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Home My WebLink About05-4454 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. OS" - 4/fSLf C!1~;L~~ : CIVIL DIVISION - LAW MID-SOUTH BUILDING SUPPLY, INe. Plaintiff MARK A. BOOV A and SHEILA M. BOOV A Each Individually and Trading As BOOV A CONSTRUCTION Defendants NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TIDS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TIDS 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 TWO LIBERTY AVENUE CARLISLE P A 17013 (717) 249-3166 MID-SOUTH BUILDING SUPPLY, INe. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. Of:; - /..;"I5Y CIVIL DIVISION - LAW C'u~L '-r ~ MARK A. BOOV A and SHEILA M. BOOV A Each Individually and Trading As BOOV A CONSTRUCTION Defendants COMPLAINT The Plaintiff, MID-SOUTH BUILDING SUPPLY, INe., by its attorneys, KNUPP, KODAK & IMBLUM, P.c., brings this action of Assumpsit against the Defendants to recover the sum of NINE THOUSAND, SIX HUNDRED SEVENTY-ONE DOLLARS AND SIXTEEN CENTS ($9,671.16), along with interest thereon from January 18,2005 upon a cause of action of which the following is a statement: I. The Plaintiff, MID-SOUTH BUILDING SUPPLY, INC., is a corporation organized and existing under the laws of the State of Virginia, having its principal office and place of business at 7940 Woodruff Court, Springfield, Virginia 22151-2122. 2, The Defendants, MARK A. BOOV A and SHEILA M. BOOV A, are adult individuals Trading and Doing Business as BOOV A CONSTRUCTION with an address of 522 Lavina Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff, at the special instance and oral request of the Defendants, sold and delivered goods, wares and merchandise to the Defendants in the total amount of Seven Thousand, Nine Hundred Ninety-Two Dollars and Seventy-One Cents ($7,992.71) as shown on Plaintiff's Statement hereto attached, marked Exhibit "A" and made a part hereof. 4. The prices charged for said goods, wares and merchandise were just and reasonable, were the legal and market prices therefor and were the prices which the Defendants orally promised and agreed to pay to Plaintiff. F:\USER\ST ACY\CCP COMPLAlNTS\ WORKIMIDSOUTH31539, wpd: 18Aug05 5. Due to Defendants' default in payment of said amount due and owing as aforesaid, interest has been added to said account in the total amount of Seven Hundred Ninety-Nine Dollars and Twenty-Five Cents ($799.25), as shown on said Exhibit "A". 6. Due to the default of Defendants, and pursuant to the terms and conditions ofthe Guarantee and Suretyship Agreement executed by Defendants hereto attached, marked Exhibit "B" and made a part hereof, attorney's fees in the total amount of Eight Hundred Seventy-Nine Dollars and Twenty Cents ($879.20) have been added to said account. 7. Plaintiff frequently demanded payment from Defendants of said amount due and owing as aforesaid, but Defendants refused and neglected and still refuse and neglect to pay said amount of any part thereof. WHEREFORE, Plaintiffbrings this suit to recover from Defendants the sum of NINE THOUSAND, SIX HUNDRED SEVENTY -ONE DOLLARS AND SIXTEEN CENTS ($9,671.16), along with interest thereon from January 18,2005, Respectfully submitted, Robert D. Kodak 407 North Front Street Post Office Box #11848 Harrisburg, P A 17108-1848 (717) 238-7151 Attorney ill No. 18041 Attorney for Plaintiff F:IUSERIST ACYlCCP COMPLAINTSIWORKIMIDSOUTIl3 J 539,wpd: 18Aug05 3 ~IDSQlJI!! @ 100% Emr}loyee Owned Distributor of Building Products ,BILLING-INQUIRIES: (703) 321.8500 . (800) 284.9111 REMIT TO MID SOUTH BUILDING SUPPLY. INC 7940 WOODRUFF COURT SPRINGFIELD. VA 22151.2122 BOOVA CONSTRUCTION 522 LAVINA DRIVE MECHANICSBURG. PA 17055 (/7 - foctl 31 ATEMENT DATE GUSTOMEftN(). 01/17/05 56354 r lNVOlCEDATE DUEMTe 06/18/04 07/18/04 IN DUE 06/18/04 07/18/04 IN DUE 06/18/04 07/18/04 IN DUE 06/18/04 07/18/04 IN .DUF 07/31/04 07131/04 SC DUE 08/31/04 08/31/04 SC DUE 09/30/04 09/30/04 SC DUE 10/31/04 10/31/04 SC DUE 11/30/04 11/30/04 SC DUE CUAAEN1: OYER3DDI\V5 0.00 0,00 Camp Hil~ PA (717}7S1-6611 (800)3132-1327 Charlolesville, VA: (434)979-2335 Chesapeake, VA: (757)523-7001 (BOO) 340-6727 fr1~(' 1:.. Boo V A- CEII:(1/7) '132.- ot7? JCjuo Invoice due 30 days from invoice date, INVOICE NO CUSTOMER PO NO 5015564.00' 5015599.00 5015601.00 501560:1.00 73104.99 83104.99 93004.99 103104.99. 113004.99 PATTI JOB BOOVAlPATTI MARIE PATTI MAR1F Df,TT! STATEMENT >~.,SUSTQMER NO: -!. ~ ...ll7n.96 AMOUNT PAID PLEASE RETURN THIS PORTION WITH YOUR REMITT ANCf' CHARGE CREDIT 4527.15 2841. 33 513 .46 11077 159.857 1Ui:;t 159,85 5(1 159.85 159.85 159.85 Balance Due $8,791.V6 Richmond,VA- (804)652-0090 (800) 310-t;988 OVER 120 QAYS =d Springfield, VA {7D3)3.21-BSOO (800)284-9111 Winchester,VA' (540) 662-3100 (800)284-7940 JAN-20-2005 11:34 MIDSOUTH BLOG SUPPLY 7033219503 P.02 Guarantee And Suretyship Agreement FOR VALUE RECEIVED. and intendi"" to Ila IllOslly bound. Ine undersigned ("Surety") llbooluIC1y and unconditionally guarantees JONES & BROWN, INC. and/or MIO-SOUTH BUILDING SUPPLIES, INC. and becomes surety for the full and timely payment, both principal and Interest. of Ihe presenl and lulure indebtedness 01 ,,_ _ ("Debtor") to JONES & BROWN.INC, endlor MID-SOUTH BUILDING SUPPLlES,INC, Together with any .Xlenaions or renewals thereolin whole or in part, then and as said indebledness becomes due and payable in accordance with the lerms therof, whelMr at maturity or by declaration, acceleration or otherwise. Surety waive.q presentment tor payment, notice of non-payment, demand and prolest and declares Ihal Surety's oIlIigations hereundel' are absolute end unconditional and shall not be released Or discharged by any releasee or discharge 01 or accord and saIls/action wllh Oebtor or any other person ~y an renewal Or ex'enslons or (Im/l of p.ymsOl 01 said indebtedneliS, by any substitution or release of collateral therefor, or by any olher maner or thing Whalso.verwhereby Surety IS unconditional and absolute !1rantor and surely 01 said indebtedness would or mlghl be released or discharged, In the evenl Debtor defaults In Ihe tvll and timely paymen.l of the principal of or Inleresl on said Indebtedness. Surely will prompdy make paymem dlractly 10 JONES & BROWN, INC, andlor MID-SOUTH BUILDING SJPPLIES, INC Surety's obllgaUons h"reuflder shall be e1irectly enforceable by JONES & BROWN, INc. andlU' MID-SOUTH BUILDING SUPPLIES, INt. without any acllon of Iny nature against Ceblor or any other person, Said obligalions are conllnuing obligations, ata absolute and uncondi\ionallrrespecllve ot the genulneanesa, validity orenforceabiiity 0' any promissory nOle or clher inslrument avidencinl/ said indabledness or of any oth.. circumstance which might OIl1erwis.. ~lInsllluts a legal equltallte discharge or a quarantor or surely, and shall 'emaln in full force and elfact as long as any of said indebledness remains oulSlanding and unpaid. Sulety has rlghl to revol<e this Agreement only as 10 indebledness or the Deblor arising oul of transactioM entered Into by Oebto,afle( receipt ofwrillen nallce of rovoc:.lIon by JONf;;5" ElROWN, INC. andAJr MID-SOVTIi BUILDING SUPPLIl<S, INt. Surely shall pay, in addilion to all other sums payable hereunder, Ihe reasonable COSlS snd expenses incurred by JONES & BROWN, INC_ andtor MID-SCUTH BUILDING SUPPLIES, l~jC. in connection with all acfions lsken to enforce collection of said i_ednOOlll upon delay/l by O<tblor, whether by legal prOGOedlng Otherwise, inclUding wilhoulllm/lations, and enorney's fee of .10% of the unpaid balan(:e 01 ~ald indebtedness and court OOSIS. Surely ernpcwe!1l the pn:oUlonotary or any anomey of any CQUrt Of record wllhln tne IJ/1Iled ::itales or elsewhere to appear for Surely and, Wllh or without one or more declarations field, 10 oonfess Judgmenl as ollen as necessary against Surely in favor of JONES & BROWN. INC, and/or MID-SOUTH BUilDING SUPPLIES, INC, in any SUCh courI, as of any term, for Ihe unpaid balance 01 SIlid indebttldn_, togethar wftn COSlS or SUIl and an attorney's commission of 15% for collection, with refease 01 all ."ors. Surety waives any rl!lht to stay 01 execution and extension ypon any levy on real astate pursuant to any jUdgement so entered and also waives the exemption of all properly from levy and sale on any executiOn thereon and also any exemplion laws now In Ioree 0( w"l~h may hereafter be enacted by any Stale or Nallon IOsolar as such exemption laws may be waived. All the foregoing promises and obligations. including withoullimltalion the foregOing warrant 01 anomey 10 confess judgemenl. ens the join! and aeYf'11lI promises and obligaUons 01 Surety When more than one, shall bind Suraty, heirs. personal representalives, successors an,l assigns, and shall Inure 10 Ihe benefil. of JONES & BROWN, iNC. andlor MID-SOUTH BUILDING SUPPLIES. INC., Its successol$ and assigns. whelher so expressed or nol. This Agreement has been enlered in'o under and pl'USUllnl 10 tne 18l\~ olllle Commonwealth 0' PennsylVania and for all purposes shall ba construed in accordanca wlltl said laws. Surety waives nOli,:& of acceptance 0' Ihis Agraement by JONES & BROWN. IN C. andlor MIO-SOUTH BUILDING SUPPLIES. INC. ALL Principal OfflcerJ/Panners/Spouses Sign Below x ~/ ' , , ,J\ A ;; .;., ~Ll" ...........~.' - .vi. - IIA~...:4. ,"S.,''/A _ " ",,' / (PI;.' N.".) ; I .-,.,.{I ....", C''l 'b "/I~tf.,,'~" ,-;..~:~___ _____. 4.;'i,./.'/~ .I ~" (Slgnarure! /.' 0'1' ~5~Jf E-~~ /i.f '::'~.:l i,':":. (Print N';;) . I . ,." 7,~ .1.1, >?; .j ."I'~':>'/'J\ .r/I, /!?~ .~-:::.-.-..--,.......,- (Gig,.,.hJre) / (PO.' N.",o) (SIgnatu(s) Date (Print Name) Uate (elgl'b1lvre) TOTAL P.OZ AUG-J9-2005 02:39 KNUPP KODAK , IMBLUM . 717 238 7t59 , . P.G5 VERIFICATION I, ~,,/ ?eevy (J1Irm:) , C (e-.lJf f'1 '6 r. (,u.) of MID-SOUTH BUll.DING SUPPLY, INC., verifY that the statements made in the aforegoing document l.Je true and correct. I Wlde:rstand !hat f8lse stateIl1ents herein are made subject to the penalties of 18 Pa. C. S. a4904, relating to Ull5wom falsification to authorities. MID-SOUTH Bun.DING SUPPLY, INC. By: ( ,~ ~ 7J!?~ ~ / y C!~L;/T ;I?,p""',,rr>r Title; Dated: g - 2-S - 05 to;:)-~u , I- NotAAv... f.OfS/tf'r~!Jt." M,,(,. ,:v8IJC Sr:.--- vv . ~r.f;,rl.iJ..., _ ~l::: c~ 8~f"i!.ol_ , I t:J:t,.;,1...s ~ . .t '.Inn...""o\~ . ~."'n' '.' ,. I' . ~"!'o/,iHJv; 31539 IUSEIlISTACY1CCP COMPLAINTSIWORKllilIXlSOU11i3IS39.wpdo IM_.en TOTAL P.os r-i.l -=It:'\tf.-.l JNI JJ\1N 8LL5L T~ mE: 9p:50 S00~/9~/80 -p D ~ ll- t ~ ~ ....... E Crt \' [ C> ~ <.J --c p::. J ,',', () ,..., C""'> E:. <..n _:'7 ~,'" , v-' p,,) \.D ("I "':'h :? fI'! fTI -'-1(T1 :uCi (:~ ,-=) -F'-'ji :::~ <,-;- ~,~~ . ) : ~.~~ :s:, - :;? C.-;'" 1") ~'- G SHERIFF'S RETURN - REGULAR CASE NO: 2005-04454 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MID-SOUTH BUILDING SUPPLY INC VS BOOVA MARK A ET AL BRIAN BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BOOVA MARK A the DEFENDANT , at 1905:00 HOURS, on the 31st day of August 2005 at 522 LAVINA DRIVE MECHANICSBURG, PA 17055 by handing to MARK BOOVA a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge 18.00 8.00 .37 10.00 .00 36.37 So Answers: ?~~=.~.~~ ./ff~ R. Thomas Kline Sworn and Subscribed to before By: Ij1fu _ Deputy Sneriff 09/01/2005 KNUPP KODAK me this J-~ day of A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2005-04454 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MID-SOUTH BUILDING SUPPLY INC VS BOOVA MARK A ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BOOVA SHEILA M the DEFENDANT , at 1905:00 HOURS, on the 31st day of August , 2005 at 522 LAVINA DRIVE MECHANICSBURG, PA 17055 by handing to MARK BOOVA, HUSBAND a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 ".... ,,~; L;/ ?''".J:<<:.. R. Thomas Kline /,~~? 7"'''''''>~ '.'<'"""-'f:~,?f. 09/01/2005 KNUPP KODAK Sworn and Subscribed to before By: '1J;;;v III Deputy Sheriff me this J-3 day of A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2005-04454 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MID-SOUTH BUILDING SUPPLY INC VS BOOVA MARK A ET AL BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BOOVA MARK A & SHELIA M BOOVA T/A BOOVA CONSTRUCTION the DEFENDANT , 2005 MECHANICSBURG, PA 17055 by handing to MARK BOOVA a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 -~J<","" 7' .,... ..' ~""; . ..r~."'t'l J/"~ R. Thomas Kline Sworn and Subscribed to before By: 'MB~~_ Deputy Sheriff 09/01/2005 KNUPP KODAK me this ,),,1 day of A.D. MID-SOUTH BUILDING SUPPLY, INe. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO, 05-4454 CML TERM MARK A. BOOV A and SHEILA M, BOOV A Each Individually and Trading As BOOV A CONSTRUCTION : CML DMSION - LAW Defendants TO: PROTHONOTARY, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE FOR DEFAULT JUDGMENT Enter judgment in favor of Plaintiff and against Defendant(s) MARK A. BOOV A and SHEILA M. BOOV A Each Individually and Trading As BOOV A CONSTRUCTION, named for failure to file within the required time an Answer to the Complaint in the above-captioned case and assess the Plaintiffs damages as follows: Amount claimed in Plaintiff's Complaint $9,67U6 Interest from January 18, 2005 at the legal fate of 6% per annum $435.24 Total $10,106.40 It is hereby certified that a written notice of intention to file this Praecipe was mailed to the Defendant( s) and his attorney of record, after the default occurred and at least ten (10) days prior to the date of the filing of this Praecipe, See Exhibits A & B attached. ~. Robert D, Kodak, Attorney for Plaintiff DATED: Judgment entered and damages assessed as above. iD-r<{~60 aL~' prot~onot~'- -; Robert L Knupp Robert 0, Kodak Gary J, Imblum LAW OFFICES OF KNUPP, KODAK & IMBLUM, P.C. CAMERON MANSION 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 Telephone: 717/238-7159 Facsimile: 717/238-7158 email: kki.law@Verizon.net F :." ,,~u ) ~ , Robert Ewin9 Knupp (1909-1976) Robert H, Maurer ( 1923-1998) September 28, 2005 MARK A BOOV A 522 LAVINA DRIVE MECHANICSBURG PA 17055 RE: Mid-south Building Supply, Inc VS: MarkA Boova and Sheila M. Boova Each Individually & lIa Boova Construction No. 05-4454, Court of Common Pleas Cumberland County, Commonwealth of Pennsylvania Our File No. 31539 Dear Mr, Boova: In accordance with Pennsylvania Rules of Civil Procedure 237.1 (a)(2), we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Office of the Prothonotary of Cumberland Cpunty, you have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County to enter Judgment against you in the amount as set forth in said Complaint. Very truly yours, KNUPP, KODAK & IMBLUM, P,C. Robert D. Kodak, Esq. THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE RDKlkqb enclosure cc; C WATKINS NORTH AMERICAN CREDIT C 18227A FLOWER HILL WAY GAITHERSBURG MD 20879 #12495 r ~~ ,"', J ....... Ii;.... _, '",.,' ":,,;j: Ii MID-SOUTH BUILDING SUPPLY, INe. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO, 05-4454 CIVIL TERM MARK A. BOOV A and SHEILA M. BOOV A Each : CIVIL DIVISION - LAW Individually and Trading As BOOVA CONSTRUCTION Defendants IMPORTANT NOTICE TO:MARK A. BOOV A, Defendant(s) DATE OF NOTICE: SEPTEMBER 28. 2005 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 YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER, 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 AGENClESTHAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LffiERTY AVENUE CARLISLE P A 17013 (717) 249-3166 Robert L Knupp Robert D, Kodak Gary J, Imblum LAW OFFICES OF KNUPP, KODAK & IMBLUM, P.C. CAMERON MANSION 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 Telephone: 717/238-7159 Facsimile: 717/238-7158 emaH: kki.law@Verizon.net F i l [be~Eul (1909-1976) Robert H, Maurer (1923-1998) September 28, 2005 SHEILA M BOOVA 522 LAVINA DRIVE MECHANICSBURG PA 17055 RE: Mid-south Building Supply, Inc VS: MarkA. Boova and Sheila M. Boova Each Individually & Va Boova Construction No. 05-4454, Court of Common Pleas Cumberland County, Commonwealth of Pennsylvania Our File No. 31539 Dear Ms, Boova: In accordance with Pennsylvania Rules of Civil Procedure 237.1 (a)(2), we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County to enter Judgment against you in the amount as set forth in said Complaint. Very truly yours, KNUPP, KODAK & IMBLUM, P.C. Robert D, Kodak, Esq. THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE RDKlkqb enclosure cc: C WATKINS NORTH AMERICAN CREDIT C 18227A FLOWER HILL WAY GAITHERSBURG MD 20879 #12495 r c' '""',", .....Tel 'c''!!: ,"~ 'v.;;. ~! ',...~, I< & MID-SOUTH BUILDING SUPPLY, INC, : IN TIffi COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA v, : NO. 05-4454 CIVIL TERM MARK A. BOOV A and SHEILA M. BOOV A Each : CIVIL DIVISION - LAW Individually and Trading As BOOV A CONSTRUCTION Defendants IMPORTANT NOTICE TO: SHEILA M, BOOV A, Defendant(s) DATE OF NOTICE: SEPTEMBER 28. 2005 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 IMPORT ANT RIGHTS, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER, 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 MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LffiERTY AVENUE CARLISLE P A 17013 (717) 249-3166 Robert L. Knupp Robert 0, Kodak Gary J, Imblum LAW OFFICES OF KNUPP, KODAK & IMBLUM, P.C. CAMERON MANSION 407 NORTH FRONT STREET POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 Telephone: 717/238-7159 Facsimile: 717/238-7158 email: kki.law@Verizon.net F I L E Ciji EYng Knupp (1!J09..1976) Robert H, Maurer (1923-1998) September 28, 2005 BOOVA CONSTRUCTION 522 LAVINA DRIVE MECHANICSBURG PA 17055 RE: Mid-South Building Supply, Inc VS: Mark A. Boova and Sheila M. Boova Each Individually & Va Boova Construction No, 05-4454, Court of Common Pleas Cumberland County, Commonwealth of Pennsylvania Our File No, 31539 Greetings:. In accordance with Pennsylvania Rules of Civil Procedure 237.1 (a)(2), we are enclosing herewith a Notice of a Praecipe for Entry of Default Judgment. According to the records as they are found in the Office of the Prothonotary of Cumberland County, you have not filed responsive pleadings to the Complaint filed against you to the above term and number, nor has any attorney entered an appearance on your behalf. Accordingly, we are forwarding to you the enclosed Notice which indicates that if you do not take action as set forth in this Notice, we, at the expiration of time indicated therein, will request the Office of the Prothonotary of Cumberland County to enter Judgment against you in the amount as set forth in said Complaint. Very truly yours, KNUPP, KODAK & IMBLUM, P.C. Robert D. Kodak, Esq. THIS LETTER IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE RDKlkqb enclosure cc: C WATKINS NORTH AMERICAN CREDIT 18227A FLOWER HILL WA GAITHERSBURG MD 20879 #12495 1;l:'Il ": "J ~ c~" '.' ! ; ""'u ;I \.1} , iI ,'ij I MID-SOUTH BUILDING SUPPLY, INe. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO, 05-4454 CML TERM MARK A. BOOV A and SHEILA M, BOOV A Each : CIVIL DMSION - LAW Individually and Trading As BOOV A CONSTRUCTION Defendants IMPORTANT NOTICE TO: BOOV A CONSTRUCTION, Defendant(s) DATE OF NOTICE: SEPTEMBER 28. 2005 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 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 AGENCIESTHAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LffiERTY AVENUE CARLISLE P A 17013 (717) 249-3166 MID-SOUTH BUILDING SUPPLY, INe. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 05-4454 CML TERM MARK A. BOOV A and SHEILA M. BOOV A Each Individually and Trading As BOOV A CONSTRUCTION : CML DMSION - LAW Defendants TO: MARK A. BOOV A, Defendant(s) You are hereby notified that on (Judgment) has been entered against you in the above-captioned case, .20_, the following Judgment entered in the amount of $10.106.40 DATE: Prothonotary I hereby certify that the name and address of the proper person(s) to receive this notice is: MARK A. BOOVA 522 LAVINA DRIVE MECHANICSBURG PA 17055 N MARK A. BOOV A, Defendido/a Defendidoslas Por este medio se Ie esta notificando que el de del 2005, ellla siguiente(Fallo) ha sido anotado en contra suya en eI caso mencionado en eI epigrafe. FECHA: Protonotario Certificao que la siguiente direccion es la del defendido/a segun indicada en eI cetificado de residencia: MARK A. BOOVA 522 LAVINA DRIVE MECHANICSBURG P A 17055 Abogado del Demandante . " . MID-SOUTH BUILDING SUPPLY, INe. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNlY, PENNSYLVANIA v. : NO, 05-4454 CIVIL TERM MARK A. BOOV A and SHEILA M. BOOV A Each Individually and Trading As BOOV A CONSTRUCTION : CIVIL DMSION - LAW Defendants TO: SHEILA M, BOOV A, Defendant(s) You are hereby notified that on / 1 tJt.--r (Judgment) has been entered against you in the above-captioned case, , 2oti5, the following Judl!1I1ent entered in the amount of $10.106.40 DATE: /(OC'105 ~~~ I hereby certifY that the name and address of the proper person( s) to receive this notice is: SHEILA M. BOOV A 522 LAVINA DRIVE MECHANICSBURG PAl 7055 AI SHEILA M. BOOV A, Defendido/a Defendidos/as Por este medio se Ie esta notificando que el de del 2005, el/la siguiente(Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: Protonotario Certificao que la siguiente direccion es la del defendido/a segun indicada en el cetificado de residencia: SHEILA M. BOOV A 522 LAVINA DRIVE MECHANICSBURG P A 17055 Abogado del Demandante . .... MID-SOUTII BUILDING SUPPLY, INC, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO, 05-4454 CML TERM MARK A. BOOV A and SHEILA M. BOOV A Each Individually and Trading As BOOV A CONSTRUCTION : CML DIVISION - LAW Defendants TO: BOOV A CONSTRUCTION, Defendant(s) You are hereby notified that on I ( Oe.r (Judgment) has been entered against you in the above-captioned case, # , 2~ the following JudlPDent entered in the amount of $10.106.40 DATE: /(o{!f 05 ~.t~'1 I hereby certify that the name and address of the proper person(s) to receive this notice is: BOOV A CONSTRUCTION 522 LAVINA DRIVE MECHANICSBURG PA 17055 N BOOV A CONSTRUCTION, Defendido/a Defendidoslas Por este medio se Ie esta notificando que el de del 2005, el/la siguiente(Fallo) ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: Protonotario Certificao que la siguiente direccion es la del defendido/a segun indicada en el cetificado de residencia: BOOV A CONSTRUCTION 522 LAVINA DRIVE MECHANICSBURG P A 17055 Abogado del Demandante ~ ~ 0 ,..., ~ C c,::::> () c:-~ c..r'1 -'n ~ ('7:) c: -i ~ ""'\' ~ ~ c- ""-' ~ ~ ~ ~,; (~~ _.Co y: (',) ,- .~ (,., ,:~ ".1 U1 .-< C:> ..\ ~ . PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENTS) P.R.C.P. 3101 to 3149 MID-SOUTH BUILDING SUPPLY, INC. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Writ No. Term 20 Plaintiff NO. 2005-04454 CIVIL TERM Term 20~ VS Amount due $ 10,106.40 MARK A. BOOVA AND SHEILA M. BOOVA EACH I/A//T/A BOOVA CONSTRUCTION 522 LAVINA DRIVE MECHANICSBURG PA 17055 Defendant (5) Interest FROM DATE OF JUDG. 10/14/05 Atty's Corom. $ 223.68 and CostsTO BE DETERMINED$ TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against MARK A. BOOVA AND SHEILA M. BOOVA EACH I/A/T/A BOOVA CONSTRUCTION (3) and against Defendant (s) Garnishee (s j l (4) and index this writ (a) against MARK A. BOOVA AND SHEILA M. BOOVA EACH I/A/T/A BOOVA CONSTRUCTION Defendant(s) and (b) against Garnishee (s) , as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy) LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS INCLUDING B(UST) NOT LIMITED TO FURNITURE, EQUIPMENT, ELECTRONICS, ~~, /'~. Exemption has (not) been waived. ~ /' Robert D. Kodak, Esquire PO Box 11848 Harrisburg, PA 17108 (717 J 238-7159 Attorney For Plaintiff(s) Dated 11/03/05 . (O)vOI[ aTnB aas 'pa~~sap ST suapuad STT e sp Du-.::xapu",\-" PUl? pa1..j::Jl?1:p'! 51: aa1..jS1"UJ:'E:D a1..j"4 JO 21Ul'2Tj alj~ U1 }\~J:adaJ:d Tea.1 11" ATua pa~aTdwoJ aq PF104s (q) (v) 4deJ6E'JE'd . 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BOOV A EACH I1AfT/A BOOV A CONSTRUCTION, 522 LAVINA DRIVE, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS INCLUDING BUT NOT LIMITED TO FURNITURE, EQUIPMENT, ELECTRONICS, ETC , (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $10,106.40 Interest FROM DATE OF JUDG 10/14/05 Atty's Comm % $223.68 Atty Paid $150.37 PlaintilTPaid Date: NOVEMBER 4, 2005 LL $.50 Due Prothy $1.00 Other Costs .~ Prothonot (Seal) By: Deputy REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No, 18041 MID SOUTH BUILDING SUPPLY INC Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-4454 CIVIL MARK A. BOOVA and SHEILA M. BOOVA, each : CIVIL DIVISION - LAW individually and trading as BOOV A CONSTRUCTION: Defendant TO THE PROTHONOTARY: PRAECIPE Please mark the above-captioned Judgment as settled and satisfied in full. TO: Cumberland County Prothonotary Dated: Mav 31 . 2006 ~ Robert D. Kodak Attorney I.D. No. 18041 Attorney for Plaintiff 31539 (") c ~ = c:::) 0""1. o -q --i I" rn- S c; /) _=i~, -, ' dfl~ <- (== Z N v <:o? ~t~~; :::6 -< o Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee Postage TOTAL $ 18.00 202.13 20.00 .50 1.00 31.68 50.00 20.00 Advance Costs: 373.31 Sheriffs Costs: 373.31 $ 000.00 Refunded to Atty on 06/05106 30.00 373.31 ~. t,/ (J f jot, SO~ ~ ~,~~ ~Tromas ~2ine~heriff I / ~~Atoare~d.l~ C) '-'" , -c -f 0\ ~ ~' (.$ ~~ (;~~d) f" {' l:~' j .:.1i'.:l ::i' 'I,:: " ~ ~ ~ ~ I G : II 'Ii L - AON ~aOl I ,'1> Ct2.. 5V3/0, ~ /7f931, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4454 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MID-SOUTH BUILDING SUPPLY, INC., Plaintiff (s) From MARK A BOOV A AND SHEILA M. BOOV A EACH IJA/T/A BOOV A CONSTRUCTION, 522 LAVINA DRIVE, MECHANICSBURG, P A 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT ABOVE-LISTED ADDRESS INCLUDING BUT NOT LIMITED TO FURNITURE, EQUIPMENT, ELECTRONICS, ETC. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $10,106.40 Interest FROM DATE OF JUDG 10/14/05 Arty's Comm % $223.68 Arty Paid $150.37 Plaintiff Paid Date: NOVEMBER 4, 2005 L.L. $.50 Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name ROBERT D. KODAK, ESQUIRE Address: PO BOX 11848 HARRISBURG, PA 17108 Attorney for: PLAINTIFF Telephone: 717-238-7159 Supreme Court ID No. 18041