HomeMy WebLinkAbout03-4429
COMMONWEALTH OF PENNSYLVANIA
. .
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
JUDICIAL DISTRICT
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMONPLIASNo. D3 -1./429 ec>~
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Convnon Pleas an appeal from the judgment rendered by the District Justice an the
date and in the ccue mentioned below.
NAME Of APPfUANT
Doris Louise Baughman
ADOI!$S OF APfEL1.ANf
QTY
I MIG. 0I5T. NO. OR NAME 01- o.J.
09-3-03
STA"
ZF COOE
751 Baltimore Pike, Gardners, PA 17324
Di'.TEOf.Jl.CGMENT jINTtECAStOffP/aintlffJ (~J
8/8/03 Doris Louise Baughman ",Debra S. Brandt & Dennis E. Brandt
CUlMNCl CV 0000203-03 SlGNAT~~::;-.~
IT Douglas ~. Mill~J! Esquire
This block will be signed ONLY when thi, notation is required under Po. R.cPJP. No. If appellant was CLAIMANT (see Pa. R.C.P.J.P. No.
loo8B.
This Notice of Appeal, when received by the District Justice, will operate as 0 1001(6) inaction before District Justice, he MUST
SUPERSEDEAS ta the judgment for possession in this case. FILE A COMPLAINT within twenty (20) days after
filing his NOTICE of APPEAL.
Signature of Prothonotary or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of fomt to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 100 I (7) in action belore District Justice.
IF NOT USED, detach /rom copy of notice of appeal to be served upon appellee).
PRAECIPE I To Prothonotary
Enter rule upon
Name 01 appellee( s)
, appellee(s), to file a complaint in this appeal
(Common Pleas No.
) within twenty (20) days after service of rule or suffer entry af judgment of non pro.
~ of appellant or his attorney or agent
RULEI To
Nwne of appe/I(H3(S)
, appeIlee(s).
(I) You are notified that a rule is hereby entered upon you ta 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:
SigvIIue of ProtJ;o, JOb. t Of DIpuf)'
AOPC 312-90
COURT FILE TO BE FILED WITH PROTHONOTARY
PROOF OF SERVICE OF NOTICE APPEAL AND RULE
COMPLAINT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
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N .. ,-COMMONWEALTH OF PENNSYLVANIA
'COUNTY OF: CUMBERLAND
09-3-03
NOTICE OF JUDGMENTITRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME arId ADDRESS
'BAUGHMAN, DORIS LOUISE .,
751 BALTIMORE PIKE
GARDNERS, PA 17324
Mag. Dist. No.:
OJ Name: Hon.
SUSAN K. DAY
Addem 229 ifILL STREET, BOX 167
MT. HOLLY SPRINGS, PA
L
..J
VS.
T"'phooo (717) 486-7672
17065
DEFENDANT: -'nAME and ADDRESS
'BRANDT, DEBRA S. & BRANDT, DENNIS E
P.O. BOX 157
ARENTSVILLE, PA 17303
L ..J
Docket No.: CV- 0000203 - 03
Date Filed: 6/26/03
DORIS L. BAUGHMAN
751 BALTIMORE PIKE .
GARDNERS, PA 17324
~':
THIS-IS TO NOTIFY YOU THAT:
Judgment:
~ Judgment was entered for:
FOR pT.ll.TNTIFF
(Name) Rll.TT~RMll.l\T, nnRTS T.OTTTflP.
~~ Judgment was entered against: (Name) RRANTlT.. DRfIRA S _ ..& BRANTlT..t. DF.1\INIS E
*JUDGEMENT AGAINST DENNIS E. BRAND1:UNLI. ACTION AGAINST DEBKA S. BRANDT DISMISSED.
in the amount of $ "I, 'i"l7 . 7.'i on: (Date of Judgment) 8/08/0"1
D Defendants are jointly and severally liable.
D Damages will be assessed on:
D This case dismissed without prejudice.
(Date & Time)
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
Total
$ 3,445.75
$ 91. 50
$ .00
$ .00
$ 3,537.25
D Amount of Judgment Subject to
AttachmenV42 Pa.C..S. ~ 8127 $
o Portion of Judgment for physical
damages arising out of residential
lease $
Post Judgment Credits $
Post Judgment Costs $
------------
------------
Certified Judgment Total $
ANY ~ARTY HAS THE RIGHT T9 APPEAL WITHIN 30 DAYS AFTE.R THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER
ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE.
UNLESS THE JUDGMENT is ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATiSFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
S-&- 03 0", I~~ ;) . Di"";oJ"",;oo
I certify that this is a true ind correct copy of the reco}: of 'J;oceedingS containing the judgment.
Date
, District Justice
My commission expires first Monday of JanuarYe 2004
SEAL
AOPC 315-03
DATE PRINTED:
8/14/03
2:03:21 PM
DORIS L. BAUGHMAN
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
v.
NO. 2003-4429 CIVIL TERM
DEBRA S. BRANDT and
DENNIS E. BRANDT,
Defendants
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, order and
notice are served, by entering a written appearance personally or by attorney and by 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 Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
(800) 990-9108
Americans with Disabilities
Act of 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our
office. All arrangements must be made at least 72 hours prior to any hearing or business before the court.
You must attend the scheduled conference or hearing.
DORIS L. BAUGHMAN
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
Plaintiff
CIVIL ACTION - LAW
v.
NO. 2003-4429 CIVIL TERM
DEBRA S. BRANDT and
DENNIS E. BRANDT,
Defendants
JURY TRIAL DEMANDED
COMPLAINT
AND NOW, this 9th day of November, 2005, comes the Plaintiff, Doris L. Baughman, by
and through her attorneys, Irwin & McKnight, and make the following Complaint against the
Defendants, Debra S. Brandt and Dennis E. Brandt, averring as follows:
1. Plaintiff, Doris L. Baughman, is an adult individual residing at 75] Baltimore
Pike, Gardners, Cumberland County, Pennsylvania ] 7324.
2. Defendant, Debra S. Brandt, is an adult individual with a mailing address of P.O.
Box 2]3, Aspers, Adams County, Pennsylvania ]7304.
3. Defendant Dennis E. Brandt, is an adult individual residing at 66 Norris Road,
Biglerville, Adams County, Pennsylvania.
4. In December 2002, Plaintiff loaned Defendants Dennis E. Brandt and Debra S.
Brandt, her son and daughter-in-law, $3,400.00 with the agreement that they would repay the
money on a monthly basis beginning in April 2003. A true and correct copy of the payment
schedule dated December 21, 2002, and signed by the Defendants is attached hereto and made a
part hereof as Exhibit "A".
5. In the event that payments were not made by the fifteenth day of the month, the
payment schedule attached as Exhibit "A" provides that a $5.00 late charge is to be added to the
monthly payment.
6. Defendants were married at the time the money was loaned to them by Plaintiff.
7. Subsequent to receiving the money from Plaintiffs, Defendant Dennis Brandt filed
for a divorce from Debra Brandt, and the diyorce action has since been finalized.
8. Because the instant litigation was commenced pnor to the divorce of the
Defendants, it was raised in those proceedings but the loan to Plaintiff was determined by the
appointed Master to be excluded from the divorce and equitable distribution proceedings.
COUNT I - BREACH OF CONTRACT
9. The averments of paragraphs one (1) through eight (8) of this Complaint are made a part
hereof and incorporated herein by reference.
10. Defendant Dennis Brandt has since agreed to repay one-half of the money loaned
to Defendants by Plaintiff in accordance with Exhibit "A."
II. Despite repeated requests by Plaintiff, Defendant Debra S. Brandt has refused and
failed to repay Plaintiff in accordance with Exhibit "A" for the money that Plaintiff loaned.
12. Defendants have breached their agreement with Plaintiff by failing or refusing to
repay the money loaned by Plaintiff.
13. Despite repeated demands, Defendant Debra Brandt continues to refuse to
acknowledge that she borrowed money from the Plaintiff, as evidence by the document attached
as Exhibit "A," or to repay any of the monies Plaintiff loaned to her.
14. Plaintiff is entitled to certain damages, including but not limited to, receiving
repayment for the full amount of the loan, interest, late fees and costs associated with this
litigation.
WHEREFORE, the Plaintiff, Doris L. Baughman, respectfully requests that this
Honorable Court enter judgment against Defendants in the amount of Three Thousand Four
Hundred and no/lOO ($3,400.00) Dollars, plus costs, late fees, interest, and all other and further
relief this Honorable Court deems fair and just
2
COUNT II - UNJUST ENRICHMENT
15. The averments of paragraphs one (1) through fourteen (14) of this Complaint are made a
part hereof and incorporated herein by reference.
16. Both Defendants accepted and actively used the money loaned by Plaintiff, by
transferring the funds into Defendants' joint account to be used to payoff their joint debt in order that
they could qualify for a home equity loan in both of their names.
17. Plaintiff conferred benefits on the Defendants by allowing them to borrow the
money needed to satisfy joint credit card debts and to organize their finances.
18. Defendants have received the benefits of the money loaned to them by Plaintiff,
and profited thereby through the payment of joint debt and qualification for a home equity loan.
19. It is and continues to be inequitable for Defendants to retain the monies loaned
from Plaintiff while failing and refusing to reimburse Plaintiff.
WHEREFORE, the Plaintiff, Doris L. Baughman, respectfully requests that this
Honorable Court enter judgment against Defendants in the amount of Three Thousand Four
Hundred and no/IOO ($3,400.00) Dollars, plus costs, late fees, interest, and all other and further
relief this Honorable Court deems fair and just.
Respectfully Submitted,
IRWIN & McKNIGHT
By:
Dated: November 9, 2005
Douglas . Miller, Esquire
Supreme Court ill # 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Attorney for Plaintiff
3
VERIFICATION
The foregoing document is based upon information which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section
4904, relating to unsworn falsification to authorities.
k)o<J~aJ
DORIS L. BAUGHMA
Date: November 7, 2005
EXHIBIT "A"
Approximate Future Payment Schedule
~ 2120/02 - Brandt Page
Pm! Principal Interest Balance
2.20% 3,400.60
1 138.71 6.23 3,261.29
2 138.96 5.98 3,122.33
3 139.22 5.72 2,983.11
4 139.47 5.47 2,843.64
5 139.73 5_21 2,70391
6 139.98 4.96 2,563.93
7 140.24 4.70 2,423.69
8 140.50 4.44 2,283.19
9 140.75 4.19 2,142.44
10 141.01 3.93 2,001.43
11 141.27 3.67 1,860.16
12 141.53 3.41 1,718.63
13 141.79 3.15 1,576.84
14 142.05 2.89 1,434.79
15 142.31 2.63 1,292.48
16 142.57 2.37 1,149.91
17 142.83 2.11 1,007.08
18 143;()9 1.85 863.99
19 143.36 1.58 720.63
20 143.62 1.32 577.01
21 143.88 1.06 433.13
22 144.15 0.79 288.98
23 144.41 . 0.53 144.57
24 144.57 0.27 0.00
-,
Loan Amount: 3,400.00
Annual Interest Rate: 2.200%
Number of Years: 2
Periods Per Year: 12
Payment Per Period: 144.94
{,
We the undersigned agree to pay this loan back to Doris BHltgltman in 8C?>rdance with
the above payment schedule beginning on April 1, 2003. If the payment is not made by
the lSdl of the month a $5.00 late Charge~:illb~..~ed ~o th:~onthly paym~nt. ..
I.,0~~t1~ 1_ ~'!'S-I'~+~fuIIYtOthiS
contract.
t' /
Date: /2;;:/ o~
CERTIFICATE OF SERVICE
I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy
of the foregoing document upon the persons indicated below by Certified Mail, postage paid in
Carlisle, Pennsylvania 17013, on the date set forth below:
DEBRA S. BRANDT
P.O. BOX 213
ASPERS, PA 17304
DENNIS E. BRANDT
66 NORRIS ROAD
BIGLERVILLE, PA 17307
Date: November 10, 2005
IRWIN & McKNIGHT
Dougla G. Miller, Esquire
Supreme Court J.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
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DORIS L. BAUGHMAN
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: CIVIL ACTION - LA W
v.
: NO. 2003-4429 CIVIL TERM
DEBRA S. BRANDT and
DENNIS E. BRANDT,
Defendants
: JURY TRIAL DEMANDED
PRAECIPE TO REINSTATE COMPLAINT
TO CURTIS R. LONG, PROTHONOTARY:
Please reinstate the Complaint in the above-captioned case.
Respectfully submitted,
IRWIN & McKNIGHT
By: ~.~ 4tJ/b
Douglas . Miller, Esquire
60 West Pomfret Street
Carlisle, PA 17013
(717) 249-2353
Supreme Court LD. No: 83776
Attorney for Plaintiff,
Doris Baughman
Date: December 2, 2005
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
DORIS L. BAUGHMAN
v.
NO. 2003.4429 CIVIL TERM
DEBRA S. BRANDT and
DENNIS E. BRANDT,
Defendants
: JURY TRIAL DEMANDED
AFFIDAVIT OF SERVICE OF COMPLAINT
COMMONWEALTH OF PENNSYLVANIA
: SS:
COUNTY OF CUMBERLAND
NOW, Douglas Mi\1er, Esquire, being duly sworn according to law, does depose and state:
I. That he is a competent adult and attorney for the Plaintiff in the captioned action.
2. That a certified copy of the Complaint was served upon the defendant, Dennis E.
Brandt, on November 12, 2005 by certified mail, return receipt requested, addressed
to 66 Norris Road, Biglerville, P A 17307, with return receipt number 7003 3110
000457707104.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn
falsification to authorities.
IRWIN & McKNIGHT
Date: December 2, 2005
By:
Douglas Miller, Esquire
Supreme Court Id # 83776
60 West Pomfret Street
Carlisle, PA 17013
(717) 249-2353
Attorney for Plaintiff
Doris Baughman
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Bi lerville PA 17307
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front if space permits.
1. ArtIcle Addressed to:
DENNIS E. BRANDT
66 NORRIS ROAD
BIGLERVILLE, PA 17307
3. Service Type
II Certified Mall Cl Exp_ Mall
Cl Reglstemd Cll Retum Receipt for Merchandise
o Insured Mall 0 C.O.D.
4. Restricted Delivery? (Extrs Fee) 0 Yes
2. Article Number
(lhInsjilrfrom _ '**!
PS Form 3811, February 2004
7003 3110 0004 5770 7104
Domestic Return ReceIpt 102595-02-M-1540:
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DORIS L. BAUGHMAN
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
v.
NO. 2003-4429 CIVIL TERM
DEBRA S. BRANDT and
DENNIS E. BRANDT,
Defendants
JURY TRIAL DEMANDED
AFFIDA TIT OF SERVICE
COMMONWEALTH OF PENNSYL VANIA
: SS:
COUNTY OF CUMBERLAND
NOW, Douglas Miller, Esquire, being duly sworn according to law, does depose and state:
]. That he is a competent adult and attorney for the Plaintiff in the captioned action.
2. That the Complaint was served upon Defendant Debra S. Brandt on or about
December 2, 2005. Pursuant to Ru]e ]930A(c), these documents were mailed to
Defendant Debra S. Brandt at her address at P.O. Box 213, Aspers. Pennsylvania
17304, both via certified mail, return receipt requested and via regular United States
mail.
3. That a copy of the certified mail envelope showing that it was unclaimed by
Defendant Debra S. Brandt is attached hereto and made a part hereof.
4. That more than fifteen (15) days have elapsed without the regular mail being
returned pursuant to Rule 1930A(c)(1).
1 verify that the statements made in this affidavit are true and correct. I understand that false
statements herein made are subject to the penalties of ]8 Pa.C.S. Section 4904, relating to unsworn
falsification to authorities.
IRWIN & McKNIGHT
Date: December 30, 2005
By: ~ ~J4.
Douglas Miller, EsqUIre
Supreme Coul1 Id # 83776
60 West Pomfret Street
Carlisle, PA 17013
(717) 249-2353
Attorney for Plaintiff
Doris L Baughman
LAW OFFICES
r'tWin Ii .MeJ{nU;fd
ST ?OMFRET PROFESSIONAL BUILDING
60 WEST POMFRET STREET
.ISLE, PENNSYLVANIA 17013-3222
o In~ufficient Address
o Moved, Left No Add(ess
C Unclaimed 0 Refused
C2Attempted. Not Knowl.
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P.O. BOX 213
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CI NOT DELIVERABLE AS ADDRESSED
. UNABLE TO FORWARD
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DORIS L. BAUGHMAN
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: CIVIL ACTION - LAW
v.
: NO. 2003-4429 CIVIL TERM
DEBRA S. BRANDT and
DENNIS E. BRANDT,
Defendants
: JURY TRIAL DEMANDED
PRAECIPE TO ENTER DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Please enter judgment by default in favor of the Plaintiff, Doris L Baughman, and against
the Defendant, Debra S. Brandt, for failure to file an Answer to the Complaint, in the amount of
$3,400.00 plus costs, continuing interest and late fees. A copy of the IO-Day Notice under Rule
237.1 is attached hereto and marked as Exhibit "A".
Respectfully submitted,
IRWIN & McKNIGHT
By:
Doug as G. iller, Esquire
Supreme Ct. J.D. # 83776
60 West Pomfret Street
Carlisle, P A 17013
(717) 249-2353
Attorney for Plaintiff
EXHIBIT "A"
DORIS L. BAUGHMAN
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
Plaintiff
: CIVIL ACTION - LA W
v.
: NO. 2003-4429 CIVIL TERM
DEBRA S. BRANDT and
DENNIS E. BRANDT,
Defendants
: JURY TRIAL DEMANDED
To Defendants:
DEBRAS.BRANDT
P.O. BOX 213
ASPERS, PA 17304
DENNIS E. BRANDT
66 NORRIS ROAD
BIGLERVILLE, PA 17307
Date of Notice:
December 29, 200S
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE 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 (10) DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST
YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT
ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
(800) 990-9108
Americans with Disabilities Act of 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our
office. All arrangements must be made at least 72 hours prior to any hearing or business before the court.
You must attend the scheduled conference or hearing.
IRWIN & McKNIGHT
By:~J,~
Dougla . Miller, 'Esquire
Supreme Court LD. No. 83776
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Attorney for Plaintiff
Doris L. Baughman
CERTIFICATE OF SERVICE
I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy
of the foregoing document upon the persons indicated below by Certified Mail, postage paid in
Carlisle, Pennsylvania 17013, on the date set forth below:
DEBRA S. BRANDT
P.O. BOX 47
CASHTOWN, PA 17310
Date: January 25, 2006
IRWIN & McKNIGHT
Douglas G. 'lIer, Esquire
Supreme Court J.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
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DORIS L. BAUGHMAN
Plaintiff
V.
DEBRA S. BRANDT and
DENNIS E. BRANDT,
Defendants
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 2003-4429 CIVIL TERM
JURY TRIAL DEMANDED 'mss i?*t--?
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PRAECIPE TO SETTLE AND DISCONTINUE=' -a
TO THE PROTHONOTARY:
Please mark the above-captioned case settled and discontinued and mark the judgment
related thereto as paid in full and satisfied and issue evidence of the same to the undersigned.
Respectfully submitted,
Date: January 13, 2011
IRWIN & McKNIGHT, P.C.
By:
Douglas G. Miller, Esquire
Supreme Court ID #83776
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Attorney for Plaintiff
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CERTIFICATE OF SERVICE
I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy
of the foregoing document upon the persons indicated below by first class United States mail,
postage paid in Carlisle, Pennsylvania 17013, on the date set forth below:
DEBRA S. BRANDT
P.O. BOX 47
CASHTOWN, PA 17310
DENNIS E. BRANDT
66 NORRIS ROAD
BIGLERVILLE, PA 17325
Date: January 13, 2011 IRWIN & McKNIGHT, P.C.
Douglas G. iller, Esquire
Supreme Court I.D. No. 83776
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353