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Home My WebLink About04-4414Y. VR°tAN. P.C. ,I Fr ? ,- N, Re rman, Esquire, T .5. Rvl T ,er ^ ., .. n E squire-. .D. 56475' 8 A' .,,ay - Rnad. Suite a0e, king of Pzu -ia_ PA 0406 ------------------------------------- r ISC`.'%VER BANK c%n FRTC M. BERMAN, PC, 1% Allendale Road, Suite 206 King of Prussia, PA 10406 up. TRACY LYNN TROU,TMAN =< ,l MOUNT ALIEN DR MSCHANTCSBCIRG. PA 17055 6107 ------------------------------- TRIAL DIVISION CTVTL ACTT "?N Term -- --Y No.OV - 4/9'/`1 etu) 1<:-- NOTICE TO DEFEND You have heen rued in court. Tf you wish. to defend against the claims Pet forth in the following pates, you must take nation within twenty (20) days after this Complaint and Notice are sprv"d, by entering a written appearance personally or by attorney and filing in writing; with the Court your defen=se=: or objections to the claims sot forth against you. You are warned that if you fail to do so the n•as;e may _r,ror,eed without you. and a judgment may be entered again=; t. you by the !'Hurt, without further notice for any money claimed in this ow-plaint. or for any other claim or relief required by the plaintiff. You may 1'017?,rr. money or property or other rights; important, to you_ YOU SHOULD TAKE THIS PAPER TO YOUR. LAWYER AT ONCE, TF YOU Dc'; NOT HAVE A LAWYER OR CANNOT AFFORD ("NT GO TO nR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE:, YOU CAN GET LEGAL HELP. TLTO OFFICE CAN PROVIDE Yn0 WITH INFORMAtTON ABOUT H.TRING A LAYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIN nFFTQF MAY RI,, ABLE Tn PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY DFr'Fy TTGAI SERVICES TO PLTGTBLE PERSONS AT A REDUCED PEE OR Nn EFF- LAWYER REFERENCE SERVICE COUNTY OF CUMBERLAND BAR. ASSOI TAtTTON 2 L.TBFR,TY AVE. CARLISLE. PA 17013 '00-990-9108 (COURT OF COMMON PLEAS k COUNTY OF CUMRF.RLANT, o. -:;,;r Fi. i.e Nn.. I?3(193p ?TTORNKYS FOR. PLATNTTFF FRTC M_ BERMAN. P.C. BY: Eric M. Berman- Psguire, I.D. 8:3698 BY: Robert M. Kline. FsgoAre,.T.D. 55479 19Allendale Road. Suite :306 Kin of Pr•u5si..a, PA. 04, (S 7 O) 205-7720 ----------------------------.-----------X DT S('i)VFR.. BANK iv`o FRTC M. -BERMAN, F.C. 1% Allendale Rnad, Suite ^-:O6 King of Prussia_ PA 19405 vs_ TRACY LYNN TRf?UTMAN MOUNT ALLEN DR MF%'HANTC7SS,'?RG. PA 17055 5107 --------------------------------------- T COMPLAINT 1. Plaintiff, DISCOVER BANK , is a DELAWARE STATE. BANK authorised to do business in the Commonwealth of Pennsylvania with its place of business at 0311 MTT.L MEADOW DRTVF., HTTS,TARD_ OH 43029. - The Defendant(s), TRACY T,YNN T R UTMAN resides at 320 MOUNT AT,T,EN DR MECHANTC BURG, PA 17355-6107, There is du from the Defendant(o) the sum of Mr ,90 for credit extended by Plaintiff to Detenda.nt(a)7 ar.i?t, no, a=si?11Ut; r??tl?.';,43C'.i. and which uah nredit was i3:c`awn and used by the Defendant(s). Defendant(,) i in default for failure to make payment, for such use- 4. The Plaintiff has made demand upon the Defendant(V) for payment of monies in the :-;um of $5,028-50 advanced to De.fendant(s, through Defendant(.) use of the above referenced credit account, but. Dofendant(s) has failed and refused to pay the said sum or any part thereof, 5- All applicable ores i t„. if any, have been duly -tpj+.. i. tj t0 Dol''np._ant! ) or."di t aprownt. COURT OF COMMON PLEAS COUNTY OF C'IIMBFRLAND CTVTT- ACTTP7!N Term No. OY- Vy/y Q'I I0 WHERFITORF_ Plaintiff claims of the Pefendan7(3) the um of t`,O'R.F;C) plus interest, Attorneys fens and coat; which are justly due and nG:.rnT :`.mill the 1.!t'f.°.ndatiti8l to the Fia7t7tlff. i:at.ed.: JUNE :',009. R.TC M. BY- FR T s BY, PERM N , 0, R, M . F /1 RM , T F'B ?J SPAC ERNW-ZN ROBERT M, KI T NF FSQUTRF Attorney, for Plaintiff ER1 77CATTON Fr5t, M_ Berman. R gT.l.ire_ being duty sworn according t -awn decjc „es and ,ays raat, ire ... ,_, the Pri.nni.pa'! attorney of Fri.,- M. Rer'Itzcl, P, 'ittorney's Por the P7. al nt.i ft - and/or polIt'rt. M. hi.i ne. F;:g1.11re, In e ng kill].y ;=twcTT) aacrtl]l.!1 t.O LaW. deLQ ' and ay:4 that. }le i.5 an a33c?oi.ate attortley with said fi T't11, and as ;3aic7 at...t rney, i.a autntr..i-ed to ta)•;e th1s verification on it:= behalf, and at. file facts jr, Oita Complaint a; set forth therein are title aM<Y :rc.xract to , lr )e:gt. of lids i;nowl.a:it ge, ran?-,rlTratroti any bet lrf. verify that. t. e :: tatemrnts true -tru:i corrHCt. T midcr.z?tand to tile- petit *ie;, of 1 + F?i C,S A_ -_ , FR'.T! M. RFRMAN- F QUTRF ,. itl,a,t E- lG file W3. tri 7. S1 Z-rl tYail]Brlt ri_l:a t4t7a` 1:a l3r' t.a `. d'tllEe ti `'.:9 aT`r ;mil i'1 SP t.ion 4 ,G4 elat,it; t.;1 iml.wnrn ?l/ R?>RFRT M. kITNF FSQJ"I ''RF. Bated= ?ITJNF 10, 1004 SPRCFRNW-7N (] N f:7 Cw) r ?T7 ?y 1 J id n ? C T m F r : I - 3 ` ? ? n S O V L? -+ SHERIFF'S RETURN - REGULAR CASE NO: 2004-04414 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS TROUTMAN TRACY LYNN DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon TROUTMAN TRACY LYNN the DEFENDANT , at 1215:00 HOURS, on the 7th day of September, 2004 at 320 MOUNT ALLEN DRIVE MECHANICSBURG, PA 17055 by handing to DANIEL TROUTMAN, HUSBAND 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 8.14 Affidavit .00 Surcharge 10.00 .00 36.14 Sworn and Subscribed to before me this day of I r?vwtu. 2 0v y A. D. /Prothonotary So Answers: R. Thomas Kline 09/08/2004 ERIC BERMAN By: /ty &-f f in Deputy / ShhnJerif (? U? SEP 1 1, 2004 t4 ANNICK BARNINGER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 03-4414 Civil HAUBERT HOMES, INC., Defendant JURY TRIAL DEMANDED A ORDE day of 2004, upon AND NOW, this consideration of Plaintiffs Motion to Make Rule Absolute, it is hereby ordered that the Rule which was issued on Defendant in the above captioned matter on July 7, 2004, to show cause why the Plaintiff should not be granted leave to file an amended complaint, and the Defendant not having responded to the Rule and more than twenty (20) days have passed since service of the Rule it is hereby ordered that the rule is made absolute. The Plaintiffs request for leave to file an amended complaint is granted. 00d J. Oq ? ? ? ice, ? r'?iilrJ tz , : v? oz ?.:aooa si ac IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHAWNA K. SURRIDGE, Plaintiff VS. No. 2002-4414 in Divorce TYPE OF PLEADING: Praecipe to Transmit the Record AARON W. SURRIDGE, FILED ON BEHALF OF: Defendant Shawna K. Surridge, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Mary Bower Sheats, Esquire PA I.D. #27911 1310 Allegheny Building 429 Forbes Avenue Pittsburgh, PA 15219 (412) 281-7266 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHAWNA K. SURRIDGE, Plaintiff VS. AARON W. SURRIDGE Defendant : No. 2002-4414 in Divorce PRAECIPE TO TRANSMIT THE RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: Ground for divorce: irretrievable breakdown under §3301(d)(1) of the Divorce Code. 2. Date and manner of service of the complaint: Acceptance of Service by Aaron W. Surridge. 3. (b)(1) Date of execution of the Affidavit required by §3301(d) of the Divorce Code: March 22, 2005; (2) Date of filing and service of Plaintiff's Affidavit upon the respondent: Affidavit filed April 12, 2005 with the prothonotary; Affidavit served on Defendant by first class mail on April 7, 2005. 4. Related claims pending: none 5. (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: May 4, 2005, by first class mail, postage prepaid, addressed to Aaron W. Surridge, 111 W. Taylor Street, Taylor, PA 18517- 1715-11. Date: q J a o Mary Bower Sheats, Esquire Pa. I.D.#27911 1310 Allegheny Building 429 Forbes Avenue Pittsburgh, PA 15219 (412) 281-7266 CERTIFICATE OF SERVICE I hereby certify that I am this day serving a true and correct copy of the attached or foregoing document upon the persons and in the manner indicated below: Service by first class mail, postage prepaid and addressed as follows: Aaron W. Surridge 111 W. Taylor Street Taylor, PA 18517-1715-11 ?- Date & 11 4 Mary Bower Sheats, Esquire Pa. ID# 27911 1310 Allegheny Building 429 Forbes Avenue Pittsburgh, PA 15219 (412) 281-7266 COPY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHAWNA K. SURRIDGE, Plaintiff V5. AARON W. SURRIDGE, Defendant No. 02-4414 Civil Action -Law TYPE OF PLEADING: Notice of Intention to Request Entry of §3301(d) Divorce Decree FILED ON BEHALF OF: Shawna K. Surridge, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Mary Bower Sheats, Esquire PA I.D. #27911 1310 Allegheny Building 429 Forbes Avenue Pittsburgh, PA 15219 (412) 281-7266 o O t. O T ._ n+_ W - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHAWNA K. SURRIDGE, Plaintiff VS. No. 02-4414 Civil Action -Law AARON W. SURRIDGE Defendant NOTICE OF INTENTION TO REQUEST ENTRY OF §3301(d) DIVORCE DECREE TO THE DEFENDANT: Aaron W. Surridge 111 W. Taylor St. Taylor, PA 18517-1715 You have been sued in an action for divorce. You have failed to answer the complaint of file a counter-affidavit to the §3301(d) affidavit. Therefore, on or after June 15, 2005, the other parry can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1 Date: 5 l 'L Mary Bower Shears, squire, Pa. ID. 427911 1310 Allegheny Building 429 Forbes Avenue, Pgh., PA 15219 (412) 281-7266 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHAWNA K. SURRIDGE, Plaintiff VS. AARON W. SURRIDGE Defendant No. 2002-4414 In Divorce NOTICE IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER AFFIDAVIT WITHIN 20 DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER §3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on or about AV, llS? 6O and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities. DATE: 4/1-s COUNTER AFFIDAVIT UNDER §3301(d) OF THE DIVORCE CODE Check either (a) or (b): _(a) I do not oppose the entry of a divorce decree. _(b) I oppose the entry of a divorce decree because (check (i), (ii) or both): _(1) The parties to this action have not lived separate and apart for a period of at least two years. _Gi) The marriage is not irretrievably broken. Check either (a) or (b): _(a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. _(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so b°vivr'v the date set fb1 LL?1 on the TY otltiei Vf Interl loll LV Request L1V VrQe Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of IS Pa. C.S. §4904, relating to unworn falsification to authorities. Date: Aaron W. Surridge, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER AFFIDAVIT. CERTIFICATE OF SERVICE I hereby certify that I am this day serving a true and correct copy of the attached or foregoing document upon the persons and in the manner indicated below: Service by first class mail, postage prepaid and addressed as follows: Aaron W, Surridge 111 W. Taylor St. Taylor, PA 18517-1715-11 Jeanne B. Costopoulos, Esquire 500 Ritter Road, Ste. 2,02 Mechanicsburgh, PA 17055 Date: Mary Bower Sheats, Esquire Pa. I.D.#27911 1310 Allegheny Building 429 Forbes Avenue Pittsburgh, PA 15219 ?4i2j 281 -1172VV IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHAWNA K. SURRIDGE, Plaintiff VS. AARON W. SURRIDGE, Defendant No. 2002-4414 in Divorce TYPE OF PLEADING: Praecipe to Transmit the Record FILED ON BEHALF OF: Shawna K. Surridge, Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Mary Bower Sheats, Esquire PA I.D. #27911 1310 Allegheny Building 429 Forbes Avenue Pittsburgh, PA 15219 (412) 281-7266 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHAWNA K. SURRIDGE, Plaintiff No. 2002-4414 in Divorce VS. AARON W. SURRIDGE Defendant PRAECiPE TO TRANSMIT THE RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(d)(1) of the Divorce Code. 2. Date and manner of service of the complaint: Acceptance of Service by Aaron W. Surridge. 3. (b)(1) Date of execution of the Affidavit required by §3301(d) of the Divorce Code: March 22, 2005; (2) Date of filing and service of Plaintiffs Affidavit upon the respondent: Affidavit filed April 12, 2005 with the prothonotary; Affidavit served on Defendant by first class mail on April 7, 2005. 4. Related claims pending: none 5. (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: Mayl, 2005, by first class mail, postage prepaid, addressed to Aaron W. Surridge, 111 W. Taylor Street, Taylor, PA 18517- 1715-11. Date: Mary Bower Sheats, Esquire Pa. I.D. #27911 1310 Allegheny Building 429 Forbes Avenue Pittsburgh, PA 15219 (412) 281-7266 CERTIFICATE OF SERVICE I hereby certify that I am this day serving a true and correct copy of the attached or foregoing document upon the persons and in the manner indicated below: Service by first class mail, postage prepaid and addressed as follows: Aaron W. Surridge 111 W. Taylor Street Taylor, PA 18517-1715-11 Date Mary Bower Sheats, Esquire Pa. ID# 27911 1310 Allegheny Building 429 Forbes Avenue Pittsburgh, PA 15219 (412) 281-7266 Curtis R. Long Prothonotary office of the Protbonotarp Cut>r><berlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 041 ? Nl! / 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