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Home My WebLink About99-07453?? ?! O? RONALD A. RILEY : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT M. MRAZ, : NO. 99-7453 EQUITY individually and residing at 3653 CHESTNUT STREET CAMP HILL, PENNSYLVANIA ORDER OF COURT AND NOW, this 20TH day of DECEMBER, 1999, based on the attached petition to proceed In forma pauperis, the request is granted and petitioner may proceed without payment of the costs. By the Edward E. Ronald A. Riley Robert M. Mraz 3653 Chestnut Street Camp Hill, Pa. 1701 1 Ad ?)FC 1 5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RONALD A. RILEY, AK-8743 in his own behalf, PLAINTIFF: C/o 1100 PIKE STREET HUNTINGDON,, PENNSYLVANIA 16652. -VS- ROBERT M. MRAZ, individually and residing at 3653 CHESTNUT STREET,' CAMP HILL, PENNSYLVANIA 17011. DEFENDANT: N 0 T I C E CIVIL ACTION NUMBER ACTION IN EQUITY JURY TRIAL DEMANDED ON ALL TRIABLE ISSUES YOU ARE BEING SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take this action within the next twenty (20) days after this complaint and notice are served by entering an appearance in writing presonally or by Attorney and filing with the Court your objection 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 ent- ered against you by the Court without further notice for any money claimed in the complaint or for any claims of relief requested by the PLAINTIFF. You may lose money or property or other rights im- portant to you. YOU SHOULD TAKE THIS PAPER TO YUOR LAWYER AT ONCE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C l_ -1 r CIVIL DIVISION RONALD A. RILEY, AK-8743, in his own behalf, PLAINTIFF: c/o 1100 PIKE STREET HUNTINGDON,' PENNSYLVANIA 16652. q -VS- ?v . CIVIL ACTION NUM-B.ER,.0 ACTION IN EQUITY JURY TRIAL DEMANDED ON ALL TRIABLE ISSUES ROBERT M. MRAZ, individually and: residing at 3653 CHESTNUT STREET CAMP HILL, PENNSYLVANIA 17011. DEFENDANT: II, . I. J U R I S D I C T I 0 N 1. This Court has exclusive jurisdiction pursuant to Art. 1 § 11, Pa. Const., providing that: "all Courts shall be open; and every man, for an injury done to him in his land, goods, person or reputation shall have remedy by due course of Law; and, rigth and justice administered without 'sale', 'denial' or 'delay'.***', This Court has further jurisdiction pursuant to Art. 1 §26, Pa. Const., and, Rule (s) 2101, 2151, Pa. Rule. Of. Civil. procedure., as relating to State Institutions, political subdivisions, and, partnerships and corporations. PLAINTIFF seeks relief pursuant to Rule (s) 1502, 1503, 1513, 1521 (b)&(c), 1021 (a), and Fraud §1-5 and, as the Law provides under existing Law(s) not mentioned here- in. T 2 I. P A R T I E 2. PLAINTIFF, RONALD A. RILEY, AK-8743, is and was, at all times mentioned herein, an individual citizen of the State of Pennsylvania whose residence is 3653 Chestnut Street, Camp- Hill, Pa 17011-4313, who presently reside at the State Correc- tional Institution at Huntingdon (SCI-H) located at 1100 Pike Street Huntingdon, Pa 16654, where he is serving a term impos- ed for a criminal conviction within said jurisdiction. 3. DEFENDANT, ROBERT M. MRAZ, is and was, at all times mentioned herein, an individual citizen of the State of Penns- ylvania who resides at 3653 Chestnut Street Camp Hill, Pa 170- 11-4313, whose relationship to PLAINTIFF is that of Step-Fath- er, is and was responsible for the caretaking, safe-keeping, protection and upkeeping of the property at the afore-said ad- dress, and everything within it. Said named DEFENDANT is being sued in his individual capscity to the extent he acted as ind- ividual as set forth below. III. F A C T S 1. PLAINTIFF, DEFENDANT MRAZ and PLAINTIFF'S MOTHER, now deceased, did reside at 3653 Chestnut Street Camp Hill, Pa 17011-4313 as family members, and, until the arrest and convi- ction of PLAINTIFF by which he remains confined therefore. For 3 PLAINTIFF'S personal use he aquired sevin (7) Credit Cards which he had sent to his home at the above address during and after his Mothers death. PLAINTIFF verbally informed DEFENDANT MRAZ and his Mother not to use any of said Credit Cards fpr any reason. And to do so would be a violation of existing Laws regulations of this State and Card Provider's. 2. On or about July 5th, 1996, unbeknownst to PLAINTIFF, until resently, DEFENDANT MRAZ knowingly, recklessly, and mal- iciously began charging up debts on all of PLAINTIFF'S seven (7) Credit Cards by verbally and physically forging his name to expenditures unbeknownst to PLAINTIFF and without PLAINTI- FF'S approval and/or consent. 3. PLAINTIFF, whose situation is that of an innocent bys- tander, now stands to lose his good Crsdit, all of his Credit Cards, and is being held liable for debts which he did not in- cur based upon the callous, reckless and deliberate conduct of DEFENDANT MRAZ, forever depriving him of his right to obtain or utilize Credit solely based upon his inability to be prese- nt to have prevented such conduct by DEFENDANT MRAZ solely based on his confinement, in violation of existing Law(s) gov- erning prohibition of such activity by named DEFENDANT. 4. Unbeknownst to PLAINTIFF, DEFENDANT MRAZ had taken PLAINTIFF'S Credit Cards to department stores, ATM machines, and other such places charging debt to PLAINTIFF'S accounts. Said debts incurred by DEFENDANT were not only absent the kno- wledge and/or consent of PLAINTIFF, but absent any material or other benefit by PLAINTIFF as a result of the debts incurred. DEFENDANT MRAZ did deliberately, recklessly and maliciously keep PLAINTIFF in the dark and totally unaware of the situat- ion relating to the fraudulent use of his Credit Cards. 4 5. PLAINTIFF, by the callous, reckless, indifferent and deliberate conduct of DEFENDANT MRAZ, is in a situation where- by he cannot competently and/or adequately asses the actions of DEFENDANT 'MRAZ based upon PLAINTIFF'S lack of all of toe facts surrounding this crime; Additionally, unless, and until PLAINTIFF has in his possession all documentation surrounding said fraudulent use of his Credit Cards, he shall continue to be unable to adequately, meaningfully and/or competently defe- nd himself against this crime perpetrated against him by DEFE- NDANT MRAZ due to his incarceration. IV. L E G A L C L A I M S 6. PLAINTIFF has no adequate, complete and/or alternative remedy at which he can utilize in efforts to correct the acti- ons of DEFENDANT MRAZ to which PLAINTIFF retains his good Cre- dit and Credit Cards. 7. PLAINTIFF shall be irreparably injured in that he shall be left without Credit, and liable for debts incurred by DEFE- NDANT MRAZ whereby he shall forever remain injured unless this Court intervenes and grants to PLAINTIFF that relief sought. V. C 0 U N T 0 N E 8. DEFENDANT MRAZ, through the aforesaid facts, did deli- berately, intentionally, recklessly, and maliciously deceive, 5 mislead and otherwise commit a fraud against PLAINTIFF by tak- ing his Credit Cards and charging them up without his knowled- ge or consent in violation with existing Law(s) prohibiting such conduct. A 9. DEFENDANT NRAZ, through his conduct set forth above and as contained in the aforesaid facts, deliberately, malico- usly, and with specific intent seek to deprive to PLAINTIFF his Credit opportunity by forging his name to documents with- out his knowledge or consent in violation of existing Law(s) prohibiting such conduct. 10. DEFENDANT NRAZ, through the herein mentioned conduct did cause injury to PLAINTIFF by causing PLAINTIFF to be lia- ble for debts at this time not fully disclosed as to the actu- al amount. 11. DEFENDANT NRAZ, through the aforesaid facts, did go into PLAINTIFF'S personal property and stole his Credit Cards for which he committed the above crimes in violation of exist- ing Law(s) prohibiting such conduct. VII. R E L I E F S 0 U G H T 12. WHEREFORE, PLAINTIFF, RONALD A. RILEY, AK-8743, respe- ctfully requests this Court to grant him the following relief, including and not limited to: (a) An Order issuing from this Court whereby the need for swift, prompt and expedient relief by PLAINTIFF compels this 6 Court to expedite discovery and allow PLAINTIFF opotunity to accumulate facts and documentation to support hisrclaims as set forth in his complaint in that PLAINTIFF, an incarFer- ated prisoner, has no other adequate, meaningful or alternat- ive means whereby he can acquire such absent assistance by this Court to prevent his loss of his Credit and Credit Cards based on conduct he is free from fault therefrom; (b) An Order issuing from this Court requiring the off- ice of the District Attorney to inspect, review and/or other- wise examine the facts and record relating to the herein cla- ims listed and explicitly set forth by PLAINTIFF for possible criminal liability and/or prosecution for such liability by named DEFENDANT; (c) Compensatory damages in the amount of Twenty Five Thousand Dollars (25.000.00) assessed against DEFENDANT MRAZ for fraud, deception, theft by deception, forgery, and reck- less and deliberate infliction of emotional distress and ang- uish, anxiety and other trauma imposed thereby which prompt- ed the herein action against said DEFENDANT, and such damages being awarded by this Court upon PLAINTIFF; (d) Punitive damages in the amount of Twenty Five Thous- and Dollars (25.000.00) to insure that named DEFENDANT shall eschew, refrain and prevent from instituting the afore-descr- ibed conduct/practices in the future; (e) DEFENDANT named herein being assessed cost of this action and reimbursing this Court and PLAINTIFF such cost in- curred in the seeking and maintaining this action against him; (f) This Court issuing immediate subpoena which compels 7 DEFENDANT to serve said Court within (3) days after service of the herein complaint all relevant documentation relating to the fraudulent use of PLAINTIFFS Credit Cards, for safe- keeping and access by both PLAINTIFF and relevant Law-Enfor- cement personnel specifically set forth in §'s (a)&(b), sup- ra; (8) Such other and further relief as this Court may de- em just, adequate and equitable. DATED: December 10th, 1999. .n., ...m IT nli !t o .Pj 4IMPLAINT REINSTATED vo-. a... hta4 ... .j:.. ...,,.. ,...... PROTHON6TAW RONALD A. RILEY : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT M. MRAZ, NO. 99-7453 EQUITY individually and residing at 3653 CHESTNUT STREET CAMP HILL, PENNSYLVANIA AND NOW, this 20TH day of DECEMBER, 1999, based on the attached petition to proceed In forma pauperis, the request is granted and petitioner may proceed without payment of the costs. Ronald A. Riley Robert M. Mraz 3653 Chestnut Street Camp Hill, Pa. 17011 By the Edward E. Guido, J. 1 4Q L O? /YY2.d -a 1-99 R Ks :sld I, d Di r I? i{ I m DEC 1 5 199 IN THE COURT OF COM1ION PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD A. RILEY, AK-8743 in his own behalf, PLAINTIFF: ' CIVIL ACTION NUMBER a U IL-3 -VS- ACTION IN EQUITY JURY TRIAL DEMANDED ON ALL TRIABLE ISSUES ROBERT M. MRAZ, individually and residing at 3653 CHESTNUT STREET CAMP HILL, PENNSYLVANIA 17011. DEFENDANT: PLAINTIFF RILEY'S MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS. TO THE ABOVE COURT: Plaintiff in the above action, RONALD A. RILEY, AK-8743, "pro se", now respectfully request this Court for leave to pro- ceed in the herein matter in forma pa uperis, without prepayment of fees or cost thereof and/or posting of security therefore be- cause, as his below affidavit in support hereof indicates, he is unable to pay cost of this action and/or to post security there- fore. WHEREFORE, named PLAINTIFF respectfully seeks this Court to grant him leave to proceed herein as a pauper espectfu ?ymtte , LAINTIF ro se 1100 PI E STREET HUNTINGDON, PA. 16654 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD A. RILEY, AK-8743 in his own behalf, PLAINTIFF: CIVIL ACTION NUMBER a -VS- ACTION IN EQUITY JURY TRIAL DEMANDED ON ALL TRIABLE ISSUES ROBERT M. MRAZ, individually and residing at 3653 CHESTNUT STREET CAMP HILL, PENNSYLVANIA 17011. DEFENDANT PLAINTIFF RILEY'S AFFIDAVIT IN SUPPORT OF MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS. STATE OF PENNSYLVANIA COUNTY OF HUNTINGDON I, RONALD A. RILEY, AK-8743, hereby declare under the penalty of perjury that the foregoing facts and statements made in support of my request for leave to proceed with this action before this Court in forma pauperis is both true and correct and made upon my personal knowledge, information and belief, to the extent that I have knowledge thereof. And, that I am confind in a State Correctional Institution under service of a term of imp- risonment whereby my ability to otherwise proceed with this act- ion is severely hampered and disabled as one similar situated in the societal portion of this State would so be able to proceed i? 2 in the same instance. I further believe that, unless this Court grant me leave to proceed in forma pauper is with m nst the DEFENDANT, I shall lose my action agai- ? have my entitlements and rights to 1 Cradit Cards and good Credit in this State, which is the focal point of my action before this Court. I further assert and aver that the answers to the following questions are correct and accurate: 1. I am the PLAINTIFF, in the above matter and because of my financial conduction I am unable to pay the fees and cost of ceeding or defending this action. pro- 2. I am unable to obtain funds from anyone, including my family and associates, to pay the cost of litigation. 3. I represent that the information below relating to my ability to pay the fees and cost is true and correct: (a) NAME: Ronald A. Riley, AK-8743 ADDRESS:SCI-HUNTINGDON, 1100 PIKE STREET HUNTINGDON, PA, 16654, SOCIAL SECURITY NUMBER: #166-46-2854 (b) EMPLOYMENT: PLAINTIFF is presently incarcerated and make .190 per hour which is approximately $27,00 per month which PLAINTIFF use for basic necessities. (c) OTHER INCOME WITHIN THE LAST TWELVE (12) MONTHS: BUSINESS OR PROFESSION: None OTHER SELF-EMPLOYMENT: None INTEREST: None DIVIDENDS: None PENSION(S): None SOCIAL SECURITY BENEFITS: None 3 SUPPORT PAYMENTS: None DISABILITY PAYMENTS: None UNEMPLOYMENT COMPENSATION & SUPPLEMENTAL BENEFITS: None WORK'S COMPENSATION: None PUBLIC ASSISTANCE: None OTHER: None (d) OTHER CONTRIBUTIONS TO HOUSEHOLD SUPPORT: Not applicable (e) PROPERTY OWNED: Possess interest in property at 3653 Chestnut Street Camp Hill, Pa. 17011. CASH: None CHECKING ACCOUNT: None SAVING ACCOUNT: None CERFIFICATES(s) OF DESPOSIT: None REAL ESTATE: Property at 3653 Chestnut Street Camp Hill, Pa 17011. MOTOR VEHICLE: None STOCK, BONDS: None (f) DEBTS AND OBLIGATIONS: None MORTGAGE: None RENT: None LOAN(s): None OTHER: None (g) PERSON(s) DEPENDENT UPON YOU FOR SUPPORT: None (WIFE)(HUSBAND) NAME: Not applicable CHILDREN, if any: None OTHER PERSON(S): None NAME: RELATIONSHIP: 4. I understand that I have A continuing obligation to inform the Court of improvement of my financial situation/circumstances 4 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 further understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. DATED: becember 10th, 1999 /S/..? aei _ PAGE 2 INMATE ACCOUNTS SYSTEM FA MONTHLY ACCOUNT STATEMENT INMATE NAME NUMBER LAST FIRST MI AKS743 RILEY RONALD A BATCH DATE f MO DY YEAR TRANSACTION DESCRIPTION 538 11-16-1999 38 INSIDE PURCHASES XEROX COPIES-10 NOVEMBER 1999 538 11-16-1999 38 INSIDE PURCHASES XEROX COPIES-12 NOVEMBER 1999 I NEW BALANCE AS OF THIS STATEMENT ------ 11-18-1999 1448H TRANSACTION BALANCE AFTER AMOUNT TRANSACTION -1.70 -10.91 -2.80 -13.71 ----------> -13.71 '• PAGE 1 INMATE ACCOUNTS SYSTEM ® 11-18-1999 FA MONTHLY ACCOUNT STATEMENT s 1447H INMATE NAME NUMBER LAST FIRST MI OLD BALANCE AK8743 RILEY RONALD A 2.21 BATCH DATE MO DY YEAR TRANSACTION DESCRIPTION TRANSACTION BALANCE AFTER AMOUNT TRANSACTION 386 10-25-1999 38 INSIDE PURCHASES XEROX COPIES-4 OCTOBER 1999 -8.20 -5.99 398 10-26-1999 37 POSTAGE LEGAL - OCTOBER 25, 1999 -.22 -6.21 396 10-26-1999 38 INSIDE PURCHASES XEROX COPIES-15 OCTOBER 1999 -9.60 -15.81 396 10-26-1999 38 INSIDE PURCHASES XEROX COPIES-15 OCTOBER 1999 -.50 -16.31 402 10-27-1999 38 INSIDE PURCHASES XEROX COPIES-18 OCTOBER 1999 -4.30 -20.61 402 10-27-1999 38 INSIDE PURCHASES XEROX COPIES-20 OCTOBER 1999 -1.60 -22.21 402 10-27-1999 38 INSIDE PURCHASES XEROX COPIES-21 OCTOBER 1999 -.30 -22.51 402 10-27-1999 38 INSIDE PURCHASES XEROX COPIES-21 OCTOBER 1999 -1.20 -23.71 435 11-01-1999 37 POSTAGE 1999 28 _ 2.75 -26.46 , LEGAL - OCTOBER 435 11-01-1999 37 POSTAGE 1999 -1.21 -27.67 LEGAL - OCTOBER 27, 455 11-04-1999 38 INSIDE PURCHASES ER 1999 -1.80 -29.47 XEROX COPIES-25 OCTOB 455 11-04-1999 38 INSIDE PURCHASES R 1999 -.30 -29.77 XEROX COPIES-26 OCTOBE 455 11-04-1999 38 INSIDE PURCHASES 10 - -29.87 XEROX COPIES-27 OCTOBER 1999 . 455 11-04-1999 38 INSIDE PURCHASES 1999 -4.60 -34.47 XEROX COPIES-28 OCTOBER 484 11-09-1999 30 MAINTENANCE PAYROLL 28 00 -6.47 OCTOBER 1999 . 492 11-09-1999 37 POSTAGE 1999 _77 . -7.24 LEGAL - NOVEMBER 5, 492 11-09-1999 37 POSTAGE 77 _ -8.01 LEGAL - NOVEMBER 5, 1999 516 11-15-1999 38 INSIDE PURCHASES ER 1999 -.40 8.41 -8.41 XEROX COPIES-1 NOVEMB 516 11-15-1999 38 INSIDE PURCHASES BER 1999 -•20 8.61 -8.61 XEROX COPIES-3 NOVEM 516 11-15-1999 38 INSIDE PURCHASES - 20 8,81 -8.81 XEROX COPIES-4 NOVEMBER 1999 . 516 11-15-1999 38 INSIDE PURCHASES 10 -2 -10.91 XEROX COPIES-5 NOVEMBER 1999 . 530 11-15-1999 30 MAINTENANCE PAYROLL 7 60 -3.31 OCTOBER, 1999 , 538 11-16-1999 38 INSIDE PURCHASES 1999 -5 90 -9.21 XEROX COPIES- 8 NOVEMBER . OF CORREC PA DEPT TIONS INMATE ACCOUNTS SYSTEM RUN IAS365 BUREAU . OF COMPUTER SERV ICES PARTIAL ACCOUNT LISTING DATE 10/20/1999 REMOTE PRINT TIME 15:04 FROM ACTIVE FILE PAGE 2 INMATE NAME NUMBER LAST FIRST MI AK8743 RILEY RONALD A TRANSACTION BALANCE AFTER BATCH # DATE MO DY YEAR TRANSACTION DESCRIPTION AMOUNT TRANSACTION 49 08-31-1999 37 POSTAGE 2 66 LEGAL - AUGUST 31, 1999 -.99 . 49 08-31-1999 37 POSTAGE AUGUST 31, 1999 99 1.67 114 09-10-1999 10 MAINTENANCE PAYROLL AUGUST 1999 18.62 20.29 121 09-13-1999 37 POSTAGE LEGAL - SEPTEMBER 13, 1999 -3.20 17.09 136 09-14-1999 39 LEGAL FEES DAUPHIN COUNTY ACT 84 -3.72 13.37 8257 09-14-1999 32 HUN COMMISSARY FOR 9/14/1999 13.20 .17 192 09-22-1999 37 POSTAGE LEGAL - SEPTEMBER 21, 1999 -.99 -.82 192 09-22-1999 37 POSTAGE LEGAL - SEPTEMBER 21, 1999 -.99 -1.81 245 09-29-1999 38 INSIDE PURCHASES XEROX COPIES-21 SEPTEMBER 1999 -3.40 -5.21 278 10-05-1999 38 INSIDE PURCHASES XEROX COPIES WK ENDING 10/2/99 -4.30 -9.51 283 10-06-1999 37 POSTAGE LEGAL - OCTOBER 4, 1999 -1.65 -11.16 283 10-06-1999 37 POSTAGE LEGAL - OCTOBER 4, 1999 -1.65 -12.81 323 10-13-1999 10 MAINTENANCE PAYROLL SEPTEMBER 1999 27.93 15.12 352 10-19-1999 39 LEGAL FEES OCT 1999 PAYMENT ACT 84 -5.59 9.53 357 10-19-1999 37 POSTAGE OCTOBER 16, 1999 -1.65 7.88 357 10-19-1999 37 POSTAGE 1999 OCTOBER 18, -.22 7.66 357 10-19-1999 37 POSTAGE OCTOBER 16, 1999 LEGAL -3.80 3.86 357 10-19-1999 37 POSTAGE OCTOBER 18, 1999 LEGAL -1.65 2.21 BALANCE AFTER THESE TRANSACTIONS ------ > 2.21 PA DEPT. OF CORRECTIONS INMATE ACCOUNTS SYSTEM RUN IAS365 BUREAU OF COMPUTER SERVICES PARTIAL ACCOUNT LISTING DATE 10/20/1999 REMOTE PRINT TIME 15:04 FROM ACTIVE FILE PAGE 1 INMATE NAME NUMBER LAST FIRST MI STARTING BALANCE AK8743 RILEY RONALD A -13.13 BATCH DATE TRANSACTI ON BALANCE AFTER # MO DY YEAR TRANSACTION DESCRIPTION AMOUNT TRANSACTION 7678 07-06-1999 13 PERSONAL GIFT FROM LAYTON, NINA (900537) 25.00 11.87 7723 07-12-1999 39 LEGAL FEES PROTHONOTARY -9.00 2.87 7725 07-12-1999 10 MAINTENANCE PAYROLL JUNE, 1999 15.79 18.66 7735 07-13-1999 38 INSIDE PURCHASES XEROX COPIES WK ENDING 7-11-99 -2.00 16.66 7740 07-14-1999 13 PERSONAL GIFT FROM LAYTON, NINA (886767) 25.00 41.66 7770 07-16-1999 32 COMMISSARY JULY 16, 1999 -3.20 38.46 7775 07-19-1999 39 LEGAL FEES ACT 84 PAYMENT JULY 1999 -13.15 25.31 7788 07-20-1999 14 MISCELLANEOUS INST CK (PROTHONOTARY) (724860) 9.00 34.31 7827 07-23-1999 37 POSTAGE LEGAL - JULY 22, 1999 -1.59 32.72 7827 07-23-1999 37 POSTAGE LEGAL - JULY 22, 1999 -.99 31.73 7827 07-23-1999 37 POSTAGE LEGAL - JULY 22, 1999 -.99 30.74 7832 07-23-1999 32 COMMISSARY JULY 23, 1999 -22.70 8.04 7839 07-26-1999 37 POSTAGE LEGAL - JULY 24, 1999 -1.81 6.23 7852 07-28-1999 37 POSTAGE LEGAL - JULY 26, 1999 -.33 5.90 7861 07-28-1999 38 INSIDE PURCHASES XEROX COPIES-WK ENDING 7/24/99 -1.30 4.60 7926 08-06-1999 32 COMMISSARY AUGUST 6, 1999 -2.43 2.17 7943 08-12-1999 10 MAINTENANCE PAYROLL JULY 1999 27.93 30.10 7967 08-16-1999 39 LEGAL FEES ACT 84 PAYMENT AUGUST 1999 -5.58 24.52 8231 08-19-1999 32 HUN COMMISSARY FOR 8/20/1999 -13.68 10.84 22 08-25-1999 37 POSTAGE AUGUST 25, 1999 -.55 10.29 8239 08-27-1999 32 HUN COMMISSARY FOR 8/27/1999 -5.65 4.64 49 08-31-1999 37 POSTAGE LEGAL - AUGUST 31, 1999 -.99 3.65 J PA DEPT. OF CORRECTIONS INMATE ACCOUNTS SYSTEM BUREAU OF COMPUTER SERVICES PARTIAL ACCOUNT LISTING REMOTE PRINT TIME 15:04 FROM PURGE INMATE NAME FIRST MI NUMBER LAST RONALD A AK8743 RILEY RUN IAS365 DATE 10/20/1999 PAGE 3 BATCH DATE TRANSACTION BALANCE AFTER ESCRIPTION AMOUNT TRANSACTION # MO DY YEAR TRANSACTION D 7652 06-30-1999 37 POSTAGE 55 -12.03 JUNE 28, 1999 . 7652 06-30-1999 POST 37 A 55 -12.58 28, 1999 UNE J 7652 06-30-1999 37 A 55 -13.13 28, 1999 JUNE BALANCE AFTER THESE TRANSACTIONS ------ > -13.13 ;I PA DEPT. OF CORRECTIONS BUREAU OF COMPUTER SERVICES REMOTE PRINT TIME 15:04 INMATE NAME NUMBER LAST AK8743 RILEY BATCH DATE INMATE ACCOUNTS SYSTEM PARTIAL ACCOUNT LISTING FROM PURGE FILE FIRST MI RONALD A # MO DY YEAR TRANSACTION DESCRIPTION RUN IAS365 DATE 10/20/1999 PAGE 2 TRANSACTION BALANCE AFTER AMOUNT TRANSACTION 0 05-19-1999 82 TRANSFER OUT HUNTINGDON 0 05-19-1999 81 TRANSFER IN PITTSBURGH 2660 05-19-1999 11 INDUSTRIES PAYROLL TRANSFER WAGES - SCIH 17.22 39.20 0 05-19-1999 82 TRANSFER OUT PITTSBURGH 0 05-19-1999 81 TRANSFER IN HUNTINGDON 7409 05-27-1999 32 COMMISSARY MAY 26, 1999 -35.61 3.59 7448 06-02-1999 37 POSTAGE 27 MAY 1998 -.77 2.82 7476 06-07-1999 13 PERSONAL GIFT FROM LAYTON, NINA (725761) 25.00 27.82 7487 06-08-1999 10 MAINTENANCE PAYROLL MAY 1999 9.36 37.18 7495 06-09-1999 38 INSIDE PURCHASES LIBRARY-WK ENDING JUNE 5, 1999 -1.20 35.98 7510 06-10-1999 32 COMMISSARY JUNE 9, 1999 -12.28 23.70 7520 06-11-1999 37 POSTAGE JUNE 10, 1999 -1.65 22.05 7532 06-14-1999 37 POSTAGE LEGAL - JUNE 14, 1999 -.55 21.50 7532 06-14-1999 37 POSTAGE LEGAL - JUNE 14, 1999 -.55 20.95 7532 06-14-1999 37 POSTAGE JUNE 14, 1999 -.22 20.73 7545 06-15-1999 44 ORGANIZATIONAL ALTAR ROCK JAYCEE JUNE 1999 -3.50 17.23 7551 06-15-1999 38 INSIDE PURCHASES XEROX COPIES- WEEK ENDING 6-12 -3.60 13.63 7564 06-17-1999 37 POSTAGE LEGAL - JUNE 16, 1999 -.99 12.64 7554 06-17-1999 37 POSTAGE LEGAL - JUNE 16, 1999 -.99 11.65 7564 06-17-1999 37 POSTAGE JUNE 16, 1999 -.55 11.10 7563 06-17-1999 32 COMMISSARY JUNE 16, 1999 -17.68 -6.58 7637 06-28-1999 38 INSIDE PURCHASES QEROX COPIES - WK ENDING 6-19 -4.90 -11.48 ?b } lt. }- 1= '? i C.'. ? ? ?i. :L": '_;1 f7Y.. u.. ' ?_'1 ._ C' t L C._ 1" ? ? ? C.'t G? CJ . y JAN 0 5 2000 RCNALD A. RILEY AK-8743 1100 PIKE STREET HUNTINGDON, PA 16654 EDWARD E. GUIDO JUDGE ONE COURTHOUSE SQUARE CARLISLE, PA 17013-3387 January 1, 2000 RE: CIVIL ACTION 99-7453 TO THE HONORABLE EDWARD E. GUIDO JUDGE; Honorable Judge, as you know, on December 10th, 1999, I filed a Civil Action with a forma pauper is attached against the Defendant in the above case. On December 31st, 1999, 6g hours before I received my Civil Action back from you granting Plaintiff forma pauperis status via mail Captain Levy (Security Captain) at the State Correctional Institution Huntingdon at 9:30 AM. called me up to his office and gave me a Direct Order not to litigate against Defendant Robert M. Mraz in any kind of way. Additionally, that to make sure that I do not do any of the above my mail will be monitored by this Institution. Honorable Judge, all of my actions in this matter has been Lawful, and to deny me by way of giving me A Direct Order not tocontact or litigate against the Defendant is A violation of my 14th Amendment Right to due process of Law. If the Defendant in this case has an Attorney please give me his name and address 1 and I will litigate with him. If not, please stop this Institution from trying to deny me the right to litigation in the above Civil Action that is now before your Court. 2 a HUNTINGDON, rA iDD74 PYS510 Cumberland County Prothonotary Civil C 's Office Page 1 ase Inquiry 1999-07453 RILEY RONALD A (vs) MRAZ ROBERT M Reference No : .. Case Ty e.....: COMPLAINT - EQUITY d t Filed........: Time 12/13/1999 Ju gmen . . . . . . : 00 Judge Assigned: .........: Execution Date 1:56 0/00/0000 Disposed Desc.: Jury Trial.... ---- -------- Case Comments ------------- Disposed Date. Hi her C t 1 0/00/0000 g r .: Higher Crt 2.: General Index Attorney Info RILEY RONALD A PLAINTIFF PRO SE C/O 1100 PIKE STREET AK-8743 HUNTINGDON PA 16652 MRAZ ROBERT M DEFENDANT 3653 CHESTNUT STREET CAMP HILL PA 17011 * Date Entries 12/13/1999 COMPLAINT - EQUITY FIRST ENTRY ------------- --------------------- 12/13/1999 PRAECIPE TO PROCEED-IN-FORMA - PAUPERIS ------------------------------ ------------------------------- ----------------------------- 13/1999 AFFIDAVIT-SUPPORTING-PETITION - FOR - LEAVE - TO - PROCEED - INFORMA - PAUPERIS ----- ------- 12/21/1999 ORDER-OF-COURT--12/20/99 BAISED ON ATTACHED PETITION TO PROCEED---- IN FORMA PAUPERIS RE UEST IS FRANTED AND PETITIONER MAY PROCEED WITHOUT PAYMENT OF TH? COSTS EDWARD E GUIDO JUDGE COPIES MAILED 12/21/99 - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - - - * End of Case Information ;J ¢ "byn COMMONWEALTH OF PENNSYLVANIA NINTH JUDICIAL DISTRICT CUMBERLAND COUNTY EDWARD E. GUIDO JUDGE Ronald A. Riley AK 8743 1100 Pike Street Huntingdon, Pennsylvania 16654 January 28, 2000 IN RE: 99-7453 EQUITY TERM Dear Mr. Riley: COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013.3387 (717) 240.6290 FAX (717) 240.6462 In response to your letter of January 1, 2000, please be advised that you may proceed in the above referenced matter as per my order of December 20, 1999. Any future correspondence in this matter should be addressed to the Prothonotary's office at I Courthouse Square, Carlisle, Pa. 17013. Sine y, Edward E. Guido EEG/sld RONALD A. RILEY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT M. MRAZ, NO. 99-7453 EQUITY individually and residing at 3653 CHESTNUT STREET CAMP HILL, PENNSYLVANIA AND NOW, this 22 day of DECEMBER, 1999, based on the attached petition to proceed In forma pauperis, the request is granted and petitioner may proceed without payment of the costs. Ronald A. Riley Robert M. Mraz 3653 Chestnut Street Camp Hill, Pa. 17011 :sld By the Cou , Edward E. Guido, J. i /j a1-99 R Ks SEP 2 7 2002 v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA RONALD A. RILEY PLAINTIFF VS. ROBERT M. MRAZ DEFENDANT , ORDER CIVIL ACTION EQUITY NO . 99-7453 AND NOW, this day of V 2902, after review of the below Plaintiff's Motion For Continuance, it is hereby ORDERED and ADJUDGED that w .? Gc. % ?O'/1Lf1 /? /?? ??./ ??c Ca/ey /o •G1 61. Co?.?glm,iv:s7?f R a V I i Iii I- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA RONALD A. RILEY PLAINTIFF VS. ROBERT M. MRAZ , DEFENDANT CIVIL ACTION EQUITY NO. 99-7453 MOTION FOR CONTINUANCE TO THE HONORABLE EDWARD E. GUIDO, JUDGE: Plaintiff in the above action Ronald A. Riley, AK-8743, 11pro-sell now submits his Motion For Continuance. Plaintiff asserts as set forth below: 1. On December 10, 1999, Plaintiff filed an Equity Action No. 99-7453 against Defendant for going into Plaintiff's property at his home removing and using several of his credit cards without his knowledge or permission. 2. On several occasions Plaintiff attempted to effect service upon Defendant to no avail as Plaintiff is incarcerated where he has resided throughout this action. 3. On December 23, 2002, Plaintiff will be released from incarc- eration at which time he shall have the above docketed action reinstated by the Prothonotary and effect service in person on Defendant. WHEREFORE, Plaintiff resFectfully requests this Honorable court to continue this Equity Action until January 2, 2003, as Plaintiff will not be able to attend the proceedings held in October 22, 2002, as Plaintiff is still incarcerated and will not be released until December 23, 2002• RespectWTly' upm P, 743 ona d A. R ley, plaintiff/Pro 1100 pike 5 set Huntingdon, PA 18654-1112 ?? 77 pATEO: VERIFICATION I verify that the statements made in the foregoing Motion For Continuance are true and correct based upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. ?ATEO: _/ / ? aa-7Z '. L:l 'Jli] C.0 CC1Cj- ?j cv j c U ?(W-9 vs. hi A44 In the Court or Common Pleas or pCumberland County, Pennsylvania No. 9i - ;? Y, S Civil. 19 99 15+S- ! To 7 Prothonoutry n w. ; h No Term, 19 _ VS. PRAECIPE 19 Atty. 1 ? ,yr1? r_1 APR 2 0 200 RONALD A. RILEY AK-8743 1100 PIKE STREET HUNTINGDON, PA. 16654 RICHARD J. PIERCE COURT ADMINISTRATOR 1 COURTHOUSE SQUARE CARLISLE, PA. 17013-3387 April 14, 2000 RE: CIVIL ACTION NO. 99-7453 Dear Mr. Pierce, On January 13, 2000, I served a copy of Plaintiff's Civil Action In Equity No. 99-7453 upon Defendant ROBERT M. PIRA2 by way of his Attorney pursuant to Rule 400 (b) Pa. Rule. Of. Civil. Pro- cedure. (Exhibit A.). On February 7, 2000, I served Notice Of Praecipe To Enter Judgment By Default upon Defendant PIRAV S Attorney. (Exhibit B.). On February 17, 2000, I filed a Praecipe To Enter Default Judgment with CURTIS R. LONG Prothonotary . On March 1, 2000, CURTIS R. LONG Prothonotary returned my Praecipe indicating that I must correct both Certificates of Ser- vice, and reflect the Certification (Pa. RCP 237.1). (Exhibit C.). }. J 2 On March 8, 2000, I filed another Praecipe To Enter Default Judgment with the corrections requested by CURTIS R. LONG Prothon- otary. (Exhibit D.). On April 7, 2000, CURTIS R. LONG again denied my Praecipe To Enter Default Judgment stating that I did not serve my Complaint and filed no important notice. (Exhibit E.). Mr. PIERCE, I have complied with the Rules Of Civil Proced- ure in this matter and entitled to the Entry Of Default Judgment against the Defendant in this case. Lastly, it would be greatly appreciated if you would inform the Prothonotary to sign all of his letter's/communications to me. DATED:V-1Z_jZ1G)vJ Respectfully S bmitted, NALD A. RIL- 8743 /PLAINTIFF ro 1100 P RE ET HUNTINGDON, PA 16654 E X 11 I B Z T (A). RONALD A. RILEY AK-8743 1100 PIKE STREET HUNTINGDON, PA 16652 BALABAN & LUCAS, LLP. 121 state street P.O. BOX. 821 HARRISBURG, PA 17108-0821 MR. LUCAS, January 13, 2000 On January 12, 2000, I was informed by my counselor . (Ms. Heather Haldeman) at The State Correctional Institution Huntingdon, that you contacted this Institution informing them of the fact that you represent Robert M. Mraz in the Action in which he is being accused of two (2) counts of Forgery and one (1) count of Theft of my personal credit cards. As Counsel for Mr. Mraz I am serving you with A copy of my Action In Equity No. H99-7453-Civil pursuant to RULE 400 (b) Pa. Rule. Of. Civil.- Procedure.. I trust that you will see that your client (Mr. Mraz) receive this Complaint. Swora?nd wbe?fibed WaYV me We ...1.2.....day of -d7iwor..t).......asca MY C0Wj1*n ??? cam l lrp4er JaR b ? cc:RAR/File Enclosure yi' E X B I B Z T (B). IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD A. RILEY, AK-8743, in his own behalf, PLAINTIFF: _VS_ ROBERT M. MRAZ, DEFENDANT: CIVIL ACTION 90. 99-7453 EQUITY TERM NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT. TO: MR. ROBERT M. MRAZ: YOU ARE IN DEFAULT BECAUSE YOU FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PRO- PERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LA14YER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLL014ING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. .e n, • ? ?L? 2 LA14YER REFERRAL SERVICE CUMBERLAND COUNTY COURTHOUSE FORTH FLOOR CARLISLE, PA. 17013 DATED: g2 Z ?ooo PLAINTIFF o se 1100 P STREET HUNTINGDON, PA 16654-1112 CERTIFICATION OF SERVICE This is to certify that, on 22 - 7 -,? ooo service of a true and correct copy of the Notice Of Praecipe To Enter Judgm- ent By Default was served upon all parties and counsel as per Rule 237.1 Pa. Rule. Of.. Civil. Procedure. First Class, and, by placing said copy in my prison mail for service at the below address: BALABAN & LUCAS, LLP. 121 STATE STREET P.O. BOX. 821 HARRISBURG, PA 17108-0821 Respectfyflly §_ktb<itteSV, MA I N T I F F ry?y?e 1100 PIKE REET HUNTINGDON, PA 16654 E X B I B I T (C) Curtis R. Long Prothonotary ®ffire of the'rotoonotarp (fumberfAnb Cnuntp Date March 1, 2000 Ronald A. Riley: T-G -WHGM--I-TF -4A-1--GGNC-&RN-: Shirley A. Peiper Deputy Prothonotary John E. Slike Solicitor We are returning the enclosed transaction(s) for the following should be S Must provide duplicate copies of the proposed judgment, decree or order and stamped envelopes addressed to the said persons and/or attorneys for notification. Please note: This notification is not a substitute for service of process. reflect the cprtifiration (Pa RCP 277 1)reason(s): * Other reasons You must r r eCt bc)th rprtifiCate-q of Service, They do n nt ctatp what was. mailpriVonr orapri Lie for dpfAuli- must, i ap = Incorrect fee received $ * Need signature * Note: All transactions directed to this office must include a SELF ADDRESSED ENVELOPE WITH POSTAGE if a return receipt or certificate is desired. PAYMENT or FEE at time of filing will be required in every instance. CURTIS R. LONG PROTHONOTARY Deputy Prothonotary One Courthouse Syuarc • Carlisle, Pennsylvaniu 17013 • (717) 240-6195 • fax (717) 240.6573 . `e? E X EI I B I T (D). IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RONALD A. RILEY, AK-8743, in his own behalf, PLAINTIFF: _VS_ ROBERT M. MRAZ, DEFENDANT: CIVIL ACTION NO. 99-7453 EQUITY TERM PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter a Default Judgment against Defendant Robert M. Mraz in the amount of $50,000.00 as requested in Pla- intiff's Complaint filed above, due to Defendant's failure to answer or otherwise plead to Plaintiff's Complaint. A copy of the Proof Of Service Of The Complaint In Equity is attached he- reto. Also find attached hereto is a copy of the notice to enter Judgment By Default along with a certification Of Service purs- uant to Pa. Rule. Of. Civil. Procedure., 237.1. DATED: March 8, 2000 Respect KUNALD A Y, AK- PLAI pro se 110 IKE STREET HUNTINGDON, PA 16652 3 VERIFICATION STATE OF PENNSYLVANIA COUNTY OF HUNTINGDON I, RONALD A. RILEY, AK-8743, declare under the penalties set forth under 18 Pa. C.S.A. §4904, (Unsworn fal- sification to authorities) that the foregoing fact as set forth in my Praecipe To Enter Default Judgment is both true and corr- ect, and made upon my personal knowledge and belief. DATED: March 8, 2000 CERTIFICATION OF SERVICE This is to certify that, on March 8, 2000, service of a true and correct copy of the Praecipe To Enter Default Judgment upon all parties and counsel as per Rule 237.1 Pa. Rule. Of. Ci- vil. Procedure. First Class, and, by placing said copy in my pri- son mail for service at the below address: BALABAN & LUCAS, LLP 121 STATE STREET P.O. BOX 821 HARRISBURG, PA 17108-0821 Respectf n ted RONALD A. RIL AK-tl/43 PLAINTIFF se 1100 PIK STREET HUNTINGDON, PA 16654-1112 7-1, 1 ," 5 ! i t \?o! y `r ??t oP o r S iO jj", I =d a J 5 I I 1 i ? W a H N a e A ? a ¢ I _d a Z ` O CO c x s ° ? m a n• c E E ° - z z ? x FP 1 r - 4, i 00 m _ C W cn o a W F 6 o _- F U 6 S h C4 CZ Cr WF[q - ;i H cn Q. H W 6 = I - ? H a - ti:Z: O - asW A ¢ E~ a j x a cn I ¢ E S H ScL'O .1 Ua UrX . ' ' r-1O ¢ N 1 1 N I N I , `A M 1? M • I i r' a O Q O U ?. S 0 a w O i I a i . r m ' I I } E X H I Q I T (E). J Curtis R. Long Prothonotary ®ffice of the Protbonotarp Cumber[anb County April 7, 2000 Mr. Ronald A. Riley AK-8743 1100 Pike Street Huntingdon, PA 16654 Dear Mr. Riley; Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor I received your letter requesting to enter a Default Judgment, however you have no service on the complaint docketed and you have no important notice filed. Sincerely, Prothonotary Office of Cumberland County One Courthouse Square • Carlisle. Pennsylvania 17013 • (717) 240.6195 • Fax (717) 240.6573 RONALD A. RILEY, Plaintiff V. ROBERT M. MRAZ, Individually and residing: at 3653 Chestnut Street, : Camp Hill, Pennsylvania, . Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - EQUITY 99-7453 EQUITY TERM ORDER OF COURT AND NOW, this 22nd day of October, 2002, it appearing that docket activity has occurred recently in the above-captioned case, the case is stricken from the purge list, and shall remain active. By the Court, /Ronald A. Riley 1100 Pike Street Huntingdon, PA 16654 Plaintiff Robert M. Mraz 3653 Chestnut Street Camp Hill, PA 17011 Defendant Court Administrator wcy J We"Jr. 21 ?5z . r CU p, ?4`,?,,, `,;;