HomeMy WebLinkAbout10-2917n
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
KAREN L. SCHWARZ, NO. I ' A4 1
Plaintiff
CIVIL ACTION - LAW
V.
HURD P. ANSTADT,
Defendant
JURY TRIAL DEMANDED
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFENDANT
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 OR 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
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32 SOUTH BEDFORD STREET
CARLISLE, PA 17013 = - - -T1
1-800-990-9108
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717-249-3166 _{
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY PENNSYLVANIA
KAREN L. SCHWARZ, NO.
Plaintiff
CIVIL ACTION -
V. LAW
HURD P. ANSTADT, JURY TRIAL DEMANDED
Defendant
COMPLAINT FOR MALICIOUS PROSECUTION
1. The Plaintiff, Karen Schwarz, is an adult individual who resides at 445 North
Second Street, Wormleysburg, Cumberland County, Pennsylvania, 17043.
2. The Defendant, Hurd P. Anstadt, is an adult individual who resides at 443 North
Second Street, Wormleysburg, Cumberland County, Pennsylvania, 17043.
3. On April 29, 2009, Defendant, through the police, brought a District Justice
Action against Plaintiff for a violation of the Pennsylvania Dog Law. On April 29, 2009,
Defendant through the police, brought a District Justice Action against Plaintiff for Harassment.
On February 24, 2010, Defendant, through the police, brought a District Justice Action for
Disorderly Conduct against Plaintiff. Copies of these charges are attached as Group Exhibit "A".
4. The charges of a violation of the Pennsylvania Dog Law Act and Harassment had
no evidentiary basis and were dismissed at the District Justice level. The charge of Disorderly
Conduct has no evidentiary basis and is pending before a District Justice.
5. Plaintiff avers that she is and always has been a good, true, honest, virtuous and
law-abiding citizen; that she has always behaved herself and has thereby earned the respect of
her neighbors and associates, and that she has not at any time been guilty of any crime or
unlawful act, prior to the willful and malicious acts of the Defendant.
._ ,
6. The bringing of the aforementioned charges was unlawful and without just or
reasonable cause of any kind and the acts of the Defendant were willful and malicious.
7. As a result of the above, Plaintiff has been brought into disrespect and ill repute
among her friends, neighbors and associates; that she has undergone great suffering of mind and
body; that she has been subject to great humiliation and that she has been otherwise greatly
injured and damaged.
8. Plaintiff further avers that she has been put to great expense and loss of time in
defending these false accusations and has been prevented from attending to her usual and
necessary duties and has thereby suffered great and irreparable financial loss in her daily
activities.
9. The said injuries and damages were caused solely by the unlawful and malicious
trespass of the Defendant.
10. As a result of the malicious, wanton and willful conduct of the Defendant,
Plaintiff demands punitive damages.
WHEREFORE, for all the foregoing reasons, Plaintiff demands damages in a sum in
excess of the compulsory arbitration limits.
vg??C
April 2010
Peter B. Foster, Esquire
Attorney for Plaintiff
114 South Street
Harrisburg, PA 17101
717/234-9321
I.D. # 15357
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Verification
I, Karen Schwarz, hereby verify that the facts set forth in the foregoing Complaint
are true and correct to the best of my information, knowledge and belief. I understand
that false statements herein made are subject to the penalties of 18 Pa. C.S.A. §4904,
unsworn falsification to authorities.
April r?,1CJ , 2010 4?WUIVI'- f
Karen L. Schwarz
of cuzj
David D. Buell- c r e P Renee Simpson
Prothonotary
q 1St Deputy Prothonotary
V to f o
Irene E. 911orrow
�irkS. Sohonage, ESQ
Solicitor 7750 2nd Deputy Prothonotary
Office of the Prothonotary
Cumberland County, Pennsylvania
16 — .29/7 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 • CarCsle, PA 17013 • (717)240-6195 • Fad(717)240-6573