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HomeMy WebLinkAbout08-3365 F.\FILESTlients\10595 S Harvey\10595.4\I0595.4.complaint Hubert X. Gilroy, Esquire I.D. No. 29943 Katie J. Maxwell, Esquire I.D. No. 206018 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SCOTT W. HARVEY, Plaintiff V. STACIE SHEELY, Defendant :IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08 - 33l 6 CIVIL TERM 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 Plaintiffs. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 1 Hubert X. Gilroy, Esquire I.D. No. 29943 Katie J. Maxwell, Esquire I.D. No. 206018 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SCOTT W. HARVEY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 335 CIVIL TERM STACIE SHEELY, Defendant COMPLAINT AND NOW, comes the Plaintiff, by and through his attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and hereby avers the following: Scott W. Harvey is an adult individual residing at 6342 North Powderhorn Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant, Stacie Sheely, is an adult individual residing at 1139 Sandpiper Court, Mechanicsburg, Cumberland County, Pennsylvania. 3. Over the course of the last year, Plaintiff has given Defendant $9,000.00 as a loan. 4. Plaintiff gave Defendant these monies with the understanding that the funds would be repaid in full. 5. Defendant has failed to return any of the monies forwarded to her by the Plaintiff. 6. Plaintiff has repeatedly requested the return of all monies paid. 7. Defendant has failed to reply to any of Plaintiff's requests. WHEREFORE, the Plaintiff requests that judgment be entered against the Defendant for $9,000.00, plus interest and costs, together with such other relief as is deemed just and reasonable by this court. MARTSON LAW OFFICES By /? a'?i?" • i' "? Hubert X. C?Wyl Esquire I.D. No. 29943 Katie J. Maxwell, Esquire I.D. No. 206018 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff VB ICATI N The foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit The language of the document is that of counsel and not my own. I bave read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statennent and verification, we made subjoct to the penalties of 19 Pa. C.S. Section 4904 relating to unswom falsification to authorities, which providers that if I make knowingly false averments, I may be subject to criminal penalties, Scott W. HWvey (?? r.v?a,Rnc?rwAiol?s ? Mw+.arwrisAt?owl?s.??Mlr ?) t?J J ? ? `? -r3 o(A SHERIFF'S RETURN - REGULAR CASE NO: 2008-03365 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HARVEY SCOTT W VS SHEELY STACIE SHAWN HARRISON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHEELY STACIE the DEFENDANT , at 1017:00 HOURS, on the 14th day of June , 2008 at POLISHED SPA LEMOYNE, PA 17043 (ITT /'PTT C+TTT-I=T V by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 16.00 Affidavit .00 Surcharge 10.00 4//?r?0 g L?.- 00 44.00 Sworn and Subscibed to before me this day 829 STATE STREET So Answers: R. Thomas Kline 06/16/2008 MARTSON LAW OFF S By: Deputy Sheriff of A. D. "r. C7 FARLES\Clients\10595 S Harvey\10595.4\10595.4.pra Hubert X. Gilroy, Esquire I.D. No. 29943 Katie J. Maxwell, Esquire I.D. No. 206018 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SCOTT W. HARVEY, Plaintiff V. STACIE SHEELY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 3365 CIVIL TERM PRAECIPE To the Prothonotary: Please mark the above-captioned matter discontinued without prejudice. MARTSON LAW OFFICES By_ Zj? 6/3o/Ot Hubert Xkilroy, Esquire I.D. No. 29943 Katie J. Maxwell, Esquire I.D. No. 206018 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff N CERTIFICATE OF SERVICE 1, Mary M. Price, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Stacie Sheely Polished Spa 829 State Street Lemoyne, PA 17043 MARTSON LAW OFFICES By M Price Ten E t High Street Carlisle, PA 17013 (717) 243-3341 Dated: q3ol 00pe 71-7 , 4r,,) ' m C.xn.