HomeMy WebLinkAbout97-04120
RONALD W. NIKLAUS and . IN THE COURT or COMMON PLEAS or
.
MARY N. NIKLAUS D/B/A . CUMBERLAND COUNTY, PENNSYLVANIA
.
STILLMEADOWS STABLES, I
Plaintiffs : NO. en- ~/U) CIVIL TERM
:
v. . Civil Action - Law
.
I
BARRY rBRRBLL and :
DOROTHY rBRRBLL, I
Defendants :
NOTICB
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 defense 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 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 TAItE THIS PAPER TO YOUR LAWYER AT ONCB. IP YOU DO
NOT HAW A LAWYER OR CANNOT AFPORD ONE, GO TO OR TELBPHONE THE
OPP'ICE SET rORTH BilLOW TO PIND OUT WHBRE YOU CAN GET LBGAL HBLP.
CUMBERLAND COUNTY COURT ADMINISTRATOR
Cumberland County Courthouse
Third Floor
Carlisle. PA 17013
(717) 249-1133 or (717) 697-0371
RONALD W. NIKLAUS and
MARY N. NIKLAUS D/B/A
STILLMEADOWS STABLES,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. q7-~/J...O e-()(~ "--rcf2..i'>1
Civil Action - Law
BARRY FERRELL and
DOROTHY FERRELL,
Defendants
COMPLAINT
AND NOW, comes Plaintiffs, RONALD W. NIKLAUS and MARY N.
NIKLAUS, by and through their attorneys, LAW OFFICES OF CRAIG A.
DIEHL, who bring this Complaint in Contract of which the following
is a statement:
1. Ronald W. Niklaus and Mary N. Niklaus d/b/a Stillmeadows
Stables, Plaintiffs, in the above-captioned action, are adult
individuals with an address of 9 Stillmeadows Lane, Enola,
Pennsylvania 17025.
2. Barry Ferrell and Dorothy Ferrell, Defendants in the
above-captioned action are adult individuals with an address of
1648 Newville Road, Carlisle, Pennsylvania 17013.
3. On or about September 3, 1995, Plaintiffs and Defendants
entered into a written agreement for the purchase of Plaintiffs'
Quarterhorse Filly by the name of Addie a/k/a SS INVESTORS
ADVANTAGE by Defendants for a purchase price of Ten Thousand Five
Hundred and 00/100 ($10,500.00) Dollars plus interest, at six (6')
percent in the amount of Six Hundred Thirty and 00/100 ($630.00)
Dollars. A true and correct copy of said Agreement is attach
hereto as Exhibit "A" and incorporated herein by reference.
4. Subsequent to September 3, 1995, Defendants sold their
horse, known as Desierto Wes, to a third party, but failed to make
payment to Plaintiffs in the amount of the proceeds from said sale
as required by the Agreement in Exhibit "A".
5. On or about March 12, 1996, Defendants made a payment in
the amount of Two Hundred and 00/100 ($200.00) Dollars to Plaintiff
on the balance due under the Agreement.
6. During the Months of July, 1996 through May, 1997,
Defendant made payments of Fifty and 00/100 ($50.00) Dollars per
month to Plaintiffs on the balance due under the Agreement, said
payments totalling Five Hundred Fifty and 00/100 ($550.00) Dollars.
CD
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LAW OFFICES OF CRAIG A. DIEHL
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SHERIFF'S RETURN - REGULAR
CASE NO: 1997-04120 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NIKLAUS RONALD W ET AL
VS.
FERRELL BARRY ET AL
DAWN L. KELL
. Shvriff or Dvputy Shvriff of
bving duly sworn according
CUMBERLAND County, Pennsylvania. who
to law, says, thv within COMPLAINT
upon FERRELL DOROTHY
dvfendant, at 184q~ HOURS, on the ~ day of AUQust
1997 at 1646 NEWVILLE ROAD
CARLISLE. PA 17013
was svrved
the
. CUMBERLAND
.
County, Pennsylvania, by handing
a truv and attested copy of the
to DOROTHY FERRELL
COMPLAINT
.
together with NOTICE
and at the sa.e timv directing ~ attention to thv contents thereof.
,
Shvriff'. Costs I
Dockvting
SlPrviclP
Affidavit
Surcharge
So anawer~;..,./ _ ~
~.,.,~ c..t
H. TC Kl:nlP'~her1
6.00
.00
.00
2.00
.8.~~ ~RAIG A. DIEHL
08/06/1997
by ~ -\
\ "h\."1~puIy
\6J. .L
5n.r111
Sworn and eubscriblPd to blPforlP me
. to- {)..A
(. - day of ~Ii..t-
'17 A,D.
this
19
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