The URL can be used to link to this page

Home My WebLink About00-07713 . ~L , ~,_J ; i '--, C'" ,-- MARLIN R. NEGLEY and CECIL J. NEGLEY, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA 7? t:3 NO. OO~ CIVIL TERM v. EDWARD A. WINGFIELD and BRENDA L. WINGFIELD, Defendants CIVIL ACTION -LAW JURY TRIAL DEMANDED v. BRENDA L. WINGFIELD Cross-Claim NOTICE TO DEFEND AND CLAIM RIGHTS 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 clainled 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 TmS 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 Lawyers Referral Service 2 Liberty Ave. Carlisle, P A 17013 (717) 249-3166 TO: MARLIN R. NEGLEY and CECIL J. NEGLEY C/O THOMAS E. FLOWER, ESQUIRE You ARE HEREBY NOTIFIED To FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER WITHIN TwENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAyBE ENTERED ~~ PETER J. Russo January 26. 2001 DATE i"~ ~L I ,,_ 1.,,__ ,I, ','r. --,,' ,- ",-'~""--- ' ,,- '",' , ".w """to;;: MARLIN R. NEGLEY and CECIL J. NEGLEY, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA '77~ NO. 00-+36 .CIVIL TERM v. EDWARD A. WINGFIELD and BRENDA L. WINGFIELD, Defendants CIVIL ACTION -LAW JURY TRIAL DEMANDED v. BRENDA L. WINGFIELD Cross-Claim NOTICE TO DEFEND AND CLAIM RIGHTS 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 TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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 COUlIlty Lawyers Referral Service 2 Liberty Ave. Carlisle, P A 17013 (717) 249-3166 TO: BRENDA L. WINGFIELD You ARE HEREBY NOTIFIED To FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAyBE ENTERED AGAINSTYOU~ G?.}-~~ . January 26.2001 PETERJ.RUSSO DATE ."-,,,, - ~ I d .1. ,'. '~i--' MARLIN R. NEGLEY and CECIL J. NEGLEY, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 77/J NO. OO~ CIVIL TERM v. EDWARD A. WINGFIELD and BRENDA L. WINGFIELD, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED v. BRENDA L. WINGFIELD Cross-Claim DEFENDANT. EDWARD A. WINGFIELD'S, ANSWER TO PLAINTIFFS' AMENDED COMPLAINT AND NOW, COMES, the Defendant, Edward A. Wingfield, by and through his counsel, Peter J. Russo, Esquire, and avers the following: I. Admitted. 2. Denied in part. Answering Defendant resides at 75 Rolo Court, Mechanicsburg, Pennsylvania, 17055. 3. Admitted. COUNT I 4. Admitted in part and denied in part. It is admitted that Plaintiffs gave a sum of money to Defendants. The remittance of said money was thought to be a gift rather than a loan. Answering Defendant does not recall the SUlll ofthe money, either gifted or loaned, being equal to $2,350.00. Strict proof is demanded at the time of trial. J " , .. .",-",. illl'!C 5. Admitted in part and denied in part. It is admitted that Plaintiffs gave a sum of money to Defendants. The remittance of said money was thought to be a gift rather than a loan. Answering Defendant does not recall the sum of the money, either gifted or loaned, being equal to $2,350.00. Strict proof is demanded atthe time of trial. 6. Denied. Since the money was a gift to Defendants, no repayment was ever required. In the alternative, in the event the money were deemed a loan, since no repayment terms were established, it would be impossible for Defendant to fail to repay as promised. 7. Admitted in part and denied in part. It is admitted that Defendants borrowed a sum of money from Plaintiffs. Answering Defendant does not recall the sum ofthe loan being equal to $5,000.00. Strict proof is demanded at the time of trial. 8. Admitted in part and denied in part. It is denied that Plaintiffs reminded Defendants about the money, either gifted or loaned, being equal to $2,350.00. Strict proof is demanded at the time of trial. 9. Admitted in part and denied in part. It is admitted that Plaintiffs gave a sum of money to Defendants. The remittance of the first sum of money was thought to be a gift rather than a loan. Strict proof is demanded at the time of trial. 10. Admitted in part and denied in part. It is admitted that Plaintiffs paid some of Defendants' joint obligations and placed a lien on the Defendants' mobile home. It is denied that the Plaintiffs discussed the process of obtaining the funds with the Defendants. 1,-.. , " '.. - 1-- - ~. -. ~., ' . ,,-',,-, II. Denied. Answering Defendant is aware that Plaintiffs took a loan out with York Federal to provide Defendants with money. Strict proof is demanded at the time oftrial. 12. Admitted. 13. Admitted in part and denied in part. It is admitted that Defendants borrowed a sum of money from Plaintiffs. Answering Defendant does not know where the money came from and strict proof is demanded at the time of trial. 14. Admitted in part and denied in part. It is admitted that Answering Defendants remitted various payments to Plaintiffs. Answering Defendant is not aware but expected that Brenda Wingfield remitted the balance ofthe payments. Strict proof is demanded at the time of trial. WHEREFORE, Defendants respectfully request this Honorable Court to enter judgment in favor of the Defendants and against Plaintiffs in the amount of all expenses and costs incurred by Defendant in defense of this matter. COUNT II 15. Denied. The Rules of Civil Procedure do not require a response to the averments in paragraph 15. WHEREFORE, Defendants respectfully request this Honorable Court to enter judgment in favor of the Defendants and against Plaintiffs in the amount of all expenses and costs incurred by Defendant in defense of this matter. .1 "' i ~. . ..liIOiiiiob COUNT III 16. Admitted in part and denied in part. It is admitted that Plaintiffs gave a sum of money to Defendants. The remittance of said money was thought to be a gift rather than a loan. Answering Defendant does not recall the sum of the money, either gifted or loaned, or the dates thereof and strict proof is demanded at the time of trial. WHEREFORE, Defendants respectfully request this Honorable Court to enter judgment in favor of the Defendants and against Plaintiffs in the amount of all expenses and costs incurred by Defendant in defense of this matter. COUNT IV 17. Denied. The Rules of Civil Procedure do not require a response to the averments in paragraph 17. WHEREFORE, Defendants respectfully request this Honorable Court to enter judgment in favor of the Defendants and against Plaintiffs in the amount of all expenses and costs incurred by Defendant in defense of this matter. COUNT V 18 (a) - (d) Admitted in part and denied in part. Any of said payments were made after the time Defendants separated and at that time the only resident of the mobile home was Brenda Wingfield, to wit making her liable for all said sums. Further, any sums advanced to the marital unit were thought to be a gifts rather than loans. - I.. . "~- l' ~ I, ~ ~ ~ - - ~: , -, ,~. ,- ""<-:~>:, 19 Admitted with qualification. As Answering Defendant believes that any sums advanced to the marital unit were thought to be a gifts rather than loans, it follows that no repayment was ever made. WHEREFORE, Defendants respectfully request this Honorable Court to enter judgment in favor of the Defendants and against Plaintiffs in the amount of all expenses and costs incurred by Defendant in defense of this matter. COUNT VI 20. Denied. The Rules of Civil Procedure do not require a response to the averments in paragraph 20. WHEREFORE, Defendants respectfully request this Honorable Court to enter judgment in favor of the Defendants and against Plaintiffs in the amount of all expenses and costs incurred by Defendant in defense ofthis matter. COUNT VII . 21 Admitted in part and denied in part. Any of said payments were made after the time Defendants separated and at that time the only resident of the mobile home was Brenda Wingfield, to wit making her liable for all said sums. Further, any sums advanced to the marital unit were thought to be a gifts rather than loans. WHEREFORE, Defendants respectfully request this Honorable Court to enter judgment in favor of the Defendants and against Plaintiffs in the amount of all expenses and costs incurred by Defendant in defense of this matter. ," _~L " ' ,[, ~J",. L&, "c_ __ , - "" - -- '-~j~ COUNT VIII 22 Admitted in part and denied in part. Any of said payments were made after the time Defendants separated and at that time the only resident of the mobile home was Brenda Wingfield, to wit making her liable for all said sums. Further, any sums advanced to the marital unit were thought to be a gifts rather than loans. 23 Admitted in part and denied in part. Any of said payments were made after the time Defendants separated and at that time the only resident of the mobile home was Brenda Wingfield, to wit making her liable for all said sums. Further, any sums advanced to the marital unit were thought to be a gifts rather than loans. 24 Admitted in part and denied in part. Any of said payments were made after the time Defendants separated and at that time the only resident of the mobile home was Brenda Wingfield, to wit making her liable for all said sums. Further, any sums advanced to the marital unit were thought to be a gifts rather than loans. WHEREFORE, Defendants respectfully request this Honorable Court to enter judgment in favor of the Defendants and against Plaintiffs in the amount of all expenses and costs incurred by Defendant in defense of this matter. - , ~!..o ' . , '-'- ~L -..- 'tJij NEW MATTER & CROSS-CLAIM CROSS-CLAIM EDWARD A. WINGFIELD v. BRENDA L. WINGFIELD 25. After the parties were separated and Edward A. Wingfield left the marital residence, Brenda L. Wingfield continued to reside in the marital residence. 26. After the parties' separation, Brenda L. Wingfield continued to utilize the marital residence for several months at her own peril. 27. Brenda L. Wingfield failed to notify Edward A. Wingfield when she removed herself from the marital residence. 28. Any alleged obligation incurred as a result each and every count of Plain tiffs' complaint is as a direct andproxill1ate of Brenda L. Wingfield's failures, acts and omissions. 29. As a direct and proximate result of Brenda L. Wingfield's failures, acts and omissions, Plaintiffs' have instituted the instant suit. 30. As a direct and proximate result of Brenda L. Wingfield's failures, acts and omissions, Plaintiffs' may obtain a judgment against both Defendants. 31. As a direct and proximate result of Brenda L. Wingfield's failures, acts and omissions, Plaintiffs' judgment may be executed against the individual or joint possessions of Answering Defendant. 32. Answering Defendant is entitled to contribution from Brenda L. Wingfield for judgments which arise as a result of her failures, acts and omissions. Hi, - ,~ L , ~ WHEREFORE, Defendant, Edward A. Wingfield, seeks the entry of a judgment against Defendant in an amount equal to any judgment obtained by Plaintiffs. NEW MATTER 33. Plaintiffs have failed to reduce any agreement into writing. 34. Each time Plaintiffs advanced money to Defendants no terms of repayment were ever established. 35. Plaintiffs never provided Defendants with any formal notice of their failure to remit required payments as alleged. 36. Prior to the experience of marital difficulties and the ultimate separation of the Defendants, Plaintiffs never sought repayment of any of the sums advanced by Plaintiffs. 37. Plaintiffs have failed to set a claim upon which relief may be granted. 38. Plaintiffs have failed to mitigate their damages, if any. 39. Plaintiffs may be barred in whole or in part by the applicable Statute of Limitations. 40. Plaintiffs may be barred in whole or in part by the principle of res judicata. 41. Plaintiffs' claim may be barred by the estoppel, waiver and latches. 42. Plaintiffs' claim may be barred by the Principles of Accord and Satisfaction. 43. Plaintiffs claim may be barred by the doctrine of payment. 44. Plaintiffs voluntarily assumed the risk of the facts set forth in this Complaint and accordingly his claim is barred. -. Ij ,I ""' ~. ~ o '~H 45. Plaintiffs' claim may be barred and limited by the doctrines of comparative negligence and/or assumption of the risk. 46. No conduct of the defendants or agent of the answering defendants resulted in or is the proximate cause of any injury or damage sustained by the plaintiffs. 47. Any injuries and/or damages claimed by the plaintiffs, if proven, were caused by persons other than answering defendants and not within the control of answering defendants. 48. At all material times hereto answering defendants acted reasonably, appropriately and caused no injuries or damage to plaintiffs. 49. Any hann suffered by the Plaintiffs arose out of their own non-performance of the essential obligations. WHEREFORE, Defendants respectfully request this Honorable Court to enter judgment in favor of the Defendants and against Plaintiffs in the amount of all expenses and costs incurred by Defendant in defense of this matter. Respectfully submitted, ~~ Peter J. Russo Date: Fridav, January 26. 2001 ~1' . .J ". '*" -"" MARLIN R. NEGLEY and CECIL J. NEGLEY, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-436 CIVIL TERM v. EDWARD A. WINGFIELD and BRENDA L. WINGFIELD, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED v. BRENDA L. WINGFIELD Cross-Claim VERIFICATION I, Edward A. Wingfield, verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. //?-t!(}/ DATE &M1ud a - w ifJ Edward A. Wingfield L: ,~~ ~ i 1 '''-''. MARLIN R. NEGLEY and CECIL J. NEGLEY, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. 00-436 CIVIL TERM v. EDWARD A. WINGFIELD and BRENDA L. WINGFIELD, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Peter Russo, hereby certify that I = on this day serving a copy of the foregoing document upon the person (s) and in the manner indicated below: Service by First-Class Mail, Postage Prepaid, and Addressed as follows: Thomas E. Flower, Esquire 2109 Market Street C=p Hill, P A 170 II Brenda 1. Wingfield 1466 Center Road Newville, PA 17241 Peter J. Russo Date: Fridav. Januarv 26. 2001 = '!l.Jm;.~~~~Wit~lliI$.Ji~IW'J.1i4.i~~-'iIi"'.'I' ,""-- . Molllll_~"" ijllllllljfilliillfll~~ ~ ""fE:lJ!tIlillll ... ">~ ! '] - 0 0 0 C Tl <'" -orJ5 ~- ~'!lt mrn ~~:: "1-1 2:1) i'''~'' ~~ 1'0 ~".'";J ~~j 0"> -::;:; l} .1; r-:;:CJ "'0 )~ ~iJ ?('... ....ii.. ZC" -:i-C) 5j ~ Urn C Z .,.. ';;! =< ::t., 0 -< h:; -~ -. , ,...J..., J k "h " _ ~_ _.' - ~ -ilif'::lu c', MARLIN R. NEGLEY and CECIL 1. NEGLEY: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA : NO. DD - Ttl3 v. EDWARD A. WINGFIELD and BRENDA L. WINGFIELD CIVIL ACTION - LAW Defendant 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 TillS 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 JLiberty Avenue Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 .~. " ~ .. ~ . iJ;..T ~ l - -, - - ,_~ ,",- ,,;.- '";,,-;,. , ,-- MARLIN R. NEGLEY and CECIL J. NEGLEY: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. EDWARD A. WINGFIELD and BRENDA 1. CIVll- ACTION - LAW WINGFIELD Defendant COMPLAINT 1. Plaintiffs are Marlin R. Negley and Cecil J. Negley, husband and wife, residing at 1466 Center Road, Newville, Pennsylvania. 2. Defendants are Edward A. Wingfield, residing at 130 North Hanover Street, Carlisle, Pennsylvania and his wife, from whom he is separated, Brenda 1. Wingfield, residing at 1466 Center Road, Newville, Pennsylvania. 3. Plaintiffs are the Parents of Brenda 1. Wingfield. 4. In 1997 Defendants asked Plaintiffs to lend them $2,350.00 to enable Defendants to pay household expenses. 5. In exchange for Defendants' promise to repay the money, Plaintiffs paid Defendents' household expense bills in the amount of$2,350.00. 6. Defendants failed to repay the money, in breach of the parties' contract. 7. In May of 1999, Defendants again came to Plaintiffs, asking for a loan to pay household bills, this time totaling more than $5,000.00. 8. Plaintiffs reminded Defendants that the $2,350.00 borrowed in 1997 had never been repaid. 9. Defendants reaffirmed the obligation to repay the $2,350.00 and promised to repay both sums if Plaintiffs would lend them an additional $5,000.00. , , . . .' - -', . -~-""" , ~ , ' , "it 10. Plaintiffs stated that they would borrow $5,000.00 and apply it to pay Defendants' bills only if Defendants would give security for their promise to repay by granting Plaintiffs a lien on Defendants' mobile home. II. On May 24, 2000, Plaintiffs borrowed $5,000.00 from York Federal Savings & Loan at 9% interest. A copy of the loan agreement is attached hereto. 12. Defendants duly promised to repay the $2,350.00 borrowed in 1997, along with the additional $5,000.00 at 9% interest, and Defendants granted Plaintiffs a lien against Defendants' mobile home to secure the obligation. A copy of the mobile home Title with properly perfected first lien in favor of Plaintiffs is attached hereto. 13. In return for these promises and security, Plaintiffs paid Defendants' bills in the amount of$5,000.OO. 14. On this obligation Defendants made three payments amounting to, in total, only $199.00, and thereafter none. 15. After June 1999, Defendants also borrowed from Plaintiffs $500.00, III $20.00 increments, all of which Defendants promised to repay, but have not done so. 16. Since June 1999, Plaintiffs have paid the following bills for Defendants, in exchange for Defendants' promise to repay them: (a) $206.00 for mobile home casualty insurance; (b) $119.00 to repair the mobile home's furnace; (c) $147.00 for kerosene to heat the mobile home; and (d) $325.00 for expenses of going to the Bloomsburg Fair. 17. None of the foregoing loans have been repaid, as promised. 18. Plaintiffs have paid the lot rent to the mobile home park where Defendants' mobile -,- ,)...," . ~.' ,j "-{ 'Co _" "__ " -. -~ ':'^'--'- 'if? home is situated, at $308.00 a month, for ten (10) months, for a total cost of$3,080.00. 19. Plaintiffs have also mowed the grass around the mobile home ten tinles at a value of $30.00 each. (the mobile home park management would otherwise charge $45.00 for each mowing). WHEREFORE, Plaintiffs now seek damages for breach of contract in the amount of $8,647.00 plus interest at 9% (reduced by $199.00 paid by Defendants); and Plaintiffs now also seek damages of $3,380.00 in restitution for Defendants' unjust enrichment due to Plaintiffs' payment of the lot rent and mowing. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Date: Novl 101 Z.OtJo BY:~~ Thomas E. Flower, Esquire Supreme Court ID #83993 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff J...... ~ ---a-~" ",'''' - ,_ ",' ,-, -='~,_L'.,.,,,,,,,,.-. _ ___,''-"<_'~',_., 't" MARLIN R. NEGLEY and CECIL J. NEGLEY: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. EDWARD A. WINGFIELD and BRENDA 1. : CIVIL ACTION - LAW WINGFIELD Defendant VERIFICATION I, Lee i I J, tV e.lj ley, hereby verifY that the statements made in the foregoing , petition are true and correct to the best of my infOIDlation, knowledge and belief. 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: Nov I 'l(J/20(JO By: ~I . -, :~~4J;i="~~..-'" I '~ . ,'J_ :. I._..!', _1.- _ 1_ -_.,-. . MARLIN R. NEGLEY and CECIL J. NEGLEY: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA , v. : NO. . EDWARD A. WINGFIELD and BRENDA L. : CIVIL ACTION - LAW WINGFIELD Defendant -' VERIFICATION I, Met\'" IiVJ R. Ne5lej , hereby verify that the statements made in the foregoing petition are true and correct to the best of my infOID1atiOD, knowledge and belief. 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: Nov. 20 J 2-000 By:7J~et{* ... ---_.-:-,;"~..~,~--- ~._,_._--- - - .~ - . , ,-,. ~ ~-".. - ~,-, ~~, - "'".''~-''''' i?it " ~""1;"1 I I I I I I I I ." MARLIN R. NEGLEY and CECIL 1. NEGLEY: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. EDWARD A. WINGFIELD and BRENDA L. : CIVIL ACTION - LAW WINGFIELD Defendant CERTIFICATE OF SERVICE AND NOW, this J.. 1) -::-- day of NoV~""'~ ,2000, I, Thomas E. Flower, Esquire, of the fIrm of Saidis, Shuff, Flower and Lindsay, hereby certify that I this day served a true and correct copy of the Complaint upon the parties listed below via United States Mail, postage prepaid, addressed as follows: Edward A. Wingfield 130 North Hanover Street Carlisle, P A 17013 Brenda L. Wingfield 1466 Center Road Newville, P A 17241 Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY BY:~~ Thomas E. Flower, Esquire Supreme Court ill #83993 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff CJ '-> , u::J f-..>. <.D rv (Jl (J1 .~,-~ , .....,~-~~ (TYPE OR PRINT) Certificate of Title must be submitted within 20 days. unless the purchaser is a registered dealer holding the vehicle for resale. WAR N I N G ~6DEo~~&~~ o~T~~6v~I~~ AR~2~~~T~~~E~~UMfJAlE~UWEIN M~lt;ti'fNh~o~9~~~~~~~E~+~ THE TRANSFER OF OWNERSHIP. FAILUR~i;;~ Regislared doolars must complete forms MV2.7A or MV278 LAST FIRST M.r.~'> : as ,aqulmd by law. 11 p1Jrchaser Is NOTa re9'steraddealer. ' :>;p::" Sec~lm 0 on lha lront 01 tn,s form must ba complele<1 PURCHASER OR FULL ",Y;j!i lIWe cettlfy, to the best 01 my/our knowledge that the odomeler reading Is BUSINESS NAME ';;, TENTliS ___,_ __ X miles ami reflecls the actuel m,leage of the vehicle. Unl(lS6 one 01 the lollowing boxEt6 is checked: O Reflects the amount of mileage 0 Is NOT Ihe actual mileage in excess of its meehanlcallimils WARNING: Odometer discrepancy CITY IlWe lurlhercattily Ihat the vehicla is lroool any encumbrance and that owner shipJshereby lransferredto the person(s) orthe dealer lisled. A. ASSIGNMENT OF TITLE- CO.PURCHASER ::'0' STREET ADOAE:SS '..,';, "./ ";:J i , l STATE '" PURCHASE:PAICE. OROIN 'SUBSCRIBED AND SWORN TO BEFORE ME: MO DAY YEAR PURCHASER SIGNATURE: SIGNATURE: OF PE:RSON ADMINISTERING OATH CO.pURCHASE:RSIGNATURE: PURCHASER AND/OR CO-PURCHASER MUST HANDPRINTNAM HERE tlWEI certity, to the bast of my/our I<nowledge that the odometer readIng Is '"EN~S ___,___ X miles anci'11ltrllcts lhe aclual mileage of the vehicle. unlessoneofthelollowingbollesischeckeci: O RelleGtS the amount of ,:"iteage 0 IS NOT the actual mlleage , in eXllll$S of its rnechanlcallimits WARNING: Odometer discrepancy IN.Ie !urlt1er cettlfy that the vehlcie is lree 01 any encumbrance and that the ownership is hereby tral1_sferrect tolhe person(s) or the dea(er listed. PURCHASER OR FULL aUSINESSNAME Co.PURCHASER i ;, ;?rt'f1[i ;,; r0't<;,; c: G t n ~ G o n ~ ~ " n , " " , .J '" W (fJ SIGNATURE: OF SELLER SIGNATUAE OF CO-SELLER STREET ADDRESS "'" SUBSCRIBED AND SWORN TO BEFORE ME: YEAR STATE PUACHASE:PRICE: OADIN , MO DAY '" c , c SIGNATURE OF PEASON ADMINISTE:RING OATH PURCHASER SIGNATURE SIGNATURE: OF SELLER , n , J n " n , C n C , > , CO-PURCHASER SIGNATURE .J '" W (fJ PURCHASER ANOJOR CO.PURCHASERMUST HANDPRINT NAME HERE SELLER MUST HANDPRINT NAME HERE If purchaser IS NQ.T a regIstered dealer Section D on the front of thIS form must RE-ASSIGNMENI OF TITLE BY; REGISTERED DEALER- be completed. - lIWecertify. to lhe best of mylour knowledge that the odometer reading Is TEN~S ___,___ X miles end reflects the actllal mileage of lhe vehicle. unless one of the following boxes is checked: O Reflects the amcunt of mileage 0 Is NOT 1he actual mileage in excess of its mechanJcallimlts WARNING: Odometer discrepancy IlWe further cerlity that Ihe vehicle is !ree ot any encllmbranceand that the ownership is hereby transferreci Iolhe person(s} or the dealer lista<J. lAST FIRST M.t. c , , t n , Q ~ ~ n , n t C > t ~ (j n PURCHASER OR FULL BUSINESS NAME CO.PURCHASER STREET ADDRESS CITI' SUBSCRIBED AND SWORN TO BEFORE ME: MO. DAY YEAR I STATE '" PUACHASEPRICE OROIN ~ SIGNATURE OF PERSON ADMINISTERING OATH PURCHASE:RSIGNATURE . .5~ , . CO.PURCHASEASIGNATURE: .J '" W (fJ PURCHASER AND/OR CO-PURCHASER MUST HANDPRINT NAME HERE ~ SIGNATUAE: OF SELLER . .. .. o SELLEA MUST HANOPRINT NAME HERE ~ RE-ASSIGNMENT OF TITLE BY REGISTERED DEALER- - ~ I/We certify. 10 lhe'best of my/our knowledge that the odometer reading Is TENTHS Xm,iesandrellaclslheactllalmileageOlthevehicle. -~-,---- unless one of Ihetollowing bo~es ischacked: O Reflects IhEl amount of mileage 0 Is NOT Ihe aclual milea!;le in excess of its machanical IImllS WARNING: Odometer discrepancy IlWefUrlhercertlfy'lhatthevehieie,slreeo!anyancumbranceandthat the ownerSh'p 's hereby trans!erredlotheperson(s)orlhedeaierl'sted. lAST FIRST M.L PURCHASER OR FULL BUSINESS NAME CO.PURCHASER STFlEET ADDRESS "'" SUBSCRIBED AND SWORN TO BEFORE ME: MO D" YEAR STATE '" PURCHASEPAICE OR DIN ~ , I .0. W '" ~ W :0 (fJ ., > " SIGNATURE OF PERSON ADMINI.3TEAING OATH I~ , I PURCHASERANDIOR ~O.PURCHASER MUST ~ANopmNT NAM' "eRe i ~~~~JtR~~~SJAME HERE PURCi-IASERSIGNATURE CQ.PURCi-IASERSIGNATURE SIGNATURE OF SELlER , rC:i [J CHECK HERE IF APPLICATION FOR DEALER TITLE AND COMI'LETE SECTION D. TITLING FEES $ .., , -~ '- ,. _ 'Ilk..' . . .11. 33 ... DRAFT STATEHIT ... --- ~IIEIlIITPA_1O: PAIIlIllI40 0 '<<lRIt PIIo_ 1.....u...ldd..I..dIId...IUL.....I.dI.ulluddd NAILIN I NEeLEY CEClI. J NESLEY 1'466 i:EtlTEflflO NEWVUU' PA 11~1-9775 CLOSln DATE 6-JO-" PAYIIEfIT DUE. PAYllEIIT DUE DATE 7-12-" ..-- '5.1' EHTER AHDUNT PAID '- .~.. . -.'. ,.: -: SJoa~9tlP':. _ _ ... ..' NOTICE; ~ ~"'~~.1NFOAMA7ION., . ._,y ,. . ..;-.: :..;:' _ .,;- "':.;.~~'::.'- .L';; :"';:-:~~",;:'~.>:f:?:'-:.~ ..IE .' ..;,~:~-_,'.i.'~""~1""$o..~~,~:. ACCOUNT NUNIER .......29.812'9 ,.. -- ...,.:------,..,--..-,.- . ~ . 'ME EQUITY LINE OF CREDIT AC~IIT c OP"-542'.'1299 PAU 1 ,. 2 UN.I; ANOUIIT' . CURRENT MUNCE '. .., S..... 4,"1.7' AV~Af~E 25,139.21 PAYlfENT DUfDATE 7-12-99 ..-, IIINIMU PA'IIEN 65.1 'IaESTPAJDTHU YEAR . . . ACCGUNT /PA YIIENT INFOIII.TIOII... MARLIN R NEGLEVTAXPAYER'~IDIIUIlBER 9.86 ,. . . ..,' .j': ,". 176-S~-8'1 .' '-'.".- MLAIln SUtiRARY ,,~lIrNT ;flra '-1l",:9~ .TIRaU8If,'~:I~;~" . .PRlIIC2PAt. '.DU:1.LU'" $U:"ARY ~ . . , .. , .. . .OO,'II1"'DI,jlR~. DUE. + . . J>> ....~~VED ..51.... INSIHfAItH.'lhJli.' .^",'w''''',:,,,'^~'''''.'''.''':''''~ III,.. ,~E.IUIIS(S), ... S.46 TDTAL A1IDUltrDUE IS . . lEU, ....TllRDUS1I..-H.99 . .'C ...... . ~iCLA~I'&lE~.. . 5..lt~:I. . I VGU<< UlSt'RUCT.lGIIS~.THEAtlOuNTOF~,.!.&"ILL HDRAFTED FROII 'tOUR caUllT ON 7-12-99. ... . .. ..... .. . z... $6.1 '.""'."'5.4 . '5.t POSTI_ DATE " " .; - - ",..', - .. , ~ , , TRAN$ACUON .ACTJVl;'rY SINCE".~R UST STATEIlENT -.," ,'. EFFECTIVE ..',J '.. .:' > ... ".1; .", '. . '.DATE; ; iACTl:~TY DE8CltIPTJON U8U1tT" >:- '<'UI .1ftCJ ;~6-.1~'9IEaINNINC. p.RIHUPAL'., .. ..i ............. .:';;'.'; . .. ,:'" ~H'ti;.: ...;.'.o.tt 6-1Z-99 1IE~~=MmCHEcKl"C-'" .~:~o~'~:~; "~"96..7l TO PRINCIPAL' . ......, . 59.21 ;:,,, , :m,:==-,~"RGE" . , ~:ft ~~.9,..E..l..a;,PRlIlCI.AI:.,. .... '. ."..";...,,~,, ~ "..... ,. i ;.., ~'- '-"~' ,"',... - . ~ " .,9.1.7' '6-12"" ~: :'h3-:.~ .:c. ." .;;' .,J:~~'f4Y "FJNAIICE eNAII8E .-SUItllARY" '~,NC-'" . t ClAn.\' ...lGD!.CaAT'p' ..uag.ra .c_UT~ ~UR FINANCE CHARHIS lASED ON A 565 DA' lR APPLIED OVER sa DAYS THIS PERlOD~-' ,tECT YOU FEDE.RAL SAVI..NO & LOAN ASSOCIATION IIUIHIES, 101 S HtR. H ST 'PD ."BDX15ua ."I9RIC -PA .7.1..?Me t:. \ ~..J 1m ..'--------- 1__ ~ .. ,"" , ,.-' - ~A~~ ~~W '[!;, "i . . ,.-'. '" .., ,;.-.. .. .-, ~ ~ i.-? '. "",' " ." .." '-,' ,.,,' ... - PlEAllE AEIIT PAYIIENr to: P.o. lOX 1<10. 'IIJllK, PA.,_<IO -- '...II....'..,.,.,..'...'II....'........'.I.'..IIH.I'.....I.' , N"IU.. R NEGLEY., .' CECIL .JNE6LEY . 1466 CENTER RJ) . NEWVILLE P"'1724I-'715 CLaslH DATE 6-10-" . PAYIIENT . ... DUE, PAYNENT DUE DATE 7-12-9' . --- -- 65.06 ENTER AftaUNT PA.ID -:5 J08-8000': NOTlCE:SeE REVERSE SIDE...'.".":." ;",,",:,..;,.,.: .";', .,> .. .. ",.. ,,_ .... .. . . FOR ~ANT lNFORMAl'ION. . ~ _......!;~~...,..f~\!~--...:;- .,:'r: .~,:,:-.-.:, :.,7"'.:", ': -:""':'"" '__.~~::-'. .' ,:_. '. ....: . ... " ...._,;.~.. ".' " _ ... ; ~. ,.... '.' . ... .. '~'_: ," . ,',' .~. . AccauNT IlUltBER !; . , . OPN-S429881299 ~~ ~'i "ti_ ':-: ;::! :'] ...,'.- rj . . , ':.." M. _...~. lifE EOItITY UNE OF CREDIT . ~ ACCOUNT,... _:'5429.012". .". . -. - . ~ ,~.' , '. ,. PA8E' . ... .2 OF ..(CONTINUED} III 2 . '.~. . FINANce CHARGE $UIIIIARY ',.. FRail .'-0~-99 : ::"'- . -. .~. ',-l"1Ai "'ONENTS.D~"If'fIJ._ECRAI8EIf..AT. PERIDDIC~TESF'D".. 6~1l-99 TlIROUGH ..'-J'-~ DI,tlll,['.fl. BIn r[llll'.lll[ 'III"I~R' .. n .:;;"""~ ;~!'cHDJTUFE..JiIiSlUNCE DAILY PI. .n . ;DODleRA. TE.....;... ....211".. .. API. ...841;'~ TOTAL ".,I.MCE CHAR6E....~L PERCENTMlE-JtkTE FOR PERIOD .,....4iix '.. . '-. .' '4;1,' ,~~ ,'" . . .. _.' :' ,'; . :,,~ -~--.~ :',; _'" '1;:,".:,,- ",_;, 'f~E PERIODIC RATE ,.p;etHft~=6f~~a~T IlAY VARY. ... ANNUAL';';'...-'""," DAILY, AVERAGE THRDUeH ...PERCENTA8E RATE~.. 'PERIODIC RATE DAILY ."LaCI ,-18-999.00'.'::'. .'.0112465711 4,975.1, ~-/j:'-':j~;.':'~hq<t .:',~"':" .~ -~:1'1';;! '.:~---::":" ..i~aj~'W.~C'.;~ ;-i~.;-~'" -'-,;S';(~..~i " "" .. - ~""'.- - ";.~~~~;':.'::~ ~';: .-, ;., .',' ..,. :; '\., -0;'.' :':~~; ;~-_i- i~ ..; .'~' ~:.{ j-?.;:'i:;~;; ~~ ;~~:.~.j- ;idC;1g ~f~ j;~J~~':r;), :';T" '~"--,,",~ 'I. .~,'" ","'., _ ,;. ~:.7'i.,}: :.-' ';~ ~~ :-:::~ ~ :-[: -.:~ _'~ ~, -:. i ~z. ", ,- , ,'... -",'. . ., '" '~ -,-~""" .~" - ilili;i-_ ._, " SAMUEL L. ANDES ATTORNEY AT LAW 525 NORTH TWELFTH STREET P. O. BOX 168 LEMOYNE, PENNSYLVANIA 17043 TELEPHONE (717) 761-5361 MEMO FAX (717) 761-1435 TO: All Counsel FROM: Samuel L. Andes DATE: 12 March 2001 I have tried to schedule the hearing in this matter far enough away that no one will have a conflict so it will not have to be postponed. If that is not the case, I put the burden on whoever has a conflict, and requires the matter be rescheduled, to contact all five of us, or our offices, to find a date that suits everyone. When you have done that and can give me a date that has been cleared with everyone, I will issue a new notice. If you need to contact me for scheduling purposes, please speak to Amy Harkins at my office. Hopefully all of that will not be necessary and I will see you at the time set by the enclosed notice. -. - ~- MARLIN R. NEGLEY and CECIL J. NEGLEY, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW EDWARD A. WINGFIELD and BRENDA L. WINGFIELD, NO. 2000-7713 CIVIL TERM Defendants TO: Thomas E. Flower, Esquire 2109 Market Street Camp Hill, Pa 17011 Counsel for Plaintiffs Peter J. Russo, Esquire 5010 East Trindle Road, Suite 200 Mechanicsburg, PA 17055 Counsel for Defendants NOTICE OF HEARING YOU ARE HEREBY NOTIFIED that the undersigned arbitrators appointed by the Court in the above-captioned matter will meet for the purpose of their appointment on Friday, 20 April 2001 beginning at 1 :00 p.m. in the Second Floor Hearing room in the Old Cumberland County Courthouse, Carlisle, Pennsylvania, at which time and place you may appear and be heard, together with your witnesses and counsel, if you so desire. /S/ SAMUEL L. ANDES Dated: 12 March 2001 Samuel L. Andes, Esquire - Chairman David R. Brechi, Esquire Thomas A. Capper, Esquire cc: Court Administrator's Office _ i il -"-if , MARLIN R. NEGLEY and CECIL 1. NEGLEY: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 -- 7713 EDWARD A. WINGFIELD and BRENDA L. : CIVIL ACTION - LAW WINGFIELD Defendant PRAECIPE TO WITHDRAW EXHIBITS ATTACHED TO ORIGINAL COMPLAINT To the Prothonotary: Kindly withdraw (or strike) from the docket (or record) the two documents marked Exhibits A and B, attached to the original COMPLAINT in the above-captioned matter. DATE: I ~cS~ Thomas E. Flower, Esquire Attorney for Plaintiff r II r MARLIN R. NEGLEY and CECIL J. NEGLEY, Plaintiffs v. EDWARD A. WINGFIELD and BRENDA L. WINGFIELD, Defendants _i - ~ r-, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000 - 7713 CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 6....-~ of IJ1d/t.d:f.OOl , in consideration of the foregoing Petition, , Esquire, jI' ()p~ ~ , Esquire and ~.~ action(s) as prayed for. , Esquire are appointed arbitrators in the above-captioned BY THE COURT: fJ. ~ I --,- ."," .."!MIl. J [ f-F~;) ... J hi .' """ ,-,' ~) ~ r;, n.{,:, -_::-:! '-,.', '-, "1 ;', 1"1""( \..Lr",,:,_: '.Le-'i"...) vl",.hJj'JI fJENNSYLV,\Niil -~-, ."'^" I"""""" ',~ "'~ -, u_~'" M""~'m~"<-~~ N''-"L'''-ljfC':~'f ~ -.-lI~~"I_Il;\""",,,,,,,~,,,, "f>l!!IIlft.l!l", ,,,,,,,,,'~i~~r'~~:~'mf~,~~jJmff%,,[-!ffi)>I'l?~~ ." - ;, ,_, ; c_ - _ - I ',~ ,',-,,""<,,-' '--.',~" 'ii" j MARLIN R. NEGLEY and CECIL J. NEGLEY, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 7713 EDWARD A. WINGFIELD and BRENDA 1. WINGFIELD, Defendants CIVIL ACTION - LAW PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Thomas E. Flower, Esquire, counsel for Plaintiffs in the above action, respectfully represents that: I. The above-captioned action is at issue. 2. The claim of the Plaintiffs in the action is $12,286.00 plus interest. The following attorneys are interested in the case as counselor are otherwise disqualified to sit as arbitrators: Hubert X. Gilroy, Peter J. Russo and Thomas E. Flower. WHEREFORE, your Petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Date: 3 / b II 0 / B~~ Thomas E. Flower, EsqUIre Supreme Court Id. # 83993 2109 Market Street CampHill,PA 17011 (717) 737-3405 Counsel for Plaintiffs lliil1 ,,,,,"~~l '" "~-"--"',.:Ij\il'1\iillM~_:clh ~ '"'~~i~>>:!l(J.ll'fi,">),,*,m~J.II~"V~''''''""''' '~':'~""""q!iil\il!~'W~ .-~., llt~ -~.= . . . l 0 C. ~ fA. c ~,~ P h ::::.....,. ..-',,", -rJG; . rnf; ::::'1 Z:-:,-: ~ Jl 0 :;:::: C. SJ;'~_ 0 r-":1 [- :< ". ....... Lv S:(~..: 0- r-- ~ :t~E ,"'-:) ~ ~ "'0 ~ -< S:J ~< ' ""~ "b -t: ....... -< '-l ~ ---(. ~_ ___ _^O_~_ , ~, ,- t:aIiI - -"'.. ,-j, ,- , , "'-i:, MARLIN R. NEGLEY and CECIL J. NEGLEY: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 -- 7713 EDWARD A. WINGFIELD and BRENDA L. : CML ACTION - LAW WINGFIELD Defendant PRAECIPE TO FILE AMENDED COMPLAINT To the Prothonotary: Kindly file the attached AMENDED COMPLAINT in reference to the above-captioned matter. DATE: I 112 ) 6 I I ~~ Thomas E. Flower, Esquire Attorney for Plaintiff ,~ ~ 1'-. -.b,. ~_ J, ,'" '0"'-" "' :"~" ,,,' .-~ ~"" ,'~ - .i'C MARLIN R. NEGLEY and CECIL J. NEGLEY: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. EDWARD A. WINGFIELD and BRENDA L. : CIVIL ACTION - LAW WINGFIELD Defendant 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 HA VB 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, P A 17013 (717) 249-3166 or (800) 990-9108 ',<- , 1-. _,,__I <; ,,-J--_ .~ MARLIN R. NEGLEY and CECIL J. NEGLEY: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. EDWARD A. WINGFIELD and BRENDA 1. : CIVIL ACTION - LAW WINGFIELD Defendant NOTICIA Le ban demandado a usted a la corte. Si usted quiere defenderse en contra estas demandas expuestas en las paginas siguientes, usted tien veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones a las demandas en contra suya. Se ha avisado que si usted no se defienda, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO 0 PROPIEDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE 0 CONOCES UN ABOGADO, VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRlTA ABAJO PARA AVERlGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 or (800) 990-9108 h-," , _J",: - -...... .''''.' MARLIN R. NEGLEY and CECIL 1. NEGLEY: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2000-7713 EDWARD A. WINGFIELD and BRENDA 1. : CML ACTION - LAW WINGFIELD Defendant AMENDED COMPLAINT I. Plaintiffs are Marlin R. Negley and Cecil J. Negley, husband and wife, residing at 1466 Center Road, Newville, Pennsylvania. 2. Defendants are Edward A. Wingfield, residing at 130 North Hanover Street, Carlisle, Pennsylvania and his wife, from whom he is separated, Brenda 1. Wingfield, residing at 1466 Center Road, Newville, Pennsylvania. 3. Plaintiffs are the Parents of Brenda 1. Wingfield. COUNT! 4. In 1997 Defendants asked Plaintiffs to lend them $2,350.00 to enable Defendants to pay household expenses. 5. In exchange for Defendants' oral promise to repay the money, Plaintiffs paid Defendents' household expense bills in the amount of$2,350.00. 6. Defendants failed to repay the money as promised. 7. In May of 1999, Defendants again came to Plaintiffs, asking for a loan to pay household bills, this tinle totaling more than $5,000.00. 8. Plaintiffs reminded Defendants that the $2,350.00 borrowed in 1997 had never been repaid. ~ J . j- ;~ I" ~, "~ --'~..r..... -- J 9. Defendants acknowledged the obligation to repay the $2,350.00 and promised orally that, if Plaintiffs would lend them an additional $5,000.00, Defendants would repay both sums. 10. Plaintiffs stated that they would borrow $5,000.00, and apply it to pay Defendants' bills, only if Defendants would give security for their promise to repay, by granting Plaintiffs a lien against Defendants' mobile home. II. In order to carry out this arrangement, Plaintiffs, on May 24, 1999, borrowed $5,000.00 from York Federal Savings & Loan at 9% interest. 12. On or about the same day, Defendants executed the documents necessary to grant Plaintiffs a properly perfected first lien against Defendants' mobile home, and recorded on the title thereto. 13. In retunl for these oral promises and perfected security interest, Plaintiffs applied the funds obtained from York Federal to payment of Defendants' bills in the amount of $5,000.00. 14. Defendants thereafter made three payments on this obligation amounting to, in total, $199.00, and nothing more. WHEREFORE Plaintiffs demand judgement against Defendants for breach of contract in the amount of $4,801.00 plus interest at 9% from May 24, 1999 and $2,350.00 plus interest from the time of the commencement of this action. COUNT II 15. Plaintiffs reallege each and every allegation contained in paragraphs I through 14 and incorporate them herein by reference. WHEREFORE Plaintiffs demand judgment against defendants in restitution for unjust enrichment in the amount of $4,801.00 plus interest at 9% from May 24, 1999 and $2,350.00 plus interest from the time of the commencement of this action. , i :1:... '..; "i1 --" "~^, COUNT III 16. After June 1999, Defendants also borrowed from Plaintiffs $500.00, in $20.00 increments, all of which Defendants promised orally to repay, but have not done so. WHEREFORE Plaintiffs demand judgement against Defendants for breach of contract in the amount of $500.00. COUNT N 17. Plaintiffs reallege each and every allegation contained in paragraph 16 and incorporate them herein by reference. WHEREFORE Plaintiffs demand judgment against defendants in restitution for unjust enrichment in the amount of $500.00. COUNT V 18. Since June 1999, Plaintiffs have paid the following bills for Defendants, in exchange for Defendants' oral promises to repay them: (a) $206.00 for mobile home casualty insurance; (b) $119.00 to repair the mobile home's furnace; (c) $147.00 for kerosene to heat the mobile home; and (d) $325.00 for expenses of going to the Bloomsburg Fair. 19. Defendants have not repaid any of these amounts. WHEREFORE Plaintiffs demand judgement against Defendants for breach of contract in the amount of $797.00. --~ I. _J-, . 'J_ ~ '" I . '~~ COUNT VI 20. Plaintiffs reallege each and every allegation contained in paragraphs 18 and 19 and incorporate them herein by reference. WHEREFORE Plaintiffs demand judgment against defendants in restitution for unjust enrichment in the amount of $797.00. COUNT VII 21. Plaintiffs have paid the lot rent to the mobile home park where Defendants' mobile home is situated, at $308.00 a month, for ELEVEN (II) months, for a total cost of$3,388.00. WHEREFORE Plaintiffs demand judgment against defendants in restitution for unjust enrichment in the amount of$3,388.00. COUNT VIII 22. When their lessees do not mow, the mobile home park management assesses a $45.00 mowing charge against the rented lot, for each ofthe stated mowing periods. 23. Defendants have not mowed the rented mobile home lot for more than a year. 24. Plaintiffs have mowed the grass around the Defendants' mobile home ten times to prevent assessment of a mowing charge. WHEREFORE Plaintiffs demand judgment against Defendants in restitution for unjust enrichment in the amount of $450.00. In the alternative, Plaintiffs demand judgment against Defendants in quantwn meruit in such amount as the court deems just. , .- ,. '. -1:- ..,1-; I" Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Date: BY:~~ Thomas E. Flower, Esquire Supreme Court ill #83993 2109 Market Street Camp Hill, PA 17011 (717) 737.3405 Attorney for Plaintiff ,. '_-~" .i'i-'" H '-,- . r , " ~ ~<~.~ -~ . , L" ,_ ~ -. - ,; '" ,- -I MARLIN R. NEGLEY and CECIL J. NEGLEY: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. ; No.7 7/ 3 ( z.~oo ) EDWARD A. WINGFIELD and BRENDA L. : CIVIL ACTION - LAW WINGFIELD Defendant VERIFICATION I, C fC IL J. N ~ C, L rc y , hereby verify that the statements made in the foregoing Amended Complaint are true and correct to the best of my information, knowledge and belief. 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: /-/Z-6/ By ck12- l1ep( , -,' ;"'~.i" _:J '.- ,._. '.._f_:",'_>., , MARLIN R. NEGLEY and CECIL 1. NEGLEY: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-7713 EDWARD A. WINGFIELD and BRENDA L. : CIVIL ACTION - LAW WINGFIELD Defendant CERTIFICATE OF SERVICE AND NOW, this /:f!' day ofJanuary 2001, I, Thomas E. Flower, Esquire, of the firm of Saidis, Shuff, Flower and Lindsay, hereby certify that I this day served a true and correct copy of the foregoing Amended Complaint upon the parties listed below via United States Mail, postage prepaid, addressed as follows: Peter J. Russo, Esquire 50 I 0 East Trindle Road Suite 200 Mechanicsburg, P A 17055 Brenda L. Wingfield 1466 Center Road Newville, P A 17241 Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY BY:~~_ Thomas E. Flower, Esquire Supreme Court ill #83993 2109 Market Street CampHill,PA 17011 (717) 737-3405 Attorney for Plaintiff Jut. , , "i .1 , '--'"-. . .): MARLIN R. NEGLEY and CECIL J. NEGLEY, Plaintiffs IN THE COURT OF COMMON PLEAS of CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-7713 EDWARD A. WINGFIELD and BRENDA L. WINGFIELD, Defendants : CIVIL ACTION - LAW PLAINTIFFS' REPLY TO NEW MATTER AND NOW, COME the Plaintiffs, Marlin R. Negley and Cecil J. Negley, by and through their counsel, Thomas E. Flower, Esquire, and, in reply to "New Matter" at Paragraphs 33 - 49 of Defendant Edward A. Wingfield's Answer, Plaintiffs aver the following: 33. Paragraph 33 is admitted. The contracts sued upon were oral, as stated in Plaintiffs' Complaint. 34. Paragraph 34 is denied. Defendants orally agreed to pay $65.07 per month at 9%, in accordance with the terms of Plaintiffs' obligation to York Federal. 35. Paragraph 35 is admitted, to the extent that Plaintiffs' demands for payment were oral, and therefore not "formal," until Defendants were given formal notice of Plaintiffs' intention to sue for payment in the District Magistrate's Court. 36. Paragraph 36 is denied. Plaintiffs repeatedly reminded Defendants of their unfulfilled obligation to repay the sums due and demanded payment thereof in full, and such demands were repeatedly addressed to Defendants before Plaintiffs became aware of Defendants' marital difficulties. 37. - 49. Paragraphs 37 - 49 merely state conclusions oflaw without factual support, to which no reply is required. I - I. - - -~ ,'.-.-- ""'" ~- '" ".lie WHEREFORE, Plaintiffs demand judgment against Defendants on all counts of the Complaint filed in the above-captioned matter. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Date: 11"3 0 10 ( BY:~~ Thomas E. Flower, Esquire Supreme Court ID #83993 2109 Market Street Camp Hill, PA l701l (717) 737-3405 Attorney for Plaintiff 2 .-'"'" ,~ I ltiifuw MARLIN R. NEGLEY and CECIL J. NEGLEY, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 2000 - 7713 EDWARD A. WINGFIELD and BRENDA 1. WINGFIELD Defendant : CML ACTION - LAW VERIFICATION I, Cecil J. Negley, hereby verity that the statements made in the foregoing Reply to New Matter are true and correct to the best of my information, knowledge and belief. 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: ~.3.o/ . By: ~ Cecil J. Ne ,-. ~ " " d -,I ,-,~;" 1 " '." 'iIIIll "".,";C",,"',;, MARLIN R. NEGLEY and CECIL J. NEGLEY: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-7713 EDWARD A. WINGFIELD and BRENDA L. : CIVIL ACTION - LAW WINGFIELD Defendant CERTIFICATE OF SERVICE .1-...;"",," c;, h . AND NOW, this ~day of~ 2001, I, Thomas E. Flower, Esquire, of the fIrm of Saidis, Shuff, Flower and Lindsay, hereby certify that I this day served a true and correct copy of the foregoing Reply to New Matter upon the parties listed below via United States Mail, postage prepaid, addressed as follows: Peter 1. Russo, Esquire 5010 East Trindle Road Suite 200 Mechanicsburg, P A 17055 Brenda L. Wingfield 1466 Center Road Newville, P A 17241 Respectfully submitted, SAIDlS, SHUFF, FLOWER & LINDSAY B~~ homas E. Flower, EsqUire Supreme Court ID #83993 2109 Market Street Camp Hill, P A 17011 (717) 737-3405 Attorney for Plaintiff "L I,; MARLIN R. NEGLEY and CECIL 1. NEGLEY: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 -- 7713 EDWARD A. WINGFIELD and BRENDA 1. : CIVIL ACTION - LAW WINGFIELD Defendant PRAECIPE TO FILE STIPULATION OF PARTIES To the Prothonotary: Kindly file the attached STIPULATION OF PARTIES in reference to the above-captioned matter. DATE: 11/2 I 0 I I ~~ Thomas E. Flower, Esquire Attorney for Plaintiff ,; .1-, . I.." ^" ",-." ",-,."-,~"",, -c.:.",,~,,-c ,-<, "/' MARLIN R. NEGLEY and CECIL J. NEGLEY, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. ~ CIVIL TERM . JJO,~-7713 EDW AlUl A. WINGFIELD and BRENDA L. WINGFIELD, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED STIPULATIpN OF THE PARTIES , AND NOW, COME, the Plaintiffsj by and through their counsel, Thomas E- Flower, Esquire and Defendant, Edward A Wingfit1d, by and through his counsel, Peter J. Russo, Esquire, and stipulate to the following: I. Plaintiffs shall file an Amended Coinplaint within thirty (30) days of the execution of this I stipulation. 2. Plaintiffs shall strike from the reco~d any and all exhibits attached to the original Complaint. 3. Plaintiffs shall separate any and all pauses of action into separate counts. I 4. Defendant, Edward A Wingfield, ,grees to file a resppnsive pleading within fourteen (14) days of service of Plaintiffs' Amende1 Complaint upon counsel for Edward A Wingfield. S. Plaintiffs shall not proceed with th~ entry of a default in this matter lmtil the expiration of , the period provided for Defendant's respoqse to Plaintiffs' Amended Complaint. zoo if] XVd SC:91 100Z/ll/10 1- , - ~I,-. ':' ~ _ .'.-"1.'_'';_,0,----,,,,;.;;-,,;-, '" '" "'" -~;: 6. This Stipulation may be executed in two counterparts and joined as one to Create a fully executed and enforceable original. Resp~ctfully submitted, ~.~ Thomas E. Flower Counsel fOT Plaintiffs Date: III ( (7 t")&- J {t- ( 0~ Peter J. Russo Counsel for Edward A. Wingfield Date: Tbursdav. January 11,2001 coo~ XVd sc:g, ,OOZ/,,/,O ~ - r-c-'_ -"'. ,,'1><>'-.' .. "-'-',,", -"-"'-'~'''' ".,'",,-, .-, MARLIN R. NEGLEY and CECIL J. NEGLEY, Plaintiffs v : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 1-1-\:J : NO. 00 -.... CIVIL TERM EDWARD A. WINGFIELD and BRENDA L. WINGFIELD, Defendants : CIVIL ACTION - LAW v BRENDA L. WINGFIELD, Cross-Claim : JURY TRIAL DEMANDED ANSWER OF DEFENDANT. BRENDA L. WINGFIELD TO COMPLAINT OF PLAINTIFFS AND NEW MATTER AND CROSS-CLAIM OF DEFENDANT EDWARD A. WINGFIELD Defendant, Brenda L. Wingfield, by her attorneys, Broujos & Gilroy, P.C., sets forth the following in response to the amended complaint of Plaintiffs and the New Matter and Cross- Claim of Defendant Edward A. Wingfield: I Admitted. 2 Admitted. 3 Admitted .....~. . I', ",,' .'" ,-0-:'<,,',", ~ '_~(" ,_ ,~, _,,~__. COUNT I 4 Admitted. 5 Admitted. 6 Admitted. 7 Admitted. 8 Admitted. 9 Admitted. 10 Admitted. 11 Admitted. 12 Admitted. 13 Admitted. -~" .~, -~,< -~ r' '0" "--I~'d',,_ "". ;-" ,~ "-_, ,- .",- ,,_-..~--"';,c"-"~""',;;,,'l""-- ,,"..-; """~! 14 Admitted. Count II 15 Admitted. Count III 16 Admitted. Count IV 17 Admitted. Count V 18 Admitted. 19 Admitted. Count VI 20 Admitted. Count VII 21 Admitted. Count VIII 22 Admitted. 23 Admitted. 24 Admitted. ~~~_""', ,",_.>. ___.0"_ '''~, .,,-,""_' ,',~."'-' ", ~ _ _ .:; -, ,"' . 'j.~' ~'-, "'~,'~. '_"" -.... 'L~,';-'",'~,.,~'k-:', -".J'--_~;" ,". e_" "! New Matter & Cross-Claim 25 Admitted in the sense that Defendant Brenda 1. Wingfield continued to reside at the marital residence for approximately three days. 26 Denied. The answer as set forth in Paragraph 25 hereof and incorporated herein by reference thereto. 27 Denied. 28 Denied. Proof thereof is demanded. 29 Denied. Proof thereof is demanded. 30 Denied. Proof thereof is demanded. 31 Denied. Proof thereof is demanded. 32 Denied. Proof thereof is demanded. WHEREFORE, Defendant, Brenda 1. Wingfield, requests that the Cross-Claim filed by Defendant Edward A. Wingfield be dismissed. ~., -'~-<~-^ ." -" .~,. - .-- '-.",-"~-U.",<.- ., '-~, '-'-" '~-'. .:\",,-, !:l~l~o' New Matter 33 Admitted. 34 Admitted. 35 Admitted. 36 Denied. Plaintiffs always anticipated repayment of these funds regardless of the marital situation between the Defendants. 37 Denied. 38 Denied. 39 Denied. 40 Denied. 41 Denied. ,--~., ,-~--~". ., _ ",,'''' -0"-." _\'. "0-". '." '"'-~,- ""-C,c,,':' oc '_'''_, _ "--'-;~''',v_, 42 Denied. 43 Denied. 44 Denied. 45 Denied. 46 Denied. 47 Denied. 48 Denied. 49 Denied. Respectfully submitted, Or Hubert X. Gi oy, Esquire Attorney D Defendant, Brenda 1. Wingfield Broujos Gilroy, P.C. 4 No Hanover Street Carlisle, P A 17013 (717) 243-4574 0" ~""~ ."~"."- ~~ ... ;;. ,,-'c :,,-, ~' I verify that the statements made in the foregoing document 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 unsworn falsification to authorities. DATE: @-(<O-o/ ~ ~ LJ~( 'tlt)~ Brenda 1. Wingfield \) .._~ ~" . , ..;.--,.,," .'-- , 'I.,;.,,,, ,. .. ---'._.1 ___f. ._'_ _~ _,'.-,,' ,"'."i,' ~",-,h~"'c ,~ -,~ "__'~_;, MARLIN R. NEGLEY and CECIL J. NEGLEY: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00 -" /3 v. EDWARD A. WINGFIELD and BRENDA L. WINGFIELD Defendant : CIVIL ACTION - LAW CERTIFICATE OF SERVICE AND NOW, this 11-t1t day of ~t.e.v-\ ~ ' 2000, I, Thomas E. Flower, Esquire, of the firm of Saidis, Shuff, Flower and Lindsay, hereby certify that I this day served a true and correct copy of the Complaint upon the parties listed below via United States Mail, postage prepaid, addressed as follows: Peter 1. Russo, Esquire 5010 East Trindle Road Suite 200 Mechanicsburg, PA 17055 Respectfully submitted, SAlDIS, SHUFF, FLOWER & LINDSAY B~~ Thomas E. Flower, Esquire Supreme Court ill #83993 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff =' I ~ -.~ "0""', , . 0 c:> CJ C .-n ~~~ ~ -0 '-'1 n-\ . 1:-:] Z 0 f':": N L.') , r::: . ~- 7':-' t~~ UJ ~ '~'~,\ ~:- ::J .< .-<,. '~-'\ ': - ".~, "~!iiIIiI!iiii1:1t"'"""' OJ . ,~- -- -,~ - - t, "'_-,",_^,-,,""~,= ~;.i!u-m it ,- it"4 ~~~;;"_'-';-'K",.-t' -~ -.- , .,1.__ o~ ~:J-"_" ',"'- ..& ' -. ~ 0 <::) 0 C 0 '~fl -ofE <::7 :0:5 f"71 ~f mrn (J Z::o :;;:;1:;:' N (rj< '-<4. '-c " :5:::: ~o ~ 'c:::!r; --r:Sfn j;:g ~ u Z ~ =< :n .f:" -< , ~; .-~=. .1 j,_,i..,,,.,,,I___ _ ,.,-.- ."''k'.;-__-- .''>''Wi::;- , 1, MARLIN R. NEGLEY and IN THE COURT OF COMMON PLEAS OF CECIL J. NEGLEY CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-7713 CIVIL TERM EDWARD A. WINGFIELD And BRENDA L. WINGFIELD CIVIL ACTION - LAW IN RE: ARBITRATION ORDER OF COURT IN RE: ARBITRATION ORDER OF COURT AND NOW, December 11, 2000, the Petition for Appointment of Arbitrators in the above case having been withdrawn by praecipe, the panel of arbitrators appointed by Order of December 6,2000, is vacated. By the Court, P.J. Peter Russo, Esquire For the Defendants c~ 1"1 J:<-/~'OO '1. Kg Thomas E. Flower, Esquire For the Plaintiffs '4r i .. ""'" "'.' , .,. ~~--, ~ .~ [-I FI)-C)l'T!CE " ",''''T' ':-"""'"IoRY !~k' -, '_':',',U'~'0jn I 00 CEe 0', If]" 1 "/ ,qn . l.. CUMt:;f.:;iLl,i'EJ COUNTY PENNSYLVANIA __ [:~:m-!W~",,,, "_,UJ~(!:".~,~~~w_,_ . ,.. ,., ,"-"....IW IJ~~"JIii_ITUiU1P j,!\i~~~J ,,'" .-" ,-r ,--..~ SAlDIS S~~WER &Ul"IuSAY ATIOIINEYS.A'f.lAW 2109 Market Street Camp1lill,PA "-. . - -. m'_;__ .-"',_;,,'<,<~'1 '.~_._. MARLIN R. NEGLEY and CECIL J. NEGLEY, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO.~2000 - 77.lJ. EDWARD A. WINGFIELD and BRENDA L. WINGFIELD, Defendants CIVIL ACTION - LAW PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Thomas E. Flower, Esquire, counsel for Plaintiffs in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiffs in the action is $11,828.00 plus interest. The counterclaim of the Defendant in the action is N/ A. The following attorneys are interested in the case(s) as counselor are otherwise disqualified to sit as arbitrators: Peter Russo, Esquire WHEREFORE, your Petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Date: Pee.. 4; J.,O(}O BY:~~ Thomas E. Flower, Esquire Supreme Court Id. # 83993 2109 Market Street Camp Hill, P A 17011 (717) 737-3405 Counsel for Plaintiffs ~ " ~ ""- I;::; ~~. '" I ..... ',', t."",,, ".. t:'~ Q ! Cl ?: - 'Z ., :::>4: - O~ 5C <:.) 0.- 03 ->: l!") 1jU"J \ ," :z ,,-z u L".iJ-w \.;.J ,DO. C -5 0 '5 0 <:.) ,;',' ":r'J"J':F!('~ . .~\~U . l .'J.,... OF ;:;;::jf~KJNOT A.R'l OOOEe -6 PM 3: 41 CUMBf.;HlllNO COUN1Y pENNS'fLVANlI\ --J.."------ C3: J.- 0"" '--d t() ~ 0- ~ J; ~ ~J '- (-) )1'* " 2J 0!. "bi .~-< I "'J.--," ~ .""h.' ""'"'' "".,.."""., , . . ,<,~ ,-,,,->"-,,."~,-- '-"c'\_,,"'__~\",?'r"'_<--_1;;'f'>',-'" --: :":,,~'r7~"'''''''':--:-'' i I 'I " :i :i II II .,.'",'., .-~ ~ .w, ,-'. ,.,,-,. ,,,,,- -o"''''''F' I... ...... J--,-,-,'-r!"",<.',,j'- ,-'} . -;,.... J: ..... -. MARLIN R. NEGLEY and CECIL 1. NEGLEY, Plaintiffs v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 771J NO.~-2000 EDWARD A. WINGFIELD and BRENDA L. WINGFIELD, Defendants CIVIL ACTION - LAW ORDER OF COURT -1^- ~ AND NOW, this r;, day of ~OO , in consideration of the foregoing Petition, ~/7 -r-'. ~ 9: h . , I ~ , Esquire, , ~ Esquire and - ,) / ~. & tl-ft<..tV , Esquire are appointed arbitrators in the above-captioned actionCs) as prayed for. J. . SAIDIS SII\.Jffi. !!OWER &Ul'luSAY ~1'lJllNEl'SoAToIAW 26W. High_t Carllsle, PA MARLIN & CECIL NEGLEY, Plaintiff v. EDWARD & BRENDA WINGFIELD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00- 11J3 c..'':'11 CIVIL - LAW PRAECIPE TO WITHDRAW PETITION FOR APPOINTMENT OF ARBITRATORS TO THE PROTHONOTARY: Kindly withdraw the Petition for Appointment of Arbitrators recently filed in the above-stated matter. By: SAIDIS, SHUFF, FLOWER & LINDSAY ~m~' ~; l' Date :~e. . i \ ) 2-000 II :! .'.'i~-.;JI;.'",",""- .. ~ -~ " ... '~:,- ... ~ ~COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL 10. 3/ '00 FROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT COM_N PLEAS No. cJd- '77 /:3 CIuU- NOTICE OF APPEAL Nofice is giyen that the appellant has filed in the above Caurt af Camman Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned belOVo( ~~ .~ (~':~:~:~~-: ADIlIlESS Of APPEllANT o No~~ So o..TE .IlJDGMENT at ClAIM NO F(Plainf) CITY IOq~Ol~""'Of~ , STATE Ca....-\\~Iv...?Y-\- II O\~ (Defendant) ZP CODE c...:.. c.., \ a ~ CVII! 43"-00 LT 19 This black will be signed ONLY when this natafian is required under Pc. R.c.PJ.P. No. 1008B. This Natice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment lor possession in this case. Signature of Prothonotary or Deputy If appellant was CLAIMANT (see Pa. R.CP.JP. ND. 1001(6) in action before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE Df APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. tOOf(?) 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 UPM'ClV-\\y'I ~ C'" C' ,\ i';:;l/'::IsJ ,appellee(s), to file a complaint in this appeal (Cornman Pleas No. Of) -7 71 ,:~ Ju~"within twenty (20) days alter ser~i~e of r~entry of judgment of non pro~ G~, Signature of appeHant or his attorney or agent RULE: To '(Y\o.V'\'V'I a. C<=..e..,\ ~c..i'1:.,/ Name of appeI/fle(s) . appellee(s). (1) You are nafified that a rule is hereby entered upon you to lile a camplaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered maiL (2) If you da nat lile a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of seniice of this rule if service was by mail is the dale of maili Dale: ID.-3/-(J(): '1-. NJPC 312.84 COURT FILE TO BE FILED WITH PROTHONOTARY j,~j,'"-~"'IIi!I'il'i.~- "~lill!~:f@:d~~;iilil,,-~~"'''''''n"i_''~'-\%__o!~~-~i' :1l~~ JlkIliMIi"ii!Iiill!tl '''~~ <}1!llf/;,tll'~_~~1.iih'ilIii':=~. . ,> I -..,.- . ., - PROOF OF SERVICE OF NOTICE OF APPEAl., AND RULE TO FILE COMPLAINT COMMONWEALTH OF PENNSYLVANIA (This prool 01 service MUST BE FiLED WITHIN TEN (10) DA YS AFTER filing Ihe notice of appeal, Check applicable boxes} J ; 8& AFFIDAVIT: I hereby swear or affirm that I served o a copy of the Notice of Appeal, Common Pleas No. , upon the District Justice designated therein on (date of service) 0 by personal service 0 by (certified) (registered) mail, sender's' receipt attached hereto, and upon the appellee, (name) , on , 19_ 0 by personal service 0 by (certified) (registered) mail, sender's receipt attached hereto, o and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to Whom the Rule was addressed on , 19~ by personal service 0 by (certified) (registered) mail, senders receipt attached hereto, SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF ,19_,__ Signature of affiant Signature of official before whom sffidsvit was made Title of official My commission expires on _19_ ..~~ B'cs q) - . <:Y0 -.J -./ -~. ~J), ~ 0.JCft b' (') C s: "'t1OJ ~!B Zr;:: ,q:>Z ~B ~O ",,0 ....C ~ , ,,'"' ","",-"' ;]: "{:2J i: r ~ - - -- - - ,T' 1~__~", ,.',-_'~~"~.m "~ ,~ - o o o n ,-I W o .." ~~;~~ '<'1-:-- ,;:;-ni :::uQ ";)6 'c.; ~r:: ...,., b:D ZO orn ~ -< v :ll: ~ t..) o ifit ""~_.m,gblJall~W,"""",,, .~.i . I . , ~ I" " ~"" .' "''-~'''-- '~"-'- :" ,ai,,___' .. "oil i: ,;./ ~~'" ....{ ",.'if" ~':" . ....,..COMMONWEAL~H OFPEN~YLVANIA COUNTY OF: CUMBERLAND 09-2-01 \NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS !NEGLEY, MARLIN & CECIL I 1466 CENTER ROAD NEWVILLE, PA 17241 L .J " " Mag. Dis!. No.: DJ Name: Hon. " PAULA P . CORREAL Addeoss, EAST WING - COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA Telephoo" (717) 240-6564 17013-0000 ATTORNEY DEF PRIVATE . . VS. PETER J. RUSSO, ATTORNEY 61 W LOUTHER ST CARLISLE, PA 17013 ,fl,' 1~ :4Jl DEFENDANT: NAME and ADDRESS 'wINGFIELD, EDWARD A, ET AL. I 130 N HANOVER ST APT.I 4 CARLISLE, PA 17013 L .J Docket No.: CV- 0000436 - 00 Date Filed: 8/11/00 THIS IS TO NOTIFY YOU THAT: -Jodgment: ",. [!] Judgment was entered for: (Name) [!] Judgment was entered against: (Name) FORPI.AINTIFP., . 1\TR~T.1i!V MlIRr.TlIT G. C"1i!C"TT. .....~~ WTlITGFTRT,n, RnWlIRn II in the amount of $ R 10R 00 on: (Date of Judgment) 10/02/00 D Defendants are jointly and severaiiy iiable. D Damages wiii be assessed on: (Date & Time) D This case dismissed without,prejudice. . $ 8.000.00 Amol,lnt of Judgment ....Judgm~n! Costs $ 108.00 Interest\ln Judgment $ .00 ". AttorneYFees $ .00 Total $ 8-.108.00 ... Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ D Amount of Judgment Subject to: Attachment/Act 5 of 1996 $ D D Levy is stayed for days or D generaiiy stayed. Objection to levy has been filed and hearing wiil be held: date ;,-, ." . .-,- .', , '. , "" , ,7'': . " "I' lace':""" , " '7' , ; , , - --,~- .. .. '. ., ., ;~"".e ','" . . , " Ti me '",,-,' ANY PARTY HAS THE RIGHT TO AgREAL~ITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE "".,~ . OF AP. PE. AL WITH., THE P.B..~.. ;T.. 'RON... OT AR. .YfC. ~RKO. 1'. 'TH~.C. O. .u. .!:l.. .'.;P.:.'~.'c. OM MON. p..~.'.i;A.. S, CIVIL DIVI.SION, : YOU. MUST INCLUDE A COPY t THIS NO: ", .~,~,U<::k~/;T FORM CTYOU~~~~I.,~::~~.~~~~,AL. , ",,!:.fJ./'UW' .J'.'i"; "'El.ate, \c.,., ,"', ,,' i"::.'Li"!e;;"''''''';,, ,,~.. ,'.J. '. ,,'fL"'L~.. ..i""'! .' 11)lstncl ~UstIC€! , ',' ,."~,~"':::,,./ ',.. ,;'.~..,..P"""~..~'~~i'> ,~,"" ...:;~, -. 1, ___~ . ,. ,_ "_ _,. _ " _, ,_ ".,," _ :',_<," ,_ _, '_, ' " , ,"',," ','. '\0 ::_ y.-"" ,.~. '" <~_ ': ':' _' , I .\ c~rtify th.at this is a t\U'e andcorre.ct c.. y otl~e re;.st r3.s,:;,9!09S contain' 3~~.~~rgm,e~t,., ,. 10/2/00 Date I' ""!/'''.,..:,-,~--.''f ;<_"/1,." ,_ " ',,Eil1ftnQl Justicil" --... " - -. - ".'" ... I'".,.. _ .. i\-~') ~.. '", '- . ,,~. ,-,', -. " '8'EALi ~ . .:".... ....,....' My commission expires first Monday of January, AOPC 315,99 2006 '.',.."__..-;.."1-,-.,,;;;,, '>-",",H.~'" ~',' ~~' ......,~.""l , 0'0 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Dist. No,: 09-2-01 DJName: Hon. PAULA P. CORREAL Add",,, EAST WING - COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PA r"'Ph'" (717) 240 - 6564 17013 - 0000 ATTORNEY DEF PRIVATE PETER J. RUSSO, ATTORNEY 61 W LOUTHER ST CARLISLE, PA 17013 OJ THIS IS TO NOTIFY YOU THAT: .' Judgment: ... [i] Judgment was entered for: iim ]!J!',-- NOTICE OF JUDGMENTITRANSCRlPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 'NEGLEY, MARLIN & CECIL 1466 CENTER ROAD NEWVILLE, PA 17241 L VS. DEFENDANT: NAME and ADDRESS 'wINGFIELD, EDWARD A, ET 130 N HANOVER ST APT.# CARLISLE, PA 17013 L I .J AL. 4 I .J . Docket No.: CV- 0000436 - 00 Date Filed: 8/11/00 FOR pr.A TNTTFF' (Name) 1ITR~T.F.V MIIRT.TN G. 1"F.I"Tr, [i] Judgment was entered against: (Name) in the amount of $ R, 1 OR 00 on: WTN~F'TF.T.n, RRRNnA T. (Date of Judgment) 10/0?/OO . o Defendants are jointly and severally liable. o Damages will be assessed on: o This case dismissed without prejudice. O Amount of Judgment Subject to Attachment/Act 5 of 1996 $ o o Levy is stayed for days or 0 generally stayed. Objection to levy has been filed and hearing will be held: (Date & Time) Amount of Judgment $ 8.000.00 Judgment Costs $ 108.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 8,108.00 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgm~nt Total $ Date: Place: .. ., . ..' Time: 10 / 2/00 Date I certify that this is a tr lQ/2/00 Date My commission expires firs Monday of January, AOPC 315.99 , District Justice judgment. "Dist'rict jlJStice 2006 . Si=AL "1.-. ..", COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTicE OF APPEAl. I FROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT COM_H PLEAS He. (jQ- 7'7 /3 C) u; I NOTICE OF APPEAL Notice is given that the appellant has filed in the above Caurt af C()II)manPleas an appeal from the judgment. rendered by the District Justice on the date and in the case menIiai1ed below. "Y-",.., '<::'"0.- NAME OF (~",!<)" J ADDRESS Of APPfU.ANf MAG. [)IST: NO OR NAME OF 0.J. \ "j 0 I'\oy \.h DATE Of AJDGMENT STATE ,:)A \'"'l 01 ~ (Defendant) (", ,^ '. r .' <J",J~!<? \'-Ic,\\c vs. '--''')VOJuVQ t-.'\\jl\nq\,d'ii, ("~T ~PPELLANT H _~. ",' ORAGEN. T 'rCY'\~~ L. l"');YHj\\'ll'(~ CV 19. \..\3<0- 00 J' ',_.A " , ~ tT 19 . ' -.' This block will be signed ONLY when this nola~on is required under Po. R.c.PJ.P. No. 1008B. This Notice of Appeal, when received by the District Jus~ce. will operate as a SUPERSEDEAS to the judgment for possession in this case. (~^ '\,J'{"\v,,<-d "" 00.. d' 0, CITY ZPC C\ :.", , r~ '" LI COy\\ ~\v. \ () "I 00 ClAIM NO '('Y\o v\,,,, " C"" <., I Signature of Prothonotary or Deputy If appellant was CLAIMANT (see Pa.. R.CP.JP. No. 1001 (6 )in action before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appeilant 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). PRAEClltlY ToProthonotary Enter rule upon I"'\') G< Y \ "'" C "''' "\ ~ ~.. J . appellee(s), ta file a complaint in this appeal (CommOn Pleas No. ;:tOO -7 7 , 3 ~\~I )I~:i~ twenty (20) days~ce of rule gr. entry of judgment of non pra~ '. c...::j;~~j Signature of appellant or his attomey or agent RULE, To {"i\C\vl, v,\ ~ Ce" ,\ \~(" \.. " Name 01 appeI/(re(s) " , appellee(s). (1) You are notified that a rule is hereby enteredupon you to file a complaint in this appeal within twenty (20) days after tlie dale of service of this rule ~~~~~.sonal service or by certified or registered mail ~~i~;:t-;~~\?'4\~-\-V \ ' . <i~~~'~!" ~:~ :(:-:C~};:t~i\, _' ~~~ '\!:- :,'-., ',,:[~:t:~;~'~?h--}. _ :' (2) ~d~J\lII;l'~~ptlI~~t-r~thin this time. a JUDGMENT OF NON PROS WILL 8E E~,~~''fQll''/';'it!. ~i:~Ir:t;';':" ,,'>~~~'__;: "-:.:..:,~':{>; .S.~~~'1~'"'' ,O"\f};: (~",,' c!6t<:,s>! i.:;"\of IhiS\'I""Jil:lJ'.service was by mail is the date of maili fl."':;,,';,,,;~ ,,'':~' . ,.0 :.' :r..,-~ t .<t-:~ '0_ -:', J:,,>\1t.' ~;,I ....;,; " . \.,. -f . " ~J':.:'-,~, , ~.J ,. ';l- ;,f'__1;1;", -"". ~ -..; :. .".:.~.,)-~~ Date: '#~~. ,I ~gi ~, . ;~,~L,,:,;~' ,t' , ,'." 'f-.," . :,: ..;i'~" ..,,. ,"" ,~ ~:: ~ :}:':~,;i', .-~ ^ Ji"' '.... ,:,,~~".!'-~:,- r"1~.. or ,''', ~ .' \""'(.',-;t!,-'-::"" , " ~ ' , . " .....,- 'J't1~\ t~i.i"" '" AC{t::"'~'~:"'"t.- . ;:l:;-~'-/~: :'~ '''~~~~~~:.~?: f ~\~ .' \'l,-, "Yl,,,,,.,~"?J,' "~or, V ,':';,;_""I!i--;" \ "~~ f'_<,. ;-.:; -",:",,:,,,~ . ,,'~~~ "~', ~-:,' ':;,:.....;;r.:'- " \'!\,"7<~~~"""";'~~~~""- - ". ~\>>~~);-"~~""!'-~-: ':' N:JPC 312--84 COURl'F~l~ ',~o,,"-,,~,;:0__ "'" "0''''''''''__ :;~;,_;"" ,~;;",",,,,,.,,,,,, ~~ ..~.......,_...... ,.,..~""~r~i~~.~-,;.'''.~~~ .'.,. .! ~~-~""""" _~~I~ I ~=" " ~:.. .., ~'''';;'I~'~''~''''''''-~''''' -, ". '''''1'~~ If,~ -- ~- --:-C'~_'~\-'" ,', '~f:I,[ 'i!:.' Vj!';i;,,}',c:":-' ,"- r"~_';:! cJ:o'\-01l-.~~_~ -"""'"-"""~ - () 0 0 C Cl '11 ,,~ 2: ....., 2m ~ il~]] zfR -;1m (J)3E w i'~9 lie] u '~~(? ~o ::ill: CS:n PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE :eiM~INJM ;;"; ~ (This proof of service MUST BE FiLED WiTHIN TEN (10) DA YS AFTER filing the notice of appeal. Checli(/lpPi@>/e ~es) COMMONWEALTH OF iENNfVLVA7tA COUNTY OF Cf) 1'VI~.ttL ; as AFFIDAVIT: I hereby swear or affirm that I served ra-a copy of the Notice of Appeal, Common Pleas No, ~ , upon the District Justice design~ted therein on (date of servige) , D by personal service !31iYTcertified) (registered) mail, sender's rec~iqt attached hereto, and upon the appellee, (name) . , on --LL::: (t ,~ D by personal service Eihly (certified) (registered) mail, sender's receipt attached hereto, D and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appeilee(s) to whom the Rule was addressed on , 19__ D by personal service D by (certified) (registered) mail, sender's receipt attadled hereto, SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME F~,~ ~ _D (=y~ Signature of affiant C- \ rifle of official My commission 0Kpir€s on d-~ 1aCM ~__">,__T_"._'~~~ _ ~"~_W",___.'_'_ ,,' NC'\d,,'d Seal j' Patrice R. Bozzo, NotaiY Public Hampden Twp., Cumberland Gounty My Commission Ex~ Feb. 23, 200~ Member, PennsylvUl1ia As;~oclaMn oi Note.r:ss ... SENDER: -8 _Complete It8ms ,_ and/or 2 for additional services. "i -Complete iterHll"S, 4&, and 4b. . !!l .p'r1nt your name and address on the reverse of this forrn so that we can retum this I!! c8rdtoyou. .. _AUach this form to the front of the mailplece, or on the back 1f space cIoes not ~ '. .~~R8rum Rscslpt RequsstBcr on the maUpiece below the article number: :& _The Return Receipt will show to whom the article was delivered and the date c delivered. o ' ! 3. Article Addressed to: .'i. JhOrvlaS -r1bWff:~ fi So-talS ~Jfi-tIlv.s/~ If.pW Hjh$t CoYlrs~ VA-- ['7DB 4b. Service Type o Registered o Express Mail 0 Insured o Return Receipt for Merchandise 0 COD 7. Date of Delive; ~b 8. Addressee's Address (Only if requesfed and fee Is paid) I also wish to receive the following services (for an extra fee): Ii 1. 0 Addressee's Address t 2. 0 Restricted Delivery ~ Consult postmaster for fee. I 4e. Article Number 1\ II: c: i 01 c: 'i " .e " ~ ... c: l! .... r;;vCertlfied PS Form 3811, December 1994 102595-97-B.Q179 Domestic Return Receipt ~';-'''''~~~~W*:%?,,;;':IjW~~''1!'i~'l?'fj~!~I'~''!,'II' ,- ""'," .~!:"', ,,0, r_'1"'1"'""i;~,_""J" ,~, 1rij)~", ~T "'''l!5::_i~,.lr'=,] ,i!!t1l~m:~'1fttN,,,,,",,,,,,,,,:;:.;"#l:~'Ii'e,,_~~!!i:l!,,.Jt!,,,y,~~tt~'ffi',,-,jl~~~!1~ = ""'..~ 1~1~ P-~ N~~" ';)...d I <::e.c;\ \T. ~~( -V5- ~\0~J A, CS~1il1d ~ d ~~cld L, C.) ~ '.Jd .. . , "~i'~ In The Court of Common Pleas of ) i Cumberland County, Pennsylvania ) G'I.h\ -- V"No. Loop - '1'1 ,~ ~ 1~........ ) ) ) C\I":'l ~~~ ...... ~J OATH J We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constit~tio~ of this Common- wealth and that we will discharge the duties of our office wit A ~; :pz ,e Il AWARD We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed),m:!lke the following award: (No#e; If damages for delay are awarded, they shall be separately stated.) fi?J ~~ .:a-, d ~~:..;}~;.Q A('~_,1~;k. i~ ~~ ~1/'~;f- ,,~ ~ 1<, D~"'r :,ck,;~;,~,l,".df 1::~'~ ,~t ~4: J\~~""'~'1i<; rr)~.~\~.~ I,. ~__..l . . Arbitrator, dissents. (Insert name if applicable. ) Date of Hearing: '7...\ ~ ::>r:i) I Date of Award: 20 ~ 2-\:i\) l NOTICE OF ENTRY OF AWARD -u- d OI- QI b~1 ~ Now, the.J.e. - ay U~-' award was entered upon the docket parties or their attorneys. , '41;26tJ I, at d.:..LL, Lm.., the above and notice thereof given by mail to the Arbitrators' compensation to be paid upon appeal: $ ;No.vv ~ /2. i':!::f" ~. (~ ) pro~honotary By: Q. ~ Deputy . .~!'!~'iH~~J;MiWll~Jii'Ml1j\,)!~\Rff~k;'\~~~'l-kit;-;"0i;J,~~l>'" :<~tlal:l,.t." ~ , - ".- ., :"'~' "'. ,~o~ ,,_ (],. /" .70, 0 ( Y' ~ ..>",.",,, "'" '- ~,"-"'''-~ ,'-". ""., --'--I--~;'-. ,,~ <~ --"---'-"IIIIiJL c. '''<--'N' 'L-__=-"-~ n~~ ~'~~~ () s::: ",'= ,-;:L?' -;,.'!- 3:?J-': V),> r::"':';" :~- ~_.! - (";t ". ~t ::~ "ry ."-,,' t\"', '::.:' r" _ ~r-'-. ..J_":.'~~::' "~b .' -"0' <...., ---{ -', r:,:) "-, L A""deS - 2-5- I~ '10 5b 3- hO...,<\. ~v'e&.\..,,' ~ ZJ>-~t/- >?rJ6 -r:. ~a('~_ /71-'f'?'-(Cf35"' .3 - - .,. 14.1- S:t' tLr l<kil. P "- ~3o IV~ , ,~ ",. -, ,,-~,~ ,~ Mf, j, ..i... -.<-. '~...;': t . , MARLIN R. NEGLEY AND CECIL J. NEGLEY, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-7713 CIVIL TERM v. EDWARD A. WINGFIELD AND BRENDA L. WINGFIELD, Defendants : CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please enter judgment in the above-captioned proceeding in favor of Marlin R. Negley and Cecil 1. Negley, Plaintiffs, and against Defendants, Edward A. Wingfield and Brenda L. Wingfield, in the amount of Twelve Thousand Thirty-Six and 00/100 Dollars ($12,036.00) which includes pre- judgment interest, pursuant to the Arbitrators' Award which is attached as Exhibit "A". Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Date: By: ~~- Thomas E. Flower, Esquire Supreme Court ill #83993 2109 Market Street Camp Hill! P A 17011 (717) 737-3405 Attorney for Plaintiffs 1 ~1Ml__ ~ --~.~" --1f:M&b:i\W!!Uh~~;,tr,""Jl~i-!t~~<~-> "-:::-- H __ -. ~~ -~ -~- <.' ~--l:ljiliUji.tiitilli!iillir:tiboiU ~, . .If&.-I 0 (=> C ~ ~:~- ~ ~ -ot;._~ ,- rnr--: -,,-~ ~ Z:--.:-_ ~~~~ I ~ 0~ Cv ~ ~C: .-D ~ ~8 ~ ~ ~ Pc:: c- :c.; ~ ~ ~ " ~ ~ ,,""" ~ ~-<~ -," " '"I ( . , ,"- .-.- .--~ I~" ~, ,..J" " - <'I: .. . " ) ) 2 ) ) Gd~~d (~, ~~~~~)d ~ d ; ~~~~ L. Wl~ ..:lcl l~i'l--\ P-~ N~(\" 1 C'~~\ 0. ~~~ -\1.5- ~d In The Court of Cornmon Pleas of Cumberland County, Pennsylvania ~o. 2000 _ "P?)"l, GJaI. l~'-<-, r,~ 'J '--I. v... I~-h~ ~ L~ OATH We do solemnly syear (or affirm) that we will supnott, obev and defend the Constitution of the United States and the Consti~tio~ of this Common- wealth and that we will discharge the duties of our office wit, fidelity. ~~ ~.ql? AWARD We, the undersigned arbitrators, having been duly appointed and syorn (or affirmed), make the following award: (Note: If damages for delay are ayarqed, they shall be separately stated.) , rh,l 41~ r~}i J~ ~ ~ ~~CJ- ~w, ~('.~ d~~ "~;0~~~1~n ;.;:~:~~? C~+t ~t l~ ~ e. ~~~;t- , r vrW...to..:j-: . Arbitrator, dissents. if applicable. ) Date of Hearing: '2<., ~I :::>lJ) I Date of Award: 20 ~ 2\J\) l f,1It. . e, NOTICE OF ENTRY OF AWARD Now, the ;2~'!!' day of [~ award was entered upon the docket parties or their attorneys. , JtI;26() I, at :J: /I , .e..m., the above and notice thereof given by mail to the Arbitrators' compensation to be paid upon appeal: $ ,;)<;0, U/J ~ /2. J? ~/'- 0<-' /) Pt"othonotary BY:~~O,~ Deputy Exhibit "A" I "'<I"~ljl4oi'l" - o c Z- -oci. rr""l,-----"" -7~-' .c..--...' -7\-- tG;~- i~ ~G rc :;.2;: :<: (=1 ~ " ~-, 'to , u:.. r .r::-' ,~".....:; ~ ->; ,,..' r j 01. ,J '~ ~ l f MARLIN R NEGLEY AND CECIL J. NEGLEY, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-7713 CIVIL TERM v. EDWARD A. WINGFIELD AND BRENDA L. WINGFIELD, Defendants : CIVIL ACTION - LAW NOTICE OF JUDGMENT TO: Edward A. Wingfield and Brenda L. Wingfield, Defendants You are hereby notified that on~ .3 entered against you in the above captio c e: , 2001 the following judgment has been Judgment in favor of Marlin R Negley and Cecil 1. Negley, Plaintiffs, and against Defendants, Edward A. Wingfield and Brenda L. Wingfield, in the amount of Twelve Thousand Thirty-Six and 00/100 Dollars ($12,036.00) which includes pre-judgment interest, pursuant to the Arbitrators' Award which is attached as Exhibit "A". Dated: 7/.3/0/ /5/ ~, ~_~ Prothonotary . I hereby certify that the proper person/entity to receive this notice under Pa. RC.P. 236 is: Brenda L. Wingfield 1466 Center Road Newville, PA 17241 Edward A. Wingfield 130 North Hanover Street, Apt. #4 Carlisle, P A 17013 Peter 1. Russo, Esquire 5010 East Trindle Road Suite 200 Mechanicsburg, P A 17055 1 .............~ ~__ ,.,0 1-, '.'_: l_u_ J, ~-- _-1__,,_, "'~, r::--- '.7.11,.,., ~ . A Edward A. Wingfield and Brenda L. Wingfield, Defendants Por este medio se Ie esta notificando que el _ de del 2001, el/la siguiente (Orden), (Decreto), (Fallo), ha sido anotado en contra suya en el caso mencionado en el epigrafe. FECHA: Protonotario Certifico que la siguiente direccion as la del defendido/a segun indicada en el certificadu de residencia: Brenda L. Wingfield 1466 Center Road Newville, P A 17241 Edward A. Wingfield 130 North Hanover Street, Apt. #4 Carlisle, P A 17013 Peter 1. Russo, Esquire 5010 East Trindle Road Suite 200 Mechanicsburg,PA 17055 Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY Date: By:~Erj_. ^ Thomas E. Flower, ES~ Supreme Court ill #83993 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiffs 2 " ~- "'-" .." J~ . 1\ .. I~;',,", k~ N~f1" ( <::'_<=-C;\ 0. e~(1'( -V$- :>....d GduJ~ d r~, kA~~~~)d, ~k,... dd L, CJ,~ oJ d .::.... We do solemnly swear (or affirm) the Constitution of the United States wealth and that we will discharge the ) ) 2 ) ) d ; ~ "Ii i , ~."-" In The Court of Common Pleas of Cumberland County, Pennsylvania :-l0.2000 -1-[0"/ \ ~ G~~ ~J"<4 Cv':'l & ~~V1 ~ L~; OATH that we will support, obey and defend and the Constit~tio~ of this Common- duties of our office 'Ni2Qidelitv. ~.q I?~' ~\ AWARD We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awar~ed, they shall be separately stated.) , fn,) ~~}; ~h -<.n ~ ~~:..~ ~liw" A{'~ d~fs G~ :~~~:i~O ;~~::~~ C~'~ ,.t i~ -w,'e. ~~~i- , r ritf'..to...,t- if . Arbitrator, dissents. applicable. ) Date of Hearing: 7..., ~1 ::>lJ) I Date of Award: 20 ~ 2..0\) \ NOTICE OF ENTRY OF AWARD f',flt. . C, Now, the;U"ff' day of O;f<? award was entered upon the docket parties or their attorneys. , }fj,26rJ i, at ~, i!....m., the above and notice thereof given by mail to the Arbitrators' compensation to be paid upon appeal: $ .:l<lo, LV 0.u..riA I? /? ':!:!)r- VI-' c-) Prothonotary By: )H<<- O. ~ Deputy Ex/libit "A" <"",",,~, "~-"'-'" , ' _-I; ....!...' ; " -h';." I I"C. PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENTS) P.R.C.P SECTION 101 TO SECTION 149 ETC. MARLIN R. NEGLEY AND CECIL 1. NEGLEY, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : WRIT NO. 2000-7713 : No. 2000-7713 vs. EDWARD A. WINGFIELD AND BRENDA L. WINGFIELD, Defendants : Amount due: $12,036.00 : Interest from : Atty's Com. : Costs To the Prothonotary of said Court: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER, (I) Directed to the Sheriff of Cumberland County, Pennsylvania; (2) against Edward A. Wingfield, 130 North Hanover Street, Apt. #4, Carlisle, Pennsylvania 17013 and Brenda L. Wingfield, 1466 Center Road, Newville, Pennsylvania 17241, Defendants; (3) and against N/A , Garnishee(s); (4) and index this writ (a) against Edward A. Wingfield, 130 North Hanover Street, Apt. #4, Carlisle, Pennsylvania 17013 and Brenda L. Wingfield, 1466 Center Road, Newville, Pennsylvania 17241, Defendants; (b) against N/A , Garnishee(s), as a lis pendens against the following personal property of the defendant( s) as follows: That certain 1985 Ritz Craft mobile home, VIN 0104855963, located at 145 Amy Drive, Carlisle, Cumberland County, Pennsylvania. Title to said vehicle is attached hereto as Exhibit "A". (5) Exemption has (not) been waived. Dated: SAIDIS, SHUFF, FLOWER & LINDSAY B~~ Thomas E. Flower, Esquire Supreme Court ill #83993 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 Attorney for Plaintiff ;.'~ . l J .. , ,.....--"..~~,--' &:<Wi.'1E:h&8!itJiliiliiJ_-""" . """'R',,,c".-;8;:i;;'- UIMi1!III'1t! ~ I.tlt.& , e ~ p ~ Pp ~ ~~ ~~ A ~ ~~ ~ ~ ~ ~ ~ ~ ~~:~ ~ ~ \.. ~. ' ..,~ .~ "" ...~.~"" o ~~ ::-:",,::"i ~~. ",X;;C. s:~2 2:= =< ''''--- . - -~ .~ .~ o ~~~,; G"::, m ,.., " ~ :~:,;T, ~~ ~~ ___HtJ. o i-' to i-' to I\.) (J1 (J1 I .~ "~~" ~ ~." ~ I .-b_ " o ~ -oC: ~~J~, Zr.-- C1]), ~~(~,. ?~;-...:: PC 2~ ~ ~ ~-' \.-- r"'~ I (...,.:, '~k '-"'J"~,,- ,.. \ ,p ~-~"! - > '" - :.' I. ' ,~, '0_ '~ ,J~,~/",_. '>,,,,~.,-,'L. . ~ _, - ,_ ,-0 ,~_I -, MARLIN R. NEGLEY and CECIL J. NEGLEY Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 7713 EDWARD A. WINGFIELD and BRENDA L. WINGFIELD CIVIL ACTION - LAW Defendants PRAECIPE TO MARK JUDGMENT SATISFIED To the Prothonotary: Kindly mark the judgment in the above-captioned matter satisfied of record upon payment of your costs only. Dated: <O/gf) /0 f ! I ~~ Thomas E. Flower, Attorney for Plaintiffs Supreme Court ID #83993 2109 Market Street Camp Hill, PA 17011 (717) 737-3405 ~~~. _,I ,-,. . --"-I"':''''''',~~I ,i~-,;~-;~ " 0 cc, c) "~ ~ n'h "'" ".-, Vl.-'., ~ n-lrr", Z~':' ZC-' C;.J cr)"F~ -< ' .....c_ r-.-- , ~""'j )",", ~C,:- ~~. ~, '. ,"~ , 2: s.)- ,.-, ~ -- -< <:)'1 -<. u - -~ "'lilhilr{t.~'n~,[;':o R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff s Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Gainishee Advance Costs: Sheriff s Costs: 150.00 84.81 65.19 18.00 1. 66 .50 1.00 13.65 Refunded to Atty on 7/15/02 30.00 20.00 84.81 Sworn and Subscribed to before me So Answers; ~~1~~~ R. Thomas Kline, Sheriff j ByCJ Qlltf'l~~41 g \ this 6'i!" day of ~ 2002A.D.g"", () ')u,Pp'J,~. , pr thonotary . v;' ,t............. .~~ ,~~. \"),;,,=,, .~ V\ l{.~!,l/':~,t:,~ 3d ,'-"-, " "~~ (i':?J '::,::::' ..~~ r,~ :.--:::;...- .;,"',~ "'@ In. \\J 6n t," S' 111\\ ..', 'jJi-oKlW ~~ i,;';:p);i~,l-Jl:lI!l ,\:C' >~-J D ~'1 ~b~ ~):z. ~~llil~,~.~Ij,_!tdi!;ill~ilIMlil~iW8ii-)Q;",",$JI;k!2;"~:-,~~";,"'jj;~'\Ii!@;!!;jjjt~~"-'I""""'"~ ~"~ .'~-"""I!ijl~ ,- m,_ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-7713 CIVIL~ CIVIL ACTION, LAW TO THE SHERIFF OF __Cumberlan~_,____COUNTY To satisfy fhe debt, interest and costs due n!1J;lr..JJ.1L R. Neqlev and Cecil J. Negley _PLAINTIFF(S) from __,Edward A. Wingfield and Brenda L. Wingfield 130 N. Hanover St. Apt. #4 CarlisJe. p~ 17n11 1466 Center Rd. Newville, PA 17241 DEFENDANT(S) That certain 1985 Drive, CarliSle. Cumberland County, Pennsylvania. Ritz Craft mobile home, VIN 0104855963, Title You are directed to levy upon the property ot the delendant(s) and to sell located at 145 Amy (1) to said vehicle is attached hereto as Exhibit "AI'. (2) You are also directed to attach the property ot the detendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notffy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property ofthe defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as agarnishee and is enjoined as above stated, Amount Due Interest Atty's Comm AttyPaid ,__~41.50 $12,036.00 LL. $.50 $1.00 Due Prothy Other Costs % Plainliff Paid Date: July S. 2001 Curtis R. Long Prothonotary, Civil Division by: *tt;"'a. F~. W Name REQUESTING PARTY Saidis, Shuff, Flower & Lindsay Thoma~ E Fl.ower-..-Esq....-__ Deputy Address: 2109 Market St. rAmp Hi11, PA 17011 Attorney for: Plaintiff Telephone: (7171 737-3405 Supreme Court 10 No. 83993