Loading...
HomeMy WebLinkAbout13-6601 FLED 0. EICE David B. Dowling, Esquire CI' T' �E PROTii0iq{ - T ;"R V Attorney I.D. No. 25452 RHOADS & SINON LLP 2013 NOY —7 PM 2: 09 One South market Square, 12 Flr. CUMBERLAND COUNTY P.O. Box 1146 PENNSYLVANIA Harrisburg, PA 17108 -1146 Tele: (717)233 -5731 E: ddowling rhoads- sinon.com Attorneys for Plaintiffs CYNTHIA LIU and CHARLES R. RAUP, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs CIVIL ACTION — LAW V. NO. ROBERT SHEELY, Individually and d /b /a SECURE CONSTRUCTION SERVICES, JURY TRIAL DEMANDED Defendant PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Please Enter Judgment in favor of Plaintiffs, Cynthia Liu and Charles R. Raup and against Defendant Robert Sheely, Individually and d/b /a Secure Construction Services, in the amount of $11,690.00, pursuant to the Award of Arbitration dated August 15, 2013, awarding damages, costs, and interest in the amount of $11,690.00. (See the Certified Exemplified Record attached hereto as Exhibit "A" and incorporated herein by reference). RHOADS & SINON LLP y . ) avid B. Dowling One South Market Square, 12 Flr. P. O. Box 1146 Harrisburg, PA 17108 -1146 (717) 233 -5731 Date: November 5, 2013 Attorneys for Plaintiffs o^A 1633,Sopd a EXHIBIT "A" In TO Court of Common PCea.0 of Mau *n Countp, Vennoplbauia Cynthia Liu Charles R Raup No. 2011 -CV- 03899 -CV VS. Robert Sheely Secure Construction Services CERTIFICATION OF DOCKET ENTRIES AND JUDGMENT I, the undersigned Prothonotary of the Court of Common Pleas of Dauphin County, Pennsylvania, do hereby certify that the attached is a full, true and correct copy of the docket entries in the above captioned case. I further certify that judgment was entered in favor of Cynthia Liu & Charles R. Raup, and against Robert Sheely Individually and d/b /a Secure Contsruction Services on September 20, 2013 in said case in the amount of $11,690.00. In Tvaimonp Wbereof, I have hereunto set my hand and affixed the seal o t Court, on Tuesday, November 05, 2013. Prot on tary ' _ sy: Depu C ofALL F.£CEIYEI) OFFICE Or / David B. Dowling RO TH C "I O TA R Y Attorney I.D. No. 25452! S�P 20 VVV Rhoads & Sinon LLP Pit 34 54 One South Market Square, 12th F Ir. P.O. Box 1146 DAUPHIN COUNTY Harrisburg, PA 17108 - 1146 Telephone: (717) 233 -5731 PENNA Facsimile: (717) 238 -8622 E -Mail: ddowlin hoads -sino c m Attorneys for Plaintiffs CYNTHIA LIU and CHARLES R. RAUP, : IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA Plain ills CIVIL ACTION — LAW V. : NO. 2011 -CV -3899 ROBERT SHEELY, Individually and d/b /a SECURE CONSTRUCTION SERVICES, JURY TRIAL DEMANDED Defe dant RULE 236 NOTICE Pursuant to Pa.R.C. . 236, notice is hereby given that a judgment in the above - captioned matter has been entered a st g you. a / i Prothono If you have any questions c' ncerning the above, please contact: �\ C David B. Dowling One South Market Square, 1 Ir. P. O. Box 1146 Harrisburg, PA 17108 -1146 (717) 233 -5731 Attorneys for Plaintiffs Distribution List: David B. Dowling, Esq., Otte S. Market Square, P.O. Box 1146, Harrisburg, PA 17108 -1146 Robert Sheely, Individually and d/b /a Secure Construction Services, 5231 Simpson Ferry Road, Mechanicsburg) PA 17050 I hereby certify that the foregoing is a true and correct copy of a original 899171.1 filed. Piothunbi'my VW ' r I • I CERTIFICATE OF SERVICE I hereby certify that bn this AM day of September, 2013, a true and correct copy of the foregoing "Rule 236 Notill was served by means of United States mail, first class, postage prepaid, upon the following Robert Sheel, , Individually and d/b /a Secure onstruction Services 5231 Simpson Ferry Road Mechanicsbiurg, PA 17050 x0 >C� ,rrt W K CR GR i i I CYNTHIA LIU and CHAR ES R. RAUP, : IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA Plain 'ffs CIVIL ACTION —LAW V. : NO. 2011 -CV -3899 . ROBERT SHEELY, Individually and =' o d/b /a SECURE CONSTRU TION p, „ < SERVICES, JURY TRIAL DEMANDED W. Defendant ca i I ENTRY O F JUDGMENT AND NOW, this day of gp 2 0 . 2013, Judgment is hereby ntered in favor y of the Plaintiffs, Cynthia Li and Charles R. Raup, and against Defendant, Robert Sheely, I Individually and d/b /a Secure Construction Services in the amount of $ I I ProbQb)6f/V %4w 899162.1 �� ;r David B. Dowling PROTh ONO TA R Y Attorney I.D. No. 25452 Rhoads & Sinon LLP One South Market Square, 12'' F . P 20 PM 31' $$ P.O. Box 1 146 �a� Harrisburg, PA 17108 -1146 WN CUUN7 Telephone: (717) 233 - 5731 PNNq Facsimile: (717) 238 -8622 E -Mail: ddowling@rhoads-sinon,com Attorneys for Plaintiffs CYNTHIA LIU and CH LES R. RAUP, IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA Plain iffs CIVIL ACTION —LAW V. : NO. 2011 -CV -3899 ROBERT SHEELY, Individually and d/b /a SECURE CONSTRUCTION SERVICES, JURY TRIAL DEMANDED Defendant PRAECIPE FOR ENTRY OF JUDGMENT TO THE PROTHONOT . I Kindly Enter Judgm nt against Defendant, Robert Sheely, Individually and d/b /a Secure Construction Services, pursi mnt to the Award of Arbitration dated August 15, 2013 awarding damages, costs, and interest in the amount of $11,690.00. (A copy of the Award of Arbitrator is attached hereto as Exhibit "A" and incorporated herein by reference). OADS & S . N LL y. David B. owling One South Market Sq 4 r. P. O. Box 1146 Harrisburg, PA 17108 -1146 (717) 233 -5731 Date: September 20, 2013 Attorneys for Plaintiffs Exhibit A i I I 0 Pap1l3 Opp I CYNTHIA LIU and CHA LES R. RAUP IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA laintiff > VS. No. 2011 CV 3899 -CV ROBERT SHEELY, Individually and d /b /ar SECURE CONSTRUCTION "c r. Defendant N R ORT AND AWARD OF ARBITRATORS We the undersigne arbitrators, having been duly appointed and sworn (or ffirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) We find in favor of the plaintiff in the amount Ql 1,690.00. 4 1a4 dAlle M nnedy Claraval, Esquire W illia m Shrev E squire Tyro ne Pow I, E Ouire (if applicable) Arbitrator dissents. Date of Hearing: Augus 13, 2013 Date of Award: August 13, 2013 NOTICE OF ENTRY OF AWARD Now, the t�. day of A msf - , year I3 the a e award was entered upon the docket and no ' e thereof given by mail to the pa 'e or their attorneys. Arbitrators Compensation to be Daid on appeal: 1t�11V 4+ (MORE THAN) (NOT EXCEEDING) (APPEAL FEE) [ ] $0.00 $4,999.99 $400.00 Prothonotary [ ] $5,000.00 $9,999.99 $500.00 n [V]- $10,000.00 $19,999.99 $600.00 [ 1 $20,000.00 $34,999.99 $700.00 B [ ] $35,000.00 $50,000.00 $800.00 Deputy I DISTRIBUTION: David B. Dowling, Esqu re, 1 S MARKET SQUARE PO BOX 1146, HARRISBURG, PA 17108 Robert Sheely, 5231 Simpson Ferry Road, Mechanicsburg, PA 17050 • I i I I I CERTIFICATE OF SERVICE I hereby certify that on this AOM day of September, 2013, a true and correct copy of the "Entry of Judgment ", "Pr ipe for Entry of Judgment", "Rule 236 Notice ", "Certificate of Residence" and "Affidavit of Non - Military Service in Compliance with the Soldiers and Sailors Civil Relief Act of 1940" w, is served by means of United States mail, first class, postage prepaid, upon the following: Robert Sheel , Individually and d/b /a Secure onstruction Services 5231 Simpsoi Ferry Road Mechanicsburg, PA 17050 i David B. Dowling P R�T�fi.1 ` r Attorney I.D. No. 25452 r�, y Rhoads & Sinon LLP X13 SEP 20 FN , One South Market Square, 12th F r. ss P.O. Box 1146 `N Harrisburg, PA 17108 -1146 ou Nry Telephone: (717) 233 -5731 PEN1Yl4` Facsimile: (717) 238 -8622 E -Mail: ddowling @rhoads -sinon com i Attorneys for Plaintiffs CYNTHIA LIU and CHARLE S R. RAUP, IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA Plain ffs CIVIL ACTION —LAW V. NO. 2011 -CV -3899 ROBERT SHEELY, Individuz lly and d/b /a SECURE CONSTRUCTION SERVICES, JURY TRIAL DEMANDED Defendant AFFIDAVIT OF NON - MILITARY SERVICE IN COMPLIANCE WITH THE SOL1 IERS AND SAILORS CIVIL RELIEF ACT OF 1940 David B. Dowling, E quire, being duly sworn according to law, deposes and says that he is the attorney for the Plaintiffs in the above entitled case, that he makes this Affidavit pursuant to the provisions of Section 200 of tie Soldiers and Sailors Civil Relief Act of 1940; and that to the best of his knowledge, information, an belief the Defendant, Robert Sheely, Individually and d/b /a Secure Construction Services, is not in the Military Service of the Army of the United States, the United States Navy, the United States Air Force, the Marine Corps, the Coast Guard, or officers of the Public Health Service detailed by proper aut ority for duty either with the Army or the Navy. RHO DS & SON LLP By: N avid B. Dowling One South Market Square, Flr. P. O. Box 1146 Harrisburg, PA 17108 -1146 (717) 233 -5731 Attorneys for Plaintiffs Date: September 20, 2013 _ I CERTIFICATE OF SERVICE I hereby certify that or this Oz � RT day of September, 2013, a true and correct copy of the foregoing "Affidavit of Non-N ilitary Service in Compliance with the Soldiers and Sailors Civil Relief Act of 1940" was served by m s of United States mail, first class, postage prepaid, upon the following: Robert Sheely, Indivi ally and d/b /a Secure Construc ion Services 5231 Simpson Ferry Road Mechanicsburg, PA 1 050 IN THE COI JRT OF COMMON PLEAS OF LEBANON COUNTY COMMONWEALTH OF PENNSYLVANIA - CIVIL 'ca� h G � as %, JUDGMENT © •o thia Liu and Charles R. Raup, Plaintiffs VS. Robert Sheel v. Individually and d/b /a Secure Construction Services Defendant CERTIFICATE OF RESIDENCE OF JUDGMENT CREDITOR It is hereby certified that the precise residence address of the judgment creditor and defendant, in the above en itled judgment, is: Dfdt: Robert Sheely, Indi idually and Plff Cynthia Liu and Charles R. Raup d/b /a Secure Constiuction Services 111 Chadwick Circle 5231 Simpson Ferri Road Hummelstown, PA 17036 Mechanicsburg, PA 17050 Dated: � zgp L" ilL tA= A orney for Judgment Creditor/ reditor NOTICE OF THE ENTRY OF JUDGMENT AGAINST THE DEFENDANT WAS GIVEN BY ORDINARYMAII, TO THE DEFENDANT TOGETHER WITH A COPY OF ALL DOCUMENTS FILF D IN SUPPORT THEREOF. 899172.1 t� Date: 11/5/2013 Dauphin County User: AREDMOND Time: 11:19 AM Complete Case History Page 1 of 4 Case: 2011 -CV- 03899 -CV Cynthia Liu, etal. vs. Robert Sheely, etal. Filed: 4/15/2011 Subtype: Civil Physical File: Y Appealed: N Comment: Status History Pending 4/15/2011 Disposed 8/14/2013 Pending / Judgment 9/23/2013 Judge History Date Judge Reason for Removal 4/15/2011 No Judge, Current Payments Receipt Date Type Amount Rhoads & Sinon 285310 11/13/2012 Civil Filing 37.75 302925 9/20/2013 Civil Filing 23.25 Rhoads & Sinon LLP 251124 4/1512011 Civil Filing 145.50 Total 206.50 Plaintiff Name: Liu, Cynthia SSN: Address: DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Attorneys Dowling, David B (Primary attorney) Send Notices Plaintiff Name: Raup, Charles R SSN: Address: DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Attorneys Dowling, David B (Primary attorney) Send Notices c: Date: 11/5/2013 Dauphin County User: AREDMOND Time: 11:19 AM Complete Case History Page 2 of 4 Case: 2011-CV-03899-CV Cynthia Liu, etal. vs. Robert Sheely, etal. Defendant Name: Sheely, Robert SSN: Address: ' DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Attorneys PRO SE, (Primary attorney) Send Notices Defendant Name: Secure Construction Services SSN: Address: DOB: Sex: Phone: Home: Work: Employer: Send notices: Y Litigant Type: Comment: Attorneys PRO SE, (Primary attorney) Send Notices Register of Actions 4/15/2011 New Civil Case Filed This Date. No Judge, Filing: Writ of Summons Paid by: Rhoads No Judge, & Sinon LLP Receipt number: 0251124 Dated: 4/15/2011 Amount: $145.50 (Check) For: Liu, Cynthia (plaintiff) Plaintiff: Liu, Cynthia Attorney of Record: No Judge, David B Dowling Plaintiff: Raup, Charles R Attorney of No Judge, Record: David B Dowling Other Contract Praecipe for Writ of No Judge, Summons, filed. Writ of Summons Issued. AOPC MONTHLY CIVIL COURT STATISTICAL REPORT DATA 4/26/2011 Writ of Summons: Sheriff of Dauphin No Judge, County returns Not Found as to Defendant(s). So Answers, J. R. Lotwick, Sheriff. to Robert Sheely on 4/26/2011; Assigned to Dauphin Co Sheriffs Office. Service Fee of $0.00. Cumberland County Sheriffs Costs: $52.94 Writ of Summons: Sheriff of Dauphin No Judge, County returns Not Found as to Defendant(s). So Answers, J. R. Lotwick, Sheriff. to Secure Construction Services on 4/26/2011; Assigned to Dauphin Co Sheriffs Office. Service Fee of $0.00. Date: 11/5/2013 Dauphin County User: AREDMOND Time: 11:19 AM Complete Case History Page 3 of 4 Case: 2011-CV-03899-CV Cynthia Liu, etal. vs. Robert Sheely, etal. Register of Actions 4/29/2011 Writ of Summons: Sheriffs Return filed No Judge, stating service was completed. So answers J.R. Lotwick, Sheriff. to Robert Sheely on 4/29/2011; Assigned to Dauphin Co Sheriffs Office. Service Fee of $70.00. 7/13/2012 Complaint filed. No Judge, 8/23/2012 Letter of defense, filed. No Judge, Defendant: Sheely, Robert Attorney of No Judge, Record: PRO SE Defendant: Secure Construction Services No Judge, Attorney of Record: PRO SE 11/13/2012 Filing: Certificate of Readiness Paid by: No Judge, Rhoads & Sinon Receipt number: 0285310 Dated: 11/13/2012 Amount: $37.75 (Check) For: Liu, Cynthia (plaintiff) Certificate of Readiness to List for No Judge, Arbitration filed by counsel for Plaintiff(s). 11/14/2012 The Certificate of Readiness filed Clark, Lawrence F. Jr. November 13, 2012 will not be entertained since Box F was not checked relating to mediation pursuant to Dauphin County Local Rule 1001. Anew Certificate of Readiness must be filed when all of the requirements of the Certificate of Readiness have been met. The Certificate of Readiness form may be found on the Dauphin County website at www.dauphinc.org. See ORDER, filed. Copies dist. 11/14/2012. 6/25/2013 Certificate of Readiness to List for No Judge, Arbitration filed by counsel for plaintiff(s). 8/14/2013 June 25, 2013 Certificate of Readiness in No Judge, Arbitration filed. July 9, 2013 Case referred to Arbitration Board No. 2 Mary Ann Kennedy Claraval, Esquire (Chairperson) William Shreve, Esquire and Tyronne Powell, Esquire August 13, 2013 Case to be heard. August 13, 2013 Report and Award of Arbitrators: We find in favor of the plaintiff in the amount of $11,690.00. August 14, 2013 Report and Award Docketed and Copies thereof Mailed. AOPC MONTHLY CIVIL COURT STATISTICAL REPORT DATA 9/20/2013 Filing: Judgment Paid by: Rhoads & No Judge, Sinon Receipt number: 0302925 Dated: 9/20/2013 Amount: $23.25 (Check) For: Liu, Cynthia (plaintiff) Date: „ 11/5/2013 Dauphin County User: AREDMOND Time: 11:19 AM Complete Case History Page 4 of 4 Case: 2011 -CV- 03899 -CV Cynthia Liu, etal. vs. Robert Sheely, etal. Register of Actions 9/23/2013 Judgment is entered in favor of the No Judge, Plaintiff, and against the Defendant, Robert Sheely, Individually and d /b /a Secure Construction Services in the amount of $11,690.00 pursuant to the attached Award of Arbitrators entered on August 15, 2013. See Notice, Praecipe, filed. Copies of all documents mailed. Judgment Order date In Favor Of Disposition Judgment 08/14/2013 Plaintiff 08/14/2013 Open Arbitration Award Comment: 11690.00 Plaintiff: Liu, Cynthia Raup, Charles R Defendant: Secure Construction Services Sheely, Robert Judgment Order date In Favor Of Disposition Judgment 09/20/2013 Plaintiff 09/20/2013 Open Judgment Comment: 11690.00 Plaintiff: Liu, Cynthia Raup, Charles R Defendant: Secure Construction Services Sheely, R rt NOV 5 2013 I hereby certify that the for go CinaViled. true an re y f th or! Prothonota .i t • 4 1 '�,f1 pF�'f 1 t• ..