HomeMy WebLinkAbout03-0428ROBERT P. KL1NE d/b/a
KLINE LAW OFFICE,
PLAINTIFF
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GERALD E. TENNY, III,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.
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
GERALD E. TENNY, III,
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
..
NO. Ob'- ¥'..~? ~,~','J
: 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. Defendant, Gerald E. Tenny, III, is an adult individual residing at 100A Verbeke
Street, Marysville, Perry County, Pennsylvania.
3. At the request of Defendant, and on behalf of Defendant, Plaintiff provided legal
representation in matters involving divorce, custody, support, Protection From Abuse and
criminal defense matters.
4. There remains due and outstanding from Defendant the sum of $4,745.09 for
outstanding attorneys fees, costs and late fees.
5. Plaintiff has made demand upon the Defendant for payment of the outstanding
fees, costs and late fees due to Plaintiff, but Defendant has failed and refuse to pay the said sum.
6. All applicable credits, if any, have been duly applied to Defendant's 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 Defendant, Gerald E. Tenny,
III, in the amount of $2,175.51, together with attorneys fees, interest, and costs, which are justly
due and owing from the Defendant to the Plaintiff.
Respectfully Submitted,
Date: /- ,2 3 'nO 3
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 tmswom falsification to authorities.
Date
Robert P. Kline
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2003-00428 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KLINE ROBERT P DBA KLINE LAW
VS
TEN-NY GERALD E III
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
TEN-NY GERALD E III
but was unable to locate Him
deputized the sheriff of PERRY
in his bailiwick. He therefore
County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On March
4th , 2003 , this office was in receipt of the
attached return from PERRY
Sheriff's Costs:
Docketing 18.00
Out of County 9.00
Surcharge 10.00
Dep Perry County 87.00
.00
124.00
03/04/2003
ROBERT P KLINE
Sheriff of Cumberland County
Sworn and subscribed to before me
this ~-- day of '~
A. D.
Prothonotary
SHERIFF'S RETURN
In the Court of Common Pleas
Of the 41st Judicial District
of Pennsylvania-Perry County Branch
Robert P.Kline d/b/a
Ys
Gerald E. Tenny III
100 A Verbeke St.
Marysville, Pa. 17053
Kline Law
NO. 2003-428
Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a
diligent search and inquiry for the within named Defendant(s) to wit Gerald E. Tenny,
III, but was unable to locate him/her in his bailiwick. He therefore returns the to the
within Compliant to the above named Defendant(s) Gerald E. Tenny, III, at 100 A
River Rd. Marysville, Pa. 17053NOT FOUND. Made 5 attempts to serve. Defendant
not at home at any of those times.
Sworn and subscribed to before me
this ~£d day of f~ ,2003.
I NOTARI^L:~i I
/ MARGAR'L~'F. FLICKINGER, NOTARYPUBUC I
/ BLOOMFIELDBORO,,PERRYCOUNTY /
/ MYCOM~ISSLON EXPIRES FEB. 16, 2004, _1
Sheriff of Perry County
ROBERT P. KLINE d/b/a
KL1NE LAW OFFICE,
PLAINTIFF
GERALD E. TENNY, III,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-428 CIVIL ACTION - LAW
PRAECIPE
TO THE PROTHONOTARY:
Please reinstate the Complaint in the above-captioned matter.
Respectfully submitted,
BRIAN C. BORNMAN, ESQUIRE
Kline Law Office
714 Bridge Street
P.O. Box 461
New Cumberland, PA 17070-0461
(717) 770-2540
Attorney fol' Plaintiff