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Home My WebLink About14-0996 LOU S. DRAYER IN THE COURT OF COMMON PLEAS OF 815 School House, Lane CUMBERLAND COUNTY, PENNSYLVANIA Lewisberry, Pennsylvania 17339 Plaintiff V. No. 2009 -2685 CIVIL TERM OLLIE A. MICK, III Q / �, 32 Montsera Road ! , l �b v` U "'` , Carlisle, Pennsylvania 17015 = :;Q CO { -� Defendant CD r . --+ PRAECIPE FOR WRIT OF REVIVA To the Prothonotary: =' Issue writ of revival of lien of judgment entered at the Court of Common Pleas of Cumberland County, Pennsylvania, Civil Term No. 2009 -2685, and enter it in the judgment index against 011ie A. Mick, III, in the amount of $26,757.03 with interest from April 29, 2009 * . a 3 . poi At Z -Zp- (� 4 • q r Bret P. Shaffer, Esquire Q. aL I.D. 309180 19 West South Street Carlisle, Pennsylvania 17013 Phone: (717) 249 -6873 00 Fax: (717) 249 -5755 0n $ bshaffer @baricscherer.com 5-0 c� .2 o o l�r�r -•�- o� �ce��i,sC sve � *It is noted that this Praecipe does not modify any agreement now existing between the parties to satisfy the judgment for an amount less than the full amount. LOU S. DRAYER IN THE COURT OF COMMON PLEAS OF 815 School House Lane CUMBERLAND COUNTY, PENNSYLVANIA Lewisberry, Pennsylvania 17339 Plaintiff V. No. 2009 -2685 CIVIL TERM OLLIE A. MICK, III �� ✓� L �/✓7 32 Montsera Road Carlisle, Pennsylvania 17015 Defendant WRIT OF REVIVAL To 011ie A. Mick, III: (1) You are notified that the plaintiff has commenced a proceeding to revive the lien of the judgment entered at the Court of Common Pleas of Cumberland County, Pennsylvania, Civil Term No. 2009- 2685. (2) The plaintiff claims that the amount due and unpaid is $26,757.03 with interest from April 29, 2009. (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. 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. C os .� s I L 0 P Cumber and County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 ('717) 249 -3166 Date: David D. Buell, Prothonotary Deputy Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY c/L,t, THE 1 R071i0!i0-i7,P; .0„ culooy ss.P 2014 HAP 1 9 NI 1: CUMBERLAND COUNTY PENNSYLVANIA )F THE 6H-E,RIFP Lou S. Drayer vs. 011ie A. Mick, III Case Number 2014-996 SHERIFF'S RETURN OF SERVICE 03/13/2014 05:22 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Writ of Revival by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: 011ie A. Mick, III at 32 Montsera Road, Dickinson Township, Carlisle, PA 17015. DAWN KELL, DEPUTY SHERIFF COST: $35.27 SO ANSWERS, March 14, 2014 RON R ANDERSON, SHERIFF (c) CountySuito Sheriff, Teleosoft, !nc, LOU S. DRAYER 815 School House Lane Lewisberry, Pennsylvania 17339 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2014-996 CIVIL TERM OLLIE A. MICK, III 32 Montsera Road Carlisle, Pennsylvania 17015 Defendant PRAECIPE TO ENTER DEFAULT JUDGMENT PURSUANT TO Pa.R.C.P. 3031 TO THE PROTHONOTARY: Please enter judgment in favor of the Plaintiff, Lou S. Drayer, and against the Defendant, 011ie A. Mick, III, for failure to file an answer to the Writ of Revival of Plaintiff. A true and correct copy of the Notice of Default is appended hereto as Exhibit "A". A true and correct copy of the Certificate of Mailing for the Notice of Default is appended hereto as Exhibit "B". I certify that the Notice of Default was given in accordance with Pa.R.C.P. 237.1. Pursuant to the Soldiers' and Sailors' Civil Relief Act, 50 U.S.C. App. § 520, An affidavit setting forth facts showing that the defendant is not in military service is appended hereto as Exhibit "C". Plaintiff requests judgment in the amount of $26,757.03 with interest from April 29, 2009. 4/6. so pd • / 3 s? otioiciv2 1Vokce in it lad Respectfully submitted, BARIC SCHERER LLC • Bret P. Shaffer, Esquire LD. 309180 19 West South Street Carlisle, Pennsylvania 17013 Phone: (717) 249-6873 Fax: (717) 249-5755 bshaffer@baricscherer.com LOU S. DRAYER 815 School House Lane Lewisberry, Pennsylvania 17339 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2014-996 CIVIL TERM OLLIE A. MICK, III 32 Montsera Road Carlisle, Pennsylvania 17015 Defendant TO: OLLIE A. MICK, III 32 Montsera Road Carlisle, Pennsylvania 17015 Date of Notice: May 8, 2014 IMPORTANT NOTICE 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 BARIC SCHERER LLC Bret P. Shaffer, Esquire 19 West South Street Carlisle, PA 17013 (717) 249-6873 EXHIBIT "A" "8" iI8IBx3 NI:POSTAL SERVICE UNITED STATES Certifitate Of This Certificate at Mailirig piriYideievidence' thatMail has beanPnsnted tb-USPSO tee. This torn may be uSed for clometti6-0nd intimations!the: From: Bar i c ScIre,r-e,r LLC 10i V1 Su -0S 110t3 Te: 011ie A. M, I 32. tvloni--sto CarliSi-e PA 1-1016 PS Form 3817, April 2007 PSN 7530-02-000-9065 LOU S. DRAYER 815 School House Lane Lewisberry, Pennsylvania 17339 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 14-996 CIVIL TERM OLLIE A. MICK, III 32 Montsera Road Carlisle, Pennsylvania 17015 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND The undersigned attorney hereby verifies that he is the attorney for the Plaintiff in the above -captioned matter, and that on information and belief he has knowledge of the following facts, to wit: 1. The Defendant, Olie A. Mick, III, is not in the military or naval service of the United States or its allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. 2. The Defendant, Olie A. Mick, III, is more than 21 years of age and has a current address of 32 Montsera Road, Carlisle, Cumberland County, Pennsylvania 17015. This statement is made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: July 7, 2014 ./f --- Bret P. Shaffer, Esquire Baric Scherer LLC I.D. # 309180 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 EXHIBIT "C" CERTIFICATE OF SERVICE I hereby certify that on July 11, 2014, I, Bret P. Shaffer, Esquire, of Baric Scherer LLC did serve a copy of the Praecipe To Enter Default Judgment Pursuant to Pa.R.C.P. 3031, by first class U.S. mail, postage prepaid, to the party listed below, as follows: OLLIE A. MICK, III 32 Montsera Road Carlisle, Pennsylvania 17015 Bret P. haffer, Esquire I.D. 309180 19 West South Street Carlisle, Pennsylvania 17013 Phone: (717) 249-6873 Fax: (717) 249-5755 bshaffer@baricscherer.com