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Home My WebLink About04-4599STEVE DICK STANLEY LANDIS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V, NO: 42¢.- ¥,.¢,¢,~ CIVIL TERM 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 of for any other claim or relief requested by the Plaintiff. You may lose money or property or other dghts 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 OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Steve Dick Stanley Landis. Plaintiff V. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW 2004- 66~¢Civil Term COMPLAINT Steve Dick is an adult individual doing business as Steve's Tile Service at 2421 Ritner Highway, Carlisle, Cumberland County, Pennsylvania 17013. Stanley Landis is an adult individual doing business as Stanley Landis Design at the last known address of 2482 Horseshoe Road Lancaster, Lancaster County, Pennsylvania 17545. On or about July 2, 2004, Steve Dick did offer to perform work for Stanley Landis at a Pretzers Plus Store in Stanton, Virginia. Pursuant to that proposal, Mr. Dick did provide a written proposal which is attached and marked as exhibit A. Pursuant to that proposal Mr, Dick would provide tile service at the store for Mr. Landis and Mr. Landis did agree to pay the sum of $3,000.00 to Mr. Dick for that work. 5. The plaintiff, Steve Dick, did perform and did provide the tile service as required. Despite repeated demand the defendant, Stanley Landis has refused to pay the sum of $3,000.00 as required by the proposal and as agreed to by the parties following the successful completion of the work by Mr. Dick. 7. The plaintiff is owed the sum of $3,000.00 plus expenses of litigation plus interest from the date of default, July 2, 2004. WHEREFORE, for all of the above reasons, the Plaintiff, Steve Dick, hereby demands judgment in his favor in the amount of $3,000.00 plus interest and costs of suit. Respectfully Submitted, TURO LAW OFFICES 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I, Ron Turo, Esquire, attorney for the Plaintiff herein, have sufficient knowledge of the facts contained in this Complaint and verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, based upon information received from the Plaintiff. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Date SHERIFF'S CASE NO: 2004-04599 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERI3LND DICK STEVE VS LANDIS STANLEY RETURN - OUT OF COUNTY R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT , LANDIS STANLEY but was unable to locate Him in his bailiwick. deputized the sheriff of LANCASTER County, serve the within COMPLAINT & NOTICE , Sheriff or Deputy Sheriff who being says, that he made a diligent search and to wit: He therefore Pennsylvania, to On October 20th , 2004 , this office was attached return from LANCASTER Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Lancaster Co 40.25 .00 77.25 10/20/2004 RON TURO Sworn and subscribe~o ~b~e~o,r.e~ me this ~ day of ~4.~%/~O--t~{/~_ in receipt of the So ans /~-'~ ~ ~-~f ....... Sheriff of Cumberland County I--IE RI FF'S OFFICI-: 50 NORTH DUKE STREET, P.O. BOX 83480, .LANCASTER, PENNSYLVANIA 17608-3480 * (717) 299-8200 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN 1 pLAINTIFF/S/ 30EFENOANT/S/ Stanley Landis SERVE f § NAME OF INDIVIDUAL, COMPANY, CORPORATION, E/C, TO 8E SERVED. Stanley Landis AT 2482 Horseshoe Road Lancaster, PA 17545 7. {NeIGATE UNUSUAL SEBVIOE; ~DEPUTIZE ~ OTNEB Ct~berland Now, 9/16 20 04 , I, SHERIFF OF'~-- _.~ COUNTY, PA., do hBr~tJ~y ~utize the Shed[f Of Lancaster County to execute this Writ.~l~'~;n th_er~eof to law. This deputation being made at the request and risk of the plaintiff. PLEASE TYPE DO NOT DETACH ANY COPIES. 04-4599 civil 4 TYPE OF WRIT OR COMRLAINT Notice and CcrrrplaJmt CUMBERLAND CO. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying ul~on or attaching a,~y properly under within writ may leave same with out a watchman, in custody ol whomever is found in possessio n, alter notifying person of levy o r attach ment, without liability on ~g' SIGNATURETu~o/ E.sQ°f A1't'ORNEY or other ORIGINATOR 10. TELEPHONE?17_240_6390NUMBER II 1 t DATE9~14~04 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). CUMBERLAND OFFICE OF THE SHERIFF ONE COURTHOUSE SQ. CARLISLE PA 17013 SPACE BELOW FOR USE OF SHERIFF ONLY -- DO NOT WRITE BELOW THIS LINE orcomplaintasindicatedabove ~ ~E~f~ ~WAL~ON 717-295-3609 JM 9/20/04 10/14/04 See Remarks 8ek~w (No, 30) 24. Advance Costs 125, Service Costs J26i~otaryCer~ ]2' 'eage osag . ) . s I c STP EOB FU D 30, Steve Dick, Plaintiff Vo Stanley Landis, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW 04-4599 CIVIL TERM PRAECIPE TO ENTER DEFAULT JUDGMENT To Prothonotary of said Court: Please enter a Default Judgment in favor of the Plaintiff, Steve Dick, and against the Defendant, Stanley Landis, for failure to plead having been served by Sheriff with a certified copy of the Complaint on October 13th, 2004, and thereafter served with a Notice of Default on November 2nd, 2004, as evidenced by the attached Notice of Default. Please enter the judgment in the amount of $3,000.00, plus interest from July 2nd, 2004, and costs of record. Respectfully Submitted TURO LAW OFFICES MICHAEL M. JEROMINSKI, ESQUIRE Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 Pa. Supreme Court No. 92977 Phone: (717) 245-9688 Fax: (717) 245-2165 Attorney for Plaintiff STEVE DICK STANLEY LANDIS Plaintiff Defendant NO: 04-4599 CIVIL TERM CIVIL ACTION - LAW TO: Stanley Landis DATE OF NOTICE: November 2, 2004 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland 'County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Date Respectfully Submitted T,~~,O LAW OFFICES .. 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff