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HomeMy WebLinkAbout10-6591 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA IN RE: ) MICHAEL S. TRAVIS ) CIVIL ACTION AT LAW ATTORNEY AT LAW ) Plaintiff ) VS. ) No. 10 TAMMIE K. SHEAFFER ) 3 Defendant r; NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND F„ AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YO - SiZ TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE -;, PERSONALLY OR BY AN ATORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIM 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 OR CANNOT AFFORD ONE, GO TO THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 CD r? 79 ca° Q x? C:D? ?rn (9 co 'q00* 'TA cw 4- ?? 01 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA IN RE: MICHAEL S. TRAVIS ATTORNEY AT LAW Plaintiff vs. TAMMIE K. SHEAFFER Defendant CIVIL ACTION AT LAW No. COMPLAINT COUNT I BREACH OF CONTRACT 1. Plaintiff, Michael S. Travis, is an attorney and individual providing legal services. Plaintiff's business address is 3904 Trindle Road, Camp Hill, PA 17011. 2. Defendant is Tammie K. Sheaffer, an individual last know to reside at 1002 Bridge Street, Suite 100, New Cumberland, PA 17070. 3. Plaintiff, at Defendant's request pursuant to a fee agreement between the parties, did provide legal services since July 10, 2009, in defense of a confession of judgment action at Defendant's real property. 4. No payments have been received on Defendant's account since March 2, 2010. The current unpaid balance, including interest charges totals $1,958.33. 5. After repeated demands, Defendant has failed to make payment. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $1,958.33 plus interest and costs. COUNT II QUANTUM MERIUIT AS AN ALTERNATIVE COUNT 6. Plaintiff incorporates paragraphs 1-5 as if set forth at length in full. 7. Plaintiff did provide Defendant valuable legal services and did prevent a mortgage foreclosure action pending by her mortgage lender, with the Defendant's knowledge and acquiescence. 8. Extensive negotiations were carried out on Defendant's behalf to prevent a foreclosure. 9. The value of the unpaid services is $1,958.33 plus interest. 10. Defendant has failed to pay the amounts due after repeated demand. WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $1,958.33 plus interest and costs. ichael S. Travis 3904 Trindle Road Camp Hill, PA 17011 717-731-9502 mtravislaw@comast net VERIFICATION The statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that fals statements made herein are subject to the penalties of 18 Pa.C.S. Se . elating to unsworn falsification to authorities. S. Travis, Plaintiff Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor C7 C .v q n SHERIFF'S OFFICE OF CUMBERLAND COUNTOP © M (A? r -?+rM ? ritr a1aurGr -i 2C C) n C) ? ? 2a Michael S. Travis vs. Tammie K Sheaffer Case Number 2010-6591 SHERIFF'S RETURN OF SERVICE 11/19/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on November 19, 2010 at 1555 hours, he was unable to serve a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Tammie K. Sheaffer. After several attempts the Complaint and Notice has expired. SHERIFF COST: $58.60 SO ANSWERS, ,I November 19, 2010 RON R ANDERSON, SHERIFF .c GauntySUi F Shrn`f, iEI2oso*t. LI MICHAEL S. TRAVIS ATTORNEY AT LAW vs TAMMIE K. SHAEFFER In the Court of Common Pleas of Cumberland County, Pennsylvania No. 10-6591 Civil Term PRAECIPE REINSTATEMENT OF COMPLAINT David D. Buell, Prothonotary Attorney Info: 20 S Attorney for Plaintiff f ??? 33s3 SHERIFF'S OFFICE OF CUMBER Ronny R Anderson Sheriff _P30 ; Jody S Smith Chief Deputy Richard W Stewart Solicitor ,i ')FP : E .,. -11 Michael S. Travis Case Number vs. Tammie K Sheaffer 2010-6591 SHERIFF'S RETURN OF SERVICE 09/22/2011 06:01 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September 22, 2011 at 1801 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Tammie K. Sheaffer, by making known unto herself personally, at 1002 Bridge Street, Suite 100, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. DENRS FRY, DEPU SHERIFF COST: $45.44 September 26, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF =,CJ (,O11 L7UI(9 whE {'. IE C.JH:7( ?I'?C. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Michael S Travis ) Civil Action at Law Attorney at Law ) Plaintiff ) vs. ) No. 10-06591 Tammie K. Sheaffer ) Defendant ) PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: ?'? f fl?i. i ERL?,D COUNT*,' PENNSYLVANIA Kindly enter Judgment against the Defendant, Tammie K. Sheaffer, above named, in the default of an Answer, in the amount of $ 1,958.33 computed as follows: Amount claimed in Complaint $ 1,958.33 Less payment/adjustment made $ 0.00 Total $ 1,958.33 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. Sctfa-vis, Attorney/Plaintiff Plaintiff's address is: Michael S. Travis, 3904 Trindle Road, Camp Hill, PA 17011 And that the last known address of the Defendant is: Tammie K. Sheaffer, 1002 Bridge Street, Suite 100, New Cumberland, PA 17070 a,,kk %t4.co Pd Ck-? 333 Lai Michael S Travis Attorney at Law vs. Tammie K. Sheaffer IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ) Civil Action at Law Plaintiff No. 10-06591 Defendant To Tammie K. Sheaffer 1002 Bridge Street, Suite 100 New Cumberland, PA 17070 Date of Notice October 17, 2011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER AN WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURTT 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 AND YOU 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 IFORMATION 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 ELEIGIBLE PERSONS AT REDUCED OR NO FEE. Office of the Prothonotary Lawyer Referral and Information Service Cumberland County Courthouse 32 South Bedford Street 1 Courthouse Square Carlisle, PA 3 Carlisle, PA 17013 (717) 27491 6 (717) 240-6195 ra*s ' 3904 Trindle Road Camp Hill, PA 17011 717-731-9502 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Michael S Travis ) Civil Action at Law Attorney at Law vs. Tammie K. Sheaffer Plaintiff No. 10-06591 Defendant NON-MILITARY AFFIDAVIT The undersigned is the Attorney/Plaintiff in the above matter and states as follows: Affiant states that the within Affidavit is made pursuant to and in accordance with the Service members' Civil Relief Act (SCRA), 50 U.S.C. App. 521. Affiant further states that based upon investigation it is the Affiant's belief that the Defendant, Tammie K. Sheaffer, is not in the military service. Affiant further states that the averments contained herein are true and correct to the best of Affiant's knowledge, information and belief and that these averments are made subject to the penalties of 18 PA C.S.A. Section 4904 relating to unsworn falsification to authorities. ichael S. ravis, Affiant h/h/W