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HomeMy WebLinkAbout00-03050 "o.>~.';'" "L,'. ,.,-.-..',..,.. ,...'., . >:;;'J~.<,'-- ,",'-' .'" , __ ''';'0'"'0 10--:0 . BARBARA RAND, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 00-3050 CIVIL TERM v, : CIVIL ACTION--LA W DuMINIQUE SCALIA, Defendant : JURY TRIAL DEMANDED TO THE PROTHONOTARY: PRAECIPE FORDEFAlJI,T .ITJDGMENT 1. Please enter a judgment in default for the amount of $10,371.60 in the above captioned matter, 2. The undersigned hereby certifies that a copy of the Default Notice was mailed to the d~fendant by first class mail on or about the date indicated, 3, A copy of the Default Notice is attached hereto. Respectfully submitted, Law 0 Ice of James K. Jones, Esquire Dirk E. Berry, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 --"'-- ~.~"' - "i..' " BARBARA RAND, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .>. .' v. : NO. 00-3050 CML TERM : CIVIL ACTION--LA W DOMINIQUE SCALIA, Defendant TO: Dominique Scalia DATE OF NOTICE: July 27,2000 IMPORTANT NOTICE : JURY TRIAL DEMANDED YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRlITEN . ' ,. ,. . APPEARANCE PERSONALLY OR BY AN ATIORNEY AND FILE IN WRlTING\VITH .'..' 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 MAYBE ENTERED AGAINST YOU WIJHOUT 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ;P);:~ f -- Dirk E. Berry, Esquire Attorney for Plaintiff Law Office of James K. Jones, Esquire 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 '..lll, ...~\ ! ;;1 ;, ',,:,,1 "'i ! -"'.""'--" . , . ,;I 'i I I , I I ..1 I ! J .......I_.,'"_._..."'~i&_,"'_,,_.__'"'''_.... "'''lilf . r~ \-> ~ '" --" " ~ "~~ ~~" ,;;.",""=- -..., (') [:: <e" ;:{?i35 -,j iI; c::: ~.:r) G") "'-I;:" C/)"., ~(;' ~O :bO ~ =< l-:- \.;1 f \ '" , "- " '" c. , "-" o Q "'" ,'" ., "f; ()) ;~;121 -.-,h-:: i~~ ::>-C) O:rn ?if -.;; :i::l" ,:1<: ~f:' ~ f\ .. :-t\ (3 ,. ." "' . ~ .; ~,' ~~, ,. . ",,""-, ".;'.,,'-'~b,' ".~>,. . :~ n', . ". -, .~ BARBARA RAND, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO, 0:') -JDSb CIVIL TERM v, CIVIL ACTION--LA W DOMINIQUE SCALIA, Defendant NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff, You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 ~. , 'k; r I i ! i i l i o ' ,,,~ ..-' ;,..,.~~~ ..~ ".~".'.<<:;'""",.,..;,;." , '~'. ,..."'.u_., -0.'","", ~''':';''.k.Ii!.f" !: . BARBARA RAND, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. f.It) - 30a CIVIL TERM v, CIVIL ACTION--LA W DOMINIQUE SCALIA, Defendant COMPlAINT AND NOW, comes Barbara Rand, Plaintiff, by and through her attorney, Dirk E, Berry, Esquire, and respectfully avers the following: 1. Dominique Scalia, Defendant, has borrowed $10,371.60, as enumerated below, from Plaintiff, Barbara Rand, 2, To date, Defendant, Dominique Scalia, has not repaid any of the above loaned amount. 3. The Defendant was fully aware at all times that the amounts borrowed were a loan and that none of it constituted a gift. 4, The amounts enumerated below remain outstanding as loans owed by Dominique Scalia to Plaintiff, Barbara Rand, 5, Item I: $3,680,00 charged to Plaintiffs First USA Credit Card account. Item 2: $781,00 loaned by Plaintiff for Defendant's baiL Item 3: $132,60 loaned by Plaintiff to purchase tires for Defendant's 1992 Dodge Caravan license number PA BV A4584, Item 4, Two checks totaling $1,100,00 withdrawn from Plaintiffs Members Federal Checking Account loaned to Defendant in amounts of $700,00 and $400,00, Item 5: $328,00 loaned to Defendant on or about August, 1999 for Service Max Home Repair Service, ,;:'-" ,. ."",. ""',' .:--Oc" 'lilt;' I .. Item 6: $2,500,00 loaned to Defendant to partially pay her $3,000,00 electric bill. Item 7: $1,000,00 cash loaned to Defendant to pay for her attorney, Paul Orr, for criminal defense work with regard to drug charges, Item 8: $500,00 cash loaned to Defendant at Defendant's request. Item 9: $380.00 loaned to Defendant for car repairs, 6, All enumerated amounts above remain due and owing to the Plaintiff as outstanding loans which have not been paid. WHEREFORE, Plaintiff, Barbara Rand, respectfully requests this Honorable Court, to enter a judgment against the Defendant, Dominique Scalia, in the amount of$10,371.60. Respectfully submitted, A;I S77 /~- Dirk E, Berry, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, P A 17013 (717) 240-0296 ~ 1 verifY that the statements made in this Complaint are true and correct to the best of my knowledge and belief, I understand that false statements herein are made subject to the penalties of 18 Pa, C,S, 94904, relating to unsworn falsification to authorities, "'-f\ Of L.o PI">- "-A-f'> rani. Barbara Rand ~ { ~ t~ r~ ~ " ,t. '" Nt' ~ f ~ . "'";,,~;',, :,: .' '^' ~ 0 a 0 c- o .." (J ~ ? :r. ..... ;V '4 -nG5 p ~~~ 6 U'f1"1 -< *- z::rJ 11:... .~ zc- '--am 8 d ~~: <T> ~D6 'J 0 C> co :-1 :c- -" ---r-"'Ti ..Q c; C 70 ::;: 5:D 7(J 0 ,:.0 v) ~-- rn I >c ~ 6' ~ "7 -- ~ :;) ~ c..., (( V) c:> '1 t J , "- ~- . '~~ SHERIFF'S RETURN - REGULAR 'CASS NO: 2000-03050 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RAND BARBARA VS SCALIA DOMINIQUE DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SCALIA DOMINIQUE the DEFENDANT , at 0008:50 HOURS, on the 12th day of June 2000 at CUMBERLAND COUNTY PRISON 1101 CLAREMONT ROAD CARLISLE, PA 17013 by handing to DOMINIQUE SCALIA a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 16.12 .00 10.00 .00 44.12 So Answers: ~~~,,<:~t R. Thomas Kline Sworn and Subscribed to before 06/13/2000 JAMES K. JONES By: ~ ~ \1_" .... ~<U...Q (\ ,'N.J2)L Deputy eriff tv me this .20 - day of ~..:Juz;o A. D. ~"'- C. /hAi, -.iF rothonotary / f . . - :;:r~ ,w" ,. ,. .~--;" ~,,? " '." -, ~...,. "._, """7". , .", 7.,~~"~_.Jnn]I!'iIA, ".<, !I;~~Llrr _lIMIQ, '.,8 ,""~ ", _'"."~, ."", 'I'.'..~.ftl !I (3 ()."r bevr4.. R6-AttfJ~.,i,'U- 'V b 0 h-\.~ "'; c"., ().R S c...C<.I,~ U Def-evtdtlV"t+ ..U/30/0Q.. , I I.,~,~~, i "'0 I i , I ,an U!13)()oJ),~ ~ ~ cL I:~ ~ (-j)tLOO--.3050). ,. l21.~ ~ J) I~~~~,~J:J~ !.~ ...,., &- ,~.~.~.a.A./. 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(An."""'C7 jt'~t>~'1""q~IiIIQ;l!1I1t"~"fl""'__('''''\.'''''Ii''_nW'''__.''t''''-r.-'''='''''P''''''''--'''''''''''t''''''''''"'"P''''''''~__'oH,,~n~ ..".~~_",,"~,"~ ,-(j.! ,~,,..,,.^" "'f'1""'if_m,,,,':._ BARBARA RAND, Plaintiff DOMINIQUE SCALIA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. c~ - ..*~ CIVIL TERM CIVIL ACTION--LAW NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in v~'iting with the Court yottr defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 BARBARA RAND, Plaintiff! DOMINIQUE SCALIA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. trO- ,~D.-q2Y CIVIL TERM CIVIL ACTION--LAW COMPLAINT AND NOW, comes BArbara Rand, Plaintiff, by and through her attorney, Dirk E. Berry, Esquire, and respectfully avers the following: 1. Dominique Scalia, Defendant, has borrowed $10,371.60, as enumerated below, from Plaintiff, Barbara Rand. 2. To date, Defendant, Dominique Scalia, has not repaid any of the above loaned amount. 3. The Defendant was fully aware at all times that the amounts borrowed were a loan and that none of it constituted a gift. 4. The amounts enumerated below remain outstanding as loans owed by Dominique Scaiia to Plaintiff, Barbara Rand. 5. Item 1: $3,680.00 charged to Plaintiff's First USA Credit Card account. ~ $781.00 loaned by Plaintiff for Defendant's bail. Item 3; $132.60 loaned by Plaintiff to purchase tires for Defendant's 1992 Dodge Caravan license number PA BVA4584. Item 4; Two checks totaling $1,100.00 withdrawn from Plaintiff's Members Federal Checking Account loaned to Defendant in amounts of $700.00 and $400.00. Item 5:$328.00 loaned to Defendant on or about August, 1999 for Service Max Home Repair Service. Item 6:$2,500.00 loaned to Defendant to partially pay her $3,000.00 electric bill. Item 7:$1,000.00 cash loaned to Defendant to pay for her attorney, Paul Orr, for criminal defense work with regard to drug charges. Item 8:$500.00 cash loaned to Defendant at Defendant's request. Item 9:$380.00 loaned to Defendant for car repairs. 6. All enumerated amounts above remain due and owing to the Plaintiff as outstanding loans which have not been paid. WHEREFORE, Plaintiff, Barbara Rand, respectfully requests this Honorable Court, to enter a judgment against the Defendant, Dominique Scalia, in the amount of $10,371.60. Respectfully submitted, Dirk E. Berry, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240~0296 I verify that the statements made in this Complaint are true and correct to the best of my knowledge and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Barbara Rand © SHERIFF'S CASE NO: 2000-03050 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RAND BARBARA VS SCALIA DOMINIQUE RETURN - REGULJtR DAWN KELL Cumberland County, says, the within COMPLAINT & NOTICE was served upon SCALIA DOMINIQUE DEFENDANT , at 0008:50 HOURS, on the 12th day of June at CUMBERLAiqD COUNTY PRISON 1101 CLAREMONT ROAD CARLISLE, PA 17013 by handing to DOMINIQUE SCALIA a true and attested copy of COMPLAINT & NOTICE , Sheriff or Deputy Sheriff of Pensylvania, who being duly sworn according to the together with law, , 2000 and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18 00 16 12 00 10 00 00 44 12 Sworn and Subscribed to before me this ~-o-- day of ~ .3~z~ A.D. [SrSthonotary ~ / , So Answers: R. ~homas Kline 06/13/2000 JAMES K. JONES By: ~a3~O~ Deputy BARBARA RAND, Plaintiff DOMiNIQUE SCALIA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-3050 CIVIL TERM CIVIL ACTION--LAW : JURY TRIAL DEMANDED 'fO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT 1. Please enter a judgment in default for the amount of $10,371.60 in the above captioned matter. 2. The undersigned hereby certifies that a copy of the Default Notice was mailed to the defendant by first class mail on or about the date indicated. 3. A copy of the Default Notice is attached hereto. Respectfully submitted, Law oJ~ce of James K. Jones, Esquire Dirk E. Berry, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 BARBARA RAND, Plaintiff DOMINIQUE SCALIA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 00-3050 CIVIL TERM : : CIVIL ACTION-LAW : : JURY TRIAL DEMANDED TO: Domlnique'Se. alia DATE OF NOTICE: July 27, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A wRrrTEN · APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OB3ECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM TH~ DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A II]EARING 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 OE'/~ LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Dirk E. Berry, Esquire Attorney for Plaintiff Law Office of James K. Jones, Esquire 7 Irvine Row Carlisle, PA 17013 (717) 240-0296