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Home My WebLink About06-4718 , . .. F:\FILES\DATAFILE\GeneraJ\Current\11371.28-comlltde Revised: August 1:5, 2006 Christopher E. Rice, Esquire J.D. Number 90916 MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 717-243-3341 Attorneys for Plaintiffs MARTS ON DEARDORFF WILLIAMS & OTTO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO.06- 4'11' (3~,;L'-r~ CIVIL ACTION - - \.. STEPHEN J. BARNDT, Defendant NOTICE You have been sued in court. If you wish to defend againstthe claims set forth in the following pages, you must take action within twenty (20) days afterthis 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 ajudgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim orreliefrequested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TIllS 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 ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 MARTS ON DEARDORFF WILLIAMS & OTTO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 06- '-I"IIP {!/ol,L ~fYl..J-1 CIVIL ACTION - - I STEPHEN J. BARNDT, Defendant COMPLAINT AND NOW, comes Plaintiff, by and through its attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and hereby avers as follows: I. Plaintiff, MartsonDeardorffWilliams & Otto (hereinafter, "MDWO"), is a Professional Corporation with a place ofbusiness at 10 East High Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant, Stephen J. Barndt, is an adult individual residing at 170 FranklintownRoad, Dillsburg, Pennsylvania. 3. Defendant signed an engagement letter with Plaintiff, which is a contract between both parties, for Plaintiff to provide legal services to Defendant and for Defendant to pay for said services. A true and correct copy of the letter agreement is attached hereto as Exhibit "A." 4. Plaintiff provided legal services to Defendant with regard to divorce and related matters. 5. At this time, Defendant has an outstanding balanceof$4,038.50, plus interest. A true and correct copy of Plaintiff's invoice is attached hereto as Exhibit "B." 6. Defendant has failed to pay for such services. 7. Despite repeated demands, no payments have been made by the Defendant for the amount due. COUNT I - BREACH OF CONTRACT 8. Plaintiffhereby incorporates byreference the averments contained in paragraphs I through 7 as if fully set forth. 9. Defendant has breached an expressed agreement to pay for services provided to Defendant from Plaintiff and/or Plaintiff's agents. , . WHEREFORE, Plaintiff, Martson Deardorff Williams & Otto, demands judgment against the Defendant in the amount of$4,038.50, plus interest and costs. COUNT 11- QUANTUM MERUIT 10. Plaintiffherebyincorporates byreferencethe averments contained in paragraphs 1 through 9 as if fully set forth. 11. Defendant is liable to the Plaintiff and/or has been unjustly enriched in the amount of $4,038.50, plus interest. WHEREFORE, Plaintiff, Martson Deardorff Williams & Otto, demands judgment against the Defendant in the amount of$4,038.50, plus interest and costs. MARTSON DEARDORFF WILLIAMS & OTTO {]e./yJ... 7 rL- By Christopher E. Rice, Esquire ill Number 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff Date: August 15,2006 . . MDW&O JNFt'R\IATh ),,," . /\IAh:1. . A\lvul'.....Cy AnOKNtYS & COLNSHI.OllS Ar L-\w TEI.ll'HONE F ACS1MIU~ INTERNET (717) 243-3341 1717) 243- J 850 www.mowo.com WIU.lAM F. MARTSON JOHN B. FOWLER IJJ ED'-"ARD L SCHORPP DANIEL K. DEARDORFf TnOMAS J. WILlI'\~S. Ivo V. OlTO III GEORGE B. FALLER JR. '" CARL C. RISCH DAVID A. fnZSI~'()!'<::; DAVID R. GALLOW;') ANTIIONY 1. Lucmo C1-JRISTOPI-fER t. Riel' JENNlft:R L SPEARS HIl.LARY A. DEAN 10 EAST I-IIGH STREf-_T CARUSlL PENNSYLVANIA 17013 .RO,\R1l CUlTlF1F!) CIVIL TRIAL SI'H'IAUSr March 2, 2005 Mr. Stephen J. Barndt 170 Franklintown Road Dillsburg, PA 17019 RE: Our File No. 11371.28 Dear Mr. Barndt: This will confirm that you have engaged Martson Deardorff Williams & Otto in c01111ection with my completion of the above referenced action which was transferred from Metzger Wickersham Knauss & Erb. This letter sets forth our agreement regarding the basis for this representation. Charges for services at Martson Deardorff Williams & Otto are generally based upon (l) the time spent by our attorneys, law clerks, paralegals and other professional staff and (2) hourly rates that vary depending upon an individual's experience and background. Our current rates are One Hundred Twenty-Five($125.00) Dollars to Two Hundred ($200.00) Dollars per hour for shareholders and Ninety-Five ($95.00) Dollars to One Hundred Seventy-Five ($175.00) Dollars per hour for associates. With respect to professional services to be rendered in this matter, the undersigned will serve as the primary attorney from Martson Deardorff Williams & Otto. My current hourly rate is One Hundred Seventy-Five ($175.00) Dollars. In order to apply resources to your fIle in an economic fashion, we may utilize law clerks and paralegals in the performance of your work, at our discretion, and at the rate of $35.00 per hour for law clerks and $45.00 per hour for paralegals. These rates are subject to change, and are ordinarily reviewed on an annual basis. Any revisions will be reflected in our invoices. Martson Deardorff Williams & Otto has agreed to pay a referral fee to Metzger Wickersham Knauss & Erb in return for the referral and transfer of your case. This in no way means you are paying extra attorney fees to Martson Deardorff Williams & Otto or to Metzger Wickersham Knauss & Erb. In addition to time spent actually researching, writing, court appearances, and the like, fee charges will be made for time spent on telephone calls, meetings, internal office conferences between attorneys, travel time, etc. We will bill you monthly for work on a time-expended basis. Costs will also be itemized and billed on a monthly basis. "Costs" are itemized out-of-pocket expenses such as expert witness fees, fIling fees, transcripts, certified mailings, and where required, online research access. EXHIBIT "A" 1 N F () H .\1 A T ION . A D V ICE . A D V 0 C f\ C Y \\1 , ' Mr. Stephen J. Barndt March 2, 2005 Page 2 In some matters, such as litigation, it is not possible to predict accurately the cost involved in performing the services required. We will keep you fully informed of the time used for conferences, telephone calls, drafting documents, research, court time, and necessary travel time. Weare always happy to work with our clients to develop a mutually agreed upon budget which can be updated and revised when circumstances require. We will keep you informed as to the progress of your case. We will send you copies of significant or material papers coming in and out of our office, including relevant correspondence, pleadings, and other court documents. If you have any questions or if anyproblerns develop, please feel free to call this office. If I am unavailable, you should feel free to speak: with my paralegal, Trish Eckenroad. Please keep us fully informed of any developments that may occur in your situation; advise us immediately of any change of address or telephone number Every effort will be made to expedite your case promptly and efficiently according to the highest standards. This engagement agreement may be modified only in writing signed by both of us. If these arrangements are acceptable to you please indicate acceptance by signing at the bottom ofthis letter under the words "ACCEPTED AND AGREED TO" and return the original to us in the stamped, self-addressed envelope enclosed herewith. A copy of this Retainer Agreement is also enclosed for your records. If you would like to discuss this agreement further, please call me at your earliest opportunity. Thank you for placing your confidence in me and this firm. We look forward to a prompt and mutually satisfactory resolution of the referenced file. Very truly yours, MARTSON DEARDORFF WILLIAMS & OTTO J eonifer L. Spears JLS/tde Enclosure ACCEPTED AND AGREED TO: By: ~-~vv- Stephen J. Barndt F:\FILES\DATAALE\Gcnc:ruI\ClIrrenl\11371.28sbl I N FOR "1 A T ION . A D v ICE . A D V 0 CAe Y '" I ' , I \\' '" \. l); j'l \ MDWSto :~~,--C--;\-'-7", r'"n E ,:-. H:C!i .'j';k, If C\Rl.I'iU p~"\'\'~,\"',,\ I 'Oi.: nt:i':\'_''\L 1'7\'7, ~..\.~-,~,~-+l F,',C,i\111L (717) ~~~-l;-o;)t) h i'!T"-,T 'S\\ \~."ld\\ \1,'.'\ '!~l T\\ li)l ,'\;1,( ".1:','" 'I \I1l; fl, ::J-20t:21;/: July 5, 2006 Billed through 07/05/06 19.00 $ 19.00 BILLING SUMMARY Jennifer L. Spears .10 hrs 190 /hr 19.00 ------------ .10 hrs $ 19.00 ------------ $ 19.00 $ 4,019.50 ------------ $ 4,038.50 TOTAL FEES TOTAL CHARGES FOR THIS BILL NET BALANCE FORWARD TOTAL BALANCE NOW DUE EXHIBIT "B" THANK YOU f " 1 r', l{ \1 \ \' I 'i', .. .\ I) \- j (' 1- . A f) \ 0 C ,\ (' Y ...T\f , . \ .~ VERIFICATION The foregoing Complaint is based upon information which has been gathered bymycounsel in the preparation of the lawsuit. The language of the docwnent is that of counsel and not my own. I have read the docwnent and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the docwnent is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities, which provides that ifImakeknowingly false averments, I may be subject to criminal penalties. . J Spears, Esquire ~ ....... ~ ~ 6.J ~ ~ 8 ~ ~ ..... ~ o r f~$ () ~ g ~ <<?" ~ -oeD ~ !ii[""- C 7-':::,-,' C'J -/1'- '?!> r:. ~id c:: 7-. ~ 0"' -0 ~ y. c.n \.P SHERIFF'S RETURN - OUT OF COUNTY " \0 CASE NO: 2006-04718 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MARTSON DEARDORFF WILLIAMS & 0 VS BARNDT STEPHEN J R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BARNDT STEPHEN J but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT & NOTICE On August 31st , 2006 , this office was in receipt of the attached return from YORK 18.00 9.00 10.00 43.47 1.26 81.73/~ 08/31/2006 MDW&O County Sheriff's Costs: Docketing Out of County Surcharge Dep York County Postage So q fa. ;fa" Sworn and subscribe to before me this day of A.D. SHERIFF'S OFFICE 11 50 NORTH DUKE STREET, P.O. BOX 63480, LANCASTER, PENNSYLVANIA 17606-3480 . (717) 299-8200 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN 1 PLAINTIFFISI PLEASE TYPE OR PRINT LEGIBLY. DO NOT DETACH ANY COPIES. 2 COURT NUMBER Stephen J. Barndt SERVE {5 NAME OF INDIVIDUAL. COMPANY. CORPORATION. ETC. TO BE SERVED ~ Stephen J. Barndt ..".. 6 ADDRESS ISlreet or RFD, Apartment No. Cily, Boro. Twp. Slale and ZIP Code) AT 170 Franklintown Road, Dillsburg, PA 17019 ~ ~ 7 INDICATE UNUSUAL SERVICE:)@DEPUTlZE 0 OTHER Now. Auqust 22 20 U6 , I, SHERIFF Op...Ulro~:i"~ COUNTY, PA., do h~~y ~utize the -S T.imr.nRter County to execute this Writ ~~of to law. This deputation being made at the request and risk of the plaintiff.T .;''' .. , SHERIFF OF _ 1"-' COUNT 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITI'tftffR'f1CfE: Cu:cnberland Please mail return of service to Cumberland County Sheri~UNfJank you. 06-4718 civil 4 TYPE OF 'f:1~Tfft~M~AI~TI CA XEXHXl Notice and Canplaint Martson Deardorff Williams & Otto 3 DEFENDANT 151 ADVANCE FEE PAID BY CUMBERLAND CO. SHERIFF. NOTE ONL Y APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any depuly sheriff levying upon or allachlng allY property under within writ may leave same without a watchman. in custody 01 whomever IS lound In possession, alter notifying person ollevy or attachment. wllhoulliablhly on the part 01 such deputy or IhE' sherill to any plaintiff herein lor any loss, destruction or removal of any such property before shenll's sale thereol 9. SIGNATURE 01 ATTORNEY or other ORIGINATOR / fA ~ (' 10 TELEPHONE NUMBER I~ D.t\ TE Christopher E. Rice, Esquire ~~_ ~ 717-243-3341 ~~l~ 12. SEND NOTICE OF SERVICE COpy TO NAME AND ADDRESS BELOW: (This area must be completed ii' notice is to be mail.d)----. Christopher E. Rice, Esquire 10 East High Street Carlisle, PA 17013 SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE NAME 01 Authorized LCSO Deputy or Clerk ~4 Date Received - 13 I acknowledge receipt of the wnt. l or complaint as indicated alJove f M J M C G ILL Y C S 0 / 2 0 0 6 ~_ 9 1 5 2 0 0 6 16 I hereby CERTIFY and RETURN that I~ave personally served, 0 have legal eVidence of service as shown In 'Remarks", cJ have executed as shown In "Remarks". the wnt or complaint describeo on the individual. company, corporation, etc. at the address shown above or on the indiVidual, company cor- poraliOn. elc. at the address ,nserted below by handing a TRUE and ATTESTED COpy thereat ") . 17 0 I hereby. certlty an re rn a NOT FOUND because I am unable to locate the individual, company. 18 Name and tilf not shown above) (Relalionship to Defendant) 8/16/2006 CUMBERLAND CO. SHERIFF E xp"atlon/Heanng date Z e (complele only If differentlhan shown above) (Street or RFO, Apartment No corporation, etc. named abo~e ISee remarks below) -~j No Service----- ~ See Remar1o;s Below {~O 30} . City, Bora Twp 21 Dale 01 Service 22 Time cJJt!~ ~ EOST 23 ATTEMPTS I 24. Advance Cosls D.p. Int. 34 day of Total Costs 29 __J ~ ~"Lf , )t-5,co '-t ?J lY -7 ~b~~::~'~~ 30 REM$1Kcro .00 YO R K CO. CO S T S STA: r-. '.'O""f'''C'-~':_''.'''"\~P;::?-\.]h.l'''''Y CVMLVI' 1~\J"Fi"'L:H \.J. ,._1'" , 31 AFFIRMED an~ ""''''C''g9Q 37 MY COMMISSION , WHITE - Issuing Authority 2. PINK. Attorney 3. CANARY. Sheriff's Office 4. BLUE. Sheriff's Office LL- ~ cc. w .P~ UJ .J) ...'1: >~.~ w~::.: u' LJ (C p:> 0.. ('I c-..J c.!? :1 t, . L (.:) -.,-:.) (:.:-::1 c::--> c--J . . Christopher E. Rice, Esquire I.D, Number 90916 MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PAl 7013 717-243-3341 Attorneys for Plaintiffs MARTSON DEARDORFF WILLIAMS & OTTO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, NO. 06 - 4718 CIVIL ACTION STEPHEN J. BARNDT, Defendant PRAECIPE TO THE PROTHONOTARY: Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant in the amount of$4,038.50, plus interest and costs of suit as prayed for in the Complaint, for failure to file an Answer to Plaintiffs Complaint. I do hereby certify that a written notice of intention to file this Praecipe was mailed to the Defendant at the address indicated thereon, on September 15, 2006, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTS ON, DEARDORFF, WILLIAMS & OTTO By c-e4L f K- Christopher E. Rice, Esquire J.D. Number 90916 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Dated: / p _ '7 - () /p , FIFILESIDA T AFILEIGenerallCurrentll1J7128.lOdaynoticeltde Revised: September 15. 2006 Christopher E, Rice, Esquire 1.0. Number 90916 MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 717-243-3341 Attorneys for Plaintiffs MARTSON DEARDORFF WILLIAMS & OTTO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 06 - 4718 CIVIL ACTION STEPHEN 1. BARNDT, Defendant IMPORTANT NOTICE TO: STEPHEN J. BARNDT DATE OF NOTICE: September 15, 2006 170 Franklintown Road, DiIlsburg, P A 17019 YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITTEN WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DA YS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE 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 MA Y BE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MA Y OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PAl 7013 Telephone:(717) 249-3166 MARTS ON DEARDORFF WILLIAMS & OTTO By Ci? .JrL 5'. R~ Christopher E. Rice, Esquire CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTS ON DEARDORFF WILLIAMS & OTTO, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Mr. Stephen J. Barndt 170 Franklintown Road Dillsburg, P A 17019 MARTSON DEARDORFF WILLIAMS & OTTO By A- r L^(Q~ Mary . Price Ten E st High Street Carlisle, P A 17013 (717) 243-3341 Dated: /0 J s-j () ~ Christopher E. Rice, Esquire LD. Number 90916 MARTS ON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 717-243-3341 Attorneys for Plaintiffs MARTS ON DEARDORFF WILLIAMS & OTTO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 06 - 4718 CIVIL ACTION STEPHEN 1. BARNDT, Defendant AFFIDAVIT AS TO MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) Christopher E, Rice, Esquire, being duly sworn according to law, deposes and says that he has authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and belief, the Defendant above named is not in the military service of the United States of America, that he has knowledge that the said Defendant is now living at: 170 Frank1intown Road, Dillsburg, P A 17019. Said Defendant's place of employment is unknown, ~4-L \-fL Christopher E. Rice, Esquire Sworn to and subscribed before me this j7}v day of OcJob er, 2006. ~ 'ttO~ Not ublic ( COMMONWEALJ 11 Ul' I'LNNSYLVANIA Notarial Seal lI.1ary M. Price, Notary Public Carlisle .Boro, Cumberland County My Commission Expires Aug. 18, 2007 Member. PennSvlvanla ASsoclallon of Notaries , . ' ~ Christopher E. Rice, Esquire J.D. Number 90916 MARTS ON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, P A 17013 717-243-3341 Attorneys for Plaintiffs MARTSON DEARDORFF WILLIAMS & OTTO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 06 - 4718 CIVIL ACTION STEPHEN J. BARNDT, Defendant COMMONWEALTH OF PENNSYLVANIA ) : SS COUNTY OF CUMBERLAND ) Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he is an employee of MARTS ON, DEARDORFF, WILLIAMS & OTTO, attorneys for the Plaintiffin the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, a notice of intention to enter default judgment against the Defendant was given to him by mail on September 15, 2006. CeM f;-L Christopher E. Rice, Esquire Sworn to and subscribed before me this stL day of @r~ , 2006. ~yt(_iQ~ Not~UbliC MONWl::ALlI1 01 I'l:NNSYLYANIA Notarial Seal Mary M. Price, Notary Public Carlisle Boro, Cumberland County My Commission Expires Aug. 18. 2007 Member, PennsylvanlB A..cellltlon at Notaries Christopher E. Rice, Esquire J.D. Number 90916 MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PAl 70 13 717-243-3341 Attorneys for Plaintiffs MARTS ON DEARDORFF WILLIAMS & OTTO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 06 - 4718 CIVIL ACTION STEPHEN J. BARNDT, Defendant TO: STEPHENJ.BARNDT,DEFENDANT NOTICE OF ENTRY OF DEFAULT JUDGMENT You are hereby notified that on the~I)+,,- day of {f2 ,..{ ,2006, the following Judgment was entered against you in the above-captioned action: judgment in the amount of$4,038.50, plus interest and costs of suit as prayed for in the Complaint for failure to file an Answer to Plaintiffs Complaint. Date: I () - t)~ 110- , 9 -lM~ kL Prothonotary . 0' ~ I hereby certify thatthe name and address ofthe proper person to receive this notice under Pa. R. Civ, P. 236 is: Stephen J. Barndt 170 Franklintown Road Dillsburg, P A 17019 ~~}~ ~ 2fJ y ~ -.j ~ d ~ \ ~ 0- 1:' n c,:.. <~ 1'-':> c:::.::- c..:~ C1''' c' -1'1 :.:;:! C) <. ; 1 \1 ".~l I en :.C: C) ct. ~:o .<