HomeMy WebLinkAbout12-3144r'
'TAMMY R. DEATRICK, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
NO. la-310
VINCENT RAMIREZ, III,
DEFENDANT CIVIL ACTION - LAW ` - ,
CD ,
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 RELIEF REQUESTED BY
'THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER IMPORTANT
RIGHTS.
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. 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.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY BAR CENTER
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
By:
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
IDS. 3 a
#a? svq?
r
TAMMY R. DEATRICK. IN THE COURT OF COMMON PLEAS
PLAINTIFF OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS.
NO.
VINCENT RAMIREZ, I1.1,
DEFENDANT CIVIL ACTION - LAW AND EQUITY
COMPLAINT
1. Plaintiff Tammy R. Deatrick is an adult individual residing at 22 Court Lane,
Carlisle, Cumberland County, Pennsylvania 17013.
2. Defendant Vincent Ramirez III is an adult individual with an unknown
residential address but who is believed to work at UPS Freight located at 6060
Carlisle Road, Mechanicsburg, Cumberland County, Pennsylvania 17050.
3. Defendant is married to Plaintiff's daughter.
4. Defendant and Plaintiff's daughter are now separated.
5. Plaintiff stored a Heritage Gun Sage (Serial Number 21507) at the marital
residence of Defendant and Plaintiff's daughter up until the time of separation.
6. At the time of separation the Defendant unlawfully removed the Heritage Gun
Safe from the marital residence.
7. The fair market value of the Heritage Gun Sage is One Thousand Nine
Hundred and (151100 ($1,905.05) Dollars.
8. Defendant is believed to have either sold the gun safe without legal authority
or hidden the gun safe.
9. Defendant has refused to return the gun safe to its owner, the Plaintiff.
COUNT I: CONVERSION AND THEFT OF GUN SAFE
10. Defendant owes the Plaintiff the sum of One Thousand Nine Hundred and
051100 ($1,905.05) Dollars.
11. Defendant has refused to pay this sum to the Plaintiff.
COUNT II: ACTION IN REPLEVIN
12. Defendant is in possession of the Heritage Gun Safe.
13. Defendant is without authority possess the personal property of the Plaintiff
14. Defendant must be ordered to return the Heritage Gun Safe to the Plaintiff's
possession.
WHEREFORE, Plaintiff requests entry of judgment in her favor for the return of
the Heritage Gun Safe and/or the payment of $1,900.05 plus costs of suit and interest
at the legal rate.
Respectfully submitted,
By:
51Ken Howell, E,,
Howell Law Firm
619 Bridge Street
New Cumberland, PA 17070
Supreme Court ID 62063
(717) 770-1277
Attorney for Plaintiff
Date: April 27, 2012
VERIFICATION
I/we verify that the statements made in the foregoing document are true and
correct. I/we understand that false statements herein are made subject to the penalties of
18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities.
BY: GLyn?
Tammy R. eatrick
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
alt?tx
Jody S Smith
Chief Deputy_
Richard W Stewart
Solicitor
Y 30
Tammy R. Deatrick
vs. Case Number
Vincent Ramirez, III 2012-3144
SHERIFF'S RETURN OF SERVICE
05/24/2012 02:41 PM - Elizabeth Muller, Deputy Sheriff, who being duly sworn according to law, states that on May
24, 201,2 at 1441 hours, she served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Vincent Ramirez III, by making known unto himself personally, at UPS Freight, 6060
Carlisle', Pike, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time
handing to him personally the said true and correct copy of the same.
SHERIFF COST: $38.00
May 25, 2012
rnuwl' ?--
ELIZABETH MULLER, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
. Goun`ySaite :henYf. ielec=cit. In;7