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HomeMy WebLinkAbout13-3811 • q CLEVELAND BROTHERS EQUIPMENT IN THE COURT OF COMMON PLEAS OF COMPANY, INC., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff ' b i-7-3v/ &aj vs. CIVIL ACTION NO. 08 -3915 Civil Term H. A. BROWN alk/a H. ALROY BROWN, Defendant JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF REVIVAL OF JUDGMENT TO THE PROTHONOTARY: Please issue a Writ of Revival of lien of judgment entered at No. 2008 -3915 and enter it in the judgment index against H.A. Brown a/k/a H. Alroy Brown, defendant, in the amount of $60,000 plus continuing interest and costs. Date: July 2, 2013 Brian . Downey (PA 59891) f „ 7 Justin G. Weber (PA 89266) e PEPPER HAMILTON LLP m co 100 Market Street, Suite 200 = � r- --Post Office Box 1181 "' r PA 17108 -1181 --A ry Harrisburg, <� 717.255.1155 =jg. `_' ._. 717.238.0575 Z;,�y downeyb @pepperlaw.com� weberjg@pepperlaw.com Attorneys for Plaintiff Cleveland Brothers Equipment Co., Inc. CERTIFICATE OF SERVICE I hereby certify that on July 2, 2013, I served a copy of the foregoing Praecipe for Writ of Revival of Judgment on Defendant by United States mail, first class postage prepaid, addressed as follows: H.A. Brown a/k/a H. Alroy Brown 257 Whiskey Springs Road Dillsburg, PA 17019 David J. Lenox, Esquire 8 Tristan Drive Suite 3 . Dillsburg, PA 17019 Just' . Weber (PA 89266) CLEVELAND BROTHERS EQUIPMENT IN THE COURT OF COMMON PLEAS OF COMPANY, INC., CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff 13-39- VS. CIVIL ACTION NO. 08 -3915 Civil Term H. A. BROWN a/k/a H. ALROY BROWN, Defendant JURY TRIAL DEMANDED WRIT OF REVIVAL OF JUDGMENT To: H. A. Brown a/k/a H. Alroy Brown 257 Whiskey Springs Road Dillsburg, PA 17019 (1) You are notified that the plaintiff has commenced a proceeding to revive and continue the lien of the judgment entered at No. 2008 -3915. (2) The plaintiff claims that the amount due and unpaid is $60,000, plus continuing interest and costs of suit. (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 plaintiff may be entered without a hearing and you may lose your property or other important rights. c - 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 BEDFORD STREET CARLISLE, PA 17013 (717) 249 -3166 Date: thonotary ZAV r E 4L�rLL 33 -.S"v SHERIFF'S OFFICE OF CUMBERLAND COUNYr,, Ronny RAnderson 10 TH'E PROT}-iON0 fARY Sheriff �{c� T 2�1 3 SEp "9 �3M 10= Jody S Smith w Chief Deputy ��♦ � Richard W Stewart ' CUMBERLAND COUHTY Solicitor OFF:IE OF Tt E Vt MIFF E� S Y LVA fd I A Cleveland Brothers Equipment Co., Inc. Case Number vs. 2013-3811 H.B. Brown SHERIFF'S RETURN OF SERVICE 08/14/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: H.B. Brown, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Writ of Revival according to law. 08/21/2013 The requested Writ of Revival returned by the Sheriff of York County, the within named Defendant H.B. Brown, not found. Richard Keuerleber, Sheriff, Return of Service attached to and made part of the within record.Address is in Cumberland County. 08/23/2013 03:56 PM- Deputy Noah Cline, being duly sworn according to law, served the requested Writ of Revival by handing a true copy to a person representing themselves to be Herbert A. Brown, Owner, who accepted as"Adult Person in Charge"for H.B. Brown at 257 Whiskey Springs Road, South Middleton, Dillsburg, PA 17019. NOAH CLINE, DEPUTY SHERIFF COST: $35.24 SO ANSWERS, August 27, 2013 RbNW R ANDERSON, SHERIFF (c)CcuntySuite Shentt,Teleosott.Inc. SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber PETER J. MANGAN, ESQ. Sheriff Solicitor Reuben B Zeager Richard E Rice, II Chief Deputy, Operations Chief Deputy,Administration CLEVELAND BROTHERS EQUIPMENT CO., INC. Case Number vs. H.B. BROWN a/k/a H.ALROY BROWN 13-3811 CIVIL SHERIFF'S RETURN OF SERVICE 08/21/2013 SHERIFF RICHARD P KEUERLEBER, BEING DULY SWORN ACCORDING TO LAW, STATES HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: H.B. BROWN A/K/A H.ALROY BROWN, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK.THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED WRIT OF REVIVAL (WOREV)AS"NOT SERVED"AT 257 WHISKEY SPRING ROAD, DILLSBURG, PA 17019. THIS ADDRESS IS IN CUMBERLAND CO. SHERIFF COST. $19.00 SO RS, August 21, 2013 RICH AD P KEUERLEBER, SHERIFF ------------------------------------------- ------------------------------------------- ------------------------------ ----------------- NOTARY Affirmed and subscribed to before me this 21ST day of AUGUST 2013 VA ib.ar Seal (c)CountySuite Sheriff,Teleosoft,Inc. Lisa L.Thorpe. Notary Public City of York, York 64 tj My Commission Expires Aug. 12, 20'_' MEMBER MNSYNAWA ASEC.1AT16t7 G=t.:-'