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HomeMy WebLinkAbout02-2502EUGENE B. HOCKENBERRY, Plaintiff Vo JOHN H. BROUJOS and WILLIAM D. FEUCHTENBERGER, t/d/b/a GREASE MONKEY, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O~-~ C;~7-~ CIVIL ACTION - LAW PRAECIPE Kindly enter judgment against the Defendants on the attached District Justice Judgments in the amount of $8,143.50. Respectfully submitted, E [u~e 60~ ~. Second S ~n~ ~te ~ Harrisburg, PA 17108 (717) 236-8000 EUGENE B. HOCKENBER~, .. fN TIlE COURT OF COMMON PLEAS FLa[ntiff : ~]~-2{K~X~COUNTY, PENNSYLVANIA JC~N H. BROUJOS and WILLIAM: cIvIu ACTION - To John H. Broujos md William, Defendant(s) 5. Feudicenberger, w'd/-D/'.a. Grease bbnkey ,~ You are hereby not'lf~ed that on [l~ ~! h,~m . May 21 ,X~ 2902ths following (Judgment) has been~ntered against you in the above- captioned case. District Justice judgment in the amot~lt of $8~143.50 [)ATE: I pro.per Prothonotary hereby certify that the name and address of the person(s) to receive this notice is: John H. Broujos William D. ~euchtenber~er t/d/b/a Gr~ ~bnkey ~/d~/a Grease M~key 2513 ~ttysbur~ ~. 2313 ~ttysbur~ ~. C~ ~11, FA i/UI1 C~ Hill, PA 17011 A John H. Broujos and William p. Defendido/a Feuahtenberger, t/d/b/a De fe nd idol/as Grease Monkey POt este me¢l[O se le esta notLficando que el de May 21 _ del ~ 2002, e~/La siguiente · - ~ ---- (Fa[lo) ha eLdo anotado en contra suya en el caso mencionado em el epigrafe. FF. CIIA: I'rotonotario Certifico que la ,[guiente direccion es la del defendido/a segun indicada en el certlficado de residencia~ John H. Brouj os t/d/b/a Grea~e Monkey 2313 Gettysburg Rd. William D. Feuchtenberger c/d/b/a Grease Monkey 2313 Gettysburg Rd. camp,Hill, PA 17011 Abogadc (lek Demandante COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBEI~.L,~ID 09-1-01 CI",.~LES A. CLEMENT, GR. Address: 400 BRI'DGI~ STREET O~E ~ ~ONS 'SUITE 3 ~e~o~: ~7~? 774 - 5989 ATTORNEY FOR PLAINTIFF : FRIEDMAN AND KING, P.C/JOHN KING,HSQ POBOX 984 600 N. SECOND ST/ 5TH FL HARRISBURG, PA 17108 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS ~HOCKENBERRY, ~-'OGEN*~ B ~ 545 PAUL AVE LEWISBERRY, PA 17339 DEFENDANT: NAME aad ADDRESS UJOHN BROUJOS/T/B/A GREASE MONKEY, 2313 GETTYSBURG 'ROAD CAMP HILL, PA 170:11 L Docket No.: CV- 0000150 - 02 ] Date F ed: 3/12/02 THIS IS TO NOTIFY YOU THAT: ~] Judgment was entered for: (Name) Mc~c~,,-~l~v: ~r~,-R R ~'~ Judgment was entered against: (Name) .'rc~t~' m~c~'~TOSi/ql/m/~, c'.~a.q~ MOt,~'~'~[ in the amount of $ R: 14a_ ~0 on: Defendants are jointly and severally liable. Damages Will be assessed on: '~ This case dismissed without prejudice~ Amount of Judgment Subject to Attachment/Act 5 of 1996 $. Levy is stayed for days or [] generally stayed. Objection to levy has been filed and hearing will be held: (Date ~f Judgment) (Date & Time) Amount of Judgment $ 8,000.01 Judgment Costs $ 143.51 Interest on Judgment $ o 00 Attorney Fees $ .00 Total $ 8,143.50 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ Date: Place: Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRiPT FORM WITH YOUR NOTICE OF APPEAL; APR' 2 ~0~Date ~ ~. ~~i .L ,District jUstiCe I Certify that this is a true an/d~c~rect c~,y~ o~e~of the,,~ngs containing the judgment. IAPR 16 2002 Date (_~',~ ,District Justice I My commission expires first Monday of January, 2008 ~ ' ~ ' SEAL AOPC 315-99 ~OMMONWEALTH OF PENNSYLVANIA COUNTY OF' COM~ERI~M~E) 09-1-01 CHAELES A. CLEMENT, JR. 400 BRIDGE STREET OLDE TOWRE COMMONS 'SUITE 3 NEW CUMBERLAND, PA 'r.~,~o,,,: (717 774-5989 17070 ATTOI~TEY FOR PLAINTIFF FRIEDMAN AND KING, P.C/JOHN KING,ESQ POBOX 984 600 N. SECOND ST/ 5TH FL HAP~ISBURG, PA 17108 NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFFCIVIL CASE NAME and ADDRESS __ ~-HOCKENBEERY, EUGENE B 545 PAUL AVE LEWISBEERY, PA 17339 DEFENDANT ~AME and ADDRESS r-jOHN BROUJOS/T/B/A GREASE MON'Y~Y, ~ 2313 GETTYSBURG ROAD CAMP HILL, PA 17011 L Docket No.: CV'- 0000150- 02 lDate Filed: 3/12/02 THIS IS TO NOTIFY YOU - Judgment:' - ' · Judgment was entered for: (Name) ~qnr,~*mum*~*n*gv: ,.~mal~ ~ . Judgment was entered against: ~me~ ~~E~/~A ~W~R Mn~ in the amount of $ R. 1~ _ g~, on:~ ~ (Date of Judgment) 4/1~/n3 Defendants are jointly and sevetafl~ liable¢." Damages will be assessed on: "~ This case dismissed without prej~t~e. Amount of Juogmem Subject to Attachment/Act 5 of 1996 $. Levy is stayed for days or [] generally stayed, ~---~ Objection to levy i~as been filed and heanng will ee held: (Date & Time) Amount of Juagment $ 8,000.01 Judgment Costs $ 143.5(] Interest on Judgment $ . O0 Attorney Fees $ .00 Total $ 8,143.50 Post Judgroent Credits Post Jud~kmen[ Cos'ts Certified 6,udgmeo't Total Date: Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEA,S, ~tC, l~ L DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRA~NSCR~PT FORM WI~H~6UR I~(~YI'OE OF APPEAL. APR I 2 2002 Date [ I codify that this ~s a true a~ correct cqpy of th~co~of th~e~n~ My commission expires first Monday of January, 2008 ~- SEAL AOPC 315-99 IIIJlJll EUGENE B. HOCKENBERRY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : JOHN H. BROUJOS AND WILLIAM D.: FEUCHTENBERGER, t/d/b/a GREASE : NO. 02-2502 Civil Term MONKEY, Defendants : PETITION TO STRIKE OFF JUDGMENT WITH STAY OF PROCEEDINGS TO THE HONORABLE, THE JUDGES OF THE SAID COURT: The petition of John Broujos, identified herein as Defendant, and one of the two parties named in district justice action and the judgment referred to herein, respectfully represents: 1. On March 12, 2002, Plaintiff Eugene Hockenberry filed suit against Grease Monkey before District Justice Charles A. Clement, Jr., of 400 Bridge Street, Olde Towne Commons - Suite 3, New Cumberland, PA 17070 address, for a claim for over $8,000.00 for work improperly performed at the lube and oil service. 2. The complaint was allegedly served upon an adult at the address of the Grease Monkey business at 2313 Gettysburg Road, Camp Hill, PA 17011. 3. At no time was the complaint or any notice of suit or demand for payment prior to suit served upon, delivered to, or mailed to John H. Broujos and/or William P. Feuchtenberger. 4. On April 12, 2002, a default judgment was entered against Defendant John H. Broujos TA Grease Monkey, by District Justice Charles A. Clement, Jr. Copy is attached hereto and made a part hereof as Exhibit A. 5. On May 21, 2002, the District Justice judgment in the amount of $8,143.50 was filed in the Court of Common Pleas of Cumberland County and entered against John H. Broujos and William D. Feuchtenberger, TA Grease Monkey. See copy of judgment attached hereto and made a part hereof as Exhibit B. This copy was the first occasion Defendant was aware of any action, heating, or judgment. 6. This judgment was improperly and without authority entered and jurisdiction of the person not obtained for the reasons following: (a) On the 15th day of December, 1999, John H. Broujos sold Grease Monkey to KBL Petroleum, Inc., (The incorrect name KPR Petroleum, Inc. was supplied by the company to Petitioner at one point in time; the name has been corrected to reflect the true name of the company, KBL Petroleum, Inc.) owned by Joe Ballas and Joe Krahe of 1680 Route 286 West, Indiana, PA 15701. (b) Defendant was not the owner of Grease Monkey at the time the incident as alleged by Plaintiff to have occurred, having sold the business to KBL Petroleum, Inc. as set forth above. (c) Plaintiff, through his attorney, served the complaint only upon a person at the Grease Monkey place of business, based upon a Fictitious Name Act registration, which was not withdrawn. Defendant was not served at any point. Defendant was not made aware of the alleged incident evoking the judgment. (d) Until he received notice that judgment had been entered against him as the owner of fictitious name Grease Monkey, Defendant was not aware that any action had been instituted against him. (e) Plaintiff's attorney knew Defendant as an attorney and his office had had legal proceedings with Defendant's fima, Broujos & Gilroy, PC, and also knew of Defendant personally and had conversations and correspondence therewith. He failed to call personally to Defendant to advise him of the action as a courtesy, if not an obligation, and to seek a negotiated settlement. He failed to call the manager of the business to relay any messages or to find who was the owner, relying upon the Fictitious Name registration law only. He could have made an effort to determine whom the true owners of Grease Monkey were at the time the alleged incident occurred by going to the business and asking the employees or looking at the posted sales tax license, and other means. 7. Defendant never had jurisdiction of either party by personal service thereon. 8. Plaintiff threatens to execute upon Defendant on the judgment. 9. William D. Feuchtenberger deceased on or about 1993 and his estate was closed. 10. Upon receipt of notice of judgment by Defendant, Defendant immediately notified Plaintiff's counsel of the actual owners, giving him the names of owners, and address of owners and later the phone number. WHEREFORE, your Defendant prays this Honorable Court to grant a Rule upon Plaintiff Eugene Hockenberry, to show cause why the judgment heretofore entered in this case against Defendant should not be stricken, all proceedings in the meanwhile against Defendant to stay. 4 NO~ Hanove~ ~treet Carlisle, PA 17013 (717) 243-4574 September .~, 2002 I verify that the statements made in this pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: September {~ , 2002 COMMONWEALTH bF ~E~NSYLVANIA COUNTY OF: CUMBE~T.AND Mag D/si. No.: 09-1-01 CHARLES A. CLEN~NT, JR. ~r,,s' 400 BRIDGE STREET -Or.nE ,TOWNE. COMMONS -SUITE 3 · Telephonei (717.) '774-5989 ~ 17070 ' ATTOP.NK~ FOR PLAINTIFF.'-: FRIEDMAN AND KING, P.C/JOHNKING, ESQ POBOX 984 600 N. SECOND ST/ 5TH FL HARRISBURG, PA 17108 THIS IS TO NOTIFY YOU THAT:. Judgrr~r,t: I-~ Judgment was entered for: (Name) ~ Judgment was entered against: (Name) NOTICE OF JUDGME T/'rRANSCRIPT CIVIL CASE PLAINTIFF: ; NAME and ADDRESS F-HOCF~NBERRY, EUGENE B 545 PAUL AVE ~.EWISBERRY, PA 17339 VS. DEFENDANT: NAM~ and ~DD~ESS F-JOHN BROUJOS/T/B/A ,G~"~SE MONKEY, 2313 GETTYSBURG "ROAD CAMP HI.~L, PA 170,11 OocketNo.: CV-0000150-02I ~ Date Filed: 3/12/02 in the amount of $ R: 14~_~11 on: (Date .of Judgment) ~] Defendants are jointly and severally liable. (Date & Time) -'-]Damages will be assessed on: ---]This case dismissed without prejudice. [--~ Amount of Judgment Subject to Attachment/Act 5 of 1996 $ r-'] Levy is stayed for__ days or ~ generally stayed. -'-]Objection to levy has been filed and hearing will be held: Amount of Judgment $ 8,000.00 Judgment Costs $ 143.50 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 8,143.50 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ Date: Ti me: Place: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTfTRA_NSCRJPT FORM WITH YOUR NOTICE OF APPEAL. APR12 200~Date ~ ~-~--~' _, District Justice ,certify that this is a true an/d~,~e~ontaining the judgment. APR ! 6 2002 DateC~~~~~:~_' ~' . '~',~' , District Justice My commission expires first Monday of January, 2008 AOPC 315-99 ~ '¢ ~ ~ t~ ~ + ~ SEAL EUGENE B. HOCKENBERRY, Plaintiff Vo JOHN H. BROUJOS and WILLIAM D. FEUCHTENBERGER, t/d/b/a GREASE MONKEY, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. O~ -- ~rOD~ C~o~ : : CIVIL ACTION - I_~.W : : PRAECIPE Kindly enter judgment against the Defendants on the attached District Justice Judgments in the amount of $8,143.50. Respectfully submitted, ~~~e Harrisburg, PA 17108 (717) 236-8000 EU(~ B. HOCKENBEPd~, '. IN TIlE COURT OF COMMON PLEAS To Jo~ H. Broujos ~d Willi~ Defendant(s) D. ~u~[e~oerger, ~/d~o/a G~e ~nkey You are he:~no['LE[ed that on ~ ~ 21 2~O~he fo/Lowing (JudgmenC) has been entered against you in the above- captioned case. Distort J~tice 3ud~nt in the ~o~t of $8,143.50 Prothonotary [ hereby certify that the name and address of the proper person(s) to receive this notice is'. ........ John H. Broujos William D. Feuchtenber§er _ .> t/d/b/a Gz~ase bbnkey c/d/b/a Grease Monkey 2315 Gettysburg Rd. 2513 Gettysburg Rd. Camp Hill, FA 17011 Camp Hill, PA 17011 a John H. Broujos and William P. DefendLdo/a Feuchtenberger, t/d/b/a De fendidos/as Grease Monkey Pot este me,ILo se le esta notLficando que el de ~hy 21 .~ del ~K 2002, el/la siguiente ~ (Fa[lo) ha s[do anotado en contra suya en el caso ,nenc[onado en el epigrafe. FECilA: ['rotonota rio Certfffco que la n[guiente d£recclon es La del defendido/a segun lndicada en el certificado de re~ idencia: John H. Brouj os t/dflu/a Grease Honkey 2513 Gettysburg Rd. Cal~' I4il I, FA l/Oil William D.Feuchtenberger t/d/b/a Grease Monkey 2313 Gettysburg Rd. Lamp,Hill, PA 17011 Ak~ogado del Demandante EUGENE B. HOCKENBERRY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : CIVIL ACTION - LAW JOHN H. BROUJOS AND WILLIAM D.: FEUCHTENBERGER, t/d/b/a GREASE : NO. 02-2502 Civil Term MONKEY, Defendants : .ORDER TO ISSUE RULE Court ~ts a Rule on Plaintiffto show cause why ~e Jud~ent agai~t Defend~t to the above number ~d tem~ should not be s~cken R I ' ' ~ ~ ) . u e ret~able wi~in ~ays a~er se~ice. Proceedings against Defend~t ~d ~1 peBons claim~g by, ~om, or ~der him, p~icul~ly those mentioned in the default jud~ent, to stay until dete~ination of the Rule. J John H. Broujos, Esquire for Defendant John F. King, Esquire for Plaintiff 02 %P 1 ? p?i I: ri5 PENNS'I'L.V/vN!A EUGENE B. HOCKENBERRY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA EUGENE B. HOCKENBERRY, Plaintiff JOHN H. BROUJOS and WILLIAM D. FEUCHTENBERGER, t/d/b/a GREASE MONKEY, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-2502 Civil Term : : CIVIL ACTION - I..~.W : ANSWER TO RULE AND NOW comes the Plaintiff in the above-captioned matter in answer to the Rule issued by the Honorable George E. Hoffer, President Judge, and responds to the Defendants' underlying Petition to Strike Off Judgment With Stay of Proceedings as follows: 1. It is admitted that the Plaintiff filed suit against John H. Broujos and William D. Feuchtenberger, t/d/b/a Grease Monkey, seeking judgment for $8,000.00, together with costs. 2. It is admitted that the Complaint was served at the address of the Grease Monkey business. By way of further answer, it is averred that the service was properly made pursuant to the filings in the Corporation Bureau, Department of State, Commonwealth of Pennsylvania, which filings indicated that the Grease Monkey was a fictitious name, with a business address at 2313 Gettysburg Road, and that the individuals interested in the business were William Feuchtenberger and John Broujos. A copy of the Corporation Bureau filing is attached hereto, marked Exhibit "A", and incorporated herein by reference. 3. It is admitted that the Complaint was not served, delivered or mailed to any address other than that indicated in the filings in the Corporation Bureau, Department of State, Commonwealth of Pennsylvania. 4. It is admitted that a default judgment was entered against Defendants, John H. Broujos and William Feuchtenberger, t/d/b/a Grease Monkey. 5. It is admitted that the District Justice Judgment in the amount of $8,143.50 was filed in the Court of Common Pleas of Cumberland County, and entered against John H. Broujos and William D. Feuchtenberger, t/d/b/a Grease Monkey. 6. It is denied that the judgment was improperly and without authority entered, and proof thereof is therefore demanded. It is also denied that jurisdiction of the person was not obtained, and proof thereof is therefore demanded. A. The Plaintiff is without sufficient information to determine whether on December 15, 1999 John H. Broujos sold Grease Monkey to KBL Petroleum, Inc., and the averment is therefore denied, and proof thereof is therefore demanded. B. The Plaintiff is without sufficient information to determine whether the Defendant, John H. Broujos, was not the owner of Grease Monkey at the time the underlying incident as alleged by the Plaintiff occurred, and the averment is therefore denied, and proof thereof is therefore demanded. C. It is admitted that Plaintiff, through his attorney, served the Complaint at the address of the Grease Monkey place of business. It is denied that Defendant Broujos was not served at any point, and that Defendant Broujos was not made aware of the alleged incident evoking the judgment, and proof thereof is therefore demanded. By way of further answer, it is averred that the Plaintiff properly served the Complaint based upon the filings in the Corporation Bureau, Department of State, Commonwealth of Pennsylvania. D. The Plaintiff is without sufficient information to determine whether Defendant Broujos was not aware that any action had been instituted against him until he received that judgment had been entered against him, and the averment is therefore denied, and proof thereof is therefore demanded. E. It is denied that the Plaintiff's attorney knew Defendant Broujos personally or professionally prior to the commencement of the action on behalf of the Plaintiff, and proof thereof is therefore demanded. It is admitted that the Plaintiff's attorney did not call personally to Defendant Broujos to advise him of the action. By way of further answer, it is averred that the Plaintiff proceeded properly by relying upon the filings in the Corporation Bureau, Department of State, Commonwealth of Pennsylvania. It is admitted that the Plaintiff's attorney did not perform any investigatory work beyond the proper investigation of the owner by way of filings in the Corporation Bureau, Department of State, Commonwealth of Pennsylvania. By way of further answer, it is averred that Plaintiff's counsel properly relied upon said filings in the Commonwealth of Pennsylvania, and that said filings are designed for that very purpose. 7. It is denied that the Plaintiff (erroneously identified as Defendant in Defendants' Petition to Strike Off Judgment With Stay of Proceedings) never had jurisdiction of either party by personal service thereon, and proof thereof is therefore demanded. 8. It is admitted that the Plaintiff's attorney informed Defendant Broujos that he had been instructed by the Plaintiff to execute on the judgment if Defendant Broujos did not provide to Plaintiff's attorney information documenting other ownership of the business, Grease Monkey. 9. The Plaintiff is without sufficient information to determine whether William D. Feuchtenberger died on or about 1993 and his estate was closed, and the averment is therefore denied, and proof thereof is therefore demanded. 10. It is denied that upon receipt of notice of judgment by Defendant, the Defendant immediately notified Plaintiff's counsel of the actual owners, giving names of owners and address of owners, and later the phone number, and proof thereof is therefore demanded. By way of further answer, it is averred that Defendant Broujos provided verbal information regarding a supposed entity that had allegedly bought the business, which entity could not be located, either through corporate filings or any other Commonwealth of Pennsylvania filings. By way of further answer, it is averred that Defendant Broujos has recently provided further information to Plaintiff's counsel of an alleged new owner, which new ownership on the date of the incident in the underlying action (12/18/01) has not yet been confirmed. WHEREFORE, the Plaintiff respectfully requests this Honorable Court to deny the Defendants' Petition to Strike Off Judgment pending further proceedings and determinations of ownership of the business in question, that being Grease Monkey. Respectfully submitted, FRIEDMAN & KING, P.C. (Jphn F. King, ~'qUir~j ~00 N. Second~lStreet Penthouse Suite P. O. Box 984 Harrisburg, PA 17108 (717) 236-8000 Attorney for Plaintiff k/p:pleadings\hockenbe.ans VERIFICATION I, John F. King, Esquire, hereby acknowledge that I am the attorney for the Plaintiff in the foregoing action; that I have read the foregoing Answer to Rule; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authori~~?--~ .~ Exhibit A EUGENE B. HOCKENBERRY, Plaintiff Vo JOHN H. BROUJOS and WILLIAM D. FEUCHTENBERGER, t/d/b/a GREASE MONKEY, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-2502 Civil Term : CIVIL ACTION - I~W CERTIFICATE OF SERVICE I, John F. King, Esquire, hereby certify that on October 9, 2002, I served a copy of the within A~swer to Rule, by fax transmission to (717) 243-8227, and by depositing same in the United States Mail, first class, postage prepaid, addressed as follows: John H. Broujos, Esquire Broujos & Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 FRIEDMAN & KING, P.C. /~ohn F./ / ~ ~- ~ing, E~ire 0500 N. Second Street Penthouse Suite P. O. Box 984 Harrisburg, PA 17108 (717) 236-8000 EUGENE B. HOCKENBERRY, Plaintiff Vo JOHN H. BROUJOS and WILLIAM D. FEUCHTENBERGER, t/d/b/a GREASE MONKEY, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-2502 Civil Term : : CIVIL ACTION - I.~W : : PRAECIPE Kindly mark the above-captioned matter as satisfied and discontinued with prejudice. Respectfully submitted, FRI~D~& KING~ P.C. ?JoSh F. K~n~, 'E,squire 1609 N. Seco~~eet [P~thouse Suite ~< O. Box 984 Harrisburg, PA 17108 (717) 236-8000 Attorney for Plaintiff