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KATHRYN E. McCLANEN,
PLAINTIFF
V.
GREG MYERS and
ADAM RHOADES, et al.,
DEFENDANTS
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
99-3169 CIVIL TERM
CIVIL ACTION - LAW
NOTICE TO DEFEND
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, order and
notice are served, by entering a written appearance personally or by attorney and tiling in writing
with the court your defenses or objections to the claims set forth against you. You are warned
that if you fail to do so the case may proceed without you and a judgment may be entered against
you by the court without further notice for any money claimed in the complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249- 3166
1-800-990-9108
ANU.RICANS WITH DISA1111 I778S
ACT OF 1990
The Coup of Common Pleas of Cumberland County is required by lain to comply with the Americans with
Disabilities Act of 1990. For inlivmation about accessible facilities and reasonable accommodations available to
disabled individuals having business before the coin, please contact our otlice. All mrangentents must be made at
least 72 hours prior to any hearing or business before the coml. You mutt attend the scheduled conference or
heating.
KATHRYN E. McCLANEN,
PLAINTIFF
V.
GREG MYERS and
ADAM RHOADES, et al.,
DEFENDANTS
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
99-3169 CIVIL TERM
CIVIL ACTION - LAW
ANSWER TO COMPLAINT WITH NEW MATTER
AND COUNTERCLAIM
AND NOW, this day of , 1999, comes the defendant, Adam Rhoades, by
his attorneys, Irwin, McKnight & Hughes, and makes the following Answer to Complaint with
New Matter and Counterclaim of the plaintiff; Kathryn E. McClanen:
ANSWER TO COMPLAINT
The averments of fact contained in the first (1) unnumbered paragraph of the Complaint
regarding the plaintiffs address is admitted.
1)
The averments of fact contained in the second (2) unnumbered paragraph of the
Complaint regarding the statement that Adam Rhoades is a defendant is admitted.
3.
The averments of fact contained in the third (3) unnumbered paragraph of the Complaint
are specifically denied. On the contrary, the detcndant, Adam Rhoades, had completed working
a night shift and was sleeping during the day of October 16, 1998. At no time did he shoot a BB
gun or a pellet gun on that date.
4.
The averments of fact contained in the fourth (4) unnumbered paragraph of the Complaint
are specifically denied. On the contrary, the defendant, Adam Rhoades, was asleep during the
day of October 16, 1998, and did not shoot a gun of any kind. lie did not and could not have
shot the plaintiffs cat.
5.
The averments of fact contained in the fifth (5) unnumbered paragraph of the Complaint
are within the sole knowledge of the plaintiff. Proof of the bills for the cat is hereby demanded
and the paragraph is denied.
WHEREFORE, the defendant, Adam Rhoades, hereby requests that the Complaint of
the plaintiff, Kathryn E. McClanen, be dismissed with costs to the defendant, legal fees, and
damages as set forth below.
NEW MATTER 7'0 THE
PLAINTIFF'S COMPLAINT
6.
The averments of fact set forth in the Answer of the defendant, Adam Rhoades, in
paragraphs one (1) through five (5) is hereby incorporated by reference and made a part of this
New Matter.
7.
The defendant, Adam Rhoades, after working through the night at his job returned home
on October 16, 1998, and went straight to bed.
8.
The defendant, Adam Rhoades, woke up at approximately 8:30 p.m. on October 16,
1998, and learned that the cat of Kathryn E. McClanen had been shot by someone earlier that
day.
9.
At no time on October 16, 1998, did the defendant, Adam Rhoades, shoot any BB gun or
pellet gun nor did he see the plaintiffs cat since he was sleeping following the night shift he had
completed.
10.
On the evening of October 16, 1998, or the following day, the plaintiff, Kathryn E.
McClanen, called the home of Adam Rhoades and stated that she knew that Adam Rhoades
did not shoot her cat.
WHEREFORE, the defendant, Adam Rhoades, seeks judgment against the plaintiff,
Kathy E. McClanen, with the costs of this suit and damages as set forth below.
COUNTERCLAIM
ADAM RHOADES V. KATHRYN E. McCLANEN
ABUSE OF PROCESS
AND NOW, this I day of u? 1999, comes Adam Rhoades by his
attorneys, Irwin, McKnight & Hughes, and makes the following Counterclaim for Abuse of
Process against the plaintiff, Kathryn E. McClanen:
The averments of fact contained in the defendant's Answer to the Complaint and the New
Matter in paragraph one (1) through ten (10) are hereby incorporated by reference and are made a
part of this Counterclaim.
12.
The plaintiff, Kathryn E. McClanen, knew or should have known that defendant, Adam
Rhoades, was unable to have shot her cat with a pellet gun.
4
13.
Her act of blaming Adam Rhoades for killing her cat and naming him as a defendant in
this case was an abuse of process, causing the defendant, Adam Rhoades, loss of time,
inconvenience and legal fees.
14.
The defendant, Adam Rhoades, seeks reasonable legal fees for the defense of this action.
WHEREFORE, defendant, Adam Rhoades, requests that the Complaint against him be
dismissed with the award of reasonable legal tees and costs to defendant.
Respectfully submitted,
IRWIN, Me 'IGHT HUGHES
By:
Marcu A. McKnig t, 11, Esquire
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Supreme Court I.D. No. 25476
Attorney for the defendant,
Adam Rhoades
Date: July 7, 1999
5
VERIFICATION
The foregoing Answer to Complaint with New Matter and Counterclaim is based
upon information which has been gathered by counsel and myself in the preparation of
this action. I have read the statements made in this document and they are true and
correct to the best of my knowledge, information and belief. I understand that false
statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904,
relating to unswom falsification to authorities.
l1-n
ADAM RHOADES
Date. ?`f , 1999
KATHRYN E. McCLANEN,
PLAINTIFF
V.
GREG MYERS and
: IN THE. COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
99-3169 CIVIL TERM
ADAM RHOADES, et al., CIVIL ACTION - LAW
DEFENDANTS
CERTIFICATE OF SERVICE
1, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Answer To
Complaint with New Matter and Counterclaim was served upon the following by depositing a
true and correct copy of the same in the United States mail, First Class, postage prepaid in
Carlisle, PA, on the date referenced below and addressed as follows:
Ms. Kathryn E. McClanen
41 Chestnut Avenue
Carlisle, PA 17013
By:
IRWIN, McKNIGHT & HUGHES
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
1Sunreme Court I.D. No. 25476
Date: July 8, 1999
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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 Answer is 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 Answer or for any other claim or relief requested
by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166
Suae• 1999
Frances H. Del Duca
10 West High St.
Carlisle, PA 17013
. •e+t,llf
Kathryn E. McClanen, Court of Common Pleas of Cumberland County, PA
Plaintiff
v.
99-3169 Civil Term
Greg Myers and Civil Action - Law
Adam Rhoades, at al.,
Defendants
Answer to Compaint with New Matter and Counterclaim
Now, this 24th day of July, 1999, comes the Plaintiff, Kathryn E. McClanen, and makes the
following Answer to Complaint with New Matter and Counterclaim.
Answer to Complaint:
1. Plaintiffs address is admitted.
2. Adam Rhoades is a defendant is admitted.
3. Denied. After reasonable investigation the party is without knowledge or information
sufficient to form a belief as to the truth of an averment.
4. Denied. After reasonable investigation the party is without knowledge or information
sufficient to form a belief as to the truth of an averment.
5. Denied. After reasonable investigation the party is without knowledge or information
sufficient to form a belief as to the truth of an averment.
New Matter to the Plaintiffs Complaint
6. Denied. After reasonable investigation the party is without knowledge or information
sufficient to form a belief as to the truth of an averment.
7. Denied. After reasonable investigation tho party is without knowledge or information
sufficient to forth a belief as to the truth of an averment.
6. Denied. After reasonable investigation the party is without knowledge or information
sufficient to form a belief as to the truth of an averment.
9. Denied. After reasonable investigation the party is without knowledge or information
sufficient to form a belief as to the truth of an averment.
10. Denied. After reasonable investigation the party is without knowledge or information
sufficient to form a belief as to the truth of an averment.
Counterclaim:
11. Denied. After reasonable investigation the party is without knowledge or information
sufficient to form a belief as to the truth of an averment.
7t . .
12. Denied. After reasonable investigation the party is without knowledge or information
sufficient to form a belief as to the truth of an averment.
13. Denied. After reasonable investigation the party is without knowledge or information
sufficient to form a belief as to the truth of an averment.
14. Denied. After reasonable investigation the party is without knowledge or information
sufficient to form a belief as to the truth of an averment.
Respectfully submitted,
V
Kathryn E. McClanen
41 Chestnut Avenue
Carlisle, PA 17013
(717) 249-6790
Plaintiff
July 24, 1999
I verify that the statements made in this affidavit are
true and correct. I understand that false statements herein
are made subject to the penalties of 10 Pa.C.S. Sec. 4904
relating to unsworn falsification to authorities.
Dated:
i`
?_a
1.7 ii)
L. - ^1iU
•e
In The Court of Common Pleas of
Cumberland County, Pennsylvania
NO. 99-3169 CIVIL TERM
AFFIDAVIT OF SERVICE
STATE OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
Kathryn E. McClanen, plaintiff, being duly sworn according to law, deposes and says
that she served a copy of the Complaint in the above matter on June 14, 1999, and that
document was received by the defendant on June 14, 1999, as evidenced by the receipt
attached hereto.
SUBSCRIBED and sworn n?to before
me this `A 4 day of.Lti?.Kd.,,1999
- NOTARIAL SEAL
SONDRA T. NECARLISLE LISLE CUMBERLAND COUNTY
.
MY COMMISSION E%PIRES NOVEMBER 15. 1999
IRWIN, McKNIGHT & HUGHES
ATTORNEYS AT LAW
60 West Pomfret Street
Carlisle, Pennsylvania 17013.3222
Phone: (717) 249.2353
RECEIVED FROM
FOR Lout?.sAm-Aaa
Amount of Acco .. $
Amount Paid .............
Balance Due .............
Cash ? Check M.O.
THANK
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3413
DATE JU Q- t -19 9'1
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CP.'aY. Kt& EALTN OF PENNSYLVANIA NOTICE OF APPEAL
COUNT OF COMMON PLEAS
FROM
JUDICIAL DISTRICT
Paula P. Correal DISTRICT JUSTICE JUDGMENT
09-2-01 Q
COMMON PLEAS No 3 1 10 9 /f;? TAN
NOTICE OF APPEAL L
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the
date and in the case mentioned below.
Adam Rhoades
40 West South Street
Carlisle
Paula P
05-10-99 McClanen, Kathryn E. vs _Greg Myers Od Adam Rhoades, et al.
CV 19 98-0000509 r?
IT 19
This block will be signed ONLY when this notation is required under Pa R.CPJP. No If t was CLAIMA J.P. No.
10088. rd?
This Notice of Appeal, when received by the District Justice, will operate as a 1 01(6) in action before ' trict Justice, he MUST
SUPERSEDEAS to the judgment for possession in this case
FILE A within twenty (20) days after
Signature of Prothonotary or Deputy 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 appellant 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).
PRAECIPE: To Prothonotary
Enter rule upon Kathryn E. McClanen
r, /? Name of assoelAWsl
(Common Pleas No Q 9' 3) I?q LEI o ww) within twenty (20) days after servic"
RULEt To Kathryn E. McClanen appellee(s).
Name of arpelAWs)
(1) You are ratified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days offer the date of
service of this rule upon you by personal service or by certified or registered mail
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU.
(3) The dale of service of this rule if service was by mail is the date of moiling.
Date:
.??. ?tCb1aJ-?
smr.e roar rry oaouy
"0P0"'-W COURT FILE TO BE FILED WITH PROTHONOTARY
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF : as
AFFIDAVIT: I hereby swear or affirm that I served
? a copy of the Notice of Appeal, Common Pleas No. - , upon the District Justice designated therein on
(date of service) , ? by personal service ? by (certified) (registered) mail, sender's
receipt attached hereto, and upon the appellee, (name) _ on
19- ? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto.
? 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 ? by (certified) (registered)
mail, sender's receipt attached hereto
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS _ DAY OF . . 19-
Signature of alriant
siennturo of Ofbt.ml Irnforo whom rdf,a., I
TWO Of 016Pl
My oommias,cn rfpur.s 19-_.
Y
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,
1 COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
Mag. 0151. No.:
09-2-01
DJ Name: Hon.
PAULA P. CORREAL
Aadroes: EAST WING - COURTHOUSE
1 COURTHOUSE SQUARE
CARLISLE, PA
Tolephone:017) 240-6564 17013-0000
ADAM RHOADES
40 W SOUTH ST
CARLISLE, PA 17013
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: CIVIL CASE
NAME and ADDRESS
rMCCLANEN, KATHRYN E r
41 CHESTNUT AVE
CARLISLE, PA 17013
DEFENDANT: vs. J
NAME and ADDRESS
rMYERS, GREG, ET AL. 1
36 W POMFRET ST
CARLISLE, PA 17013
L J
DocketNo.: CV-0000509-98
Date Filed: 10/29/98 _
THIS IS TO NOTIFY YOU THAT:
Judgment: _LrEF}-1T-TL LnMaMFNT yr ME
X? Judgment was entered for: (Name)-. _MC r.Ab= xnmuuviv r
0 Judgment was entered against: (Name) nunAnac AnAM
in the amount of $ 812 nF on:
Defendants are jointly and severally liable.
Damages will be assessed on:
F] This case dismissed without prejudice.
Amount of Judgment Subject to
Attachment/Act 5 of 1996 $
0 Levy is stayed for days or ? generally stayed.
F1 Objection to levy has been filed and hearing will be held:
Date: Place:
Time:
ANY PARTY HAS THE I
OF APPEAL WITH THE
MUST INCLUDE A COP
05-1U-99
GHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
R THRYXI.5RK'OFTHE/ COURTQFCOMMOWPLEAS, CIVIL DIVISION. YOU
OF THIS ICE OF JUDGMENT T
,?A4SCRIPT FO M WITH YOUR NOTICE OF APPEAL.
District Justice
I certify that this is a true and cor ct co y of
Date
(Date of Judgment) 511 n/qG
(Date & Time)
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
Total
Post Judgment Credits
Post Judgment Costs
S
Certified Judgment Total
proceedin s containing the judgment.
District Justice
My commission expires first Monday of January, 2000 SEAL
AOPC 315-99
?4)4 rt-(l E , ye ciaY)Z°(1 - 3 /'/ 9 U v? P (ter
?S
ec? N?e?s d ,gum P6? egos e?
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 Answer is 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 Answer or for any other claim or relief requested
by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17j13
717-249-3166
June 1999
Frances H. Del Duca
10 West High St.
Carlisle, PA 17013
Court of Common Pleas
Cumberland County
Kathryn E, McCianen
V
Greg Myers, Adam Rhoades
COMPLAINT
Plaintiff is Kathryn E, McCianen, 41 Chestnut Ave., Carlisle, PA 17013
Defendants are Greg Myers and Adam Rhoades.
On or about October 16, 1998, the defendants were shooting a BB gun at 40 W. South St.
The defendants shot plaintiffs cat.
Plaintiff incurred $722.88 in veterinarian bills for operation to save the pet.
The pellet remains in the shoulder of the cat.
Wherefore plaintiff requests judgment in the amount of $722.88 plus $109.18 for
costs totalling $632.06.
O,l ? 01?n
I verify that the statements made in this affidavit are
true and correct. I understand that false statements herein
are made subject to the penalties of 10 Pa.C.S. Sec. 4904
relating to unsworn falsification to authorities.
Dated:
?/l
OCT CARLISLE SMALL ANIMAL VETERINARY CLINIC
DRS. IBARNC-ETT,GF.EENWnLT,STROW HEID:C Kc.R -
c - FAGS: 1
25 ;'SHADY LANE
CARLISLE, PA. 17013
717-243-2717
A% Ela yne MaClanen
41 Cho utn ut Avanuc? CL IENT
IT .: °,j S
C, K
- ia: lo. VO
Pa. 170.13 INVOICE !15944
-------
PATIENT IN ------
3 ---------------------------------------------------
- --------------------------
SPECIES: FELINE COLOR: SRY
-------------------------
PATIENT N
AME:
BLUE
BREED: DOMESTIC SHORT HAIR MAP
Y
S: SEX: FEMALE(S)
...........
... .
.
-------------------------------------------------------- BIRTHDAY: 00-00
--------- ---------- ----
OI;T
19
9P2
OFFICE. VIS'17 --
OCT 19 90 X-RAY ! X 2 = 2
.
OCT
19
?0
X--RAY @ X 10 ADDITIONAL
VIEWS 0)
7
OCT
19
90 .
PRE OPERATION SEDATION 17.00
11CT 19 9El ANESTHESIA--ISOFLUORANE 0 00
J-
OCT 19 12 Ketamine. 100 mg ml 1r > m! 1 r>
_
9 55
C)
0
.
O
OCT
19
98 .
FRACTURE REPAIR
FELINE «
,
Otl
OCT
19
90 ,
APPLY CAST FELINE 207.00
OCT
19
98
E4elytl',1 ;1 i,7 20 m
l 00
40.
QcT
t19
9S .
HOSRITALI _ATION-FEL IME 3 0.00
OCT 19 TO INP'AT'IENT EXAM FEE: .0
i JC:I
19
a 2
Kr- tooro'f='n !Oomglm
l 20.00
OCT
19
98 .
0.1
IBaytri.l. No. 20 500 tabs 15.5 S.O(.)
14
50
I11.1 19 98 Ketamine 100 mg/ml 10 ml .
00
0
OCT Q 98 OFFICE VISIT-BRIEF .
O(CT
19
9CJ
Canine/Feline A/ D 16.50
OUT
14
?R
C:ommlete Blond Count (CPC) 0.93
20
00
UCY 19 90 Mini Health Profile
--------- .
22.00
-------------• -------------
PATIENT SUBTOTAL: ------------------------
1; 527.20
.INVOICE SUBTOTAL: j -527.28
TALES TAX., 0.0E
INVOICE TOTAL: 527.34
OCT 30 1990 CARLISLE SMAL-. ANIMAL.. VFTERTN,ARY CLINIC
DRS. 0APNET7,SR.EF.NWAL-T,STR0CK, HEIU!CC4MF
23 SHADY LANE
CARLISLE, PA. 1701!j
717-243-2717
K. El ayne McClanan
41 Chostnut Aven:.tc.
Carlisle, Pa. 17013
PATIENT ID: 3
PATIENT NAME: BLUE
----------------------°----------------
BODY WEIGHT SUMMARY:
Weight Range: 0.00 - 0.00 lbs.
REMINDERS: JUN 12 99
JUN 12 ?9
MAY 08 101
SPECIES: FELINE
BREED:
•-------- DOMESTI
--------- C SHORT HAIR
--
JUN 12
98 ---
7.50 -------
lbs.
MAY 07 98 7.25 lbs.
MAY 09 98 7.25 Ibs.
MAY 19 97 9,00 lbs.
MAY 07 96 8.50 lbs.
PAGE: 1
CLIENT 10: 5R3
INVOICE: 116427
WEIGHT: 7.50 lbs. SEX: FEMALEIS!
BIRTHDAY:
----------------------
OFFICE VISIT--BRIEF
FECAL EXAM INATTON-F-.OTATION
B. 0(,:)
Today's Dr...,-tor was Dr. Str-arl::.
Proc=sscd by Sandy. Thank yc:.;! 0.Q.)
------------------------------------------------
PATIFNT SUBTOTAL: 5 24. SC)
FELINE DIST. 'AC. W1 CHLAMYDIA
FELINE LEUKEMIA BOOSTER,
FELI4E RABIES 3 YEAR BOOSTER
-----------------
TOTAL TNVOICEg 24.5r.-)
----------- --
7E NT T^,FC E '- P 0T O CF 0 -0 f I77'L WT7H I V. FT rF M 9c:' EOTICM ;'.nD
T!1TEST1 N i.. "],=" " Oi`:.. I' T'...!_.. NE!,J -i Fn ; LI rAj S i i o i i .111,
NOV 12 199E CARLISLE St-IALL ANIMAL VETERINAF;Y CLINIC
DRS. BARNETT,GREENWAL.T,STROCK, HEIDECKER PAGE: 1
25 SHAD`f LANE
CARLISLE, Pig. 17013
717--243-271'7
K. Eliaryne McCl:in:an
41 Chestnut :^rleanLLL CLIENT ID: 523
Car-1>ele, Pa. 17013 INVOICE: 117031::
PATIENT 10: 3 SPECIES: FELINE HEIGHT: 7.50 lbs. SEX: FEMALE ISI
PATIENT NAME: BLUE BREED: DOMESTIC SHORT HAIR BIRTHDAY:
------------------------------------------------------------
---------------------------------- - ----------
BODY WEIGHT SUMMARY: JUN 12 98 7.50 its.
Height Range., 0.00 - 0.00 Its. MAY 09 98 7.25 its.
MAY 08 98 7.25 lbs.
MAY 19 97 8.00 lbs.
MAY 07 96 8.50 lb
X-RAY 10 X 12 ADDITIONAL VIEWS a 2O.00
-----------------------------------------------------------
PATIENT SUBTOTAL: 2 2O.00
Re check and re -:ay leg in 2 weeks
P.EMIl1DERS: JUN 12 99 FELINE DIST. VAC. W1 CHLANYDIA
JUN 12 99 FELINE LEUKEMIA BOOSTED
MAY 08 101 FELINE RABIES 3 YEAR BOOSTER
TOTAL INVOICE: $ 20 .00
BALANCE DUE: S 20 00
SEINTINEL THE C01•19INAI-ION OF FLE,^, ?Cl•11'l::'=!_ !•JITH I-1L=ARTWC'RM =RE'•rENTI'ON AND
INTESTINAL DPWORIIER IN CI•JE PILL.... t•JE!4....s" l: FOR DETAILS I I ! I I ? I 1 I I
FINANCE CHARGE applieJ tD ail acwu.nis unpaid after 30 Jays. FINANCE CHARGE Cvaputed by a pericdtc
rote of 1.50% per ebnth, which is the annual Jercentage rate cf 18.00% Minifu0 Char:e fl.00
T•JUV c':1 _ .`:?? ::iif?: L,.T::I-E: Ei T'1F,1_I •: (,: 1'i'!iil_ UG-T[: f`
DF:S. ?+Ai=:!•dE?°I-.?3ifiEE??i:•Jr", L.?".?31"I?CC};. iiEIpfEC!;13[;: _
nr CNrl l.r'r L. ry(•J E.
it^-?'43-"E2^17 .
P:. Ela, r)o i`JcClailr ii
41 Chess, t;tu L• Ftvv`rn.u= ID: !?23
Cat'-.lislu, Pi. t?!;t .13 T14V1].TCE: 11'??,?E3
PATIENT 10: 3
PATIE14T NAME: BLUE ----------------
SRECIES: FELINE HEIGHT: 7.50 15s.
SEX:
FEMALECS!
-------------------- BREED: DOMESTIC SHORT HAIR BIRTHDAY:
----------------------
Y WEIGHT SUMMARY: -----
JUN 12 99 7.50 lbs.
-°
-
Height Range: 0.00 - 0.00 lbs. MAY 09 98 7,25 lbs.
MAY 09 99 7.25 lbs.
MAY 19 97 B.00 lbs.
MAY 07 95 e. 413 1b.-
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REMINDERS: JUN 12 99 FE! NET. VAC. H! CHLANYDIA
JUN 12 99 FELINE LEUY,EMIA ?nnSTE,
MAY uB !0'. FELINE RA21E3 3 YEAR :nn=
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------ Pa. 1701211
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CARLISLE, PA . 1701
PAYMENT ON ACCOUNT
Elayno McCL wnw
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. CLIENT 1D: 522
Carlisle, Pa.
----_-----_----_-_----------- 17013
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PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Chock applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF-Cumbq and __ ; as
AFFIDAVIT: I hereby swear or affirm that I served
h5 a copy of the Notice of Appeal, Common Pleas No. 99_-3169 Civil Term upon the District Justice designated therein on
(date of service) May 26 1229 _ , U by personal service fx1 by (certified) (registered) mail, sender's
receipt attached hereto• and upon the, appellee, (name) ___ Kathryn E. McClanen , on
Mav 26 19_99__ 0 by personal service 9 by (certified) (registered) mail, sender's receipt attached hereto.
I and furlhor that I ervedlhe Rule to File a Cornp!aint accompanying the above Notice of Appeal upon the appellee(s) towhom
the Rule was addressed on Mav 25 -._ , 1999_• ? by ersonal ser e X] by (certified) (registered)
mail, sander's receipt attached hereto.
SWORN (AFFIRMED) AND SUBSORIBED BEFORE ME
THIS 271:h y . DAY OF _Ma-Y_--, 1919_._
v CL- aturo of affiant
Squidw" of oh,oa; 6'rlor® n'hv,; ofh,otatI na, nr
_--_-_--
Notarial Seal
na crnmi bw, Martha L. Noel, Notary Public
My 06itlsle13bro,CumbertertrlCounty-- '?1---
My Commission Expires Sept. 18, 1999
Merchrr, Penas.1^L-oi?. P. sc,- iron m n,+aries
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COMMONWEALTH OF PENNSYLVANIA NOTICE OF APPEAL
COURT Of COMMON PLEAS
FROM
JUDICIAL DISTRICT _
Paula P. Correal DISTRICT JUSTICE JUDGMENT
09-2-01. Q
COMMON PLEAS Na. Ci .f .. 3 I fo 9 r t,?
V
.4A^r /
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the
date and in the case mentioned below.
Adam T0t°adLs Paula P. Corneal
ADWESS Of AMT I uI,N TY 5TAIE Lp
40 Heat Soutj Street Casrli.ale PA 17013
WE Of N N THE CASE OF fftu Mr ILwe a-wl
05-10-99 RcClanen, Kathryn I. VS Grey Flyers a%fd Adam Rhoades, et al
T? ,?i 7G E-t7b F-R
Cv 1
LT 1'
9li-0000509
P
This bock will be signed ONLY when this notation is required under Pa R.CRJP. Na
10086
This Notice of Appeal, when received by the District Justice, will operate as a
SUPERSEDEAS to the judgment for possession in this case
If appeflant was CLAIMANT {see-Pa-R:C.P.J.P. No.
1001(6) in action before a trict Justice, he MUST
FILE A CCMPCA7NT within twenty (20) days after
filing his NOTICE of APPEAL.
a Deputy
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. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPEt To Prothonotary
Enter rule upon Kathryii E. McClanen
Nana of appe/bdsl
rr,, c ? r
(Common Pleas Na within twenty (20) days after service ofd or
RULEL To Kathryn E. hcClanon
Kane of Ar"Ibds) °PP? (s)•
to filp'"a complaint in this appeal
try of judgment of non pros.
ue "
! ap eW or his attorney a agent
(1) You are notified that a rule is hereby entered upon you to file a complaint 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 do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU.
(3) The dale of service of this rule if service was by mail is the date of mailing.
Dote ,19_1-1. <<l/ ( Ct
r.) swature d An ito eery aa0epury
AOK312ae COURT FILE
I
8
NEl
8
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Z 013 274 L185
US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
De net use for Intmmnllnnal Dan /Can mo -l
Sent to
DST JUST PAULA P CORREAL
sreet A PAm ew EAST WING COURTHO
1 COURTHOUSE SQUARE
Post Office, sate, 6 LP Code
CARLISLE PA 1701'
POM" g $ .33
Certlsed Fee R l , t.l p
Spa" Delivery Fee -
Restricted Delivery Fee
Return Reo* Shuwirp to
Whom 8 Date Deevered %
1 M1S
Fatal Rcept lihowry to Whom,
Do. i Adtiswe; Paden
TOTAL Postage 6 Foes X1
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CC
$
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p
1
Postmark or Date
MIRE
05-25-99
RHOADES APPEAL
SE
SENDER:
• Complete Heme .1 and/W
2 for otltlltionel services I also wish to receive the
a. a
.
Print yr name a, da extra f SOrYICeS (for an
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mB and eddr drBss 66 on the reVARB of IIIIB!•Jrm 60 that we can return this extra fee):
Ca
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e Wdte'Rolum Receipt Reeoeefod' on the mailpiece bolow, the amok number. 2.0 Restricted Oeuvey
e Tire Return Receipt will show to whom the article was d
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n
ame
and the dale
del"ted. Consult postmaster for fee.
g
a. AnlGle Addressed to: 4a. Artl(Ve Number
2 013 279 085
DIST JUST PAULA P CORREAL 4b. Service Typo
EAST WING - COURTHOUSE Q Registered M Candied
1 COURTHOUSE SQUARE ? Express Mail ? Insured
CARLISLE PA 17013 ? Return Receipt for Merchandise Q COD
7. Date of DDeellivey
.?
L
n
5. Received
Qy: eme)
v '
? 8. Addressee's Address (Only resi
(,Y qJ and fee is paid)
id. Signature: (A drdssogor/fjge
nt)
?
X
S PS Form 3841, December IM la eas-ae "I" Domestic RaLtm Rm i,,it
Z 013 279 086
i=
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US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
Do not use for International Mall t9na mvamal
Seta to
KATHRYN E McCLANEN
Street 6 Number
41 CHESTNUT AVE
Post Office, Stale, & LP Code
CARLISLE, PA 17013
Postage B $ , "!>3
Certified Fee % I L10
Special Delivery Fee
Restricted Delivery Fee
Return
RO a
Wham 8
DeWeramd
Itekxn Rerapt
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to yAgrn.
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Dale, 8 dessee Y Adders
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TOTAL Postage s Fees g $ , q 7>
Postmark or Dale
MIHH
05-25-99.
RHOADES APPEAL
SENDER: I also wish to receive the
• Complete items 1 anNor 2lor additional cervices.
•CompIota Items 3, 4a, and 4b. following services (for an
¦ Pnllt your name and address on the reverse 01 This form so that we can return this extra fee):
card 10 you
a Attach Ihla lorm to the front of the mallpiece, or on the back It space does not 1. Q Addressees Address
ppearms.
Rrceip Requested' on the e low the ertkW
number, 2. ? R¢sldclo
d Delivery
•
The
he dale
Return R
a The Realm eoelpl will show chow t to whom the 41tcl arteae Was e dollvere0 and the dale
delivered. Consult postmaster for fee.
3. Article Addressed to: 4a. Article Number
KATHRYN E McCLAREN Z 013 279 086
4b. Service Type
41 CHESTNUT. AVE
.
CARLISLE PA 17013 O Registered M Certified
0 Express Mail 0 Insured
0 Return Rdceipt for Merchandise 0 COD
7. Date of Delivery
5. Received By; (Pnnf Name) 6. Addressea's Address (Only d requested 4E
And toe is paid)
8. Si al _ r w ..
9 PS Form 3811, December 1994 I IWIA 9e Bona