HomeMy WebLinkAbout04-4502COMMONWEALTH OF PIrNN§YLVANIA
COURT OF COMMON PLEAS
JUDICIAL DISTRICT
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. 04-4502 Civil Term
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Coud of Common Pleas an appeal from the judgment rendered by the
District Justice on the date and in the case mentioned below.
CLAIM NO,
This block will be signed ONLY when this notation is required under PA. If appellant was Claimant (see PA R.G.P.d.P.
R.C.P.d.P. No. t00gB. No. I001(G)) in action before district dustice, he
This notice of Appeal, when received by the District dustice, will operate as
A SUPERSEDEAS to the Judgment for possession in this case. MUST FILE A COMPLAINT within twenty (20)
days after filing his NOTICE of APPEAL,
S~Jnature of Prothonotary or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDAN'r (see PA R.C.P.J.P. No. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAEClPE: To Prothonotary ^ ~
Enter rule upon ~'J'{"';,.~'} ~/ ~/~/o~s/-/L'' , appellee(s), to file a complaint in this appeai
04-4502 Civi~'"~t~e~l~ ~/
(Common Pleas No. ) within fwenty (20) days after service o[ rule or suffer entry of judgment of non pros.
~,~ature of appeflant'orT~is attorney or agent
RULE: To Hudson & Keyse, LLC , appellee(s)
Name of appellee(s)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty(20) days
after the date of service of this rule upon you by personal service or by cedified or registered mail.
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU
UPON PRAECIPE.
Date:
(3)
White - Prothonotary Copy
Green Cour[ File Copy
Yellow - Appelant's Copy
Pink - Appellee Copy
Gold - D.J. Copy
The date of service of this rule if service was by mail is the date of the mailing.
September 7 ,Year 2004 3~[..~ /~Sign~ateo~ryorD~eputy~
Ptoth.- 76
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicablo bo×es
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ; ss
AFFIDAVIT: I hereby swear or affirm that I served
] a copy of the Notice of Appeal, Common Pleas No. , upon the District Justice designated there,
(date of service) , year , [] by personal service [] by (certified) (registered) ma~l,
receipt attached hereto, and upon the appellee, (name
, year , [] by personal service [] by (certified) (registered) mail, sender's receipt attached
] and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to
whom the Rule was addressed on _ , year , [] by personal service [] by (certified) hegiste~,:
mail, sender's receipt attached hereto.
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS DAY OF , YEAR .
My commission expires on , year
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERT"AND
09-1-02
ROBEI~T V. MANLOVE
ADd ....1901 STATE STREET
CAMP HILL, PA
Telepho.e (717) 761-0583
MARY B. MORRISON
3422 BEDFORD DR
CAMP HILL, PA 17011-2717
17011-0000
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
~Cu-DSON & KEYSE, LLC q
107 N COt~ERCE WAY
BETHLEHEM, PA 18017
VS.
DEFENDANT: NAME and ADDRESS
~MOP, RISON, GEROGE A, ET AL. ~
3422 BEDFORD DR
CAMP HILL, PA 17011-2717
Docket No.: CV-0000302-04
Date Filed: 7/01/04
THIS IS TO NOTIFY YOU THAT:
Judgment:
[] Judgment was entered for: (Name)
[] Judgment was entered against: (Name)
DEFAULT JUDGMRNT PLTF
klH~ON & KRYRR, T,T,C
MORRISON, MARY B
in the amount of $
2., 1:2.4.1~ on:
(Date of Judgment)
Defendants are jointly and severally liable.
Damages will be assessed on:
~] This case dismissed without prejudice.
Amount of Judgment Subject to
Attachment/42 Pa.C.S. § 8127 $
~ Podion of Judgment for physical
damages arising out of residential
lease $
(Date & Time)
Amount of Judgment $ 2,032.15
Judgment Costs $ 92.00
Interest on Judgment $ .00
Attorney Fees $ .00
Total $ 2,124.15
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FiLiNG A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL,
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR DISTRICT JUSTICES, IF THE JUDGMENT HOLDER
ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT
OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE DISTRICT JUSTICE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES,
OR OTHERWISE COMPLIES WITH THE JUDGMENT.
My commission expires first Monday of January. 2006 ·
AOPC315-03 DATE PRINTED: 8/09/04 4:21:51 PM
~' .,~ ~, .;.d~t~Ct Justice
Date
is a tr~¢¢ ~YCe record of the proceedings cA~ ~'~,¢,j,~gme~.. ,
Date~:~/~ r ~ ~. t~rlct O~,ce
~A~
COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
JUDICIAL DISTRICT
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. 04~'~ 502 Civ~-I
NOTICE OF APPEAL
Notice is given that the appe}lant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the
District Justice on the date and in the case mentioned below.
LT YEAR
This block will be signed ONLY when this notation is required under PA.
R.C.P.J.P. No. 1008B.
This notice of Appeal, when received by the District Justice. will operate as
A SUPERSEDEAS lo the Judgment for possession m this case.
If appel/ant was Claimant fsee PA R.G.P.J.P
No. 1001(6)) in action before districl Justice, he
MUST FILE A COMPLAINT within twenty (20t
days after filing his NOTICE of APPEAL.
PRAEClPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDAN f (see PA R.C.P.J.P. No. t001t71 m ac~on calera District Justice.
IF NOT USED, detach from copy of notice of appeal to be servea aDbe abeeliee.
PRAEClPE: To Prothonotary
04-4502
(Common Pleas No. ) within twenty (20) days after semite o[ ~uie or suffer ent~ el judgment of non pres.
RULE: .... aD~ilee(s)
To
(t)
(2)
(3)
D at e: _ _~?.e~pt: emi:~r
White * Proth~ot~y Copy
Green - Court ~ Copy
Yellow Appelarit~_opy
~ink - Appellee CdlS~ -~
,~old - D, J. Copy
You are notified mm a rule is hereby entered upon you to file a complaint in this appeal within twenty(20) days
aJter the date of service of this ru[e ueon you by personal se,~,ice or by certified or registered mail.
It you do not file' ~ cempJaint within this time. a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU
U ~O,N PRA~CIPE.
The date ct s~ice of this r~ if se~ice was oy mail is the date o[ the mailing. ~..
: 2004 ~ ' "~ .... [
. Ve~r ' Y-' - Signa~;o~not~ryorDo~uty'
Pmth.- 76
-*-*-*-*~a,' p% & ~ee~
(This proof of sen/ice MUST BE
APPEAL AND RULE TO FILE COMPLAINT
(10) DAYS AFTER filing the notice of appeal, Check applicable
COMMONWEALTH OF PENNSYLVANIA
oo, N oF
_ ;ss
AFFIDAVIT: I hereby swear or affirm that I served
h
r~pt attac~ ~rmo, a~ u~n the appellee, {name ~ ~ ~ ~ ~ , o~
~and fu~her that I se~ the Ru~e to Fire a Complaint accompanying the above Notice of Appea~ upon the appellee{s) to
whom the Rute was addressed on ....... year , ~ by personal se~ice ~ by (ce~ifled} (registered)
mail, sender's receipt attached hereto
SWORN {AFFIRMED) AND SUBSCRIBED BEFORE ME
['~ NOTAR AL SEAL
ROBERT ,} GOLD Notarf public
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC :
:
Plaintiff : No. 04-4502 Civil
VS. :
:
MARY B. MORRISON
CIVIL ACTION
Defendam :
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.
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 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
AMATO AND MARGLE, P.C.
Ronfil(~ Ar~, Atty ID #32323
Michael Keffnedy, Arty ID #72412
Michael Lessa, Atty ID #88617
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff
VS.
MARY B. MORRISON
Defendant(s)
: No. 04-4502 Civil
CIVIL ACTION
COMPLAINT
The above Plaintiff brings this action against the above Defendant to recover the sum
of $2,077.82, with interest thereon as hereinafter stated, upon the following cause of action:
1. The Plaintiff, HUDSON & KEYSE, LLC is located at 382 Blackbrook Road,
PAINESVILLE OH 44077.
2. The Defendant, MARY B. MORRISON is located at 3422 Bedford Drive,
CAMP HILL PA 17011-2717.
3. At the special instance and request of the Defendant, Chase Manhattan Bank,
N.A., issued to Defendant its Mastercard credit card, and from time to time thereafter,
Defendant made various purchases, in which transactions Defendant made use of said
Mastercard credit card. A true and correct copy of a Statement of Defendant's Account, is
attached hereto, made a part hereof and marked Exhibit "A".
4. For value received, Chase Manhattan Bank, N.A. assigned, transferred and set
over to Plaintiff all its rights, title and interest in this claim.
5. By virtue of said assignment, Plaintiff acquired legal title to said Account, and
became the legal holder of the claim against the Defendant.
6. Defendant has not adhered to the agreed repayment obligations that govern the
aforesaid Mastercard credit card account, by reason of which Defendant is in default thereof.
7. The Defendant received, accepted and made various purchases using the credit
card described in Exhibit "A", and a total amount which became due as a result thereof, after
allowance for all proper credits for payments and/or adjustments, if any, was $1,540.16.
8. Plaintiff is entitled to receive interest on the above amount determined by
applying the agreed interest rate of 14.90% ~ to the past due balance. As of
September 14, 2004 the total amount of interest due to plaintiff is $537.66.
9. Plaintiff is entitled to have the 14.90% interest charge continue to accrue as set
forth above, from September 14, 2004 on down to the date of judgment in this matter.
10. The Plaintiff has made demand against the Defendant for the aforesaid sum, but
Defendant failed or refused to pay the same or any part thereol?.
WHEREFORE, Plaintiff demands judgment against the Defendant for $2,077.82 together
with the continually accruing interest charge at the agreed rate of 14.90% ~ from
September 14, 2004, and cost of suit.
COUNT Il
Alternative to Count I - Unjust Enrichment
11. Plaintiff incorporates the allegations of every paragraph enumerated above of
this Complaint as if said paragraphs were fully set forth here at length.
12. The goods, wares, merchandise, and/or services, described in the exhibits
attached hereto were purchased by Defendant, and Defendant received and accepted the benefit
of such goods, wares, merchandise, and/or services provided by Plaintiff.
13. At all times material hereto, Defendant was aware that Plaintiff was providing
· the aforesaid goods, wares, merchandise, and/or services to Defendant, and that Plaintiff
expected to be paid for such.
14. At all times material hereto, Defendant, with the aforesaid knowledge,
permitted Plaintiff to provide and/or deliver said goods, wares, merchandise, and/or services,
and to incur damages.
15. At all times material hereto, Defendant was unjustly enriched by retaining the
benefit of receiving said goods, wares, merchandise, and/or services without paying Plaintiff
fair and reasonable compensation.
16. By reason of the aforesaid unjust enrichment of Defendant at Plaintiff's
expense, an implied contract exists between Plaintiff and Defendant, and Defendant is
obligated to pay Plaintiff the quantum meruit value of the value of the goods, wares,
merchandise, and/or services described in the exhibits attached hereto, in the amount of
$1,540.16.
WHEREFORE, Plaintiff demands judgment against Defendant for $1,540.16 together
with the continually accruing interest charge at the statutory rate of 6.00% l~er annum from
September 14, 2004, costs of suit and all other relief to which Plaintiff may be justly entitled.
AMATO AND MAflGLE, P.C.
R.o. na~dtAma~'o,~i ID #32323
Michael Lessa, Atty ID #88617
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
STAT. E OF OHIO
COUNTY OF LAKE
SS
HUDSO. N & KEYSE, L.L.C.
ASSIGNEE CHASE MANHATTAN BANK
Plaintiff,
VS.
George A. and Mary B. Morrison
Defendant (s)
I solemnly affirm under penalties of perjury:
AFFIDAVIT
1. That I, Joseph M. Carroll, am the President of the Plaintiff herein and am competent to testify to the matters stated
herein, which are made on my personal knowledge and are tree and correct.
2. That there is justly an amount due and owing Hudson & Keyse, L.LC. Assignee Chase Manhattan Bank by the
Defendant(s) to the Plaintiff, the sum of money amounting to $1,540.16 plus interest totaling $370.65 through
November 30, 2003; and that such balance will continue to earn interest at a rate of 24.00% from August 21, 2002 as
an annual percentage rate calculated as required by the Federal Truth In Lending Act.
3. That the said indebtedness represents the amount due and originating on a Credit Card which Hudson & Keyse,
L.L.C., is the Assignee of Chase Manhattan Bank and that Hudson & Keyse, L.L.C., Assignee Chase Manhattan
Bank, the within named Plaintiff, having purchased said Credit Card from said assignor, is the owner of said debt and
is the proper party to bring this action.
That Plaintiff has not directly or indirectly received any part of the money or goods herein as due, or received any
security or satisfaction for which credit has not already been given.
That the Plaintiff keeps regular books of account and that the keeping of said books of account is in the charge of or
under the supervision of the undersigned affiant. The entries in said books of account are made in the ordinary
course of business. Said entries show that the Defendant(s) is/are indebted to the Plaintiff in the manner and amount
set forth herein.
6. That I have made diligent inquiry to determine if the defendant is in the military service of the United States of
America, and have determined that defendant is not in such military service and is therefore not entitled to the rights
and privileges provided under the Soldiers and Sailors Civil Relief Act of 1940, as amended.
Dated t~December, 2003.
Jose~. 11, President
Subscn~ed'~md sworn to before me, a Notary Public for the State of Ohio, this 22"d day of December, 2003 as certified by
my hand and official seal as set forth immediately below.
l~lotary Puhl~, State of O'o~~-
NANCY A. QUERE
Notary Public, S,~afe of Ohio
My Commission Expires ,~'
HUDSON & KEYSE, INC.
STATEMENT OF ACCOUNT
CREDITOR NAME:
ORIGINAL CREDITOR:
ORIGINAL ACCOUNT #:
DEBTOR NAME:
ACCOUNT NUMBER:
DATE OPENED:
DATE LAST PAID:
PRINCIPAL:
INTEREST:
TOTAL:
Hudson & Keyse, L.L.C.
Chase Manhattan Bank
5260368110002768
Mary B. and George A. Morrison
232500* 1
12/01/01
08/21/02
$1,540.16
$370.65
$1,910.81
INTEREST RATE: 24.00%
0%
LOCAL: (440)354-6978 FAX: (440)354-1336 ~
TOLL FREE: 1(800)654-5391 & 1(800)654-1660 ..................
PLEASE SEND CORRESPONDENCE TO:
HTTP: WWW.HKINC.COM
EMAIL: COLLECTIONS~HK/NC.COM
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE, LLC
Plaintiff
VS,
No. 04-,¢502 Civil
MARY B. MORRISON
Defendant(s)
: CIVIL ACTION
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of Plaintiff's Complaint was
served via first class mail, postage prepaid on September 21, 2004:
Mary B. Morrison
3422 Bedford Drive
CAMP HILL PA 17011-2717
AMATO AND MARGLE, P.C.
Ronald Amato,"'Atty ID #32323
Michael Kennedy, Atty ID #72412
Michael Lessa, Arty ID #88617
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400
HUDSON & KEYSE, LLC
Plaintiff
VS.
MARY B. MORRISON
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 04-4502 CIVIL
RESPONSE OF MARY B. MORRISON TO COMPLAINT
1. After reasonable investigation, Mary B. Morrison is without
knowledge or information sufficient to form a belief as to the truth
of paragraph 1. The same is therefore denied.
the credit
Morrison
thereof,
George A. Morrison
several months before the December 1,
account was opened as set forth in
complaint.
4. After reasonable investigation, Mary B.
knowledge or information sufficient to form a
of paragraph 4. The same is therefore denied.
card application and on the various purchases. George A.
is Mary B. Morrison's deceased husband. In partial proof
attached hereto as Exhibit A is the death certificate of
indicating a date of death of June 7, 2001 which is
2C01 date this particular
Exhibit A attached to the
Morrison is without
belief as to the truth
2. Admitted.
3. Denied. Mary B. Morrison never requested Chase Manhattan
Bank, N.A. (Chase} issue her a credit card.. Mary B. Morrison never
used the credit card. It is believed by Mary B. Morrison that her
son, George L__z. Morrison, who died on March 2, 2004, forged Mary B.
Morrison and George A__. Morrison's (Date Of Death: 6/7/2001) name to
After reasonable investigation, Mary B. Morrison is without
knowledge or information sufficient to form a belief as to the truth
of paragraph 5. The same is therefore denied.
6. Admitted that Mary B. Morrison has not made the
the debt. For the reasons set
herein by reference), it is
money to Chase.
payments on
forth in paragraph 3 (incorporated
denied that Mary B. Morrison owes any
7. It is Denied that Mary B. Morrison ever used the credit card.
After reasonable investigation, Mary B. Morrison is without knowledge
or information sufficient to form a belief as to what the balance
owing on the account is. That $1,540.16 is OWing is therefore denied.
8. After reasonable investigation, Mary B. Morrison is without
knowledge or information sufficient to form a belief as to the truth
of paragraph 8. The same is therefore denied.
of paragraph
9. After reasonable investigation, Mary B. Morrison is
knowledge or information sufficient to form a belief as
9. The same is therefore denied.
without
to the truth
10. Admitted.
WHEREFORE, Mary B. Morrison requests that Plaintiff's complaint
be dismissed.
11. No response required.
12. Denied. Nothing in the exhibits sets forth what was
purchased with the credit card.
13. Denied. Mary B. Morrison denies receiving any goods, wares,
merchandise, and or services from Chase or finanoed by Chase.
14. Denied. Mary B. Morrison denies receiving any goods, wares,
merchandise, and or services from Chase or financed by Chase.
15. Denied. Mary B. Morrison denies receiving any goods,
wares, merchandise, and or services from Chase or financed by Chase.
16. Denied. Mary B. Morrison denies receiving any goods, wares,
merchandise, and or services from Chase or financed by Chase.
WHEREFORE, Mary B. Morrison requests that Plaintiff's complaint
be dismissed.
YOFFE & YOFFE, P.C.
~~uire
ttorne for Mary B. Morrison
214 Senate Avenue, Suite 203
Camp Hill., PA 17011
(717) 975-1838
Attorney ID No. 52933
jyoffe~verizon.net
HUDSON & KEYSE, LLC
Plaintiff
VS.
MARY B. MORRISON
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 04-4502 CIVIL
VERIFICATION
I hereby state that I am an adult individual who is authorized
to make this verification and that the facts set forth in the foregoing
Answer are true to the best of my knowledge, information, and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to
authorities.
Dated:
MARY B. 6fORRISON
18/12/2884
i2:42 717783536i
CENTRAL DAL~HIN~
PAGE 02
~ ~ 66, P.L. ~, ~pp~d ~y the Gen~ ~b~, Ju~ ~, 1953.
WARNING: h i~ ill~al ~ dupll~e ~1. ~ by phol~l~t ~ ~mph,
1838904
CERTllqCATE* OF DF. ATH
EXHIBIT "A"
HUDSON & KEYSE, LLC : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO. 04-45(12 CIVIL
MARY B. MORRISON :
CERTIFICATE OF SERVICE
The undersigned certifies that on the date indicated below he
served a copy of the foregoing response on Michael R. Lessa, Esq.
Service was accomplished by mailing the same as follows:
Michael Lessa, Esq.
107 North Conunerce Way
Bethlehem, PA 18017
YOFFE & YOFFE, P.C.
Date:
October 18, 2004
Je~fre~ N. Yo{fe, Esquire
Attorney for Mary B. Morrison
214 Senate Avenue, Suite 203
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
jyoffe~verizon.net
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
HUDSON & KEYSE~ LLC
Plaintiff
VS.
MARY B. MORRISON
Defendant(s)
No, 04-4502 Civil
CIVIL ACTION
PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please discontinue the above-captioned case WITHOUT prejudice.
AMATO AND MARGLE, P.C.
BY~~323
Michael Kennedy, Atty ID//72412
Michael Lessa, Atty ID #88617
Attorneys for Plaintiff
107 North Commerce Way
Bethlehem, PA 18017
(610) 866-0400