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HomeMy WebLinkAbout14-2188 BAYLEY & MANGAN 1 Mark F. Bayley, Esquire q r � , 17 West South Street P4 ' , ' 2 1 ) 10 Carlisle, PA 17013 (717) 241 -2446 ? L��'rdS YL��Ei�, Supreme Court I.D. #8766 TELKORE, INC. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 09 -2355 STEVEN DANNER and CIVIL ACTION -LAW DANA DANNER Defendants : PRAECIPE FOR WRIT OF REVIVAL To the Prothonotary: Issue writ of revival of lien of judgment entered at Civil Action Number 09 -2355 and enter it in the judgment index against Defendants, Steven Danner and Dana Danner, in the amount of $20,000.85 with costs and interest from May 27, 2009. Respectfully submitted, BAYLEY & MANGAN Mark F. Bayley Estfuire 17 West South Street Carlisle, PA 17013 (717) 241 -2446 pX XY0 Supreme Court I.D. #87663 s / y.0 D Attorney for Plaintiff 3(�y f, 3a��y� TELKORE, INC. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 09 -2355 STEVEN DANNER and CIVIL ACTION -LAW DANA DANNER : Defendants CERTIFICATE OF SERVICE 1, Mark F. Bayley, Esquire, do hereby certify that I this day served a copy of the foregoing document upon the following by First Class U.S. Mail: Steven Danner 9 Cromwell Court Mechanicsburg, PA 17050 Dana Danner 9 Cromwell Court Mechanicsburg, PA 17050 r. Mark F. Bayley, Es uire 17 West South Street Carlisle, PA 17013 (717) 241 -2446 Supreme Court I.D. #87663 TELKORE, INC. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 09 -2355 STEVEN DANNER and CIVIL ACTION -LAW DANA DANNER Defendants WRIT OF REVIVAL To Steven Danner and Dana Danner: I . You are notified that the plaintiff has commenced a proceeding to revive the lien of the judgment entered at Civil Action 09 -2355. 2. The plaintiff claims that the amount due and unpaid is $20,000.85 with costs and interest from May 27, 2009. 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717 - 249 -3166 Date: (Name of Prothonotary (Clerk)) C By (Depu ) SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~~. "~~"�"o . ~~ ~=. . "~°~~ ��" RgnnyR Anderson OF-'�� Sheriff UF THE PROTHONOTAR` u-`�z�� Jody SSmith �0Q&�#�� �� �:�' \ Chief Deputy �".,". " 28 . ./ � w� ' =p= Richard W Stewart ����~ CUMBERLAND HNTY Solicitor TRE. SHE,RIFF PENNSYLVANIA Telkore, Inc. vs. Steven Danner (et al.) Case Number 2014-2188 SHERIFF'S RETURN OF SERVICE 04/22/2014 PM Dawn Kell, being duly sworn according to law, served the requested Writ of Revival by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Dana E. Danner at 9 Cromwell Court, Silver Spring Township, Mechanicsburg, PA 17055. C-31-LAsY1 DAWN KELL, DEPUTY 04/22/2014 04:35 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Writ of Reviva by handing a true copy toa person representing themselves bobe Dana Danner, Wifa.who accepted an "Adult Person in Charge" for Steven Danner at 9 Cromwell Court, Silver Spring Township, Mechanicsburg, PA 17050. 0,0y, kqa DAWN KELL, DEPUTY SHERIFF COST: $55.79 SO ANSWERS, April 23, 2014 RONN R ANDERSON, SHERIFF TELKORE, INC. vs. STEVEN DANNER and DANA DANNER : CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT OF REVIVAL TO THE PROTHONOTARY: Kindly enter default judgment of revival against the defendants, Steven Danner and Dana Danner, with regard to the above captioned matter in the amount of $20,000.85 with costs and interest from May 27, 2009. Undersigned counsel hereby certifies and verifies, subject to 18 Pa.C.S. 4904 relating to unsworn falsifications to authorities, that a written notices of intention to file the within praecipe was mailed to the defendants on April 30, 2014 (copies of said notices are attached as "Exhibit A" and "Exhibit B") pursuant to Pennsylvania Rule of Civil Procedure 237.1, 1037 and other applicable rules of procedure. Service of plaintiffs writ of revival and praecipe for writ of revival on defendants was performed by Cumberland County Deputy Sheriff Dawn Kell on April 22, 2014 at defendant' residence and current address of record as evidenced by a Sheriffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-2188 Return of Service (a copy of which is attached as "Exhibit C"). /6.0 Id 4 4/644 3675 -- 0 -0 - Respectfully submitted, BAYLEY L4 • NGAN Mark F. Bayley, Esquir 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D.#87663 -10 W co ALL-STATE LEGAL®1 TELKORE, INC. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : DOCKET NO. 14-2188 STEVEN DANNER and DANA DANNER : CIVIL TERM To: Steven Danner 9 Cromwell Court Mechanicsburg, PA 17050 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 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. DATE: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 EXHIBIT A 4 4 BAYLEY & MANGAN Mark F. Bayley squire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D.# 87663 TELKORE, INC. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : DOCKET NO. 14-2188 STEVEN DANNER and DANA DANNER : CIVIL TERM To: Dana Danner 9 Cromwell Court Mechanicsburg, PA 17050 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 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. DATE: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 BAYLEY & MANGAN Mark F. Bayley, quire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D.# 87663 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ttt, nielrrabrr/4:11 4 OFFICE QF Tii'E SHERIFF Telkore, Inc. vs. Steven Danner (et al.) Case Number 2014-2188 SHERIFF'S RETURN OF SERVICE • 04/22/2014 04:35 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Writ of Revival by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Dana E. Danner at 9 Cromwell Court, Silver Spring Township, Mechanicsburg, PA 17055. �% rY_1s cr1 c�3- l/ 0 0 - DAWN KELL, DEPUTY 04/22/2014 04:35 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Writ of Revival by handing a true copy to a person representing themselves to be Dana Danner, Wife, who accepted as "Adult Person in Charge" for Steven Danner at 9 Cromwell Court, Silver Spring Township, Mechanicsburg, PA 17050. 61 • t DAWN KELL, DEPUTY SHERIFF COST: $55.79 SO ANSWERS, April 23, 2014 (c) CountySuito Sheriff, Toleosoft. Inc. RONPKS' R ANDERSON, SHERIFF TELKORE, INC. vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 14-2188 STEVEN DANNER and DANA DANNER : CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Plaintiffs, do hereby certify that I this day served a copy of the foregoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Steven and Dana Danner 9 Cromwell Court Mechanicsburg, PA 17050 r�( (( u_Ar Mark F. Bayley, Esquire