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HomeMy WebLinkAbout09-4042. I TIMOTHY J. BLACK and MOBILITY INDEPENDENT TRANSPORTATION SERVICES, INC Plaintiffs V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5530 Civil Term GREGORY T. CLOUSER, t/a, d/b/a CIVIL ACTION -LAW WEST SHORE PRE-OWNED t-c Defendant JURY TRIAL DEMANDED G c?oY ?'T - 0 o?se ; T/c _ CI b ?? t Gr PRAECIPE FOR WRIT OF REVIVAL 5 y ??v,5-fir ? A (fir i d "w %l t,r F4 1"13 TO THE PROTHONOTARY: 3g Issue Writ of Revival ofLien of Judgment entered at No. 2003-5530 in the Court of Common Pleas of Cumberland County and enter it in the judgment index against Defendant, Gregory T. Clouser, t/a, d/b/a West Shore Pre-Owned, in favor of Plaintiff, Timothy J. Black, in the amount of $108,598.00 and in favor of Plaintiff, Mobility Independent Transportation Services, Inc., in the amount of $39,148.59, together with interest and costs from June 25, 2004. Dated: 6(16?q LI , .C. By Laurence W. Dague, I.D. # 19715 Evan C. Pappas, I.D. #200103 P.O. Box 88 Harrisburg, PA 17108 (717) 763-1121 Attorneys for Plaintiffs :222296 CERTIFICATE OF SERVICE I, Evan C. Pappas, Esquire, of the law firm of Shumaker Williams, P.C., hereby certify that I served a true and correct copy of the foregoing Praecipe for Writ of Revival on this date by depositing a copy of the same in the possession of the United States Mail, first-class, postage prepaid, addressed as follows: Matthew Eshelman, Esquire 8 S. Hanover Street, Suite 201 Carlisle, PA 17013 Dated: I SHUMAKER WILLIAMS, P.C. By Evan C. Pappas, I.D. #200103 P.O. BOX 88 Harrisburg, PA 17108 (717) 763-1121 s1 T THE 2009 JUN 16 Aid 10: 50 C99 - 40 '10d. a4 ?? 307 ,=2. a5) ot,.e-e"!-- - . A TIMOTHY J. BLACK and MOBILITY INDEPENDENT TRANSPORTATION SERVICES, INC Plaintiffs V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 09 -?Foya Cis: C NO. 03-5530 Civil Term GREGORY T. CLOUSER, t/a, d/b/a CIVIL ACTION -LAW WEST SHORE PRE-OWNED Defendant JURY TRIAL DEMANDED WRIT OF REVIVAL TO: Gregory T. Clouser t/a d/b/a West Shore Pre-Owned c/o Bath Fitter 542 Industrial Drive Lewisberry, PA 17339 (1) You are notified that the Plaintiffs have commenced a proceeding to revive and continue the lien of the judgment entered at No. 03-5530 in the Court of Common Pleas of Cumberland County. (2) The Plaintiffs claim that the amount due and unpaid is $108,598.00 in favor of Plaintiff, Timothy J. Black, and $39,148.59 in favor of Defendant, Mobility Independent Transportation Services, Inc., plus interest and costs from June 25, 2004. (3) 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 in the amount claimed by the Plaintiffs may be entered without a hearing and you may lose your property or other important rights. i 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 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, PA 17013 (800) 990-9108 Dated: C Long, UW&e;P? Cvsfs 13 j,. ©9 pot. aq4y a. av bve Co By Deputy Prothonotary 222296 Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith r'1 ;jkfy}. kY Civil Process Sergeant OFF C F $HERIPF Edward L Schorpp Solicitor Timothy J. Black vs. Gregory T. Clouser SHERIFF'S RETURN OF SERVICE Case Number 2009-4042 06/19/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Gregory T. Clouser d/b/a West Shore Pre-Owned, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of York County, PA to serve the within Writ of Revival according to law. 06/26/2009 03:36 PM - York County Return: And now June 26, 2009 at 1536 hours I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of Revival, upon the within named defendant, to wit: Gregory T. Clouser by making known unto Theo McCracken, Sales Manager at 542 Industrial Drive Lewisberry, PA 17339 its contents and at the same time handing to him personally the said true and correct cop' of the ____ _ SHERIFF COST: $37.44 July 08, 2009 C`3 C-7' r" r ? - _ TI _ c f fi 9 _ ; T COUNTY OF, YORK OFFICE OF THE SHERIFF 45 N. GEORGE ST., YORK, PA 17401 SERVICE CALL (717) 771-9601 SHERIFF SERVICE MtiSTFMTMS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LW 1 THRU 12 DO NOT DETACH ANY COPES 1 PLAINTIFF/S/ 2 COURT NUMBER 09-404, CIVIL Timothy J. Black & Mobility Independant Transporation Services 4 TYPE OF WRIT OR COMPLAINT 3. DEFENDANT/S/ Gregory T. Clouser, t/a, d/b/a West Shore Pre-Owned Writ of Revival SERVE 5 NAME OF INDIVIDUAL, COMPANY, CORPORATION. ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD Gregory T. Clouser 6 ADDRESS (STREET OR RFO WITH BOX NUMBER. APT NO, CITY, BORO. TWP, STATE AND ZIP CODE) AT t/o Bath Fitter, 542 Industrial Drive Lewisberry PA 17339 7. INDICATE SERVICE CKIPERSONAL U PERSON IN CHARGE )tJDEPUTIZE U RT U 1ST CLASS MAIL U POSTED -f OTHER .Pi NOW June 19, 2009 20 I, SHERIFF OF COUNTY PA do hereby deputize the sheriff of YORK COUNTY to execute- make return according to law. This deputization being made at the request and risk of the plaintiff., SHERIFF Or, 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE OUT OF CO CUMBERLAND ADV FEE PAID BY ATTY. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or thing any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, w hout liabi on part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before shenfrs sale thereof. 10. TELEPHONE NUMBER 11 DATE FILED 9. TYPE NAME and ADDRESS of ATTORNEY I ORIGINATOR and SIGNATURE Evan C. Pappas, P.O. Box 88, Harrisburg, PA 1710 04 717.909.1655 106/16/2009 1? 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed d notice is to be masted) CUMBERLAND CO SHERIFF Evan C. Pappas, Esquire, Shumaker Williams, P.C., P.O. Box 88, Harrisburg, PA 17108 Cn w nC nC1 nui LAn I I&C Ar' Tt= C M WC M YnT WOITC QCi t%%M TLrC 1 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15 Expiration/Hearing Date or complaint as indicated above. M.7 M(•i(1_TTT. V(1Qn A-99-9nnA 9-14-n9 16. HOW SERVED P SO L ( ) RESIDENCE ( ) POSTED( ) POEK SHERIFF'S OFFICE ( ) OTHER( ) SEE REMARKS BELOW 17. O 1 hereby an n a NOT FOUND because I am unable to locate the individual, company, etc named above. (See remarks below.) oll 18. E LE IVIDUA ERVED /LIST ADDR S HERE IF NOT)HOWN ABOVE (Relationship to Defendant) Date of Seri 20 low o&,S 21. E Oa Time re) -int Date Time Miles Int. Date Time Miles Int. Dale Time Miles Int. Dale Time Miles Int. Dale Time Miles Int. 2Z. REMAKRJ:?? , /? • V `? / " `G?F? G i? ??si?1?7 V /!.???l 23. Advance Costs 24 SeC ots 25 N/F 26. Mileage 27 Postage 28. Sub Total 29. Pound 30 Notary 31. Surehg 32 Tot. Costs 33 Costs Due Refund Check No 100.00 " 1 :2 Q-1-1 1 1-In -? ? f 9l 34. Foreign County Costs 35. Advance Costs 36 Service Costs 37 Notary' Cert 38 MNeagelPoslage/Not Found 39 total Costs 40 Costs Due or Refund ANSWERS I 41. AFFIRMED and subscribed to befor is Signature of 44 ON JULY 09 42, day of .20 _ 43 . Dep. Sheriff COMMONWEALTH OF ENN AN /NOTARY 46. Signature of brk 47 DATE Notarial Seal County Sheriff -09 Kristel Stambaugh Notar Publi RICHARD P. ,S F , c y City of York, York County J 48 Signature of Foreign 49 DATE May 16 201 1 County Sheriff F4 Or 50. 1 A t11921ti t-r ETURN SIGNATURE 51 DATE RECEIVED OF RUTFIORIZECT'f85CAKTYI ?t ( 1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sherifrs Office 4. BLUE - Shenfrs Office