HomeMy WebLinkAbout11-6777FILED-OFFIC'
OF THE PRO1'HCNDT \R
2011 AUG 29 AN ! ! : 13
CUMBERLAND COUNTY
PENNSYLVANIA
CHARLES E. PETRIE, ESQUIRE
ID# 29029 Attorney for Plaintiff
3528 Brisban Street
Harrisburg, Pennsylvania 17111
(717) 561-1939
PetrieLaw(d),AOL. COM
AARON J. GREGOR, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND C/OUN?yTY,,, PENNSYLVANIA
vs. NUMBER: d / -/ / ?l y! L Af kk .
JOLLEEN PAZICH, : CIVIL ACTION -LAW
Defendant :
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 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.
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AARON J. GREGOR,
vs.
JOLLEEN PAZICH,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
NUMBER:
CIVIL ACTION -LAW
Defendant :
COMPLAINT FOR ACTION OF REPLEVIN
NOW COMES the Plaintiff, AARON J. GREGOR, by and through his
attorney, Charles E. Petrie, and respectfully represents as follows:
1. That Plaintiff is AARON J. GREGOR, an adult individual currently
residing at 377 Orchard Hill Road, Palmyra, County of Lebanon, Pennsylvania.
2. That Defendant is JOLLEEN PAZICH, an adult individual currently
residing at 207 Pine Street, Wormleysburg, County of Cumberland,
Pennsylvania.
3. That commencing in 2008, and continuing through May,2010,
Plaintiff moved/and or appropriated various items of personal property into
Defendant's residence.
4. Attached hereto as Exhibit "A" is a list of the items that Plaintiff
owned prior to taking up residence with Defendant. Exhibit "B" is a list of
those items purchased solely by Plaintiff for use by Plaintiff and Defendant in
WHEREFORE, Plaintiff requests that Your Honorable Court enter an
Order:
a. Scheduling a hearing in this matter, and
b. After hearing, entering judgment and writ of seizure in favor of
Plaintiff and against Defendant.
Respectfully submitted
CHARLES E. PETRIE
3528 BRISBAN STREET
HARRISBURG, PA 17111
(717) 561-1939
(717) 561-4121 FAX
PetrieLav*,AOL.com
Sup. Ct. I.D. No. 29029
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
I verify that the statements set forth in the foregoing Complaint are true
and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities.
f Zak(
DATE AARON . GREGOR
EXHIBIT "A"
1. (1) garment steamer
2. (1) 100-inch projector screen
3. (1) Elgin pocket watch
4. (1) Optima high-definition projector
5. (1) 20-feet-long DVI to HDMI cable
6. (1) Tag Heuer men's watch & box with papers
7. (1) Breitling 18k 2-tone men's watch 8s box with papers
8. (1) 2.5 ct. engagement ring & box with papers
9. (1) air compressor
10. (1) Craftsman tool chest
11. (1) Craftsman work bench
12. Numerous hand, power, cordless, and air tools
13. (2) 2007 Harmony remote controls
14. (8) weaved outdoor chairs
15. (2) outdoor reclining chairs
16. (2) outdoor patio umbrellas
17. Outdoor table and chairs
18. (1) outdoor fountain
19. (2) Polk outdoor speakers
20. (1) JBL 12-inch subwoofer
21. (1) Apple iMac computer with all accessories and keyboard
22. (1) HP Laserjet printer with cables
23. (1) HP all-in-one printer with cables
24. (1) Logitech wireless keyboard and mouse
25. Clothing, shoes, coats
26. (1) six-foot long power strip
27. (1) Home-theatre surge protector
28. (1) 42-inch plasma television set with wall mount and remote
29. Numerous HDMI cables and audio-visual cables
30. (1) jewelry box
31. (1) yellow sofa
32. (1) Chaise lounge
33. BOSE Center and 2 tower speakers
34. (2) Kilpsh tower speakers
35. (1) SONY 10-inch sub-woofer
36. (1) glass coffee table and (2) glass end tables
37. (1) wine refrigerator
38. Noritake colorwave dishes, silverware and glasses
39. Kenmore stainless steel refrigerator, dishwasher, and stove
40. Stainless steel table and two stools
41. Stainless steel water cooler and trash can
42. Stainless steel knife set with block
43. (1) Bello TV stand
44. (1) SONY 500 Disc CD changer
45. (1) MTD lawn mower with Honda engine
46. (1) Troy-built weed-eater
47. (1) Harmony remote control
48. (1) Tall light-wood cabinet with white panel door
49. (1) Tall light-wood wardrobe with 2 doors and a white panel on each door
50. Ou tdoor bar with three bar stools
51. (1) stainless steel outdoor grill
52. (1) Hoover vacuum cleaner
53. (1) Craftsman shop-vac
54. (1) Cigar humidor and cigars
55. (1) chest freezer
56. (1) king-sized bed
57. (1) head board
EXHIBIT "B"
1. (1) Pippo woman's watch square with diamonds & box with papers
2. (1) Chariol men's watch with Python band & box with papers
3. (1) Pioneer Premier audio/visual receiver with remote
4. (1) SONY audio/visual receiver with remote
5. (2) 2008 Insignia DVD players
6. (1) 2009 Bose Cine-mate Home Theatre speaker system
7. (1) baby grand piano
8. (1) 25-1b. bag of protein powder
9. (2) Electrolux floor air conditioning units
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
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Aaron James Gregor
vs.
Jolleen Frances Pazich
Case Number
2011-6777
SHERIFF'S RETURN OF SERVICE
09/29/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on September 29, 2011 at
1030 hours, he was unable to serve a true copy of the within Complaint and Notice, upon the within
named defendant, to wit: Jolleen Frances Pazich. After several attempts the Complaint and Notice has
expired.
SHERIFF COST: $76.44 SO ANSWERS,
September 29, 2011 RON R ANDERSON, SHERIFF
.C,: Coun`ySu.e Srenrf ie!ro ort. !i
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Ut?FSY
CHARLES E. PETRIE, ESQUIRE
ID# 29029
3528 Brisban Street
Harrisburg, PA 17111
(717) 561-1939
PetrieLa??),AO L. com
Attorney for Plaintiff
AARON J. GREGOR, : IN THE COURT OF COMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NUMBER: 11 - 6777 - Civil Term
JOLLEEN PAZICH, CIVIL ACTION - LAW
Defendant :
PRAECIPE
Please reinstate Plaintiff's Complaint filed August 29, 2011.
CHARLES E. PETRIE
3528 Brisban Street
Harrisburg, PA 17111
(717) 561-1939
ID# 29029
PetrieLaw(cr7,AOL.com
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X012 FEB 22 Ali g: 2t,
CUMBERLAND COUNT"
PFNNSYLVANIA
CHARLES E. PETRIE, ESQUIRE
ID# 29029
3528 Brisban Street
Harrisburg, PA 17111
(717) 561-1939
PetrieLawic AOL.com
Attorney for Plaintiff'
AARON J. GREGOR, : IN THE COURT OF COMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. NUMBER: 11 - 6777 - Civil Term
JOLLEEN PAZICH, : CIVIL ACTION - LAW
Defendant :
PRAECIPE
Please reinstate Plaintiff's Complaint filed August 29, 2011.
CHARLES E. PETRIE
3528 Brisban Street
Harrisburg, PA 17111
(717) 561-1939
ID# 29029
PetrieLaw&AOL.com
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2512 APR 10 AN 8: ?:-,
UM ERLANU vf? U i' 1
PENNSYLVANIA
CHARLES E. PETRIE, ESQUIRE
ID# 29029
3528 Brisban Street Attorney for Plaintiff
Harrisburg, PA 17111
(717) 561-1939
PetrieLaw(i,AOL. corn
AARON J. GREGOR, IN THE COURT OF COMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. NUMBER: 11 - 6777 - Civil Term
JOLLEEN PAZICH, CIVIL ACTION - LAW
Defendant :
PRAECIPE
Please reinstate Plaintiff's Complaint filed August 29, 2011.
CHARLES E. PETRIE
3528 Brisban Street
Harrisburg, PA 17111
(717) 561-1939
ID# 29029
PetrieLaw(&,AOL.com
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TH[E PR0TIv1r W ,.;
2112 JUL 12 AM 9: 51
CUMBERLAND COUNTY
PENNSYLVANIA
CHARLES E. PETRIE, ESQUIRE
ID# 29029
3528 Brisban Street
Harrisburg, PA 17111
(717) 561-1939
PetrieLawa,AOL.com
Attorney for Plaintiff
AARON J. GREGOR,
Plaintiff
VS.
JOLLEEN PAZICH,
Defendant
IN THE COURT OF COMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NUMBER: 11 - 6777 - Civil Term
CIVIL ACTION - LAW
PRAECIPE
Please mark the above-referenced matter settled, discontinued, and
withdrawn.
Y
CHARLES E. PETRIE
3528 Brisban Street
Harrisburg, PA 17111
(717) 561-1939
ID# 29029
PetrieLaw(a,AOL.com
FILED-OFFICE
T WE I ROTHUno' ?;.
2012 JUL 12 AM 9: 51
CUMBERLAND COUNTY
PENNSYLVANIA
AARON J. GRF.GOR,
VS.
JOL,LEEN PAZICH,
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVAN[A
No. 11-6777 Civil Term
CIVIL ACTION - LAW
Defendant
SETTLEMENT AGREEMENT ?
THIS AGREEMENT, made this day of _ J. 2012, by and
between Aaron J. Gregor, an adult individual hereinafter referred to as "Plaintiff", and Jolleen
Pazich, an adult individual hereinafter referred to as "Defendant."
WITNESSETI I
R'HERF.AS Plaintiff filed a civil action in replevin against Defendant for the return of
certain personal items; and
W[IERF.AS the parties wish to settle that matter;
NOW THEREFORE, in consideration of the premises and of the mutual promises,
covenants and undertakings hereinafter set forth and for other good and valuable consideration,
receipt of which is hereby acknowledged by each of the Parties hereto. Plaintiff and Defendant.
each intending to be legally bound hereby, covenant and agree as follows:
1. PROPERTY TO RE RETURNED TO PLAINTIFF: Defendant hereby agrees to
return the tollowing items to Plaintiff:
* .ubi n y,
a)
b)
C)
d)
C)
,furl IN
kvri
mo ? V9k4ck of pyg*.
In%1` a* ^A I P
Elgin Pocket Watch
Breitling i Sk 2 tone men's watch & box with papers
Tag Heuer Men's watch & box with papers
Pippo Women's watch square with diamonds & box with papers
2.5 ct. Engagement ring with box & papers
2. INSTR>rCTION`S FOR RETURNING PRopmry: Defendant hereby agrees to
give the items set forth in paragraph I to her attorney, Heather E. Verchick, Fsquire of
Andreozrl & Associates, located at 215 Pine Street, Suite 200, Harrisburg, PA 17101. These
items will be available at that location to be picked up by Plaintiff or his friend Noel Diaz.
Defendant agrees to provide the specified items to her attorney within ten (10) days of the date of
execution of this agreement.
3. REMAINING PROPERTY: Any property not specified herein that is currently in
Defendant's possession shall become the sole and exclusive property of Defendant. Plaintiff
does hereby specifically waive, release, renounce and forever abandon whatever claims, if any.
he may have with respect to the above items, which shall become the sole and separate property
of Defendant.
4. DISCONTINUATION OF ACTION: Within ten (10) days of receiving the
above-specified property from Defendant, Plaintiff hereby agrees to file with the Cumberland
County Prothonotary, a Preacipe to Discontinue, Settle & End the above-captioned Replevin
action.
?. DATE OF EXECUTION: The "date of execution" or "execution date" of this
Agreement shall be defined as the date upon which it is executed by the Parties if they have each
2
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executed the Agreement on the same date. Otherwise, the "date of execution" or "execution
date" of this Agreement shall be defined as the date of execution by the party last executing this
Agreement.
6. LAWOF PENNSYLVANIA APPLICABLE: This Agreement shall be construed
in accordance with the laws of the Commonwealth of Pennsylvania.
7. INTEGRATION- This Agreement constitutes the entire understanding of the
parties and supersedes any and all prior agreements and negotiations between them. There arc
no representations or warranties other than those expressly set forth herein.
8. SEVERABILITY: if any term, condition, clause or provision of this Agreement
shall be determined or declared to be void or invalid in law or otherwise, then only that term,
condition, clause or provisions shall be stricken from this Agreement and in all other respects
this Agreement shall be valid and continue in full force. effect and operating. Likewise, the
failure of any Party to meet his or her obligations under any one or more of the paragraphs
herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or
alter the remaining obligations of the Parties.
9. CONSTRUCTION: No provisions of this Agreement shall be interpreted for or
against any party because that party or party's representative drafted this Agreement in whole or
in part. In the construction of this Agreement, the parties hereto intend and agree that the
separate provisions of this Agreement shall be construed as a whole, and, where possible,
consistent with each other.
j o. HEADINQ NOT PART OF AGREIMENT: Any headings preceding the text of
the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference
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and shall not constitute a part of this Agreement; nor shall they affect its meaning, construction
or etIect.
IN WITNLSS WHEREOF, the Parties hereto have set their hands and seats the day and
year tirst abo•. a written.
4t (SEAL)
ESS - or
q?k? 1.? %,/w-
Wf I NESS
r--tlleen (SEAL)
Pazic
1P
COMMONWEALTH OF D rV 1 15-5 "55 t P P I
COUNTY OF / l?N _ : SS.
On this T day of 2012, before me, a Votary Public for the
Commonwealth of Pennsylvani& the undersigned officer, personally appeared Aaron J. Gregor,
kn«wn to me to be the person whose name is subscribed to the within Settlement Agreement and
acknowledged that ccuted the same for tlx: put poses therein contained.
\S0\\\I? 11I1rii,/iL
IN ?t.71",{,[.have hereunto set my hand and official seal.
?Jij 96? ' gyp,
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20 . PU? 4"'0ry0 : Notary Public
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COMMONW)rAl! HIQPOp SYi.VANIA
COLNTY OF . SS.
On this day of 2012, before me, a Notary Public for the
Commonwealth of Pennsylvania, the undersigned officer. personally appeared Jolleen Pazich.
kivv, n to me to be the person whose name is subscribed to the within Settlement Agreement and
acknowledged that he executed the same for the purposes therein contained.
IN WITNUSS WHFREOF. I have hereunto set my hand mid offrcia
OOMMONYVEALTH OF PENNSY6VANIA Notary
NOTARIAL SEAL
MICi-IELLE POWERS, Notary Public
Chambersburg Boro, Franklin County
My CommWsion Expires October 5, 2014
ac I