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Home My WebLink About03-0427ROBERT P. KLINE d/b/a KLINE LAW OFFICE, PLAINTIFF KENNWOOD W. LOSH, SR. AND SUSAN K. LOSH, DEFENDANTS : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. O3- : CIVIL ACTION - LAW . NOTICE 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 ROBERT P. KL1NE d/b/a KLINE LAW OFFICE, PLAINTIFF KENNWOOD W. LOSH, SR. AND SUSAN K. LOSH, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. ~3~ q.z'7' ~ : CIVIL ACTION - LAW : ; COMPLAINT 1. Plaintiff is Robert P. Kline, an attorney licensed to practice law in the Commonwealth of Pennsylvania, who does business as Kline Law Office, with its office located at714 Bridge Street, New Cumberland, Cumberland County, Pennsylvania. 2. Defendants, Kennwood W. Losh, Sr. and Susan K. Losh, (hereinafter "Defendants"), are adult individuals residing at 43 Subdivision Road, Newville, Cumberland County, Pennsylvania. 3. At the request of Defendants, and on behalf of Defendants, Plaintiff provided legal representation in matters involving civil litigation, real estate transactions, Tax Claim Bureau matters, and other legal matters. 4. There remains due and outstanding from Defendants the sum of $2,175.51 for outstanding attorneys fees, costs and late fees. 5. Plaintiff has made demand upon the Defendants for payment of the outstanding fees, costs and late fees due to Plaintiff, but Defendants have failed and refuse to pay the said sum. 6. All applicable credits, if any, have been duly applied to Defendants' account. WHEREFORE, Plaintiff, Robert P. Kline, d/b/a Kline Law Office, respectfully requests this Honorable Court to enter a judgment in his favor and against Defendams, Kennwood W. Losh, Sr. and Susan K. Losh in the amount of $2,175.51, together with attorneys fees, interest, and costs, which are justly due and owing from the Defendants to the Plaintiff. Respectfully Submitted, Date: Brian C. Bornman, Esquire Kline Law Office 714 Bridge Street New Cumberland, PA 17070-0461 (717)770-2540 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Complaint 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 unswom falsification to authorities. Date Robert P. Kline ' CASE NO: 2003-0042q P CoMMOIq~ _~ ~UMBE~LAiqD COUNTY o~ ~ ~S pennsylvania' cumberland CountY, was served upon the sayS, the within --~- at ~ by handing to NEWVILLE, PA 17241 KENWOOD W LOSH SR a true and attested copy sheri[f or Deputy Sheriff of who being duly sworn according to laW, of coMPLAINT & NOTICE together with and at the same time directing Hi_~s attention to the contents thereof. sheriff's CostS: 18.00 Docketing 9.66 Service .00 Affidavit 10.00 surcharge .00 sworn and subscribed to before ~ day of me this °~ ~'~ A.D. So Answers ine o2/oq/ .oo ROBERT p KLINE By: SHERIFF'S RETURN - REGULAR CASE NO: 2003-00427 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KLINE ROBERT P DBA KLINE LAW VS LOSH KENNWOOD W SR ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon the LOSH SUSAN K DEFENDANT at 1242:0~ HOURS, on the 6th day of February--, 2003 at 43 SUBDIVISION ROAD NEWVILLE, PA 17241 by handing to KENWOOD W LOSH SR, HUSBAND a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this %~-~ day of ~ ~)~ 3 A.D. ! Prothonotary So Answers: R. Thomas Kline 02/07/2003 ROBERT P KLINE By: Deputy Sheriff ROBERT P. KLINE d/b/a KLINE LAW OFFICE, PLAINTIFF Vo KENNWOOD W. LOSH, SR. AND SUSAN K. LOSH, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-427 CIVIL CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT AND ASSESSMENT FOR DAMAGES TO THE PROTHONOTARY: Kindly enter judgment against Defendant for failure to file, or enter, a timely Answer to Plaintiff's Complaint in the above-captioned matter as follows: Real Debt ................................................ $2,175.51 Filing fees ................................................ $64.50 Service costs .......................................... $53.66 Total ................................................... $2,293.67 Kindly assess damages against Defendant in the sum of $2,293.67, plus interest from date of judgment at the rate of 6% per year. I HEREBY CERTIFY that on February 27, 2003, a ten (10) day Default Notice in the above -captioned matter was mailed to the Defendants, Kennwood Losh, Sr. and Susan K. Losh, by regular mail, postage prepaid in accordance with Pa.R.C.P. 237.1. A tree and correct copy of the 1 O-day Default Notice is attached hereto and incorporated herein by reference. KLINE LAW OFFICE 714 Bridge Street New Cumberland, PA 17070 (717) 770-2540 Attorney for Plaintiff To: Kennwood W. Losh, Sr. and Susan K. Losh 43 Subdivision Road Newville, PA 17241 ROBERT P. KLINE d/b/a KLINE LAW OFFICE, PLAINTIFF Vo KENNWOOD W. LOSH, SR. AND SUSAN K. LOSH, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-427 CIVIL CIVIL ACTION - LAW NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against in the above proceeding as indicated below. X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: BRIAN C. BORNMAN, ESQUIRE AT THIS TELEPHONE NUMBER: (717) 770-2540 ROBERT P. KLINE d/b/a KLINE LAW OFFICE, PLAINTIFF KENNWOOD W. LOSH, SR. AND SUSAN K. LOSH, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-427 CIVIL CIVIL ACTION - LAW AFFIDAVIT OF NON-MILITARY SERVICE I, Robert P. Kline, Esquire, depose and say that Defendants are individuals, more than Eighteen (18) years of age and that Defendants are not in the Armed Forces of the United States of America or its Allies, or otherwise within the purview of the Soldiers' and Sailors' Civil Relief Act of 1940, as amended. 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 Robert P. Kline, Esquire ROBERT P. KLINE d/b/a KLINE LAW OFFICE, PLAINTIFF Vo KENNWOOD W. LOSH, SR. AND SUSAN K. LOSH, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-427 CIVIL : · CIVIL ACTION - LAW AFFIDAVIT OF TEN (10) DAY NOTICE I, Brian C. Bornman, Esquire, being duly sworn according to law, depose and say that I served a copy of the attached Ten (10) day notice by regular mail to Defendant on February 27, 2003. Sworn and Subscribed Before me this~la~y Of ~~ ,2OO3 Notary Public ROBERT PETER KLINE, Notary Pub_lic I New Cumberland Boro., Cumberland Co. My Commission Expires June 21, 2004 By: Brian C. Bornman, Esquire Attorney for Plaintiff ROBERT P. KLINE d/b/a KLINE LAW OFFICE, PLAINTIFF KENNWOOD W. LOSH, SR. AND SUSAN K. LOSH, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-427 CIVIL CIVIL ACTION - LAW TO: Kennwood W. Losh, Sr. and Susan K. Losh DATE OF NOTICE: February 27, 2003 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 BRIAN C. BORNMAN, ESQUIRE 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff CERT~ICATE OF SERVICF. I hereby certify that I served a tree and correct copy of the foregoing Notice upon Defendants by depositing same in the United States Mail, first class, postage pre-paid on the 27th day of February, 2003, from New Cumberland, Pennsylvania, addressed as follows: Kennwood W. Losh, Sr. and Susan K. Losh 43 Subdivision Road Newville, PA 17241 BRIAN C. BORNMAN, ESQUIR_E 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff ROBERT P. KL1NE d/b/a KLINE LAW OFFICE, PLAINTIFF Vo KENNWOOD W. LOSH, SR. AND SUSAN K. LOSH, DEFENDANTS : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-427 CIVIL : CIVIL ACTION - LAW : PRAECIPE TO THE PROTHONOTARY: Please satisfy the judgmem in the above-captioned case. Respectfully submitted, DATE BI~I~AN C. BORNMAN, ESQUIRE 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff '77.