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Home My WebLink About04-6413 JUDICIAL DISTRICT NOTICE OF APPEAL J~ /.:.l/';/I! or DISTRICT JUSTICE JUDGMENT fROM , .;MONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS COMMON PLEAS No. 0 '1_ (.; cr 13 0t.;/ ~ NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. ClAIM NO. ADDRESS Of APPellANT C/O stock &. Grimes, LLP, 804 West A.venue, Jenkintown, PA 19046 DA.TE Of .JUOGMfNT IIN THE CASE OF (PlalTl/lff) 11/22/04 Elite Recovery Svc/Providian funk vs. Theodore Gill SlGNATUR APPELLANT OR HIS ATT CV 478-04 ~s x. . GR ' #62404 Tho bOo,' .,;11 ~ .",... ONLY whe, th;, oolanon ;, "",,;red ood~ p~ ~ a 1/anI was CLAIMANT (see Pa. R.C.P.J.P. No. 1oo8B. This Notice of Appeal, when received by the District Justice, will operate as a 1001 (6) in action before District Justice, he MUST SUPERSEDEAS to the judgment for possession in this case. FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. aTY I MAG. D1ST. NO. OR NAME Of D.). 09-1-01 STATE ZP COOE NAME Of APPEllANT ELITE RECOVERY SVC/PROVIDIAN BANK (Defendant) Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO fiLE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 100 1( 7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee). PRAECIPE: To Prothonotary Enter rule upon , appellee(s), to file a complaint in this appeal Name of appellee( s) (Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or hiS attomey or agent RULE: To Name of appeli(3e(s) , appellee(s). (1) You are notified that a. rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST yOU. (3) The date of service of this rule if service was by mail is the date of mailing. Date: Signature of ProttJonotwy 01 Deputy AOPC 312-90 COURT FILE TO BE FILED WITH PROTHONOTARY PROOF OF SERVICE OF NOTICE APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN DA YS AFTER the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF_________ ,55 AFFIDAVIT: I hereby swear or affirm that I served a copy of the Notice of Appeal, Common Pleas No, (date of service) ___ _____ attached hereto, and upon the (name) upon the District .Justice therein on by personal service by (certified) (registered) mail, sender's ..._._~.____..._'_.._~, on ___,_~~, service by (certified) (registered) mail, sender's receipt attaChed hereto o and further that I served the Rule to File a "o~ompaf;y:ng the above Notice of Appeal upon the apPellee(s) to whom the Rule was addrpssed on .________'.,.___,,_,_ hy service (certified I mall. sender's attached hereto SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS ~__ DAY OF ~____~,___,_ , Signature of affiant Signature of oftroa! t)etore whorn afhdd\!{! Title of offil;ial My commiSSIon expires on c.; t... ., ~ --'~ ~<',~ ~ ~ ~ ...... ...... <r, '--\ .",p ~ -!; <" C> ~ ":-*:> c-: ~ ~ ~ r:-" I,i CJ t".' r,) ".:1. "n! :" "1')'':) ! .., '. . - ~ - -: ' Hj \r, ""., \, Jf ,J ~ ~ t x ~ (' ~ \ ' - ' .- COMMONWEALTH OF PENNr " VANIA COUNTY OF: CUMBERLAm. Mag Dist No. 09-1-01 OJ Name. Hon CHARLES A. CLEMENT, JR. Address: 400 BRIDGE STREET OLDE TOWNE COMMONS -SUITE 3 NEW CUMBERLAND, PA Telephone: (717 ) 774-5989 17070 ATTORNEY FOR PLAINTIFF STOCK & GRIMES, LLP 804 WEST AVENUE FRANCIS X GRIMES ESQ JENKINWOWN, PA 19046 THIS IS TO NOTIFY YOU THAT: Judgment: NOTICE ( \JUDGMENTITRANSCRIPT \,r,IVIL CASE PLAINTIFF: NAME and ADDRESS ~LITE RECOVERY SVC/PROVIDIAN BANK I 804 WEST AVE C/O STOCK & GRIMES LLP ~ENKINTOWN, PA 19046 .J VS. DEFENDANT: NAME and ADDRESS /GILL, THEODORE 415 2ND STREET NEW CUMBERLAND, PA 17070 L Docket No.: CV-0000478-04 Date Filed: 8/25/04 I .J FOR nF.FRmlA1\lT [!J [iJ Judgment was entered for: (Name) ~TT.T., THR(,)110RF. Judgment was entered against: (Name) in the amount of $ RT.TTF. RRC'.QVF.RY ~VC'JpROVTnTAN R 11/'-'-/04 _ 00 on: D Defendants are jointly and severally liable. D Damages will be assessed on: D This case dismissed without prejudice. D Amount of Judgment Subject to Attachment/42 Pa.C.S. ~ 8127 $ o Portion of Judgment for physical damages arising out of residential lease $ (Date of Judgment) (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total $ $ $ $ $ .00 .00 .00 .00 .00 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COpy OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. NfW '} '} ?OOlpate ~Q.~.~. , District Justice Date I certify that this is a true and correct copy of the record of the proceedings containing the judgment. , District Justice My commission expires first Monday of January, 2008 . AOPC 315-03 DATE PRINTED: 11/22/04 SEAL 5:11:26 PM JUDICIAL DISTRICT NOTICE OF APPEAL J~ /~i.J11 or DISTRICT JUSTICE JUDGMENT FROM , ..MONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS COMMON PLEAS No. 0 '1_ & V J3 (!;.t'J ~ NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. ADDRESS Of APPEUANT C/O stock & Grimes, LLP, 804 West Avenue, Jenkintown, PA 19046 DATE Of JUDGMENT IIN THE CASE Of (Plaintiff) 11/22/04 Elite Recovery Svc/Providian Bank vs. Theodore Gill SlGNATUR APPELLANT OR HIS ATT CV 478-04 l1S X. . lT r j /MIl/I?, This block will be signed ONLY when this notation is required under Po. . lifr~~vvv' A a. I/ant was CLAIMANT (see Pa. R.GP.J.P. No. 1008B. This Notice of Appeal, when received by the District Justice, will operate as a 1001 ( 6) in action before District Justice, he MUST SUPERSEDEAS to the judgment for possession in this case. FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. OTY I MAG. DtST. NO. OR NAME Of D.l. 09-1-01 STATE ZI' COOE NAME Of APPELLANT ELITE RECOVERY SVC/PROVIDIAN BANK (Defendant) aAlM NO. #62404 Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONL Y when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001 (7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee). PRAECIPE: To Prothonotary Enter rule upon , appe/lee(s), to file a complaint in this appeal Name of appellee(s) (Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or hiS attorney or agent RULE: To Name of appel/fffl( s) , appe/lee(s). (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, 0 JUDGMENT OF NON PROS Will BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of mailing. Date: Si{TlaIlXe of ~ Of Deputy AOPC 312-90 COURT FILE TO BE FILED WITH PROTHONOTARY - -.... PROOF OF SERVICE OF NOTiCE APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DA VS AFTER rhe notice of appeal Check applicable boxes) COMMONWEALTH Of PENNSYLVANIA COUNTY OF_____,___ ; 1111 AFFIDAViT: I hereby swear or affirm that I served a copy of the Notice of Common Pleas No, r date of service) attached hereto, and upon the upon the District Justice DeSignated therem on by personal service by (certified) (registered) mail, sender's o and further that I served the Rule to File a Rule was addrp':lSed on ._ ,~._~~__ mail. sender's attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEfORE ME __.~__, on by (certified) (registered) mail, sender's receipt attached hereto the above Notice of Appeal upon the appcllee(sl to whom by service THIS _ DAY OF Signature of affiant Sfgnature af of1f(;1[11 before whom f;.1f:(}til;'l! T,Ue of offioial My commiSSion expires on <.; r., ) r..,'_.7:l , ~:.l "~ ~ ~ ~ -- ...... V\ (.\ ~ """ ...c:; (', C ~ -:-I::> ?-= ~ ' ':!\ ~.". c:.1 j', i C) r....'i : j :1- . :~. I . i ..1') '.:.) ',1.. .\ ~ ~: V>, i " .-' I. ..:: > J( ..t..:- ~ "" t ~ ~ ::: " ~ ' .. '"- COMMONWEALTH OF PENNf' -, VANIA COUNTY OF: CUMBERLAm. Mag. Dls!. No 09-1-01 DJ Name: Hon. CHARLES A. CLEMENT, JR. Address. 400 BRIDGE STREET OLDE TOWNE COMMONS -SUITE 3 NEW CUMBERLAND, PA Telephone (717) 774-5989 17070 ATTORNEY FOR PLAINTIFF STOCK & GRIMES, LLP 804 WEST AVENUE FRANCIS X GRIMES ESQ JENKINWOWN, PA 19046 THIS IS TO NOTIFY YOU THAT: Judgment: NOTICE ( \)~UDGMENT/TRANSCRIPT ~IVIL CASE PLAINTIFF: NAME and ADDRESS ~LITE RECOVERY SVC/PROVIDIAN BANK I 804 WEST AVE C/O STOCK & GRIMES LLP ~ENKINTOWN, PA 19046 -.J VS. DEFENDANT: NAME and ADDRESS rGILL, THEODORE 415 2ND STREET NEW CUMBERLAND, PA 17070 L Docket No.: CV- 0000478 - 04 Date Filed: 8/25/04 I -.J FOR nF.FRmlANT ~ ~ Judgment was entered for: (Name) ~TT.T., rrHF.0l10FF. Judgment was entered against: (Name) in the amount of $ F.T.TTF. RF.~OVF.RY ~V~/PROVTnTAN' R (Date of Judgment) 11/22/04 _ 00 on: o Defendants are jointly and severally liable. D Damages will be assessed on: D This case dismissed without prejudice. D Amount of Judgment Subject to Attachment/42 Pa.C.S. S 8127 $ D Portion of Judgment for physical damages arising out of residential lease $ (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total $ $ $ $ $ .00 .00 .00 .00 .00 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COpy OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. NOV ') ') 200lpate ~Q ~#< , District Justice Date I certify that this is a true and correct copy of the record of the proceedings containing the judgment. , District Justice My commission expires first Monday of January, 2008 . AOPC 315-03 DATE PRINTED: 11/22/04 SEAL 5:11:26 PM iI " " S10CK & GRIMES, LLP BY: Francis X. Grimes, Esquire 1.0. # 62404 804 West Avenue Jenkintown, PA 19046 (215) 576-1900 Attorney for Plaintiff 'j .1 ELITE RECDVERY SERVICES AS P$SIGNEE OF PROVIDIAN NATIONAL BANK c/o Stock & Grimes, LLP 804 West Avenue Jenkintown, PA 19046 COURT OF COMMON PLEAS aJMBERLn.ND CO U N T Y CIVIL ACTION-LAW :\ 'I II i j .j Ii ;1 '! il iI ;i ji ;' il ,I " il 1I I, :1 Plaintiff vs. NO. 0 l/- ~ I.{ 13 Cu.2J 7l~ THEOOORE GILL 415 2nd Street New Cumber land, PA 17070 ~fendant ( s) CIVIL ~OO "NOTICE .. "Y ou have been sued in courl. I f you wi sh to .defend against the claims set forth in the fol- lowing pages, you must t.1ke action within twenty (20) days after this conlplaint and notice are served, by entering a written appdar.1nce person- alty or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that .if you fail to do so the case Illay proceed without you and a judgment may be entered against you by the court wi thout further not ice for any money claimed In the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. "AVISO" "Le han demandado a usteden I a corte. Si usted quiere defenderse de estas demandas ex- puestas en las paginas siguientes, usted tiene veinte (20) dras de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escri ta sus defensas 0 sus objeciones alas demandas en con tra de su persona. Sea avi sado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificaci6n. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de est a demanda. Usted puede perder dinero 0 SUS propiedades u otros derechos importantes para usted. " "YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. il II ,I 'I II I ,I II II iI "LLEVE EST A DEMANDA A UN ABO- GADO INMEDIATAMENTE. SI NO TIENE ABO- GADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAn TAL SERVICIO) VAYA EN PER- SONA 0 LLAME POR TE,LEFONO A LA OFI- CINA CUY A DIRECC10N SE ENCUENTRA ESCRIT A ABAJO 4.RA AVERIGUAR DONDE SE PUEDE CONSE llR ASISTENCI' LEGAL. L1\WYER REFERENCE SERVICES Court"~llinistrator ....::.......CUnberland"COunty Courthouse 4th Floor, One Courthouse Square Carlisle, P1\ 17013 (717) 240-6200 " . " . STOCK & GRIMES, LLP BY: Francis X, Grimes, Esquire I,D.#62404 804 West Avenue Jenkintown, PA 19046 (215) 576-1900 ELITE RECOVERY SERVICES AS ASSIGNEE OF PROVIDIAN NATIONAL BANK c/o Stock & Grimes, LLP 804 West Avenue Jenkintown, PA 19046 Plaintiff vs. THEODORE GILL 415 2ND Street New Cumberland, PA 17070 Defendant(s) Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW NO. CIVIL ACTION COMPLAINT 1. Plaintiff, Elite Recovery Services, is the purchaser and assignee of the obligation under suit herein, and/or is the authorized representative of providian National Bank or the servicer of a credit card account issued by providian National Bank to the Defendant(s) herein, in accordance with a credit card agreement between Providian National Bank and the Defendant. 2. The Defendant(s), Theodore Gill, is/are adult individual(s) residing at the address contained in the above caption. 3. On sundry and various occasions, Defendant(s), with the use of a (or) credit card(s) issued by providian National Bank pursuant to their credit card agreement(s), made various purchases of goods and/or merchandise with the use of the credit card(s) from authorized merchants. 4. The present outstanding balance which is due on the account(s) is $3,347,03; and, although repeated requests and demands have been made upon the Defendant(s) to satisfy the same in accordance with the terms and conditions of the credit card agreement(s), the Defendant(s) has/have and still refuse(s) to pay the same. 5. As a result thereof, Plaintiff has been forced to incur reasonable attorney collection fees in the sum of $836.76 in an attempt to legally enforce collection of the debt due it from the Defendant(s), which reasonable attorney fees are the responsibility of the Defendant(s) to pay in accordance with the Cardmember Agreement. 6. Plaintiff's investigation has determined that the Defendant(s) is not in the military service. 7. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. WHEREFORE, Plaintiff, Elite Recovery Services, as the assignee and/or purchaser of the credit card account(s) with providian National Bank, demands Judgment against the Defendant(s), Theodore Gill, in Attorney fo the sum of $4,183.79, with interest and DATE: j7-/JJ~i' ~ VERIFICATION FRANCIS X. GRIMES, ESQUIRE, Attorney for Plaintiff herein, verifies that the statements made in this Pleading are true and correct and that he is authorized to make them on behalf of the Plaintiff. He understands that the statements herein are made subject to the penalties of 18 Pa. C.S.A. Sec. 4904, relating to unsworn falsification to authorities. , ~ Request for Military Status https:/ /www.drndc.osd.miI/udpdril owa/sscra.prc _Select Department of Defense Manpower Data Center DEC-20-200407:1O:42 Military Status Report Pursuant to the Servicemen's Civil Relief Act of 2003 I <Last Name First I Middle Begin Date ~. Active Duty Status ! Service/Agency I G~L THEODORE [currentlY not o~ Active Military Duty, based on the Social Security Number and last name provided.. Upon searching the information data banks ofthe Department of Defense Manpower Data Center, the above is the current status of the Defendant(s), per the Information provided, as to all branches of the Military. ~)&6-~ Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. If you have information that makes you feel that the DMDC response is not correct, please fax your response to 703-696-4156 or call 703-696-6762 and further research will be done. For personal privacy reasons, SSNs are not available on this printed results page. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non-match. 1 of 1 12/20/2004 10: 15 AM r:1 .... .' '. -, ... , .~ , i r::,.' --. , I - , Co 1 ; r\, ;'( ~ ....-.~ :'t I J .1 -.:: r. .) ..,J..." JUDICIAL DISTRICT N01'ICE OF APPEAL ~~ /, / /f/'./ V / ,A/ _, _ , DISTRICT JUSTICE JUDGMENT FROM COMMOttWEALTH OF PENNSYLVANIA ". COURT OF COMMON PLEAS .. COMMONPI.EASNo.:, 'I (. "j j :'~iJ~.rl--r;;~._ NOTICE OF APPEAL Notice is giYell that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. NAMf Of APPElLANT ELIlr~ ~ECO~IB'R_Y ~\lc/p"ROVI')Il'on p"\T:{ ] M~ Dl.Sr. NO. OR NAME Of OJ. . t'jQ-1-:11 STAn: Pl\ '10;)16 ZI' CODe cry ,'?, Gric~1.8S, Lf..P 1 S04 '-'Test 1\venue, .T-:::lk.intr),Fl,. IN THE CAse Of (Plam/iff) rli. b2 '?ecovery (Defendant) ClAIM NO. CV 17.'j-04 lT This block will be signed ONLY when this notation is required under Po. 10088. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case. ilG2M)4 Signature of Prothonotary or Deputy / ~) 1\ afJj lIant was CLAIMANT (see Pa. R.C.P.J.P. No. '--. 1001 (6) in action pefore District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing' his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO. FILE COMPLAINT j~ND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.JP. No. 1001 (7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee). PRAECIPE: To Prothonotary Enter rule upon (Common Pleas No. Name 01 appellee( s) , ; ) within tWenty (2<n ,days after sE!l'vite of rule or suffer entry of judgment of non pros. ,./ .,1~ ~,/,::' ?l, ... . " '., ..f'J.A;JI/1 . .. "f -{ V ' i""r t /' '. Signature 01 appellant or hIS attorney or agent , appellee(s), to file a complaint in this appeal RULE: To Name of appel/f3e( s) . appeIlee(s). (1) You are notified that a. rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail (2) If you do not file 0 complaint within this time, a JUDGMENT OF NON PROS Will EIE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of mailing. Date: Signature of Prothonotary or Deputy ~ " AOPC 312-90 COURT FILE .. ~IIIIIIII. ,'" ,,,_^Ut "" ... - ",i),_. PROOF OF SERVICE OF NOTICE APPEAL AND RULE TO FILE COMPLAINT (This proof 01 service MUST BE F.!.!::.,ED WITHIN TEN (1O) D::\ AFTEfi COMMONWEALTH OF PENNSYLVANIA 1.'18 nct;r;p f){ t;ppeB( {:;rt~?r'h 0opf:cabie boxes) COUNTY OF M:NIG:J>mY ."~__.'''_''.."''__.''".._'' ; sa AFFIDA VIT: I hereby swear or affirm that: served a copy thf; Notice of Common Picas No, (date of service) Decemper 2a, 2Q.Q.4_____ receipt altac[led hereto, and ;,pon December 2~2~04 by o and further that j served the Ru Ie to File a the Rule was addr(;ssed on_._~_.. mail, SOndlY'S receipt 110r810 04-6413 jos:gnaZe{i ;nGrein on by personal service ,The0Q9..!:.~._Gill,.".,. ., r-x flY (certifieo) (regJstered) mall, sender's .,.__,on servicA ~.!J by {certified) (rt'gislered) mall, sender,.; receipt attached hereto the abov0 Notice of Appeal on the appol1ee(s) to whom ~c~,~"j ~h~rt!d; AND SUBSCRIBED BEFORE ME December 2004 y OF ~ ' . nile of official 0 ~ ~ <= c:: c:::> c.n <- --4 --c.": C~_, ::e." nO'l' 3>"' n1p= /" % -Om ~ ; l :00 - .' w b6 ~~ ..', ::;1...", c:: '-- -0 ,.:) ::D -.,.~ ::1r. :"",(") <{::.'C' -'.- ,(1 >c t>? 9 ~ r:- ~ ,- ..- My commJsslDn fJxp1rcs on ,~____~^~^~>~_____ ..D IT' CJ .-"I U.S. Postal Service CERTIFIED MAILr' RECEIPT (Domestic Mail Only; No Insurance Coverag Provided) .:T CJ CJ r'- Poslage . ,. . U1 rn ..D .-"I U1 Certified Fee CJ CJ Retum RecIept Fee CJ (EndonIement RequInld) CJ Restricted DeIlvery Fee U1 (Endol'llement Requllecl) rn .-"I ru CJ .-"I .-"I U.S. Postal Service,,, CERTIFIED MAIL., RECEIPT (Domestic Mail Only; No Insurance Coverag Providedl U1 rn ..D .-"I Poslage $ U1 CeItilIedFee CJ CJ RllIUm Reciept Fee CJ (Endorsement ReqUll8d) r::J Restrlcled De!!verY Fee U1 (Endoreement ReqU\red) rn .-"I December 27, 2004 Hon. Charles A. Clement, Jr. District Court 09-1-01 400 Bridge Street Olde Towne Commons - Suite 3 New Cumberland, PA 17070 Mr. Theodore Gill 415 2nd Street New Cumberland, PA 17070 Re: Elite Recovery Svc/Providian Bank vs. Theodore Gill District Court 09-1-01 No. CV-478-04 Court of Common Pleas Cumberland County No. 04-6413 Dear Mr. Gill: On behalf of the plaintiff, Elite Recovery Svc/Providian Bank, enclosed please find a true and correct copy of a Notice of Appeal, the original of which was filed with the Court of Common Pleas of Cumberland County on November 22, 2004 in regard to the above matter. Please be guided accordingly. Respectfully, FRANCIS X. GRIMES FXG:kd Enclosure CERTIFIED MAIL, RRR THIS COMMUNICATION IS FROM A DEBT COLLECTOR, THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. December 27, 2004 Hon. Charles A, Clement, Jr. District Court 09-1-01 400 Bridge Street Olde Towne Commons - Suite 3 New Cumberland, PA 17070 Mr. Theodore Gill 415 200 Street New Cumberland, PA 17070 Re: Elite Recovery Svc/Providian Bank VB. Theodore Gill District Court 09-1-01 No. CV-478-04 Court of Common Pleas Cumberland County No. 04-6413 Dear Judge Clement: On behalf of the plaintiff, Elite Recovery Svc/Providian Bank, enclosed please find a true and correct copy of a Notice of Appeal, the original of which was filed with the Court of Common Pleas of Cumberland County on November 22, 2004 in regard to the above matter. Please be guided accordingly. Respectfully, FRANCIS X. GRIMES FXG:kd Enclosure CERTIFIED MAIL, RRR THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAII~ED WILL BE USED FOR THAT PURPOSE. . STOCK & GRIMES, LLP BY: Francis X. Grimes, Esquire I.D.#62404 804 West Avenue Jenkintown, PA 19046 (215) 576-1900 Attorney for Plaintiff ELITE RECOVERY SERVICES AS ASSIGNEE OF PROVIDIAN NATIONAL BANK c/o Stock & Grimes, LLP 804 West Avenue Jenkintown, PA 19046 COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW NO. 04-6413 Civil Term vs. THEODORE GILL 415 2ND Street New Cumberland, PA 17070 Defendant(s) CERTIFICATION OF SERVICE FRANCIS X. GRIMES, ESQUIRE, Attorney for the Plaintiff herein, certifies that on December 28, 2004 he mailed to the Defendant, Theodore Gill, a true and correct copy of the Civil Action Complaint filed herein, as per the attached letter, by posting the same with the United States Post Office, First :lass Mail, postage prepaid, to the Defendant at address lesignated in the attached \TE: / ~ CIS X. ESQUIRE -.L-- '0"1> e c'G>- c-o.$ > . $ 'G'(\>- .~'i>'2> ,-'2> "\.'2>,-'2> ""' " Ii\.'-v $"\J .. STOCK & GRIMES, LLP BY: Francis X. Grimes, I.D.#62404 804 West Avenue Jenkintown, PA 19046 (215) 576-1900 Attorney for Plaintiff Esquire ELITE RECOVERY SERVICES AS ASSIGNEE OF PROVIDIAN NATIONAL BANK c/o Stock & Grimes, LLP 804 West Avenue Jenkintown, PA 19046 Plaintiff vs. THEODORE GILL 415 2ND Street New Cumberland, PA 17070 Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW NO. 04-6413 Civil Term PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Enter Judgment by Default in favor of the Plaintiff, Elite Recovery Services As Assignee of Providian National Bank, and against the Defendant(s), Theodore Gill, for failure to Answer the Civil Action Complaint. Assess Plaintiff's damages in the sum of $4,183.79 in accordance with the prayer of th Complaint. DATE: / ESQUIRE . , . December 28, 2004 Mr. Theodore Gill 415 2~ Street New Cumberland, PA 17070 Re: Elite Recovery Services As Assignee of providian National Bank vs. Theodore Gill CCP Cumberland County No. 04-6413 Civil Term Dear Mr. Gill: Enclosed please find a true and correct copy of a Civil Action Complaint, the original of which was filed in regard to this case with the court on December 21, 2004. Please be guided accordingly. Sincerely, FRANCIS X. GRIMES FXG:kd Enclosure THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ~ .. STOCK & GRIMES, LLP BY: Francis X. Grimes, I.D.#62404 804 West Avenue Jenkintown, PA 19046 (215) 576-1900 Attorney for Plaintiff Esquire ELITE RECOVERY SERVICES AS ASSIGNEE OF PROVIDIAN NATIONAL BANK c/o Stock & Grimes, LLP 804 West Avenue Jenkintown, PA 19046 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW NO. 04-6413 Civil Term vs. THEODORE GILL 415 2ND Street New Cumberland, PA 17070 Defendant(s) PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY, Enter Judgment by Default in favor of the Plaintiff, Elite Recovery Services As Assignee of Providian National Bank, and against the Defendant(s), Theodore Gill, for failure to Answer the Civil Action Complaint. Assess Plaintiff's damages in the sum of $4,183.79 in accordance with the prayer of th DATE: /' ESQUIRE Complaint. AFFIDAVIT OF NON MILITARY SERVICE Francis X. Grimes, Esquire, being duly sworn according to law, deposes and says: (a) That the Defendant(s) is/are not in the Military or Naval Service ofthe United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; (b) That Defendant, Theodore Gill, is approximately 40 years of age, resides at 415 20d Street, New Cun1berland, P A 17070, and is self-employed. (c) That Defendant, , is approximately 40 years of age, resides at , and is a housewife. Affiant has ascertained the foregoing information by personal investigation and makes this Affidavit in due authority; and he understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904, relating to unsworn falsification to authorities. ELITE RECOVERY SERVICES AS ASSIGNEE OF PROVIDIAN NATIONAL BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW Plaintiff NO. 04-6413 vs. THEODORE GILL Defendant(s) CERTIFICATION UNDER PA. R.C.P. 237.1 FRANCIS X. GRIMES, ESQUIRE, Attorney for Plaintiff, Elite Recovery Services As Assignee of providian National Bank, certifies that he sent a copy of the attached Notice on January 6, 2005 by regular mail, to the Defendant(s) at the address at which the Defendant(s) was/were served with a copy of the Complaint by the First Class Mail as indicated by the Certificate of Service FRANCIS X. Attorney f r ~TEW . ELITE RECOVERY SERVICES AS ASSIGNEE OF PROVIDIAN NATIONAL BANK Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW vs. NO. 04-6413 Civil Term THEODORE GILL Defendant( s) TO: Theodore Gill 415 2nd Street New Cumberland, P A 17070 Date: January 26, 2005 IMPORTANT NOTICE YOU ARE IN DEF AUL T 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. 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. LAWYER REFERENCE SERVICES COURT ADMINISTRATOR-CUMBERLAND COUNTY COURTHOUSE 4TH FLOOR, ONE COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200_ _ ~ ~~~ FRANCIS X. GRIMES, ESQUIRE Attorney for Plaintiff 804 West Avenue Jenkintown, PA 19046 (215) 576-1900 ,--- . ~, ~~.....:,\~\,;;;:"". \. _...~ ~.,\~. ~h .. '" ." ,} .. ~ -bs 'C ?:::J ...0 '\\:. \l:- e> ~ () r-... ~ -J -'" M ,..' , r ~. ., ?r ----I !:: ~ I"~ +- ---L ,