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HomeMy WebLinkAbout02-2031IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL T. DECKMAN CIVIL ACTION - LAW 5 North Stoner Avenue Shiremanstown, PA 17011 Plaintiff NO. Q? - -W31 vs. RON HEDGES and CELESTE HEDGES, 3008 Harvard Avenue Camp Hill, PA 17011 Defendants NOTICE TO PLEAD 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 of 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL T. DECKMAN CIVIL ACTION - LAW 5 North Stoner Avenue Shiremanstown, PA 17011 Plaintiff NO. 02-2031 Civil VS. RON HEDGES and CELESTE HEDGES, 3008 Harvard Avenue Camp Hill, PA 17011 Defendants PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter Default Judgment in favor of the Plaintiff, Michael T. Deckman, and against Defendants Ron Hedges and Celeste Hedges, jointly and severally, for their failure to plead to the Complaint in this Action within the required time. The Complaint contains a Notice to Defend within twenty (20) days of the date of service thereof. The Defendants were served with the Complaint by the Sheriff on May 2, 2002 and their answers were due to be filed on May 22, 2002. To date, Defendants have not filed or served their answers to the Plaintiff s complaint. Please assess damages and enter Judgment against the Defendants, jointly and severally, in the following amount, being the amount demanded in the Complaint: Amount of debt as stated in Complaint $13,372.50 Interest from July 21, 2001 $ 740.63 Balance as of June 18, 2002 $14,113.13 I certify that a written Notice of Intention to file this Praecipe was mailed to the Defendants after the date default occurred and at least ten days prior to the date of the filing of this Praecipe. Copies of said Notices of Intention to file the Praecipe are attached hereto as Exhibits A and B. LAW OFFICE OF ROBERT P. REED BY: ;'?%"- Robert P. Reed, Esquire P.O. Box 6034 Harrisburg, PA 17112 717 909-6637 Attorney's I.D. No. 15624 Counsel for Plaintiff c oa Dated: ? r / o EXHIBIT A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL T. DECKMAN CIVIL ACTION - LAW 5 North Stoner Avenue Shiremanstown, PA 17011 Plaintiff NO. 02-2031 Civil VS. RON HEDGES and CELESTE HEDGES, 3008 Harvard Avenue Camp Hill, PA 17011 Defendants Dated: May 30, 2002 TO: Ron Hedges 3008 Harvard Avenue Camp Hill, PA 17011 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717 249-3166 800 990-9108 LAW OFFICE OF ROBERT P. REED BY: Robert P. Reed, Esquire P.O. Box 6034 Harrisburg, PA 17112 717 909-6637 Attorney's I.D. No. 15624 Counsel for Plaintiff Dated: 5 -'A0 e o7 CERTIFICATE OF SERVICE AND NOW on this i"xy of May, 2002 I Robert P. Reed, Esquire, hereby certify that I served the within Ten Day Notice this day by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Ron Hedges 3008 Harvard Avenue Camp Hill, PA 17011 LAW OFFICE OF ROBERT P. REED BY: Robert P. Reed, Esquire P.O. Box 6034 Harrisburg, PA 17112 717 909-6637 Attorney's I.D. No. 15624 Counsel for Plaintiff EXHIBIT B IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL T. DECKMAN CIVIL ACTION - LAW 5 North Stoner Avenue Shiremanstown, PA 17011 Plaintiff NO. 02-2031 Civil VS. RON HEDGES and CELESTE HEDGES, 3008 Harvard Avenue Camp Hill, PA 17011 Defendants Dated: May 30, 2002 TO: Celeste Hedges 3008 Harvard Avenue Camp Hill, PA 17011 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717 249-3166 800 990-9108 LAW OFFICE OF ROBERT P. REED BY: 24-4 -/- 264!! Robert P. Reed, Esquire P.O. Box 6034 Harrisburg, PA 17112 717 909-6637 Attorney's I.D. No. 15624 Counsel for Plaintiff Dated: 5--- 30 - 6 ;? CERTIFICATE OF SERVICE AND NOW on this day of May, 2002 I Robert P. Reed, Esquire, hereby certify that I served the within Ten Day Notice this day by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Celeste Hedges 3008 Harvard Avenue Camp Hill, PA 17011 LAW OFFICE OF ROBERT P. REED BY: 44i? e%'& Robert P. Reed, Esquire P.O. Box 6034 Harrisburg, PA 17112 717 909-6637 Attorney's I.D. No. 15624 Counsel for Plaintiff CERTIFICATE OF SERVICE AND NOW on this Zay of June, 2002 I Robert P. Reed, Esquire, hereby certify that I served the within Praecipe for Entry of Default Judgment this day by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Ron Hedges 3008 Harvard Avenue Camp Hill, PA 17011 Celeste Hedges 3008 Harvard Avenue Camp Hill, PA 17011 LAW OFFICE OF ROBERT P. REED BY: A 9!% Robert P. Reed, Esquire P.O. Box 6034 Harrisburg, PA 17112 717 909-6637 Attorney's I.D. No. 15624 Counsel for Plaintiff ? ? ? (? f? rv -n ? ?1 I- ?... ?J ? "V ? rl .` \'' -j L : 7 n ?` •? . ??j /? ? _n y :n " J .? -G THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717 249-3166 800-990-9108 LAW OFFICE OF ROBERT P. REED BY: its Robert P. Reed, Esquire P.O. Box 6034 Harrisburg, PA 17112 717 909-6637 Attorney's I.D. No. 15624 Counsel for Plaintiff Dated: f -a y -0,? NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la facha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una Orden contra usted sin previo aviso o notificacion y por cualquier quaja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA SE PUEDE CONSEGUIR ASISTENCIA LEGAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717 249-3166 800-990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL T. DECKMAN CIVIL ACTION - LAW 5 North Stoner Avenue Shiremanstown, PA 17011 Plaintiff NO. Q :?L-? vs. RON HEDGES and CELESTE HEDGES, 3008 Harvard Avenue Camp Hill, PA 17011 Defendants COMPLAINT AND NOW, comes the Plaintiff by his Attorney, Robert P. Reed, Esquire, and makes claim against the Defendants as follows: 1. Plaintiff, Michael T. Deckman, is an adult individual residing at 5 North Stoner Avenue, Shiremanstown, Cumberland County, Pennsylvania 17011. 2. Defendants, Ron Hedges and Celeste Hedges, are adult individuals residing at 3008 Harvard Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The events and occurrences hereinafter related took place at or about 12:15 p.m. on Saturday, July 21, 2001 in the 200 block of East Main Street in the borough of Shiremanstown, Cumberland County, Pennsylvania. 4. At the time and place aforesaid, the Plaintiff was the owner and operator of a 1997 Honda Accord sedan bearing Pennsylvania registration number FN422K, which he was then and there operating in a westerly direction in the travel lane of the aforesaid East Main Street. 5. At the time and place aforesaid, Defendant Ron Hedges was the operator of a 1995 Nissan Pathfinder bearing Pennsylvania registration number DFA6356 which was then and there facing westbound in the parking lane of the aforesaid East Main Street while said Defendant prepared to enter the travel lane of East Main Street. 6. At the time and place aforesaid, Defendant Celeste Hedges was the owner of the aforesaid 1995 Nissan Pathfinder then being operated by her husband, Ron Hedges, and was present in said vehicle in a passenger's seat. 7. At the time and place aforesaid, Defendant Ron Hedges suddenly, and without warning, maneuvered his vehicle from the parking lane into the travel lane of East Main Street immediately into the path of the Plaintiff's vehicle, resulting in a collision between the right front of the Plaintiff's vehicle and left rear of the Defendants' vehicle. 8. As a result of the aforesaid collision, Plaintiff's vehicle was damaged to such a severe extent that the costs of repair exceeded the fair market value of said vehicle, rendering it a total loss. 9. At the time of its destruction, the Plaintiff's vehicle had a fair market value of $15,025.50. Salvage was realized in the sum of $2,092 resulting in net vehicle loss of $12,933.50. 10. As a result of the aforesaid collision Plaintiff incurred towing and storage fees in the sum of $209. 11. As a result of the aforesaid collision, Plaintiff received personal injuries preventing him from pursuing his normal employment for a period of two (2) days and resulting in the loss of $230 in wages. 12. As a result of the aforesaid collision Plaintiff's total damages amounted to the sum of $13,372.50. COUNTI MICHAEL T. DECKMAN. PLAINTIFF V. RON HEDGES. DEFENDANT 13. The averments contained in paragraphs one through twelve are incorporated herein by reference as though set forth at length. 14. The aforesaid collision was caused solely by the negligence, carelessness and recklessness of the Defendant, Ron Hedges, in that he: a. Operated his vehicle without keeping a careful and prudent lookout for approaching traffic; b. Maneuvered his vehicle from the parking into the travel lane of East Main Street without first checking to see if said maneuver could be performed in safety; c. Failed to yield to the right of way of the Plaintiff; d. Cut off the assured clear distance of the Plaintiff; e. Effected a change of lanes without first signaling approaching traffic of his intention to do so; f. Failed to operate his vehicle so as to avoid injury to others. 15. Despite being asked to do so, Defendant Ron Hedges has refused and continues to refuse to pay the just claim of the Plaintiff. WHEREFORE, Plaintiff demands judgment against Defendant Ron Hedges in the sum of $13,372.50 together with interest from July 21, 2001, and the costs of this action, which sum is within the arbitration limits for Cumberland County. COUNT II MICHAEL T. DECKMAN. PLAINTIFF V. CELESTE HEDGES. DEFENDANT 16. The averments contained in paragraphs one through fifteen above are incorporated herein by reference as though set forth at length. 17. At the time of the events giving rise to this cause of action Defendant Ron Hedges was an unlicensed driver, his Pennsylvania registration having been suspended or revoked. 18. It is believed and therefore averred that Defendant Celeste Hedges, at all times material to the Plaintiff's cause of action, was aware that her husband, Defendant Ron Hedges, was an unlicensed driver. 19. Despite the knowledge that her husband, Ron Hedges, was an unlicensed driver Defendant Celeste Hedges knowingly permitted her husband, Defendant Ron Hedges, to operate her 1995 Nissan Pathfinder, which conduct constitutes a violation of 75 Pa. C.S.A. Section 1574, a copy of which is attached hereto as Exhibit A. 20. Under the terms of the aforesaid 75 Pa. C.S.A. Section 1574 Defendant Celeste Hedges is jointly and severally liable with her husband, Defendant Ron Hedges, whose negligence, carelessness and recklessness resulted in the aforesaid collision giving rise to this cause of action. WHEREFORE, Plaintiff demands judgment against Defendant Celeste Hedges, in the sum of $13,372.50 together with interest from July 21, 2001 and the costs of this action, which sum is within the arbitration limits for Cumberland County. LAW OFFICE OF ROBERT P. REED BY: Robert P. Reed, Esquire P.O. Box 6034 Harrisburg, PA 17112 717 909-6637 Attorney's I.D. No. 15624 Counsel for Plaintiff Dated: Z/_ eC y' 9 2- EXHIBIT A PA ST 75 Pa.C.S.A. § 1574 75 Pa.C.S.A. § 1574 Page 1 PURDON'S PENNSYLVANIA STATUTES AND CONSOLIDATED STATUTES ANNOTATED PURDON'S PENNSYLVANIA CONSOLIDATED STATUTES ANNOTATED TITLE 75. VEHICLES PART H. TITLE. REGISTRATION AND LICENSING CHAPTER 15. LICENSING OF DRIVER SUBCHAPTER C. VIOLATIONS Copr. © West Group 2002. All rights reserved. Current through End of the 2001 Regular Session S 1574. Permittine unauthorized person to drive (a) General rule.-No person shall authorize or permit a motor vehicle owned by him or under his control to be driven upon any highway by any person who is not authorized under this chapter or who is not licensed for the type or class of vehicle to be driven. (b) Penalty.-Any person violating the provisions of subsection (a) is guilty of a summary offense and shall be jointly and severally liable with the driver for any damages caused by the negligence of such driver in operating the vehicle. CREDIT(S) 1996 Main Volume 1976, June 17, P.L. 162, No. 81, § 1, eff. July 1, 1977. <General Materials (GM) - References, Annotations, or Tables> HISTORICAL AND STATUTORY NOTES 1996 Main Volume Prior Laws: 1959, April 29, P.L. 58, § § 622, 626 (75 P.S. § § 622, 626). 1951, Aug. 24, P.L. 1368, § § 8, 12. 1929, May 1, P.L. 905, art. VI, § § 618, 622 (75 P.S. § § 211, 233). 1927, May 11, P.L. 886. 1923, June 14, P.L. 718, § 12. 1919, June 30, P.L. 678, § 14. CROSS REFERENCES Summary offense, defined, see 18 Pa.C.S.A. S 106. Copr. C West 2002 No Claim to Orig. U.S. Govt. Works VERIFICATION I, Michael T. Deckman hereby swear or affirm that the facts set forth in the foregoing Complaint are true and correct to the best of my information, knowledge and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unswom falsification to authorities. Dated: (4 , a - ' ?? Michael T. Deckman ? ? ?;°? cT rv ?';? ?-,. ? \ ? ? ? ` Z' L ?- -'? ? ? ? ? N ?;? V ? _ i L] ?r ??wv?`,{? . ?? ? n ,? c?a ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Raymond Muniz Plaintiff VS. Aaron Cluck, Defendant File No.: 02 - 2131 Civil Action -Tort PRAECIPE TO ATTACH VERIFICATION To the Prothonotary: Please attach the executed Verification of Plaintiff Raymond Muniz, to the Complaint filed May 1, 2002. Perry A. H1 r. Bar No.: 26 2 P.O. Box 265 Red Lion, PA 17356-0265 (717) 265-1234 CERTIFICATE OF SERVICE I hereby certify that a copy of the above Praecipe and the attached Verification was mailed postage prepaid to: Aaron Cluck 1732 Cushing Green Camp Hill, PA 17011 Perry VERIFICATION I, the undersigned, Raymond Muniz, hereby affirm that the facts contained in the foregoing Com?xt are true and correct to the best of my knowledge information and belief. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to Date: D o rv m . A rn cr: co ,e SHERIFF'S RETURN - REGULAR CASE NO: 2002-02031 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DECKMAN MICHAEL T VS HEDGES RON 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 HEDGES RON the DEFENDANT , at 2032:00 HOURS, on the 2nd day of May , 2002 at 3008 HARVARD AVENUE CAMP HILL, PA 17011 by handing to HEDGES 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 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this I7'=., day of hL" a2l9U? A. D. Prot otary So Answers: R. Thomas Kline 05/03/20 ROBERT R By: SHERIFF'S RETURN - REGULAR CASE NO: 2002-02031 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DECKMAN MICHAEL T VS HEDGES RON ET 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 HEDGES CELESTE the DEFENDANT at 2032:00 HOURS, on the 2nd day of April 2002 at 3008 HARVARD AVENUE CAMP HILL, PA 17011 by handing to CELESTE HEDGES a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this /7`H day of Jv0,2 A. D. Prothonotary' So Answers: R. Thomas Kline 05/03/2002 ROBERT REED By: Awi) t Deputy Sheriff w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL T. DECKMAN CIVIL ACTION - LAW 5 North Stoner Avenue Shiremanstown, PA 17011 Plaintiff NO. 02-2031 Civil VS. RON HEDGES and CELESTE HEDGES, 3008 Harvard Avenue Camp Hill, PA 17011 Defendants Dated: May 30, 2002 TO: Celeste Hedges 3008 Harvard Avenue Camp Hill, PA 17011 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717 249-3166 800 990-9108 LAW OFFICE OF ROBERT P. REED O!p BY: Robert P. Reed, Esquire ' P.O. Box 6034 Harrisburg, PA 17112 717 909-6637 Attorney's I.D. No. 15624 Counsel for Plaintiff Dated: 5-- 30 - O ;( CERTIFICATE OF SERVICE AND NOW on this :?,fjcday of May, 2002 I Robert P. Reed, Esquire, hereby certify that I served the within Ten Day Notice this day by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Celeste Hedges 3008 Harvard Avenue Camp Hill, PA 17011 LAW OFFICE OF ROBERT P. REED BY: %e? Robert P. Reed, Esquire P.O. Box 6034 Harrisburg, PA 17112 717 909-6637 Attorney's I.D. No. 15624 Counsel for Plaintiff ? LJ ;] f.. ?4 ',; _ J , °? ,. r?-- `; ? .. ..? ., -' -? C -tt? .,? G; ? y --C f,3 -?- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL T. DECKMAN CIVIL ACTION - LAW 5 North Stoner Avenue Shiremanstown, PA 17011 Plaintiff NO. 02-2031 Civil VS. RON HEDGES and CELESTE HEDGES, 3008 Harvard Avenue Camp Hill, PA 17011 Defendants Dated: May 30, 2002 TO: Ron Hedges 3008 Harvard Avenue Camp Hill, PA 17011 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717 249-3166 800 990-9108 LAW OFFICE OF ROBERT P. REED BY: Robert P. Reed, Esquire P.O. Box 6034 Harrisburg, PA 17112 717 909-6637 Attorney's I.D. No. 15624 Counsel for Plaintiff Dated: 5- - 30 - ©o7 CERTIFICATE OF SERVICE AND NOW on thisy of May, 2002 I Robert P. Reed, Esquire, hereby certify that I served the within Ten Day Notice this day by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Ron Hedges 3008 Harvard Avenue Camp Hill, PA 17011 LAW OFFICE OF ROBERT P. REED BY: ? 5j4 Robert P. Reed, Esquire P.O. Box 6034 Harrisburg, PA 17112 717 909-6637 Attorney's I.D. No. 15624 Counsel for Plaintiff C-) CD c. V r, - pC _1, SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-02031 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIBANK N A VS ALLISON PEGGY R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT ALLISON PEGGY but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT NOT FOUND , as to , ALLISON PEGGY HASN'T LIVED AT 6304 VALLEYBROOK FOR OVER 2 YEARS. FORWARDING ORDER AT POST OFFICE HAS EXPIRED. Sheriff's Costs: Docketing 18.00 Service 6.90 Not Found 5.00 Surcharge 10.00 nn So answers R. Thomas ine Sheriff of Cumberland County WELTMAN WEINBERG REIS 11/06/2002 Sworn and subscribed to before me this 7 ? day of 020V-21 A. D. 11 1 0, Pro notary r -.i w ?.i r r Law Office of Robert P. Reed Robert P. Reed, Esquire 1983 Mannsville Road Elliottsburg, PA 17024 717 582-3008 Attorney's I.D. No. 15624 Email: reedlaw@hughes.net IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL T. DECK-MAN Plaintiff vs. RON HEDGES and CELESTE HEDGES, Defendants CIVIL ACTION - LAW No.: 02-2031 Civil PRAECIPE FOR SATISFACTION OF JUDGMENT TO: Curtis R. Long, Prothonotary: Mark the judgment in this action satisfied upon payment of your costs only. LAW OFFICE OF ROBERT P. REED v BY: Robert P. Reed, Esquire 1983 Mannsville Road Elliottsburg, PA 17024 717 582-3008 Attorney's I.D. No. 15624 Counsel for Plaintiff Dated: /0 CERTIFICATE OF SERVICE And now, on this /L` day of March, 2008, I, Robert P. Reed, Esquire, hereby, certify that I served the within Praecipe for Satisfaction of Judginent this day by depositing the same in the United States snail, postage prepaid in New Bloomfield, Pennsylvania addressed to: Ronnie and Celeste Hedges 45 Colgate Drive Camp Hill, PA 17011 LAW OFFICE OF ROBERT P. REED BY: Robert P. Reed, Esquire 1983 Mannsville Road Elliottsburg, PA 17024 717 582-3008 Attorney's I.D. No. 15624 Counsel for Plaintiff ? ? 1i°j` r-?F. I- ° ?_? ? ?. ?' "-I ? ? d ? .4??f;, 7 • ? t. _ . L7 7 .jl ,? ,?•• ? ••,`