HomeMy WebLinkAbout11-5797r (LED-GFFIc
IE PROTNONOTAR?
'C! t JUL 21 AH I I : oG
aUMBERLAND COUNTY
PENNSYLVANIA
LAW OFFICES OF
HAYT, HAYT & LANDAU, LLC
By: Arthur Lashin, Esquire
Identification No. 23425
123 S. Broad Street
Suite 1660
Philadelphia, PA 19109-1003
(215) 928-1400
OUR FILE NO. 352585
Attorney for Plaintiff
CUMBERLAND COUNTY
MIDLAND FUNDING LLC
P.O. BOX 939019
SAN DIEGO, CA 92123
Vs.
DAVID STOUFFER
1619 S YORK ST
MECHANICSBURG PA 17055
"NOTICE
CIVIL ACTION
`You have bean wed 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 persorMy or by attorney and
filing in writing with the court your deforaos or objections to the
claims set forth against you You are Waned that if you fail to do
so the caw may proceed without you and a judgment may be en-
tered agairat you by the overt without further ration for any mon-
ey claimed In the oonnplaint or for arry other claim or nMlef requed-
ad by the plaintiff. You may bee money or property or other rights
Mnportant to you.
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 ELIGIBLE PERSONS AT A REDUCED FEE
OR NO FEE
CUMBERLAND COUNTY BAR ASSOCIATION
32 S BEDFORD STREET
CARLISLE PA, 17013
800-990-9108
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM.
Civil
No. \I-S-101-7
"AVISO
"Le hen demandado a used an r aorta. Si uated quiers
definderse de wise domarMias expusses on las pigbws eiguiartes,
used tiwe voirb (20) dies, de plow al palir de la feahra do Y
denanda y Y notiAcad6rr. I laoo bft goer go une cor parencia
auxtta o en persona o con un abogedo y enbegm aim ports en
forma esata an defense o sus Ali 1 Am roe a be demadas an
contra de au persona. Sea aviando que at used no to detferde, to
carte tomari rrrotNrdas y puedo ooriiranr r wind ancmb
suys sin provio avfeo o notrfcaddn. Adonis„ Y Oonte puede
decidir a favor del den ndw*o y regimes quo used curple con
todas lea provisions do see dNrar .. Uslod puede padw dkmo
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`LLEVE ESTA DEMANDA A UN ASOGADO
IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO
TIENE EL DINERO SUMSENTE DE PAGAR TAL SERVIGIO,
VAYA EN PERSONA O LLAME POR TEL tFONO A LA
OFICINA CUYA ENRECC16H SE ENCUENTRA ESCRITA
ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUiR
ASISTENCIA LEGAL.
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CIVIL ACTION
1. Plaintiff, MIDLAND FUNDING LLC, is a business entity with offices located at 8875
Aero Drive, Suite 200, San Diego, CA 92123.
2. Defendant(s) STOUFFER/DAVID is/ are individual(s) residing, upon information and
belief, at 1619 S YORK ST, MECHANICSBURG, PA 17055.
3. As set forth in records maintained on behalf of Plaintiff, this action is based upon a
credit agreement entered into between Defendant(s) and the original credit grantor.
4. Plaintiff is the current owner of, and/or successor to, the obligation sued upon, and was
assigned all the rights, title and interest to Defendant's CHASE BANK USA, N.A. account
4254491200642839 (hereinafter "the account").
>. Defendant(s) used or authorized the use of the account to obtain loans from the original
credit grantor for the purpose of obtaining goods and/or services and/or cash advances.
6. The account shows that the defendant(s) owe(s) a balance of $16853.10.
WHEREFORE, Plaintiff respectfully requests that judgment be entered in favor of Plaintiff
and against Defendant(s) in the amount of $16853.10, together with interest and costs.
LAW OFFICES OFA
HAYT, HAYT & L , LLC
By 4LI114
Arthur Lashin, Esquil
Attorney for Plaintiff
#23425
Page - 1
8533867604 AFFINDEBT 352585001
Verification
Ashley Hoffman, being duly sworn (or affirmed) according to law deposes and says that
I am employed as a Legal Specialist for Midland Credit Management, Inc. ("MCM"),
servicer of this account on behalf of plaintiff. I am authorized to make this verification
on plaintiffs behalf. The facts set forth in the foregoing pleading are true and correct
upon information and belief.
;SAY 0 6 2Q??
Date
STATE OF MINNESOTA
COUNTY OF STEARNS
Signed and sworn to (or affirmed) before me on
' Francine M. Semmier
-: y
',`.:' -?` i' • NOTARY PUBLIC-MINNESOTA
(Seal) -.->
y}h `', My Comm. Exp. Jan. 31, 2015
PA I O
Hayt, Hayt & Landau, LLC
by Ashley Hoffman.
Notary Public
My commission expires:
Page - 2
8533867604 AFFINDEBT 352585001
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson i F _ .. t
Sheriff (?= loft I ii} t ,
Jody S Smith tiol ?q 4?0tjnhj,,,7 ¢ € i t w t t t l,+l ., r
Y
Chief Deputy 1 A UG - S P 2: 4
Richard W Stewart ?
Solicitor :? °. r ????????AND %; i? ?? ?
, ..... _ .
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PENNSYLVA1111 A
Midland Funding LLC
vs. Case Number
David Stouffer 2011-5797
SHERIFF'S RETURN OF SERVICE
07/28/2011 08:27 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July
28, 2011 at 2027 hours, she served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: David Stouffer, by making known unto Nancy Stouffer, Wife of Defendant at 1619 S.
York Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time
handing to her personally the said true and correct copy of the same.
Anfik( omwL
AMANDA cbBAUGH,-DEPUTI-
SHERIFF COST: $38.44
August 02, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
W '::?Ae She, 1. fti 'It.II1-;.
IN THE COURT OF COMMON PLEAS rrn CO
CUMBERLAND COUNTY PENNSYLVANIA =av
MIDLAND FUNDING LLC
Plaintiff
vs.
DAVID STOUFFER,
Defendant
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CaseNo.: 11-5797Civil aC)
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DAVID STOUFFER
PRO SE NOTICE OF APPEARANCE
NOTICE OF APPEARANCE
The undersigned enters an appearance in this action, and demands notice of all further
proceedings., The Clerk of Courts and the opposing party will be informed of any and all changes
in address. Any and all notices may be sent to the address as indicated below.
V
August 05, 2011
David Stouffer, I
1619 South York Street
Mechanicsburg, PA 17055
(717)790-5535 (facsimile)
(717)439-5472
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
MIDLAND FUNDING LLC
Plaintiff
vs.
Case No.: 11-5797 Civil
DAVID STOUFFER,
Defendant
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ANSWER and
AFFIRMATIVE DEFENSES
I
ANSWER
Comes now, Defendant, David Stouffer, Pro Se, who denies the following paragraphs of
Plaintiff's Complaint:
1. Defendant denies the allegations contained in Paragraph 1 of the Complaint as Defendant
is without information or knowledge sufficient to form an opinion as to the truth and accuracy of
alleged assignments and entitlements.
2. Defendant agrees with statement in Paragraph 2 of the Complaint that he is an individual
who resides at 1619 South York Street, Mechanicsburg, PA 17055.
3. Defendant denies the allegations contained in Paragraph 3 of the Complaint as there is not,
nor has there ever been any agreement, written, oral or implied with the Plaintiff and the
Defendant.
4. Defendant denies the allegations contained in Paragraph 4 of the Complaint as Defendant
is without information or knowledge sufficient to form an opinion as to the truth and accuracy of
the allegation(s).
5. Defendant denies the allegations contained in Paragraph 5 of the Complaint as
Defendant is without information or knowledge sufficient to form an opinion as to the
truth and accuracy of the allegation(s).
6. Defendant denies the allegations contained in Paragraph 6 of the Complaint as
Defendant is without information or knowledge sufficient to form an opinion as to the
truth and accuracy of the allegation(s).
II
AFFIRMATIVE DEFENSES
Defendants other defenses are:
1. The Plaintiff failed to name the real party of interest.
2. The Plaintiff failed to state a claim upon which relief can be granted.
3. The Defendant was not notified of any assignment of any debt that is the subject
of this Complaint.
4. The Plaintiff's Complaint may be time-barred because it fails to state any date(s)
necessary to make such a determination.
5. The Defendant claims Lack of Privity as Defendant has never entered into any
contractual or debtor/creditor arrangements with the Plaintiff.
6. The Plaintiffs Complaint fails to allege a valid assignment of debt and there are
no averments as to the nature of the purported assignment or evidence of valuable
consideration; the Plaintiff's fails to allege whether or not the purported assignment was
partial or complete and there is no evidence that the purported assignment was bona fide.
2
7. The Plaintiffs Complaint further fails to allege that the Assignor even has
knowledge of this action or that the Assignor conveyed all rights and control to the
Plaintiff. The record does not disclose this information and it cannot be assumed without
creating an unfair prejudice against the Defendant.
8. The Plaintiff has not proven that they are authorized and licensed to collect claims
for others in the State of Pennsylvania, solicit the right to collect or receive payment of a
claim of another.
9. The Plaintiff is barred under the Fair Debt Collection Practices Act, hereinafter
called FDCPA, Section 807(2), 15 U.S.C. § 1692e(2) from collecting interest and any
amount unless it is expressly authorized by agreement creating the alleged debt or
permitted by law. The Plaintiff has failed to attach proper documentation to verify if
such principle or interest is allowed, or even exists.
10. The Defendant claims Accord and Satisfaction as the Defendant alleges that the
original creditor accepted payment from a third party for the purported debt, or portion of
the purported debt, or that the Original Creditor received other compensation in the form
of monies or credits from the Plaintiff.
11. The Plaintiff's damages are limited to real or actual damages of actual cost paid or
exchanged to alleged Original Creditor for the purported debt, for which the Plaintiff
failed to reference by number or written instrument in their Complaint.
12. The Defendant reserves the right to plead other affirmative defenses that may
become applicable and/or available at a later time.
3
Wherefore, for the reasons set forth in the above Answers and Affirmative Defenses the
Defendant prays this case be dismissed with prejudice along with any further relief the
Court deems just and proper.
August 5, 2011
Respectfully submitted by:
David Stouffer, P?o-
1619 South York Street
Mechanicsburg, PA 17055
(717)790-5535 (facsimile)
(717)439-5472
4
CERTIFICATE OF SERVICE
The undersigned hereby certifies that, on August 05, 2011 a copy of the foregoing
"Answer and Affirmative Defenses" was deposited in the United States Mail, postage
paid, addressed to: Law Offices of Hayt, Hayt & Landau, LLC, Arthur Lashin,
Esquire, 123 South Broad Street, Suite 1660, Philadelphia, PA 19109-1003, Attorney for
the Plaintiff.
David Stouffer, Pro se
1619 South York S
Mechanicsburg, PA 17055
(717)790-5535 (facsimile)
(717)439-5472
5
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
MIDLAND FUNDING LLC
VS.
DAVID STOUFFER,
Plaintiff
Defendant
RESPONSE
Case No.: 11-5797 Civil
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RESPONSE TO PLAINTIFF'S
NOTICE OF INTENTION TO TAKE
DEFAULT PURSUANT TO
PA R.C.P. 237.2
Comes now, Defendant, David Stouffer, Pro Se, in response to Plaintiff's "Notice of Intention
to Take Default Pursuant to PA. R.C.P. 237.2", as follows:
1. Postmarked on August 26, 2011 the Plaintiff mailed the Defendant their "Notice of Intention
to Take Default Pursuant to PA. R.C.P. 237.2", (see Exhibit 1).
2. The Plaintiff's "Notice of Intention to Take Default Pursuant to PA. R.C.P. 237.2" authored
on August 26, 2011, falsely alleges that the Defendant had "...failed to enter a written appearance
personally or by attorney and file in writing with the court your defenses or objections to the claims
set forth against you.,,
3. The Defendant did in fact serve upon the Plaintiff's counsel of record in a timely manner by
U.S. Mail, postmarked August 5, 2011, received on August 8, 2011, Defendant's "Pro se Notice of
Appearance", and "Answer and Affirmative Defenses" , (see Exhibit 2).
4. On August 24, 2011, at 9:12 am, served by U.S. Mail, and prior to the authorship of the
Plaintiff's "Notice of Intention to Take Default Pursuant to PA. R.C.P." 237.2", the Plaintiff was in
possession of not only the Defendant's "Pro se Notice of Appearance", and "Answer and Affirmative
Defenses", but also had in their possession a copy of Defendant's "Amended Answer and Affirmative
Defenses", and "Notice To Produce Documents and Records", (see Exhibit 3).
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5. On August 26, 2011 the Plaintiff had full knowledge that the claims made within
their "Notice of Intention to Take Default Pursuant to PA. R.C.P. 237.2", were not only
misleading to the court, but patently false.
6. On September 1, 2011, after returning from out of state due to hurricane
conditions which rendered our home without electricity and water for a week, the
Defendant received the Plaintiff's ten (10) day, "Notice of Intention to Take Default
Pursuant to PA. R.C.P. 237.2", and has a matter of record, done everything possible to
comply with time limitations for the Defendant's response.
Wherefore, for the reasons set forth in the above "Response to Plaintiff's Notice
of Intention to Take Default Pursuant to PA. R.C.P. 237.2", and for the reason set forth in
the Defendant's "Answer and Affirmative Defenses", and "Amended Answer,
Affirmative Defenses and Objections", the Defendant prays this case and the
aforementioned "Notice" be dismissed without prejudice along with any further relief the
Court deems just and proper.
September 3, 2011 Respectfully submitted by:
C--?
David Stouffer, Pro
1619 South York Street
Mechanicsburg, PA 17055
(717)790-5535 (facsimile)
(717)439-5472
2
CERTIFICATE OF SERVICE
The undersigned hereby certifies that, on September 3, 2011 a copy of the foregoing
"Response to Plaintiff's Notice of Intention to Take Default Pursuant to PA. R.C.P.
237.2" was deposited in the United States Mail, postage paid, Confirmation Number:
03051720000231998752, addressed to: Law Offices of Hayt, Hayt & Landau, LLC,
Arthur Lashin, Esquire, 123 South Broad Street, Suite 1660, Philadelphia, PA 19109-
1003, Attorney for the Plaintiff.
David Stouffer,
1619 South York Street
Mechanicsburg, PA 17055
(717)790-5535 (facsimile)
(717)439-5472
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LAW OFFICES OF
HAYT, HAYT & LANDAU, LLC
By: Arthur Lashin, Esquire
Identification No. 23425
123 S. Broad Street
Suite 1660
Philadelphia, PA 19109-1003
(215) 928-1400
Attorney for Plaintiff
DATE : AUGUST 26, 2011
MIDLAND FUNDING LLC
P.O. BOX 939019
SAN DIEGO, CA 92123
VS.
DAVID STOUFFER
1619 S YORK ST
MECHANICSBURG PA 17055
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM.
No. 11-5797 CIVIL
- --NOTICE -O€-I rrENTZoN To T DEFA "Tr T-
PURSUANT TO PA.R.C.P 237.1
You are in default because you have failed to enter a written
appearance personally or by attorney and file in writing with the
court 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 information 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 eligible persons at a reduced fee or no fee.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S BEDFORD STREET
CARLISLE PA, 17013
800-990-9108
By: If A ARTHURL rIA ?tyN 23425
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
MIDLAND FUNDING LLC
Case No.: 11-5797 Civil
Plaintiff
VS.
DAVID STOUFFER,
Defendant
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DAVID STOUFFER
PRO SE NOTICE OF APPEARANCE
NOTICE OF APPEARANCE
The undersigned enters an appearance in this action, and demands notice of all further
proceedings. The Clerk of Courts and the opposing party will be informed of any and all changes
in address. Any and all notices may be sent to the address as indicated below.
August 05, 2011
(- - - - t ?7'.
David Stouffer, Pro se
1619 South York Street
Mechanicsburg, PA 17055
(717)790-5535 (facsimile)
(717)439-5472
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
MIDLAND FUNDING LLC
Case No.: 11-5797 Civil
Plaintiff
vs.
DAVID STOUFFER,
Defendant
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ANSWER and
AFFIRMATIVE DEFENSES
I
ANSWER
Comes now, Defendant, David Stouffer, Pro Se, who denies the following paragraphs of
Plaintiff s Complaint:
1. Defendant denies the allegations contained in Paragraph 1 of the Complaint as Defendant
is without information or knowledge sufficient to form an opinion as to the truth and accuracy of
alleged assignments and entitlements.
2. Defendant agrees with statement in Paragraph 2 of the Complaint that he is an individual
who resides at 1619 South York Street, Mechanicsburg, PA 17055.
3. Defendant denies the allegations contained in Paragraph 3 of the Complaint as there is not,
nor has there ever been any agreement, written, oral or implied with the Plaintiff and the
Defendant.
4. Defendant denies the allegations contained in Paragraph 4 of the Complaint as Defendant
is without information or knowledge sufficient to form an opinion as to the truth and accuracy of
the allegation(s).
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
MIDLAND FUNDING LLC
Plaintiff
vs.
DAVID STOUFFER,
Defendant
I
ANSWER
Case No.: 11-5797 Civil
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AMENDED
ANSWER and
AFFIRMATIVE DEFENSES
c?
Comes now, Defendant, David Stouffer, Pro Se, who denies the following paragraphs of
Plaintiff's Complaint:
1. Defendant denies the allegations contained in Paragraph 1 of the Complaint as Defendant
is without information or knowledge sufficient to form an opinion as to the truth and accuracy of
alleged assignments and entitlements.
2. Defendant agrees with statement in Paragraph 2 of the Complaint that he is an individual
who resides at 1619 South York Street, Mechanicsburg, PA 17055.
3. Defendant denies the allegations contained in Paragraph 3 of the Complaint as there is not,
nor has there ever been any agreement, written, oral or implied with the Plaintiff and the
Defendant.
4. Defendant denies the allegations contained in Paragraph 4 of the Complaint as Defendant
is without information or knowledge sufficient to form an opinion as to the truth and accuracy of
the allegation(s).
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
MIDLAND FUNDING LLC
Case No.: 11-5797 Civil
Plaintiff
vs.
DAVID STOUFFER,
Defendant
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NOTICE TO PRODUCE
DOCUMENTS AND RECORDS
Comes now, Defendant, David Stouffer, Pro Se, who requests that produce documents
and records in accordance with Pennsylvania Rule of Civil Procedure 4009, the originals or clear,
readable copies of the below documents and records. These documents and/or Records will be
examined, copied by any method, including but not limited to photocopying. The below listed
documents and/or records are to be produced and forwarded to the Defendant on or before thirty
(30) days from the date of service herein. Such request is continuing up to and at the time of trial.
DEFINITIONS
A. "You" or "your" refers to the Plaintiff herein and to all other persons acting or purporting
to act on behalf of the Plaintiff, including agents and employees.
B. "Communications" shall mean all inquiries, discussions, conversations, negotiations,
agreements, understandings, meetings, telephone conversations, letters, correspondence, notes,
telegrams, telexes, advertisements, facsimiles, e-mails, or other forms of verbal and/or
communicative intercourse.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
MIDLAND FUNDING LLC
Vs.
DAVID STOUFFER,
Plaintiff
Defendant
I
ANSWER
Case No.: 11-5797 Civil
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AMENDED ANSWER,
AFFIRMATIVE DEFENSES, AND
OBJECTIONS
Comes now, Defendant, David Stouffer, Pro Se, who denies the following paragraphs of
Plaintiff s Complaint:
1. Defendant denies the allegations contained in Paragraph 1 of the Complaint as Defendant
is without information or knowledge sufficient to form an opinion as to the truth and accuracy of
alleged assignments and entitlements.
2. Defendant agrees with statement in Paragraph 2 of the Complaint that he is an individual
who resides at 1619 South York Street, Mechanicsburg, PA 17055.
3. Defendant denies the allegations contained in Paragraph 3 of the Complaint as there is not,
nor has there ever been any agreement, written, oral or implied with the Plaintiff and the
Defendant.
4. Defendant denies the allegations contained in Paragraph 4 of the Complaint as Defendant
is without information or knowledge sufficient to form an opinion as to the truth and accuracy of
the allegation(s).
5. Defendant denies the allegations contained in Paragraph 5 of the Complaint as
Defendant is without information or knowledge sufficient to form an opinion as to the
truth and accuracy of the allegation(s).
6. Defendant denies the allegations contained in Paragraph 6 of the Complaint as
Defendant is without information or knowledge sufficient to form an opinion as to the
truth and accuracy of the allegation(s).
11
AFFIRMATIVE DEFENSES AND OBJECTIONS
Defendants other defenses are:
1. The Plaintiff failed to name the real party of interest.
2. The Plaintiff failed to state a claim upon which relief can be granted.
3. The Defendant was not notified of any assignment of any debt that is the subject
of this Complaint.
4. The Plaintiffs Complaint may be time-barred because it fails to state any date(s)
necessary to make such a determination.
5. The Defendant claims Lack of Privity as Defendant has never entered into any
contractual or debtor/creditor arrangements with the Plaintiff.
6. The Plaintiffs Complaint fails to allege a valid assignment of debt and there are
no averments as to the nature of the purported assignment or evidence of valuable
consideration; the Plaintiff's fails to allege whether or not the purported assignment was
partial or complete and there is no evidence that the purported assignment was bona fide.
2
7. The Plaintiff's Complaint further fails to allege that the Assignor even has
knowledge of this action or that the Assignor conveyed all rights and control to the
Plaintiff. The record does not disclose this information and it cannot be assumed without
creating an unfair prejudice against the Defendant.
8. The Plaintiff has not proven that they are authorized and licensed to collect claims
for others in the State of Pennsylvania, solicit the right to collect or receive payment of a
claim of another.
9. The Plaintiff is barred under the Fair Debt Collection Practices Act, hereinafter
called FDCPA, Section 807(2), 15 U.S.C. § 1692e(2) from collecting interest and any
amount unless it is expressly authorized by agreement creating the alleged debt or
permitted by law. The Plaintiff has failed to attach proper documentation to verify if
such principle or interest is allowed, or even exists.
10. The Defendant claims Accord and Satisfaction as the Defendant alleges that the
original creditor accepted payment from a third party for the purported debt, or portion of
the purported debt, or that the Original Creditor received other compensation in the form
of monies or credits from the Plaintiff.
11. The Plaintiff's damages are limited to real or actual damages of actual cost paid or
exchanged to alleged Original Creditor for the purported debt, for which the Plaintiff
failed to reference by number or written instrument in their Complaint.
12. The body of the Plaintiff's "Complaint" contains no date of the signer, and
although it was filed on July 21, 2011, not served until July 28, 2011, the person
verifying the complaint and its content purportedly did so on May 6, 2011, over three (3)
3
months before the filing, and creating a question concerning the validity such
verification.
13. The Defendant reserves the right to plead other affirmative defenses that may
become applicable and/or available at a later timeWherefore, for the reasons set forth in
the above Answers and Affirmative Defenses the Defendant prays this case be dismissed
without prejudice along with any further relief the Court deems just and proper.
September 3, 2011 Respectfully submitted by:
David Stouffer, Pro
1619 South York Street
Mechanicsburg, PA 17055
(717)790-5535 (facsimile)
(717)439-5472
4
CERTIFICATE OF SERVICE
The undersigned hereby certifies that, on September 3, 2011 a copy of the foregoing
"Amended Answer, Affirmative Defenses, and Objections" was deposited in the United
States Mail, postage paid, addressed to: Law Offices of Hayt, Hayt & Landau, LLC,
Arthur Lashin, Esquire, 123 South Broad Street, Suite 1660, Philadelphia, PA 19109-
1003, Attorney for the Plaintiff.
David Stouffer, Pro
1619 South York Street
Mechanicsburg, PA 17055
(717)790-5535 (facsimile)
(717)439-5472
5