HomeMy WebLinkAbout10-2263MICHELLE CORSETTI, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVA NIA
PLAINTIFF k DOCKET NO
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PAUL TIMMONS, R
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DEFENDANT CIVIL ACTION LAW -'q
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NOTICE TO DEFEND
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS
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CUMBERLAND COUNTY BAR ASSOCIATION
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNYSYL VANIA
Michelle Corsetti IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : No.
Paul Timmons
Defendant : CIVIL ACTION -LAW
COMPLAINT
WHEREFORE COMES Now Plaintiff, Michelle Corsetti, by and through her counsel, Kusha A.
Desai and Palmer Lockard, on the 31_ day of March 2010, and avers as follows
1. Plaintiff is Michelle Corsetti, an adult residing at 4103 Gettysburg Pike, Apartment 4,
Camp Hill, PA 17011.
2. Defendant is Paul Timmons, an adult residing 1025 Northfield Dr., Carlisle, PA 17013
3. In 2003, Defendant gave;a dog to Plaintiff as a gift.
4. Sometime thereafter, Plaintiff and Defendant shared a residence in Florida.
5. On or about July 2009, Plaintiff and Defendant ended their personal relationship.
6. On or about July 2009, the parties entered an oral agreement in which Defendant agreed
that Defendant would care for dog till Plaintiff, who moved to Pennsylvania, could find
an apartment that would allow pets.
7. On or about October 2009, Plaintiff settled into her new apartment which allowed pets.
8. On or about November 2009, Defendant returned to Pennsylvania with the dog but did
not notify the Plaintiff.
9. On or about December 2009, Plaintiff went to Defendant's residence and to demand the
dog's return.
10. On or about January 5 `h, 2010, Plaintiff sent a letter to Defendant demanding the dog be
returned to Plaintiff otherwise legal action would be taken.
11. On or about January 2010, Defendant responded to Plaintiff's letter stating he would not
return the dog.
COUNT ONE - BREACH OF BAILMENT AGREEMENT
12. Paragraphs 1-11 are incorporated by reference hereto.
13. Plaintiff and Defendant reached an oral agreement of the temporary care of the dog to be
provided by the Defendant.
14. Plaintiff left the dog in the care of the Defendant.
15. Plaintiff sent a letter of demand on January 5th, 2010.
16. Defendant breached the agreement when the dog was not returned after the demand letter.
17. Defendant has not returned the dog or made any attempts to return the dog.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter judgment in favor
of the Plaintiff in returning the dog in addition to any other costs the Court deems appropriate.
COUNT TWO - REPLEVIN ACTION
18. Paragraphs 1-18 are incorporated by reference hereto.
19. Plaintiff wants to regain possession of the dog.
20. Defendant has detained the dog and not allowed Plaintiff to see or care for it after
demand was made.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter judgment in favor
of the Plaintiff in returning the dog in addition to any other costs the Court deems appropriate.
Date: 51 Z hd'o
XtA)t, /0,94.
Kusha A. Desai
Certified Legal Intern
Palmer Lock ar , Esquife
Supervising Attorney
Id. No. 33681
Harisburg Civil Law Clinic
Widener University School of Law
3605 Vartan Way, 2nd floor
Harrisburg, PA 17110
WIDENER UNIVERSITY SCHOOL OF LAW
HARRISBURG CIVIL LAW CLINIC
3605 VARTAN WAY, 2ND FLOOR
HARRISBURG, PA 17110
717-541-0320; FAX #717-909-0442
IawclinichbCcD-mail.widener.edu
MICHELLE CORSETTI,
PLAINTIFF
VS.
PAUL TIMMONS,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
DOCKET NO.
CIVIL ACTION LAW
VERIFICATION
I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. § 4904, relating to unsworn falsification to authorities.
DATE: ?/U , ZZ)
MIC ELLE CORSETTI, PLAINTIFF
i
i
HARRISBURG CIVIL LAW CLINIC
WIDENER UNIVERSITY SCHOOL OF LAW
3605 VARTAN WAY, 2ND FLOOR
HARRISBURG, PA 17110
(717) 541-0320
MICHELLE CORSETTI,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Ib - to3 0,Vit It°m
VS.
PAUL TIMMONS,
DEFENDANT
: CIVIL ACTION
c
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PRAECIPE TO PROCEED IN FORMA PAUPERIS
To The Prothonotary:
Kindly allow Michelle Corsetti, Plaintiff, to proceed in forma pauperis.
I, Kusha Desai, Certified Legal Intern, for the party proceeding in forma pauperis, certify
that I believe the party is unable to pay the costs and that I am providing free legal service to the
party.
Date: 3 3i J C-)
us a Desai, Certified Legal Intern
J. Palmer Lockard, Esquir
Id. No. 33681
O F c 416'e
David®. Buell- ;' Wine X Simpson
Prothonotary r .T ¢Hk� Z 1St Deputy cProthonotary
KirkS. Sohonage, ESQ 4 Irene E. Morrow
Solicitor T 7 50 2nf Deputy Prothonotary
Office of the Prothonotary
CumberCanciCounty, cPennsy[vania
JO —€2.2L 2 CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 291" 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 • Fa.,(717)240-6573