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HomeMy WebLinkAbout13-0942 GULF OIL LIMITED PARTNERSHIP, Plaintiff v. J. WAYNE MAJOR, individually and d/b/a Super Car Wash and JUL-WAY ENTERPRISES, INC., Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION -LAW og- 14(~~ NO.99-~6}7 Civil Term PRAECIPE TO REVIVE JUDGMENT BY AGREEMENT OF PARTIES PURSUANT TO PA. R.CIV.P. 3025 AND 3027 TO THE PROTHONOTARY: t~ ~;. r~':~i ~3 cn ~ ~ c~~ ~' c-~ s~ -~:= +~~ ~~ -~, m as N 0 -~, c~ M1~ .C- ~,:~ ~f =~ •-~ ~~:~ ~:, ~a ..~ -~. ~_ _.~ ..-~~ , ;~ f Pursuant to the above-referenced rules, kindly accept for filing the attached Agreement to Revive Judgments in the above-referenced matter, and enter same in the judgment index against each Defendant. BROADS 8~ s~Tpl)d1 LLP By: ~ ~ Mich el W. Win "" One S uth Market S u e P. O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Plaintiff, Gulf Oil Limited Partnership I~~ ~ a~ ~ so ~a 3~f . a o car nu yS.SO G~,bo q,o~ °(, 00 ~ ~lj$~ 874245.1 ~.3. rya ~,/ . O~ ~t~ ~, ~aas~~~~ ~~ << it ~ ~ , a..s ~~~sai.so~d a~ ~~} I X33 l ~~aB~~si 1loh~e Vn~le~ n 4 GULF OIL LIMITED PARTNERSHIP, : IN THE COURT OF COMMON PLEAS ~. Plaintiff : OI: CUMBERLAND COUNTY v. :CIVIL ACTION -LAW 05r ~S'~~ J. WAYNE MAJOR, individually and : NO. 99-~~-Civil Term d/b/a Super Car Wash and JUL-WAY ENTERPRISES, INC., Defendants AGREEMENT TO RF,VIVE JUDGMENTS B The parties hereto hereby agree that the lien of judgment dated March 25, 2003 and July 22, 2003, and entered April I, 2008 in the Court of Common Pleas of Cumberland County at Docket No. 00-7697, be revived, and further authorize the Prothonotary to enter in the judgment index a judgment of revival in the amount of $72,896.71 plus interest at 6% per annum from March 28, 2000 as against J. Wayne Major and Jul-Way Enterprises, Inc., jointly and severally; and $15,000.00 for reasonable, attorney's fees as against J. Wayne Major individually; pursuant to this Court's Orders of March 2S, 2003 and July 22, 2003, copies of which are attached hereto as Exhibit "A" and "B" respectively. GIJLI~ OIL T iD PARTNERSHI JUL-WAY ENTERPRISES, INC. Couns for Gulf it Limit Pat ership ~ J. Wayne Majo WITNESS: Date: ~ ~ I ~ ~ l ~. t ~~ EXHIBIT "A" ~~, GULF OIL LIMITED PARTNERSHIP, Plaintiff v. J. WAYNE MAJOR, individually and d/b/a Super Car Wash and JUL-WAY ENTERPRISES, INC., Defendants ,_.. i IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY CIVII. ACTION -LAW NO. QO-7697 Civil Term ORDER AND NOW, upon consideration of the Joint Stipulation for Entry of Judgment filed by the parties, it is hereby ORDERED that; Judgment is entered in favor of Plaintiff Gulf Oil Limited Partnership and against Defendants J. Wayne Major and Jul-Way Enterprises, Inc., jointly and severally, in the amount of $72,89d.7i, along with interest at ti% per annum from March 28, 2000 until payment is made, and costs of suit; and, 2. Judgment is entered in favor of Plaintiff Gulf Oil Limited Partnership and against Defendant J. Wayne Major, individually, for Plaintiff's reasonable attorneys fees incurred in this matter, in an amount to be subsequently agreed to by the parties, or as determined by the Court after a subsequent hearing Iimited to that issue. BY THE COURT: r 1~ j / lea a~s~~s lei ~~St1ii~(h"~'~' 1~~fnTi~tif i } '~ q~ i , liti9'H+,if??:~ err iJ~,r i~r~. i'~3~ UiQ ~~1 ~t~ ~?~j~ ~rJ~~l~ i~J. ~,.+~t'e4;+i~ f%, , ~~~ ~ T'~; r, EXHIBIT "B" J . i (.,._, r i _ JUG. 2 ~ X003 GULF OIL LIMITED PARTNERSHIP, Plaintiff v. J. WAYNE MAJOR, individually and d/b/a Super Car Wash and JUL-WAY ENTERPRISES, INC., Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION -LAW N0.00-7697 Civil Term ORDER AND NOW, upon consideration of the Joint Stipulation for Entry of Judgment filed by the parties, ~it is hereby ORDERED that 1. Judgment is entered in favor of Plaintiff Gulf Oil Limited Partnership and against Defendant J. Wayne Major, individually in the amount of $15,000 for Plaintiffs reasonable attorney's fees incurred in this matter. 2. This judgment is in addition to the judgment entered by this Court by Order dated March 25, 2003. BY THE COURT: ~u.L~. a2, Zoos v 471540.1 CERTIFICATE OF SERVICE I hereby certify that on February 13, 2013 a true and correct copy of the Praecipe to Revive Judgment by Agreement of Parties Pursuant to Pa. R.Civ.P. 3025 and 3027, was served by means of United States mail, first class, postage prepaid, upon the following: Mr. J. Wayne Major 113 Juniper Drive Mechanicsburg, PA 17055 Thomas S. Beckley, Jr., Esquire Beckley & Madden 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108-1998 ~~~~1.POQ d~ Teresa Laughead r GULF OIL LIMITED PARTNERSHIP, . : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY v. : CIVIL ACTION - LAW J. WAYNE MAJOR, individually and : NO. 13-942 Civil Term d/b/a Super Car Wash and JUL-WAY . ENTERPRISES, INC., : Defendants : MARK JUDGMENT SATISFIED TO THE PROTHONOTARY: Kindly mark all judgments entered to the above docket number as satisfied in full. Respectful submitted, RHOAD. ON LL 1� Date: February 18, J4tJ y 8, 2014 By: , :41,L; Michael 4 Winfield One South arket Square P. O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Plaintiff r,-rz -,.i CO r-- r-,.-- - CO rte. -� n zC., a' r -7-7 5. r2-.--,- ". 937018.3 .X- CERTIFICATE OF SERVICE I hereby certify that on this 18th day of February, 2014, a true and correct copy of the foregoing Mark Judgment Satisfied was served by means of United States mail, first class, postage prepaid, upon the following: J. Wayne Major 113 Juniper Drive Mechanicsburg, PA 17055 Mr. Thomas S. Beckley,Jr.,Esquire Beckley&Madden 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108-1998 49/16-d---