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HomeMy WebLinkAbout11-5326CCT 3.-%'Y` e- 2 --"? : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Ka,; A e %& Defendant NO. V?o Civil Term to -urn . or o© NOTICE TO DEFEND ? w 2> 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 AN ATTORNEY AND FILLING 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 PEOPERTY 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 WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 PO 1-800-990-9108 1 -qd2 • p 717-249-3166 )w /37 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Joseph Craig Franczak 202 Heisers Lane Carlisle, PA 17015 Plaintiff, Vs. Kari An Behrens 7588 Porch Road Warrenton, VA 20187 Defendant. Civil Action Case NO: J/ , ? 316 Judge: COMPLAINT REPLEVIN UNJUST ENRICHMENT CONVERSION COUNT ONE 1. Plaintiff states that he has a special ownership in and is entitled to possession of the following goods and chattels: A. Diamond engagment ring B. Historic picture of house at 202 Heisers Lane C. Navigation DVD D. Music CDs E. Table leaf 2. In June 2011, Defendant moved out of Plaintiff's residence at 202 Heisers Lane and took with her the above listed items. 3. The above listed items did not belong to Defendant. 4. Item A, a diamond engagement ring was a conditional gift to Defendant from Plaintiff. 5. The condition on said gift did not occur, therefore, there was no gift and the property belongs to Plaintiff. 6. Defendant, Kari An Behrens, still retains possession of the above described goods to Plaintiff's damage. WHEREFORE, Plaintiff demands judgment against Defendant, Kari An Behrens as follows: A. An order requiring Defendant, Kari An Behrens to return possession of the Goods and for damages if any, plus costs OR B. An award of damages in the amount of $20,000.00 for Defendant's retention of the Goods. C. Any other relief the Court deems fair. Respectfully submitted, Joseph A. Kacyon (308298) Jc1? Attorney for Plaintiff 2745 Nesbitt Ave. Akron, Ohio 44319 Telephone: 330-745-2175 FAX: 330-745-4059 Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson 9 ! E0-UFF C Sheriff t% r ??yLlV tl? ?IUtI (lp?j . Jody S Smith L? Tt - Pi C: tI Chief Deputy Richard W Stewart CUMBERLAND LE;it tc I '; Solicitor - ?'EN'DS Y EV,A MA Joseph Craig Franczak Case Number vs. Kari An Behrens 2011-5326 SHERIFF'S RETURN OF SERVICE 07/01/2011 On this date Ronny R. Anderson, Sheriff mailed the within Complaint and Notice by certified mail, return receipt requested to Kari An Behrens. 08/01/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he served the within Complaint and Notice upon the within named defendant, Kari An Behrens, in the following manner: On July 1, 2011 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Complaint and Notice to the defendant's last known address of 7588 Porch Road, Warrenton, VA 20187. The certified mail return receipt card was received by the Cumberland County Sheriff's Office as "Return to Sender", "Unclaimed", "Unable to Forward" by The United States Postal Service on August 1, 2011. SHERIFF COST: $34.03 August 02, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF r C OU T' i ..t. Inc: AFFIDAVIT OF SERVICE SNOOP SISTERS PRIVATE PROCESS SERVICE, LLC c? r-4 rV P.O. BOX 3498 ,Q3 0 .?? WARRENTON, VA 20186 ® =-rr Tel: (540) 349-8747 Fax: (540) 349-8748 Zr" moo rn- -t rn O -.J r Joseph Craig Franczak v. Kari An Behrens CD -n Case No.: 11-5326- CIVIL =? _ scn' Court: In The Court Of Common Pleas: Cumberland County, Pennsylvania y,c m Document Served: Complaint r Served: Kari An Behrens rn 7588 Porch Road Warrenton, VA 20187 I, Robin Honaker, the Private Process Server hereby certify under penalty of perjury that I am over the age of 18 and not a party to the proceeding or otherwise interested in the subject matter in controversy. I further certify that on: Served date: August 26, 2011 @ 5.10 AM /® I served a: Summons/Complaint on the defendant listed above ? Other: ? (Personal) By delivery a copy of the above-described process in writing to him/her in person. (Substitute) Being unable to make a personal service and not finding the above mentioned person at his/her usual place of abode by delivering a copy of the said process and giving information of its purport at his/her usual place abode, Karon Behrens who is a member of his/her family and is the Mother of above mentioned person, other than a temporary sojourner or guest and who is the age of 16 years of older. ? (Posted) Being unable to make a personal service and not finding the above mentioned person at his/her usual place of abode nor any member of his/her family the age of 16 years or older at said abode by posting a copy of such process at the front door or at such other door as appears to be the main entrance of such place abode. ? At usual place of business or employment during business hours, by delivering the above-specified place of employment. Name of person I found in charge: ? Copy mailed to judgment debtor on the date listed above after serving the garnishee. ? Certified Mail ? Non Serve / Not Found ? Served on Secretary of the Commonwealth ? Served on a Registered Agent: Name of Person Receiving & Address Name of Defendant being served: Process Server (Signature) Notary State: Virginia County/City: Fauauier I, the undersigned, a Notary Public in and for the above-mentioned jurisdiction, hereby certify that the foregoing was subscribed and swo o before me by, the Process Server Robin Honaker, above this 2e day of August, 2011. Notary Public: Registration # 7308786 My Commission Expires: January 31, 2014 SEAL DA Additional Comments: EXp Ssr o :• G\??• ••. ••••.....•00 ?•??i rH OF ?l\Q :????