HomeMy WebLinkAbout01-4794COMMON~YEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
JUDICIAL DISTRICT
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
CC ,*ONPL,ASN 01- ?'-J
NOTICE OF APPEAL
Notice is giv~q that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice off the
date and in the case mentioned below.
~is ~k will ~ ~ ONLY ~n ~is ~mfi~ is required u~er P~ R.C~. ~
1~8~
T~s ~t~e of A~al, ~n ~ei~ by t~ Dis~ict Jus~ce, will ~emte as o
~PER~DEAS ~ the j~gm~t f~ ~ssi~ in this case
Signature of Prothonot~y or Deputy
If appellant was CLAIMANT (see Pa. R.C.P.J.P. No.
1 O01 ( 6 ) in action before District Justice, he MUST
FILE A COMPLAINT within twenty (20) days after
filing his NOTICE of APPEAL.
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of fon'n to be used ONLY when al:~oellan~ was DEFENDANT (see Pa. R.C.P.J.P No. 1001 (7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prothoe~tory
Ente~ rule upm~ , appellee(s), to file a complaint in this appeal
(Common Pleas ~ ) within twenty (20) days after service of rule o~ suffer entry of judgment of non pros.
RULE: To , appellee(s).
(1) You am notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of
set'vice of this rule upon you by personal service or by certified or registered mail
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of mailing.
Date: , 19 .
COURT FILE TO BE FILED WITH PROTHONOTARY
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED W~THIN TEN (?0) DAYS AFTER fiting the notice of appeal. Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY
AFFIDAVIT: i hereby swc~ar or affirm that I served
[~ a copy of the Notice of Appeal, Common Pleas No
(date of service)
receipt attached hereto, and upon the appellee
, upon the District Justice designated therein on
· ~ by personal service E~ by (certified) (registered) mail, sender's
mail sender's receipt aItached hereto
SWORN (AFFIRMED) AND SUBSCRtB[D BEFORE ME
--.- . 19________ ~ by personal service [] by (certified) (registered) mail sender's receipt attached hereto
~ and furtherthat~servedtheRu~et~Fi~eaC~mpt~intacc~mpa~yn~theab~veN~tice~fAppea~up~ntheappe~ee(s)t~wh~m
he Rule was addressed on , 19 ..~ ~ by personal servce ~ by (certified) (registered)
Signature of affiant
COI~IMcO'I(IWEALT'",¢'t oF PP~NSYLVANIA
COUNTY OF: CUMBER~'.,AND
'09:3-05
GAYLE A. ELDER
507 N. YORK ST.
MECHANICSBURG, PA
(717) 766-4575 17055
RICHARD R. BUCHER
214 S HIGH STREET
MECHANICSBURG, PA 17055
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
214 S HIGH STREET
MECHANICSBURG,~ ~.P_A L70~5.=~
L ~ VS. ','
DEFENDANT: NAME and ADDRESS
WGRIFFIN, M. DAVID -q
2ND FLOOR APT
214 SOUTH HIGH ST REAR
iMECHANICSBURG, PA 17055
Date Filed: 6/01/01
THIS IS TO NOTIFY YOU THAT:
Judgment:
F~ Judgment was entered for: (Name)
F~ Judgment was entered against: (Name)
in the amount of $
A~_ O0 on: (Date of Judgment) '7/1 ~/nl
Defendants are jointly and severally liable.
Damages will be assessed on:
(Date & Time)
~--] This
Amount of Judgment $ .00
~ Judgment COSTS $ 56.00
lnterbst on Judgment $ .00
~' : - ,.~'~ Attorney Fees $ . O0
Total $ 56. O0
of 11996 '$ .-
[-~ Levy is stayed f~'r da~s or [~ generally stayed.
Oblectlon to Io~.o~ has been hied and heanng W;~be held:
Date: ~2 ~ Place:
Time: ~
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
7/'/~'I¢, Date . ~/~:=:;~ d'~..~.(/ ''_ ~.'7 ,District Justice
II certif~ that thi~ is a true and correct copy of the record of the proceedings containing the judgment.
Date , District Justice
My commission expires first Monday of January,
AOPC 315-99
2006 SEAL
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 the notice of appeal Check applicable boxea
COMMONWEALTH OF PE~NSYLVANI~
COUNTY OF CLX. I,vt ~...~' I~ ~ ;$$
AFFIDAVIT: I hereby swear or affirm that l served C~, ~00}--0~
(date olservice) ~J~j~OI __ , ~.by p~sonal~[rvi~ ~rtified)(registered) mail, sender's
red, pt atta~h~eret0, anU up0q the appellee, (name) [~, U ~VI q (~ ~ ~ ~ ~ I ~ __, on
~ ~.~ ~ , ~O~ ~ by persona se~ice~y (cedi(ed) (registered) ma t, sender's receipt aUsch~ hereto
~ and fu~her tha~served the Rut~ to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom
the Rule was addressed on , 19 , ~ by ~rsonal service ~ by (cedi(led) (registered)
mail, sender's receipt attached hereto,
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
RICHARD R. BUCHER,
Plaintilk
VS.
M. DAVID GRIFFIN,
Defendant.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action No. 01-04794
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend the claims set forth in the
following pages, you must take action within twenty (20) days atter this Complaint and Notice are
served, by entering a written appearance personally or by 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 fights 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania
(717) 249-3166
RICHARD IL BUCHER,
Plaintifl~
VS.
M. DAVID GRIFFIN,
Defendant.
1N THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
:
Civil Action No. 01-04794
.
:
: CIVIL ACTION - LAW
:
: JURY TRIAL DEMANDED
COMPLAINT
NOW COMES, Plaintift~ Richard R. Bucher, by and through his attorneys, TOMASKO &
KORANDA, P.C., and files the following Complaint against Defendant, M. David Griffin,
averring as follows:
Parties
1. Plaintiff, Richard R. Bucher is an adult individual presently residing at 214 South
High Street, Meehanicsburg, County of Cumberland, CoImnonwealth of Pennsylvania.
2. Defendant, M. David Griff~ is an adult individual residing at 619 Apple Drive,
Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania.
3. Plaintiffis the owner and/or operator of a second floor rental/lease property or
apartment located at 214 South High Street, Rear, Mechaniesburg, County of Cumberland,
Commonwealth of Pennsylvania.
Venue and Jurisdiction
4. Venue is proper in this judicial district pursuant to Rule 1006(a) of the
Pennsylvania Rules of Civil Procedure.
5. The monetary damages claimed by Plaintiff against Defendant do not exceed the
jurisdictional limit requiring compulsory arbitration pursuant to the Local Rules of this Court.
Count I: Violation of Le~e Agreement
6. On July 8, 2000, Plaintiff and Defendant entered into a one (1) year
landlord-tenant lease agreement (hereinafter "lease"), wherein Plaintiff agreed to rent a second
floor apartment and one car garage located at 214 South High Street, Rear, Mechanicsburg,
Pennsylvania (hereina~er "second floor apartment") to Defendant from August 1, 2000 through
July 31, 2001 [A true and correct copy of the lease is attached hereto and marked as "Exhibit A"].
7. Under the terms of the lease, Defendant would live in, occupy, or otherwise
possess the second floor apartment for the term of the lease. In return, Defendant would pay
$9,540.00 in monthly installment payments of $795.00 to the Plaintiffon the last day of each
month for the term of lease, namely twelve (12) months.
8. Defendant made monthly rental payments in the amount of $795.00 for ten (10)
months of a twelve (12) month lease.
9. Defendant has failed and/or refused to make monthly rental payments for the
months of June and July 2001 as required under the lease.
I0. Under the terms of the lease, Defendant was also required to pay for all electricity
usage thru meter no. 35117782.
11. Defendant has also failed to pay the electricity bill in the amount of
$60.97 thru the month of July 2001 that was recorded thru meter no. 35117782.
12. Accordingly, Plaintiffhereby requests an award in the amount of $1,650.97 as
payment for electricity thru meter no. 35116682 and as payment for rent for the months of June
and July, 2001.
-2-
Count H - Material Damages to Apartment and Forfeiture of Seeuritv Deposit
12. Under the t~mts of the lease, Defendant was respons~le to return the second floor
apartment in the same good order as which it was delivered, excepting reasonable wear and tear.
13. As part of said lease, Defendant was also required to pay an additional deposit
in the amount of one (1) month's rent or $795.00 for possession of the residence to be held as
security and subject to return to tenant only iff
a. One year lease is not broken;
b. 30 day notice to move is given to lessor in any month afler the one year lease
period;
c. No damage to any property owned by the lessor; and,
d. Afler moving the apartment must be cleaned and all trash removed.
14. During Defendant's entry, residence, and departure fi.om the second floor
apartment, Defendant caused substantial damage to the physical structure of the apartment,
including some damage which Plaintiff alleges is unmpalrable. Additionally, Defendant did not
clean or otherwise remove all trash from the apartment at the time he vacated the premises.
15. Defendant also failed to return the apartment in good order as it was delivered and
as required under the lease prior to departing the second floor apartment.
16. Defendant has forfeited his security deposit under the provisions of the lease.
17. Defendant's violation of the lease and damage to the apartment caused
damages, maintenance, and repair above and beyond normal wear and tear and which for which
Plaintiff is entitled to reimbursement and/or compensation.
18. As a result of said damages, maintenance, and repair, Plaintiff suffered, to
his detriment, an ascertainable loss of money and property, both real and personal, in the amount
of $2,344.00 for which a claim is hereby made. [A true and correct copy of a description of
-3-
herein called LEsso~, hereby Lc.. to ,~, i~)~¥i~
herein called TENANT for the term of O/~ y¢~)~. -- '~Smmendn. g on the /"~---'/~'.__-----
of ~
~'~1 A.D. ~D~and ending on the ~/~-~dayof ~Lu
following described premises and street to ~e center, subject to the public easement therein, in its present con-
The FellQwing are fm~ther agreements betwee~ ~' _ ~'
~a ~Ar. ~ard ~. ~mer ~.Aess~J. .~ ~
~~_~ .... es~ el_ I
Pe~ ~t~.
~~~ octopi ed.
, ad di t~er month. Only
.in
3. Ne pe~l~we~ lm ' e~a apprevml
~~ h~s been given to
~~11 be the on~y per~on~lewed to
reside in aPartm~If m~y veins to this are demlre~
prier ~v~ mmst be~ frem lesser. ~Pr~v~l
m~st be i~itin~~ia~ made ~themt prier
apprev~~m~ of ~ person Per
~ ~ the
~. ~a e~se who is ~nv~lve~ in a~
· il .
6. NcthlRg can be pasted em ceiling, walls amd w~odwerk.
Omly a very thin mail may be rased to h~ng items.
No lemd mmsic er incise will be allowed.
This se~rity ~ll be returned to ten~nt(s) iff~
ao One yeor lease is not bremen.
b. 30 dsy notice to reeve is given~o le~'sor in any
memth after the ene year lease Peried.
e. No dmm~ge $o ~ny property owned by'le.~or.
d. A~er meviag She apartment mms$ be cleamed amd
~11 ~ra~ remove~.
The Perties heretc
set their hands ~nd seals this
pzoo.
dsy
'
VERIFICATION
I verify that the statemems made in the attached COMPLAINT are true and correct.
Pursuant to Pa. R.C.P. 1024, I am making this verification in lieu of the Plaintiffdue to PlaintiWs
health condition which prevemed his signature at the time of filing the Complaint. I verify that I
have sufficient knowledge, information and belief of the facts contained in the Complaint as same
was communicated to me by the PlaintifE. I understand that
DATED: {~/~ ~0 Isubject to penalties of 18 Pa.C.S. §4904 relating to
statements herein are made
I/
JtlkqDNAI~ ~ T. TOMASKO
Attorney for the Plaintiff,
Richard Bucher
-5-
RICHARD R. BUCHER
Plaintiff
M. DAVID GRIFFIN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION NO. 01-04794
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE TO PLEAD
TO: Richard B. Bucher
c/o Ronald T. Tomasko, Esquire
You are hereby notified to file a written response to the enclosed Complaint
within twenty (20) days from service hereof or a judgment may be entered against you.
M. David Griffin, Pro Se !
619 Apple Drive
Mechanicsburg, PA 17055
RICHARD R. BUCHER
Plaintiff
M. DAVID GRIFFIN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION NO. 01-04794
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
ANSWER TO COMPLAINT
AND COUNTERCLAIM
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
COUNTI
Admitted.
Admitted.
Admitted. It is averred that Defendant only lived in the apartment for ten
(10) months. Defendant moved out with the notice and consent of Plaintiff at the end of
May 2001.
9. Denied. Defendant moved out of the apartment with the consent of
Plaintiff at the end of May 2001.
10. Admitted in part and denied in part. Defendant admits that he agreed to
pay and did pay for electric use for the period he occupied the apartment. He did not
occupy the apartment during June and July of 2001 and denies that he agreed to pay for
electricity for those months.
11. The averments of paragraph 10 are incorporated herein by reference.
12. The averments of paragraph 10 are incorporated herein by reference.
COUNT II.
12. Admitted.
13. Admitted.
14. Denied. Defendant denies that he caused damage to the apartment or
failed to remove trash from the apartment at the time he vacated the premises.
15. Denied. Defendant denies that he failed to surrender the premises in good
order.
16. The averments set forth in paragraph 16 constitute a conclusion of law and
to the extent said paragraph contains averments of fact, they are denied.
17. The averments set forth in paragraph 17 constitute a conclusion of law and
to the extent said paragraph contains averments of fact, they are denied.
18.
of Defendant.
19.
WHEREFORE, Defendant requests
Defendant.
Denied. Plaintiff suffered no loss as a consequence of any act or omission
Denied. It is denied that Plaintiff is entitled to damages.
that judgment be entered in favor of
2
COUNTERCLAIM
20. The averments of paragraphs 1-19 of the Complaint are incorporated
herein by reference.
21. Defendant deposited with Plaintiff the amount of $795.00 as security
deposit at the signing of the lease.
22. In May of 2001 Defendant vacated the premises with the consent of
Plaintiff and left the premises in the condition that he received them, normal wear and
tear expected.
23. Defendant notified Plaintiff of his new address in writing and surrendered
the keys and the premises to Plaintiff at the end of May 2001.
24. Plaintiff has to date failed and refused to return Defendant's security
deposit.
WHEREFORE, Defendant demands judgement in the amount of $1,790.00 plus
interest and costs.
M David Griffin, Pro Se
619 Apple Drive
Mechanicsburg, PA 17055
RICHARD R. BUCHER
Plaintiff
M. DAVID GRIFFIN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION NO. 01-04794
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
Verification
I verify that the statements made in the foregoing Answer to Complaint and
Counterclaim are true and correct. I understand that false statements are made subject to
the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to
authorities.
Date:
M. David Griffin
Certificate of Service
I, M. David Griffin, hereby certify that I served a true and correct copy of the
foregoing by depositing same in the U.S. mail, first class postage prepaid, addressed as
follows:
Ronald T. Tomasko, Esquire
Tomasko & Koranda, P.C.
219 State Street
Harrisburg, PA 17101
Date: t~//~/)/ ,2001
LAW OFFICE OF
THOMAS D. GOULD
ATTORNEYS AT LAW
2 EAST MAIN STREET o SHIREMANSTOWN, PA ~7011
717-731-1461
RICHARD R. BUCHER,
PLAINTIFF
M. DAVID GRIFFIN,
DEFENDANT
IN THE COURT OF COCA'ON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action No. 01-04794
CIVIL ACTION - LAW
ANSWER TO DEFENDANT'S COUNTERCLAIM
NOW, comes the Plaintiff, Richard R. Bucher, by and through
his attorney, Thomas D. Gould, and files this answer to the
Defendant's counterclaim.
20. The averments of paragraphs 1-19 of the complaint are
incorporated herein by reference.
21. Admitted
22. Denied that the Defendant
2001 with the consent of Plaintiff.
vacated the premises in May
In a letter dated May 2, 2001,
year lease, July
23. Denied
Plaintiff of his new
and signed for by the Defendant on May 3, 2001, Plaintiff advised
Defendant that he was terminating the lease at the end of the one
31, 2001.
that Defendant returned the keys and notified
address at the end of May. Defendant has
never provided Plaintiff with written notice of his new address.
At the time of District Justice Elder's decision on July 18, 2001,
Defendant's address was Second Floor Apartment, 214 South High
Street (Rear), Mechanicsburg, Pennsylvania. In late June,
Defendant telephoned Plaintiff and
the keys to the apartment.
24. Admitted that Plaintiff has not
security deposit. Pursuant to paragraph
advised him where he had left
returned Defendants,
9a. of the lease the
Plaintiff's duty to return the security deposit was contingent upon
the tenant not breaking the 12 month lease, giving 30 days notice
of his departure after the expiration of the one year lease, no
damage to the premises and the apartment cleaned with all trash
removed. The Defendant left before the expiration of the lease,
failed to give 30 days notice, damaged the property and failed to
clean and remove trash upon his departure. In addition, until this
counterclaim, Defendant has not requested a return of his deposit.
Wherefore, Plaintiff demands that Defendant's counterclaim be
dismissed.
Date:
Thomas D. Gould, Esquire
I.D. % 36508
2 East Main Street
Shiremanstown, PA 17011
(717) 731-1461
VERIFICATION
I verify that the statements made in this Answer to
Defendant's Counterclaim are true and correct. 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:
Richard R. Bucher
RICHARD R. BUCHER,
PLAINTIFF
Vo
M. DAVID GRIFFIN,
DEFENDANT
IN THE COURT OF CO~ON PT.~S
CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action No. 01-04794
CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
AND NOW, this ~ day of October 2001, I, Thomas D. Gould,
Esquire, Attorney for Plaintiff, Richard R. Bucher, hereby certify
that I have this day sent a copy of Plaintiff's Answer to
Defendant's Counterclaim by depositing a copy of it in the United
States mail, postage prepaid, addressed to:
M. DAVID GRIFFIN
619 APPLE DRIVE
MECHANICSBURG, PA 17055
DATED
Thomas D. Gould, Esquire
ID # 36508
2 East Main Street
Shiremanstown, PA 17011
(717) 731-1461
89:55 AM THOMAS D GOULD ?I? 761 1974
C&v4-1 kotion No. 01-04~94
CZvz'r. AC~:IO~ - ~
To THE PROTHONOTARY:
~n~ld T. TomaSko, ~guire
I.D. % 61190
219 Sta=e Street
Harrisburg, PA 17101
~X or AppBAiU~CR
Please enter my appearance on behalf of the plaintiff, Richard
R. Bucher, in the above captioned matter.
Date:
Thomas D. Gould, Esquire
I.D, # 36508
2 East Main Street
Shire~anstown, PA 17011
BETTE BUCHER, EXECUTOR
OF THE ESTATE OF
RICHARD R. BUCHER, Deceased,
Plaintiff
vs.
M. DAVID GRIFFIN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-04794
CIVIL ACTION - LAW
SUGGESTION OF DBATHAND
SUBSTITUTION OF PARTY PLAINTIFF
AND NOW, comes the Plaintiff by substitution, Bette Bucher,
Executor of the Estate of Richard R. Bucher, deceased, and
substitutes herself as party plaintiff in the above matter pursuant
to Pa.R.C.P. 2352 as follows:
1. Richard R. Bucher was the party plaintiff in the above
matter.
2.
Said Richard R. Bucher died on February 16, 2002.
Plaintiff by substitution, Bette Bucher, was appointed Executor of
the Estate of Richard R. Bucher by the Register of Wills in and for
Cumberland County, Pennsylvania,
21-02-198·
on February 25, 2002 to Estate No.
Respectfully submitted,
Thomas D. Gould, Esquire
I.D. #36508
Two East Main Street
Shiremanstown, PA 17011
VERIFICATION
Bette Bucher, hereby verifies that the facts set forth in the
foregoing Suggestion of Death and Substitution of Party Plaintiff
are true and correct to the best of her knowledge, information and
belief, and understands that false statements herein are made
subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn
falsifications.
PATE: June /~, 2002
RICHARD R. BUCHER,
Plaintiff
V.
M. DAVID GRIFFIN,
Defendant
IN THE COURT OF CO~ON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-04794 CIVIL TEBM
CIVIL ACTION
CERTIFICATE OF SERVICE
AND NOW, this //~ day of June 2002, I, Thomas D. Gould,
Esquire, Attorney for Plaintiff, hereby certify that I have this
day sent a copy of Plaintiff's Suggestion of Death and Substitution
of Party Plaintiff by depositing a copy of it in the United States
mail, postage prepaid, addressed to:
M. DAVID GRIFFIN
619 APPLE DRIVE
MECHANICSBURG, PA 17055
DATED
Thomas D. Gould, Esquire
ID # 36508
2 East Main Street
Shiremanstown, PA 17011
(717) 731-1461
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
c ,m
RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form:
PETITION FOR APPOINTMENT OF ARBITRATORS
TO THE HONORABLE, THE JUDGES OF SAID COURT:
~'~n~4' _~. GO ~..Lc~? , counsel for the plaintiff/d~f~dnntin the above action (or actions),
respectfully represents that:
1. The above-captione~r actions~) at issue.
2. The claim of the plaintiff in the action is $ ~, 9~'c/ '~'7 + O~: :f~ea' /'- ~'o,3"r-x
The counterclaim'of the defendant in the action is /; "79~ LTO .
The following attorneys are interesl~l in the case(s)as counsel or are otherwise disqualified to sit as arbitrators: __
WHEREFORE, your petitioner prays your H6norable Court to appoint three (3) arbitrators to whom the case shall be
submitted.
Respectfully submitted,
ORDER OF COURT
actions) as prayed for#
~.~-~in consideration of the
/
, Esq., are appointed arbitrators in the above captioned actid'n (or
By the ~
RJ.
OAilt
~4e do soi--m[? swear (or a~firm) =ha= we will suDOor~, obey and defend
the Cone=itu[ion of the ~nic~d $~&~es and ~he Constitution of =his
~eai=h and ~ha= we will d±$char~e =he du~Zes of our office wl~h fidelity.
&W~KD
(or affirmed), make ch. ~o!1~ ~ard~
(Nopsi If d~es for deiay are avarded, they shall be
separately s~acad.)
applicable,)
. &rbiuracor, dissentS. (Ins&re name if