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HomeMy WebLinkAbout06-1820 .' ;OMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. Pt,. / ;;;).{) C.;J NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case referenced below. 4 ZIP CODE /7C)::9~ C V-()6cO~5-05 This block will be signed ONLY when this notation is required under Pa. If appeffant was Claimant (see Pa. R.C.P.D.J. No. 1001(6) in action R.C.P.D.J. No. 1008B. This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty SUPERSEDEAS to the judgment for possession in this case. (20) days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONL Y when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be selVed upon appellee. PRAECIPE: To Prothonotary Enter rule upon _.r ~ :YfbueO'/ J<:i.5<:!lf) Name of appel/ea(s) (Common Pleas No _ l')t~>lc20 ... Ctf~d ~ ) within twenty (20) days atter selVice ot rule or suffer entry ot judgment of non pros. appellee(s), to file a complaint in this appeal RULE: To S~uer Jet ~ n --- Name 01 appel/ea(s) , appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified Of registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: /llau~ ,.;}<J ,20C'& ~/MA ,/ f" ~'C:.('. ~ Signature of rotb olary or Deputy YOU MUST INCLUDE A COpy OF THE NOTICE OF JUDGMENTfTRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312.02 WHITE - COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE YELLOW - APPELLANT'S COPY PINK - COPY TO BE SERVED ON APPELLEE GOLD - COPY TO BE SERVED ON DISTRICT JUSTICE PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FfLED WITHIN TEN (10) DAYS AFTER lIIing of the notice of appeal. Check appl.Jcahle ooxe,,) COMMONWEALTH OF PENNSYLVANIA COUNTY OF , S5 AFFIDAVIT: I hereby (swear) (afiirm) fhat I served o a copy of the Notice of Appeal, Common Pleas , upon the District Justice deslqnate() therein on (date of service) _________m.m___' sender's receipt attached hereto. , 20 0 by personal servicE: and upon \I", appellee, (name) o by personal service o by (certified) (req1stered) mad, _ en 20 by (certified) (registered) mail, sender's feC8Jpt attached hereto. (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF SIC)r)dU;iV uf !iffiun! S'1!}nature of officiai before whom ar'!idavil was made Title of official My commission expires on <-> 0 (~.;) iJ', '^ c=;:, " d"' 1)\ \ \::)1 z .-1 ~ , :I-f' ~:' :t::i,~ rl1-.;;:; \) ;;V -,..!-" 10 ~ ~ l".' j.,~;,~: '+ VI, \.0 G, t ) (~') \ '\ '\ -- "'- \ ~ 0 C~,)!'T' ~ ~ :.-\ ?n -< -< "- ~ ~ ~ ( ,~ COMMONWEALTH OF PENNSYLVANIA ~ COUNTY OF: CUMBBRLAJID NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE 09-2-01 PLAINTIFF: 'sHOVER, JASON 1554 NEWVILLB RD CARLISLB, PA 17013 NAME and ADDRESS ., Mag. Dist. No.: MDJ Name: Hon PAULA P. CORR~~ Add"" 2260 SPRING RD SUITB #3 CARLISLB, PA L -.l VS. T.I.,ho,,: (717) 218-5250 17013-0000 DEFENDANT: NAME and ADDRESS iJmMKA CONST/MICIlABL MUMMA 1316 HONEYSUCKLB HOLLOW R BLLIOTTSBtrRG, PA 17024 L ., MUMMA CONST/MICIlABL MUMMA 1316 HONEYSUCKLB HOLLOW R BLLIOTTSBtrRG, PA 17024 Docket No.: CV-0000525-05 Date Filed: 12/06/05 -.l ~- ~ THIS IS TO NOTIFY YOU THAT: Judgment: [i] Judgment was entered for: POR PLllIlI1TIPF (Name) A'Rn'U"RV .Ta. Rn. . [i] Judgment was entered against: (Name) lITTMMa COlllAT/MTC"'lra1lT. lITTMMa in the amount of $ A 11;7 1 0 on: (Date of Judgment) 1/01106 . D Defendants are jointly and severally liable. D Damages will be assessed on: D This case dismissed without prejudice. (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total $ 8.000.00 $ 157.10 $ .00 $ .00 $ 8.157.10 D Amount of Judgment Subject to Attachment/42 Pa.C.S. S 8127 $ o Portion of Judgment for physical damages arising out of residential lease $ Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU ---MUSt INCLUDE 'A COPY OF"'fRIS N01nCEOl"JUiillMENTITRA.NSCRIPTFClRM WITH YOUR NOTICE OF APPEAL EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS. ALL FURTHER PROCESS MUST COME FROM THE COURT OF,COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED,IN>TH,E JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF Tt-!,~JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. ..", ""...".:,) _, ..A..;.(-)f..'" ...... ,. "" ,. ,_,...,;.1-.1 Date (2t?~ ~~J3'(;. Magisterial District Judge ''-,.- " :.--,-: :--, " ..' . ....'::.<--.'.:'..:'~' ' I certifyJhat this is atrueahd correct copy of the recprdof the proceedings containing ,the judgment. Date , Magisterial District Judge My commission expires first Monday of January, 2012 SEAL AOPC 315.05 DATB PRIlI1TBD: 3/07/06 8:18:16 AM II. _......:,!)~c.\,. lr M " M ~ l i: '" \lJ D D D D Ul [I /"- D ~~ ',.-/ '~~~>, , \~\ ) 'fJ ~ lv1i _.:40. ..,~-Ll...._," ___~ -- I -1 ~~s 0' e, I , ./;)~on :,111)\ J.i:;4 \,?\,\ ~'tJ'/jSll P 1'1<<1;1 7()ll '/ '7 ,', n m lI=Umll I;, I Ii I.'~ i I . - ....-- p :II; I .f;'\ ICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT ,,'{THIN TEN (10) DAYS AFTER filing of the notice of appeal, Check applicable boxes.) PS Form 3aOO, June 20Q2 See Reverse for InstructIons (1 /;)f )'o'.;en Cl cm 1 vc I~ IEALTH OF '-LNNS,) l'IIINLA cm H { F ; 55 \lJ D M U.S. Postal ~ice,.. CERTIFIED MAIL. R~OEIPT (Dom& MsI1 Only; No Insurance Coverage Prcwlded) lr [f" r-~nli'/'-l..ml'IIIII;IFl']I.Jnl.'l'l. ,;I;'1'1i ; ~ L_--~---C--T S '" Po".,. , ~___-.J'1__! cp ~~ g c.rtified'e{~ 4 [' 'cf.t~"m k \ o Aelurn Aeciept Fee! ''-,'','' C g{ Hel'~ , Gl (Endorsement Requirec.!} ~ J ..' ') ,.,' :t1 D f---"'-- ~_ XI Restricted Delivery Fee , ......- / Ul (Endorsement AequireC) ; / " '" ,I /"- 1---- Vol..", Q"I-" ' D Totar Postage & FeM ) $ _ __ _~_9 f.c} 4__ ~/ . '" .0r- a Sent To D f"'- Siiee(Apt or PO Box CJ1Y:-Stafe, l rhe ! lonorahk Paula P. Correal Magisterial District No. 09-2-0 I 2260 Spring Road_ Suite) Carlisle, PA 17\113 AFFOA,V'IJ I heretJ/ (swear) 'affirm) that I served ~ a copy 01 the Notice of Appeal, Common Pleas (Xb-/8';{)upon the District Juslice designated therein on (dale 01 service) ,&r:.L,3 ,20~, Q by personal service 'M by (~:2j)registered) mail, sender's receipt att~clled hereto, and upon the appellee, (name) . 101~.. S ~ov/!. r , on _^ 1..;1.3.._______, 20 ~ 0 by personal service M by (€~ft.) (registered) mail, se;1er's receipt attached hereto. (SWt I ,1'1) , .FFIRMED) AND S.UBSCRIBED BEFORE ME THISc_I' ::_DAYOF 1.,1Z,'J'j','------;;---}OJ) ~" /' 'I /' I"~ ,., . <'.I....~ -: (,,_ ,. __,'; c'" I,? /' '.....' \ l-c" #.'i signat'~:;'ti~#before whom a davit was made - , c Nt~ JJ . Vdt.----. Signature of affiant ,....., = = 0" :P>> \.'J :::rJ \ (T', o -n :::r.!" rnp 'TJ::'J. :~~ '"'( l_~, r-I ~~j ~~ ;;.~;rTl :~I --~ "cO '< :;:;,;'. ...;:... "::j -< _-1 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgmenl rendered by the District Justice on the date and in the case referenced below. .':: NAME OF D.J. ~ NAME OF APPELLANT ;... ., .i" t . DOR S OF APP T'/ c 5 ATE ZIP CODE " ',.,' . ~~ DATE JU M (Defendant)' f '~".C'('. V$i DOCKET o. SIGNATURe TOR OR Y GNT "\ ' ;.,>;",.", '.. ,,<(>#r." This block will be signed ONLY when this notation is required under Pa.' If appellant was C/liimant (see Pa. RC.P.D.J. No. 10Q1(6) in action RC.P,D,J. No. 100BB. This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty SUPERSEDEAS to the judgment for possession in this case. (20) days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF NOT USED. detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon ...;;,1L~lt' .':>" Name of appe/leers) appel/ee{s), to file a complaint in this appeal (Common Pleas No, ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. .';.1 ".'<."i! , Signature of appellant or attorney or agent RULE: To , appel/ee(s) Name of appel/ea(s) (1) You are notified thet a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of thiS rule upon you by personal seNiee or by certified or registered mail. (2) If you do not file a complainl within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailing. Date: .(; ,20 Signature of Prothonotary or Deputy YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENTfTRANSCRJPT FORM WITH THIS NOTICE OF APPEAL, AOPC 312-02 WHITE - COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE: YELLOW - APPELLANT'S COpy PINK - COpy TO BE SERVED ON APPELLEE GOLD - COPY TO BE SERVED ON DISTRICT JUSTICE Jason Shover vs. Mike Mumma/Mumma Construction Docket # 06-1820 Civil Complaint I. Jason Shover 1554 Newville Road Carlisle, PA 17013 2. Mike Mumma/Muma Construction 1316 Honeysuckle Hollow Road Elliottsburg, P A 17024 3. My wife and I contracted with Mr. Mumma to build our house in March, 2004. June, 2004 we moved into our new home. Mr. Mumma repaired some faulty work during the summer of 2004 after receiving calls from me. Beginning November, 2004 Mr. Mumma would no longer return or receive any calls from me. December, 2004 my wife and I hired an attorney, Stephen Tiley, to have him attempt to contact Mr. Mumma so that Mr. Mumma may finish our home. May, 2005 Mr. Mumma agreed to come to our house, with an attorney, to look over what needed to be repaired and finished. May, 2005 Mr. Mumma, his attorney, my wife, our attorney and I all met at our house to determine what repairs still needed to be made. Mr. Mumma agreed at that meeting that he would, in 2 weeks, make all of the necessary repairs and finish what needed to be done to our house. Those 2 weeks came and went without any contact from Mr. Mumma. I then placed several phone calls to his home/business phone number, leaving messages in June, 2005 and July, 2005 asking Mr. Mumma to please come to our home to finish his work for which he was paid. To date, Mr. Mumma has never returned any of my calls, nor has he made any of the repairs to my home. I have since had several contractors come to our home to give me estimates for the repairs that need to be done, they also pointed out several building code violations in different parts of our home that needed to be addressed immediately for the safety of my family. February, 2006 I filed a complaint against Mr. Mumma in district court, where he agreed that the repairs should have been made, and took responsibility for fixing them. Jason A. Shover ;z." 1. ~ ;') " cP -- -~ -- --"~~.,,.-' '" )-\ , ..... J . ~'"~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JASON SHOVER, v. MUMMA CONSTRUCTION, and MICHAEL MUMMA NO.: 2006-1820 Defendant NOTICE You have been sued in court. If you wish to defend against the claims 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 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 THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, 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 Telephone: 717-249-3166 " . Jason Shover vs. Mike Mumma/Mumma Construction Docket # 06-1820 Civil Complaint 1. Jason Shover 1554 Newville Road Carlisle, P A 17013 2. Mike Mumma/Muma Construction 1316 Honeysuckle Hollow Road Elliottsburg, P A 17024 3. My wife and I contracted with Mr. Mumma to build our house in March, 2004, June, 2004 we moved into our new home, Mr. Mumma repaired some faulty work during the summer of2004 after receiving calls from me. Beginning November, 2004 Mr. Mumma would no longer return or receive any calls from me. December, 2004 my wife and I hired an attorney, Stephen Tiley, to have him attempt to contact Mr, Mumma so that Mr. Mumma may finish our home. May, 2005 Mr. Mumma agreed to come to our house, with an attorney, to look over what needed to be repaired and finished. May, 2005 Mr. Mumma, his attorney, my wife, our attorney and I all met at our house to determine what repairs still needed to be made. Mr. Mumma agreed at that meeting that he would, in 2 weeks, make all of the necessary repairs and finish what needed to be done to our house. Those 2 weeks came and went without any contact from Mr. Mumma. I then placed several phone calls to his home/business phone number, leaving messages in June, 2005 and July, 2005 asking Mr. Mumma to please come to our home to finish his work for which he was paid. To date, Mr, Mumma has never returned any of my calls, nor has he made any of the repairs to my home. I have since had several contractors come to our home to give me estimates for the repairs that need to be done, they also pointed out several building code violations in different parts of our home that needed to be addressed immediately for the safety of my family. February, 2006 I filed a complaint against Mr. Mumma in district court, where he agreed that the repairs should have been made, and took responsibility for fixing them. Jason A. Shover fL" ;/ ~ ~. :r--:c \?~;, ~~~2'{:~;:' '.. ~,~ ,.- 'i;)\Z'.~- _.~~.:". ':-"\"~ 0.- ~.;:1 \. ' , ;.J- :t ~. :0 '.0 C-J ...- - ~:- ~ Q"'\ - ~ ~ ...C> ,.....'~I ~ ~ -;-1': ~).) ~~ .' ~}:~ ,-):3 .' -~ ~~ ~J) h -- -;' ," .r.~.... ,~; L,U ,go- ~ o \ ..J"~'~'~':'" , " :< . I .. ,...~~) fft~ Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JASON SHOVER, and v. MUMMA CONSTRUCTION, and MICHAEL MUMMA NO.: 2006-1820 Defendant VERI FICA TION I, Jason A. Shover, depose and say that I am the Plaintiff in the above matter; and that the facts set forth in the foregoing Complaint are true and correct based partly upon personal knowledge and the remainder upon information and belief; I understand that this Verification is made subject to the penalties of 18 Pa.C.S. ~904, relating to unsworn falsification to authorities. Dated: October ;5, 2006 ~jason{~ ,c " \ f'~., ,~,.... i', '~tJ ,',,' "''l'' t ~" r! t ~ ~ :.:-~ , j " \':, ... ~ ,.- ft.. ...... .-t ;" ~ ~.1 .;~~ : .-t', l..; ~ (0;,' ~ .,.'. 1';,.; .~ '( ".; " ,~ -,', , ",~ ,.,-. (') C. :c:.~. -r-t \=~ ,".\! r.....) '8 Q..... (:::) ,-"l ':.-\ r-,') 6' -0 :;;;. '-:-? ~ .....\ :r....... r\"\ f": -Or'!:' '0 t') .-::.", \ -~',O ',,':: -1"'" -;l~. ~ ''P' ~ 0' cP .' . . .' JASON SHOVER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. MUMMA CONSTRUCTION, and MICHAEL MUMMA NO.: 2006-1820 Defendant CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint on October 26, 2006, by placing a certified true and correct copy of the same in the United States mail, postage pre-paid, addressed to: Mumma Construction 1316 Honeysuckle Hollow Road Elliottsburg, P A 17024 Mr. Michael Mumma 1316 Honeysuckly Hollow Road Elliottsburg, PA 17024 Date: ~v/P~ ~ c?"006 ~e'l Step en-: TiI~Y. Esquire Attorney for Plaintiffs 5 S. Hanover Street Carlisle, PA 17013 (717) 243-5838 Attorney 1.0,#32318 us ,...., = = c::r- o C) -i ~ o -n :r!" n1- ur,:; "'")0 b -,; '-Iel _-1::-t. ':) ...!] -.,..c. csrn ~ ~..o -< N 0"'1 -0 --L;.. (I} U1 0,) Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JASON SHOVER, v. MUMMA CONSTRUCTION, and MICHAEL MUMMA NO.: 2006-1820 Defendant PRJECIPE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Plaintiff, Jason Shover. Dated: /;ki,;2BPh Respectfully submitted, Frey and Tiley, By ~ -4/7.A1 Stephen D. Tiley, Esquire Frey & Tiley Attorneys for the Plaintiff 5 South Hanover Street Carlisle, PA 17013 (717) 243-5838 Supreme Court I.D.#32318 ........, = = en o n -l N 0'"\ -0 ::: o 11 -I :r: r1,:r:l r- -om ::nD ,") . ':::. (I...) l~~i :.'/ C) ::Srn --I > :-:0 -< .r- C) -..l .. JASON SHOVER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. MUMMA CONSTRUCTION, and MICHAEL MUMMA NO.: 2006-1820 Defendant CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Important Notice setting forth intention to file a Praecipe to enter judgment by default pursuant to Rule 237.1(a)(2)(ii) on December 9' , 2006, by placing a true and correct copy of the same in the United States mail, postage pre-paid, addressed (separately) to: Mumma Construction 1316 Honeysuckle Hollow Road Elliottsburg, PA 17024 Mr. Michael Mumma 1316 Honeysuckly Hollow Road Elliottsburg, PA 17024 Date: De'~~ 021 ~p~ ~/~ c;(/. 7 --:-7 Stephen D. Tiley, Esquire Attorney for Plaintiffs 5 S. Hanover Street Carlisle, PA 17013 (717) 243-5838 Attorney I.D.#32318 t Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JASON SHOVER, v. MUMMA CONSTRUCTION, and, MICHAEL MUMMA NO.: 2006-1820 Defendant To: Mumma Construction and Michael Mumma (Defendants) Date of Notice: December 4, 2006 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 OF 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 ABOE TO PROVIDE YOU WITH THE 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 Telephone: 717-249-3166 J ~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JASON SHOVER, v. MUMMA CONSTRUCTION, and MICHAEL MUMMA NO.: 2006-1820 Defendant PRJECIPE TO ENTER JUDGMENT BY DEFAULT TO THE PROTHONOTARY: The Defendants having failed to respond to the Complaint filed in the above captioned matter, and the undersigned having provided at least ten days notice to the Defendants ofthe intention to file this Praecipe (pursuant to Pa. R.C,P. 237.1(a)(2)(ii)), please enter judgment by default against the Defendants in the above captioned matter, in the amount of the prior District Justice Judgment, to wit: $8,157.10, plus costs. Attached hereto is a copy of the Notice given pursuant to Rule 237. 1 (a)(2)(ii) to the Defendants. Dated: December 20,2006 Respectfully submitted, By ~ -f), 7~ Stephen D. Tiley, Esquire Frey & Tiley Attorneys for the Plaintiff 5 South Hanover Street Carlisle, PA 17013 (717) 243-5838 Supreme Court I.D.#32318 " JASON SHOVER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. MUMMA CONSTRUCTION, and MICHAEL MUMMA NO.: 2006-1820 Defendant To: Mumma Construction and Michael Mumma (Defendants) Date of Notice: December 4,2006 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 OF 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 ABOE TO PROVIDE YOU WITH THE 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 Telephone: 717-249-3166 ~ \ ,~ ~ ~ ........ <:>("'\ ~ :0\\ ~ ~ \S ~ , " ~ o ~:; '"'TJi+' ~fL:--" Q~' '" = = O'~' o -'1'1 --I ::c \11;:.:2 -Orn ::')0 '-~~() >!~. '~T-, ~=~ f;: .-:) rn ::-{ J> ..0 --< o r'I'"'; ('"') ", C) -0 ::;; -- ~" N f'V