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. `_'
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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.:-'