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HomeMy WebLinkAbout07-1713r Turo Law Offices, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. No. 41473 CIVIL TERM Marcy Goshorn, Defendant : 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 of 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 32 Bedford Street Carlisle, PA 17013 (717) 249-3166 1 COMPLAINT 1. The Plaintiff is Turo Law Offices, a Pennsylvania sole proprietorship doing business as a law firm located at 28 S. Pitt Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. The Defendant is Marcy Goshorn, an adult individual who resides at 7561 Waterfall Road, P.O. Box 389, Hustontown, Fulton County, Pennsylvania, 17229. 3. On or about September 15, 2004 Ms. Goshorn contracted with Turo Law Offices to perform services related to child support, custody and divorce proceedings. 4. The Plaintiff, through licensed attorney Galen R. Waltz, Esquire performed the services for the Defendant and billed the Defendant based on the law firm's standard hourly rates. 5. The Plaintiff allowed the Defendant to make regular ongoing payments on the outstanding invoice even though the Defendant never was able to pay the bill in full even though the services were requested, performed and necessary. 6. In December 2006 the Defendant advised the Plaintiff that the Defendant's parents had secured the services of another attorney to proceed in her legal matters and the Plaintiff was discharged from further services. 7. The Plaintiff attempted, on several occasions, to resolve the outstanding legal invoice but after numerous attempts Defendant failed to respond. Turo Law Offices, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. No.01 -17/3 CIVIL TERM Marcy Goshorn, Defendant : CIVIL ACTION - LAW 8. The Plaintiff has made written demand on Defendant for payment of the outstanding bill but this demand has been ignored and the outstanding bill due to the Plaintiff by the Defendant is $15, 068.00. WHEREFORE, the Plaintiff, Turo Law Offices, requests this Honorable Court to find in it's favor and order the Defendant to pay the sum of $15, 068.00 plus interest from date of award and the costs of suit to the Plaintiff. }7 Date , 7ec tful ly submitte Turo Law Offices 28 S. Pitt Street Carlisle, PA 17013 717-245-9688 -140 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. §4904 relating to unsworn falsification to authorities. Date Ron Turo N fL 0 n r_ . Tiil J t== 0 -Ti jT f c: iTTI ??f TURO LAW OFFICES COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION vs. MARCY J. GOSHORN CUMBERLAND COUNTY Defendant CASE NO. 07-1713 SUGGESTION OF BANKRUPTCY COMES NOW the Defendant, Marcy J. Goshom, through her undersigned attorney, and would show the Court: She has filed a petition for relief under Title 11, United States Code, in the United States Bankruptcy Court for the Middle District of Pennsylvania, which bears the case number 1:07-bk- 01149. 2. Relief was ordered on April 16, 2007. 3. This action is founded on a claim from which a discharge would be a release or that seeks to impose a charge on the property of the estate. 4. This is for informational purposes only, and does not constitute a notice of appearance by the undersigned. WHEREFORE, the defendant suggests that this action has been stayed by the operation of 11 U.S.C. § 362. D. Lloyd Reichard, 1107324 Attorney for Defendant IT IS HEREBY CERTIFIED that a copy of the foregoing Suggestion of Bankruptcy was delivered by mail to Turo Law Offices, 28 S. Pitt Street, Carlisle PA 17013 this 17`x' day of A ril 2007. t Lloyd Reichard, II 07324 Attorney for Defendant Software Copyright (c) 1996-2004 Best Case Solutions, Inc. - Evanston, IL - (800) 492-9037 Best Case Bankruptcy LEI ?F ? 2T7 - 7 ?.. - Fn 6m Q Q SHERIFF'S RETURN - OUT OF COUNTY .... -1% CASE NO: 2007-01713 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TURO LAW OFFICES VS GOSHORN MARCY 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: GOSHORN MARCY but was unable to locate Her deputized the sheriff of FULTON in his bailiwick. He therefore serve the within COMPLAINT & NOTICE County, Pennsylvania, to On April 5th , 2007 , this office was in receipt of the attached return from FULTON Sheriff's Costs: So answer Docketing 18.00 Out of County 9.00 Surcharge 10.00 Thomas Kli Dep Fulton County 25.00 Sheriff of Cumberland County Postage 1.74 63 . 74 .yl ?31o7 t 04/05/2007 TURO LAW OFFICES Sworn and subscribe to before me this day of A. D. -In The Court of Common Pleas of Cumberland County, Pennsylvania Turo Law Offices VS. Marcy Goshorn No. 07-1713 civil Now, March 29, 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Fulton County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Please mail return of service to Cumberland County Sheriff. Thank you. Affidavit of Service Now, within upon at by handing to a and made known to So answers, the contents thereof. Sheriff of Sworn and subscribed before me this day of , 20 copy of the original COSTS SERVICE _ MILEAGE _ AFFIDAVIT 20 , at o'clock M. served the County, PA FULTON COUNTY SHERIFF'S OFFICE 207 NORTH SECOND STREET, McCONNELLSBURG, PA 17233 (717) 485-4221 SHERIFF SERVICE PROCESS RECEIPT AND AFFIDAVIT OF RETURN 1. PLAINTIFF/S/ 2. COURT NUMBER #07-1713 Civil Turo Law Offices Cumberland County 3. DEFENDANT/S/ SERVE 0 AT 7. INDICATE UNUSUAL 4. TYPE OF WRIT OR COMPLAINT: Marcy Goshorn I Notice/Complaint Civil 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD Marcv Goshorn 6. ADDRESS (Street, or RFD, Apartment No., Boro., Twp., State and Zip Code) OTHER 7561 Waterfall Road, Hustontown, Pa. 17229 RFRVIC:F- M COMMON. OF PA M DEPUTIZE Now, 1, SHERIFF OF FULTON COUNTY, PA, do hereby deputize the Sheriff of County to execute this Writ and make return thereof according to law. This deputation being made at the request and risk of the plantiff. SHERIFF OF FULTON COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Service deputized by Cumberland County Sheriff R. Thomas Kline. NOTICE COMPLAINT VERIFICATION - Ron Turo 4 Pages in all.. (LEO) 9. SIGNATURE of ATTORNEY or other ORIGINATOR Ron TuroEsq. (Thomas Kline Cumberland County Sherifjg 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS 10. TELEPHONE NUMBER 11. DATE March 30, 2007 area must me completed if notice is to be mailed) One Courthouse Square, Carlisle, Pa. 17013 13. 1 acknowledge receipt of the writ NAME of authorized FCSD Deputy of Clerk and Title 14. Date Received 15. Expiration/Hearing Date or complaint as indicated above. Nancy Drew Suders , Deputy March 30, 2007 16. 1 hereby CERTIFY and RETURN that 1 ® have personally served,0 have legal evidence of service as shown in "Remarks", ? have executed as shown in "Remarks", the writ or complaint that described on the individual, company, corporation, etc., at the address shown above or on the individual, company, corporation, etc., at the address inserted below by handling a TRUE and ATTESTED COPY thereof. 17. rl I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., named above. (See remarks below) 18. Name and title of individual served (if not shown above) I 19. A person of suitable age and discretion then residing in the defendant's usual place of abode. E3 20. Address of where served (complete only if different than shown above) (Street or RFD, Apartment No., City, 21. Date or Service 22. Time ED AM Boro, Twp., State and Zip Code) ® PM EST 719 Lincoln Way East, McConnellsburg PA 17233 April 02, 2007 5:25 ® EDST 23. ATTEMPTS Date Miles Dep. Int. Date Miles Dep. Int. Date Miles Dep. Int. Date Miles Dep. Int. Date Miles Dep. Int. 1 1 04-02-07 2.1 LEO Advance. 25. Service Costs 26. Notary Cert. 27. Mileage 28. Postage 29. Surcharge 30. Total Costs 31. COST DUE OR REFUND $ 75.00 $ 18.00 $ 5.00 $ 1.00 $1.00 $25.00 REFUND - $50.00 32. REMARKS The Cumberland County Notice / Complaint in Civil Action No. 07-1713 for Marcy Goshorn was handed to her while standing in the parking lot of the Main Moon Chinese Restaurant, 719 Lincoln Way East, McConnellsburg. 33. AFFIRMED and subscribed to before me this 3RD. S NSWE 34. day f , ril, 200 ?sls a of Larry E. Ott Date 4/3/2007 "Ap 37. 114 . j' 8, signature of 39. Date Prothono ary eputy otary ublic SHERIFF OF FULTON COUNTY MY COMMISSION E PI January 1 )2010 40. 1 ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE 41. Date Received OF AUTHORIZED ISSUING AUTHORITY AND TITLE. Aaril 03 200'