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HomeMy WebLinkAbout99-04614 I 44 V Z %A 'L3 l` C? s r w a, Uj ' fail(: ?'' ?. if J 1-- aC C? q\ CJ P4 O A 3 ooo w a0 lJ e x 44 02 a d a t y,. DENNIS W. HANCOCK AND IN THE COURT OF COMMON PLEAS JEAN D. HANCOCK, OF CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA CIVIL ACTION - LAW No. 994614 Civil Term SHARON K. BRYAN, Jury Trial Demanded Defendant TO: Dennis W. Hancock & Jean D. Hancock c/o Anthony McBeth, Esquire 407 North Front Street Cameron Mansion Harrisburg, PA 17101 You are hereby notified to plead to the within document within twenty (20) days after service hereof, or a default judgment may be entered against you. Respectfully submitted, Q GJ Attorney for Defendant DATE: 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court I.D. #71786 DENNIS W. HANCOCK AND JEAN D. HANCOCK, Plaintiffs SHARON K. BRYAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL. ACTION - LAW No. 994614 Civil Term Jury Trial Demanded DEFENDANT'S ANSWER AND NFW MATTER TOP ADNTDFF'S COMP ATh"^ Defendant, Sharon K. Bryan, by her undersigned attorney, hereby answers Plaintiffs complaint as follows: 1. Admitted. 2. Admitted. 3. Admitted in part. Denied in part. It is admitted that Defendant is an adult individual. It is denied that Defendant resides in Newville, Pennsylvania. To the contrary, Defendant's correct address is 224 B Street, Carlisle, Pennsylvania 17013. 4. Admitted. 5. Denied. To the contrary, Defendant never asked for nor received loans on several occasions. By further answer, Defendant did ask for a single loan of approximately $300 on a "Monday", received same, and repaid that amount on "Friday" of that week. 6. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth or accuracy of these allegations, and therefore said allegations are denied. Denied. To the contrary, the entire loan amount was $300 referred above in paragraph 5. 8. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth or accuracy of these allegations, and therefore said allegations are denied. 9. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth or accuracy of these allegations, and therefore said allegations are denied. 10. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth or accuracy of these allegations, and therefore said allegations are denied. 11. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth or accuracy of these allegations, and therefore said allegations are denied. 12. Denied with regard to the assertion that Defendant received any such sum from Plaintiff. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the accuracy of these allegations pertaining to any obligation that Plaintiff Jean D. Hancock might owe to her bank. 13. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth or accuracy of these allegations, and therefore said allegations are denied. 14. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth or accuracy of these allegations, and therefore said allegations are denied. By further answer, Defendant denies that $2000 was lent to her by Plaintiff. 15. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth or accuracy of these allegations, and therefore said allegations are denied. 16. Denied. To the contrary, the only demands for payment were through Attorney McBeth's office by way of letter dated July 8, 1999 and civil suit served on Defendant on August 4, 1999. 17. Denied. The allegations contained in this paragraph are conclusions of law to which no responsive pleading is required. 18. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth or accuracy of these allegations, and therefore said allegations are denied. 19. Denied. To the contrary, Defendant never promised to pay back Plaintiffs as Defendant never received any money from Plaintiffs other than that referred to in Paragraph 5 above. 20. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth or accuracy of these allegations, and therefore said allegations are denied. 21. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth or accuracy of these allegations, and therefore said allegations are denied. WHEREFORE, Defendant Sharon K. Bryan respectfully requests that this Court enter judgment in its favor, and against Plaintiffs Dennis W. Hancock and Jean D. Hancock for all consequential and incidental damage, including reasonable attorney fees and costs and such other and further relief as this Court deems just and proper. 22. Defendant hereby incorporates paragraphs 1-21 above as if the same were fully set forth herein at length and avers the following: 23. Plaintiff Dennis Hancock on several occasions expressed a romantic interest in Defendant. 24. Plaintiff Dennis Hancock sent Defendant flowers, gave her presents, took her out to dinner, and bought gasoline for Defendant's car. 25. When questioned by Defendant about why suit was filed, Plaintiff Dennis Hancock told Defendant that he had medical bills to pay. 26. Hence, this is a frivolous lawsuit lacking an arguable basis in law and fact. 27. Pursuant to 42 Pa.C.S.A. §8351, Plaintiffs are liable to Defendant for the wrongful use of these civil proceedings. WHEREFORE, Defendant Sharon K. Bryan respectfully requests that this Court enter judgment in its favor, and against Plaintiffs Dennis W. Hancock and Jean D. Hancock for all consequential and incidental damage, including reasonable attorney fees and costs and such other and further relief as this Court deems just and proper. gbj? q I DA J The Law Offices of Paul Bradford Orr 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court I.D. # 71786 Attorney for Defendant I hereby certify that a true and correct copy of the foregoing Answer and New Matter to the following: > ) ? 5 CLA55 MAIL Anthony T. McBeth, Esq. 407 North Front Street Cameron Mansion Harrisburg, PA 17101 Date: 1G3 91 By: Paul Bradford squire VERIFICATION I verity that the statements made in the foregoing Petition 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: Sharon K. Bryan, Defendant e >: Rp o+ C ?_? 111 ?? .?. '_Y?r l7+ `:y. ?? a? _ L ..1 ' y I . .1 L'_ ?.? .. Grp L'. '.J U 1 V '4Pkq9 tct' DENNIS D. HANCOCK and JEAN D. HANCOCK, Plaintiffs V. SHARON K. BRYAN, Defendant IN THE COURT OF COMON PLEAS OF CLTBERLAND COUNTY, PENNSYLVANIA NO. 4614 CIVIL 1999 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: Anthony T. McBeth , counsel for the plaintiffXR*Xg in the above action (or actions), respectfully represents that: 1. The above-captioned action kMX1tk } is BERM at issue. 2. The claim of the plaintiff in the action is $3600.00 The counterclaim of the defendant in the action is_ML The following attorneys are interested in the case(s) as counsel or are other- wise disqualified to sit as arbitrators: Anthony T. McBeth for Plaintiffs, Paul Bradfo d nr• p n v a--f- WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. /Respectfully ubn't-ea, ORDER OF COURT AND NOW, 190L, in consideration of the foregoing petition, 4? Es Esq., and _ _ _ O ,Esq., are appointed arbitrators in the above-captioned action (or actions) as prayed for. By e ? t, P. J. ... r_._ ;:ij f, UI<. L.' I O n' LI C^. C.' 1J ?Tl S L' I-- 1 7 ? u v V SHERIFF'S RETURN - REGULAR CASE NO: 1999-04614 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HA24000K DENNIS W VS. BRYAN SHARON K RICHARD SMITH , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT was served upon BRYAN SHARON K the defendant, at 16:30 HOURS, on the 3rd day of August 1999 at POE: LEAR CORPORATION 50 SPRING ROAD CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to JUSTIN PRINCE (SUPERVISOR) a true and attested copy of the NOTICE AND COMPLAINT and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So answers: 18.00 3.10 .00 8.00 r 1' o7? mas h ine, eri 8T04/199 by Sworn and subscribed to before me this day of 1999 A.D. 'YO oiE1 noary?y C/I O ? cl: C o pqfflo t Z < 6 v DENNIS W. HANCOCK AND IN THE COURT OF COMMON PLEAS OF JEAN D. HANCOCK, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs CIVIL (ACTION/- LAW V. No. 97 - ?61Al- l. /?1lvt SHARON K. BRYAN, Defendant JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse 1 Courthouse Square, Fourth Floor Carlisle, PA 17013 (717) 240-6200 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en Is corte en forma escrita sus defensas o sus objeciones a las medidas y pueda entrar una orden contra sted sin previo aviso o notificacion y por cualquier queja o a -vio que es pedido en la peticion de demanda. Usted puede perder inero o sus propiedades o otros derechos importantes para uste. DENNIS W. HANCOCK AND IN THE COURT OF COMMON PLEAS OF JEAN D. HANCOCK, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs CIVIL ACTION - LAW V. I Q //,, c? SHARON K. BRYAN, No. +? ry?luc? Defendant JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAK E THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFOR D ONE. GO TO OR TELE PHO NE THE OFFICE SE T FORTH BE LOW TO FIND OUT WHERE YOU CAN GET LEG AL HELP, Court Administrator Cumberland County Courthouse 1 Courthouse Square, Fourth Floor Carlisle, PA 17013 (717) 240-6200 NOTICIA Le han demandado a usted en la torte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demands y la notification. Usted debe presenter una apariencia escrita o en persona o por abogado y archivar en la torte en forma escrita sus defensas o sus objeciones a las medidas y pueda entrar una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que as pedido en la petition de demands. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. Court Administrator Cumberland County Courthouse 1 Courthouse Square, Fourth Floor Carlisle, PA 17013 (717) 240-6200 DENNIS W. HANCOCK AND IN THE COURT OF COMMON PLEAS OF JEAN D. HANCOCK, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs CIVIL ACTION - LAW V. 9? C .No. vj,/ v u - SHARON K. BRYAN, Defendant JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff Dennis W. Hancock is an adult individual residing f 204 West Main Street, Walnut Bottom (South Newton Township), Cumberland County, Pennsylvania. 2. Plaintiff Jean D. Hancock is an adult individual, the mother of Plaintiff Dennis W. Hancock, also residing at 204 West Main Street, Walnut Bottom (South Newton Township), Cumberland County, Pennsylvania. 3. Defendant Sharon K. Bryan is an adult individual last known by the Plaintiffs to be residing at 88 East Main Street, Newville, Cumberland County, Pennsylvania. 4. Prior to residing at the Newville, Pennsylvania address described in the previous paragraph, Defendant lived next door to Plaintiffs at 200 West Main Street, Walnut Bottom (South Newton Township) Cumberland County, Pennsylvania. 5. At various times in late 1997 and through the Spring and Summer of 1998, at Defendant's request, Plaintiffs made several cash loans to the Defendant. 6. In each of the several instances when Defendant sought money from the Plaintiffs, Defendant requested a "loan" and Plaintiffs 1 advanced funds to the Defendant with the clear understanding that such advancements did indeed constitute loans. 7. The total of the cash advancements made by Plaintiffs to Defendant was and is Three Thousand Six Hundred ($3,600.00) Dollars. 8. During at least the first transaction that is the subject of this suit, and possibly during other of the transactions, Defendant disclosed to one or both of the Plaintiffs the fact that relatives of hers had refused to lend her money, and that such refusals were the reason that Defendant sought loans from the Plaintiffs. 9. On one of the occasions when Defendant sought funds from Plaintiffs, she requested the precise sum of $2,000.00. 10. In response to that request, one or both of the Plaintiffs informed Defendant that, in order to be able to loan Defendant a sum as large as $2,000.00, Plaintiff Jean D. Hancock would be required to take an advance on a line of credit available to her through her bank. 11. Defendant acknowledged this, and agreed to pay all of the loans back to Plaintiffs at the same interest rate that Plaintiff Jean D. Hancock was and is charged for advances on the line of credit from her bank: 14% per annum. 12. The funds for the $2,000.00 advance made to Defendant, as disclosed earlier, did in fact come from the line of credit that was also described earlier, which Plaintiff Jean D. Hancock is 2 obligated to repay to her bank with interest at the rate of 14% per annum. 13. Plaintiff Dennis W. Hancock customarily reimburses Plaintiff Jean D. Hancock for one-half of the monthly payment that is necessary on the advance from the line of credit that was used to loan funds to the Defendant; as such, Plaintiff Dennis W. Hancock continues to suffer legal damages from Defendant's failure to repay the loan, as does Plaintiff Jean D. Hancock. 14. The advances made to Defendant apart from the $2,000.00 advance that has been described above (the other advances total $1,400.00), came from the personal funds of Plaintiff Dennis W. Hancock. COUNT 1 - BREECH OF CONTRACT 15. The facts set forth in paragraphs one through fourteen are incorporated herein by reference. 16. Despite repeated demands from Plaintiffs, Defendant has failed to and refuses to repay any of the $3,600.00 advanced to her by Plaintiffs. 17. Under the circumstances described herein, Plaintiffs believe and therefore aver that Defendant is obligated to reimburse them not only for the $3,600.00 loan to her in principle sum, but also to reimburse them at the interest rate of 14% per annum, the same interest rate that plaintiff Jean D. Hancock is now obligated to pay to her bank, the institution from which the funds for the majority of the loans to Defendant initially came. 3 WHEREFORE, Plaintiffs request this Honorable Court to enter judgment in their favor and against the Defendant for Three Thousand Six Hundred ($3,600.00) Dollars together with interest at the rate of 148 per annum, the costs of this action and any other relief this Court deems appropriate. COUNT II - RELIANCE 18. The facts set forth in paragraphs one through seventeen are incorporated herein by reference. 19. On most if not all occasions which Plaintiffs made the cash advances to Defendant that have been described above, Defendant promised to repay Plaintiffs. 20. Plaintiffs reasonably relied on the series of Defendant's promises described in the previous paragraph and materially changed their position, both in terms of the actual cash advances to Defendant and Plaintiff Jean D. Hancock's obligation to reimburse her bank with interest at the rate of 148 per annum, all as of a result of their reasonable reliance on Defendant's promises to repay the cash advancements. 21. As a direct result of Plaintiffs' reasonable reliance on Defendant's promises to repay the cash advances - and Defendant's utter failure and refusal to repay the cash advances - Plaintiffs have suffered legal damages as described in the previous count. WHEREFORE, Plaintiffs request this Honorable Court to enter judgment in their favor and against the Defendant for Three Thousand Six Hundred ($3,600.00) Dollars together with interest at 4 the rate of 14% per annum, the costs of this action and any other relief this Court deems appropriate. I?eLlto Date 'Anthony T. eth, Esq. Attorney fQont intiffs 407 North F t., F irst Floor Harrisburg17101 (717) 238-3686 Supreme Court I.D. # 53729 5 VERIFICATION We, Dennis W. Hancock and Jean D. Hancock, Plaintiffs in the foregoing action, verify that the facts set forth in the attached document are true and correct to the best of our knowledge, information and belief. We so state subject to the penalties of 18 Pa. C. S. §4904 (relating to unsworn falsificatiionJ to authorities). a 29, 1999 ennis W. Hancock a ' an D. Hancock n o .a, OD to CO {(I N N vFr4 f0 0 5; v u P: m o a y m ? o 0 U U U N O td o 0 N M O ? M O K • O W co H m H ? I Q co a a a i N .rl ;, coma ? O O H O H Q X H W o A u W x H N 4 E W Q P: H X N E A w X U .?.. Q 4w y 0,4 ¢ X E W .c a ova ? - .q HX? Q H H U ya wVIW UX y H W U Q U ?p U 0.'XN w N X W Q X x W O H H> Q U W axAr H H HW Q a H W n W N U I I I GI i? ?0 ?O CO M [ O O U CO CO co co ?„' N 0 0 0 O 01 O I I k ? C1 ? OI OI IR1, iM N ¢ NII OI li_ ._. '5 It O m O OI m W a MI~INI I c mWI I I I !, rv ,o r r m w.U M m V' Q 99 ? - rv M y'Q _ ? QI I? t pI F O U H I o ? W tt t O . o o i U U i" ' u X o u Q M.?' w ? a t7 '? 5 it M? U U w i U U W W W ¢ 2 .C ? it II Im fit; c Q` m m m m m m I ' O i I, n' O J Kr OLDER SERVICES S FL CA I PB?X 21222 LISA OK 74121.1222 MAKE PAYMENTS PAYABLE TO: DIRECT MERCHANTS BANK MINIMUM PAYMENT DUE PAST DUE AMOUNT PAY BY NEWBALANCE ACCOUNTNUMBER ENTER AMOUNT ENCLOSED 129.00 0.00 09108198 6445.56 5458 0000 4303 0549 ? FORADDRESS CHANGE, CHECK THIS BOXAND COMPLETE THE FORM ON REVERSE SIDE. PAYMENT CENTER DENNIS W HANCOCK PO BOX 17036 204 W MAIN ST BALTIMORE MD 21297-0448 WALNUT BOTTOM PA 17266-9706 I„I,I,.I it ?, I I I I, I, I I I,.I II,.,.I t.l, V I I I„I.,.I I, I 545800004303054900012900006445565 DOMM&W Wan Wa MP PONon in Vw oWosM onvalapa. Basuto NO Payment Cantor nn4toss shorn in onvolopa window. ACCOUNTNUMBER 5458000043030549 0722 0722 SXVX FARMERS AND MERCHANT SHIPPENSBURGPA 0722 0722 CASH ADVANCE FEE 0723 0723 2TSP MELLON BANK 0442SHIPPENSBURG PA _ 0723 0723 CASHADVANCEFEE _ 08/07 00/07 YXAW PAYMENT-THANKYOU 08114 08/14 ACCOUNT PROTECTION PLUS 'FINANCE CHARGE' PURCHASES $72.05 CASH ADVANCE 539.47 TOTAL DEFERRED TOTAL AVAILABLE CASH ADVANCE CASH ADVANCE OVER LIMIT CREDIT LINE BALANCE CREDIT CREDIT LIMIT' AVAILABLE CREDIT AMOUNT 6500 0.00 0 6500 0 0.00 DATEOF REFERENCE NUMBER DESCRIPTION CREDITS CHARGES TRANS. POST. `JW.11114<1 00 ` 1100.00 3. 120.00 - 35.25 111.52 WIN A TRIP TO EVERY MAJOR LEAGUE BASEBALL ALL-STAR GAME FROM 1999.2008 AND $50,000.00 SPENDING MONEYI SIMPLY USE YOUR FINGERHUTMASTERCARD WITH THE ENCLOSED BASEBALL CARD FOR EXCLUSIVE SAVINGS BETWEEN NOW AND 9/30/90. SEE THE ENCLOSED INSERT FOR DETAILS, TERMS AND CONDITIONS. SUMMARY AVERAGE MONTHLY NOMINALANNUAL FINANCE ANNUAL DAILY PERIODIC PERCENTAGE CHARGE PERCENTAGE RATE ACCOUNT SUMMARY BALANCE RATE RATE PURCHASE PURCHASES CASH PREVIOUS BALANCE 4976.79 PURCHASES + 35.25 3684.50 1.850% 22.20% 72.05 22.20% 45.82% CASH ADVANCES + 1400.00 00 CREDITS 0 . CASH # DAYS IN THIS STATEMENT PAYMENTS - 120.00 BILLING CLOSING OTHER + 0.00 2133.61 1.650% 22.20% 81.47 CYCLE DATE FINANCE CHARGE + 153,52 PASTDUE AMOUNT MINIM PAYMEN UM PAY BY T DUE NEW BALANCE 6445.56 0,00 129.0 0 09108198 30 011/ma NOTICE: SEERE VERSESIDE SEND PAYMENTS TO: PAYMEN T CENTER PO BOX 17036, BALTIMORE MD 21297-0448 FOR IM PORTANT MAIL INQUIRIES TO: CARDHOLDE R SERVICES PO BOX 21222, TULSA, OK 74121.1222 INFOR MATION. CARDHOLDER SERVICE CENTER, CALL 800.205.9988 'CASH ADVANCE CREDIT LIMIT IS A PORTION OY YOUH 1VIn R,MW unc. 5984 HYD 1 10 7 Pago toll 6800 0000 F806 980814 OIAA5994 %? 1 C) ? ?_ -t I._ IIJC. N i )..f ? ' C}?:: -i 7 _ '? , ?? I i .: t. ? (_)?. G.. . : .I i L:1- I: i?_. t_t ??, _ I1 C fl <:? ?) IJ r DENNIS W. HANCOCK AND JEAN D. HANCOCK, Plaintiffs V. SHARON K. BRYAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 99-4614 Civil Term JURY TRIAL DEMANDED PLAINTIFFS' REPLY TO DEFENDANT'S NEW NATTER 22. Plaintiffs incorporate the paragraphs of the complaint (1-21) here in by reference. 23. Denied. Although Dennis W. Hancock and Defendant were friends at one time, Dennis W. Hancock never expressed a romantic interest in Defendant. 24. Denied as stated or implied. On one occasion, Dennis W. Hancock did give Defendant flowers on her birthday. Further, nPfPndant and Dennis W. Hancock (often with others) did occasionally take an evening meal at establishments such as Pizza Hut, and Dennis W. Hancock did occasionally by gasoline for Defendant's car. On the relatively few occasions when this occurred, it was always because Defendant complained of having no money, and asked Dennis W. Hancock to pick up the expense then involved. 25. Denied as stated or implied. In the conversation to which Defendant is presumably alluding, Defendant asked Dennis W. Hancock why he had filed suit instead of continuing to wait interminably for Defendant to repay the loan that is the subject of this action. Dennis W. Hancock replied that, because of the diabetes and resulting complications from which he suffers (of which Defendant was and is well aware), he did had to pay certain medical bills and could no longer wait for Defendant to repay the loan at her leisure, which Defendant was not doing, anyway. 26. Denied. This averment is an absurd conclusion of law to which no response is required. 27. Denied. This averment is an absurd conclusion of law to which no response is required. WHEREFORE, Plaintiffs requests this Honorable Court to dismiss Defendant's new matter, grant the relief requested in Plaintiffs' complaint, and provide any other relief this Court deems appropriate. at nt!.on T. cBet Esq. Attorney f Plaintiffs 407 Nort F nt St., First Floor Harrisbu PA 17101 (717) 238-3686 Supreme Court I.D. # 53729 2 VERIFICATION We, Dennis W. Hancock and Jean D. Hancock, Plaintiffs in the foregoing action, verify that the facts set forth in the attached document are true and correct to the best of our knowledge, information and belief. We so state subject to the penalties of 18 Pa. C. S. 54904 (relating to unsworn falsification to authorities). AUGUST 26, 1999 A¢? Date Dennis W. Hancock AUGUST 26. 1999 w L);I iA Date an D. Hancock c In The Court of Common Pleas of Cumberland County, Pennsylvania No. 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 Common- wealth and that we will discharge the duties of our office with fidelity. / Chairman x • u1aM..Y AWARD 47e, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: applicable.) Date of Hearing: 10 , Date of Award: Arbitrator, dissents. (Insert name if NOTICE OF ENTRY OF AWARD Now, the i /T- day of 60 li , 19 `i , at ?' 3 3 .'1., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: rothonotary $ By: Deputy (Note: If damages for delay are awarded, they shall be 4, G t vi 41V w r> F i C- C-: CIQ V `.'Ill L Gam' ?'1 CJ 6 t, q/ -11 1 JQE '9h • r6l \\Av?