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Home My WebLink About13-4033 f COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, : DOCKET NO. f3 - �D33 �i ° - Jj 5 r Plaintiff V. CONFESSION OF JUDGMENT SNS BUDDIES, INC., DBA UNI -MART, Defendant PREVIOUSLY ASSIGNED rri cu JUDGE KEVIN A. HESS cn r— -- c-_ .. __ 1 PRAECIPE FOR WRIT OF REVIVAL 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 -4407 and enter it in the judgment index against SNS Buddies, Inc., dba Uni- Mart, 94 S Pennsylvania Avenue, Wilkes Barre, PA, 18701 -3403, Defendant, in the amount of $383,164.21 with interest from July 14, 2008. Respectfully submitted, McNees Wallace & Nurick LLC Date: July 12, 2013 By: /'; 9; '/ fupHarrisbur ffre , Esquire re o ID #24848 C ine S eet, PO Box 1166 , PA 17108 -1166 -*33. -co pp ATrY (717) 237 -5439 a? . 50 CBF Attorneys for Plaintiff � col. 00 Pb A $9•9,5 1) oe CO & 6L au 000 o ag31 0 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, DOCKET NO. 13 - 463 Plaintiff V. CONFESSION OF JUDGMENT SNS BUDDIES, INC., DBA UNI -MART, cw _ Defendant PREVIOUSLY ASSIGNED TO: C . JUDGE KEVIN A. HESS �X Y, <> cn ' r-- - I WRIT OF REVIVAL CD Z: (D :z TO: SNS Buddies, Inc., DBA Uni -Mart, Defendant 94 S Pennsylvania Avenue M: CO Wilkes Barre, PA 18701 -3403 (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 -4407. (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. W57s ' *& tO Pq ATH CUMBERLAND COUNTY BAR ASSOCIATION a.as 4UE CD 32 South Bedford Street Carlisle, PA 17013 (717) 249 -3166 or (800) 990 -9108 Date: July 15 , 2013 Prot o o ary SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff f'I=` f tip Jody S Smith r Chief Deputy C 13 AUG —7 PFD 3: 0 9 Richard W Stewart Solicitor s=k r w frw CUMBERLAND C0UNT Y PENNSYLVANIA PNC Bank National Association VS. Case Number SNS Buddies, Inc. d/b/a Uni-Mart 2013-4033 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: SNS Buddies, Inc. d/b/a Uni-Mart, 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. 07/31/2013 The requested Writ of Revival served by the Sheriff of Luzerne County upon Sunil Khanna, Owner, who accepted for SNS Buddies, Inc. d/b/a Uni-Mart, at 94 S. Pennsylvania Avenue,Wilkes-Barre, PA 18701-3403. John F. Gilligan, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, 6�� x Va--- Augu 05, 2013 RONW R ANDERSON, SHERIFF I (c)CcuntySuRo Sheriff,Teleosoft,Inc, rDD (570) 825-1860 FAX: (570) 825-1849 Luzerne County Sheriffs Department Luzerne County Courthouse Sheriff Jahn F. Gilligan [x• Yom_ Z. 200 North River Street Wilkes-Barre, Pennsylvania 18711 (570) 825-1651 CUMBERLAND COUNTY 13-4033 P.N.C.BANK VS SNS BUDDIES,INC.,ET AL STATE OF PENNSYLVANIA LUZERNE COUNTY, SS: GINO GURNAR.I , DEPUTY SHERIFF, for SHERIFF of said county, being duly sworn according to law, deposes and says, that on WEDNESDAY the 31ST day of JULY 20 13 at 9:52 A. M., prevailing time , he served the within WRIT OF REVIAL upon SNS BUDDIES,INC. the within named, by handing to SUNM KHANNA -OWNER the person for the time being in charge at THE PLACE OF BUSINESS 94 SOUTH PA AVENUE,WILKES-BARRE in the County of Luzeme, State of Pennsylvania, a true and attested copy and making known the contents thereof. Sworn to and subscribed before me this/Pl--day of 2015— Sheriff of Lu ne County Notary oM ►vvvCA"H.OF 'k Y. NOTAMAL SEAL PATRiCiA E.BENZI,No4"F�ltW by - tGngstcm Sao.,Lueme Got�nty Deputy Sheriff of Luzerne County, Pennsylvania MIr Comm, t E Dewtbw 24; 1 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, : DOCKET NO. 13 -4033 Plaintiff v. : CONFESSION OF JUDGMENT SNS BUDDIES, INC., DBA UNI -MART, . Defendant : PREVIOUSLY ASSIGNED TO: : JUDGE KEVIN A. HESS 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 Defendant, SNS Buddies, Inc., dba Uni -Mart, 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 Notice of intention to file this Praecipe was sent. Pursuant to Pa.R.C.P. No. 237.1, I hereby certify that a Notice of intent to take a default judgment was forwarded to SNS Buddies, Inc., dba Uni -Mart, by United States Mail, first class, postage prepaid, on March 19, 2014. The aforesaid Notice was contained within an envelope bearing the return address of the undersigned. The Notice has not been returned to the undersigned as undeliverable or otherwise. A copy of the Notice and Postal Forms 3817 are attached hereto and marked Exhibits "A" and `B ", respectively. 00.-1-16.567Y/ 161 CLIV 36(-1 aao MG X/J Mt/WA/ Date: April , 2014 Respectfully submitted, McNees Wallace & Nurick LLC By: G ffrey -S. S1fuff, Esquire the 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 -4033 Plaintiff CONFESSION OF JUDGMENT SNS BUDDIES, INC., DBA UNI- MART, Defendant : PREVIOUSLY ASSIGNED TO: : JUDGE KEVIN A. HESS IMPORTANT NOTICE TO: SNS Buddies, Inc., DBA Uni -Mart 94 S Pennsylvania Avenue Wilkes Barre, PA 18701 -3403 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 Date: March 19, 2014 By: Geo i ey uff, ' squire Supreme Court . #24848 100 Pine Street, PO Box 1166 Harrisburg, PA 17108 -1166 (717) 237 -5439 Attorneys for Plaintiff EXHIBIT B UNITED STATES Sr POSTAL SERVICE,'LJ This Corti This form From: McNees Wallace & Nurick L — 100 Pine Street — P.O. Box 1166 — Harrisburg, PA 17108 -1166 Certificate Of D>dAekieS FThC. ybQA V1n∎ -*V&A �1� S OfwAsytvi,A;ct. /rvev v.e. \NiIkQs awe , -PA is-10\ -3403 PS Farm 3817, April 2007 PSN 7530 -02- 0009065 0 • CO COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION PNC BANK, NATIONAL ASSOCIATION, : DOCKET NO. 13 -4033 Plaintiff v. : CONFESSION OF JUDGMENT SNS BUDDIES, INC., DBA UNI -MART, . Defendant : PREVIOUSLY ASSIGNED TO: : JUDGE KEVIN A. HESS NOTICE OF JUDGMENT TO: SNS Buddies, Inc., dba Uni -Mart 94 S Pennsylvania Avenue Wilkes Barre, PA 18701 -3403 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 Defendant, SNS Buddies, Inc., dba Uni -Mart, 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 Notice of intention to file the Praecipe for Entry of Judgment of Revival by Default in this action was sent. Dated: 1-1)q i 1 J. ' , Prothonotary I hereby certify that the proper person to receive this notice under Pa.R.C.P. No. 236 is: SNS Buddies, Inc., dba Uni -Mart 94 S Pennsylvania Avenue Wilkes Bane, PA 18701 -3403 A SNS Buddies, Inc., dba Uni -Mart 94 S Pennsylvania Avenue Wilkes Barre, PA 18701 -3403 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: SNS Buddies, Inc., dba Uni -Mart 94 S Pennsylvania Avenue Wilkes Barre, PA 18701 -3403 Respectfully submitted, McNees Wallace & Nurick LLC Date: April , 2014 By: Ge °ai?i►'' u , Esquire Supreme 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, 13-4033 Plaintiff v. : CONFESSION OF JUDGMENT SNS BUDDIES, INC., DBA UNI-MART, : Defendant : PREVIOUSLY ASSIGNED TO: : JUDGE KEVIN A. HESS AFFIDAVIT OF NON-MILITARY SERVICE TO THE PROTHONOTARY: I do certify, to the best of my knowledge, that Defendant in the above-captioned action, SNS Buddies, Inc., dba Uni-Mart, is not presently on active or nonactive military status. Respectfully submitted, McNees Wallace & Nurick LLC Date: April ,,, 2014 By: G offi-ey u , squire Su. e Court D #24848 100 Pine Street, PO Box 1166 Harrisburg, PA 17108-1166 (717) 237-5439 Attorneys for Plaintiff, PNC Bank, National Association