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Home My WebLink About02-5879COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT NOTICE OF APPEAL Notice is give~ that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date ard in the case mentioned below. <:~u~,,,e' t ~ -- ', i IS'~TUREO~W'B'L'~NT~H~SAT~ c¥ I LT I // This block will be s~.ed ONLY when fi,is nomtio, is requi,~l u~ler Pa R.C~°J~. ~I~/appella~t was CLAIMANT (see Pa. R.C.P.J.P. No. }.O.08J~ ................ ~ emte as a //1 O01 ( 6 ) in action before District Justice, he MUST SUPERSEDEA$ to the judgment for possessio, in this case £iLE A OOMPLAINT within twenty (20) daF~ after fi#nD his NOTICE of APPEAL. Signature o! Prothonotary o~ D~p~ty PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of fo,'n to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee). PRAECIPE: To Prothonotary , (~. Enter rule upoo ,~ I ~ ~') (~ I~) ~- 5g'~ ~' ~ ~f '"J ~ ~ , appellee(s), to file a complaint in this appeal / ) within twenty' (20)days after service of rule or//(s]~- entry of judgment~of non:::~.~s. ~ , appdlee(s). ~ (1) You am notified that a rule is hereby enteeed upon you to file a complaint in this appeal within twenty (20) days after the date of service of this role upcx~ you by personal service or by certified or mgisteeed mail. (2) If you do not file a complaint within this time, a JUDC-MENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of mailing. AOPC312-90 COURT FILE TO BE FILED WITH PROTHONOTARY PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of serwce MUST BE FILE[) WITHIN TEN ( tOi PAYS AFFER filing the notice of appeal, Check applicable boxes,) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; SS AFFIDAVIT: i hereby swear or affirm that I served EEl a copy of the Notice of Appeai Common Pleas No upon the District Justice designated therein on (date of service) [] by Personal service [] by certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name on [] by personal s(rvice [] by (certified (registered) mai sender's rece p [] and further that I served the Rule to File a Complaint ~ccompanying the above Notice of Appeal upon [he appellee(s) to whom the Rule was addressed on , [] by personal servce ~ by (certif ed) (regis eredi mail, senders receipt attached h~:~i~ SWORN (AFFIRMED) AND SUBSORIBED BEFORE ME THIS .... DAY OF COMMONWEALTH OF PENNSYLVANIA COUNTY OF.'_ ~IJ"~?,ERI~,_N~ Mag Disl NO.: ~ 09-3-04 DJ Name: Hon. TROMAS A. PLACEY Address: 104 S. SPORTING RILL MECHANICSB~TRG, PA Temepho.e: (717) 761-8230 17050 RONALD KIPPS RR 1, BOX 80K UNIONDALE, PA 18470 TH~S IS TO NOTIFY YOU THAT: Judgment: ~ Judgment was entered for: ~ Judgment was entered against: (Name) KTpp.q, in the amount of $ 1: "/n2 _ n0_ on: E~ 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: NAME and ADDRESS ~INGWOOD, SAMOUNE T 496 MT PLEASANT RD ANNVILLE, PA 17003 DEFENDANT: VS. NAME and ADDRESS FKIPPS, RONALD P~E 1, BOX 80K UNIONDALE, PA 18470 NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: CIVIL CASE Docket No.: C'V- 0000442- 02 Date Filed: 9/06/02 DEFAULT duD~r~ PLTF (Name)_RT~wca3~: ~AMnT'I'~'R T (Date of Judgment) _ (Date & Time). Amount of Judgment $_1. 600 ,. O( Judgment Costs $. 102 .,0~__~ Interest on Judgment $_ ,_~ Attorney Fees $ .00 Total $.. 1,702 ~.0~ Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $_ 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 ~E OF JUDGI'V~-~T~RIPT FORM WITH YOUR NOTICE OF~ APPEAL ~, District Justice ~ I cert~Q~e~dings contai~ I~'~- Date i ,'1 .... ;? M"com--' ' ' . ~/: ~ ~ ~ y ,toss,on expmres fmrst Monday of JanUary, ~ 2004 ~ AOPC 3~5-99 SEAL PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED W/THIN TEN (10) DAYS AFTER filing the notice of appeal Check applicable boxes,) COMMO.W ALT" OF., ""SYLW"I* r/ AFFIDAVIT: I hereby swear or affirm that I served (date of service ~ / (~..~/~ ~ersona service t / -l- .................. . ' receipt attached hereto, ;~~e appellee, (ncme):.-- ~~&~;~r~ t~ '~'~i'e t~ite ~ bom~laint accompany ng the above Notice of Appea upon me appe~te~~) ice,nora,. ~ ~"~",' ........ %; ~_% __ r.~__ /~ ~~ by personal service ~ (certified} ~reg~sterea~ the Hula was aeeresseu u. ~...~~ .................. . ~, . . mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSC[~BED BEFORE ME THIS ~ign,'~ture~' My commission ex~ires .......... ~' ..... -~i~i~tur of affiant (Endorsement Req~ired) (End ....... Total Postage & Fees SAMOUNE RINGWOOD, Plaintiff V. : NO.: 02-5879 .- . : CIVIL ACTION - LAW RONALD KIPPS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 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, PA 17013 (717) 249-3166 Christophef'J. keller, Esquire Attorney for Plaintiff SAMOUNE RINGWOOD, Plaintiff RONALD KIPPS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA · NO.: 02-5879 · CIVIL ACTION - LAW USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion or remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE, SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME O VAYA A LA SlGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASlSTENClA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Christopher J. Keller, Esquire Attorney for Plaintiff SAMOUNE RINGWOOD, Plaintiff RONALD KIPPS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : · NO.: 02-5879 : : · CIVIL ACTION - LAW AND NOW, this day of ,200 , it is hereby; ORDERED that a hearing in this matter shall be held on the __day of 200 , at __ A/P.M. in Courtroom __, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Cumberland County, Pennsylvania. BY THE COURT: SAMOUNE RINGWOOD, Plaintiff V. : NO.: 02-5879 _. : : CIVIL ACTION - LAW RONALD KIPPS, Defendant NOW COMES, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, Samoune Ringwood, by and through her attorneys, Christopher J. Keller, Esquire, and the Law Offices of James A. Miller, and requests judgment against Defendant, Ronald Kipps, and for reasons therefore aver: 1. Plaintiff is Samoune Ringwood, an adult married woman residing at 496 Mount Pleasant Road, Annville, Lebanon County, Pennsylvania, 17003. 2. Defendant is Ronald Kipps, an adult individual whose last known address was RR#1, Box 80K, Union Dale, Susquehanna County, Pennsylvania 18470. 3. Plaintiff was a prospective tenant of the premises known and located at 4902 East Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055, (hereinafter referred to as "premise") 4. On or about mid-July 2002, Plaintiff contacted Defendant by calling the telephone number listed on the "For Lease" sign located at the premise. 5. On or about July 23, 2002, Defendant presented himself to Plaintiff as owner and/or property manager for the subject premise described above. 6. Defendant presented himself to Plaintiff as the owner and/or property manager of the premise with the necessary and sufficient authority to enter into a leasehold agreement for the subject premise. 7. On or about July 23, 2002, Defendant requested that Plaintiff provide bank references, business references and a deposit of Sixteen Hundred Dollars ($1,600.00) in order to secure a leasehold interest in the subject premise. 8. On or about July 23, 2002, Plaintiff provided the information requested by Defendant by way of facsimile. (See attached Exhibit "^"). 7. On or about July 23, 2002, Plaintiff mailed to Defendant a check in the amount of Sixteen Hundred Dollars ($1,600.00) as deposit for obtaining a leasehold interest in the premise. (See attached Exhibit "B") 8. On or about July 23, 2002, Plaintiff attempted to set several appointments with Defendant to sign the lease to the subject premise and obtain possession. 9. On or about July 31, 2002, Defendant presented Plaintiffs check for payment and did in fact receive payment thereon. 10. On or about July 31, 2002, Defendant informed Plaintiff that other parties were also interested in leasing the subject premise. 11. On or about August 2002, Plaintiff requested Defendant return her deposit in the amount of Sixteen Hundred Dollars ($1,600.00) since repeated attempts to sign the lease were not completed by Defendant. 12. As of December 30, 2002, Defendant has refused to return Plaintiff's deposit. 13. As a result of Defendant's conduct and actions as defined herein, Plaintiff filed an action on or about September 6, 2002 at the District Justice level before the Honorable Thomas A. Placey seeking damages for the losses she sustained. 14. On December 5, 2002, Honorable Thomas A. Placey entered judgment by default for the Plaintiff in the amount of her security deposit plus judgment costs (See attached Exhibit "C"). COUNT I - ASSUMP~IT Plaintiff hereby incorporates the preceding paragraphs as if fully set forth 15. herein. 16. On or about July 31, 2002, Defendant received Sixteen Hundred Dollars from Plaintiff as a deposit on property to be rented by Plaintiff. 17. Defendant has failed to provide a lease, possession of the subject premise or return monies deposited for the lease of the premise. 18. It is believed and therefore averred that Defendant has subsequently rented the subject premise to another party. 19. Defendant has been unjustly enriched by retaining Plaintiffs money. 20. Defendant verbally informed Plaintiff that her funds were used by Defendant to pay property taxes and would not be returned. 21. Plaintiff has suffered monetary losses by way of attorney's fees, loss of business opportunity and court costs to prosecute her rights in this matter. 22. Plaintiff incurred filing fees, service costs and J.C.P expenses totaling $102.00 before District Justice Thomas ^. Placey (Docket Number CV-0000442-02) (See attached Exhibit "C"); to the hereinabove captioned case; and, attorney fees. WHEREFORE, Plaintiff requests judgment against Defendant in the amount of her damages, costs, expenses and attorney's fees associated with the herein action, plus the legal rate of interest (6%) on said amount. COUNT II - FRAUD Plaintiff hereby incorporates the preceding paragraphs as if fully set forth 23. herein. 24. On or about July 23, 2002, Plaintiff contacted Defendant by way of a telephone number located on a "For Lease" sign at the subject premise because Plaintiff was desirous of leasing said premise. 25. On or about July 23, 2002, Defendant represented to Plaintiff that in order to procure a lease for the subject premise, Plaintiff would have to provide Defendant with certain information and a deposit in the amount of Sixteen Hundred Dollars ($1,600.00). 26. Defendant maintained that the deposit of the $1,600.00 was material to Plaintiff's procuring the lease over other prospective tenants. 27. On or about July 23, 2002, Plaintiff faxed the required information to Defendant and mailed a check to Defendant in the amount of $1600.00. On or about July 31, 2002, Plaintiff's check was presented for payment by 28. Defendant. 29. On or about July 31, 2002, Defendant informed Plaintiff that other prospective lessees were interested in the subject premise. 30. On or about early August 2002, Plaintiff requested the return of her $1,600.00 deposit. 31. On or about early August 2002, Defendant informed Plaintiff that the $1,600.00 was used to pay Defendant's taxes and would not be returned. 32. Defendant's representation that the deposit was required in order for Plaintiff to procure a lease to the premises was made falsely with knowledge or recklessness of Defendant's other intentions for the deposited monies. 33. Defendant's representation that the deposit and references were required to procure a lease to the premises was made with the intent of obtaining $1,600.00 from the Plaintiff for Defendant's benefit and not to secure Plaintiff's obtaining a leasehold interest in the subject premises. 34. Plaintiff justifiably relied on Defendant's representation by providing the requested information and deposit at the request of the Defendant who advertised the subject premise as available for lease. 35. On or about August 2002, after repeated failed attempts to have Defendant produce a lease and deliver possession of the subject premise; Plaintiff requested her deposit be returned. 36. On or about August 2002, Defendant informed Plaintiff that her money would not be returned as it was used to pay Defendant's tax liability. 37. Plaintiff's injury, the loss of $1,600.00, court costs and attorney's fees are the direct result of Plaintiff's reliance upon Defendant's false representations regarding Plaintiff's deposit and the lease to the subject premise. 38. Defendant committed fraud upon Plaintiff by intentionally falsely representing the necessity of a $1,600.00 deposit from Plaintiff as a material requirement in order to secure a lease of the subject premise, which representation Plaintiff justifiably relied upon to Plaintiffs detriment and financial injury through Defendant's misuse of the deposit and failure to return the aforesaid deposit. WHEREFORE, Plaintiff requests judgment against Defendant in the amount of her damages, costs, expenses and attorney's fees associated with the herein action, plus the legal rate of interest (6%) on said amount. Respectfully submitted, Law Offices of James A. Miller By: Christopfler J. Keller, Esquire I.D. # 86889 Attorney for Plaintiff 2157 Market Street Camp Hill, PA 17011 (717) 737-6400 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Samoune Ringwood ...... ~'~' :-"' Check 'ew Check 1089, Amount $96.31 Date Presented 7/23/2002 Page 2 of Da~e 8/i5/o2 Account 51~218693 Check 1090. Amount S70.00 Date Presented 7~24~2002 Check 1091, Amount $149.11 Date Presented 712312002 Check109.." Amount 553 35 Date Presented 7/24/2002 Check 1093, Amount $950.00 Date Presented 7/23/2002 Check 1094. Amount S410.00 Date Presented 7/25/2002,, Check 1095, Amount $1,600.00 Date Presented 7/31/2002 Check 1095. Amount 595.00 Date Presented 81612002 Check 1097, Amount $61.03 Date Present%d E ~mount S 132 00 Date Presented 8/12/2002 Commerce Commerce Bank/Harrisburg N.A 100 Senate Avenue Camp Hill Pa 17011 888-937-0004 SAMOUNE T RINGWOOD D/B/A T & T VENTURES 496 MT PLEASANT RD ANNVILLE PA 17003 11 *** CHECKING *** NOW SOLE PROPRIETOR Page I of 3 CYCLE-014 ACCOUNT NUMBER 0513218693 PREVIOUS STATEMENT BAI~A~;CE AS OF 07/16/02 ........................ PLUS 11 DEPOSITS AND OTHER CREDITS ................... LESS 14 CHECKS AND OTHER DEBITS ...................... LESS CYCLE SERVICE CHARGE ..................... CURRENT STATEMENT BALANCE AS OF 08/15/02 ......................... NUMBER OF DAYS IN THIS STATEMENT PERIOD 30 i,061.70 4,589.26 4,270.73 18.00 1,362.23 *** CHECK TRANSACTIONS *** SERIAL DATE AMOUNT SERIAL DATE 1089 07/23 96.31 1090 07/24 1091 07/23 149.11 1092 07/24 1093 07/23 950.00 1094 07/25 1095 07/31 1,600.00 1096 08/06 1097 08/05 61.03 1098 08/12 1099 08/12 435.00 AMOUNT 70.00 53.36 410.00 95.00 132.00 *** CHECKING ACCOUNT TRANSACTIONS *** DATE DESCRIPTION 07/19 AC-BANKCARD -POS SETL 07/19 DEPOSIT 07/23 POS DEBIT 07/22 2023 W;tL-WAL312246 LEBANON2023 PA 07/24 AC-BANKCARD -POS SETL 07/24 DEPOSIT 07/24 AC-CLARKEAMERICAN -CHK ORDER 07/25 AC-BANKCARD -POS SETL 07/25 AC-BANKCARD 07/25 AC-BANKCARD 07/31 DEPOSIT 08/02 AC-BANI{CARD 08/09 AC-BANKCARD 08/15 AC-BANKCARD 08/15 INTEREST PAYMENT -POS SETL -POS SETL -POS SETL -POS SETL -POS SETL 08/15 CYCLE SERVICE CHARGE DEBITS 100.00 86.25 32.67 18.00 CREDITS 122.64 1,000.00 151.64 2,100.00 48.66 146.71 195.12 750.00 48.90 24.33 1.26 *** BALANCE BY DATE *** 07/16 1,061.70 07/19 07/25 2,911.44 07/31 08/06 1,872.74 08/09 2,184.34 07/23 2,061.44 08/02 1,921.64 08/i2 PAYER FEDERAL ID NUMBER INTEREST PAID YEAR TO DATE 888.92 07/24 2,028.77 08/05 1,354.64 08/15 23-2324730 5.87 2,930.95 1,967.74 1,362.~3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. D~$1. No.: 09 -3-04 :: DJ Name: Hon. THOMAS A. PLACEY '~,ess: 104 S. SPORTING HILL RD. MECHANICSBURG, PA (717) 761-8230 17050 '" SAMOUNE T. RINGWOOD 496 MT PLEASANT RD ANNVILLE, PA 17003 THIS IS TO NOTIFY YOU THAT: Judgment: [~] Judgment was entered for: (Name) Judgment was entered against: (Name) NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: CIVIL CASE I'~AME and ADE'RESS r-RINGWOOD, SAMOUNE T --I 496 MT PLEASANT RD ANNVILLE, PA 17003 L ~ ~ VS. DEFENDAH'F: I-KIPPS, RONAT.D RR 1, BOX 80K UNION'DALE, PA 18470 Docket Nc).: Date Filed': CV'0000442-021. 9/06/02 DEFAULT J]3"DGt-~ PLTF KT PPR; RONA'I',D (Date ol Judgment) (Date & Time) . 1~/o5!n2 Amount of Judgment $ 1,600.00 Judgment Costs S 102.00 Interest on Judgment S ';, 00 Attorney Fees $ .00 Total $ 1,702.00 Post Judgment Credits S .... Post Judgment Costs S Certified Judgment Tolal S in the amount of $ I .. 702 _ 00 on: --']Defendants are jointly and severally liable. l-'~ Damages will be assessed on: r--]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: IDate: Time: Place: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN'30 DAYS ,~FTER THE ENTRY OF JUDGMENT BY FILING A NO~ICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUSTINCLUDE A COPY OFfiCE OFJUD~~RiPT FORM WITH YOUR NOTICE OF APPiAL. I certify that this is a true a orrect copy of the record of the p/oceedir My commission expires first Monday of Ja 20 4 AOPC 3 ! 5-99 SAMOUNE RINGWOOD, Plaintiff RONALD KIPPS, Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA : · NO.: 02-5879 : CIVIL ACTION - LAW Certificate of Servic~ I, Christopher J. Keller, hereby certify that I have forwarded to the person on the date and in the manner indicated below a certified copy of the preceding Complaint in answer to his appeal from the District Justice Judgment CV-0000442-02 of Magisterial District 09-3-04. Date: December 31, 2002 - Certified First Class Mail No.: 7001 1140 0002 1274 5289 Ronald Kipps, Defendant RR1, Box 80K Union Dale, PA 18470 Attorney for Plaintiff 2157 Market Street Camp Hill, PA 17011 (717) 737-6400 5,~/nr~) ,oj~dff. ~/~ l In the Court of Common Pleas of 'Cumberland County, Pennsylvania Prothonotary Attorney for Plaintiff No. Term, 19 03FEB-'? [ilq 9:25 PENNSI'L¥7~,NIA *CS, Filed PRAECIPE 19 SAMOUNE RINGWOOD, Ve RONALD KIPPS, DEFENDANT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-5879 CIVIL TERM : CIVIL ACTION - LAW AFFIDAVIT OF SERVICE I, Christopher J. Keller, Esquire, Attorney for Plaintiff, hereby certify that I have mailed a true and correct copy of Plaintiff's reinstated Complaint to the Defendant, Ronald Kipps, by Regular and Certified United States First Class Mail, postage prepaid on Friday, February 14, 2003, as evidenced by the attached Sender's receipt as to the Certified envelope, to the address Defendant Kipps listed on his appeal from the District Justice decision in this matter, namely, RR#1 Box 80K, Union Dale, Pennsylvania 18470, in conformance with Pa.R.C.P.D.J. 1005(D). I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. {}4904, relating to unswom falsification to authorities. m'istopner J. Keller, Esquire 2157 Market Street Camp Hill, PA 17011 (717) 737-6400 rtl m m Postage _ ru _.Retum Rscelpt Fee ~ I=naorsement Required) I'-1 Restricted Delivery Fee r-1 (Endorsement Required) rq [ Sent To /~ /.I .~ [or.oeo..o /~£~ o pon ,iT, SAMOUNE RINGWOOD, Plaintiff VS. RONALD KIPPS, Defendant : IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · NO: 02-5879 Civil Term · Civil Action - Law PRAECIPE PROTHONOTARY: Please withdraw the appearance of Christopher J. Keller, Esquire and the Law Offices of James A. Miller, as counsel for the Plaintiff in the above-captioned matter. Dated: ~,/~//~' ~' James A. M~er,,JL~qu e 2157 Market S~eet Camp Hill~nnsylvania 17011 (7~-6400 Please enter the appearance of Christopher J. Keller, Esquire, as counsel for Plaintiff in the above-captioned matter. Dated: Christopher J'. Keller, Esqu' 101 South Market Street Mechanicsburg, PA 17055 (717) 790-5451 SAMOUNE RINGWOOD, Plaintiff RONALD KIPPS, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5879 Civil Term Civil Action - Law CERTIFICATE OF SERVICE. I, Christopher J. Keller, Esquire, hereby certify that I have forwarded to the unrepresented Defendant in the above-captioned matter, a true and correct copy of the foregoing Praecipe on the date and in the manner indicated below. United States First Class Mail, postage prepaid Ronald Kipps RR#1 Box 80K Union Dale, PA 18470 Date: Friday, March 21,2003 Christopher J. Keller Supreme Court ID# 86889 101 South Market Street Mechanicsburg, PA 17055 Counsel for Defendant (717) 790-5451 SIMOUNE RINGWOOD, Plaintiff RON KIPPS and ELK TRAILS BISON RANCH, Defendant · IN THE COMMON PLEAS COURT OF · CUMBERLAND COUNTYI · PENNSYLVANIA · CIVIL ACTION - LAW · NO. 02-5879 PRAECIPE TO: PROTHONOTARY Please enter my appearance on behalf of the Defendant. Dated: q\~.~0 3o Respectfully submitted, Daniel Stem, Esquire 2650 North Third Street Harrisburg, PA 17110 (717) 234-4531 Supreme Court ID#25989 Attorney for Defendant' SIMOUNE RINGWOOD, Plaintiff Vo RON KIPPS and ELK TRAILS BISON RANCH, Defendant · IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, · PENNSYLVANIA · CIVIL ACTION - LAW · NO. 02-5879 CERTIFICATE OF SERVICE I, Queena S. Baumbach, hereby certify that a true aa~d correct copl of the foregoing Praecipe was served upon the following person by first class m~il, postage prepaid: Date: Christopher J. Keller, Esquire 101 S. Market St. Mechanicsburg, PA 17055 eena S. Baffmbach, v . alegal to Daniel Stem, Esi:luire SAMOUNE RINGWOOD, Plaintiff VS. RONALD KIPPS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 02-5879 Civil Term : Civil Action - Law p~RAECIPE OF SATISFACTION AND DISCONTINUANCE PROTHONOTARY: Kindly enter this Praecipe of Satisfaction and Discontinuance in the above-captioned matter. Please enter PlaintiWs voluntary discontinuance of this action. The District Justice judgment, CV-0000442-02, from which this appeal was taken, has been satisfied by the Defendant. Kindly mark the judgment as satisfied. Date: August 2, 2003 Attomey for Plaintiff I01 South Market Street Mechanicsburg, PA 17055 (717) 790-5451 Daniel Stern, Esquire Attorney for Defendant 2650 North Third Street Harrisburg, PA 17110