The URL can be used to link to this page

Home My WebLink About13-4031 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, DOCKET NO. (3 - J4031 Civt ( lTev i Plaintiff V. CONFESSION OF JUDGMENT SUNIL KHANNA and NEERU KHANNA, Defendants PREVIOUSLY ASSIGNED TO: N/A -a3 JUDGE M. L. EBERT, JR rte - cn r A C' PRAECIPE FOR WRIT OF REVIVAL MC) R l To the Prothonotary: ° Please issue writ of revival of lien of judgment entered at the Cumberland County Court of Common Pleas at case no. 08 -4409 and enter it in the judgment index against Sunil Khanna and Neeru Khanna, 15 Genoa Lane, Shavertown, PA, 18708 -9608, Defendants, in the amount of $383,164.21 with interest from July 14, 2008. Respectfully submitted, McNees Wallace & Nurick LLC Date: July 12, 2013 By: eoffr AW Shu , Esquire eme Cou ID #24848 100 Pine Str et, PO Box 1166 $3 PO A - re Harrisburg, A 17108 -1166 (71.7) 237 -5439 Attorneys for Plaintiff ( j .O (> p0 Ai 9-0-5 bue O & aa(foo?D 1? a931aa Wr1 +4 d COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, : DOCKET NO. 3 — t3 I iv� lT Plaintiff V. CONFESSION OF JUDGMENT SUNIL K14ANNA and NEERU KHANNA, Defendants PREVIOUSLY ASSIGNED TO: N/A - f JUDGE M. L. EBERT, JR � cu � -- -r, a: :Z,y r--- r-. --0 f" i WRIT OF REVIVAL TO: Sunil Khanna and Neeru Khanna, Defendants p 15 Genoa Lane - Shavertown, PA 18708 -9608 C. '`;' (1) You are notified that the plaintiff has commenced a proceeding to revive the lien of the judgment entered at the Cumberland County Court of Common Pleas at case no. 08 -4409. (2) The plaintiff claims that the amount due and unpaid is $383,164.21 with interest from July 14, 2008. (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 LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. - *(n( .op PA /iTy CUMBERLAND COUNTY BAR ASSOCIATION 01.015 UU Co 32 South Bedford Street Carlisle, PA 17013 (717) 249 -3166 or (800) 990 -9108 Date: July, 2013 Pro o ry SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ti Sheriff � ;t i � ,'�' li �,e a�ct`+��' l5t t"_ararrtr��f� � 1 SIC. " Chief Deputy Richard W Stewart Solicitor QM CE w PNC Bank National Association vs. Case Number Sunil Khanna (et al.) 2013-4031 SHERIFF'S RETURN OF SERVICE 07/16/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Sunil Khanna, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Luzerne, Pennsylvania to serve the within Writ of Revival according to law. 07/16/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Neeru Khanna, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Luzerne, Pennsylvania to serve the within Writ of Revival according to law. 08/05/2013 02:12 PM -The requested Writ of Revival served by the Sheriff of Luzerne County upon Sunil Khanna, Wife, who accepted for Neeru Khanna, at 15 Genoa Lane, Shavertown, PA 18708-9608. John Gilligan, Sheriff, Return of Service attached to and made part of the within record. 08/05/2013 02:12 PM-The requested Writ of Revival served by the Sheriff of Luzerne County upon Sunil Khanna, personally, at 15 Genoa Lane, Shavertown, PA 18708-9608. John Gilligan, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $53.00 SO ANSWERS, 4Z� August 13, 2013 RbNW R ANDERSON, SHERIFF (C)CounlySuite Sheriff,Teleosott.Inc. TDD (570) 825-1860 FAX: (570) 825-1849 Luzerne County Sheriffs Department Luzerne County Courthouse 200 North River Street Wilkes-Barre, Pennsylvania 18711 (570) 825-1651 CUMBERLAND COUNTY 13-4031 PNC BANK VS STATE OF PENNSYLVANIA SUNIL KHANNA,ETUX LUZERNE COUNTY, SS: JIM JOYCE , DEPUTY SHERIFF, for SHERIFF of said county, being duly sworn according to law, deposes and says, that on MONDAY the 5TH day of AUGUST 2013. at 2:12 PM , prevailing time, he served the within WRIT OF REVIAL upon NEERU KHANNA the within named, by handing to SUNIL KHANNA an adult member of the household, whose relationship to the within named is that of HIS WIFE at 15 GENOA LAND,SHAVERTOWN in the County of Luzerne, State of Pennsylvania, a true and attested copy and making known the contents thereof. Sworn to and subscribed before me this day 20 Sheriff of Luzern ounty N M*r pENt4SyLVANIA by NOTARIAL SEAM Depu' eri zerne County, Pennsylvania pATRICIA E.BENZI,Noe Co ntY PU Kingston ewo.,L� r 24,2013 Cpm,niasion Expires Dece TDD (570) 825-1860 FAX: (570) 825-1849 Luzerne County Sheriffs Department Luzerne County Courthouse 200 North River Street Wilkes-Barre, Pennsylvania 18711 (570) 825-1651 CUMBERLAND COUNTY 13-4031 PNC BANK VS SUN1L KHANNA,ET UX STATE OF PENNSYLVANIA LUZERNE COUNTY SS: JIM JOYCE , DEPUTY SHERIFF, for SHERIFF of said county, being duly sworn according to law, deposes and says, that on MONDAY the 5TH day of AUGUST 20 13 at 2:12 P. M., prevailing time, he served the within WRIT OF REVIAL upon SUNIL KHANNA the within named, by handing to HER personally, at 15 GENOA LAND,SHAVERTOWN in the County of Luzerne, State of Pennsylvania, a true and attested copy and making known the contents thereof. Sworn to and subscribed before me QiO Sheriff of Luzerne County this of 20-& Notary coN+ � -7 F NOTA LS AL; by PATR)CIA E.BENZI.Notary�Udl Kingston Wo..Luzeme County Deputy S o County, Pennsylvania Como w Elms peremher 24,2011_ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, : DOCKET NO. 13 -4031 Plaintiff v. : CONFESSION OF JUDGMENT SUNIL KHANNA and NEERU Defendants A, : : PREVIOUSLY ASSIGNED TO: N/A : JUDGE M. L. EBERT, JR PRAECIPE FOR ENTRY OF JUDGMENT OF REVIVAL BY DEFAULT TO THE PROTHONOTARY: Please enter judgment in the captioned action in favor of Plaintiff, PNC Bank, National Association, and against Defendants, Sunil Khanna and Neeru Khanna, in the amount of $383,164.21 with interest from July 14, 2008, through the date of payment, including on and after the date of entry of judgment, plus costs. Judgment is entered pursuant to Pa.R.C.P. No. 1037(b) for failure to file a pleading to Plaintiffs Writ of Revival which contained a notice to defend within twenty (20) days of service thereof, and after 10 -day Notices of intention to file this Praecipe were sent. Pursuant to Pa.R.C.P. No. 237.1, I hereby certify that Notices of intent to take a default judgment were forwarded to Sunil Khanna and Neeru Khanna, by United States Mail, first class, postage prepaid, on March 19, 2014. The aforesaid Notices were contained within an envelope bearing the return address of the undersigned. Neither of the Notices has been returned to the undersigned as undeliverable or otherwise. Copies of the Notices and Postal Forms 3817 are attached hereto and marked Exhibits "A" and `B ", respectively. Respectfully submitted, McNees Wallace & Nurick LLC Date: April , 2014 By: Go S uff, Esquire S e eC urt ID #24848 100 Pine treet, PO Box 1166 Harrisburg, PA 17108-1166 (717) 237-5439 Attorneys for Plaintiff, PNC Bank, National Association EXHIBIT A COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, : DOCKET NO. 13-4031 Plaintiff : CONFESSION OF JUDGMENT SUNIL KHANNA and NEERU KHANNA, : Defendants : PREVIOUSLY ASSIGNED TO: N/A : JUDGE M. L. EBERT, JR IMPORTANT NOTICE TO: Sunil Khanna Neeru Khanna 15 Genoa Lane 15 Genoa Lane Shavertown, PA 18708 -9608 Shavertown, PA 18708 -9608 Date of Notice: March 19, 2014 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249 -3166 or (800) 990 -9108 Respectfully submitted, McNees Wallace & Nurick LLC By: G :ffre hu squire S e Court #24848 100 Pine Street, PO Box 1166 Harrisburg, PA 17108 -1166 (717) 237 -5439 Attorneys for Plaintiff EXHIBIT B UNITED STATES �c' MIN POSTAL SERVICE. Certificate Of_ Mailing T - for marling: F McNees Wallace & Nurick LLC 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108 -1166 To Nee.vv I.i YWh f it Getn or. Lay.;e. ��` SWAv y wv), PA Ik31UR -'l (vJ PS Form 3817, April 2007 PSN 7530 -02- 000 -9065 UNITED STATES 1" MEI POSTAL SERVICE • 7° Certificate Thi! Tilt! Fro McNees Wallace & Nurick LL 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108 -1166 1C Gevvbct Lcvv-. Since -ev�ev„v. , PA ►81 - t t0G $ To PS Form 3817, April 2007 PSN 7530 -02- 000 -9065 4 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, : DOCKET NO. 13 -4031 Plaintiff v. : CONFESSION OF JUDGMENT SUNIL KHANNA and NEERU KHANNA, : Defendants : PREVIOUSLY ASSIGNED TO: N/A : JUDGE M. L. EBERT, JR NOTICE OF JUDGMENT TO: Sunil Khanna 15 Genoa Lane Shavertown, PA 18708 -9608 Neeru Khanna 15 Genoa Lane Shavertown, PA 18708 -9608 You are hereby notified that on April 1, 2014, the following judgment has been entered against you in the captioned case: Judgment in favor of Plaintiff, PNC Bank, National Association, and against Defendants, Sunil Khanna and Neeru Khanna, in the amount of $383,164.21 with interest from July 14, 2008, through the date of payment, including on and after the date of entry of judgment, plus costs. Judgment is entered pursuant to Pa.R.C.P. No. 1037(b) for failure to file a pleading to Plaintiffs Writ of Revival which contained a notice to defend within twenty (20) days of service thereof, and after 10 -day Notices of intention to file the Praecipe for En of Judgment of Revival by Default in this action were sent. Dated: 17 I y Prothonotary I hereby certify that the proper persons to receive this notice under Pa.R.C.P. No. 236 are: Sunil Khanna 15 Genoa Lane Shavertown, PA 18708 -9608 Neeru Khanna 15 Genoa Lane Shavertown, PA 18708 -9608 A Sunil Khanna 15 Genoa Lane Shavertown, PA 18708 -9608 Neeru Khanna 15 Genoa Lane Shavertown, PA 18708 -9608 Por este medio se le esta notificando que el de del 2014, el /la siguiente (Orden), (Decreto), (Fallo), ha sido anotado en contra suya en el caso mencionado en el epigrafe. Fecha: Protonotario Certifico que la siguiente direccion as la del defendido /a segun indicada en el certificado de residencia: Sunil Khanna Neeru Khanna 15 Genoa Lane 15 Genoa Lane Shavertown, PA 18708 -9608 Shavertown, PA 18708 -9608 Respectfully submitted, McNees Wallace & Nurick LLC Date: April V , 2014 By: . Shuff, Esquire Sheme Court ID #24848 100 Pine Street, PO Box .1166 Harrisburg, PA 17108 -1166 (717) 237 -5439 Attorneys for Plaintiff, PNC Bank, National Association COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, : DOCKET NO. 13 -4031 Plaintiff v. SUNIL KHANNA and NEERU KHANNA, Defendants : CONFESSION OF JUDGMENT • : PREVIOUSLY ASSIGNED TO: : JUDGE M. L. EBERT, JR N/A AFFIDAVIT OF NON - MILITARY SERVICE TO THE PROTHONOTARY: I do certify, to the best of my knowledge, that Defendants in the above - captioned action, Sunil Khanna and Neeru Khanna, are not presently on active or nonactive military status. Date: April % , 2014 Respectfully submitted, McNees Wallace & Nurick LLC By: of ff, Esquire upreme • urt ID #24848 100 Pinetreet, PO Box 1166 Harrisburg, PA 17108 -1166 (717) 237 -5439 Attorneys for Plaintiff, PNC Bank, National Association