central PA, is a corporation existing in the. Commonwealth of Pennsylvania and is not presently in active duty in the military or naval service of the United States of America, is not an active member of the Army of the United States, the Marine Corps or Coast. Guard, and is not an officer of the Public Health Service detailed by proper authority for duty with the Army or Navy; nor has it engaged in any active military service or active,military duty with any military or naval unites covered by the Soldiers and Sailors Civil Relief Act of 1940 (the "Act") and designated therein as military service; nor has it,to the best of my knowledge, enlisted in any military service covered by this Act. 4. 1 have been advised and therefore believe and aver that the Defendant, Robert H. Black, is an adult individual existing in the Commonwealth of Pennsylvania and is not presently in active duty in the military or naval service of the United States of America, is not an active member of the Army of the United States, the Marine Corps or Coast Guard, and is not an officer ' of the Public Health Service detailed by proper authority for duty with the Army or Navy; nor has he engaged in any active military service.or active military duty with any military or naval unites covered by the Soldiers and Sailors Civil Relief Act of 1940 (the "Act") and designated therein as military service; nor has he, to the best of my knowledge, enlisted in any military service covered by this Act. 5. 1 make this Affidavit on behalf of Citizens Bank, on the basis of my own knowledge, and subject to the penalties for perjury pursuant to 18 Pa. C. S. A. § 4901 et seq., and false swearing before a notary public pursuant to 18 Pa. C. S. A. § 4903, and/or unsworn verification to authorities pursuant to 18 Pa. C. S. A. § 4904, as applicable, and am aware that if any of the statements I have made herein are willfully false,that I am subject to such penalties.. THE CH T ELL L OFFICES;LISP' Date: July 15,2013 By: L"ert J. M augh q i SWORN TO and SUBSCRIBED before me,this 1 th day f Ju1y, 2013 NOTARY PUB , C My Commission Expires: "r COMMONWEALTH OF PENNSYLVANIA Notarial Seal Eileen M.Aquilani,Notary Public tower Providence Twp.,Montgomery county My commission Expires Dec.12,2014 MEMBER;PENNSYLVANIA ASSOCIATION OF NOTARIES c _ r ` r THE CHARTWELL LAW OFFICES,LLP Robert J. Murtaugh, Esquire (#57494) ,970 Rittenhouse Road, Suite 300 Eagleville, PA 19403 Telephone: (610) 666-7700 Facsimile: (610)'666-7704 Attorneys for Plaintiff, Citizens Bank CITIZENS BANK, COURT OF COMMON PLEAS 525 William Penn Place, Suite 2720 CUMBERLAND COUNTY, PA Pittsburgh, PA 15219 CIVIL ACTION, LAW Plaintiff, No. 2007-1121 V. Revival No. 2013-2317 R.H. BLACK, INC. d/b/a CUSTOM ra PATIO ROOMS OF CENTRAL PA ZZ 2550 Bumble Bee Hollow Road _ t � Mechanicsburg, PA 17055 : ;C� `r— 70 CJ AND ROBERT H. BLACK „ 2250 Bumble Bee Hollow Road C1 Mechanicsburg, PA 17055 Defendants. co AFFIDAVIT OF LAST KNOWN ADDRESSES COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF MONTGOMERY BEFORE ME, the undersigned attorney, a Notary Public, personally appeared Robert J. Murtaugh, Esquire, whose identity was known to me or established to my satisfaction, and who, after having been duly sworn according to law, deposes and says as follows: 1.' I am over eighteen (18) years of age, I am currently an attorney in good standing and am duly admitted to practice law in the Commonwealth of Pennsylvania; I am an associate at . The Chartwell Law Offices, LLP, and in that capacity, have been retained to represent the Plaintiff, Citizens Bank, in the above-captioned matter, and as such I am duly authorized to make this Affidavit on its behalf. 2. I have responsibility for handling the files and litigation concerning the loan documents and collateral involved in this,matter, and I am fully familiar with the facts therein, described. 3. 1 hereby certify that the last known address of the Plaintiff, Citizens Bank, is 525 William,Penn Place, Suite 2720, Pittsburgh, PA,15219. 4. I hereby certify that the last known address of the Defendants, R.H. Black, Inc. d/b/a Custom Patio Rooms of Central PA and Robert H. Black, is 4560 Battle Ridge Road, Oakdale, PA 15071-1708. 5. I make this Affidavit on behalf of Citizens Bank, on the basis of my own knowledge, and subject to the penalties for perjury pursuant to 18 Pa-C. S. A. § 4901 et seq., and false swearing before a notary public pursuant to, 18 Pa. C. S. A. § 4903, and/or unsworn verification to authorities pursuant to 18 Pa. C. S. A. § 4904, as applicable, and am aware that if any of the statements I have made herein are willfully false,that I am subject to such penalties. THE CH T ELL LA FFICES, LLP Date: July 15, 2013 By: , R ert J. Mu a gh, uire t( — SWORN TO and SUBSCRIBED before me, this 1!5V' day f July, 2013 NOTARY PUB L C My-Commission Ex res:. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Eileen M.Aquilani,Notary Public Lower Providence Twp.,Montgomery county My Commission Expires Dec.12,2014 f 'I MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES THE CHARTWELL LAW OFFICES,LLP . Robert J. Murtaugh, Esquire (#57494) 970 Rittenhouse Road, Suite 300 Eagleville, PA 19403 Telephone: (610) 666-7700 Facsimile: (610) 666-7704 Attorneys for Plaintiff, Citizens Bank CITIZENS BANK, COURT OF COMMON PLEAS 525 William Penn Place, Suite 2720 CUMBERLAND COUNTY, PA Pittsburgh, PA 15219 CIVIL ACTION, LAW Plaintiff, No. 2007-1121 V. Revival No. 2013-2317 R.H. BLACK,INC. d/b/a CUSTOM PATIO ROOMS OF CENTRAL PA 2550 Bumble Bee Hollow Road : Mechanicsburg, PA 17055 : AND ROBERT H. BLACK : 2250 Bumble Bee Hollow Road Mechanicsburg, PA 17055 Defendants. CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 151h day of July, 2013, a true and correct copy of the foregoing Judgment by Default, and all supporting papers, was served upon the Defendants,by United States First Class Mail, postage prepaid, addressed as follows: R.H. Black,Inc. d/b/a Custom Patio Rooms of Central PA c/o Robert H. Black 4560 Battle Ridge Road, Oakdale, PA 15071-1708 Robert H. Black, 4560 Battle Ridge Road, Oakdale, PA 15071-1708 THE CH T EWLA FFICES, LLP Date: July 15, 2013 By: Ro eih J. Mu ugh, q it ( 494) THE CHARTWELL LAW OFFICES,LLP Robert J. Murtaugh, Esquire(#57494) 970 Rittenhouse Road, Suite 300 Eagleville,PA 19403 Telephone: (610) 666-7700 Facsimile: (610) 666-7704 Attorneys for Plaintiff, Citizens Bank CITIZENS BANK, COURT OF COMMON PLEAS 525 William Penn Place, Suite 2720 CUMBERLAND COUNTY, PA Pittsburgh, PA 15219 CIVIL ACTION, LAW Plaintiff, No. 2007-1121 V. Revival No. 2013-2317 R.H. BLACK,INC. d/b/a CUSTOM PATIO ROOMS OF CENTRAL PA 2550 Bumble Bee Hollow Road Mechanicsburg, PA 17055 : AND ROBERT H.BLACK 2250 Bumble Bee Hollow Road Mechanicsburg, PA 17055 Defendants. NOTICE OF ENTRY OF JUDGMENT PURSUANT TO PA.R.CIV.P. RULE 236 TO: R.H.Black,Inc. dlb/a Custom Patio Rooms of Central PA c/o Robert H. Black. 4560 Battle Ridge Road, Oakdale,,PA 15071-1708 ROBERT H. BLACK, 4560 Battle Ridge Road, Oakdale, PA 15071-1708 You are hereby notified pursuant to Pa. R. Civ. P. Rule 236 that on Z /7 , 2013, a judgment, was entered against you in the above-captioned matter. Attached hereto is a true and correct copy of all (recorded) documents filed in support of said judgment. IF YOU HAVE ANY QUESTIONS CONCERNING THE ENTRY OF THIS JUDGMENT, YOU MAY CALL THE ATTORNEY FOR .THE PLAINTIFF, ROBERT J. MURTAUGH,ESQUIRE AT(610) 666-7700. BY THE OT OT .► T