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HomeMy WebLinkAbout07-3329DONALD P. URSO, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA vs. CIVIL ACTION AT LAW JOSEPH URSO, Defendant NO . (~ '~ _ ''~ '3 ~,q C ~ ~ ~ ~ `~'~~` N O T I C E T O D E F E N D You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint 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 Court House Court Administrator 1 Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 ~. William `Dissinger, Esquire Attorn for Plaintiff (RONALD P. URSO, Plaintiff vs. (JOSEPH URSO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION AT LAW COMPLAINT AND NOW comes the Plaintiff, Ronald P. Urso, by and through his attorneys, Dissinger and Dissinger, and represents the following: 1. The Plaintiff is Ronald P. Urso, an adult individual, who resides at 33 McKees Road, Port Trevorton, Northumberland County, Pennsylvania. 2. The Defendant is Joseph Urso, an adult individual, who resides at 241 Wyoming Avenue, Enola, Cumberland County, .Pennsylvania. COUNT I REPLEVIN 3. Paragraph one and two of this complaint are incorporated herein by reference thereto. 4. Plaintiff, Ronald P. Urso, is the owner of certain items of tangible personal property. Said items are identified and valued in a list marked exhibit "A", attached hereto and made a part hereof by reference thereto. 5. Plaintiff, Ronald P. Urso, with the consent of Defendant, Joseph Urso, placed the items described in exhibit "A" in the easement of the house located at 241 Wyoming Avenue, Enola, Cumberland County, PA, as temporary storage. 6. Defendant, Joseph Urso, resides in the house located at 241 nlyoming Avenue, Enola, Cumberland County, PA, is in possession and control of said property. 7. Despite repeated requests, Defendant, Joseph Urso, has Failed and refused to allow Plaintiff, Ronald P. Urso, to retrieve Zis items of personal property, as described in exhibit "A", from she house at 241 Wyoming Avenue, Enola, Cumberland County, PA. 8. The refusal by Defendant, Joseph Urso, is wrongful and without legal justification. WHEREFORE, Plaintiff demands judgement against Defendant for possession of the personal property, and in the alternate, for the value of said personal property. COUNT II CONVERSION 9. Paragraphs one through eight of this complaint are _ncorporated herein by reference thereto. 10. Plaintiff, Ronald P. Urso, owned a vintage Weber Grand 'iano with a value of $2,500.00. 11. Plaintiff, Ronald P. Urso, stored said piano at the home •f Defendant, Joseph Urso, located at 241 Wyoming Avenue, Enola, Cumberland County, PA. 12. Defendant, Joseph Urso, without the consent or permission of Plaintiff, Ronald P. Urso, sold said piano. 13. Defendant, Joseph Urso, gave $400.00 out of the proceeds of the sale of the piano to Plaintiff, Ronald P. Urso, keeping the 'balance. WHEREFORE, Plaintiff demands judgement against Defendant in the ';amount of $2,100.00. COUNT III DAMAGE TO PERSONAL PROPERTY 14. Paragraphs one through thirteen of this complaint are _ncporated herein by reference thereto. 15. Plaintiff, Ronald P. Urso, owns a Lowery Theatre Organ. 16. Said organ is stored in the home of Defendant, Joseph Jrso, located at 241 Wyoming Avenue, Enola, Cumberland County, PA. 17. Defendant, Joseph Urso, wrongfully and without legal justification threw a heavy ceramic vase at Plaintff, Ronald P. Urso. 18. The vase missed Plaintiff but struck the organ damaging Lt. 19. The damage to the organ consists of breaking/smashing the Mahogany Music Easel. 20. The cost of the repair/replacement to bring the organ back into the condition that it was in prior to being damaged by Defendant, Joseph Urso, is $690.00 WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $690.00. Respectfully submitted, DISSINGER & DISSINGER William C. Dj~s~~fnger, esquire Attorney f Plaintiff Supreme Court ID #27737 400 South State Road Marysville, PA 17053 (717) 957-3474 VERIFICATION I, Ronald P. Urso, verify that the statements made in the ',Complaint are true and correct. I understand that false statements ',herein are made subject to the penalties of 18 Pa. C.S. X4904 ',relating to unsworn falsification. Ronald P. Urso, Plaintiff PROPERTY OF PLAINTIFF, RONALD URSO WRONGFULLY HELD BY DEFENDANT, JOSEPH URSO Mahogany Armoire Theatre Organ Sleigh Bed Sealy Mattress/Box Springs Fireplace Mantel/Black Fire Place Cover/Logs Cherry Rocker Cherry Trunk Antique Stroller 2-Bose Stereos Silver Candelabra 2-Wicker Trunks Mahogany Hand painted Tale with 4 matching stools Cottage style Teacup Cabinet 3-Chinese Rosewood end tables Chinese Omate Large Cabinet Small Omate Chinese Cabinet Mahogany Jewelry Cabinet 15-Aubuson Oriental Rugs Tiffany Glass Pole Lamp RCA DVD/VHS Flat Screen Color TV Panasonic VHS Color TV combo Panasonic Microwave Oreck Rug Steamer Oreck Vacuum $5,000.00 $2,500.00 $3,500.00 $800.00 $500.00 $100.00 $200.00 5300.00 51,000.00 5500.00 5200.00 $600.00 $200.00 $350.00 $500.00 $200.00 $450.00 54,500.00 $450.00 $695.00 5300.00 5450.00 $450.00 $450.00 EXHIBIT "A" Electrolux Vacuum $650.00 1-Childhood memorabilia box with birth certificate N/A 1-small air conditioner ~ $ Mahogany game table with solid crystal chess set $350.00 Paulys Island Hammock $300.00 Treadmill/Maker Pro Form $890.00 1-Total Gym $400.00 1-Weider Weight set/Weider weight bench $500.00 1-Black Art Portfolio $350.00 Black Chinese chair with gold brocade upholstery $350.00 Very rare Mickey Mouse sculpture $1,200.00 Large 3-panel Victorian screen $500.00 Medium Chinese hand painted paneled screen $450.00 Bread machine $300.00 Cherry chest-Solid Silver Paul Revere $850.00 Erica Creme phone $120.00 Uniden Telephone with base and 2°d handset $400.00 Color printer $100.00 Nesco Cooker (large) $150.00 Rowenta Ironing Board/iron $300.00 Christmas collectibles-antique/Christopher Radko Christmas Trees/Porcelain/Antique Christmas $5,000.00 Full contents of 59 boxes N/A Cooks Essential Cookware $600.00 2 Cement Antique Cherub Lawn Statues $2,700.00 Glass Greenhouse $250.00 Antique large dollhouse $575.00 Clock/knick knacks $1,100.00 Baskets ~ $500.00 Pillows Linens $2,500.00 Pillows-goose down $2,000.00 Pillows-European Upholstered Assortment from NYC ABC Carpet & Home $6,000.00 Coverlets, Comforters-Fur Mink, Sable, Brocades, Jacquards, Antique Quilts $10,000.00 Egyptian Towels $1,200.00 Belgium Tapestries $2,000.00 Silk Shantung Duvet Covers/Large Curtains Shawls-from Belgium/Italy $1,400.00 Rare Antique books/Art. History, Costume Design, Novels $5,000.00 Kitchenware-Cookware, Kitchen-Aid Large Restaurant Mixer, Coffee. Grinder, Food Processor $2,000.00 11-Lamps-Antique/Tiffany Reproductions/Belleck ABC Carpet/Home-Cherub/Antique Bonze Cherub $4,000.00 Chinese vases/Antique vases $2,200.00 Antique clocks/Rare Music boxes Reproduction Antique Record Player/Radio $5,000.00 Antique Clock-mantel $2,000.00 Antique dolls/Marie Osmond dolls $7,800.00 Boyds Bears-500 TL/Dolls $15,000.00 China-rare Bob Mackie-service for 8 $600.00 Antique rare Lithographs/Paintings $5,000.00 TOTAL $116,780.00 C"? ~ O ' ~ ~ ~~ °C3 ~ ~ 4 - ( 1 ~-~~ l~' ~ -" -~ s'n ~ G- n~ ~ ~ O V H -. 1 SHERIFF'S RETURN - REGULAR CASE N0: 2007-03329 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND URSO RONALD P VS URSO JOSEPH RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - REPLEVIN was served upon TTnc„ T~~~nv the DEFENDANT at 1212:00 HOURS, on the 8th day of June 2007 at 241 WY(~MTNG AVENUE ENOLA, PA 17025 by handing to a true and attested copy of COMPLAINT - REPLEVIN So Answers: and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.40 Postage .41 Surcharge 10.00 .00 4~IsI0^'j ~ ~ 42.81 Sworn and Subscibed to before me this day of , R. Thomas Kline 06/11/2007 DISSINGER & DISS~,ATGER By: together with ty Sheriff A.D. KOPE & ASSOCIATES, LLC BY: JACOB M. JIVIDEN, ESQUIRE ATTORNEY ID 87519 4660 TRINDLE ROAD, SUITE 201 CAMP HILL, PA 17011 (7]7)761-7573 RONALD P. URSO, Plaintiff, v. JOSEPH URSO, Defendant. Attorney for Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION AT LAW N0.07-3329 civil NOTICE TO PLEAD To: Ronald P. Urso YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED ANSWER WITH NEW MATTER AND COUNTERCLAIM WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. Respectfully Submitted, KOPE & ASSOCIATES, LLC ~/ -'/ uire Date: July 25, 2007 KOPE & ASSOCIATES, LLC BY: JACOB M. J]VIDEN, ESQUIRE ATTORNEY ID 87519 4660 TRINDLE ROAD, SUITE 201 CAMP HILL, PA 17011 (717)761-7573 RONALD P. URSO, Plaintiff, v. JOSEPH URSO, Defendant. Attorney for Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION AT LAW N0.07-3329 civil ANSWER WITH NEW MATTER AND COUNTERCLAIM NOW comes the Defendant, Joseph Urso (hereinafter referred to as "Defendant"), by and through his counsel, Kope & Associates, LLC, and responds to the Complaint of Ronald P. Urso (hereinafter referred to as "Plaintiff') as follows: 1. Admitted. 2. Admitted. COUNT I-REPLEVIN 3. This paragraph is one of incorporation and, as such, no response is required under the Pennsylvania Rules of Civil Procedure. 4. Denied. Although Plaintiff may at some time have been the owner of certain items of tangible personal property, Plaintiff is no longer the owner of said personal property due to operation of law. By way of further answer, said personal property was abandoned by Plaintiff or, in the alternative, said property was the subject of a bailment to Defendant. To the extent that the remaining averments of this paragraph purport to summarize, interpret or characterize a writing, that document speaks for itself, and the averments of this paragraph aze therefore denied. By way of further answer, Defendant specifically denies the values attributed to said personal property and strict proof thereof is demanded. 5. Admitted. 6. Admitted. 7. Denied. To the contrary, despite several attempts by Defendant to effectuate the return of said property, Plaintiff failed and refused to retrieve said property. 8. Denied. The allegations of this paragraph aze conclusions of law and, as such, no response is required under the Pennsylvania Rules of Civil Procedure. COUNT II-CONVERSION 9. This pazagraph is one of incorporation and, as such, no response is required under the Pennsylvania Rules of Civil Procedure. 10. Admitted in part and denied in part. It is admitted that at some time Plaintiff owned a Weber Grand Piano. It is denied that the Weber Grand Piano was valued at $2,500.00. To the contrary, Defendant is without knowledge or information sufficient to form a belief as to the truth of these averments and, therefore, such allegations aze deemed to be denied and strict proof thereof is demanded. 11. Admitted. 12. Denied. To the contrary, Plaintiff consented to placing an advertisement in the local newspaper in an attempt to sell the piano. By way of further answer, at no time did Plaintiff withdraw his consent or permission to Defendant to sell said piano. 13. Admitted. By way of further answer, Defendant kept the balance to offset the costs of storage and Gaze of the piano. COUNT III-DAMAGE TO PERSONAL PROPERTY 14. This pazagraph is one of incorporation and, as such, no response is required under the Pennsylvania Rules of Civil Procedure. 15. Denied. Although Plaintiff may at some time have been the owner of a Lowery Theatre Organ, Plaintiff is no longer the owner of said personal property due to operation of law. 16. Admitted in part and denied in part. It is admitted that said organ was at one point stored in the home of Defendant located at 241 Wyoming Avenue, Enola, Cumberland County, Pennsylvania. It is denied that said organ is still being stored at Defendant's residence. 17. Denied. Defendant specifically denies that he threw a heavy ceramic vase at Plaintiff. To the contrary, Defendant never threw a heavy ceramic vase at Plaintiff. 18. Denied. Defendant specifically denies that he threw a heavy ceramic vase that missed Plaintiff and struck said organ. Defendant specifically denies that said organ was damaged by any act of Defendant. To the contrary, Defendant never damaged said organ by throwing a heavy ceramic vase that missed Plaintiff and struck said organ. 19. Denied. Defendant specifically denies that said organ was damaged by any act of Defendant. To the contrary, Defendant never damaged said organ. By way of further answer, Defendant is without knowledge or information sufficient to form a belief as to the truth of these averments and, therefore, such allegations aze deemed to be denied and strict proof thereof is demanded. 20. Denied. Defendant specifically denies that said organ was damaged by any act of Defendant. To the contrary, Defendant never damaged said organ. Defendant denies that the cost of the repair/replacement of said organ was $690.00. To the contrary, Defendant is without knowledge or information sufficient to form a belief as to the truth of these averments and, therefore, such allegations are deemed to be denied and strict proof thereof is demanded. WHEREFORE, Defendant respectfully requests this Court enter judgment in his favor and against Plaintiff, together with costs, interest, attorney fees, and any other fees the Court deems appropriate. NEW MATTER 21. Paragraphs one (1) through twenty (20) of the foregoing Answer are incorporated herein by reference as through the same were fully set forth herein. 22. Plaintiff's Complaint fails to state a claim against Defendant upon which relief can be granted. 23. Plaintiff s claims are barred by the Doctrine of Estoppel and/or Waiver. 24. Defendant's conduct was justified in that Plaintiff abandoned said property or, in the alternative, said property was the subject of a bailment to Defendant 25. Plaintiff s claims are barred by laches. Despite repeated requests, Plaintiff had previously refused to remove said property from Defendant's residence. Plaintiff subsequently refused and failed to remove said property from Defendant's residence. Nevertheless, Plaintiff has refrained from commencing this action until now. WHEREFORE, Defendant respectfully requests this Court enter judgment in his favor and against Plaintiff, together with costs, interest, attorney fees, and any other fees the Court deems appropriate. COUNTERCLAIM 26. Pazagraphs one (1) through twenty-five (25) of the foregoing Answer and New Matter aze incorporated herein by reference as through the same were fully set forth herein. 27. In or about June 2005, Defendant allowed Plaintiff to store numerous items of personal property in the basement of Defendant's residence located at 241 Wyoming Avenue, Enola, Cumberland County, Pennsylvania. 28. Between July 31, 2005, and June 6, 2006, Defendant sent numerous letters to Plaintiff requesting that he remove his personal property from Defendant's residence. 29. Plaintiff failed and refused to remove said personal property from Defendant's residence. 30. In or about December 2006, Defendant ceased storing Plaintiff's personal property at Defendant's residence. 31. Between June 2005 and December 2006, Defendant provided Plaintiff with storage space for Plaintiff s personal property. 32. Defendant provided care and maintenance for Plaintiff s personal property and maintained suitable storage conditions. 33. At no time was Defendant reimbursed by Plaintiff for storage fees, maintenance, and care. 34. The value of these services provided by Defendant is $150.00 per month. WHEREFORE, Defendant respectfully requests this Court enter judgment in his favor and against Plaintiff, in the amount of $2700.00 together with costs, interest, attorney fees, and any other fees the Court deems appropriate. Jacob .KGid6 Esquire I.D. 7519 Kope & Assoc' tes, LLC 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 KOPE & ASSOCIATES, LLC BY: JACOB M. JIVIDEN, ESQUIRE ATTORNEY ID 87519 4660 TRINDLE ROAD, SUITE 201 CAMP HILL, PA 17011 (717) 761-7573 RONALD P. URSO, Plaintiff, v. JOSEPH URSO, Defendant. Attorney for Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION AT LAW N0.07-3329 civil CERTIFICATE OF SERVICE I, Jacob M. Jividen, Esquire, hereby certify that on July 25, 2007, I served a copy of the foregoing Answer with New Matter and Counterclaim by first-class, United States mail addressed to the following: William C. Dissinger, Esquire Dissinger &Dissinger 400 South State Road Marysville, PA 17053 KOPE & LLC Jaco .1ivi`d squire I. 87519 ope & As fates, LLC 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717)761-7573 f~ _.a -11 c ~~ ;~~. nz?' ~.. - - ~ _ C,'3 .~:; rwy C.~ m.. ~ , .:r • ~ - ~:,. _ d ` ; ~ ~Y, 1 ~ ,/ 1 ,• KOPE & ASSOCIATES, LLC BY: JACOB M. JIVIDEN, ESQUIRE ATTORNEY ID 87519 4660 TRINDLE ROAD, SUITE 201 CAMP HILL, PA 17011 (717) 761-7573 RONALD P. URSO, Plaintiff, v. JOSEPH URSO, Defendant Attomey for Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-3329 CIVIL TERM CIVIL ACTION-LAW PRAECIPE TO ATTACH VERIFICATION TO THE PROTHONOTARY: Please attach the enclosed Verification signed by the Defendant to the Answer With New Matter and Counterclaim that was filed in the above captioned matter. It was inadvertently not attached when the original was filed. Respectfully Submitted, KOPE & ASSOCIATES, LLC By: Jac M. Jivid ,Esquire 46 0 Trindle oad, Suite 201 Camp Hill, PA 17011 (717) 761-7573 I.D. 87519 (Attorney for Defendant) VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Date: ~ o~ c~ C~`~"~-- OSEP URSO ~~ f s~ KOPE & ASSOCIATES, LLC BY: JACOB M. JIVIDEN, ESQUIRE ATTORNEY ID 87519 4660 TRINDLE ROAD, SUITE 201 CAMP HILL, PA 17011 (717) 761-7573 Attorney for Defendant RONALD P. URSO, : IN THE COURT OF COMMON PLEAS Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA v. : N0.07-3329 CIVIL TERM JOSEPH URSO, :CIVIL ACTION-LAW Defendant CERTIFICATE OF SERVICE KOPE & LLC Jaco M. Jivide sq. 46 Trindle ad, Suite 201 Camp Hill, PA 17011 (717) 761-7573 I.D. 87519 (Attomey for Defendant) I, Jacob M. Jividen, Esquire, hereby certify that on July 25, 2007, I served a copy of the foregoing Praecipe to Attach Verifcation by first class United States mail upon the following: William C. Dissinger, Esquire Dissinger &Dissinger 400 South State Road Marysville, PA 17053 ~-~, r`', c ~ ;.~ •,_. .-~ti~`':° ~~~ _.. _ -,- iii`- ~`_- , , ~ ~ c-, , `-, -,- ~~w r ~ r RONALD P. URSO, Plaintiff vs. JOSEPH URSO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION AT LAW N0. 07-33-29 CIVIL TERM PLAINTIFF'S ANSWER TO DEFENDANT'S NEW MATTER AND COUNTERCLAIM AND NOW comes Plaintiff, Ronald P. Urso, who by and through his attorney, William C. Dissinger, Esq., responds to the New Matter and Counterclaim of Defendant, Joseph Urso, as follows: 21. No answer required. 22. Denied. Plaintiff's complaint fully states a claim against Defendant upon which relief may be granted. 23. Denied. Neither the Doctrine of Estoppel nor Waiver bars Plaintiff's claims. 24. Admitted in part and Denied in part. Plaintiff did not abandon his property. However, it is admitted that Plaintiff's actions in placing his personal property with Defendant constitutes a bailment. It is denied that this, in any way, justified Defendant's actions. 25. Denied. Laches does not bar Plaintiff's claims. Plaintiff repeatedly attempted to remove his property from the possession of Defendant. Defendant failed to cooperate and allow Plaintiff to remove his property. WHEREFORE Plaintiff requests that Defendant's New Matter be dismissed. 26. No answer required. 27. Admitted in part and Denied in part. It is admitted that Defendant allowed Plaintiff to store numerous items of personal property in the basement of Defendant's residence located at 241 Wyoming Avenue, Enola, Cumberland Count, Pennsylvania. However, this took place in July of 2005, not June. 28. Admitted in part and Denied in part. It is admitted that Defendant, or his agents, sent letters to Plaintiff requesting removal of the property. However, these communications always r contained conditions or limitations which made it unable for Plaintiff to comply. 29. Admitted in part and Denied in part. It is admitted that Plaintiff did not remove his property from Defendant's residence. It is denied that he failed and refused to do so. To the contrary, Plaintiff made repeated requests to Defendant to retrieve his property only to be denied by Defendant. 30. Plaintiff is without knowledge or information sufficient to form a belief as to the truth or falsity of this averment. The same is therefore denied and proof thereof demanded at trial. 31. Admitted. 32. Admitted. 33. Admitted in part and Denied in part. It is admitted that Plaintiff did not pay Defendant any storage fees. It is denied that any such fees are due and owing. 34. Plaintiff is without knowledge or information sufficient to form a belief as to the truth or falsity of this averment. The same is therefore denied and proof thereof demanded at trial. WHEREFORE, Plaintiff requests that Defendant's Counterclaim be dismissed. Respectfully submitted, DISSINGER & DISSINGER ~~ William C. Dissinger Esquire Attorney for Plaintiff Supreme Court ID #27737 400 South State Road Marysville, PA 17053 (717) 957-3474 VERIFICATION I, Ronald P. Urso, verify that the statements made in the Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. X4904 relating to unsworn falsification. ei~~..(i*'l :~' ~ Lift.,-~ Ronald P. Urso, Plaintiff RONALD P. URSO, Plaintiff vs. JOSEPH URSO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION AT LAW N0. 07-33-29 CIVIL TERM CERTIFICATE OF SERVICE I, William C. Dissinger, hereby certify I have, on the date and year indicated, served a true and correct copy of the forgoing Answer on Defendant by depositing the same, postage pre-paid, with The United States Postal Service addressed as follows: Date: Jacob M. Jiriden, Esq. 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