HomeMy WebLinkAbout12-24441i.
MICHAEL L. BANGS, ESQUIRE x ` "TA ATTORNEY FOR PLAINTIFF
Bangs Law Office, LLC r ry 1: 03
I.D. #41263
429 South 18'h Street Y`J IDERLANu COUNTY
Camp Hill, PA 17011 F= E N N S) Y LVA' N I A
(717) 730-7310
HEMPT BROS., INC. )
Plaintiff )
vs. )
SETH B. HUGHES and JENNIFER )
A. HUGHES, his wife, Individually and )
HUGHES CONTRACTING, INC. )
Defendants )
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO.2012 -dLI4q ClV
NOTICE
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 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 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 THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
6)
Ck- * /ors v
MICHAEL L. BANGS, ESQUIRE
Bangs Law Office, LLC
I.D. #41263
ATTORNEY FOR PLAINTIFF
429 South 18d' Street
Camp Hill, PA 17011
(717) 730-7310
HEMPT BROS., INC.
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
SETH B. HUGHES and JENNIFER
A. HUGHES, his wife, Individually and
HUGHES CONTRACTING, INC.
Defendants
NO. 2012
COMPLAINT
AND NOW comes the Plaintiff, Hempt Bros., Inc., by and through its counsel, Michael
L. Bangs, Esquire, and in support thereof files the following Complaint:
1. Plaintiff, Hempt Bros., Inc., is a Pennsylvania corporation with its principal place of
business at 205 Creek Road, Camp Hill, Cumberland County, Pennsylvania, 17011.
2. Defendants Seth B. Hughes and Jennifer A. Hughes, are adult individuals who reside
at 14 Cardinal Drive, Cumberland County, Pennsylvania, 17015 (hereinafter referred to as
"Hughes")
3. Defendant Hughes Contracting, Inc., is a Pennsylvania corporation with its principal
place of business at 1787 West Trindle Road, Carlisle, Cumberland County, Pennsylvania, 17015
(hereinafter referred to as "Hughes Contracting").
4. Plaintiff is in the business of providing certain materials including, but not limited to,
crushed stone, sand, transit mixed concrete, and other asphalt material.
5. Defendants Hughes contacted Plaintiff and requested Plaintiff to set up a credit
account for Defendant Hughes Contracting to supply Defendant Hughes Contracting with certain
materials for various jobs at various times.
6. Plaintiff agreed to set up a credit account with Defendant Hughes Contracting
provided that all invoices evidencing materials supplied to Defendant Hughes Contracting were
paid within thirty (30) days of receipt.
7. Plaintiff also agreed to set up a credit account with Defendant Hughes Contracting
provided that Defendants Hughes personally guaranteed payment for all materials supplied to
Defendant Hughes Contracting. Attached hereto and marked as Exhibit A is a true and correct
copy of the Guarantee.
8. The personal guarantee provides, among other things, for the payment of all costs
including, but not limited to, reasonable attorney's fees for the enforcement of the terms and
conditions of the personal guarantee.
9. Plaintiff has engaged the law firm of Bangs Law Office, LLC, at the rate of $210.00
per hour to enforce the terms of the agreement between the parties and for the enforcement of the
personal guarantee.
10. Defendant Hughes Contracting and Defendants Hughes, pursuant to the guarantee,
also agreed to pay the sum of one (1%) percent interest per month for any outstanding invoices
due over thirty (30) days.
COUNTI
HEMPT BROS., INC., vs. HUGHES CONTRACTING, INC.
BREACH OF CONTRACT
11. The averments of Paragraphs 1 through 10 are incorporated herein by reference as if
more fully set forth herein.
2
12. Plaintiff, at the insistence and request of the agents, servants, or employees of
Defendant Hughes Contracting, acting within the scope of their employment, sold and delivered
to Defendant Hughes Contracting certain goods and materials at the times and in the amounts
and for the prices set forth in Plaintiff's Statement of Account which is attached hereto and
marked as Exhibit B.
13. Defendant Hughes Contracting accepted and received all materials ordered from
Plaintiff and referenced on Exhibit B.
14. Defendant Hughes Contracting has failed or refused to pay Plaintiff for the materials
received by it and identified by the invoices which are reflected on Exhibit B.
15. Defendant Hughes Contracting has breached the agreement with Plaintiff by its
failure to pay for the materials received pursuant to the terms and conditions of the credit
account.
16. Plaintiff has been damaged in the amount of $6,587.95 as a result of Defendant
Hughes Contracting's failure to pay for all outstanding invoices in accordance with the
agreement between Plaintiff and Defendant Hughes Contracting.
17. Plaintiff is also entitled to receive interest at the rate of one (1%) percent per month
for all invoices due over thirty (30) days as a result of Defendant Hughes Contracting's failure to
pay for the materials received in accordance with the credit account established by Plaintiff.
WHEREFORE, Plaintiff demands judgment against Defendant Hughes Contracting in
the amount of $6,587.95 plus interest at the rate of one (1%) percent per month for all
outstanding invoices due over thirty (30) days, to be calculated until the time of judgment in this
case.
3
COUNT II
HEMPT BROS., INC., vs. HUGHES CONTRACTING, INC.
UNJUST ENRICHMENT
18. The averments of Paragraphs 1 through 17 are incorporated herein by reference as if
more fully set forth herein.
19. The prices charged for said goods and materials are just and reasonable and are the
prices which the agents, servants, and employees of Defendant Hughes Contracting, acting
within the scope of their employment, orally promised to pay Plaintiff for those goods and
materials.
20. Defendant Hughes Contracting has failed or refused to pay for the goods and
materials received by it despite repeated demands by Plaintiff.
21. Defendant Hughes Contracting has been unjustly enriched at Plaintiff's expense by
its failure to pay for the goods and materials it received in the amount of $6,587.95, plus interest
at the rate of one (I%) percent per month for all invoices due over thirty (30) days, as a result of
its acceptance of the goods and materials delivered by Plaintiff and used by Defendant Hughes
Contracting.
WHEREFORE, Plaintiff demands judgment against Defendant Hughes Contracting in
the amount of $6,587.95 together with interest at the rate of one (1%) percent per month for all
invoices due over thirty (30) days, to be calculated until the time of judgment in this case.
COUNT III
HEMPT BROS., INC., vs. SETH B. HUGHES and JENNIFER A. HUGHES
ACTION ON PERSONAL GUARANTEE
22. The averments of Paragraphs 1 through 21 are incorporated herein by reference as if
more fully set forth herein.
4
23. Defendants Seth B. Hughes and Jennifer A. Hughes, pursuant to Exhibit A,
personally guaranteed the amounts due and owing to Plaintiff, on a joint and several basis for the
materials received by Defendant Hughes Contracting.
24. Plaintiff is owed the amount of $6,587.95 as a result of the failure of Defendant
Hughes Contracting to pay all outstanding invoices in accordance with the terms of the credit
account agreement between Plaintiff and Defendant Hughes Contracting, and as such, the
guarantors, Defendants Seth B. Hughes and Jennifer A. Hughes, are personally liable, joint and
severally liable, for said payment to Plaintiff.
25. Plaintiff is also entitled to receive interest at the rate of one (1%) percent per month
for all invoices due over thirty (30) days as a result of the failure to pay for the outstanding
invoices and pursuant to the terms of the guarantee.
26. Defendants Seth B. Hughes and Jennifer A. Hughes are also responsible for all costs
and expenses, including, but not limited to, reasonable attorney's fees and costs which are
incurred by Plaintiff in the enforcement of the personal guarantee and in the enforcement of the
terms and conditions of the credit account between Plaintiff and Defendant Hughes Contracting,
said attorney's fees totaling $500.00 as of April 1, 2012 which will continue to accrue until the
time of judgment in this case.
WHEREFORE, Plaintiff demands judgment against Defendants Seth B. Hughes and
Jennifer A. Hughes, joint and severally, in the amount of $7,087.95, plus interest at the rate of
one (I%) percent per month for all invoices due over thirty (30) days, to be calculated until the
time of judgment in this case, plus reasonable attorney's fees and costs of suit continuing until
the time of judgment.
Respectfully submitted,
BANGS LAW OFFICE, L
V'vi ?4?J Z_.
IC EL L. BANGS
Attorney for Plaintiff
429 South 18th Street
Camp Hill, PA 17011
(717) 730-7310
Supreme Court ID #41263
6
VERIFICATION
MAX J. HEMPT, being duly sworn according to law, deposes and says that he is the
President of HEMPT BROS., INC., a Pennsylvania corporation, the Plaintiff herein, and that as
such President, he is authorized to make this Verification on its behalf and that the facts set forth
in the foregoing Complaint are true and correct to the best of his knowledge, information and
belief, and further understands that false statements herein are made subject to the penalties of 18
Pa. C.S. Section 4904, relating to unsworn falsification to authorities.
HEMPT BROS., INC.
er
MAX J. HEMPT, President
6
EXHIBIT A
WdS) Of iadivideeah(a) who pravi ftg guaraaaty), W*Aft talieeM tO as "CAMOf l2r, for
urabta cosy &"0% tier W-0 Of %i&h is aoturaN W* sad iuteeo ft to be lgpUy bound hwoby,
io&Wmuy, Joktty and several , hasby wamtadi4onslly gaaramees to ? BROS., INC., the'i f dt
#ad procp?pt pecf nw= and at by
(tea d ar herelualloar refnttbd to an "Obli?o?''. Qwantor mooo ttov*
gtuna?ea nsaat to 0 OS., ham., fa All obligW mr which Abligor aa? have to 'f
BROS.. INC., sad psymcW *a t duo of all suits owed by Mpr to BMAff BROS., INC.
M4119 Ww- For purposes of this Ow =W. all mu owed by the Obligor an
udmooadi mxW ad gurrraotead shut! be deemM to become ?nww imeld due said payabk if.
A. Obligor dd+b in may of its obHpdons to HEWr BVM., M.;
M A pertitiam ray C'tsapw otdw Baakngmy Act of dw appoiosmw of a
reoaivae ofmgr pat of pmpaeq of Obligor is fated sgwioet Oblidot a W aot disnaiered
Whig thirty (30) ds";
C. Obbgar flm peat"for t wwaptcy;
D. Obkor a pwd a slip ent fbr do bandt of creditaxs or sugmuds
bWasm or commits sot sma mti ng to a babas feadute;
B. An aftebm it whiait is levied or a tax tiem tired sgiM m W of Obllgot's
Prom.
This is a com*m iaj pmo* and ladareoulslr spument wad shdt be dnmeed to be a fft ivo and
b mfr an to G=wW wad not be ®paired or kthdad bar
A New? ar?eidi?i Me ou of speb moats, renswak at waiver of ddak
as to as a dting of a HI ---- ' of 0btips or extagaaiew of cavA to 0bligar,
B. awmpromiw or tdom s day obligation of Obligor as
be twmq LOW IRROS W, we as betwem Obligor and wW third pally;
C. Iaoosl?"owls, hwUN&y or icoyanAoreaability for any rawaoe.of
any insepsoaaoot dim
,
D. or other Wkf granted Obligor puasuad to may statuto
pre mdy in ffi. F.
to any obtlgor;
G. deaomd on Obligor tat p maeat pw mm to this G= uV.
ah"WOEUM : 'no mmo mt of Ctmnntor's liwlm Vq sbag bo irc? as mnouat equal to
dao credit 4teaded to Obliges.
I= &M ZMAY, QKL0A=- The obligates bm under of aafi of the mddo feud
Cuan km wo joist nd saversl shoal br W4 on tbsk rimpaebe hairs and pe:csonsl
mprms h&u. The 13aik" of y ptmn to eiga taw Qoatauty easel hwtmD* spell not weed ttw
llsbittty of my oter h Gs:are?aror ereiq.
1
snwuNae #"K WWI FJMA W. 717 761549 Poe 314
.'VPLJ m-ja TwunCJUVAIRAU111„71 fif'L9J'VVJL-P-7 fit (V)JVIv Y414
T£RMD(ATIM OF L , Any G+tut,sntas my tumink his or ber mspective
ob Nouns henunder as to *m iyttuctmsuaoo betwe s MOT BROS., INC., end Obligor pt'ovided
that thoy give wd un notice ?o BROS., INC., by regWond mull at 205 Cteek Road, CwW HAL
Petwdylvania,170 l 1, providady, owthat ouch tetlmhoiou shall not alNect tides hu&vr liability
heretmder wits rospeci to ady o liptioas of Obligor to zr 13R05.,1NC., inooured prior m rgceipc
of mob notice, nor shall It effic the continuing liablk of any A w GuamaW who has not givotl notice.
PAXWW Op In additiom to all other liability of owMMr, OttiMtor ague to pay
T'B1tO&, INC., all cow axpmw Wludia?g, brat to Wa*d 6Q, tea=)ablc ftniWs ices
and cogs' whialt may be inams in the adlbreement of this Gowaty and OWigm'n oWig/t*m to
MOT BROS., INC.
AND RMOM This Our&* and it.nnaRy is
atadBO"cad gball be coo liberally is fOW of HOP'I' BM-,1NC., atd s6rdl itlM to thb
benefit of the saccessw ad of MOT BROS., I NC, If 4bII* shall deitutlt is tho
perfonatanw of ww of Obligor' oblftgxtioat+ to ORAPT BROS, RC, and if any third party wakes any
payment b T BROS., with mipeet thtr+do, sub tbi?t+d pjr shall, to the tosant of payment.
be adapted to all rigl? of BROS., NC-, agai w Obligor and Guarantor.
This Gwt+Mty u into two, (9 1 ? day of = n jekr 1 209 and is
bwX awuted gad dakiwed to BRos, jNc, in mptd m wwp4ans between RMPT
BROS., INC., and Obligor, ail •not a cowoom transaction.
\ . ? SIGN T W GUAUM
•li AMPTi OPALS .
TIMM SMS=.MUS
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PP414
EXHIBIT B
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
00'11' ai t ,
?: rid
r' U-
, 0,
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Hempt Bros. Inc.
vs.
Seth B Hughes (et al.)
2012MAY -8 AM g: 55
CUMBERLAND COUNTY
P'E'NNSYLVANIA
Case Number
2012-2444
SHERIFF'S RETURN OF SERVICE
04/24/2012 03:00 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on April 24,
2012 at 1500 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Hughes Contracting, Inc., by making known unto Seth Hughes, Owner of Hughes
Contracting, Inc. at 14 Cardinal Drive, Carlisle, Cumberland County, Pennsylvania 17015 its contents and
at the same time handing to him personally the said true and correct copy of the same.
DENNI FRY, DEPUTY,,-
04/24/2012 03:00 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on April 24,
2012 at 1500 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Seth B. Hughes, by making known unto himself personally, at 14 Cardinal Drive,
Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him
personally the said true and correct copy of the same.
DENN FRY, DEPU
04/26/2012 04:20 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on April
26, 2012 at 1620 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Jennifer A. Hughes, by making known unto herself personally, at 14 Cardinal Drive,
Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to her
personally the said true and correct copy of the same.
TEPHEN ENDER, DEPUTY
SHERIFF COST: $66.45
April 27, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
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MICHAEL L. BANGS, ESQUIRE ATTORNEY FOR PLAINTIFF
BANGS LAW OFFICE, LLC
I.D. No. 41263
429 South 18th Street
Camp Hill, PA 17011
(717) 730-7310
HEMPT BROS., INC., ) IN THE COURT OF COMMON PLEAS
Plaintiff ) OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS. ) C=
NO. 2012-2444 CIVIL TERM
SETH B. HUGHES and JENNIFER
A. HUGHES, his wife, individually and ) CIVIL ACTION - LAWS
HUGHES CONTRACTING, INC.,
Defendants ) -?
PRAECIPE T
TO THE PROTHONOTARY:
Please enter judgment in favor of the Plaintiff and against Defendant Seth B. Hughes and
Defendant Jennifer A. Hughes, individually and collectively, in the amount of $7,685.59, for
their failure to file a responsive pleading in the above-referenced matter.
I hereby certify that the attached Notice in accordance with Rule 237.1(a)(2) was mailed
by regular mail on or about May 21, 2012, to Defendant Seth B. Hughes and Defendant Jennifer
A. Hughes at 14 Cardinal Drive, Carlisle, Pennsylvania, 17015.
Respectfully submitted,
BANGS LAW OFFICE, LLC
MICHAEL L. BANGS
Attorney for Plaintiff
Date:
Eo 12
I it
*11p.50 PQ ATty
e* rogcas
a# a7&508
Nc? ce wade {
MICHAEL. L. BANGS, ESQUIRE ATTORNEY FOR ]PLAINTIFF
BfiNC S L,-% X OFFICE, LLC
I.D. NO. 4'.263
42) SOUTH 18 TI STREET
CAMF HILL, PA 17011
7 ,_",'30-7-10
HEMPT BROS., INC., ) IN THE COURT OF COMMON PLEAS
Plaintiff ) OF CUMBERLAND COUNTY.
PENNSYLVANIA
vs. )
NO. 2012-2444 CIVIL TERM
SETH B. HUGHES and JENNIFER )
A. HUGHES, his wife, individually, and ) CIVIL ACTION
HUGHES CONTRACTING, INC., )
Defendants )
TO: SETH B. HUGHES
14 Cardinal Drive
Carlisle, PA 17015
DATE OF NOTICE: May 21, 2012
IMPORTANT NOTICE
Required by Rule 237.1(a)(2)
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 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.
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 FEED OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
MI HAEL L. BANGS
Attorney for Plaintiff
BANG S L zz t'v OFFICE, LLC
1. D. N :,. 4 L 63
429 SOU T11 18 TI STREET
CAMI` HILL PA 17011
7( 17) 730-7310 _
ATTORNEY FOR PLAINTIFF
HEMPT BROS., 1NC.. ) IN THE COURT OF COMMON PLEAS
Plaintiff ) OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs. )
NO. 2012-2444 CIVIL TERM
SETH B. HUGHES and JENNIFER )
A. HUGHES, his wife, individually, and ) CIVIL ACTION
HUGHES CONTRACTING, INC., )
Defendants )
TO: JENNIFER A. HUGHES
14 Cardinal Drive
Carlisle, PA 17015
DATE OF NOTICE: May 21, 2012
IMPORTANT NOTICE
Required by Rule 237.1(a)(2)
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 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.
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 FEED OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
n
MICHAEL L. BANGS
Attorney for Plaintiff
MICHAEL L. BANGS, ESQUIRE ATTORNEY FOR PLAINTIFF
BANGS LAW OFFICE, LLC
I.D. No. 41263
429 South 18'' Street
Camp Hill, PA 17011
(717) 730-7310
HEMPT BROS., INC., ) IN THE COURT OF COMMON PLEAS
Plaintiff ) OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS. )
NO. 2012-2444 CIVIL TERM
SETH B. HUGHES and JENNIFER )
A. HUGHES, his wife, individually and ) CIVIL ACTION - LAW
HUGHES CONTRACTING, INC., )
Defendants )
NOTICE PURSUANT TO RULE 236
TO: JENNIFER A. HUGHES, Defendant(s)
You are hereby notified that on .1 6ne ii , 201, the following
(Judgment) (Order) (Decree) has been entered against you in the above-captioned case:
$7,685.59. N ow'. *101V& /
DATE: /
Prothono Woxf
I hereby certify that the name and address of the proper person(s) to receive this notice is:
Jennifer A. Hughes
14 Cardinal Drive
Carlisle, PA 17015
A: JENNIFER A. HUGHES, Defendido/a o Defendidos/as
Por este medio se le esta notificando que el de del 20 ,
el/la siguiente (Orden) (Decreto) (Fallo) ha sido anotado en contra suya en el caso mencionado
en el epigrafe: $7,685.59.
FECHA:
Protonotario
Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado
de residencia:
Jennifer A. Hughes
14 Cardinal Drive
Carlisle, PA 17015
MICHAEL L. BANGS, ESQUIRE ATTORNEY FOR PLAINTIFF
BANGS LAW OFFICE, LLC
I.D. No. 41263
429 South 18'' Street
Camp Hill, PA 17011
(717) 730-7310
HEMPT BROS., INC., ) IN THE COURT OF COMMON PLEAS
Plaintiff ) OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs. )
NO. 2012-2444 CIVIL TERM
SETH B. HUGHES and JENNIFER )
A. HUGHES, his wife, individually and ) CIVIL ACTION - LAW
HUGHES CONTRACTING, INC., )
Defendants )
NOTICE PURSUANT TO RULE 236
TO: SETH B. HUGHES, Defendant(s)
You are hereby notified that on a Un _ I , 20-L&-, the following
(Judgment) (Order) (Decree) has been entered against you n the above-captioned case:
$7,685.59. 'k 414k
DATE: /
Protho
I hereby certify that the name and address of the proper person(s) to receive this notice is:
Seth B. Hughes
14 Cardinal Drive
Carlisle, PA 17015
A: SETH B. HUGHES, Defendido/a o Defendidos/as
Por este medio se le esta notificando que el de del 20
el/la siguiente (Orden) (Decreto) (Fallo) ha sido anotado en contra suya en el caso mencionado
en el epigrafe: $7,685.59.
FECHA:
Protonotario
Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado
de residencia:
Seth B. Hughes
14 Cardinal Drive
Carlisle, PA 17015
i
MICHAEL L. BANGS, ESQUIRE ATTORNEY FOR PLAINTIFF
BANGS LAW OFFICE, LLC
I.D. No. 41263
429 South 18`x' Street
Camp Hill, PA 17011
(717) 730-7310
HEMPT BROS., INC., ) IN THE COURT OF COMMON PLEAS
Plaintiff ) OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
NO. 2012-2444 CIVIL TERM `== ='
SETH B. HUGHES and JENNIFER
A. HUGHES, his wife, individually and ) CIVIL ACTION - LAW r ''= T
HUGHES CONTRACTING, INC., ) T 3 .
Defendants
C7
PRAECIPE _ . ....;
TO THE PROTHONOTARY: -
Please enter judgment in favor of the Plaintiff and against Defendant Hughes
Contracting, Inc., in the amount of $6,785.59, for its failure to file a responsive pleading in the
above-referenced matter.
I hereby certify that the attached Notice in accordance with Rule 237.1(a)(2) was mailed
by regular mail on or about May 21, 2012, to Defendant Hughes Contracting, Inc. at 1787 West
Trindle Road, Carlisle, Pennsylvania, 17015.
Respectfully submitted,
BANGS LAW OFFICE, LLC
MICHAEL L. BANGS
Attorney for Plaintiff
Date: 011
a
$ i(0.5o. P b Arty
& J7W
Ka(be wiled
MICHNElL L. HANGS, ESQUIRE
BANGS L XO `GFFICE, LLC
1. D. NC. 4? 21i3
429 SOUTH 18TH STF:EET
ATTORNEY FOR PLAINTIFF
CAMP HILL,. PA 17011
X717) 7:i0-7310
HE;MPT BIOS., INC.. :{N THE COURT OF COMMON PLEAS
Plaintiff ) OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
NO. 2012-2444 CIVIL TERM
SETH B. HUGHES and JENNIFER
A. HUGHES, his wife, individually, and ) CIVIL ACTION
HUGHES CONTRACTING, INC., )
Defendants )
TO: HUGHES CONTRACTING, INC.
1787 West Trindle Road
Carlisle, PA 17015
DATE OF NOTICE: May 21, 2012
IMPORTANT NOTICE
Required by Rule 23 T 1(a)(2)
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 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.
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 FEED OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
MICHAEL L. BANGS U.
Attorney for Plaintiff
MICHAEL L. BANGS, ESQUIRE
BANGS LAW OFFICE, LLC
I.D. No. 41263
429 South 18t' Street
Camp Hill, PA 17011
(717) 730-7310
ATTORNEY FOR PLAINTIFF
HLMY I BKUS., INC., )
Plaintiff )
VS. )
SETH B. HUGHES and JENNIFER )
A. HUGHES, his wife, individually and )
HUGHES CONTRACTING, INC., )
Defendants )
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 2012-2444 CIVIL TERM
CIVIL ACTION - LAW
NOTICE PURSUANT TO RULE 236
TO: HUGHES CONTRACTING, INC., Defendant(s)
You are hereby notified that on V Ur L I 1 , 20 IQ , the following
(Judgment) (Order) (Decree) has been entered agairQ you in above -captioned
c :
$6,785.59.
DATE: " ` /
Pr
I hereby certify that the name and address of the proper person(s) to receive this notice is:
Hughes Contracting, Inc.
1787 West Trindle Road
Carlisle, PA 17015
A: HUGHES CONTRACTING, INC., Defendido/a o Defendidos/as
Por este medio se le esta notificando que el de del 20
el/la siguiente (Orden) (Decreto) (Fallo) ha sido anotado en contra suya en el caso mencionado
en el epigrafe: $6,785.59.
FECHA:
Protonotario
Certifico que la siguiente direccion es la del defendido/a segun indicada en el certificado
de residencia:
Hughes Contracting, Inc.
1787 West Trindle Road
Carlisle, PA 17015
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 20112-2444 Civil
CIVIL ACTION - LAW
TO TI-IL' SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HEMPT BROS, INC. Plaintiff (s)
From HUGHES CONTRACTING, INC., 1787 WEST TRINDLE ROAD, CARLISLE, PA 17015
(1 )You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ANN' AND
ALL PROPERTY OF THE DEFENDANT HUGHES CONTRACTING, INC. LOCATED AT 1787
WEST TRINDLE ROAD, CARLISLE, PA 17015.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If'property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due$6,785.59
Interest
Ally's Comm
Ally Paid $215.20
Plaintiff Paid
Date: Julv 31, 2012
(Seal)
L. L. S
Due Prothy 52.25
Other Costs
David D. Buell, Prothonotary
Deputy
Rr.oUL:S 'NG PARTY:
Name : MICHAEL L. BANGS, ESQUIRE
Address: BANGS LAW OFFICE
429 SOUTH 18Te STREET
CAMP HILL, PA 17011
Attorne% for: PLAINTIFF
Telephone: 717-730-7310
Supreme t?ourt ID No. 41263
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSVI v. V rt`+! +-f wi?1ti?T lt'? (`'
CIVIL DIVISION
Hempt Bros., Inc.
vs.
Seth B. Hughes, et al.
PRAECIPE FOR WRIT OF EXECUTION
Confessed Judgment
Plaintiff ® Other
File No. 2012-2444
Amount Due $6,785.59
Defendant
address:
10 THE PROTHONOTARY OF THE SAID COURT:
Interest
Atty's Comm
Costs
The undersigned hereby certifies that the below does not arise out of a retail installment sale,
contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original
proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as
amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland
ounty. for debt, interest and costs, upon the following described property of the defendant (s)
Please levy upon any and all property of the Defendant Hughes Contracting, Inc. located
at 1787 West Trindle Road, Carlisle, PA 17015.
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of County, for debt. interest
and costs, as above, directing attachment against the above-named garnishee(s) for the following property
(if real estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnisheci s'.
Date
El (Indicate) Index this writ against the garnishee (s) as a lis pendens against real estate of' the
defendant(s) described in the attached exhibit.
Signature:
Print Name: Michael L. Bangs
C? G
?f f,
b fit
90
9 ;),as
Address:
Attorney for:
: AM
OUNTY
"NNSYLVkNIA
429 South 18th Street
Camp Hill, PA 17011
Plaintiff
Telephone: 717-730-7310,_
Supreme Court ID No: 41263
ove 6.
A L_ 14
a
V?-''< ? ?SSd'ed
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N02012-2444 Civil
CIVIL ACTION - LAW
f0 THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due HEMPT BROS, INC. Plaintiff (s)
F-om SETH B. HUGHES AND JENNIFER A. HUGHES, 14 CARDINAL DRIVE, CARLISLE,
P4 17015
( I )You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ANN' AND
ALL PERSONAL PROPERTY OF THE DEFENDANTS SETH B. HUGHES AND JENNIFER A.
HUGHES, LOCATED AT 14 CARDINAL DRIVE, CARLISLE, PA 17015,
12 ) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
&kRNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) if property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that fie/she has been added as a
garnishec and is enjoined as above stated.
An-count DueS7,685.59
Interest
AttV's Comm (%
Atl'd Paid S217.70
Plaintiff Paid
Date: July 31, 2012
(Se,!i)
L.L. S.50
Due Prothv S2.25
Other Costs
David D. Buell, Prothonotary
v:
Deputy
REQUESTING PARTY:
Mime: MICHAEL L. BANGS, ESQUIRE
Ac'dress: BANGS LAW OFFICE
429 SOUTH 18TH STREET
CAMP HILL, PA 17011
Attornev for: PLAINTIFF
Telephone: 717-730-7310
Supreme Court ID No. 41263
I.
N?SY,I,y'A1111) -
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,,,
: 'L 11 II FF
:,
CIVIL DIVISION
Hempt Bros., Inc.
vs.
Seth B. Hughes, et al.
PRAECIPE FOR WRIT OF EXECUTION CUMBERLAND COUNTY
? Confessed Judgment PENNSYLVANIA
Plaintiff OR Other
File No. 2012-2444
Amount Due $7,685.59
Defendant Interest
Address:
Atty's Comm
Costs
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail installment sale,
contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original
proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as
amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland
County, for debt, interest and costs, upon the following described property of the defendant (s)
Please levy upon any and all personal property of the Defendants Seth B. Hughes and
.Jennifer A. Hughes, located at 14 Cardinal Drive, Carlisle, PA 17015.
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of County, for debt, interest
and costs, as above, directing attachment against the above-named garnishee(s) for the following property
(if real estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(,,).
? (Indicate) Index this writ against the garnishee (s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit. -
Date _ Signature: ?''•! 'f --
sz-
awk?
)b3 ? ? ar rr
50
250
Print Name: Michael L. Bangs
Address: 429 South 18th Street
Camp Hill, PA 17011
Attorney for: Plaintiff
Telephone: 717-730-7310
Supreme Court ID No: 41263
o,. SaL-
CLy II bo 6
(24- ?-19U8?
?,Im+ ?( tx Ts?.,?
?a-?1F iLr
MICHAEL L. BANGS, ESQUIRE " FHON}3T? ATTORNEY FOR PLAINTIFF
BANGS LAW OFFICE, LLC 2G12 OCT ( , PH 1; 25
I.D. No. 41263
429 South 18`r' Street iC'?HBERLAND COUNTY
Camp Hill, PA 17011 PENNSYLVANIA
(717) 730-7310
HEMPT BROS., INC., ) IN THE COURT OF COMMON PLEAS
Plaintiff ) OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS. )
NO. 2012-2444 CIVIL TERM
SETH B. HUGHES and JENNIFER )
A. HUGHES, his wife, individually and ) CIVIL ACTION - LAW
HUGHES CONTRACTING, INC., )
Defendants )
PRAECIPE
TO THE PROTHONOTARY:
Please mark the judgment entered in the above-referenced matter against Seth B. Hughes
and Jennifer A. Hughes SATISFIED.
Please mark the judgment entered in the above-referenced matter against Hughes
Contracting, Inc., SATISFIED.
Please mark the above-referenced matter settled and discontinued.
Respectfully submitted,
BANGS LAW OFFICE, LLC
MICHAEL L. BANGS
Attorney for Plaintiff
429 South 18th Street
Camp Hill, PA 17011
(717) 730-7310
Supreme Court ID #41263
Date: October 9, 2012