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HomeMy WebLinkAbout99-03998 (2)a ?: ? : IN TI IE COURT OF COMMON PLEAS EVELYN KNULL, : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF : DOCKET No. 99-3998 VS. CIVIL. ACTION- LAW NEVIN KECKLER, _ DEFENDANT :.JURY TRIAL DEMANDED 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 and notice are served, by entering a written appearance personally or by attorney and tiling in writing with t he 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 judgement 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 OITICE SET FORTH BELOW TO FIND OUT WI4ERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service 2 Liberty Avenue Carlisle, Pennsylvania 717-249-3166 NOTICIA USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar action dentro de los proximos veinte (20) dias despues de la notification de esta Demanda y Aviso radicando personalmente o per medic, de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objeccioncs a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar action cotno se describe anteriormente, el case puede proceder sin usted y un fallo por cualquier suns de dinero reclamada en la demanda o cualquier otra reclamation o remedio solicitado por el demandante puede ser dictado en contra suya per la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGARLE A UNO, LLAME O VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service 2 Liberty Avenue Carlisle, Pennsylvania 717-249-3166 EVELYN KNULL, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA No. 99-3998 V. CIVIL ACTION-LAW NEVIN KECKLER, Defendant JURY TRIAL DEMANDED COMPLAINT 1. Evelyn Knull is an adult individual who resides at 1301 North 6th Street, Harrisburg, Dauphin County, Pennsylvania 17102. 2. Nevin Keckler is an adult individual who resides at 339 Pitt Street, Enola, Cumberland County, Pennsylvania 17025. 3. Evelyn Knull rented an apartment from Bunker Hill Apartments in Camp Hill, Cumberland County, Pennsylvania in 1998. 4. Nevin Keckler worked for Bunker Hill Apartments in Camp Hill, Cumberland County, Pennsylvania in 1998. 5. Evelyn Knull met Defendant Keckler at the Bunker Hill Apartments rental office. 6. Evelyn Knull and Defendant Keckler entered into an oral contract, whereby Defendant Keckler would use his van and move Evelyn Knull's personal belongings into her apartment at Bunker Hill Apartments in Camp Hill on September 12, 1998, and Evelyn Knull would pay Defendant Keckler'l'wo Hundred and Fifty ($250) Dollars. As part of the contract, Defendant Keckler was to pay Brian Coates to help him move Evelyn Knoll's personal belongings. On September 12, 1998, Defendant Keckler and Mr. Coates loaded Defendant Keckler's van and a trailer with Evelyn Knull's personal belongings. 9. Defendant Keckler drove his van and trailer to Evelyn Knoll's apartment. 10. Defendant Keckler and Mr. Coates unloaded Evelyn Knoll's personal belongings from the trailer. 11. Defendant Keckler then stated that he had to leave for a brief period. 12. Evelyn Knoll paid Defendant Keckler Two Hundred ($200) Dollars of the Two Hundred and Fifty ($250) owed on the oral contract. 13. Defendant Keckler never returned with Evelyn Knoll's personal belongings that were in his van. 14. It is believed and therefore averred that the following list of items were owned by Evelyn Knoll and were in Defendant Keckler's van: Item Value a. Double antique brass candelabra - $500 10 b. Large box of clothes - $600.01 C. Box of household and kitchen goods - $30000 d. Large box of wall paper - $100.00 e. Box of extension cords & light bulbs - $100.00 f. Pots, pans, and other dishes - $ 75.'0 9. Large box, Christmas lights & Cords - h. Antique books - i. Documents and other important papers - j. Family and other pictures $ 50!'0 k. Book Case $200.`0 *11NA1111 TO ASSESS VALUE 15. None of Evelyn Knoll's personal belongings that were in Defendant Keckler's van were returned to Evelyn Knull. 16. The value of the personal belongings in the van was approximately Two Thousand ($2,000) Dollars. See paragraph 14. Count 1 - Conversion 17. Paragraphs 1-16 are incorporated herein by referenced hereto. 18. It is believed and therefore averred that Nevin Keckler has either sold Evelyn Knoll's personal belongings and is no longer in possession or has converted her belongings to his own use. 19. Defendant Keekler's retention of Evelyn Knull's personal property equals a wrongful conversion of her property. WHEREFORE, Evelyn Knull prays for a judgment by this Honorable Court in her favor and against Defendant Keckler in the amount of Two Thousand ($2,000) Dollars. This amount does not exceed the jurisdictional amount required for arbitration. Count 2 - Breach of Contract 20. Paragraphs 1-19 are incorporated herein by reference hereto. 21. The oral agreement between Evelyn Knoll and Defendant Keckler constituted an oral contract. 22. By not delivering and unloading all of Evelyn Knull's personal property, Defendant Keckler breached the contract. 23. Evelyn Knull has lost TWO Thousand ($2,000) Dollars as a direct result of Defendant Keckler's breach of contract and loss of her property. WHEREFORE, Evelyn Knull prays f'or a judgment by this Honorable Court in her favor and against Defendant Keckler in the amount of Two Thousand ($2,000) Dollars. This amount does not exceed the jurisdictional amount required for arbitration. Respectfully submitted, Aaron D. Hollis Certified Legal Intern Supervising Attorney Geoffrey M. Biringer, Esq. Sup. Ct. I.D. 18040 Widener University School of Law Harrisburg Civil Law Clinic 2300 Vartan Way Harrisburg, PA 17110 Tel. (717) 541-0320 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 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Date: Evely null Petitioner ? 1 I : _J C. ?. '?1 ?__ (1 1, ? ) .? ._ ?. i J EVELYN KNULL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 99-3998 V. NEVIN KECKLER, CIVIL ACTION - LAW Defendant NOTICE TO PLEAD TO: Evelyn Knull C/O Geoffrey M. Biringer, Esquire Widener University School of Law Harrisburg Civil Law Clinic 2300 Vartan Way Harrisburg, PA 17110 You are hereby notified to plead to the enclosed New Matter within twenty (20) days from service hereof, or a default judgment may be entered against you. Date: J.:Z_oi SAIDIS, SHUFF, FLOWER & LINDSAY By L / SAIDIS o L. Hitchings, Esqu e , FLOV*TER " S& LINDS IN Supreme Ct. I.D. # 65551 uW TT? 26 West High Street 36 W. High Street Carlisle, PA 17013 Carlisle, PA (717) 243-6222 Attorney for Defendant EVELYN KNULL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 99-3998 V. NEVIN KECKLER, CIVIL ACTION - LAW Defendant ANSWER TO COMPLAINT AND NOW, comes the Defendant, Nevin Keckler, by and through his attorneys, Saidis, Shuff, Flower & Lindsay, and answers Plaintiff's Complaint as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted in part; denied in part. It is admitted that the Plaintiff and Defendant agreed that the Defendant would move Plaintiff's belongings from her residence in Harrisburg to her apartment at Bunker Hill Apartments in Camp Hill on September 12, 1998. It is denied that there was an SAIDIS SHUFF,FLOWER agreement that the Plaintiff would pay the Defendant $250.00. & LINDSAY ArIORMYS-Ar•twW 26 W. High Street It was discussed between the parties that the Plaintiff would Carlisle, PA pay the Defendant $250.00 if he used his own men to move Plaintiff's belongings, which he did not do as he used a friend of the Plaintiff's, Brian Coates, to help him move the belongings. The personal belongings which the Plaintiff asked Defendant to move included the larger items in her residence including various pieces of furniture. 7. Denied. Plaintiff advised Defendant that she was going to pay Brian Coates' $50.00 for him to help Defendant move the Plaintiff's belongings. 8. Admitted. 9. Admitted. 10. Admitted. By way of further answer, Defendant also unloaded Plaintiff's personal belongings from the van. 11. Admitted. 12. Denied. Plaintiff paid the Defendant $150.00, and SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, PA advised the Defendant that she would pay Brian Coates directly. 13. Denied. All personal belongings of the Plaintiff which the Defendant moved, were removed from both the trailer and the van. 14. Denied. It is specifically denied that the items identified in paragraph 14 of Plaintiff's Complaint were ever in the Defendant's van. By way of further answer, Defendant has hired by Plaintiff to move the larger items in Plaintiff's residence, including various pieces of furniture. 2 15. Denied. See answer to paragraphs 13 and 14 above. 16. Denied. See answer to paragraphs 13 and 14 above. Count I - Conversion 17. Paragraphs 1 through 16 of Defendant's Answer are incorporated by reference as if the same were more fully set forth at length herein. 18. Denied. As stated herein, all of the items belonging to the Plaintiff which Defendant moved, were removed from the trailer and van and placed in the Plaintiff's apartment. As such, it is denied that the Defendant retained possession, that he sold or converted any of Plaintiff's use. 19. The averments in paragraph 19 constitute conclusions of law to which no responsive pleading is required. To the extent that the averments are deemed factual in nature, the same are denied and strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant, Nevin Keckler, demands judgment in SAIDIS SHUFR FLOWER & LINDSAY ANXNEYS•AMAW 26 W. High Street Carlisle, PA his favor and against the Plaintiff upon her Complaint. Count II - Breach of Contract 20. Paragraphs 1 through 19 of Defendant's Answer are incorporated by reference as if the same were more fully set forth at length herein. 3 21. The averments in paragraph 21 constitute conclusions of law to which no responsive pleading is required. To the extent that the averments are deemed actual in nature, the same are denied and strict proof thereof is demanded at the time of trial. 22. The averments in paragraph 22 constitute conclusions of law to which no responsive pleading is required. To the extent that the averments are deemed actual in nature, the same are denied and strict proof thereof is demanded at the time of trial. 23. Denied. It is denied that Defendant Keckler breached any contract with the Plaintiff, or that he is responsible or in any way liable as a result of her alleged loss of property. WHEREFORE, Defendant, Nevin Keckler, demands judgment in his favor and against the Plaintiff upon her Complaint. NEW MATTER 1. Plaintiff has failed to set forth a cause of action SAIDIS SHUFF, FLOWER & LINDSAY AT17ORNEYS•AP AW 26 W. High Street Carlisle, PA upon which a relief may be granted against the Defendant. 2. As this claim seeks liquidated damages in the amount of $2,000.00, which amount is less than the jurisdictional 4 amount required for arbitration, Plaintiff's demand for jury trial is inappropriate and must be stricken. 3. Plaintiff, in the past, has made unfounded allegations of theft against the Defendant on numerous occasions, all of which have proven to be untrue. 4. It is believed and therefore averred that as a result of her advanced age, the Plaintiff may suffer from dementia, which causes her to be confused and forget where she has placed items of her property. WHEREFORE, Defendant, Nevin Keckler, demands judgment in his favor and against Plaintiff, Evelyn Knull. Respectfully submitted, SAIDIS, SHUFF, FLOWER 6, LINDSAY J s h L. ings, E uire By ? ?ltc ttorney I.D. # 65551 26 W. High Street Carlisle, PA 17013 Attorney for Defendant SAIDIS SHUFF, FLOWER & LINDSAY A7TOMYS-AT•uW 26 W. High street Carlisle, PA 5 VERIFICATION I verify that the statements made in the foregoing Answer to 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. DATED : -LAL?i _ 4-x / Nevin Keckler, Defendant SAIDIS SHUFF, FLOWER & LINDSAY ArroBN6rs•APLAW 26 W. High Street Carlisle. PA CERTIFICATE OF SERVICE On this k- 9A-4- day of C ?ten c , 2042-, I , hereby certify that I served a true and correct copy of the foregoing Answer with New Matter upon all parties of record via United States Mail, postage prepaid, addressed as follows: Geoffrey M. Biringer, Esquire Widener University School of Law Harrisburg Civil Law Clinic 2300 Vartan Way Harrisburg, PA 17110 SAIDIS SHUFF, FLOWER & LINDSAY Armar?rsunuw 26 W. High Street Carlisle, PA SAIDIS, SHUFF, FLOWER & LINDSAY r u Li <) EVELYN KNULL, : INTHE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF NO. 99-3998 VS. NEVIN KECKLER, DEFENDANT CIVIL ACTION - LAW ANSWER TO NEW MATTER AND NOW, comes the Plaintiff, Evelyn Knull, by and through her Certified Legal Intern, Kevin Dugan, and answers Defendant's Answer with New Matter as follows: I. Denied. Plaintiff pled sufficient facts in her complaint to support her causes of action in conversion and breach of contract. 2. Denied. Plaintiff properly pled her claim as within the amount requiring arbitration, but retained her right to jury trial should that be necessary on appeal. 3. Admitted in part; denied in part. Plaintiff admits to making allegations of theft against the defendant in the past, however, denies that these allegations were unfounded or proven untrue and proof thereof is demanded at trial. 4. Denied. Plaintiff does not suffer from dementia or any other illness or disease that would affect her memory. Wherefore, Plaintiff, Evelyn Knull, demands that Defendant's New Matter be dismissed and judgment entered forPlaintiff as stated in the Complaint. Respectfully submitted, 1. 4m Kevin M. Dugan Certified Legal Intern By: Supervising Attorney Geoffrey M. Biringer Sup. Ct. I.D. 18040 Widener University School of Law Harrisburg Civil Law Clinic 2300 Vartan Way, 2nd Floor Harrisburg, PA 17110 Tel. (717) 541-0320 VERIFICATION 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 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. 2 Date:%_ Ev yn Knull Petitioner U ?[yJ! ra d N ch RipV???,n c m C? r MA 2 , 2003 EVELYN KNOLL, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, DOCKET NO. 99.3998 VS. NEVIN KECKLER, DEFENDANT : CIVIL ACTION - LAW ORDER upon Motion of the Harrisburg Civil Law Clinic, a Rule Absolute is granted and the Harrisburg AND NOW, this *1 & day of /46. , 2003, Civil Law Clinic is permitted to withdraw as counsel Ch the ab_ova-ca p?ioned proceeding. J. i;. ri.n nn CIIr.L,. ?r r J r ? l ? d 2 `^ o wi EVELYN KNULL, PLAINTIFF, VS. NEVIN KECKLER, A=1d=0I71.Yi IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 99.3998 CIVIL ACTION - LAW MOTION FOR RULE ABSOLUTE Movants, Harrisburg Civil Law Clinic, hereby set forth as follows: 1. On January 29, 2003, a Rule was issued giving both parties in the above- captioned proceeding twenty (20) days to show cause why the Harrisburg Civil Law Clinic should not be permitted to withdraw as counsel for the Plaintiff in the above-captioned proceeding. 2. Said Rule was served upon Evelyn Knull and Joseph L. Hitchings Esquire, for the Defendant via first class mail on January 28, 2003. 3. No one has responded to the Rule to date. WHEREFORE, the Harrisburg Civil Law Clinic requests that this Court enter a Rule Absolute in the above-captioned proceeding permitting the Harrisburg Civil Law Clinic to withdraw as counsel for the Plaintiff. DATE: -3 - 20 - 03 LAt ), ROBERT HF KA CERTIFIED LEGAL INTERN GEOFFREY M. BIRINGER V ID NO. 18040 WIDENER UNIVERSITY SCHOOL OF LAW HARRISBURG CIVIL LAW CLINIC 2300 VARTAN WAY, 2ND FLOOR HARRISBURG, PA 17110 In The Court of Common Pleas Evelyn Knull, : Cumberland County, Pennsylvania Plaintiff No. 99-3998 VS. Nevin Keekler, Defendant : Civil Action - Law CERTIFICATF OF SERVICE 1, Robert Shayka, Certified Legal Intern for the Harrisburg Civil Law Clinic, and counsel for the above Plaintiff, do hereby certify that on the ;k* day of Ma^ci. 2003,1 served a Motion For Rule Absolute on the following people at the following addresses: 1) Evelyn Knoll, Plaintiff, at P.O. Box 265, Harrisburg PA 17108- 0265, 2) Joseph L. Hitchings, Esquire, counsel f'or Defendant, at 26 West High St., Carlisle, PA 17013 by depositing same in the U. S. Mail, first class postage prepaid. Date: 3-do-09 Robert Shayka Certified Legal Intern "/,/, Z,44? Supervising Attorney s Geoffrey M. Biringer, Esq. Sup. Ct. I.D. 18040 Harrisburg Civil Law Clinic Widener University School of Law 2300 Varian Way Harrisburg, PA 17110 Tel. (717) 541-0320 Y ?_.. L.. n. tO .. L : IN Tim COURT OF COMMON P LEAS EVELVN KNULL, : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF No. 99-3998 Vs. NEVIN KECKLER, , DEFENDANT : CIVIL ACTION - LAW ORDER And now, this the 4 day of 2003, a Rule is issued upon the Plaintiff above to show cause, il'any she has why the Harrisburg Civil Law Clinic should not be permitted to withdraw as her counsel in the above-captioned proceeding. Said Rule returnable to this Court within 0 days.Fh J. c 01.30.03 to: N'I ?-ch?? ?s = r_ c; to` +_, In The Court of Common Pleas Evelyn Knull, : Cumberland County, Pennsylvania Plaintiff No. 99-3998 VS. Nevin Keekler, Defendant : Civil Action - Law Petition for Leave of Court to Withdraw as Counsel The Harrisburg Civil Law Clinic, pursuant to Pa. R.C.P. No. 1012, seeks to withdraw as counsel for the Plaintiff in the above-captioned civil matter for the following reasons: On April 18, 2002, Evelyn Knoll retained the Harrisburg Civil Law Clinic as counsel in the above-captioned matter. 2. Ms. Knull was advised by the Clinic through the retainer agreement that a certified legal intern would be representing her under the supervision of an attorney and that at the end of the academic semester another intern would be assigned Ms. Knull's case. 3. Ms. Knull sought representation in order to pursue a claim against the Defendant. 4. Certified legal interns and a supervising attorney attempted to investigate the facts alleged in order to prepare a complaint. 5. Fact investigations were made practically impossible due to Client's inability to produce a key witness, maintain contact with such witness, and insistence on discussing matters unrelated to her claim. Throughout the I larrisburg Civil Law Clinic's relationship with Plaintiff, she has expressed her displeasure in being represented by multiple student interns despite being informed in writing of the Clinic's operation on more than one occasion and verbally by the Clinic's supervising attorneys. 7. Due to Plaintifrs unwillingness to confine client meeting discussion to the issues included in the complaint and her obvious dissatisfaction with the attorney-client relationship, continued representation is not possible. 8. Specifically, her conduct has made it impossible for counsel to adequately prepare and proceed with her claim. 9. Plaintiff has also exhibited a level of disrespect for clinic attorney-supervisors and for the clinic interns that is unnecessary and unacceptable. Wherefore, the Harrisburg Civil Law Clinic seeks permission from this Court to withdraw as counsel for Plaintiff in the above. Harrisburg Civil Law Clinic C? By: tcz Geoffrey M. Biri ger. Esq. Sup. Ct. 18040 Widener University School of Law 2300 Vartan Way Harrisburg, PA 171 10 Tel. (717) 541-0320 : In The Court of Common Pleas Evelyn Knull, : Cumberland County, Pennsylvania Plaintiff r? No. 99-3998 VS. Nevin Keekler, t Defendant ?.. Civil Action - Law CERTIFICATE OF SERVICE 1, Robert Shayka, Certified Legal Intern for tile Harrisburg Civil Law Clinic, and counsel for the above Plaintiff, do hereby certify that on the Y4' day of _ 2003, I served a Petition For Leave of Court to Withdraw As Counsel and Order on the following people at the following addresses: 1) Evelyn Knull, Plaintiff, at P.O. Box 265. Harrisburg PA 17108- 0265, 2) Joseph L. Hitchings, Esquire, counsel for Defendant, at 26 West High St., Carlisle, PA 17013 by depositing same in the U. S. Mail, first class postage prepaid. Date: % k Robert Shayka Certified Legal Intern ?I Supervising Attorney / Geoffrey M. Biringer, Esq. Sup. Cf. I.D. 18040 Harrisburg Civil Law Clinic Widener University School of Law 2300 Varian Way Harrisburg, PA 171 10 Tel. (717) 541-0320 } ?T 4r? EVELYN KNULL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff PENNSYLVANIA VS. No. 99-3998 NEVIN KECKLER, Defendant CIVIL ACTION-LAW ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Ms. Evelyn Knull, Plaintiff, in the above-captioned matter. l chael T. Edwards, Certified Legal intern Elder Law Clinic 150 South College Street Carlisle, PA 17013 717-240-5152 r? F. r_7 COMMONWEALTH Of PENNSYLVANIA COURT OF COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No L" 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 dote and in the case mentioned below. Name or appelke(sl appellee(s), to file a complaint in this appeal within twenty (20) days after service of rule or suffer entry of judgment of non pros 02" !- O CV 19 C] LT 19 / IIm3 block will be signed ONLY when this notation is required under Pa R.CPJP. No 10081. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possession in this case Signature of Pmthonotary or Deputy If appellant was CLAIMANT (see Pa. R.C.P.J.P. 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 lam 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 (Common Pleas No RULE: To Name of Signature of appMlant a nor attorney a agent appellee(s). (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 date of service of this rule if service was by mail is the date of mailing. 19- Of a Rornaamry AOPC3,2ss COURT FILE TO BE FILED WITH PROTHONOTARY ,`. h -. Q Lt_.. Lip J -Ii, .lei I%"IAI!, I(,q 1u,.03 A, /HIJI/(J Jo of"I 1ue11/p 1o ein}eu6is ?. Y `:I'.N 1/l1'pi'W 1'(141 OIO,J'1 (Cr'irll (, J0 ?,,:ICU(Ils` -6l -- - 20 AVO -- SIHl 3W 3HOd3e c7iomosans ONV (03WHIddV) NHOMS 0laJa4 Pagoelle ldlaaaJ sJopuas'geuJ (poialsl6ai) (pappia.i) Aq [] OltAJas IeuosJad Aq L. - 6t - '- ua paSSaJppe sem alnH O41 woymol(s)aalladdeayl uodn leaddVlo au4oNanoge agl 6wAuedwowe luleldwo0 eapjolalnd eql panJas 1 le41 Jaqunl pue Cj ,oleJay pagoelle idlaoa s,Japuas'pew (paialsi6ai) (palplJao) Aq ? aowas IeuosJad Aq ? -6L ' uo (nwau) nalladde agl uodn pue olaJaq paquelle idlaoaJ sjapuas 'pew (palalsl6ai) (payplao) Aq 0 aolAJas IeuosJad Aq C-' (9.91AJOS /O 019p) uO ulaJagl paleubisap aogsnp Up1sIO o4l uodn - ON seaid uowwa') geaddV 10 aopON a41 1o Adoo e ? panJas teyl uuq}v. Jo Jeams Agalay I UlAVQIddV ss' d0 A1.Nnoo VINVAIASNN3d JO HIIV3MNOWW00 (sexoq algeogdde )ioogo 7eadde 1o oogct, n41 6u,P! :131 IV SAVO 1011 N31 NIHI IId O37l 1 39 1snW agmJes 101aoJd 5141) 1NIV-IdW00 311:1 Ol 3ind ONV -IV3ddV 30 30110N j0 301AM3S d0 d00dd COMMONWEALTH OF PENNSYLVANIA COtINTV OF:- CUMBERLANn 09-1-02 DJ Nam: Hon. ROBERT V. MANLOVE Afters: 1901 STATE STREET CAMP HILL, PA TalopWno: (717 ) 761- 0583 17011-0000 I w? ry/j e ? NOTICE OF JUDIEM NT/TRANSCRIPT PLAINTIFF: CIVIL CASE NAME aW ADDRESS fKNULL, EVELYN -I 1103-YVRRD0N-DE -APT --3A CAMP HILL, PA 17011 JI/ L SIJ S d,?a'L S1 • H{?j /710y J vs. DEFENDANT: NAME An ADDRESS rKKECKLER; NEVIN 339 PITT ST ENOLA,'PA 17025 EVELYN KNDLL L J 1103 YVERDON DR APT.# 3A DocketNo.: CV-0000139.99 CAMP HILL, PA 17011 Date Filed: 4/14/99 THIS IS TO NOTIFY YOU THAT: Judgment: FOR nsPENDANT ® Judgment was entered for: (Name) xRCirr.RR NInrim Q Judgment was entered against: (Name) xNm,L= K rmT, M in the amount of $ Defendants are jointly and severally liable. Damages will be assessed on: This case dismissed without prejudice. ? Amount of Judgment Subject to Attachment/Act 5 of 1996 $ on: (Date of Judgment) F/ni /qq ? Levy is stayed for days or ? generally stayed. El Objection to levy has been filed and hearing will be held: (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total Post Judgment Credits Post Judgment Costs Judgment Total $ I Date: Place: Time: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING AN OTICE MUST IINC UDE A COPY OF THIIS?4 TTI • LEr D NT/TRANSCRIPTOM RMNWPLEAS, ITH YOUR INOTICE IOF APPEAL. Date this is a tr Date My commission expires first Monday of January, District Justice of the proceedings containing the judgment. District Justice 2000 SEAL AOPC 315-99 COMJAONWEALTN OF PINNSYLVANIA COURT OF COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. Cyf'.1- 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 an the date ad in the case mentioned below. CV 19. / 21 ?4 LT 19 1 -block will be signed ONLY when this notation is required u 1008184 nder Pa. R.CP.JP. No. If appellant was CLAIMANT (see Pa. R.C.P.J.P. No. This Notice of Appeal, when received by the District Justice, will operate as a 1001(6) in action be/ore District Justice, he MUST SUPERSEDEAS to the judgment for possession in this case FILE A COMPLAINT within twenty (20) days after Signature of Prothonotary or Deputy tiling 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.JP. 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 , Nang of apxlMe(sl appelee(s), to file a complaint in this appeal (Common Pleas Na )within twenty (20) days after service of rule or suffer entry of judgment of non pens. Somfure of Amellant or ns attorney a epee RULE: To oppellee(s). ` Nave a a{pelkas) (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 date of service of this rule if service was by mail is the date of mailing. Dale: , 19_. Sipretae of 1tuDKriotay a OAaM J, COURT FILE ? , PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MLSI' BE FILED WITHIN TEN (Id) LA'/.S Af7ER h4ng the notice of appeal. Check applicable boxes) COMMONWEALTWPF PENNSYLVANIA COUNTY OF AFFIDAVIT: I hereby swear or affirm that I served [fT`?fJ ?%J ? 9 ? a copy of the NOW; 01 App,:;, C-m^mon Pleas NJ, _c' _e Ypo?ha District Justice designated therein on (date of se/vic0; 9r __.-.- L] by personal service: y Icer Ii11Cf1) (registered) mail, senders receipt attached hr.nato. rnd upon the appellee. rnema) on ___-__ tn_.___ ? by personal service i? by (cerlitied) (registered) mail, sender's receipt attached hereto. ? and further that l served the Rule to File a CompialntaccOmpany,ng the above Notice of Appeal upon the appellee(s) to whom the Rule was addressed un ------ 19- U by personal service ? by (certified) (registered) mail, sender's recerpT art:,ched nereto- SWORN (AFFIRMED) AND SUR C1 IOLD BEFORE MlE J THIS DAY OF 19. Signa uro of affiant ALI TOM or or ,,M MY comnussiov r.nv.'c rr 4 L,_?, o r? yC-5 LLi t '-`1L WO- ?p U a, i SENDER: a I also wish to receive the follow- Z O Complete items tats, and for additional services. Ing sefVIC05 (for an extra fee): ): m Complete items 3, its, and db. O Pont your name and address OO the RVeI9e 01111191011116a that WB can relUln this card to you. 1. ? Addressee's Address O Attach this lone to the front of the mailpiece, or on the back it space does not lt 2. Restricted Delivery OWrite 'Return Receipt Re don the meilpieca below the arllde number. C 0The Return Receipt will ship.la Whom the ankle was delivered and the dale p delivered. n 3. Article Addressed to: ^^ 4a. Article Plumber 4b. Service Type /per I^^"^ n 0 Registered Acidified ? Express n Receipt ? Insured ? Return Receipt for Merchandise ? COD COD a 7. Calls f Delivery ? _ pia Y-Rc kcaG ,ct l `1/ ? 4 l r S. Received By: (Print Name) tlressee's s(Only ilrequested and lee is paid) 1] -e lv?lke c . Signature (Ad ress or Agent) T _N PS Form 3811, December 1994 102.595.99 6.00223 Domestic Return Receip r i rti ? N 6 , c ' 3 ra to i c N , 0 I T Y 1 m i I 1 Il 1 l I SHERIFF'S RETURN - REGULAR CASE NO: 1999-03998 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KNULL EVELYN VS KECKLER NEVIN SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KECKLER NEVIN the DEFENDANT at 1740:00 HOURS, on the 6th day of December , 2001 at 339 PITT STREEET ENOLA, PA 17025 by handing to NEVIN KECKLER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.75 Affidavit .00 Surcharge 10.00 .00 37.75 Sworn and Subscribed to before me this 13 - day of l0A4z,,J - 1&0!1&0! A.D. So Answers: R. Thomas Kline 12/10/2001 GEOFFREY BIRIr By: eputy/S othonotary Evelyn Knull, V. Plaintiff Nevin Keekler, Defendant : In the Court of Common Pleas : Cumberland County, Pennsylvania : Dkt. 99-3998 : Civil Action - Law PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Evelyn Knull, Plaintiff, to proceed in forma pauperis. I, Aaron Hollis, Certified Legal Intern for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Date: 111adol 41?. L)A Aaron Hollis Certified Legal Intern Supervising Attdrney Geoffrey M. Biringer, Esquire I.D. No. 18040 Widener University School of Law Harrisburg Civil Law Clinic 2300 Varian Way Harrisburg, PA 17110 Tcl.(717)541-0320 Evelyn Knoll, Plaintiff V. Nevin Keekler, Defendant : In the Court of Common Pleas : Cumberland County, Pennsylvania Dkt. 99-3998 Civil Action - Law PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS TO THE HONORABLE JUDGES OF SAID COURT: The Petitioner, Evelyn Knull residing at1301 North 6th St., Harrisburg, Dauphin County, Pennsylvania, upon her oath deposes and says: 1. I am the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. 1 represent that the information below relating to my ability to pay the fees and costs is true and correct: (a) Name: Evelyn Knull Address: 1301 North 6" St. Harrisburg, PA 17102 Social Security Number: 158-09-3741 (b) Employment If you are presently employed, state Employer: none Address: Salary or wages per month: Type of work: none Ifyou are presently unemployed, state Date of last employment: none Salary or wages per month: none Type of work: none (c) Other income within the past twelve months Business or profession: none Other self-employment: none Interest: none Dividends: none Pension and annuities: none Social security benefits: $365.00 per month Support payments: none Disability payments: $220.00 per month Unemployment compensation and supplemental benefits: none Worker's compensation: none Public assistance: none Other: none (d) Other contributions to household support - Spouse Name: none If your spouse is employed, state Employer: none Salary or wages per month: none Type of work: none Contributions from children: none Contributions from parents: none Other contributions: none (e) Property owned Cash: none Checking Account: $120.00 Savings Account: none Certificates of Deposit: none Real Estate (including home): none Motor vehicle: none Make Year , Cost Cost Amount Owed $ none Stocks; bonds: none Other: none (f) Debts and obligations - Mortgage: none Rent: $366.00 per month Loans: none Other: none (g) Persons dependent upon you for support - Name: none Children, if any: none Name: Age: Other persons: none Name: Relationship: 4. 1 understand that 1 have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements maar; ik. this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Date: 11 $ JO-/ Evelyn null Petition r ' ; 1 li. ?. ../ .1 `,l .? I i.l ` :`- ) , J ) ;,, i J :? E uelnt1 kr..,.11 VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.'IA--3?9W CIVIL 19 I.?e v ; t. Ke ?k1e ?, D??e-r•c?C,.,,?r RULE 1312-1. The Petition for Appointment of Arbitrators shall he substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: ffl t_"eA "1' EA,-,u Aj , counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of the plaintiff in the action is $ a 000 The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Ul WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully sub it?Locu"r L ..? 5.,.?err\ ORDER OF COURT ?1a`r t ?a r t 'SA. PR tt4iot3 7lT-QHO 'cilSa AND NOW, F9'? in co stderation of the y ?je foregoing petition, oKGA? Esq., Esq., and Esq., are appointed arbitrators in the above captioned action (or actions) as prayed for. By the Court 11JNAY),__ P.J. r ?- ?s Up C} Cl) T ?-' u U 4--l/t'/y c V / I I f / / : IN THE COURT OF COMMON PLEAS OF J CUMBERLAND COUNTY, PENNSYLVANIA NO. ?9=9Q TERM OATH We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. AWARD We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) . Arbitrator, dissents. Date of Hearing: Z0Jlt± Date of Award: "7?l moo' (insert name if applicable.) Chairrnap( r ,+ r NOTICE OF ENTRY OF AWARD Now, the ? day of G66 , 20A2, at 2 :31 , P.M., the above award was entered upon the docket and notice thereof given by mail to th parties or their attorneys. Artibitrators'compensation to be ?t , Paid upon appeal: Prothonotw' $ 290.00 By: LI) D uty p _ ?(..-Tslw •(?u..e%? v yo-?ic.., PC'- D ?..L14 1r10t- aJ'.zy /'/l,choel /h.D D 3S?o ,,u ;I[. el. A(Aony Qe Utica Est. ??131?a3 u''J.u-ea ? t? cr vta?'7 Q GI W ;ir ? I--: C - ; TJ J?e?o.c 1(-13-v3 ?` o a r IOF PENNSYLVANIA NOTICE OF APPEAL COURT OF COMMON PLEAS FROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT COMMON PLEAS NO (n.- 'X) p I .I f 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 NAME OF AMUAW MAG DIST NO OR NAME OF W. og_ 1, O?-' A LLA CITY ZP CODE 1_ ST rrI ????/ v I?r DATE OF AX6WNT iM4TE CASE OF (R'ainfiff) " NO U ) ` - SIGNATURE OF AFFEL HIS ATTORNEY OR AGENT CV 19 -yh LT 19 1i"o-L l' Al This block will be signed ONLY when this natation is required under Pa. R.C.RJA No, If appellant was C AIMANT (see Pa. R.C.P.J.P. No. 10088. This Notice of Appeal, when received by the District Justice, will operate as a 1001(6) in action before District Justice, he MUST SUPERSEDERS to the judgment for possession in this case FILE A COMPLAINT 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 , oppellee(s), to file a complaint in this appeal fJarre of appellees) (Common Pleas No ) within twenty (20) days after service of rule or suffer entry of judgment of non pros Signature of appeJand or his atror y or agent RULE: To oppellee(s). IJa,Ie of apperfearal (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 date of service of this rule if service was by mail is the date of mailing. Date: 19_ . Sgrwft- of P oth notary or Deputy AOPC 312-M 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 00) DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF. ; ss AFFIDAVIT; I hereby swear or affirm that I served 1 a copy of the Notice of Appeal, Common Pleas No, upon the District Justice designated therein on (date of service) , D by personal service ? by (certified) (registered} mail, senders receipt attached hereto, and upon the appellee. (name) on 19 __ D by personal service ? by (certified) (registered) mail, sender's receipt attached hereto. ? and furtherthat i served the Ruleto Filea Complaint accompanying theabove Noticeof Appeal upon theappellee(s)towhom th,g Rules was addressed on by personal service E' by (cerotieo) (remstered7 mail, sender's receipt attached hereto. SWORN (AFFiRNIED; AND SUBSCRIBED BEFORE ME THIS ._._.?.?...?._. DAY OF Signature of afhant siona v J cor oo ^rlom 11110tH r+ 6nav! w s m ds 71110 of orrda7 MY commis: iOr, , 7i ,t, Ci COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag. Dist. No.: 09-1-02 DJ Name: Hon, ROBERT V. MANLOVE Address. 1901 STATE STREET CAMP HILL, PA Telephone:(717) 761-0583 17011-0000 `>-Ld'-" 7// a/ ? NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rKNULL, EVELYN 1-103 YVERDON DR APT.# 3A CAMP HILL, PA 17011 L S143 if d32c? S? A VS. DEFENDANT:, NAME and ADDRESS rKECKLER NEVIN 339 PITT ST ENOLA,'PA 17025 EVELYN INQLL L 1103 YVERDON DR APT.# 3A Docket No'.: CV-0000139-99 CAMP HILL, PA 17011 Date Filed: 4/14/99 THIS IS TO NOTIFY YOU THAT: Judgment: FOR DEFRNDA'NT ® Judgment was entered for: (Name) 1rRr'KT.RR, NWTN ® Judgment was entered against: (Name) KNUT.T., RVRT.YN in the amount of $ _ DD on: (Date of Judgment) ? Defendants are jointly and severally liable. ? Damages will be assessed on: ? This case dismissed without prejudice. ? Amount of Judgment Subject to Attachment/Act 5 of 1996 $ ? Levy is stayed for days or ? generally stayed. ? Objection to levy has been filed and hearing will be held: Date: Time: Place: (Date & Time) 1 171C Al J Xft 6/01/99 Amount of Judgment $ .00 Judgment Costs $ .00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ .00 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING NA OTICE OE APPt=AL WITH THE PROTHONOTARVf LERK F T E COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY Ogndf D NT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. c.0'119 ! Date District Justice I cify hat his is a rue t cord of the proceedings containing the judgment. tD/ s!)99 Date l? District Justice i My commission expires first Monday of January, 2000 SEAL AOPC 315-99 T....,.?,. ?-,- - COMMONWEALTH OF PENNSYLVANIA NOTICE OF APPEAL COURT OF COMMON PLEAS FROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT COMMON PLEAS No? 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. NAME OF APPELLANT MAG. DISL NQ OR NAME OF D.J. C3 L G i y r1 rV1 a ADDRESS OF AEPEIJANT arr sTAm zP CODE DATE OF JUDGMENT E CASE OF lPlaMitlNl 1 (oeta der) I NO SIGNATURE OF APPELLANT OR HIS ATTORNEY OR AGENT C) V p Cv 19 LT 19 This block will be signed ONLY when this notation is required under Pa. R.CP.1P. Na1 If appellant was C AIMANT (see Pa. R.C.P.J.P. No. 10088. This Notice of Appeal, when received by the District Justice, will operate as a 1001(6) in action before District Justice, he MUST SUPERSEDEAS to the judgment for possession in this case FILE A COMPLAINT 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 N. R.C.P.JP. 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 , appeNee(s), to file a complaint in this appeal Name of appe/lee(s) (Common Pleas No. ) within twenty (20) days after service of ruk: or suffer entry of judgment of non pros signature of appellant a his attorney or agent RULE:. To , appellee(s). .. Hanna of appeltee(sl (1) You are notified thate°rule islwebj 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 date of service of this rule if service was by mail is the date of mailing. - Date: , 19. k COURT FILE sig mb- of Rothalotsry a DWAy r C." PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (IOj DAYS AFTER tiling too notice of aopeat Check appticabta boxes] CIMIIIINWEALT F ENNSYLVANIA /COUNTY OF- AFFIDAVIT: ?.,.._.._.. ; ss I hereby swear or affirm that I served _ CJ a rosy of the Notice of Appe I, Common D(strlc' fu tics designated ihereirr 01 (datA of service) -- " -=o- / _ , LJ by personal service y {certitieat ireg+ster d} mail, sender s roc n.; alpic`ed hereto, and upon the appetlAe. (name) _._. ---_ _ _----- - ------- ---- .-------- -, ?n _._....__.-,..?_.__..... .9 by personal service [J by (certified} (registered) mad, senders receipt attached hereto. and further that I nerved the Rule to File a Complaint accompanyng the above Notice of Appeal upon the appellees), to whom the FSuIe was addressed on ta_.._, by per sonic( service ; oy {certified} :rep'stereaf mail. sender's receipt, attached hereto. SWORN {AFFIfthAFDi ; N- SUB CF IBLD BEFORE MF THIS OF ?.. , 79_? F,-rqn.? t prf+ere? store w+.ozn att7avX xas martyr ?oil 415 y brie or o7F>rbl My ccmmssior. expires oFr L Y ? G 7 f LO ii-a-' ? f3]O. ?"- --??--6 Si9na ure of at(ran? ?f? r` Is your RETURN ADDRESS completed on the reverse side? v e? 1C u o 0 o a d y m m U +lf O a ,93 J a?'S X b R.R e Z s dos' 44 C F ? ,r ? ? ? SC@33 ???, d d „ 330 0, . s Z Jl ?? A ?s r? 5 m Thank you for using Return Receipt Service. SHERIFF'S RETURN - REGULAR CASE NO: 1999-03998 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KNULL EVELYN VS KECKLER NEVIN SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KECKLER NEVIN the DEFENDANT , at 1740:00 HOURS, on the 6th day of December , 2001 at 339 PITT STREEET ENOLA, PA 17025 by handing to NEVIN KECKLER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs Docketing 18.00 Service 9.75 Affidavit .00 Surcharge 10.00 .00 37.75 Sworn and Subscribed to before me this /.3 day of ?? ?[w1 A. D. othonotary So AAnns(wsers : f R. Thomas Kline 12/10/2001 GEOFFREY BIRIN By: eputy S -? Evelyn Knoll, Plaintiff V. Nevin Keckler, Defendant : In the Court of Common Pleas : Cumberland County, Pennsylvania Dkt. 99-3998 Civil Action - Law PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Evelyn Knull, Plaintiff, to proceed in forma pauperis. I, Aaron Hollis, Certified Legal Intern for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Date: /4- 0d 0 / /)'? Aaron Hollis Certified Legal Intern Supervising Att ey Geoffrey M. Biringer, Esquire I.D. No. 18040 Widener University School of Law Harrisburg Civil Law Clinic 2300 Vartan Way Harrisburg, PA 17110 Tel. (717) 541-0320 Evelyn Knull, : In the Court of Common Pleas : Cumberland County, Pennsylvania Plaintiff Dkt. 99-3998 V. Nevin Keekler, Civil Action - Law Defendant PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS TO THE HONORABLE JUDGES OF SAID COURT: The Petitioner, Evelyn Knull residing at1301 North 6th St., Harrisburg, Dauphin County, Pennsylvania, upon her oath deposes and says: 1. I am the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct: (a) Name: Evelyn Knull Address: 1301 North 6 s St. Harrisburg, PA 17102 Social Security Number: 158-09-3741 (b) Employment If you are presently employed, state Employer: none Address: Salary or wages per month: Type of work: none If you are presently unemployed, state Date of last employment: none Salary or wages per month: none Type of work: none (c) Other income within the past twelve months Business or profession: none Other self-employment: none Interest: none Dividends: none Pension and annuities: none Social security benefits: $365.00 per month Support payments: none Disability payments: $220.00 per month Unemployment compensation and supplemental benefits: none Worker's compensation: none Public assistance: none Other: none (d) Other contributions to household support - Spouse Name: none If your spouse is employed, state Employer: none Salary or wages per month: none Type of work: none Contributions from children: none Contributions from parents: none Other contributions: none (e) Property owned Cash: none Checking Account: $120.00 Savings Account: none Certificates of Deposit: none Real Estate (including home): none Motor vehicle: none Make Year , Cost Cost Amount Owed $ none Stocks; bonds: none Other: none (f) Debts and obligations - Mortgage: none Rent: $366.00 per month Loans: none Other: none (g) Persons dependent upon you for support - Name: none Children, if any: none Name: Age: Other persons: none Name: Relationship: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. 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 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: Evely u 1 Petition r : IN THE COURT OF COMMON PLEAS EVELYN KNULL, : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF : DOCKET N0.99-3998 VS. NEVIN KECKLER, : CIVIL ACTION -LAw DEFENDANT : JURY TRIAL DEMANDED 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 and notice are served, by entering a written appearance personally or by attorney and filing in writing with t he 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 judgement 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 Lawyer Referral Service 2 Liberty Avenue Carlisle, Pennsylvania 717-249-3166 NOTICIA USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de on abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en In demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra soya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME O VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service 2 Liberty Avenue Carlisle, Pennsylvania 717-249-3166 EVELYN KNULL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 99-3998 V. NEVIN KECKLER, Defendant : CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT Evelyn Knull is an adult individual who resides at 1301 North 6th Street, Harrisburg, Dauphin County, Pennsylvania 17102. 2. Nevin Keckler is an adult individual who resides at 339 Pitt Street, Enola, Cumberland County, Pennsylvania 17025. 3. Evelyn Knull rented an apartment from Bunker Hill Apartments in Camp Hill, Cumberland County, Pennsylvania in 1998. 4. Nevin Keckler worked for Bunker Hill Apartments in Camp Hill, Cumberland County, Pennsylvania in 1998. 5. Evelyn Knull met Defendant Keckler at the Bunker Hill Apartments rental office. 6. Evelyn Knoll and Defendant Keckler entered into an oral contract, whereby Defendant Keckler would use his van and move Evelyn Knull's personal belongings into her apartment at Bunker Hill Apartments in Camp Hill on September 12, 1998, and Evelyn Knull would pay Defendant Keckler Two Hundred and Fifty ($250) Dollars. 7. As part of the contract, Defendant Keckler was to pay Brian Coates to help him move Evelyn Knull's personal belongings. 8. On September 12, 1998, Defendant Keckler and Mr. Coates loaded Defendant Keckler's van and a trailer with Evelyn Knull's personal belongings. 9. Defendant Keckler drove his van and trailer to Evelyn Knull's apartment. 10. Defendant Keckler and Mr. Coates unloaded Evelyn Knull's personal belongings from the trailer. 11. Defendant Keckler then stated that he had to leave for a brief period. 12. Evelyn Knull paid Defendant Keckler Two Hundred ($200) Dollars of the Two Hundred and Fifty ($250) owed on the oral contract. 13. Defendant Keckler never returned with Evelyn Knull's personal belongings that were in his van. 14. It is believed and therefore averred that the following list of items were owned by Evelyn Knull and were in Defendant Keckler's van: Item Value a. Double antique brass candelabra - $500.00 b. Large box of clothes - $600.00 C. Box of household and kitchen goods - $300.00 d. Large box of wall paper - $100.00 e. Box of extension cords & light bulbs - $100.00 f. Pots, pans, and other dishes - $ 75.00 g. Large box, Christmas lights & Cords - h. Antique books - i. Documents and other important papers - j. Family and other pictures $ 50.00 k. Book Case $200.00 *UNABLE TO ASSESS VALUE 15. None of Evelyn Knull's personal belongings that were in Defendant Keekler's van were returned to Evelyn Knull. 16. The value of the personal belongings in the van was approximately Two Thousand ($2,000) Dollars. See paragraph 14. Count 1 - Conversion 17. Paragraphs 1-16 are incorporated herein by referenced hereto. 18. It is believed and therefore averred that Nevin Keckler has either sold Evelyn Knull's personal belongings and is no longer in possession or has converted her belongings to his own use. 19. Defendant Keckler's retention of Evelyn Knull's personal property equals a wrongful conversion of her property. WHEREFORE, Evelyn Knull prays for a judgment by this Honorable Court in her favor and against Defendant Keckler in the amount of Two Thousand ($2,000) Dollars. This amount does not exceed the jurisdictional amount required for arbitration. Count 2 - Breach of Contract 20. Paragraphs 1-19 are incorporated herein by reference hereto. 21. The oral agreement between Evelyn Knull and Defendant Keckler constituted an oral contract. 22. By not delivering and unloading all of Evelyn Knull's personal property, Defendant Keckler breached the contract. 23. Evelyn Knull has lost Two Thousand ($2,000) Dollars as a direct result of Defendant Keckler's breach of contract and loss of her property. WHEREFORE, Evelyn Knull prays for a judgment by this Honorable Court in her favor and against Defendant Keekler in the amount of Two Thousand ($2,000) Dollars. This amount does not exceed the jurisdictional amount required for arbitration. Respectfully submitted, Aaron D. Hollis Certified Legal Intern ??aD7?r ? i Supervising Attorney Geoffrey M. Biringer, Esq. Sup. Ct. I.D. 18040 Widener University School of Law Harrisburg Civil Law Clinic 2300 Vartan Way Harrisburg, PA 17110 Tel. (717) 541-0320 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 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: I/ 3 F/o 41-vel..fl Petitioner EVELYN KNULL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 99-3998 V. NEVIN KECKLER, CIVIL ACTION - LAW Defendant NOTICE TO PLEAD TO: Evelyn Knull C/O Geoffrey M. Biringer, Esquire Widener University School of Law Harrisburg Civil Law Clinic 2300 Vartan Way Harrisburg, PA 17110 You are hereby notified to plead to the enclosed New Matter SAIDIS SHUFF, FLOWER & LINDSAY ArfORNEYS•AT•LAW 26 W. High Street Carlisle, PA within twenty (20) days from service hereof, or a default judgment may be entered against you. ?_ Z_OI Date: SAIDIS, SNUFF, FLOWER & LINDSAY By Ao.ph L. Hitchings, Esqu e Supreme Ct. I.D. # 65551 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Defendant EVELYN KNULL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 99-3998 V. NEVIN KECKLER, CIVIL ACTION - LAW Defendant ANSWER TO COMPLAINT SAIDIS SHUFF, FLOWER & LINDSAY ATrORNEYS.AT•LAW 26 W. High Street Carlisle, PA AND NOW, comes the Defendant, Nevin Keckler, by and through his attorneys, Saidis, Shuff, Flower & Lindsay, and answers Plaintiff's Complaint as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted in part; denied in part. It is admitted that the Plaintiff and Defendant agreed that the Defendant would move Plaintiff's belongings from her residence in Harrisburg to her apartment at Bunker Hill Apartments in Camp Hill on September 12, 1998. It is denied that there was an agreement that the Plaintiff would pay the Defendant $250.00. It was discussed between the parties that the Plaintiff would pay the Defendant $250.00 if he used his own men to move Plaintiff's belongings, which he did not do as he used a friend of the Plaintiff's, Brian Coates, to help him move the belongings. The personal belongings which the Plaintiff asked Defendant to move included the larger items in her residence including various pieces of furniture. 7. Denied. Plaintiff advised Defendant that she was going to pay Brian Coates' $50.00 for him to help Defendant move the Plaintiff's belongings. 8. Admitted. 9. Admitted. 10. Admitted. By way of further answer, Defendant also unloaded Plaintiff's personal belongings from the van. 11. Admitted. 12. Denied. Plaintiff paid the Defendant $150.00, and advised the Defendant that she would pay Brian Coates directly. 13. Denied. All personal belongings of the Plaintiff which the Defendant moved, were removed from both the trailer and the van. 14. Denied. It is specifically denied that the items SAIDIS identified in paragraph 14 of Plaintiff's Complaint were ever SNUFF, FLOWER & LINDSAY in the Defendant's van. By way of further answer, Defendant ATTORNEYS-AT-LAW 26 W. High Street Carlisle, PA has hired by Plaintiff to move the larger items in Plaintiff's residence, including various pieces of furniture. 2 15. Denied. See answer to paragraphs 13 and 14 above. 16. Denied. See answer to paragraphs 13 and 14 above. Count I - Conversion 17. Paragraphs 1 through 16 of Defendant's Answer are incorporated by reference as if the same were more fully set forth at length herein. 18. Denied. As stated herein, all of the items belonging to the Plaintiff which Defendant moved, were removed from the trailer and van and placed in the Plaintiff's apartment. As such, it is denied that the Defendant retained possession, that he sold or converted any of Plaintiff's use. 19. The averments in paragraph 19 constitute conclusions of law to which no responsive pleading is required. To the extent that the averments are deemed factual in nature, the same are denied and strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant, Nevin Keckler, demands judgment in SAIDIS SHUFF, FLOWER & LINDSAY ArrORMYS•Ar.LAW 26 W. High Street Carlisle, PA his favor and against the Plaintiff upon her Complaint. Count II - Breach of Contract 20. Paragraphs 1 through 19 of Defendant's Answer are incorporated by reference as if the same were more fully set forth at length herein. 3 21. The averments in paragraph 21 constitute conclusions of law to which no responsive pleading is required. To the extent that the averments are deemed actual in nature, the same are denied and strict proof thereof is demanded at the time of trial. 22. The averments in paragraph 22 constitute conclusions of law to which no responsive pleading is required. To the extent that the averments are deemed actual in nature, the same are denied and strict proof thereof is demanded at the time of trial. 23. Denied. It is denied that Defendant Keckler breached any contract with the Plaintiff, or that he is responsible or in any way liable as a result of her alleged loss of property. WHEREFORE, Defendant, Nevin Keckler, demands judgment in his favor and against the Plaintiff upon her Complaint. NEW MATTER 1. Plaintiff has failed to set forth a cause of action SAIDIS upon which a relief may be granted against the Defendant. SHUFF, FLOWER & LINDSAY 2. As this claim seeks liquidated damages in the amount ATPORNEYS•AT-LAW 26 W. High Street Carlisle, PA of $2,000.00, which amount is less than the jurisdictional 4 amount required for arbitration, Plaintiff's demand for jury trial is inappropriate and must be stricken. 3. Plaintiff, in the past, has made unfounded allegations of theft against the Defendant on numerous occasions, all of which have proven to be untrue. 4. It is believed and therefore averred that as a result of her advanced age, the Plaintiff may suffer from dementia, which causes her to be confused and forget where she has placed items of her property. WHEREFORE, Defendant, Nevin Keckler, demands judgment in his favor and against Plaintiff, Evelyn Knull. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY By. ?. J seph L. Hitchings,"ire ttorney I.D. # 65551 rr 26 W. High Street Carlisle, PA 17013 Attorney for Defendant SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle. PA 5 VERIFICATION I verify that the statements made in the foregoing Answer SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, PA to 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. DATED : //)-/0 7i Nevin Keckler, Defendant CERTIFICATE OF SERVICE On this ( day of 200 I, hereby certify that I served a true and correct copy of the foregoing Answer with New Matter upon all parties of record via United States Mail, postage prepaid, addressed as follows: Geoffrey M, Biringer, Esquire Widener University School of Law Harrisburg Civil Law Clinic 2300 Vartan Way Harrisburg, PA 17110 SAIDIS, SNUFF, FLOWER & LINDSAY SAIDIS SHUFF, FLOWER & LINDSAY ATrORNEYS•AT•LAW 26 W. High Street Carlisle, PA O i ?' i . ? .., '` ?_ % 1 ? J p { (i. EVELYN KNULL, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF NO. 99-3998 VS. NEVIN KECKLER, DEFENDANT CIVIL ACTION -LAW ANSWER TO NEW MATTER AND NOW, comes the Plaintiff, Evelyn Knull, by and through her Certified Legal Intern, Kevin Dugan, and answers Defendant's Answer with New Matter as follows: 1. Denied. Plaintiff pled sufficient facts in her complaint to support her causes of action in conversion and breach of contract. 2. Denied. Plaintiff properly pled her claim as within the amount requiring arbitration, but retained her right to jury trial should that be necessary on appeal. 3. Admitted in part; denied in part. Plaintiff admits to making allegations of theft against the defendant in the past, however, denies that these allegations were unfounded or proven untrue and proof thereof is demanded at trial. 4. Denied. Plaintiff does not suffer from dementia or any other illness or disease that would affect her memory. Wherefore, Plaintiff, Evelyn Knull, demands that Defendant's New Matter be dismissed and judgment entered forPlaintiff as stated in the Complaint. Respectfully submitted, ? - r+,. ?'.- Kevin M. Dugan Certified Legal Intern By: Supervising Attorney Geoffrey M. Biringer Sup. Ct. I.D. 18040 Widener University School of Law Harrisburg Civil Law Clinic 2300 Vartan Way, 2"d Floor Harrisburg, PA 17110 Tel. (717) 541-0320 VERIFICATION 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 18 Pa. C.S. §4904, relating to unssNpworn falsification to authorities. `O Q p /? Date: Nt Q/7-C/) °?jr1 ?v -? Ev?yn Knull Petitioner IN THE COURT OF COMMON PLEAS EVELYN KNULL, : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF No. 99-3998 VS. NEVIN KECKLER, DEFENDANT : CIVIL ACTION - LAW ORDER And now, this the IPI day of V Y? - d' , 2003, a Rule is issued upon the Plaintiff above to show cause, if any she has why the Harrisburg Civil Law Clinic should not be permitted to withdraw as her counsel in the above-captioned proceeding. Said Rule returnable to this Court within 4?0 days.OYW Vt- e J. cI. oi.3p-03 ta. ?- ;J ?: r . :. ;,;. ?. .. ,: , _ ? . , , ? -.' - ; ' ? _ : In The Court of Common Pleas Evelyn Knoll, : Cumberland County, Pennsylvania Plaintiff No. 99-3998 VS. Nevin Keckler, Defendant : Civil Action - Law Petition for Leave of Court to Withdraw as Counsel The Harrisburg Civil Law Clinic, pursuant to Pa. R.C.P. No. 1012, seeks to withdraw as counsel for the Plaintiff in the above-captioned civil matter for the following reasons: 1. On April 18, 2002, Evelyn Knull retained the Harrisburg Civil Law Clinic as counsel in the above-captioned matter. 2. Ms. Knull was advised by the Clinic through the retainer agreement that a certified legal intern would be representing her under the supervision of an attorney and that at the end of the academic semester another intern would be assigned Ms. Knull's case. 3. Ms. Knull sought representation in order to pursue a claim against the Defendant. 4. Certified legal interns and a supervising attorney attempted to investigate the facts alleged in order to prepare a complaint. 5. Fact investigations were made practically impossible due to Client's inability to produce a key witness, maintain contact with such witness, and insistence on discussing matters unrelated to her claim. 6. Throughout the Harrisburg Civil Law Clinic's relationship with Plaintiff, she has expressed her displeasure in being represented by multiple student interns despite being informed in writing of the Clinic's operation on more than one occasion and verbally by the Clinic's supervising attorneys. Due to Plaintiff's unwillingness to confine client meeting discussion to the issues included in the complaint and her obvious dissatisfaction with the attorney-client relationship, continued representation is not possible. 8. Specifically, her conduct has made it impossible for counsel to adequately prepare and proceed with her claim. 9. Plaintiff has also exhibited a level of disrespect for clinic attorney-supervisors and for the clinic interns that is unnecessary and unacceptable. Wherefore, the Harrisburg Civil Law Clinic seeks permission from this Court to withdraw as counsel for Plaintiff in the above. Harrisburg Civil Law Clinic By: 4 ' Geoffrey . Biri ger, Esq. Sup. Ct. 18040 Widener University School of Law 2300 Varian Way Harrisburg, PA 17110 Tel. (717) 541-0320 : In The Court of Common Pleas Evelyn Knull, : Cumberland County, Pennsylvania Plaintiff No. 99-3998 VS. Nevin Keekler, Defendant : Civil Action - Law CERTIFICATE OF SERVICE I, Robert Shayka, Certified Legal Intern for the Harrisburg Civil Law Clinic, and counsel for the above Plaintiff, do hereby certify that on the day of ?w+vuc? y 2113,1 served a Petition For Leave of Court to Withdraw As Counsel and Order on the following people at the following addresses: 1) Evelyn Knull, Plaintiff, at P.O. Box 265, Harrisburg PA 17108- 0265, 2) Joseph L. Hitchings, Esquire, counsel for Defendant, at 26 West High St., Carlisle, PA 17013 by depositing same in the U. S. Mail, first class postage prepaid. Date: Robe ert Shayka //// !!! J' Certified Legal Intern t. , l Supervising g AAtto ey Geoffrey M. Biringer, Esq. Sup. Ct. I.D. 18040 Harrisburg Civil Law Clinic Widener University School of Law 2300 Varian Way Harrisburg, PA 17110 Tel. (717) 541-0320 C r -c?r7` r Cn , W i_; T _ ?.( ?. 1_i y'!. it ;.?% ? -? _ ? CT -< NA 1 1003 EVELYN KNULL, PLAINTIFF, VS. NEVIN KECKLER, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : DOCKET NO. 99-3998 CIVIL ACTION - LAW ORDER day of • 4lA - j A, 2003, AND NOW, this a*' upon Motion of the Harrisburg Civil Law Clinic, a Rule Absolute is granted and the Harrisburg Civil Law Clinic is permitted to withdraw as proceeding. J. w ?. 0 W R } ? n!a??c ," ?f?.?,i? ? ?? hl? ^ ? ? ? ,.,nJ ? fi r r. ?? ??y 4? il. ?i _??? • n L;': i. EVELYN KNOLL, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, DOCKET NO. 99-3998 VS. NEVIN KECKLER, DEFENDANT : CIVIL ACTION - LAW MOTION FOR RULE ABSOLUTE Movants, Harrisburg Civil Law Clinic, hereby set forth as follows: 1. On January 29, 2003, a Rule was issued giving both parties in the above- captioned proceeding twenty (20) days to show cause why the Harrisburg Civil Law Clinic should not be permitted to withdraw as counsel for the Plaintiff in the above-captioned proceeding. 2. Said Rule was served upon Evelyn Knull and Joseph L. Hitchings Esquire, forthe Defendant via first class mail on January 28, 2003. 3. No one has responded to the Rule to date. WHEREFORE, the Harrisburg Civil Law Clinic requests that this Court enter a Rule Absolute in the above-captioned proceeding permitting the Harrisburg Civil Law Clinic to withdraw as counsel for the Plaintiff. DATE: 3--o)0-03 ROBERT H KA CERTIFI D LEGAL INTERN ?h I f ? GEOFFREY M. BIRINGER ID NO. 18040 WIDENER UNIVERSITY SCHOOL OF LAW HARRISBURG CIVIL LAW CLINIC 2300 VARTAN WAY, 2ND FLOOR HARRISBURG, PA 17110 Evelyn Knull, Plaintiff : In The Court of Common Pleas : Cumberland County, Pennsylvania No. 99-3998 VS. Nevin Keckler, Defendant : Civil Action - Law CERTIFICATE OF SERVICE I, Robert Shayka, Certified Legal Intern for the Harrisburg Civil Law Clinic, and counsel for the above Plaintiff, do hereby certify that on the ;00` day of 2003,1 served a Motion For Rule Absolute on the following people at the following addresses: 1) Evelyn Knull, Plaintiff, at P.O. Box 265, Harrisburg PA 17108- 0265, 2) Joseph L. Hitchings, Esquire, counsel for Defendant, at 26 West High St., Carlisle, PA 17013 by depositing same in the U. S. Mail, first class postage prepaid. Date: 3 - 0?0 - 03 ??G? ` OH /k I Robert Shayka / o Certified Legal Intern Supervising Attorney Geoffrey M. Biringer, Esq. Sup. Ct. I.D. 18040 Harrisburg Civil Law Clinic Widener University School of Law 2300 Vartan Way Harrisburg, PA 17110 Tel. (717) 541-0320 c _ . ?-? ?; - . :i ?? ? r( - . .. ? fV S EVELYN KNULL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff PENNSYLVANIA VS. No. 99-3998 NEVIN KECKLER, Defendant CIVIL ACTION - LAW ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Ms. Evelyn Knull, Plaintiff, in the above-captioned matter. Michael T. Edwards, Certified Legal Intern Elder Law Clinic 150 South College Street Carlisle, PA 17013 717-240-5152 C? ? -' - _ . i l ; .? . G , i- t> Y _... ? ? Y . ;v -? '_. Evel?r, kr\uJ\ vs. IJe- v: r% kec, Ae c- De_ CEN4<& A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Tk-,-:?-kq-j CIVIL 19 RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: (n.,". A T E d.. rc ?S counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of the plaintiff in the action is $ c7, 000 The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. ORDER OF COURT AND NOW, foregoing petition, Esq., and ?c`l?i??r/ l!/GrltL actions) as prayed for. Re spectf ull tt?f f C er4XiQ-1 1,2ygtal M"Ac eN F_Uu LwaJ C_ Iso Soy 4' Cott e S4• Cart,aa tpr Xok3 7t?-140 `515a in co sideration of the /J Cr / Esq., , Esq., are appointed arbitrators in the above captioned action (or By the Court P.J. w ell ?flsdd??,?,SS?l3 AA!no C7 C_: fill ?+ '1