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Home My WebLink About13-3868 J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA, PAUL VONSTEIN Civil No. 3 8815 Clearridge Road Everett, PA 15537 Plaintiff CARLA L. PETERSON, C/o LaShelle's Island Bar and Grill c 1582 Holly Pike Carlisle, PA 17013 Defendant Civil Action — Law PRAECIPE FOR ENTRY OF APPEARANCE, TRANSFER OF JUDGMENT, ASSESSMENT OF DAMAGES, AND VERIFICATIONS OF ADDRESS, VALIDITY AND NONMILITARY SERVICE TO THE PROTHONOTARY: Enter my appearance for the Plaintiff in the above - captioned matter, enter judgment in favor of Plaintiff against Defendant on the duly authenticated copy of the judgment contained in the docket entry hereto attached, entered in the jurisdiction noted therein, and assess damages as follows: Amount Due: $39,800.00 Interest (from 11/25/2009):. $ 1,222.12 TOTAL (to 8/25/2012): $41,022.12 PLUS COSTS Pursuant to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, I verify that: 1. The precise last known addresses of the Plaintiffs and Defendants are as listed above; Q�� * 3.3 da (21. I (44 1 S Cvat;c� c�.le� 2. 'Said judgment was entered in the said jurisdiction in the said amount with costs and interest due as noted, no part of which has been paid (except as noted) and that are valid, enforceable and unsatisfied; 3. Defendant is over 18 years of age and not in the military service of the United States or it allies or otherwise within coverage of the Soldiers and Sailors Relief Act of 1940, as amended and has civilian occupation. Keith E. Kendall, Esq. Attorney for Plaintiff Attorney ID No. 42910 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 THIS DAY OF , JUDGMENT IS ENTERED IN FAVOR OF PLAINTIFF AND AGAINST DEFENDANT[S] BY DEFAULT FOR WANT OF AN ANSWER AND DAMAGES ASSESSED AT THE SUM OF $ 4 1 6 5:a, OAS PER THE ABOVE C TIFICATION. NOTICE GIV P?,UATI TO PA. .P. 236. PROTHOI ARY By: Deputy Prothonotary Keith E. Kendall, Esq. ID No. tr� '14 TA PA Attorney 42910 ;, ,.,i., C Ry SCARINGI & SC ARINGI, P.C. 0 t1.N T Y PA Attorneys for Plaintiff 1013 ,I 30 A ID 3 1_ 2000 Linglestown Road, Suite 106 Harrisburg, PA 171.10 UNDA L. BEARD (717) 657 -7770 PRO i HONOTA (717) 657 -7797 (1=-'AX) DEPW Y keith @scaringilaw, com IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA PAUL VONSTEIN, Civil No. 2012 -4825 8815 Clearridge Road Everett, PA 15537 Plaintiff VS. CA RT .A L. PETERSON, 2406 Somerset Road Chambersburg, PA 17202 Defendant Civil Action — Law PRAECIPE FOR ENTRY OF UDGMENT FOR WANT OF AN ANSWER ASSESSMENT OF DAMAGES VERIFICATION OF ADDRESS AND NONMILITARY SERVICE TO THE PROTHONOTARY: .Enter judgment for want of an answer for Plaintiff and against defendant above named and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $39,800.00 Interest $ 1,222.12 ` T01AL $41,022.12 13 - 1►onb #y rankl n' i uigt�'� +A Understanding that false statements made herein are subject to penalty under 18 Pa. C.S.A. 4904, Unswom Falsification to Authorities, I verify that: 1. The above are the precise last known addresses of the parties; 2. The attached notice of intention to file Praecipe was mailed to all parties defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this Praecipe; 3. The said defendant is not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Relief Act and is over 18 years of age; and 4. Proof of Service of the Complaint — by Sheriff's Service -with Notice to Defend, is attached hereto. Keith E. Kendall, Esq. Attorney for Plaintiff Attorney ID No. 42910 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 THIS DAY OF 2-DL3 , J UDGMENT IS ENTERED IN FAVOR OF PLAINTIFF AND AGAINST DEFENDANT[S] BY DEFAULT FOR WANT OF AN ANSWER. AND DAMAGES ASSESSED AT THE SUFI OF s '41 bn12 PER THE ABOVE CERTIFICA'T'ION. NO'T'ICE GIVEN PURSUANT TO PA.R.C.P. 236. PROTHONOTARY Bv: . ro notary 4DCPU y SHERIFF °S RETURN - REGULAR CASE NO: 2012 -04825 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FRANKLIN PAUL VONSTEIN VS CARLA PETERSON DEPUTY BRIAN CRAMER Deputy Sheriff of FRANKLIN County, Pennsylvania, who being duly sworn according to law, says, the within COMP CIVIL ACTION was served upon PETERSON CARL L the DEFENDANT at 0014:16 Hour, on the 13th day of December 2012 at 2406 SOMERSET ROAD CHAMBERSBURG, PA 17202 by handing to CARLA PETERSON AT 2406 SOMERSET pn ruAMBERSBURG a true and attested copy of COMP CIVIL ACTION together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing .00 Service .00 DEPUTY AN CRAMER Affidavit 0 Surcharge .00 By .00 Deputy Sheriff 00 12/17/2012 SCARINGI & SCARINGI Sworn and Subscribed to before me this day of Notary I r IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA PAUL VONSTEIN, Civil No. Plaintiff of 2012 VS. CARLA L. PETERSON, , Defendant Civil Action - Law TO: CARLA L. PETERSON Date of Notice:jI IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCIs I ERSONALL,�c' OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINTST YOU. UNLESS YOU ACT WITHIN TI DAYS FROIt -I °rPIE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST.. YOU WITHOUT A HEARING A ND PROPERTY OR OTHER IMPORTANT' RIG YOU �'�LAY LOSE YOUR YOU SHOULD 'TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORM BELOW PROVIDE YOU WITH INFORI�IA'I'ION ABOUT HIRING A LAWYI�R N IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLFs TO PROVIDE YOU W ITH INFORMATJON ABOUT AGENCIES 'TI -IAT iM-AY OFFER LEGAL SERVICES TO ELIGIBLE,' PERSONS AT A REDUCED FEE OR NO TEE, Pennsylvania Bar Association Lawyer Referral Service Telephone: 1- 800 - 692 -7375 (PA ONLY) or 717 - 238 -6715 Certificate of Service I, Keith E. Kendall, Esq., attorney for the Plaintiff, Paul Vonst ' em, hereby certify that 1 have this date caused the foregoing Praecipe for Entry of judg ment to � be served upon the Defendant, Carla Peterson, by mailing a true and correct co of the Praecipe for Entry of Judgment to the Defendant, by first class U.S..Mail ' ,postage Prepaid, addressed as follows: Carla Peterson 2406 Somerset Road Chambersburg, P A, 17202 Date: Keith 1�. Kendall, Esq. Attorney for Plaintiff Cl C__ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL12WIA =C=v* CIVIL DIVISION co PRAECIPE FOR WRIT OF EXECUTION PAUL VONSTEIN ❑Confessed Judgment C-3 —4 sr Plaintiff Q Other Tt vs. File No. 2013 - 3868 7_4 CARLA L. PETERSON Amount Due $39,800.00 Defendant Interest $8,955.00 Address: 231 Mcarthur Court Carlisle,PA 17013 TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract,or account based on a confession of judgment,but if it does,it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County County,for debt,interest and costs,upon the following described property of the defendant(s) Any property,real or personal belonging to the Defendant,Carla L. Peterson, located at the residence at 231 Mcarthur Drive,Carlisle, PA, 17013,subject to applicable exemptions,as provided by law. PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County,for debt,interest and costs,as above,directing attachment against the above-named garnishee(s)for the following property (if real estate,supply six copies of the description;supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s). F,/1 (Indicate)Index this writ against the garnishee(s)as a lis penden,s nst I e th defendant(s)described in the attached exhibit. Date August 26, 2013 Signature: ith L 11 eith E. endall, Esq. Print Name. Address: 2000 Linglestown Road,Suite 106 ItIlA Asa Harrisburg, PA 17110 Attorney for- Paul Vonstein, Plaintiff Telephone: (717) 657-7770 Supreme Court 1D Na.. 42910 C 0/ 4CA WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 2013-3868 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PAUL VONSTEIN Plaintiff(s) From CARLA L.PETERSON,231 MCARTHUR COURT,CARLISLE,PA 17013 (1) You are directed to levy upon the property of the defendant(s)and to sell ANY PROPERTY,REAL OR PERONAL BELONGING TO THE DEFENDANT,CARLA L.PETERSON,LOCATED AT THE RESIDENCE AT 231 MCARTHUR COURT,CARLISLE,PA 17013,SUBJECT TO APPLICABLE EXEMPTIONS,AS PROVIDED BY LAW. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEES)as follows: and to notify the garnishees)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$39,800.00 Plaintiff Paid$ Interest$8,955.00 �- Attorney's Comm. % Law Library$.50 Attorney Paid$62.00 Due Prothonotary$2.25 Other Costs$ Date:AUGUST 28, 2013 David D.Buell,Prothonotary By: Deputy REQUESTING PARTY: Name : KEITH E.KENDALL,ESQUIRE Address:2000 LINGLESTOWN ROAD,SUITE 106 HARRISBURG,PA 17110 Attorney for:PLAINTIFF Telephone: 717-657-7770 Supreme Court ID No. 42910 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY � ~°hIlth�^ OFFICE OF THE SHERIFF THp-i-RO-HONOb`i. ^8|: APR �� PM �`�( .."." .` ... �'`. CUHQER|ANJCOUN-y PENNSYLVANIA Pou|Vonnhan vs. Carla LPeterson Case Number 2013-3868 SHERIFF'S RETURN OF SERVICE 09/12/2013 06:40 PM - Sen deputies out to address provided of 231 MacArthur Drive, Carlisle, PA 17013. There is no 200 biock of MacArthur Drive only a7UUblock. Advised attorneys office of such. They are attempting to obtain a new address for defendant. 09/25/2013 07:02 PM - Jamie DiMartle, Deputy , being duly sworn according to law, states that on September 25, 2013 at 7:02 PM hours, served the requested Writ of Execution and Claim for Exemption Form by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Carla L Peterson at 731 MacArthur Drive, Middlesex Township, Carlisle, PA 17013, informed Defendant of contents of same and levied upon personal property as directed. Postcard and copy of levy mailed to attorney and Ietter mailed to defendant on September 26, 2013. 04/14/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: *77J3 SO ANSWERS, April 14.2014 RONmYR ANDERSON, SHERIFF 2^��- fid 61-4i