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
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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
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Mark F. Bayley, Esquire