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Home My WebLink About04-3777BRAD PITTINGER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, T77 V. NO. O?- CIVIL ACTION - LAW JANET GETTEL, IN REPLEVIN Defendant 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 this Complaint and notice are served, by entering a written appearance personally or by attorney and 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 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, PA 17013 (717) 249-3166 BRAD PITTINGER, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. :NO: 9'4/-j77-7 CIVIL ACTION - LAW JANET GETTEL, IN REPLEVIN Defendant. ACTION IN REPLEVIN AND NOW, comes the Plaintiff, Brad Pittinger, by and through his attorneys, Mancke, Wagner & Spreha, and files the following Action in Replevin: 1. The Plaintiff, Brad Pittinger, is an adult individual residing at 571 E Street, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant, Jane Gettel, is an adult individual residing at 3 Alexander Spring Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant for a period of time resided together at 940 Sterling Court, Enola, Cumberland County, Pennsylvania. 4. The period of time within which they resided together was from approximately March 2004 until approximately the end of June of 2004. 5. During the time that the parties resided together, Plaintiff moved considerable personal property into the residence of the Defendant at 940 Sterling Court, Enola, Cumberland County, Pennsylvania. 6. The list of personal property moved into the residence is attached hereto, incorporated herein by reference, made a part hereof, and marked as Exhibit A, consisting of three (3) pages of personal property. The items on Exhibit A with a check mark have been recovered by the Plaintiff. 7. Plaintiff removed himself from the residence at 940 Sterling Court, Enola, Cumberland County, Pennsylvania, on or about the end of June of 2004. 8. Plaintiff has requested on numerous occasions the return of his personal property, however, despite repeated requests, the Defendant has refused and continues to refuse to return the personal property. 9. Plaintiff believes and therefore avers that he is entitled to the return of the personal property that is at 940 Sterling Court, Enola, Cumberland County, Pennsylvania. -2- WHEREFORE, Plaintiff prays this Court to grant relief in the form of directing the Defendant to return his personal property that is set forth in Exhibit A attached hereto. The items on Exhibit A with a check mark have been recovered by the Plaintiff. Respectfully submitted, Mancke, Wagner & Spreha B=--f' Richard Wagner, Esquire 1.D.#23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff Date:_ 7/aQJOc{ -3- VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE: ///V/0p JUL- .J •Z3• 2 CG4 1I SP,P..NCKE WAGNER SPREHA -06 . +717-234-7080 T-5Na 30uul/00a rZ-581 LT. fdy2own/ Sow ..... V,/ ewo r w corAF Sr'? . _ /rG7T??/-- ?iA1?i?(?.. T/4BGF W?2---Lf?f? I!?!?__?G?A'i?_?___ . ^ixeX ''Pow Aft-e- flvv4n?s dL" APT wlh7t . 490sol -71'W - _?/ Fhb Sts s? `y IOMI- ?r - _...... - -------- -- -' Mgsfk?GD aA,?DG,? L/Gthr jTA?c 70 LIG sTA of 3 Sfi ?XOS r 6 Pr (by WAZ W KNUg) !A JUL _?. , `O.,a 1 ?EAANCKE WAGNER SPREHA +717-234-7GBG T-5t? 300u2/00? r-591 ?SoNIG 3s W-00 164&4wio XAE ?-?? s.KcfLS kG4 , of ep cis Pup* _ - CifsE FtuC dF C b r -- yM."r'Y sfl, u5?' - dvoo 79 if x S ./,Oat At4s-mrz - - ? LI6Pr Juk'Ll. 2 G4 11.'9AM JUL-iu-auuv iu.iann rno rwNCHE WAGNER $PREHA ,6 P. +717-234-7080 T-5Ai0 3 .u 311 r 591 RmS?«w?L 8C ' f3Fr-C ?FZJ?G of cQufPNrw? Sir POr5 Q .460 - 0469 PUSWu -7%B W?7"°4S WIC 71FX . Mi sc _ VI .CA WAT, t?R.bw$?r Am iAi E Ar?D &AL, 1 - - 7 4-IJ ... - ieuE? - - - - j . v >>? 71 l fn C>IQN ,ir7 ci , cJN . r BRAD PITTINGER, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff; V. : NO: CIVIL ACTION - LAW JANET GETTEL, Defendant. IN REPLEVIN PETITION FOR INJUNCTION AND NOW, comes your Petitioner, Brad Pittinger, by and through his attorneys, Mancke, Wagner & Spreha, and files the following Petition for Injunction: 1. Your Petitioner, Brad Pittinger, is an adult individual residing at 2. Respondent, Jane Gettel, is an adult individual residing at 3 Alexander Spring Road, Carlisle, Cumberland County, Pennsylvania. 3. Petitioner herein has filed a Complaint in Replevin at the above-captioned number seeking the return of personal property that is at the residence of the Respondent as set forth in paragraph 2 above. 4. For a short period of time, Petitioner and Respondent resided together as having an intimate relationship. 5. That relationship ended at the end of May, 2004, on less than amicable terms. 6. Petitioner has considerable personal property which is more fully set forth in Exhibit A attached to a Complaint in Replevin and is also attached hereto, incorporated herein by reference and marked as Exhibit A. 7. Petitioner believes and therefore avers and further fears that damage may occur to the personal property in the form of the Respondent damaging, giving away, selling or otherwise discarding and destroying the personal property contained in Exhibit A. 8. Petitioner believes and therefore avers that he has no adequate remedy at law to protect and preserve the personal property pending the outcome of the action in replevin, and further, that irreparable harm can occur to the personal property. 9. Petitioner requests this Court to grant an immediate injunctive relief enjoining the Respondent from continuing to retain the personal property contained in Exhibit A attached hereto. The items on Exhibit A with a check mark have been recovered by the Plaintiff. -2- WHEREFORE, Petitioner prays this Court to enter an immediate injunction directing the Respondent to return the personal property of the Petitioner pending outcome of the underlying replevin claim. Respectfully submitted, Mancke, Wagner & Spreha Y / P. Richard Wagner, Esquire I.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff Date: 71,4 9 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE: 7 VL JUL u 3 • LOOS 1I.:'']-.8.A M,NCKE WAGNER SPREHA +717-234-7080 T-5N0.3OO61/00a r 591 G/1y416E - R7eiyJo..¢E Clf?R?2y - _.. LT. ?y??/ Soy¢ ..3 Pr. w Lie -- _ -- A" oov e~ plSfl /S Vo/ 0A1Z ?l - - . _ ? . . _ . ....._L_..... - CRBt? t?/et? ?t?. ---l?n/ B?yG6? ??s-?t? -r 5'7??P?: ks A mAf?M UGth` STAB n? GIGS srA? of 3 17-Y: &Xes WAAAW KIPO'L?) 23• 2004 I I 8AwNCKE WAGNER SPREHA +717-254-7090 Mir v uu2loon r-591 C$luJ6R? Uo htF2_ - - ?? . ?Gacs°nc s•KEfLs .- - :5XV&f Picot co G}sE Frcu dF cz S writ" -- y,?.uS - :. 7' -- . cNOCp w m .Sri ea ii 7?tP?€ .BMX Ski -- - • - ... _.. _ Aft? ?Nv# Muse • M411, b , KEY f f n?-0 . _ _ ....? _. P.A'P6i??.1 6'ae?E ?drtt•R? ??ur¢G: fFJ?---- /flier ___--- - . OtS t.? MIIQkcK - oLD .. woo,D Goa fw-D ?31? Jul•23, 2004 11:19AM No, 3006 P 4 JUL-W-6Ya4 .u-ia" rawrwnNCKE WAGNER SPREHA +717-234-7080 T-941, r.uu3/095 r-591 j?o54llo?roL 8 ?4t? ??? of S`l EQate trin' 5?-! !3?•?rs ? Ktas -!'lS?- DY?Fs? ?i?t's co,Pr C?Ct 5 G?GG 3 ?1,1P _ 5XI Gtov?? z,?il i5??+? , - CM49 ??lc • 7zttg wl7tiOGS Wl,r? ?TFA 4] sc - Pow' A n w*`?-r AFjo ,Btu C?= MAP 64070-S 2 D? ?' r-Jri? 7Dw?GLS • . - r-' -? °;1 -°- ./ jiYl 41 -p??i ? ?? ?? ?. ?+ .:. ??. 1 (?) ?:? 5... ?. ? a ._. C,,,; if AUG 0 3 2004 BRAD PITTINGER, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. _ NO: 7 7 7 e;4t_? CIVIL ACTION - LAW JANET GETTEL, IN REPLEVIN Defendant. AND NOW, this 4q day of . 2004, upon Petition of Brad Pittinger, a hearing is set for the day o2004, at ?oO?J &,t,,k- in Courtroom No. of the Cumberland County, -Fo d&+;e; ;,,W ula#vt a wit;t- Or- Courthouse, Carlisle, Pennsylvania, to s Stj 1"rte Sid"ck IS S tit .2a 7A;S mr f-f >e- ction BY T; f - K? '04-04 C)s J. L j a vL ;0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-03777 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PITTINGER BRAD VS GETTEL JANET R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT GETTEL JANET but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - REPLEVIN , NOT FOUND , as to the within named DEFENDANT , GETTEL JANET 3 ALEXANDER SPRING ROAD CARLISLE, PA 17013 THERE IS NO SUCH ADDRESS IN CUMBERLAND COUNTY. Sheriff's Costs: Docketing 18.00 Service 3.70 Not Found 5.00 Surcharge 10.00 .00 36.70 So answ R. Thomas Kline Sheriff of Cumberland County MANCKE WAGNER SPREHA 08/06/2004 Sworn and subscribed to before me this 9 w day of .2 OV Protho ary BRAD PITTINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 04-3777 CIVIL TERM JANET GETTEL, Defendant IN REPLEVIN IN RE: HEARING CONTINUED ORDER OF COURT AND NOW, this 19th day of August, 2004, it appearing that the Defendant was not timely served, her request for a continuance is granted. Hearing on the motion for writ of seizure shall be held on Friday, September 10, 2004, at 8:30 a.m. Richard Wagner, Esquire For the Plaintiff Jet Gettel 3 Alexander Spring Road Carlisle, PA 17013 Defendant, Pro se (J? O srs ??, 1:';; ..,i? +??:? Ana ,. ?'? °;'?rr„ s? .. ,? ??; ,?, BRAD PITTINGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS NO. 04-3777 CIVIL TERM JANET GETTEL, Defendant IN REPLEVIN IN RE: WRIT OF SEIZURE ORDER OF COURT AND NOW, this 10th day of September, 2004, it appearing to the Court that Defendant does not have possession of any of the Plaintiff's items, the petition for writ of seizure is denied Edward E. Guido, J. Richard Wagner, Esquire For the Plaintiff Jdanet Gettel 3 Alexander Spring Road Carlisle, PA 17013 Defendant, Pro Se mlc -0 ? 04 -13 Curtis R. Long Prothonotary office of the Protbonotarp C2umberlanb Cuuntp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor Qq - 777 ! 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