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HomeMy WebLinkAbout14-1650 08 -7379 Civil Term 2014 HAR 21 P11 3. G 2 BARLEY SNYDER LLC P E I' f� S Y �, ���� �� i �, Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 Attorneys for Plaintiff (717) 299 -5201 Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES COURT OF COMMON PLEAS OF CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION — LAW V. R evival No. C � t N�' � JOSEPH D. CLUCK, udgment entered on July 23, 2009 ply l 7bl, f Defendant o. 08 -7379 Civil Term PRAECIPE FOR WRIT OF REVIVAL TO THE PROTHONOTARY: Issue a Writ of Revival of Judgment entered to 08 -7379 Civil Term and index it in the judgment index against Joseph D. Cluck in the amount of $14,199.67 plus costs of suit. G Is) BARLEY SNY � X33 , Sa � �-� By: haven Long, Esquire Court I.D. No. 83774 Attorneys for Plaintiff, Pennsylvania State 1 C) ' << Employees Credit Union (� 126 East King Street y y „�' Lancaster, PA 17602 -2893 (717) 299 -5201 V 14 p�� Su ✓tte , � C 4245428_1 � � L! &4 08 -7379 Civil Term BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 Attorneys for Plaintiff (717) 299 -5201 Pennsylvania State Em to ees Credit Union PENNSYLVANIA STATE EMPLOYEES COURT OF COMMON PLEAS OF CREDIT UNION, CUMBERLAND COUNTY, PENNSYLVIA Plaintiff CIVIL ACTION — LAW V. evival No. � d S o C 0 1 * 7 JOSEPH D. CLUCK udgment entered on July 23, 2009 Defendant N o. 08 -7379 Civil Term 1�►nd f�-dtl g " '- AA t &6- WRIT OF REVIVAL TO: Joseph D. Cluck 1 • You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the Judgment entered to 08 -7379 Civil Term. 2. The Plaintiff claims that the amount due and unpaid $14,199.67 plus costs of suit. 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. 42454281 08 -7379 Civil Term 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 / Prothonotary Dated: a �� (Depu ) $1 1 /6 1 42454281 SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Anderson ' `- Sheriff , T` E PROTG-?OH0l�!, i kxx,v of nor..ey Jody S Smith ° 2 1y APR 21 PM 3:',. 42 Chief Deputy Richard W Stewart • CUMBERLAND COUNTY Solicitor OF=3w..0 rw $ i = PENNSYLVANIA Pennsylvania State Employees Credit Union vs. Joseph D Cluck Case Number 2014 -1650 SHERIFF'S RETURN OF SERVICE 04/15/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Joseph D Cluck, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Revival as "Not Found" at 12 Chestnut Street, Mt. Holly Borough, Mt. Holly Springs, PA 17065. Per the current resident Ryan Colson he has lived here since December 2013 and does not know the defendant and per the Mt. Holly Springs Postmaster the defendant is not known at the address provided. SHERIFF COST: $35.91 SO ANSWERS, April 15, 2014 (c) CcuntySuite Sheriff: Teleosoftt, Inc RONR ANDERSON, SHERIFF BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 14 -1650 -Civil r 4� //ONO- 4'11 /O,,O.CUMDE4 RC, PENNSYLVANIA ENNS ��L Q N I Ail T.� Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, v. JOSEPH D. CLUCK, Plaintiff Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW Revival No. 14 -1650 -Civil Judgment entered on July 23, 2009 No. 08-7379 Civil Term PRAECIPE TO REISSUE WRIT OF REVIVAL TO THE PROTHONOTARY: Kindly reissue the Writ of Revival in the above matter. 4302081-1 BARLEY SNYDER Shawn Long, Esquire Keith Mooney, Esquire Court I.D. No. 83774, 74001 Attorneys for Plaintiff 126 East King Street Lancaster, PA 17602-2893 (717) 299-5201 aakt% (1.1Spci CAL* 383 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FiCE 1 HE PROTHONtO TAR't Hifi HAY 23 AM i3: 17 CUMBERLAND COUNTY PENNSYLVANIA OFFICE QFtH SkERIFF Pennsylvania State Employees Credit Union vs. Joseph D Cluck Case Number 2014-1650 SHERIFF'S RETURN OF SERVICE 05/16/2014 08:34 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Joseph D Cluck, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Revival as "Not Found" at 156 Stonehouse Road, Dickinson Township, Carlisle, PA 17015. Deputies were advised that the defendant never resided at this address, his brother did but moved out approximately five years ago. SHERIFF COST: $39.78 SO ANSWERS, May 19, 2014 RONNY R ANDERSON, SHERIFF (c) CountySulto Sheriff, Teleosoft. Inc. BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 14 -1650 -Civil H I'!'' 1: 22 CUMBERLAND COUNTY PENNSYLVANIA Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, v. JOSEPH D. CLUCK, Plaintiff Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW Revival No. 14 -1650 -Civil Judgment entered on July 23, 2009 No. 08-7379 Civil Term PRAECIPE TO REISSUE WRIT OF REVIVAL TO THE PROTHONOTARY: Kindly reissue the Writ of Revival in the above matter. BARLEY SNYDER Shawn Long, Esquire Keith Mooney, Esquire Court I.D. No. 83774, 74001 Attorneys for Plaintiff 126 East King Street Lancaster, PA 17602-2893 (717) 299-5201 4302081-1 C#y37gi° PM -3°892-7 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FILED- 1C -L. (.IF THE PROTHON0s C 20111 JUL 31 10= 36 CUPSITYENNYVCOUNTY N A OFFICE OF THE SRERIFF Pennsylvania State Employees Credit Union vs. Joseph D Cluck Case Number 2014-1650 SHERIFF'S RETURN OF SERVICE 07/14/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Joseph D Cluck, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Writ of Revival according to law. 07/16/2014 02:05 PM - The requested Writ of Revival served by the Sheriff of Dauphin County upon Cheree Browning, Mother of defendant, who accepted for Joseph D Cluck, at 352 Lincoln Street, Steelton, PA 17113. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, July 21, 2014 RONNY R ANDERSON, SHERIFF (c) C ountySuite Sheriff, Teleosoft. Inc. Shelley Ruhl Real Estate Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania County of Dauphin Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy PENNSYLVANIA STATE EMPLOYEES CREDIT UNION VS JOSEPH D. CLUCK Sheriffs Return No. 2014-T-2041 OTHER COUNTY NO. 2014-1650 And now: JULY 16, 2014 at 2:05:00 PM served the within REISSUED WRIT OF REVIVAL upon JOSEPH D. CLUCK by personally handing to CHEREE BROWNING * 1 true attested copy of the original REISSUED WRIT OF REVIVAL and making known to him/her the contents thereof at 352 LINCOLN STREET STEELTON PA 17113 * MOTHER OF DEFENDANT WHO ACCEPTED AS ADULT PERSON IN CHARGE Sworn and subscribed to before me this 17TH day of July, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, Sheriff of Dauphin County, Pa. Byt 7LZ 4 .. Deputy Sheriff Deputy: M SWEIGART Sheriffs Costs: $43.25 7/16/2014 > r BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 FILED -OFFICE THE PROTHONOTARsf. 2014 SEP -3 PM 12: 30 CUMBERLAND COUNTY PENNSYLVANIA Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, v. JOSEPH D. CLUCK, Plaintiff Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW Revival No. 14 -1650 -Civil Judgment entered on July 23, 2009 No. 08-7379 Civil Term PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff, Pennsylvania State Employees Credit Union and against Defendant, Joseph D. Cluck for want of an answer in the amount of $14,199.67 plus costs of suit. (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. () Pursuant to Pa. R.C.P. 237 (notice of praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. (X) Pursuant to Pa. R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to *110.5o P11\ 01438Lfoa 2,*.310545 rn (ed 4413499-1 his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. BARLEY SNYDER NOW, 4413499-1 By: 3vd Shawn M. Long, Esquire Keith Mooney Attorneys for Plaintiff Pennsylvania State Employees Credit Union Court I.D. No. 83774; 74001 126 East King Street Lancaster, PA 17602 (717) 299-5201 , 2014, JUDGMENT IS ENTERED AS ABOVE. Prothono y/CleCiv. vision By: BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, V. JOSEPH D. CLUCK, Plaint Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW Revival No. 14 -1650 -Civil Judgment entered on July 23, 2009 No. 08-7379 Civil Term AFFIDAVIT THAT THE DEFENDANT IS NOT IN THE MILITARY SERVICE, PURSUANT TO "SOLDIERS AND SAILORS" CIVIL RELIEF ACT OF 1918, RE-ENACTED 1940 The undersigned authority, Keith Mooney, Esquire, doth depose and say that Joseph D. Cluck, the Defendant is not in the Military or Naval Service, based on the following facts: Age of Defendant is unknown; Present place of employment is unknown; Present place of Residence is 352 Lincoln Street, Steelton, Pennsylvania 17113 as of the date of this affidavit. ADDITIONAL FACTS, if any. The statements set forth in this affidavit are made subject to the penalties of 18 Pa. C.S._ §4904, relating to unsworn falsification to authorities. Date: q/I4' By: 4413499-1 BARLEY SNYDER Shawn M. Long, Esquire Keith Mooney, Esquire Attorneys for Plaintiff BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 No. 14 -1650 -Civil Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, v. JOSEPH D. CLUCK, Plaintif Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW Revival No. 14 -1650 -Civil Judgment entered on July 23, 2009 No. 08-7379 Civil Term AFFIDAVIT OF SERVICE Kelly Neumann, Paralegal, doth depose and say that she served a true and correct copy of the 10 -Day Default Notice upon Joseph D. Cluck at 352 Lincoln Street, Steelton, Pennsylvania 17113 by first class mail on August 8, 2014 at 5:00 p.m. The statements set forth in this Affidavit are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. BARLE SNYDER Date: August 8, 2014 By: 4402654_1 . DOC X Kelly Neu , Paralegal 126 East Ki - Street Lancaster, PA 17602-2893 717.299.5201 BARLEY SNYDER LLC Shawn M. Long, Esquire Court I.D. No. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201 No. 14 -1650 -Civil Attorneys for Plaintiff Pennsylvania State Employees Credit Union PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, v. JOSEPH D. CLUCK, Plaintiff Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW Revival No. 14 -1650 -Civil Judgment entered on July 23, 2009 No. 08-7379 Civil Term To: Joseph D. Cluck Date of Notice: August 8, 2014 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. 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 A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 4402654_1.DOCX No. 14 -1650 -Civil 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 AVISO IMPORTANTE USTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARECENCIA ESCRITA POR SI MISMO 0 A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA USTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUVA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. 4402654_1.DOCX No. 14 -1650 -Civil SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 BARLEY SNYDER By: 4402654_1.DOCX Shawn M. Long, quire Attorneys for Pla'ntiff UNITED STATES Certificate Of POSTAL SERVICE. Mailin,c This Certificate of Mailing provides evidence that mail has been presented to USPS O for mailing, This (fop ma be used for domestic nd Mal mail. Fr°m: .< \i[ k r n itiro gcc,( iViJ nydor -7o_cia on r .1. -7 Dem 74qn_119-11(111-Png5