HomeMy WebLinkAbout00-03051
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BARBARA RAND,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.OO-JaS1 CIVIL TERM
v,
CIVIL ACTION--LA W
LASHAE 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,
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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
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BARBARA RAND,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 60. 3M I CIVIL TERM
v,
CIVIL ACTION--LA W
LASHAE SCALIA,
Defendant
COMPLAINT
AND NOW, comes Barbara Rand, Plaintiff, by and through her attorney, Dirk E, Berry,
Esquire, and respectfully avers the following:
1, During the period of October, 1998 through March, 2000, Plaintiff, Barbara Rand, has
loaned to the Defendant, Lashae Scalia, $2,305,00
2, To date, the Defendant, Lashae Scalia, has not repaid any of the above loaned amount.
3. All of the amounts borrowed were loans and none of it constituted gifts,
4, At all times, the Defendant was aware that the amounts enumerated below were loans
and had to be repaid.
5. Item 1: $2,155,00 loaned to Defendant to allow her to make baiL
Item 2: $150,00 for plane ticket.
6, Defendant is fully aware that all of the above enumerated items were loans and that
she is responsible for paying them in fulL
7, To date, Defendant has refused to repay any amount of these loans.
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WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter judgment
against Defendant in the amount of$2,305,OO,
Respectfully submitted,
L1f)-;;/"'" E_, >
Dirk E, Berry, Esquire
Attorney for Plaintiff
7 Irvine Row
Carlisle, P A 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. I understand that false statements herein are made subject to the penalties
of 18 Pa, C,S, 94904, relating to unsworn falsification to authorities,
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Barbara Rand
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SB~RIFF'S RETURN - NOT FOUND
CASE NO: 2000-03051 P
COMMONWEALTH OF PENNSYLVANIA
, COUNTY OF CUM~ERLAND
,...,
RAND BARBARA
VS
u1?f
SCALIA LASHAE
R. Thomas Kline ,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named defendant, DEFENDANT
SCALIA LASHAE
but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
, NOT FOUND , as to
the within named DEFENDANT
, SCALIA LASHAE
DEFT. COULD NOT BE LOCATED AT ADDRESS STATED
PRIOR TO EXPIRATION DATE OF 6/16/00.
Sheriff's Costs:
Docketing
Service
Not Found Return
Surcharge
18.00
12.40
5.00
10.00
.00
45.40
County
----
Sworn and subscribed to before me
day of
this
A.D.
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Prothonotary
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BARBARA RAND,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO, 00-3051 CIVIL TERM
LASHAE SCALIA,
Defendant
: CIVIL ACTION--LA W
PRAECIPE TO REINSTATE
To the Prothonatary:
Please reinstate the Complaint filed in the above captioned matter. Service will be
perfonned by the Cumberland County Sheriffs Department.
LAi [~JOO" E~Wre
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'Dirk E. Berry, Esquire
Attorney for Plaintiff
7 Irvine Row
Carlisle, PA 17013
(717) 240-0296
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BARBARA RAND,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO,OO-JoSI CIVIL TERM
CIVIL ACTION--LA W
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LASHAE 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 A VENUE
CARLISLE, P A 17013
(717) 249-3166
TRue CQPVI;Et^UDE
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BARBARA RAND,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO.
CIVIL TERM
v.
CIVIL ACTION--LA W
LASHAE SCALIA,
Defendant
COMPLAINT
AND NOW, comes Barbara Rand, Plaintiff, by and through her attorney, Dirk E. Berry,
Esquire, and respectfully avers the following:
I. During the period of October, 1998 through March, 2000, Plaintiff, Barbara Rand, has
loaned to the Defendant, Lashae Scalia, $2,305.00
2. To date, the Defendant, Lashae Scalia, has not repaid any of the above loaned amount.
3. All of the amounts borrowed were loans and none of it constituted gifts,
4, At all times, the Defendant was aware that the amounts enumerated below were loans
and had to be repaid.
5, Item I: $2,155,00 loaned to Defendant to allow her to make baiL
Item 2: $150,00 for plane ticket.
6. Defendant is fully aware that all of the above enumerated items were loans and that
she is responsible for paying them in fulL
7, To date, Defendant has refused to repay any amount of these loans,
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WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter judgment
against Defendant in the amount of$2,305.00,
Respectfully submitted,
Law Office of James K. Jones, Esquire
i0:::
Attorney for Plaintiff
7 Irvine Row
Carlisle, PAl 70 13
(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 unsworn falsification to authorities.
. '--f\ r>( L.d'JP&'.:' ~.(')mL
Barbara Rand
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