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Home My WebLink About99-0738077 `i i i r i? J f I N T H E 0 0 0 R T O F C 0 M M 0 N P L E A S. ` C U M B E R L A N D 0 0 0 N T Y, P E N N S Y L V A N I A CIVIL DIVISION NO. 99-7380 PATTI REYNOLDS(plaintiff) (formally Patti Freeman) VS. ZACK BROWN (defendant) ANSWER TO WRIT OF REVIVAL TO THE HONORABLE JUDGES,OF THE SAID COURT: PETITIONER Zack Brown, pro se, hereby moves and represents: 1. Petitioner admits to original cash loan he obtained from plaintiff, Patti Reynolds, aka, Patti Freeman. 2. Original loan for the amount of $2500.00; loan was consumated in 1985. 3, Petitioner was represented by counsel, Sam Milkes, (c/o Jacobsen K M.), 52 High St., Carlisle, PA 17013, (717)249 6427. 4. Petitioner avers that plaintiff admitted in open court that defendant made payments of $125.00 cash per month, and one $800.00 cash payment in '97 in the the court of Honorable Kevin Hess. 5. Petitioner avers 15 payments at $125.00 were made to plaintiff. 6. Petitioner avers that a total of $2775.00 cash was paid to plaintiff which satisfies debt; paid in full. 7. Petitioner claims collateral estoppleto writ of revival.EXH'A' B. In an effort for fair play petitioner would now, pursuant to Rule 105(b), request enlargement of time in order to proced with this matter upon his release from confinement; SCI Camp Hill. WHEREFORE in regard to the foregoing information the pettitoner prays this Honorable Court to grant. enlargement of time; a continuance until release from confinement. Respectfully Submitted, Defendant-Zack brown EXH'A' Patti Reynolds (formerly Patti A. Freeman) Plaintiff VS. Zack Brown Penna. State Correctional Institution P. O. Box 8837, Lisburn Road Camp Hill, Pa. 17011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-7380 CIVIL TERM 19 WRIT OF REVIVAL TO Zack Brown Pennsvlvnia State Correctional Institution P O Box 8837 Lisburn Road, Camp Hill, Pa. 17011 You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the judgment entered to NO. 94-5697 CIVIL TERM 19 The Plaintiff claims that the amount due and unpaid is $_2,545.00 with interest from February 15. 1990. You are required within twenty (20) days after service of this Writ to file an answer or otherwise, plead to this Writ. If you fail to do so, judgment of revival will be entered. $ 87.45 Pd Atty Costs $ 47-50 n. J r„Gt, $ 2.00 County Due Date Dprembpr 8 19-gg Seal _ Carol J. Lindsay, Esq. Attorney for-the Plaintiff 11 Pa High Street Carlisle, Pa. 17013 (717) 243-5513 Curtis R. Long PROTHONOTARY ?La?.Lnc. `77ccGQ...? D P Y T R1IE C 0 P Y ER0M REEC0 D In Tnflfft.nmy Wi1di C.^..f, { t G• unto WI my (land and tho s ::l rf &';iu cclurt at U..riis;4, f tq. This et- day o 9?fd>,?-n1?? Prothon ky f N?. (( OFFICE ^.F T°r ^il.^.'jIFF :'? 7 DEC I() 119 SHERIFF'S RETURN - REGULAR CASE NO: 1999-07380 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REYNOLDS PATTI VS. BROWN ZACK CPL MICHAEL BARRICK , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF REVIVAL was served upon BROWN ZACK the defendant, at 12:35 HOURS, on the 16th day of December 1999 at PA STATE CORRECTIONAL INSTITUT P 0 BOX 8837 LISBURN RD CAMP HILL, PA 17011 CUMBERLAND County, Pennsylvania, by handing to ZACK BROWN a true and attested copy of the WRIT OF REVIVAL and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answ s Docketing 18.00 Service 8.68 Affidavit .00 Surcharge 8.00 omas ine, eri $3768-FLOWER, FLOWER, LIND Y _ 1LOWER 999 F/?jJ// /• by epu y eri_ Sworn and subscribed to before me this /N day of W .2&co A. D. a 1 ,?p nY rro on aT y . Patti Reynolds :IN THE COURT OF COMMON (formerly Patti A. Freeman), :PLEAS OF CUMBERLAND Plaintiff :COUNTY, PENNSYLVANIA q q- -7 5 8 0 ?cLI T, V. :NO.612 CIVIL TERM 1990 Zack Brown, qy. 56 97 OcZ,--; T Defendant PRAECIPE FOR WRIT OF REVIVAL To the Prothonotary: Issue writ of revival of judgment entered to the Court of Common Pleas of Cumberland County, Pennsylvania No. 612 Civil 1990 and index it in the judgment index against Zack Brown in the amount of $2,545.00 with interest from Feb. 15, 1990. Carol #ay s(Attorney for Plaintiff) s ? 14 C' cz?' T' n 1? ?`. coT `? y a s `n cl: h j< CI ? LL L•.. L !'JW 4J _7] l1 C: C pi U J IN THE COURT OF COMMON PLEAS OF Patti Reynolds (formerly Patti A. Freeman) Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW Zack Brown Penna. State Correctional Institution N0,99-7380 CIVir TERM 19_ P. O. Box 8837, Lisburn Road Camp Hill, Pa. 17011 'BRIT OF REVIVAL TO Zack Brown Pennsvlvnia State Correctional institution p.. 0. Box 8837 Lisburn Road Camp Hill Pa. 17011 You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the judgment entered to NO. 94-5697 CIVIL TERM 19_ The Plaintiff claims that the amount due and unpaid is $ 2,545.00 with interest from F br+arv 15, 1990 You are required within twenty (20) days after service of this :brit to file an answer or otherwise, plead to this Writ. if you fail to do so, judgment of revival will be entered. $ 87.45 Pd Atty Costs $ a? sn n .T_ r„<rs $ 2.00 County Due _ Curtis R. Long PROTHONOTARY Date npremrer 8 19•S2 D P Y Seal Carol J. Lindsay, Esq. Attorney for the Plaintiff 11 East High street Carlisle, Pa. 17013 (717) 243-5513 1 I LAW OFFICES . ,Hi1FF,'FLOWER & LINDSAY 2109MARKEI'SiREEr to 17013 , 'CAMP HILL. PA 17011 243.6222 ' PHONE (717) 737.3405 PATTI A. FREEMAN, Plaintiff VS. ZACK BROWN, Defendant CF COPY: ` ?. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW REVIVAL OF JUDGMENT No. 99-7380 Civil Term REPLY TO ANSWER TO WRIT OF REVIVIAL To the extent that Defendant's Answer may contain New Matter, in the nature of an averment that payments were made to Plaintiff since revival of the captioned judgment was ordered on the 19" day of August, 1996, such averment is denied. // 0Cl Zeol Respectfully submitted, FLOWER, FLOWER & LINDSAY Attorneys for Plaintiff L X 3 Carol J. Lind y,Esquire 11 East High_ treet Carlisle, PA 17013 (717) 243-5513 I.D. #44693 PATTI A. FREEMAN, VS. ZACK BROWN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW NO. 99.7380 CIVIL TERM Defendant : CERTIFICATE OF SERVICE AND now, this day of 2001, I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, SHUFF, FLOWER & LINDSAY, P.C., Attorneys, hereby certify that I served the within REPLY TO ANSWER TO WRIT OF REVIVAL this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Zach Brown Pennsylvania State Correctional Institution P. O. Box 8837 Lisburn Road Camp Hill, PA 17011 SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff SAIDIS, SHUFF & MASLAND 26 W. High Street Carlisle, PA By: Carol J. Lindsay, Esquire ID# 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 it ,'.1 L: 1? ? l'I `f _1?-+ i,? YI _? f?. _- ' _ rt.Ll _. t_)