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Home My WebLink About03-6204 WAYNEF.SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania l7013 N.L. MINICH & SONS, INC., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW ; NO. 03- (p.o cjcrvIL TERM v. ROBERT HOCUTT and JEAN R. HOCUTT, 125 Richland Road Carlisle, Pennsylvania 17013 Defendants PRAECIPE FOR WRIT OF REVIVAL TO: Curtis R. Long, Prothonotary Please issue writ of revival of the judgment at No, 263 Civil 1993 as revived at No. 98-7116 Civil Tern1. The revival is in the amount of$5,997.38 plus interest at the rate of 6% per annum from March 26, 2003, and costs. Date: November 26, 2003 ~~baG~ Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff ~ ~ C- .-J -----1'- i-t- ;D R-. ~ ~ ~ ~ _ -... ~ ->:J ~~ ~~<;L~~? ...... ~ 'V c -- '" .. C) ~~ ~ , ~ 0 0 w ._" ;l!: ~J ,::) -r; - c::: ;.'..c. -C. N --....,...,.\ a> '~'r ~ ii .::':"?( ) €' :s>> ?~:B -C"\ ::r; 2.:~ '0 ~ If! .-.-.... :.-:4 C><Q. "'" 'J>' Cl ~ cl' " N~b. MINICH & SONS, IMNC. IN THE COURT OF COMMON PLEAS OF vs. CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROBERT HOCUTT and JEAN R. HOCUTT 125 Richland Road Carlisle PA 17013 NO. 03-6204 CIVIL TERM 19_ WRIT OF REVIVAL TO Robert and Jean R. Hocutt You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the judgment entered to NO, 98-7116 CIVIL TERM 19_ The Plaintiff claims that the amount due and unpaid is $$5,997.38 with interest from March 26, 2003 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. Costs $ 177.40 Pd Attv $2.00 Co due CURTIS R. LONG PROTHONOTARY Date November 26, :@j)03 C\~J1 ^ ~ @TYrY !1 d Seal WAYNE F. SHADE, ESQUIRE Attorney for the Plaintiff 53 W. POMFRET ST. CARLISLE PA 17013 (717) 243-0220 .,,",-~-- SHERIFF'S RETURN - REGULAR CASE NO: 2003-06204 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND N L MINICH & SONS INC VS HOCUTT ROBERT ET AL RON KERR Sheriff or Deputy Sheriff of Cumberland County,pennsylvania, who being duly sworn according to law, says, the within WRIT OF REVIVAL was served upon HOCUTT ROBERT the DEFENDANT , at 0852:00 HOURS, on the 17th day of December, 2003 at 125 RICHLAND ROAD CARLISLE, PA 17013 by handing to ROBERT HOCUTT a true and attested copy of WRIT OF REVIVAL together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 4.14 .00 10.00 .00 32.14 r~=:~.c~ R. Thomas Kline 12/18/2003 WAYNE SHADE Sworn and Subscribed to before me this 'J.!? day of ~, /n.l<( A.D. '--- L.,,,,- 0, n~AO/>K' p/~onotary , -r--/ By: !Z~ /t/\~ Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2003-06204 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND N L MINICH & SONS INC VS HOCUTT ROBERT ET AL RON KERR Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF REVIVAL was served upon HOCUTT JEAN R the DEFENDANT , at 0852:00 HOURS, on the 17th day of December, 2003 at 125 RICHLAND ROAD CARLISLE, PA 17013 by handing to ROBERT HOCUTT, HUSBAND a true and attested copy of WRIT OF REVIVAL 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 -r'~r/<-~ R. Thomas Kline 12/18/2003 WAYNE SHADE Sworn and Subscribed to before By: L Deputy r~/\/'--' Sheriff me this ? ~ day of C)Q/ ,;u.v'l A.D. C ''1'-<.-12 /'J1A)tu... JjJO;:; rdthonotary ,''' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N.L. MINICH & SONS, INC., Plaintiff No. 03 - 6204 Civil v, ROBERT R. HOCUTT and JEAN R. HOCUTT, Defendants. DEFENDANTS' ANSWER TO PLAINTIFF'S WRIT OF REVIVAL AND NOW, this 16th day of January, 2004, come the Defendants, Robert R. Hocutt and Jean R. Hocutt, by and through their counsel, James 1. Nelson, Esquire, of Hanft and Knight, P,C" and file the following Answer to Plaintiffs' Writ of Revival, and in support thereof aver as follows: I. The above-named Defendants, responding to the writ of revival filed herein on January 8,2004, object to the revivor of the judgment heretofore rendered herein, due to the fact that the judgment amount has been partially satisfied, 2, As of July 21, 2003, the total amount owed by the Defendants to the Plaintiff is $3,485,O(} [see Exhibit A], and not $5,997.38, the judgment amount that Plaintiff seeks to revive, elson, Esquire ey ,D. No. 91144 19 Brookwood Avenue, Suite 106 Carlisle, P A 17013-9142 (717) 249-5373 Counsel for Plaintiff F:\User FolderlFinn Docs\Gendocs2004\3406.1answer. wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA N,L, MINICH & SONS, INe., Plaintiff No. 03 - 6204 Civil v, ROBERT R. HOCUTT and JEAN R. HOCUTT, Defendants, VERIFICATION James L Nelson hereby verifies that he is the attorney for the Defendants and that the facts set forth in the foregoing Answer are true and correct to the best of his knowledge, information and belief, and he understands that false statements herein are made subject to the penalties of IS Pa. C.S. 94904 relating to unsworn falsifications to authorities. > ~ame~lson, Esquire Attorney LD, No. 91144 19 Brookwood Avenue, Suite 106 Carlisle, P A 17013 (717) 249-5373 IGHT, P,C. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N.L. MINICH & SONS, INC" Plaintiff No. 03 - 6204 Civil v. ROBERT R. HOCUTT and JEAN R. HOCUTT, Defendants. CERTIFICATE OF SERVICE AND NOW, this 16th day of January, 2004, I, James 1. Nelson, Esquire, of Hanft & Knight, P.C" hereby certifY that I have served a copy of the Defendants' Answer by mailing the same by United States mail, postage prepaid, to: Wayne F, Shade, Esquire 53 West Pomfret Street Carlisle, PA 17013 Exhibit A .ti:ilil ~w_ -a:., ~!i;- Ow:::! 0CJ_ ..~~ :z: W cl - iEo:;j a "::I .Jz~ . Ii! 2.... <i..~ .".... ~006840 ~ ADDRESS: DOLlARS ,56. {;{J , .' J\ BY~ .......,-. ~"i -.~. '-"'-'''''''--'' ,,\i '::,.t,::'" i'-.: C? c. ,..., c.::? I...-.:::J .r:- <- - ~ 0> ~~ .-1 :1: -:D r11r -ern ~1 '\ c,J '>6 _.~ -'.~i ~~ '.j~ .-;.., -< ( .~, C,...'i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N.L. MINICH & SONS, INC" Plaintiff No, 03 - 6204 Civil v. ROBERT R. HOCUTT and JEAN R, HOCUTT, Defendants. STIPULATION AND NOW, this 22nd day of June, 2()()4, it is hereby agreed and stipulated between N,L. Minich & Sons ("Plaintiff') and Robert R, and Jean R, Hocutt ("Defendants"), as follows: 1. Defendants agree and stipulate to the revival ofthe judgment in the above-captioned matter; said judgment amount being $5,997.38, plus court costs. 2. Plaintiffs agree and stipulate that, in exchange for the agreement ofthe Defendants to revive said judgment, they will not seek to enforce the judgment for at least twelve (12) months from the date that this Stipulation is filed with the Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania. 3. Plaintiffs further agree and stipulate that the Defendants shall not be liable for the accrual of any interest on the amount specified in Paragraph 1, above; however, in the event that the judgment amount is not made on or before the expiration of the twelve (12) month period referenced in Paragraph 2, above, interest will accrue at the rate of 6% simple per year until the judgment amount is paid in full, 4. The above Stipulation has been read by all parties and all parties are in agreement hereof, 5, No representations have been made beyond those set forth in this Stipulation, ~ ~ Wa e Shade, Esquire Attorney fo Plaintiff .- ~ . Nelson, Esquire for Defendants F:\UscrFolder\FinnDocslGtlldocs2004\3406-1stipulalioo,wpd (') C.- C..tI "" C'::, '"~ ...- ~ c. '"~) (:) -r, cr. ::-"" -.:.1,., WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Car\i.sle, Pennsylvania 17013 N.L. MINICH & SONS, INC., Plaintiff v, ROBERT HOCUTT and JEAN R. HOCUTT, Defendants TO: Curtis R. Long, Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. ~l! : 116 CIVIL TERM tJ31", 2.0'7' C4% PRAECIPE Please enter satisfaction of judgment and costs in the above matter. Date: March 3, 2005 uJ~~~ Wayne . Shade, EsqUire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff :"'-.,:> ,-,." ,';.::; <':.r' ::j,~ :,oJ I ::;J ::i"1?~1 ;~: -~! f.....::' r ~, >' WAYNE F. SHADE Altorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 N.L. MINICH & SONS, INC., Plaintiff v. ROBERT HOCUTT and JEAN R. HOCUTT, Defendants TO: Curtis R. Long, Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 03-6204 CIVIL TERM PRAECIPE Please enter satisfaction of judgment and costs in the above matter. Date: September 19, 2005 /d~ Edk~, Wayne . Shade, EsqUire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff (") ~ 1:);:;0< n'lJ,,..t ~!~; -/" ~ >, - ~~i z ::2 '" = = c.n V) r'7 " N <=> ;no :z S? w ~ :I! ~~ 66 =t=H 2c'5 om ~ -<