HomeMy WebLinkAbout04-6509GREGORY R. HESS, and : IN THE COURT OF COMMON PLEAS OF
TOINETTE L. HESS, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
CIVIL ACTION-LAW
V.
NO. 00-1587
H. DANIEL BEIGH, III, and SOP ??
ONEIDA H. BEIGH,
Defendants 1
PRAECIPE FOR WRIT OF REVIVAL
TO THE PROTHONOTARY:
Issue writ of revival of judgment entered in this Court at No. 00-1587 and index it in the
judgment index against H. Daniel Beigh, III, and Oneida H. Beigh, Defendants, in the amount of
$64, 53 7.50, with interest at 12.5% per annum, compounded monthly, from March 17, 2000.
Dated: 1 ZJz?/?Lf
Of Counsel
Respectfully submitted,
Beckley & Madden /?1??9vr2ti+a U , "`lrez-c /ly
212 North Third Street Thomas A. Beckley
P.O. Box 11998
Harrisburg, PA 17108
(717) 233-7691
V?JG.c
Attorneys for Plaintiffs
7 (-?
^
? ? -ice
n
Q
N
C.n
BECKLEY& MADDEN
ATTORNEYS AT 1,Aw
CaeNSa 0o
818 NORT Tr STaa
r TOF87OSH0X119
HARRISBURG, PENNSYLVANIA 17108-1998
P 0NS:17 171 099-7601
FAX: 17171'233?--3740
F M uua,wy@p6.m
December 27, 2004
Curtis R. Long, Prothonotary
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Re: Hess v. Beigh. No. 00-1587
Dear Mr. Long:
F NO.
34802
Enclosed for filing is a praecipe for writ of revival. We are also enclosing a check in the
amount of your filing fee, of $20.00.
I understand that your office will prepare the writ and forward it to your Sheriff for
service upon the Defendants. To that end, we are also enclosing a check in the amount of
$100.00, payable to your Sheriff, for this service. The last-known addresses for the Defendants
are as follows:
H. Daniel Beigh, III
2300 Foxfire Circle
Upper Allen Township, PA 17055
i ?2 ecL,?,.>resbunc?
Oneida H. Beigh
304 Mary Street, Unit #95
Harrisburg, PA 17104
Thank you.
Very truly yours,
BECKLEY & MADDEN ' L_??
John G. Milakovic
Cc: Mr. Gregory R. Hess
GREGORY R. HESS AND IN THE COURT OF COMMON PLEAS OF
TOINETTE L. HESS
VS. CUMBERLAND COUNTY, PENNSYLVANIA
H. DANTZEL BEIGH, III CIVIL ACTION - LAW
2300 FOXFIRE CIRCLE
MECHANICSBURG, PA 17055
and N0. 04-6509 CIVIL TERM
ONEIDA H. BEIGH
304 MARY STREET, UNIT #95
HARRISBURG, PA 17104 WRIT OF REVIVAL
TO H. DANIEL BEIGH, III AND ONEIDA H. BEIGH
You are notified that the Plaintiff has commenced a proceeding to
revive and continue the lien of the judgment entered to
NO. 00-1587 CIVIL TERM
The Plaintiff claims that the amount due and unpaid is $ 64,537.50
with interest from MARCH 17, 2000 with interest at 12.5% per annum. compounded monthly.
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 will be entered.
Costs $ 65.94 PD ATTY
1.00 CO.
Curtis R. Long
PROTHONOTARY
Date DECEMBER 28, 2004
Seal
THOMAS A. BECKLEY, ESO. AND JOHN G. MITAKOVIC, ESQ.
Attorney for the Plaintiff
BECKLEY F. MADDEN
212 NORTH THIRD STREET
P.O.BOX 11998
HARRISBURG, PA 17108
717-233-7691
GREGORY R, HESS, and
TOfNETTE L. HESS,
Plaintiffs
V.
H. DANIEL BEIGH, III, and
ONEIDA H. BEIGH,
Defendants
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
NO. 04-6509 Civil
PRAECIPE
Please reissue the writ of revival in the above-captioned matter.
Dated: March 3, 2005
Respectfully submitted,
Of Counsel
Beckley & Madden (?`2?
212 North Third Street Thomas A. Beckley
P.O. Box 11998
Harrisburg, PA 17108
(717) 233-7691
I n G. Milakovic
Attorneys for Plaintiffs
h.j
C.'1 ? ?.i
?'
;il
?.. .I ,?
(?:
V\?
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2004-06509 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HESS GREGORY R ET AL
VS
BEIGH H DANIEL III ET AL
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
BEIGH ONEIDA H
but was unable to locate Her
deputized the sheriff of DAUPHIN
in his bailiwick. He therefore
serve the within WRIT OF REVIVAL
County, Pennsylvania, to
On January 24th , 2005 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing 6.00
Out of County 9.00
Surcharge 10.00
Dep Dauphin County 26.25
nn
01/24/2005
BECKLEY & MADDEN
So answer
R. Thomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
this J j, day of
fro.; A.D.
Prothonotary
CASE NO: 2004-06509 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HESS GREGORY R ET AL
VS
BEIGH H DANIEL III ET AL
ROBERT BITNER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF REVIVAL was served upon
BEIGH H DANIEL III
DEFENDANT
the
at 1250:00 HOURS, on the 6th day of January , 2005
at 2300 FOXFIRE CIRCLE
MECHANICSBURG, PA 17055 by handing to
DANIEL BEIGH III
a true and attested copy of WRIT OF REVIVAL together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 8.14
Affidavit .00
Surcharge 10.00
.00
36.14
Sworn and Subscribed to before
me this day of
7 21LLS A.D.
w., e ? n 2 Le?
Prothonotary
So Answers:
R. Thomas Kline
01/24/2005
BECKLEY & MADDEN
By:
Deputy Sheri f
In The Court of Common Pleas of Cumberland County, Pennsylvania
Gregory R. Hess et al
vs.
H. Daniel Beigh III et al _ 04-6509 civil
SERVE: Oneida H. Beigh No.
Now, DerEinber 30. 004 I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Dauphin
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
within
upon
at
20 , at o'clock M. served the
by handing to
a copy of the original
and made known to
So answers,
Sheriff of
COSTS
Sworn and subscribed before SERVICE
me this _ day of , 20 MILEAGE
AFFIDAVIT
the contents thereof.
County, PA
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 255-2660 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
County of Dauphin
HESS GREGORY R ETAL
vs
BEIGH ONEIDA H
Sheriff's Return
No. 0026-T - - -2005
OTHER COUNTY NO. 04 6509
J. Daniel Basile
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
I, Jack Lotwick, Sheriff of the County of Dauphin, State of
Pennsylvania, do hereby certify and return, that I made diligent
search and inquiry for BEIGH ONEIDA H
the DEFENDANT named in the within WRIT OF REVIVAL
and that I am unable to find him/her in the County of Dauphin, and
therefore return same NOT FOUND, January 19, 2005
AS PER OFFICE MANGER, DEFT MOVED SEPT OR AUG OF 2004
NO NEW ADDRESS
Sworn and subscribed to
before me this 19TH day of JANUARY, 2005
?tec/
NOTARIAL SEAL
MARY JANE SNYDER, Notary Public
Highspire, Dauphin County
My Commission Expires Sept 1, 2006
(p f fire ?f the,,ShPxtff
So Answers,
Sheriff of Dauphin County, Pa.
By
Deputy Sheriff
Sheriff's Costs:$26.25 PD 01/05/2005
RCPT NO 202848
GREGORY R. HESS AND IN THE COURT OF COMMON PLEAS OF
TOINETTE L. HESS
VS. CUMBERLAND COUNTY, PENNSYLVANIA
H. DANIEL BEIGH, III CIVIL ACTION - LAW
2300 FOXFIRE CIRCLE
MECHANICSBURG, PA 17055 _O 04-6509 CIVIL TERM
and
ONEIDA H. BEIGH
304 MARY STREET, UNIT #95
HARRISBURG, PA 17104 WRIT OF REVIVAL
TO H. DANIEL BEIGH III AND ONEIDA H. BEIGH
You are notified that the Plaintiff has commenced a proceeding to
revive and continue the lien of the judgment entered to
N0. 00-1587 CIVIL TER M
The Plaintiff claims that the amount due and unpaid is $ 64.537.50
with interest from MARCH 17, 2000 with interest at 12.5% Der annum compounded monthly.
You are required within twenty (20) days after service of this '.1rit
to file an answer or otherwise, plead to this Writ. If you fail to do
so, judgment of revival will be entered.
Costs $ 65.94 PD ATTY
1.00 CO.
Date DECEMBER 28, 2004
Seal
Curtis R. Long
PROTHONOTARY
THOMAS A. BECKLEY, ESO. AND JOHN G. MILAKOVIC, ESQ.
Attorney for the Plaintiff
_ BFrxr.JU & MADDEN
212 NORTH THIRD STREET
P.O.BOX 11998
HARRISBURG, PA 17108
717-233-7691
A.. TI-itJ
.. .. a n..c
4.8.
?Yf }
SHERIFF'S RETURN - REGULAR
CASE NO: 2004-06509 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HESS GREGORY R ET AL
VS
BEIGH H DANIEL III ET AL
CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according
says, the within WRIT OF REVIVAL was served upon
BEIGH ONEIDA H
DEFENDANT , at 2137:00 HOURS, on the 5th day of
at 31 WOODMYRE LANE
ENOLA, PA 170
ONEIDA BEIGH
by handing to
law,
e
it 2005
a true and attested copy of WRIT OF REVIVAL togetherl with
and at the same time directing Her attention to the contents
Sheriff's Costs:
Docketing
Service
Postage
Surcharge
So Answers:
18.00
r?
22.20
.37
10.00 R. Thomas Kline
.00
50.57 04/06/2005
BECKLEY & MADDEN _
Sworn and Subscribed to before By:
me this day of ? `alt4k
A.D.
Prothonota
y S
GREGORY R. HESS, and
TOINETTE L. HESS,
Plaintiffs
V.
H. DANIEL BEIGH, III, and
ONEIDA H. BEIGH,
Defendants
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
NO. 04-6509
PRAECIPE
Enter judgment in favor of Plaintiffs and against Defendants above-named, for failure of
Defendants to file an answer to the writ of revival within twenty (20) days after service thereof,
or otherwise to plead in response thereto. Assess Plaintiffs' damages as follows: In the principal
amount of $64,537.50, with interest at 12.5% per annum, compounded monthly, from March 17,
2000.
It is hereby certified that a notice of intention to file a praecipe for entry of a default
judgment was mailed to each Defendant at least ten days prior to the filing of this praecipe and
after default occurred.
Dated:
Of Counsel
Beckley & Madden
212 North Third Street
P.O. Box 11998
Harrisburg, PA 17108
(717) 233-7691
Respectfully submitted,
Thomas A. Beckley
ohn G. Milakovic
Attorneys for Plaintiffs
GREGORY R. HESS, and
TOINETTE L. HESS,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
V.
H. DANIEL BEIGH, III, and
ONEIDA H. BEIGH,
Defendants
NO. 04-6509
To: H. Daniel Beigh, III, 2300 Foxfire Circle, Upper Allen Township, PA 17055 (Defendant)
Date of Notice: January 27, 2005
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN 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 IMPORTANTRIGHTS.
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
JX G. Milakovic
Attorney for Plaintiff
GREGORY R. HESS, and
TOINETTE L. HESS,
Plaintiffs
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
V.
H. DANIEL BEIGH, III, and
ONEIDA H. BEIGH,
Defendants
NO. 04-6509
To: Oneida H. Beigh, 21 Woodmyre Lane, Enola, PA 17025 (Defendant)
Date of Notice: April 26, 2005
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN 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 IMPORTANTRIGHTS.
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
J G. Milakovic
Attorney for Plaintiffs
CERTIFICATE OF SERVICE
It is hereby certified that a copy of the foregoing document was this day served upon the
following persons in the manner below indicated.
FIRST CLASS MAIL
H. Daniel Beigh, III
2300 Foxfire Circle
Upper Allen Township, PA 17055
Oneida H. Beigh
31 Woodmyre Lane
Enola, PA 17025
Robert E. Chernicoff, Esquire
P.O. Box 60457
Harrisburg, PA 17106-0457
Dated: &/V/'s;-
Inn G. Milakovic
c") r? O
.? Q ' rl
(N? ? v,
?T i ??? r Z
(/? ? f t1 T
-J _? L
r ?
f
i1
C r
_ C 7
_?
CJ -?
(Release of Real Estate)
IN THE COURT OF COMMON PLEAS OF YORK COUNTY
GREGORY R. HESS and
TOINETTE L. HESS
VS.
H. DANIEL BEIGH and
ONEIDA H. BEIGH
No. 2004-6509
Principal Debt: $64,537.50
GREGORY R. HESS and TOINETTE L. HESS, the Plaintiffs in the above Judgment, for value received, hereby
releases from the lien, effect and operation of the above Judgment:
ALL that certain tract or parcel of land known as 21 Woodmyer Lane, Enola, PA 17025, situate in East Pennsboro
Township, Cumberland County, Pennsylvania, recorded in Book 264, Page 3757 and known as Parcel No. 09-12-2992-
181.
S-14-
WITNESS hand and seal, the (91 day of 2009.
WITNESS:
(00296986/1)
OF THE' PP'"I ,r yi Y
2009 AN 29 Pli 2' 22
?
t
woo pct h?
et* I*t 0
J
John G. Milakovic, Esquire
Attorney I.D. No. 34843
Beckley & Madden
212 North Third Street
Harrisburg, PA 17108
(717) 233-7691
GREGORY R. HESS, and
TOINETTE L. HESS
Plaintiff,
V.
H. DANIEL BEIGH, and
ONEIDA H. BEIGH,
Defendant
CIVIL ACTION - LAW
PRAECIPE FOR SATISFACTION OF JUDGMENT
TO THE PROTHONOTARY:
Please mark the lien of judgment in the above-captioned matter SATISFIED of record
and DISCONTINUE and END the above-captioned case.
Respectfully Submitted,
BECKLEY & MADDEN
Date: 12-4-011) By:
4GJZMilakovic, Esquire
Attorney I.D. No. 34843
212 North Third Street
Harrisburg, PA 17108
(717) 233-7691
Attorney for Plaintiff
0::* FILED-OFFICE
HE PROT,joj,r
2010 DEC 21 PM 1: 33
r'1 18EA1 LAJgo Cf?Ut4 v
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Docket No. 2004-6509
1
GREGORY R. HESS, and IN THE COURT OF COMMON PLEAS OF
TOINETTE L. HESS CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
V. Docket No. 2004-6509
H. DANIEL BEIGH, and : CIVIL ACTION - LAW
ONEIDA H. BEIGH,
Defendant
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing document was this day served upon the
following persons in the manner below indicated:
FIRST CLASS MAIL
H. Daniel Beigh, III
2300 Foxfnre Circle
Mechanicsburg, PA 17055
Oneida H. Beigh
31 Woodmyre Lane
Enola, PA 17025
Quintina M. Laudermilch, Esquire
Daley Zucker Meilton
Miner & Gingrich, LLC
1029 Scenery Drive
Harrisburg, PA 17109
Susan E. Good, Esquire
Smigel Anderson & Sacks, LLP
4431 North Front Street
Harrisburg, PA 17110
Date: /2-/2-0/0
Jo G. Milakovic, Esquire