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Home My WebLink About09-822469-~~a ~ PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ;ss AFFIDAVIT: I hereby (swear) (affirm) that I served a copy of the Notice of Appeal, Common Pleas No. 2009-8224, upon the District Judge designated therein on (date of service) November 25, 2009, ^ by personal service ~by (certified) (.~~$ictPrP~) mail, sender's receipt attached hereto, and upon the appellee, (name) Stephanie Finkenbinder, on November 25, 2009 ^ by personal service by (certified) (~~~ mail, sender's receipt attached hereto. (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS~~ DAY OF /U6u2r~,c.l~e~ , 2009. Signature of official lie or wh m affidavit was made ~~ Title of official ~-~- Signature of affiant My commission expires on 'N'~~ Y T L Pe6MSr NoWYP~c qa $°~8°q' 41D~'t wp Nay fTl ~ . - • f1J LJ7 ~" - ~ Postage $ L ~ Certified Fee ° ° Retum Receipt Fee ° (Endorsement Required) Restricted Delivery Fee ° (Endorsement Required) ° ° Total Postage 8 Fees --{ Postmark Here ° Street, A- t 1Vo.; • N or PD Box No. ~ ~ Yo /t .n _ ~[~_r~ ~'Q-,, _ ----------------- - ( l '-'-'-'---' l v. City, St ZIP+4 ----~----~---~----------- (l -e t~.4- :r~ i~. U S . . Post al Ser vice ~ ,, CE RTIF IED I VIAIL REC ~n, EIPT (Dom estic M ail Only ; No Ins urance C overage Provided) FOf fl ail VEN i nf nrmnfi.,. , ..~~:~ ... . _ ..._ ~ _ .. ~' ._ O ca Postage $ ~ ~~- ~ Certified Fee Q /, O Y o l.J O ~ Retum Receipt Fee (Endorsement Required) Postmark ~, Here O Restricted Delivery Fee (Endorsement Required) ~ Total Postage & Fees 0-" ant _ ~~ O p - ---•-- --- - ~ ~ _ Street, Apt. No.; ---------- ------------- t_` ~ '- - °---• r' or PO Box No. city, Stare, z~lp+a --- - ------------ ~ ra roan 3800. Au us[ 2006 -~~~~ See Reverse for Instructions rik fit`: ";:.`" rr,, n , n ~,,, v . ~ it .~ .._ Stephanie Finkenbinder Court of Common Pleas (Plaintiff) Docket No. CV-125-09 VS. Old Town Homes LLC. Civil Action 09-8224 C/O Daniel Parson Jr. Complaint for Security Deposit (Defendant) 231 Pa. Crde ~.~>~e 2~7 To: Rominger and Associates 155 S. Hanover Street Carlisle, PA 17013 ~ p ~4i Date of Notice: March 9, 2010 ~± ~ r-., . ._ o ~ , ~ ~`~ } '; + , ~ ~ ` Y IMPORTAN ~' T NOTICE ~_ w YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN :~ 4 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 ANDYOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013-3302-32 `~ `~ (Plaintiff Signature) Ste h Finkenbind 14 No High Street Newville, PA 17241 U ~~ r rn ~~ -r -j ~, ~rn -~ STEPHANIE FINKENBINDER, Plaintiff v. OLD TOWN HOMES, LLC C/O DANIEL PARSON, JR., Defendant TO: Stephanie Finkenbinder, pro se 14 North High Street Newville, Pennsylvania 17241 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 0 4 -sz,~~ NO.-6H-i'2~ CIVIL TERM CIVIL ACTION -LAW NOTICE TO PLEAD ~ ~ J ^^ ,, . { c , -. `- -~ ~~ ~ ~ ~ You are hereby notified to file a written response to the enclosed within twenty (20) days from service hereof or a judgment may be entered against you. Respectfully Submitted, Rominger & Associates Date: March 19, 2010 Karl F/Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendants STEPHANIE FINKENBINDER, 1N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v• NO. 09-125 CIVIL TERM OLD TOWN HOMES, LLC CIVIL ACTION -LAW C/O DANIEL PARSON, JR., Defendant DEFENDANT'S PRELIMINARY OBJECTIONS TO COMPLAINT AND NOW, comes Defendants, Old Town Homes, LLC and Daniel Parson, Jr., by and through their counsel, Karl E. Rominger, Esquire, and in support of his Preliminary Objections, avers as follows: 1. It is not clear from the pleadings who is being sued, as the caption says Old Town Homes, LLC C/O Daniel Parson, Jr.. 2. Daniel Parson, Jr. is an adult individual sui juris. 3. Old Town Homes, LLC is a limited liability company. 4. The parties feel compelled to enter their appearance and object in case they are the intended targets of this law suit. 5. Paragraph 2 of the complaint fails to define who or what the defendant is, and the answering parties suggest in fact that there is no such entity as "Town Homes, LLC C/O Daniel Parson, Jr." 6. The failure to define the defendant renders the complaint invalid. 7. Further, there is 'no claim that either individual is the land owner of the tenancy subject to this complaint. WHEREFORE Defendant requests this Court dismiss the complaint for the failure to state a real party in interest and / or a claim for relief. Respectfully Submitted, Rominger & Associates Date: March 19, 2010 Karl ~Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendants STEPHANIE FINKENBINDER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 09-125 CIVIL TERM OLD TOWN HOMES, LLC CIVIL ACTION -LAW C/O DANIEL PARSON, JR., Defendant CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, certify that I this day served a copy of the within Defendants Preliminary Objections to Complaint upon the following by depositing a copy of the same in the United States Mail, first class, postage prepaid, addressed as follows: Stephanie Finkenbinder, pro se 14 North High Street Newville, Pennsylvania 17241 Respectfully Submitted, Rominger & Associates ~~ Date: March 19, 2010 Karp. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendants David D. Buell °Q 1enee 7 Simpson Prothonotary 5` Deputy Prothonotary � � -.,� .� y p y v .' °` Irene E. Morrow�irkS. Sohonage, ESQ _.�-��-s Solicitor 7750 2nd Deputy Prothonotary Office of the Prothonotary Cumberland-County, Pennsylvania 69-82z.y CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER, 2013,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, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • Fax(717)240-6573