HomeMy WebLinkAbout04-0480KEITH HOLLAND and,
EARLANDA M. HOLLAND
Plaintiffs
vs.
ANTHONY MAGARO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Dy y0?2 4.?/
CIVIL ACTION-LAW
REPLEVIN ACTION
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 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
4th Floor
I Courthouse Square
Carlisle, PA 17013
(717) 240-6200
KEITH HOLLAND and EARLANDA M.
HOLLAND,
ANTHONY MAGARO,
Plaintiffs
Defendant
IN THE COURT OF COMMON PLEAS,
CUMBERLAND COUNTY,
NO. Oy-916
CIVIL ACTION-LAW
REPLEVIN ACTION
COMPLAINT IN CIVIL ACTION-REPLEVIN
AND NOW, this 4th day of February, 2004 come Plaintiffs Keith Holland and Earlanda
Holland, by their Attorney, Peter B. Foster, Esquire, and bring this Action in Replevin, as
follows:
Plaintiffs Keith Holland and Earlanda Holland are husband and wife and reside at
550 Camp Street, Harrisburg, PA 17110.
2. Defendant Anthony Magaro is an adult individual with a business address of 515
South 32nd Street, Annex, Camp Hill, Cumberland County, Pennsylvania 17011.
COUNTI
EARLANDA HOLLAND VS. ANTHONY MAGARO
3. Plaintiff Earlanda Holland is the true and lawful owner of a 1993 U.M.C. Truck,
V.I.N. 45VXA02B2PW003905. A copy of Mrs. Holland's title to said truck is attached as
Exhibit "A."
4. The reasonable value of said property is $8000.00.
5. The said truck was illegally seized from Plaintiff Earlanda Holland's possession
by Defendant on January 27, 2004.
6. The said truck is presently located at 515 South 32nd Street, Annex, Camp Hill,
Cumberland County, Pennsylvania 17011.
Said Plaintiff believes and, therefore, avers that Defendant has possession of said
truck.
8. Since Plaintiff Earlanda Holland has clear title to said truck she is entitled to
immediate possession of it.
WHEREFORE, Plaintiff Earlanda Holland demands judgement in Replevin in her favor
and against Defendant Anthony Magaro for:
(1.) The possession and delivery of the above-described truck; or
(2.) The value of the property with interest to the date of trial, in case possession and
delivery cannot be had, being a sum in excess of $8000.00; and
(1) Any and all other relief which this Court deems appropriate.
COUNT II
9. Plaintiff Keith Holland incorporates by reference paragraphs 1-8 of this
Complaint as if said averments were fully set forth at length herein.
10. Plaintiff Keith Holland is the true and lawful owner of the following tools and
equipment:
2
a) Handsaw
b) Devalt Drill
C) Tablesaw
d) Tool Box
e) Hose
f) Vacuum Extensions
g) Plug Rotor
h) Sandpaper
i) 2 Ladders
j) Screen
k) Protector, Cleaner Bucket
1) Finish
M) EZ 8 Clark Floor Sander
n) EZ 7 Clark Edger
o) 17" Buffer
p) 17" U.F.O.
11. Plaintiff Keith Holland purchased said tools and equipment from Defendant and
has fully paid for them.
12. The reasonable value of said tools and equipment is $6000.00.
13. Defendant Anthony Magaro illegally seized said tools and equipment from said
Plaintiff s possession on January 27, 2004.
14. Said tools and equipment are presently located at 515 South 32nd Street, Annex,
Camp hill, Cumberland County, Pennsylvania 17011
15. Plaintiff Keith Holland avers that Defendant Anthony Magaro has possession of
said tools and equipment.
16. Plaintiff Keith Holland is the lawful owner of said tools and equipment is entitled
to possession of these items.
WHEREFORE, Plaintiff Keith Holland demands judgement in Replevin in its favor and
against Defendant Anthony Magaro for:
(1) The possession and delivery of all the above-itemized property; or
(2) The value of the property with interest to the date of trial, in case possession and
delivery cannot be had, being a sum in excess of $6000.00; and
(3) Any and all other relief which this Court deems appropriate.
February 4, 2004
Peter B. Foster
Attorney for Plaintiffs
Pinskey & Foster
121 South St.
Harrisburg, PA 17101
(717) 234-9321
4
VERIFICATION
The undersigned is Earlanda Holland. I verify that the statements made in the foregoing
Complaint in Replevin are true and correct to the best of my information, knowledge and belief.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §
4904, relating to unworn falsification to authorities.
February 4, 2004
Earlanda Holland"
VERIFICATION
The undersigned is Keith Holland. I verify that the statements made in the foregoing
Complaint in Replevin are true and correct to the best of my information, knowledge and belief.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §
4904, relating to unworn falsification to authorities.
February 4, 2004 19'?'( ,//?//1L
Keith Holland
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KEITH HOLLAND and
EARLANDA M. HOLLAND,
Plaintiff's
VS.
.ANTHONY MAGARO,
Defendant
NO 04-480 CIVIL
CIVIL ACTION - LAW
REPLEVIN ACTION
ANSWER TO COMPLAINT
1. Admitted.
2. Admitted.
3. Denied. Earlanda M. Brown n/k/a Earlanda M. Holland transferred the title
to the vehicle to MR. SANDMAN, INC., a Pennsylvania business corporation
for which Defendant, Anthony Magaro, is the President, on January 23,
2004, thereby ownership is vested in MR. SANDMAN, INC. By way of further
answer Defendant avers that EAR.I.ANDA M. BROWN held title to the subject
vehicle as a straw party for KEITH HOLLAND, for reasons which have never
been disclosed and the fact of such a titling which was never disclosed to MR.
SANDMAN, INC. Strict proof of the averment is hereby demanded.
4. Denied. On the contrary Defendant avers that the subject vehicle is worth
only $1,000.00. Strict proof of the averment is hereby demanded
5. Denied. On the contrary, on January 23, 2004, all parties to this action met
at Central Pennsylvania Motor Club in Camp Hill, Pennsylvania, to transfer
the title to the subject Van, and it was at that time that MR. SANDMAN, INC.
learned that the Van had been titled in the name of Earlanda M. Brown. The
title transfer documents were signed and notarized and the transfer fees
were paid by MR. SANDMAN, INC., however physical possession of the
vehicle remained in Mr. Holland at that time since it was intended that Keith
Holland was continuing a business relationship with MR. SANDMAN, INC. as
an employee effective February 1, 2004. On January 24, 2004, Anthony
Magaro having received numerous complaints from MR. SANDMAN, INC.
customers that Keith Holland had been failing to proceed and complete floor
jobs on a timely basis, Anthony Magaro determined that Keith Holland would
not able to remain even as an employee of MR. SANDMAN, INC. At that time
Mr. Holland delivered the keys to the subject vehicle to MR. SANDMAN, INC.
and the vehicle was moved to Camp Hill, PA. Thereafter the Plaintiffs entered
the Business property of MR. SANDMAN, INC, without permission,
knowledge or consent from MR. SANDMAN, INC., and removed not only the
subject vehicle with the tools described in COUNT II of to Complaint but also
the folder containing all of the documentation regarding the business
dealings between MR. SANDMAN, INC and KEITH HOLLAND. Subsequently
MR. SANDMAN, INC. located the van, made a recovery of possession without
a breach of the peace. Strict proof of the averment is hereby demanded.
6. Admitted.
7. Denied. On the contrary possession of the vehicle resides in MR. SANDMAN,
INC. pursuant to the title transfer made by Earlanda M. Brown on January
23, 2004 and the surrender of possession by Keith Holland on January 24,
2004. Strict proof of the averment is hereby demanded.
8 Denied. On the contrary Defendant avers that while Earlanda M. Brown is
the record owner of the subject vehicle, she had transferred title thereof to
MR. SANDMAN, INC. on January 23, 2004, and thereafter fraudulently
procured a duplicate title from the Pennsylvania Department of
Transportation by falsely claiming that the original title had become lost or
destroyed, when in fact the title had been transferred to MR. SANDMAN, INC.
for valuable consideration.
WHEREFORE, Defendant requests that the Court dismiss this Complaint with
prejudice.
9. No answer is required to this averment.
10. Denied. The said tools had been purchased with funds provided by MR.
SANDMAN, INC. for the sole and express purposes of making a loan to
Plaintiff, Keith Holland, to assist Keith Holland in establishing a sub-
contractor floor refinishing business affiliated with MR. SANDMAN, INC.,
which loan was intended by Plaintiff and Defendant to be repaid on a regular
basis. Strict proof of the averment is hereby demanded.
11. Denied. By way of further answer, from and after June 30, 2003, Keith
Holland engaged in the business of floor reSnishing as a subcontractor for
MR. SANDMAN, INC., using the vehicle referenced in Count I and equipment
purchased with funds provided by MR. SANDMAN, INC. and using materials
provided by MR. SANDMAN, INC. In January, 2004, it became apparent to
Anthony Magaro that the loan/subcontract arrangement with Mr. Holland
was not functioning as intended when the loan funds had been advanced for
the purchase of the vehicle and tools. MR. SANDMAN, INC. and Keith
Holland agreed that Mr. Holland would become an employee of MR.
SANDMAN, INC., as of February 1, 2004, and turn aver the subject vehicle
and floor finishing equipment and materials to MR. SANDMAN, INC.
12. Denied. Defendant is without knowledge or information sufficient to form a
belief as to the truth of the averment, and strict proof of the averment is
hereby demanded.
13. Denied. On the contrary, MR. SANDMAN, INC. had received possession and
ownership of the said tools from KEITH HOLLAND on January 24, 2004.
Strict proof of the averment is hereby demanded.
14. Admitted. See paragraph S above
18. Denied. The tools are presently located at the business office of MR.
SANDMAN, INC., as herein averred and are not in the possession Anthony
Magaro. Strict proof of the averment is hereby demanded.
16. Denied. The tools were voluntarily transferred by Mr. Holland to MR.
SANDMAN, INC., in exchange for partial cancellation of the debt obligation
owed by KEITH HOLLAND to MR. SANDMAN, INC. Strict proof of the
averment is hereby demanded.
WHEREFORE, Defendant requests that the
prejudice.
Robert G. Radebach, Esquire
I.D. # 19255
107 Locust Street
Harrisburg, PA 17101
(717) 234-6655
Attorney for Defendant
with
I verify that the statements made in this Answer 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.
Dated: February IZ , 2004 MR. SANDMAN, INC.
BY:
Anthony F. I garo, CEO
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SHERIFF'S RETURN - REGULAR
CASE NO: 2004-00480 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOLLAND KEITH ET AL
VS
MAGARO ANTHONY
KENNETH GOSSERT
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - REPLEVIN was served upon
MAGARO ANTHONY
the
DEFENDANT , at 1615:00 HOURS, on the 6th day of February , 2004
at 515 SOUTH 32ND STREET ANNEX
CAMP HILL, PA 17011
by handing to
ANTHONY MAGARO
a true and attested copy of COMPLAINT - REPLEVIN together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs
Docketing 18.00
Service 10.35
Affidavit .00
Surcharge 10.00
.00
38.35
Sworn and Subscribed to before
m--eJJ this 13 0-? day of
J(? o7oa y\ A.D.
Prothonotary
So Answers:
R. Thomas Kline
02/09/2004
PETER FOSTER
By:
Dep t ri f
KEITH HOLLAND and EARLANDA M. . IN THE COURT OF COMMON PLEAS,
HOLLAND, CUMBERLAND COUNTY,
Plaintiffs PENNSYLVANIA
V.
NO. 04-480 Civil
ANTHONY MAGARO, CIVIL ACTION - LAW
Defendant
REPLEVIN ACTION
ATTORNEY PETER B. FOSTER'S MOTION TO WITHDRAW AS COUNSEL
FOR PLAINTIFFS' KEITH HOLLAND AND EARLANDA HOLLAND
AND NOW, this 19" day of January, 2005, comes Attorney Peter B. Foster and requests
this Court for permission to withdraw as counsel for Plaintiffs Keith Holland and Earlanda M.
Holland and, in support thereof, avers as follows:
Attorney Peter B. Foster is counsel of record for Plaintiffs Keith Holland and
Earlanda M. Holland.
2. At the inception of this lawsuit, Plaintiffs agreed to pay Attorney Peter B. Foster
$100.00 per hour for his legal services in representing them in this lawsuit.
Despite repeated demands by Attorney Foster, Plaintiffs have failed to pay
Attorney Foster any fee monies relative to his legal fees for legal services performed in
representing Plaintiffs in this lawsuit.
WHEREFORE, Attorney Peter B. Foster, Esquire, respectfully requests this Honorable
Court for permission to withdraw as counsel for Plaintiffs in this civil litigation.
Respectfully submitted,
0 sler \`J,q
Peter B. Foster, Esquire
Pinskey & Foster
114 South Street
Harrisburg, PA 17101
(717) 234-9321
VERIFICATION
I, Peter B. Foster, hereby verify that the statements made in the foregoing Motion for
Permission to withdraw as Counsel for Plaintiffs 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 unworn
falsification to authorities.
January 19, 2005
Peter B. Foster
CERTIFICATE OF SERVICE
I hereby certify that on this date, January 19, 2005, I served a copy of the foregoing
Motion for Permission to Withdraw as Counsel for Plaintiffs on the Plaintiffs and Defendant by
mailing said copies by first class mail at Harrisburg, PA to Plaintiffs and the attorney for
Defendant at the following addresses:
Keith and Earlanda Holland
550 Camp Street
Harrisburg, PA 17110
Robert G. Radebach, Esquire
Attorney for Anthony Magaro
912 North River Road
Halifax, PA 17032
January 19, 2005 ?? t;•
Peter B. Foster, Esquire
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JAN 2 5 200 5
KEITH HOLLAND and EARLANDA M. . IN THE COURT OF COMMON PLEAS,
HOLLAND, . CUMBERLAND COUNTY,
Plaintiffs PENNSYLVANIA
V. NO. 04-480 Civil
ANTHONY MAGARO, CIVIL ACTION - LAW
Defendant
REPLEVIN ACTION
ORDER
AND NOW, this '20 day of January, 2005, upon consideration of Attorney Peter B.
Foster's Motion for Permission to Withdraw as Counsel for Plaintiffs, said Motion is granted and
Attorney Peter B. Foster is permitted to withdraw as counsel for Plaintiffs Keith Holland and
Earlanda Holland in this Action.
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Curtis R. Long
Prothonotary
Office of the Protbonotarp
Cumberland Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
bq • j7e?0 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square - Carlisle, Pennsylvania 17013 - (717) 240-6195 - Fax (717) 240-6573