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Home My WebLink About04-3648EARL T. ROBSON JR., PLAINTIFF VS. RON KENES, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Dy - 304? CIVIL `Ta-e-1 NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THE COMPLAINT AND NOTICE ARE SERVED, 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 JUDGEMENT 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 OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 EARL T. ROBSON JR., PLAINTIFF VS. RON KENES, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.O1!-3LLIP' CIVL `7? In COMPLAINT 1. The Plaintiff, Earl T. Robson Jr., also known as Tom Robson, is an adult individual residing at 213 North Baltimore Street in Dillsburg, Cumberland County, Pennsylvania 17019. 2. The Defendant, Ron Kenes, is an adult individual residing at 429 Bernheisel Bridge Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. On or about April 4, 1997 Plaintiff loaned the sum of Ten Thousand ($10,000.00) Dollars to Defendant, which funds were received by Defendant. 4. Defendant was to repay Plaintiff together with interest in the amount of One Thousand ($1,000.00) Dollars 5. The parties executed a written verification of the items specified in paragraphs three (3) and four (4) of this Complaint a copy of which is attached hereto, incorporated herein by referenced and marked Exhibit W. 6. Defendant repaid Plaintiff some portion of the Eleven Thousand ($11,000.00) Dollars sum as follows: a) In 1998 Three Thousand ($3,000.00) Dollars was paid to Plaintiff. b) In June of 1999 Seven Hundred ($700.00) Dollars was paid to Plaintiff. c) In July of 2000 One Thousand Fifty ($1,050.00) Dollars was paid to Plaintiff. d) In October of 2003 One Thousand Fifty ($1,050.00) Dollars was paid to Plaintiff. For a total repayment by Defendant to Plaintiff of Five Thousand Eight Hundred ($5,800.00) Dollars. 7. Defendant continues to be indebted to Plaintiff in the amount of Five Thousand Two Hundred ($5,200.00) Dollars. 8. Plaintiff has demanded payment of said sum from Defendant and has attempted to communicated personally with the Defendant. 9. The Defendant has ignored Plaintiffs demands and has refused to make payment of the Five Thousand Two Hundred ($5,200.00) Dollar sum due to Plaintiff. NOW THEREFORE, Plaintiff requests this Honorable Count to enter judgement in his favor and against the Defendant in the amount of Five Thousand Two Hundred ($5,200.00) Dollars plus interest and cost of this action. William A AV Duncan, Hartman, & Douglas, P.C. 1 Irvine Row Carlisle, PA 17013 (717) 249-7780 &UR68N = srrwzzu TON[ ROBSON AIM RON lj/vmS on Apr'_1 9, 1997, Tom Robson loaned $10,000 to Ron Konen for oonetructlon by Mr. Kenes of a home for resale purpose. The terms of the loan are that the $10,000 will be repaid by Mr. Xeres to Mr. Robson un or before October 1, 1997. In addition, Mr. Kenes will also pay on or before October 1, 1990 an interest fee of $1,000 to Mr. Robson for the use of Mr. Robson•s noney. IcENEB ? ^iDM ROB SON O l Date: EARL T. ROBSON JR., PLAINTIFF VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL RON KENES, DEFENDANT VERIFICATION I, Earl T. Robson Jr., verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. §4904, relating to Unswom Falsification to Authorities. Date EARL T. ROBSON JR. 4cL w SHERIFF'S RETURN - REGULAR CASE NO: 2004-03648 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ROBSON EARL T JR VS KENES RON BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KENES RON the DEFENDANT , at 1652:00 HOURS, on the 4th day of August 2004 at 429 BERNHEISEL BRIDGE ROAD CARLISLE, PA 17013 by handing to RON KENES a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.18 Affidavit .00 Surcharge 10.00 .00 33.18 Sworn and Subscribed to before me this 9 day of ?InnIU 1y ?? A.D. a?;;rothonotary So Answers: R. Thomas Kline 08/05/2004 DUNCAN HARTMAN DO GLAS By: eputy S e EARL T. ROBSON JR., PLAINTIFF VS. RON KENES, DEFENDANT TO: Ron Kenes 429 Bernheisel Bridge Road Carlisle, PA 17013 Date of Notice: September 3, 2004 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04 - 36,48 CIVIL IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH HE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS : T AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OFT NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YO U W THOUT A H FORTH AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHT3?RING YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 Bedford Street Carlisle, PA 17013 (717) 249-3166 WILLIAMA.'DUNCAN ESQUIRE 1 IRVINE ROW QUIRE CARLISLE, PA 17013 ID# 22080 Attorney for Plaintiff , P.C. n N d ? - G7 ?n u W ? aCr - r? C rs> c_ JI Curtis R. Long Prothonotary office of the Protbonotarp Cumbedanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor (n4/ - .?1o yQ CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 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, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573