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HomeMy WebLinkAbout12-4401COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. p? _ L`t 6 / 6V1 NOTICE OF APPEAL I Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Distri Justice on the date and in the case referenced below. OF APPELLANT _. I MAG. DWJ NO. £SS OF APPELLANT CRY STATE ZM 'w 56L j?eN k -A F-b . A W3 OF JUDGMENT IN THE CASE OF (PMir ( )L-U-CL vs ?t . 55WT RRE OF APPELLANT OR ATTORNEY OR AGENT This block will be signed ONLY when this notation is required under Pa. If 6AWant was Claimant (see Pa. R.C.P.D.J. No. 10(1(6) in action R.C.P.D.J. No. 1008B. This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILE within twenty SUPERSEDEAS to the judgment for possession in this case. (20) days after filing the NOTICE of APPEAL. SONIft a of pmowndwy or DSPW (This sect' t NOT USED, de PRAECIPE: To Enter rule upon PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO F 1 to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1 ) ' action before from copy of notice of appeal to be served upon appellee. (Common Pleas No. 19 RULE: To ac "Y", to file k)?glplaint in this appeal within twenty (20) days after appellee(s), to file a complaint in is appeal Name of apPOWS) within twenty (20) da service of rule or suffer entry of judgment o non pros. c? Signature of sAm tent or homey or agent Ilee(s) (1) You are notified that a rule is hereby entered of this rule upon you by personal service or by ce (2) If you do not file a complaint within this (3) The date of service of this rule if as Date: 20 1UDGMENT OF NON P MAY BE ENTERED AGAINST YOU. by mail is the date of the mailing. Justice. IF of service or Deputy YOU MUST INCLUDE Y OF THE NOTICE OF JUDGMENT/TRANSCRIPT FORM IS NOTICE Or APPEAL. AOPC 312-02 WHITE -COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE YELLOW - APPELLANTS COPY PINK -COPY TO BE SERVED ON APPELLEE GOLD -COPY TO BE SERVED ON DISTRICT JUSTICE O THE Pf?QTHONO T; 2012 JUL 16 AM 11. 4 6 ?i Cu ? AND COUNT a,4 %163. st pa ?dbh PROOF OF SERVICE OF NOTICE OF APPEAL ANl1 RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ss AFFIDAVIT. I hereby (swear) (affirm) that I served ? a copy of the Notice of Appeal, Common Pleas upon the District Justice designated therein on (date of service) 20 , ? by personal service ? by (certified) (registered) mail. sender's receipt attached hereto. sender's receipt attached hereto, and upon the appellee, (name) .20 ? by personal service (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF , 20 signature of official before whom affidavit was made Title of official ? by (certified) (registered) mail, , on Signature of affiant My commission expires on 20 THE PR0TH0fj(J f/ ZD 12 JUL 16 AM 11: 46 CUMkRLAND PEWS YLVANiA a" 16 1 b3- P8 Cash L4 0-) 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 of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF : 5s AFFIDAVIT: I hereby (swear) (affirm) that i served ? a copy of the Notice of Appeal. Common Pleas . upon the District Justice designated therein on (date of service) 20 , ? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) on 20 ? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF .20 Signature of affiant Signature of official before whom affidavit was made True of official My commission expires on 20 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Notice of Judgment/Transcript Civil Case Mag. Dist. No: MDJ-09-2-02 MDJ Name: Honorable Jessica Brewbaker Address: 18 North Hanover Street, Suite 106 Carlisle, PA 17013 Telephone: 717-240-6564 Gordon Luce 1 West Penn Street Apt 102 Carlisle, PA 17013 Disposition Summary Docket No Plaintiff Defendant MJ-09202-CV-0000063-2012 Gordon Luce Goin Postal Gordon Luce V. Goin Postal Docket No: MJ-09202-CV-0000063-2012 Case Filed: 3/28/2012 Disposition Disposition Date Judgment for Defendant 06/14/2012 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 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 MAGISTERIAL DISTRICT JUDGES, 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 MAGISTERIAL DISTRICT JUDGE. 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 MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. 4-*A t I 4 ?N Date Magisterial District Judge Jessica Brewbaker I certify that this is a true an correct copy o the record o the proceedings containing the judgment. Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed: 06/15/2012 8:15:58AM Opinion: Gordon Luce v. Goin Postal The testimony and the exhibits provided at the hearing on June 13, 2012 indicated that Mr. Luce had paid Goin Postal for a new computer and a Windows 7 upgrade. In sum, the computer did not work for Mr. Luce, and he sued Goin Postal for the money that he had paid to them. It appears to the Court, however, that Goin Postal was willing to stand by its work, and to rectify any problems, but Mr. Luce became frustrated and hired someone on the outside (who was not available to testify in Court). Without an expert to testify, and with Mr. Luce himself not sure what had happened with the computer, the Court is unable to find that Goin Postal violated any duty in the work it did for Mr. Luce. As a result of these findings, Judgment is for the Defendant in the amount of $0. It is so ORDERED. ? j Z? (Seal) ';'N\ ica E. Brewbaker, Esq. Date: \`? L- Magisterial District Judge ,s Gordon Luce V. Goin Postal Docket No.: MJ-09202-CV-0000063-2012 Participant List Plaintiff(s) Gordon Luce 1 West Penn Street Apt 102 Carlisle, PA 17013 Defendant(s) Goin Postal 247 S Spring Garden St Carlisle, PA 17013 MDJS 315 Page 2 of 2 Printed: 06/15/2012 8:15:58AM OF THE PROTHONO 1AW11 29.12 JUL 25 AM 10: 41 CU FEWYLVANMRLAND COUNTY 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 of the notice of appeal. Check COMMONWEALTH OF PENNSYLVANIA COUNTY OF ((t. ?W.r/ d ,, _Q ; ss AFFIDAVIT: I hereby (swear) (affirm) that I served a a copy of the Notice of Appeal, Common Pleas ->??u ,, upon the District Justice designated thi (date of service) , 20 (z by personal service ? by (certified) (register sender's receipt a the hereto, and upon the appellee, (name) pt* 9-4 t iff)G(n- JJA .1 4j _, 20__L2,_ ® by personal service ? by (certified) (registered) m sen er's eceipt attached hereto. (SWORN I D A SUBSCRIBED BEFORE ME THIS D F 20. Sign a of officia e% .who idavit was made N / )1W1 I Title of official 1 ( l My commission expires on `1 ?T 201,. E Am Nar?nSE d?Y,3 OAHOIE A. NEIL, Notary Public Wro Of Oaftle, Cumberland County My OOnlmlabn Expires f!ovember 24, 2018 boxes.) on mail of affiant COURT of COMMON PLEAS Judlclsi District, County Of NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT CON PLEAS No.r NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the district Justices on the date and in the case referenced below. AODF49SS OF uwT cm STATE VP CODs DATE OF MIDGMENT IN THE CASE OF ( «. (DtKirIt+YIIQ 41 e-? rill ' DOCKET No. SIGNATtrl 71Pp? This block will be signed ONLY when On notation is required under' Pa. If was Clefmard (see Pa. R.C.P.D.J. No. 1004(6) in action R.C.P.D.J. No. 111088. This Notice of Appeal, when received by the District Justice, will Operate as a before a District Justice, A COMPLAINT MUST 8E FILED 41hin twenty SUPERSEDERS to the judgment for possession in this case. \ (20) days a flag the"NOPCE 'of APPEAL. SOWN 01PMdorwlry-D00* P Ct IRE' TO ENTER RILE TO FILE COMPLAINT AND RULE TO (This of form to be used'a? L when ap? Iant was DEFENDANT (fee Pe.R.C.P.D.J. No.1Q action bokm Disbict Justice, IF NOT USED, from copy of notice of appeal to be served upon appellee '" PRAECIPE: To Pro tary Enter rule u appeN(s). we carne ?C appeal I l f s __ s (Common Pleas No. vrnthin twenty (20) d + , spnr of ntte tSr,sliffei : jt rn?nt of non*os. RULE: To (s) ... VOL 1 (1) You are notiredpas a rule is hereby entered to file nt in this appeal within twenty (20) days after the date Of service of this rule upon you by pprwml service M by mad. ?- (2) If you do not file a complaint within this ' JUDGMENT OF NON P Y BE ENTERED AGAINST YOU. (3), Thy df?qo?of this rule if s by mail is the date of the mailing. Dqfe; f 'l.;l°„ f`' otPro?!wnaruya>?ty h .J Y OF THE NOTICE OF ,lMTfI RANSCRIPT FORM YIT NOTICE OF APPEAL. 7 17 AOPC 31Z-e7 i j`, WHITE - COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE YELLOW - APPELLANTS COPY e to MnV TA oc crIuM 1 nN ADDCi I Cr r-nt n - rnov Tn jW 4f'RVFn nN nMTRK'T ItATICE awdm Lam pleas at. Apt, 102 Ur OA 17013-2353 my Oercmomt oerwplairrt for reaso?w br? siMe aseeseed set?iens M IN of SslIMO back whaCs ofe M fas oft riyht'riy was woe !mow as /saws of ill k 08 -- 1 My cash for ncoWd"as 1s commo e 1 - "- law user p mpg iybt low stoker owe in trawwctlws for s mpok Sao or wor raboN brawl' wow eeaPr•n eNker owe this appeal m o a Laws thst were newt oew edrMlh by the JOi7M JEMWA HlRL?wHlA'®t NOR 4Cm rcwAL M ways F 9-- l¦? FAIR OEWT COi:LH:CTION !'RACTICEA NOR brws resrded ! AMs IROTECTION W NOR MONOWC AN>H " c Pow C-- LAWS , REOASD® AS LEaAt., TRAIIACTIEp C V.DIWO s WHAT SO XVM FROM NOTHM PotgHi Ili WHAAT xm C_- TO A CAM OF CAM MONEY TAH FROM US FOR can r` N ? ?' EXd1AM E FOR A MLOWN U! JUNI OUT ©OMlUv= ...,.,. CS1 vn THIS APPEAL CASE AMOUNTS TO CRIMWAL W110 MM ? Z5 401I'fTEO A4MWq ME PERSONALLY AS lERS??NAI REASOHHIi . FOR AHlIIS ME AM TANWG Mr MOMV FOR WWTO HIR AT ALL M w *T OF A OOOO USALLY HHAOFE mrAL AT ALL- lima aM[ eased Xmb d tnwwe \ 1 WRA Pam Street, / 102 Grtttk, PA 17013.2355 i?r Ieeoe ?wtnies for 0eerr Iitiy __ ewer Brit Ile smna alm -tits Ia grin The Cask Mousey HMs Ar tl bW ksld used are pralerty hehrwSs at Ike Ferwdeliew ListlwOs skoww M !ke AMa Adifw LaMis i or Wie are just l -- l s IbM talcs cane sf Ike Firwdmllsws bMMwyser 9 -P - 9 - l a or rwwsy as" bald. thuss !e'er dser.e? am of Cm? ? peewee" "UNIMS awd CewrwsraW Tirade Law l4""m as 'a "Of orr owwed ?'M? hss cwt rood and etherw4e NIaHl? OR l?SONAL OR !lRSO " CONTACT AEONS THE FAIR DEBT COLLECTION PRACTICES ACT VIOLATIONS INCLUDES FOLLOWING SUBTITLES OF Illegal INVOLVEMENT DONE : By following listed subtitles # 806 SUBTITLE : HARRASSMENT & ABUSE (15 use 1692d) # 807 subtitle false or misleading representations ( 15 USC 1692 e) # 808 subtitle : unfair practices ( 15 1692 f ) # 809 subtitle : Validation of Debts ( 15 USC 1692 g ) # 810 subtitle : Multiple Debts ( 15 USC 1692 h ) # 811 subtitle : Legal Actions by Debt Collections ( 15 USC 16921) # 813 subtitle : civil liability ( 15 USC 1692k) # 814 subtile : Administrative Enforcement ( 15USC 16921) Older People's Protection Law , Against , Me under Civil Abuse LAW terms, enhanced upon Illegally , Provoked into being, ILLEGASLLY USED , it can there otherwise purchased or reduced by utilizing, legal agreements negotiated or established by court decisions AS purposes A ..Lien use was already established , for, protective abuse now for several years prior or since the Foundation was formed in January 1998 , for protection to personal things,items , as well as company owed money or items such as computers and other property too ..................................... In regards to the referred to computer that goin Postal claims to have been . 1 built new. blew up when it was set up and plugged in immediatediy it hd to be junked it was totally ruined inhibiting casts of being ideas of installing things as devices ,software and or strange things Inside the computer declared as being new bust had old software and many features in it that were in the old computer was otherwise paid for him to build a new computer entirly besides no warrenty was issued as new computers usually have and usuualiy are set up brand new by computer sales outfits but this was not the case with goin Potal at all ..... we were forced as all computer equipment was owned by the foundations created and weredesignateduse for foundation use only , there fore had to go buy a brand new computer, else where, other than from goin postal , which it caused full rejection entirely from his inferior actions taken with out approval the concerns of intimidation and very much of concets of being very victimizing with threats of course enhanced using thellsted complaint laws in this court case of appeal forms entered . As Lien issues, concerned protective protections made since January 1st 1998 the Luce Foundation For Better Living along with enhand dupon Va. Land trust named Better living the America way became formed Oct 2010 as actions to make better wys for any and usal public concerns which were not designed for what has occurred , because the consequence of over- running me personally or my attorneys or other trustee staff members with variating misinterpretations of court laws, or protection of saftety concerned laws by misusing I abusive wayshe took in meddling in legal case assumptions, a going on for no good Justice reasons, to actuate waysto beat us out of money requests to get as were made for the return of the money owed us as a total amount specified as actual costs only of $1884.00 ..................................... BUT THe other Infractions of Heath n ifare tatctics omitted by his inferlating ways of actions taken besides those of honesty or nor non Business negotiating we added on more costs which of course is showing as lein costs and health damging ensued problems 2 especially recognised asw" hearing or other handicapped measueres against physicaa well being as well as pschological types too as we have shown to be there by involb¦ved also . IT as of course price wise can be fully adkjust by proper dulings or negotating terms which Mr. Goin Postal was never at all obligated at all to NEGOTIATE .. But CAN BE REDUCED OFTEN , Depending on what attitudes are taken but, not so , that neglect & negotiating of very extreme Nonsatisfatory NON AUTHORIZED service , that physical or economic health damages are insufficently, prominently, og drastic incuurred or out of proportionment ways ,caused as non business infractionsof very peculiar unlawful actions taken as abusive methods unacustomed to any thing to do with building or repairing computers , we have used a Lien Status, already Automaticaal is placed where by we purchase buyor sell anything at for protection for us in all Busess transactions regardless Invoked to cover, what is concerned to be a value , which is concerned , to cover what, damages ,and added on , costs invoked other than is normal usual ways of doing normal business with him .. He has incited, upon us , all , very much actions taken , we had never expected , we got .. That is far from any copyight Law , of legal concerns , or not as Commercial Trade Laws concens , either for what supposed, to be a Business of law ful expectations Mr Goin Postal is not at all consistent there for, at all in Ming Businees further, ever again with him , for the fact we are coyright covered personally aswell as Business wise along as also INSURED COVERAGES TO ALL HOUSED EQUIPMENT ENTIRELY BY OUR INSUANCE COMPANY ,HORACE MANN. FOR A BLOWN UP JUNKED COMPUTER NO LESS BESIDES ..... M d 6? ,77? f 02/14/2012 92000 PY number 37 -001804954 Property Insurance AUM A041 FRONK. DONALD B FRONK INS A FIN SERY 5236 E TRINDLE RD MECHANICSBURG, PA 17050 LUCE. GORDON E , OrtYe 03/16/201 1NN ST APT 102 CARLISLE. PA 17013-2353 d~ $ 37. )0 T $ 87. )0 Horace Mann Edwawd Fmmcw sabetiow THIS IS TO NOTIFY YOU THAT THE AMOUNT SHOWN IS DUE ON 03/16/2012. PLEASE REMIT THE FULL AMOUNT DUE PROMPTLY SO THAT WE CAN PROVIDE YOU VITH CONTINUOUS PRO TECTION TO 12/16/2012. IF PAYMENT HAS ALREADY BEEN SENT. PLEASE DISREGARD THIS NOTICE . Ow twowOe d ww? am so prtmtmato va be pMYw go b w s & Adds *Mar n?orr)r=W jsftN* al w j"fb . dldonaAly Plws eMroA aad n riie bdlom paltan tMr1s you CAr * D PUM 1?et/ed o not arpba w LUCE. GORDON E 8 LUCE. 6 L Wyk UWM 1 M PENN ST APT 102 37-001804954 CARLISLE, PA 17013-2353 w?rw?r?ouodwmwdwanvw Pi yaw omo b 4 dada b yw Nast Do nat ad owh.'mw* y= Mr A e yw d%Kk or matey w* prA* to PIM1101001 dOm 6W 03/16/2012 Horace Mann Insurance Company P 0 Box 19464 art it S 37 TilRi?r 00 E Springfield, IL. 62794-9464 . .Y _, . 1A, kiz, PR 370410 0001804954 07012012 00008700 0000370000000 3 ,/L qI ms Ww b m ?ftmaswed *an" mil li I w ?""'"m.r.r .r6 or.ir...iNr.. w :? ONMIOWSAL aOarpaarbi? yi--d wa ?r OM ?r va Wis, ow sawadr"r?raa?tt?+itrrs?td?it„ra irM?iil4arAim.ar p?+i?rftw too,r~aft "m? ilt?wwr ?r ?Mli?r. +? M?M?r t? wM @o ft* ft* at W ip*ftor MMr??irryi>?i um ~ Mi¦Ilt of ?11? aM Ok ?? Oat it! rilliir It l a Od f r b {? hill /irir? Ar a• adr?ii abw? ri a1 i arr? -'Mir!`R?stistipafrl?rluhesrrs.... _ _ ___arrte?a? --- T?iaW tiMiMls a \Iorritl C?Amffft" tips sa arm Oar ?Ulrr? an bwaMaR No ar am 6&m" we ase tills prehetiow far ~ owft n for prebeliew to ow equipwset aar saoaay a d m Ma business Mke a eertlRsd peteat t to prataet ow best i.ts>a?t whb 2m ~ ;~, I~t' = ,i )M'~'I -N P' F/1S OF CUME3ERLAND COUNTY, PENNSYI Vl1Nll1 lV'L ~~CTION-~AbV GORDON LUCE , 1 WEST PENN STREET, CARLISLE, PA. 17013 No. 124401 CIVIL 7crn~~~ GOIN POSTAL a. JESSICA BREWBAKER ,CARLISLE, PA. 17013 TITLE-WHAT YOLf ARE`FILWG COMPLAINT ACTION DETAILS TO COMPUTER FRAUD !n ~hE ~r~ ~~ ~,~} ~~ ac?i~~n ;nee will need the plaintiff's name an~~ ~~{cr~~~,, ~ , eli i `he deterd~~nt's name and address. the film ~i~:i°~t ., ~,> ~~ -,r ;:>ri~;in~3~ signature. GORDON LklCIE' 1 WEST PENN STREET tt tCt2 C ARLI SLE,PA. 1701:3-2333 ~,IIOLATION TO T#HiF FAIR DEBT COLLECTION tAW PRA+CTICE:i At"'1' T+tfPIC HERE !>~ THIS TITITLED COMPLAINT ISSUANCE , tS OIF AVERY UNUSAL Ir1ATURE, YO INCLUDE AS INVALID DEBT CI~I.LECTING INCLUDIN~6 ELF»'~LE~D BANK FUN0ti6 AMID ALL BE4'AUSE, OF, """" THE FAIR CIE'BT COLLECTION PF'JICTICES ACT °"'" VIOLATION ttF r:..,AW4 ,.. thIVOL1/ED , WITH THE THEORY' A COMPUTER TAKEN, INTO MR. COIN POSTAL ,i'Ir REPAIR , €;)R MQSTLY TO HAVE BEEN , f'UL01NG A NEW COMPUTER, ALT01.;~THER .3T 8Et,AM£ A CC>NTiGENT FACT, """' GOIN PI?:'sTAL""" SIGNED AS A NOTARY PUBfi«IC THE DOCUMENTS OF HAVING A M[LLION DOLLAR LkEN PLACED , ONTHE COMPUTER, AS WE DO PkACI~ l,itPNS I;tSUALLY, FOit NORMAL REAS01~i ,ON ALL OUR EQIItPMEMT FOR LIEN SUBJEC'If ioNr , TO COLLECT AS OI1R PROTECTION [NONE FOR BUSINESS REASONS , AM`M'MIAY ... ,TO PNRtATEf1.;,T 1.l5 B`d' FILING LIE1V5 ,AGAINST AL.L EQUiPMWENT AS WELL AS HOME OR FURNISHINR".5 ~Tt , USED, SUCHH AS, WOULD BE , iWCLUDED ,WITH THE COMPUTER HE, WORKED t1NhI,. ~iE ACTUALLY RUINED FOR UNKi1lOMlIN REASONS NO O!NE CAN FIGURE OUT,WHY` , ~1;ti HIS C1IUSED,ONLY , UtNOiONM REASI]NS ,WHICH MADE 1'T BLENIYt1P, BEI:AUSE ,HE WA:S PUTTING tN STUFF A5 '°""'TAMPERINC, FORMS ""° , ILLEGAL.ILY ,UNAUTHORIZED ,EN'YIRE#.'t' FROM US OR MEOR AWtYON ELSE , INSIDE, THAT COMPUTEER UINAUTHOR,IZED, TOT'AI..L ~" ,I3Y §US ,E:NTIRELY RE.IECTED THRU OU'T ..... INSTEAD Qi~ PLAINL.Y GIVING ME OR MY, r,)tg OiAR MONEY BACK WHICH AS A TRUSTEE, ONLY, TO THE MONEY , THAT WAS OWNECr, ENTIRELY !3Y BOTH THic IRREVOCABLE ,LAND TRUST REGISTERED IN VA. STATE: ,AND i..C;tCA1 P,A 'SPATE TRUST!'s ._.., HE ANTICPILTED , 1N DOING AWAY , WITH THE COMPUTER : 'I!'~I;1 #'11T ME OUT' OF BUSIIt1ESS FOR UMiOiOIIMI~f REASONS T22't?? AS iT USED FOR HEALTH RE:t:OVERY REASONS CAUSING tN)iGE DISTRESS AMOUNTS RELATING TO BE AS ik'IUCH AS ONE IE::lIAtIRPLED NitISPiTAL BILL. OF OVER 1fs,000,.011 WAS OR HAS (NEVER KNOWN AS YET WHtI' „ANYOWE IJiITHE1R SANE MIND WOULD CAUSE SUCH ILLFATED !DAMAGES AS THIS ??T?? "'!I-IE: k.IENS AMOUNT TO A iMILLION DOLLAR:1, EACH AND EVERY PIECE OF THINGS, WE OWhI, p;!z I.OR OUR PROTECTIrDN AGAINST SUCHH ABUSE, AS HE GAVE , THi5 PARTICULAR COMPtI"1°ER WAS USED FOR GATt~RtNG MEDICAL'Nl:LP IN tMPROVMG MY HEALTH, AS WELL A5 OTVItER4 fi; MY POWER OF ATTORNEY WAS THERi~ THAT DAY AND COUlLD HAVE BEEN ASKED TO VEF;IFY THESE L;ONDITiOMS , #fOTHING AT 111.1.. iN11S CONSIDERED ONE HEARING NOII'HING FROM ~.IS LiOTN .4T '.°Ir1AT HEARING ....... ALSO, USED FOR RELIGIOUS (BEING A OIDCTOR OF DlVfiNtl'°Tb' N,'EASONS ANC( FOUNDATION , AS WELL , AS TAX FILING USES....... HE ALLOWEI:1 E'1 T'E:~ CAIISE ENDANGERMENT TO US ,A,S WELL AS OTHER5 iIN THE BUILDING ,WHERE WE ICHt, ~ LIVE il~# ANO tOR ,TO , BLOW UP, BtECAUSE, YES INDEED NO PARTITION, WAS SIJPPI.IEC1 BETWEEN THIE WINDOWS 7 ,AINCI WINDOWS VISTA, /-S ITS REOUIitED YYHEN LOADINf~ ltrf "HOSE TWO PROGRAMS , TOGETI/ER .. HE WAS INSTRUCTED TO REMOVE WINDONIw;,, ';di5'F'A FRtIMTHAT COMPUTER EXPLtt:iTiEL.Y, 8Y ME AS MY OitDERS WERE GIVEN ... T FI~!1l1~ ,°!', iN Il° , WHEN IT MYAS PURCHASED PFtEV10SLY, FROM STAPLES 3-4 YEARS PRIOR. ,., ... sale, Il°, 9CTUAL.L.Y WA5 1~10T A NEk`"l.Y Bi.![I.T COMPUTER,A5 , HE SAID OR E:LAIMED IT WA!5. sv1R AS I.DNINDICATIED AS NO PROOF 01= ONE THING STATED BY COIN POSTAL'S CLAIM HfA'a '~ F''7" ENDICATED NOR SHOWN PROOF BE`POND OUR TERM itEQUESTS OR ItEQUtRED ORCtERS r;1VEN F18R WHAT WE DAMANDEO AS OIRDERED ....«... BY MFI. COIN POSTAL, O BUILD 9T er1Rx ,. WIHEN HE CLAIMED HE BUILT A VIEW COMPUTER, IN THE SMALL CILAiMS COURT $~~ ~"AM':PERING WITtI, AND PUTTING,. UN~EOYiFlN UNAUTHORIZED THING:i ,PARTS CI.AiME:D tIY FIIM tIVTHE COMPI,ITER, HE HAD TO L.IE ABOUT, 7'HE ATTEMPT TO KEEP , TH£ Iri..'I_!1-£~/~,N L'1~ EMBEZZLED MONEY, FROM ME ... THEN JESSICA BREWBAKER ALLOWED AM INVALID DEB1' AMOUNT IDF COST, TO BE2 PLACED AGAINST IME,THE PLAINTIFF COMPLAINING WHICH SHE REFUSED Tt) HEAR AT ALL ,...... AS ,ALL , MALCIIOUS TRANSAt:T10NS DONE ON THE RE.lECTED BUILT OR REPAIRED COMPUTER , REf~ERRED TO, A5 CLAIMED Blr MR.GOIN POSTAL, OR INNER ATTACHED IDOCOCUMENT SHOWIN AS ONE BUILT NEW, AND FOR , HAVING NO HOUIRLY WORK ,OR N~DFt RATE PER HOUR, PROOF NOR CHARGED AS E::HARGED , ~'O ONLY AS C!-SH REGISTER St.tP3 ,ONLY, WITH NO WAY OF KNCIWING ,WHAT t'HE MONEY WA:S SPENT FOR ??? AT ALL .....,,. NOR AMOUNT OF TAX, CHARGED, NOR INDICATION OF PROOF THAT THE EMBEZZLED BANIK MONEY WAS APPLIED, AS PRCIOF , TO ANY I;"OMPUTER BUILDING, OR NOR REPAIR, NOR iNARRENTY , WHAT' SO EVER; AT ,ALL . THIS WAS QUITE WELL lMPRESSEeD AS MONEY A8 STOLEN MONEY, FROM MY CREDIT CARD PAYMENTS, OR CHEECKS WRiTTEiN ON MY BANK , SUPPOSEDLY HA1/LNG TO USE FOR BOTH BUSINESS AND PERSONAL REA:50NS , OF ACCQUINT NUMBER 24949-0, . OR W)TIiDRAWN ON M'M' CREDIT ~~ARD, AS WITHDRAWALS, HAVINta INVALID REASONS , FULL'If ADtIRESSED ,AND CHARGED , TO ME, AND NOWT US , WITH NO PROOF AT ALL WHAT FOR , ALONG WITH A JUDGEMENT 4SSdGNED,AS OWLY PARTIAL COSTS LISTED , TO GET A COMPUTER , TO WORK PRt:>PERLIf', I ~iAD 'TO BUY, A BRAND NEW ONE, FROM OFFICE MAX ..... iT WAS BECAUSE THE ONE, HE, ~sO1N POSTAL , CLAIMS WAS BRAND NEW BLEW UP, LIKE AS IF A t30MB , HAD BEEN PLACED INSIDE IT, AND CAUSED THE COMPUTER TO HAVE , TO BE JUNKED THE ONLY'WAY WE :OULD GET A WORKABLE COMPUTEIR, WAS TO HAVE IT THEM PURCIHASED NEW FNtOM OFFICE MA)( ,AS SHOWN, BY VERIFICAT}Ol~i, OF PROOF OF PIURCHASE SLIP SHOWN FOR EXHIBIY , aNITIi THEIR NAME ON IT, FOR EXHIBIT PURPOSES , AND THAT, IT WAS NOT REB4UIIl..T, NOR BUILT TO EXPLODE , 1-S MR GOIN POTS~TAL CLAIMED , IT WAS ,, !">~ WAS REQUESTED ,TO HINT , AND BY !./-W SUIT FILED , TO GET OUR MONE'lY BACK; 8'~ECAUSE OF REJECTION ,FOR HAVING, NO COMPUTER AT ALL, AS A NONWORKABLE, SERVICE GIVEiN , BY MR COIN PI)STAL'S CLAIMED ,FAILED SERVICE , GOIN POSTAL, PROVED TO BE AL ABOUT ,NOTHING FOR OUR MONY AT ALL....,.. , AND WE GO"f A TOTAL REJECTION , OF 7HE RETURN Oi' t1UR MONEY , WHIt:H JESSICA BREWBAKER REFUSED, 'TO HEAR ANY Pl1RT, OF MY ,OR ~: ~DUR SIDE OF THE :STORY, AT ALL. ,AND ASSIGNED F'HE .JUDGMENT , TO ME WITH INO RELIEF AT ALL , 1=ROM HAVING MONEY STOLEN ,OR 1=MBEZZELED, PROM QUR ACCOUWT ..SO FAR, ITS NOT YET BEEN REPORTED, Tt) THE BANK A;5 STOLEN MONEY, AS FOR , WO SERVICE GIVEN„ FROM MR.GOIN POSTAL , ~CIR THEY WO~IlLD BE CHARGING HIM, BY LAVN TO RETURN THAT MONEY TAKEN FROM MY AiI:COUT AS STLEN MONEY { GOIN POSTAL. } AS ITS NOW IN COURT APPEAL FORM, TO CORRECT , 'WHAT"S BEEN DONNE, WRONG . AND HOPEFULLY WILL SE HEARD POSSIBLY ? 1=Y.IR !PROPER SETTLEMENT, TO THE CASE ,Tt11:1 TIME WITHOUT RESULTING F/IILURES EXPL[,IITFD AS EXTOR'f10N MONEY THIS'CtME ........ l-HIS I=S MY COMPt.A1NT FILED, IN REPLACEMENT TO THE OTHER OR FIRST COMPt.JAaN'~" RELEASED EARLIER , IN ACCORDANCE REQUEST BY MY ATTORNEY iNORKiNG. THE ~IaASE WITH ME, AS MY ATTOIRNEiY LOVE, OF WrELCH ,GOLD AND SEiGEL AUTHORED AS A DRAFT, 8Y GORD~OIN LUCE WITH MY C~DPYRIGHT' ON IT , IN ACCORDANCE TO ATTORRNEY LOVES REQUEST TO DO . AI~cuS~ '+a ,~a~a ~', ~ d C~anlrx ~M1(t~pad or fq~q pi+fnied} Si~raiu~e of Qranlnr #~t 5T/~TE OF ~a+ Per~yi~tria ~_ COUNTY OF ..._ t,txKhetfancf S~^~~__ _ ~; ~~ _ ~.~~.'..~._,~~ - b6brB ~r r .ts ~ ~ _ .n .~_...a_ ~ If11~1~ f1~'Ele atld ~ tJf the P aPP __..._.~ M~ t~+e'~ b me on ibasit of cwt er+denoe b be the perst~(s~ wtase~ name(s) isfane subar~tbed b ~~ w~+in ins~ur~t and ardo~ow b me .tl~ ~~ eo~eexiied the same Et hisfier~Mheir wed ca~aiy~'bs}, and- triad by l~s+~nl~eir sne(sj cn the ~ the p~er~s~on(s}, a~ be erfi`ty uhpa~n taeta~tf ~ ~~ r ~~ ~ ~~~ ~E K. I aertxfp tutdet PENALTY OF PERJURY aoJCr tie lsrn~s of ttsc Ststc of ~_ _ _~_ that ~ ~ P~ 31 eac sEd c~cx. my ~cancf ~dd :~uti. t~ Y swwto~or w ~'~~~ ~.. oet s, fN1 IEXAMpILE EXHfIBIT` of ~o~N ~-asT~i.s ~a~tl11AEN'~'S FNE S~~NED ~'~i~t ~17"!',4.'CIN'~~t~'''~~f f ""'~~' ".,~Ti3`MT'~"1~' ~CAI~' 1Ca01Yr~ar'.rl~l~•rtr rCad rn,•"'N'4 Cal S'=~.~. sn -1.1-:. _. aA. tbrer d ~ - . + Swri. k is-5e@y C`9aarflSr>a 1dY,4 trrtllClr~K{y EKM',?:'. e-.aa~~.~~t~r ~e[il etll i!rfe. en t-~ 9Btt !alSlHrre rasa h+eure OEiiral vakres. up an ~'°rY 9rrtA ~ ~, thAeieN !lien Ue~eNr '~>I~et ~.sirr r MJi<llet 1'~iISQ.~OerX~C.Ai4id) .a! tag 6Ne 9dMGf +x +_+•-. nrtrr~y ~ ]:!r ,Felt!, fer t1 a fa9~ an.+e al' ,.aira n+wd Wrvtia e+!rtuPy tlrfady e-rryls gs sr+rrrrsssacs_ n,ra.• aoewsls, .!dlcraeutler!; y9AS, Afs:l4s. ~~la^I 't:rEF{ryl~ .rasa~e caatly aM aanwerally. ~ trr~Ytau seEtalle~ iSao;Me...9 1~yrty . cerraSt ImalreS ielZfe^Yl ae a ~c~s~ al ~:i mteeme rf/ d4el>ts et !di!!tS lereidl! +.r-.,: any tee! ai~> ~piatee! sgaine t ~trrs s resaaaai tra>RitAGn.~ :a+A awrSSnblRa OI l~rmort ilre aandYri,a ,<, !Art b>sed es Lt~et S:xueet i aK y r ocee+ent!: eA !6~r ceelaia ?begs r~s xeeas of Waeaor, as sac reair .n tnr= agadiee Ga,e~a al Setae es AcyarreAert f>f sae eases dae4 ane a+acrJfieg arareYraK card Oeseer tarlerrlw+r~. !o lerrre a t av Tralcwdiog xb+l ar aeacaa lea,srisaal irec~ .p, .rut aear>max eatt~ enM eoeeuf9wA, ~ the t1M`t'HS 4Tt1"E5~ a+r1 ai C1M~rs xnea ' r-rrr~ x •>€yrw°, *s >r ;~eak~~ ++- rsi ~n~.~r.m~++, ~•x ,. ~0~1tf1r/A~1-tLH,s raltr,. aea rteNw M•+. . rralp9':'1e7d t'ra awed tca,scs ~ weeeeo des r, Nre ~rrx+rr'e: ar trausar ~~owle~°ac rise. ,,~: txrc aatctery nl vrc aIl~i'r~^.: Gaatereraet SewalM APer eu>rt, Beer ; m rrcari; araiaece In sna,exf Party 9,an ar~uim~~ eanetielcee !ry i,rerrr ~M its Pane::, e+r a as aaR arsaler as aenr~ne~.~e: tnasts, m noes orors:mr~ aeec~ beer laaaf• eelera~:ap rs '~setrrsr akd .~eraieatalrae~ d11 sre tBiTEW ST/~'ItES C- ItS s<,retl+rsata~rs agerres, a- ,;litlcuiw 1>tineu et in .ray lase t=t see tJl91f~}51A'dS. sse lfre ; N see parn,ae d Yre aleat:Md sraCatyr ! gr+eernAt SaeaarAA Paty V :elrees>ssaA Ise sus sett tufe.4 diorrr 'f.rtt aG~ ii :tie a~caeeaa,l 4, e~eie :se giar~ti, ~!"Y.'aM, :; µ+. RAAee,' 9e>b4[ rlMhx 'nM gS~igah[:rr; ^rp'.+~,ra•, !yr flrAtor rr~ he3raA al 3ers ar t ~ p1t QGr~er, aa~ace ire CiGlIC~ 0e' 1I6~~aOp tlr AgpFiea- deed: ~', - tlfecrfarri, arm raldlttaWC ~,: earl/. deler+o. aeed Iro44 ;letwed Parry haralless earn aetl :er~east any .end as tleu+e. ~se:a isersies, tAAaot iw,araseu, a ee,„ mt lf1~g. raleefer men. legal eoaYS, agelraises, pellaletr.~ aw! Bees Pserapn6ly! ~iae,• ~e ie,tcrfed, mr b lw a>rOafge! r- ireeered oy Smred Party. n asmorna'aucr ,east Sro~nrt Pah`'a Prime ~ 9e +~ ~ to teaws n+ iMelenMrres ba Dee~rro'• "'meir3 ~If anaoawl dlee tl~r ~y tae deemed raA care ae~ a put9it'. ~'~i1or td ~„ ma!u~m .eraesoeau Seranayt P:rn•r enaM'rac~psay adrest I]nllas o! .~ mutlie !~ Nreergerc dfl sr+ei paxm!,~ atpsaet ut presnlx ear 1idrrr {tcgrAlr at Weldor. ai of A.cn :. sar,grn ey tt+e ahar#w secumrp. asFeaee:r rp to tiro ~icF~rl9ar aeeceasrt declald ttear!Hr, asee m I>.owkse Cir~hsoc w.ri tue eeWns.., say/ ElamisN. ~ t~:aer: al, as eaerrslnredd,ey; a,csxs.. tar a~errs ~~ e01M DeEeor lttorlo ae,crxeci Party. Semnee c.y*, <~ae ~vrltn ?rar~Aaracr r,»~,,,~, ~eM rV 8'MY4' getOCefe lfr~I'. relaNq Nr 97uCtt tlbRs3 Z ~ ~9kt t1d~ S~La~ t?C a7 ~! 1:faL':. reNer2 ass mt Yte ~ N~ Al >V 5M~ anm ~'~ ~ ~e ~.. A3la' pf6al~ld d-3f S~ /~iUy rae+/ f~ ttrra t"YlAd aott tis retmeat d fti111a1 ~ leafala-tl!r Gdr deir~ega ~y (~dq ^a~le4 araYt:• d acwe~ee b feeAcer Yo,sWw,9c 4eramiM !ha• arrest lr~f: tfll)1• tisp~ raoea+ed by r~ .emsw~e ~e swn.e,e Parery net to nee ~+sm of seed tlMly C-~t mr ~K>~ , O ~ ~t,, ewra ar rmeitr of ranaf:eior, aM m +>b eaw~r:t ri,« ~. tlNl~ ~srrths i ~.~ r~nsgc>Yaur seasa agarattl: its esIl:atrmll Ikbear agrees trf tames H!e Itlerrlt Dore sce erd ai 1Nrr ttna~rr (~'I dey Od-+od for rif emratt dseil m rA grraen +tfe~ 11~ Ilties 9Rltfkx'p l~ ^a9~"r~fL rAnler:r !@b Parbc's el.5tr~n rWreerrew. ~~'ie~e sGM.ae a! 'gK2n~r'::. ~ll ~ 1''X`t~'+, QT' ~,i~P 7 Q t?rn er9rrYfcrc,M Caer+46wei ~ '~~vpW,..,~,G~omar~~>rxai Y~a~; do zr8 laaolner'eY e,t D~,ror ~t~, ar Gelmyl ~. a106 NEt }eP t'Krllit Qt, !y°axeA ° `~! Cn~lllc+r ~! -.w lt1Q 2r7rIw1'8h 01 or+e l~Yrr~s:4? 1k9~lM9- ~ ~ tJnrard StaRt si+eec Arii07es !y~ tAU„dtD,flClti,O~p_pryl ar 9~L9 ie,e saves '11'as rerr rrrt eeisare of tlSr• rrvnm,r:~r.. Hrae.. brdnrtlr,eee 0/ nrt~~eff Iec: Herr ~. ~~ sy enar5nscrsee.~. piera~ take notlee Mfe• Whom, WE 'I'NE BETTEAtLfY'I*IIG OF THE AMERICAN WAY Ali IRRE1ifOCABi,E LAND '~ ~tIU'~T W ~ HAS BEEN INFOIRMED THAT T'ME Ie1CINE1/ BELONGING TA US BY THE WAY HAS BEEN CONFICATEO 8V A DECISION TO ALLOW .link COIN PINJTAL IOdOWLEDGE THAT ME WAS t LIEN PLACED AGiAMIST ALL PROPERTY USED 8Y GORDON LUCE BELOIMCiS TO US A5 'Ct•IIS W ~ Tlt+liST l1AS 07'NERWISE WAYS TO CONFORM THRU SWC}I DOCUMENT<.i AS THESE ANI]~ ~AMI OR J Will. BE COLLECTABLE UNDER AI.I OR ANY" .WDC'aMENT'S MADE REGARDLESS . IIIfE C~~rMrr aNf Egccipmeet tools OR Prsr,pirty oIr rstatex ax real estates PmP~erllex AND are there h'v lrrat+ected OR C>aDING TO PROTECT 'P!!EM BY by this liesn ... IN THIS CA.5E coeldattons exist9. UNDER TKii RES~IlL.TING CONDITIONS LEFT AS CAUSES NOT SPECK 1Ep AS RIGMtTFULLY JU:iTiF1ED ., THERE FI?R EQUAL TO THE DAMAGES OF A:iSESSED EVALLtlq,T'ION MADE ,UPON A t1EARING, DESCR!lkED AS A HEARING BIASED CfMi PERSOINAL FORMS FC)R NKiT HA1liNG MERITS TO THE CASE JUDGED AS THIS CASE WAS ABOUT A ~C N01f 9rRQVIDED .WSTLY SO BY MFI~ R OR WRCPJI= W .GOING POSTAL ANY MORE THAN )T WASS ct!F A916, TIE S FO CONFIRM BY MR LUCE EITHER AND THAT NO REPRESENTATIVES OF OTHERWISE PRCIFESSIONAL PURPQSEi REASONS WERE CLAIMED BY PROFIESSIONAL ACCiLA1M IBT MR CsO1N POSTAL. EITHER AS A LfEC:AL PRESENTIMENT MADE BY THE! HONORABLE JESSIClk BRE:WBAKER OF i8 NORTH HAI~MtOVER STREET , CARLIISLE PA. ,SUITiE 106 , CARILSl,E.lranr f7Qf,-a NJN A CIO~;KET NUMBER MdO!1202-CV-0000063.20•E2 ON 3r?.8120~:g F5 REQUESTEIp '"' 'i~ ,~ ~ ~ ~ _ ~~ l ti ~ .~ Efl65414;8 ~.5 !:~j ~9 aatewa~' Qn$~ t~liK4~f~s-t,i}~1 q~ ~ 1 ea ~ 7~~~a~i~gcs. ~~~ }-v~ f ^ , i)0~ i ?; ~ ~a~ ?'9.99 gales ~ss~. c~.,_ ~ ~3'i~ _~er~~ica ~ ~de "~~`3 '~r a!es NSSUC `>~ ~ t'i.~ ~~26362495d6 5:-u.09 Oata T ~~a~id~t ~~~ .' ~... ~, OT ~l ` A~~ I N~~S ~ $90.OC1'~ ;unlata ~a~)9,96 .x 6 . ~: t~0~ ~~IB .60 "Atr ~8:~i8.56 „hinge ~=I ` »4 `~axP21"~'~~AbE~a e'~~5~~15 ... ,. . =or Max~a~~s~~ anc;.~ _~u~at;cna ., ~cr~~~er~S ., . ~ ~~6E-305-9(,'35 +a?;Ferks .~Ua ~: F ~, , ,f;;e ~~j a~; ;e as .Ei~42616 . ,(1,'<4~,i1Q~U~ ~i~'13~ 9 -04/05/17. ,fl~.Oq,'6 AM :C'~ '72t ~5 : f`' 1 !' '.~~' ~L5 Vii:"Ct?aSe, ' S i ' C f f 1 ~E'.mch "?edhc 'K . ;:Jm afi(" enter _"~ `~ , ~~- r,~ _~ ~~~ ,-e~~ .;ode Jl4i~-()1-4'1:x_ RGER B'~ r~IC~~tE `#-~7~ ~~1~1=I8~~IA;~ F ~~~D_.F g1 ~~tia, ~f~c.emax.~~,rn t-~~ _ F,~ vN~ (;ATE il( !i Tn,i ~,a~-: , c~RFU c~ni ~t T NF' F E t it 23-151 c7A7 ._ - --- ... .. ~ _.... ,.y,1tEh1T A r PKTIE3iT NLNEER ~( AGE AONISSrI")N l1lTl -E.~~:E:: ~:+~R1)tJN t ~- 42?45(}8 f3~_ 'JE>~`2i t., ~ r~~rr ~ r ~ '~ ~_ _ ~ ,_ _ _ .~ -M~- F.1f ~_ -- DIS(.kiAH(iE CMTE CfAY _. .. _. ".'°. .,._ ~__ ~...... y ._ _. __ _- _ _. _.__ ..._..~ ~ _-. _ _ e _,_- _ _. _. ___ _---------.___--__ - Y~r,>K,«~-~s+ r Krr,rnA~ti+NrR _ _ _. _.,.__ _ _. C rxe uisuRAN(.E: CU~APrwv NAweE t t;~WFiAMTCSi '-.>~.t~''~4~~Rqq"t ~... iJ~'~~ ~~:yy k~wE ~.' .'. ,~p ~. ay.~ ::~~~. ~v.; t ~:-'~ jr .~: ~.. _ ~ '. :: # I _ __ _ _,.__....t. .. .... =e~~i7F.+`~ ~, - -` MACHAVT f.~ y r_ASE: RETt)RN THUS PtJRTiON ~N1TN Yt1t1R PAYMEI'~T +(i ~/~~ ~ P+~EOVT ~ __._ _ __ r Ea£S(~t1PTK3hi Qf ~ SEAYICF P7TAL EST CO1fE~E F ST C04ERAGE~ ES. COVERAGE ~ i C CCNERM3E 'Al1ENT ~ E_ c c COOF '~LUaGES MfS (Xl !i0 t (nS r,~ E.10 2 MIS CL1 1x:.3 ,NS O. NO a AM(.lUNT 'OSTFD '*~SP(TAL S €1VK:E ~_~_.__ ~~...__.. .,..~.~_..-..._.... _a_.w_..e... _~~ .._ _._-_._.~.-_-.. .-._...,.__._... ...._....__..~a.-.,.~ ._ ....,.,.-_. _.._...__ ...~._._..____._...- 3UM1'1Y i3* ~.1~~t~6t=S ~%~~xt; M> `a?3AuSk~ t :. ~2 Ott r~;r i t] . ~CTO 5? 1 C% JCi ='1-is4N°#A(' r' 2S0 i?;ic`I'~*. t}`~ 27c4~` fir:: r a7 _p cr ~- =1P~`.af~A~C :srR' ~iJC) ey_,3_i~. C}t~ 23 $c? ~~)t) i :! ~~::~ I tlt; ~~ER'v ~t~c 1~#E~b. pCE 14tlt3 titJ ~~ i 2E~~~ ~.~"~~'I~~t'r Si:~ ~tCy t~E3. Cat) t1R-3 ~:}!:a ..a E"?f T7 k. ~. t'~d.... ~~f~~~ti/ ~~p ~,]~~6. ~~ C~Ci ~.~ G},f ~ e! °~t :~I~;F~rr~r: ~~ ~iaGi"' 450 1 5~i~ vv t ~=.~~~~ t}t~ ~ I i.. t `~ i 4 ~ i rl ']l+~~ . i~~J ~E~~ taS~ ~ ~ ! -F`if ErC`: T~i.} i`~~- rye ~~11,, ~}J 77 ~1(:: "FIE ~^pk=.; ~ ~ 77 i:H~J ~ ' ~` ~~~J f i ~;ts~- ~.~T~~ l~ C 41ARpE`_; 16735 SS ~1.b7?~- ~r k ~~~~~r ~~ ~~ EX-RMp EgS p~s'~~' ~~ -~rtE%iA1 toeErr nto r3 rsizra7 PAnENT NttIMBER REFER ALL OUES'RONiS TO TE•tE _____ --.-d BCtSiNESS OFRCF 4274 ,~~~; ~~~-zt:~± __.__ ._ .~L~.~._._ PLEASE SENO 1'AYME.M1fT TC}: HOLY SPIRR HOSPITAL 543 NORTH 21ST ~'zT~iEET n un a u! i nn. -r ~ i }car ACmITBCIPIAL PgT1ElYT BdtMKi YAV BE ME[:ESSARV FOR Arav t;EY1q(a'ES NOT IaCk4TE~ WEEK T7iS 91LL WAS PREPARF.O JR ff It0..lIRMACIE GA.RRIERS 00 F~qT PAY AIW PART f>F 4ilyol - - rf f i `t 1HONO {A i 2D12 OCT 19 AM 10: 19 l.'U BERLAND COUNTY - -FORM 17s:?,-2 - PENNSYLVANIA Praedpe to Eater ,Hipotnt of Rewi al Upw Deb" (CMpdm) To the Prodwnowy: Eater judgman of revival is favor of pig, -l"Ix L urcod against deftad w 4cr,: sod torte teaaat, ,fiess,rc.? Move to gk an aaswtx or otherwise plod to the writ of revival wWhm twenty days of service thereof, and assess dwmps as follows: Ong" Mevrad) lodgment Casa Imaest from /4 ?blZ (due) S? °'i' f.c r? S how Jloo;,-A S 18s??s_a? S 1y4.48' Md S?-lI= }02W x I a "d, " - ?, , /02 - .41410 1 PROTHONOTAR-e 12 Q`*T 19 AM 10: i 8 FORM 176.19-2 }`UMBERLAND CO to E*w J mat Reviva! Upon Ds PEN'NSYLYANI To tho Prod xwwy: Lwe and Wins' Emer kWgWCM of frvivat in favor of plf??ttiff, - an 4efe dam gain pmw and teffe tee, -0- m - Mmw*- far fof =vice ailffre =vice to tfil file e an answer of athefwise plead to ft writ of revival w&m mw q dop and assess dmwps as follows. OrigirW (Revived) JudVf mt Costs ?i?(date) InUM4 from e tu.1.[?•?_ ?e jl?eil+c Ai ?. sus j gc { 8 cr S -L IA4 ---4& (Ka 37M.I 0e pwbtea x %rA?, ?Y? - David R. Galloway Attorney l.D. 8732b 54 E. Main St. Mechanicsburg, PA 17055 Telephone: 717-697-4650 Counsel for Defendant, Coin Postal IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GORDON LUCE, Plaintiff v. NO. 12-4401 CIVIL ACTION - LAVJ GOIN POSTAL, Defendant ;) r.a ~- c~ 3 r~ rnw d y m c-~ ~ ~ --s Cl) ~ N -<; ~ ~t7 t- .~_ ~~ ~: c ;~, ~ ~+~ ~ _.~ Cp PLAINTIFF'S PETITION TO OPEN AND/OR STRIKE DEFAULT ,TUDGMENT ;._, Y ~, --+ _.~ ~,~ i~ .Q {'r , ?J `~ ~ ---t r~., ~~_ _,~ , c. --r; c ~~ _~ , _ J AND NOW, comes Defendant by and through its attorney, David R. Galloway, Esquire, and petitions this Honorable Court to strike the default judgment entered in favor of Plaintiff entered Ocirober 19, 2012, for the following reasons: 1. The above captioned action is an appeal from Magisterial District Court 09=2-02. 2, Magisterial District Judge Brewbaker entered judgment in favor of Defendant and against Plaintiff on June 14, 2012. 3. This Court's docket reflects Defendant filed an appeal with the Prothonotary's Office on July 16, 2012. 4. Although the docket reflects personal service of the appeal was made by Plaintiff on Defendant and Magisterial District Judge Brewbaker, Defendant was never served. ~. On or about July 25, 2012, the docket reflects Plaintiff filed a document titled "Complaint." 6. The Complaint failed to contain a caption, verification or numbered paragraphs in violation of Pa.R.Civ.P. 1018, 1022 and 1024. i . In addition to the aforementioned deficiencies, Plaintiff failed to attach a notice to defend to the Complaint in violation of Pa.R.Civ.P. 1018.1. 8. Pursuant to Pa.R.Civ.P. 1026, "no pleading need be filed unless the preceding pleading contains a notice to defend...." 9. Plaintiff failed to attach a certificate of service or otherwise indicate he served the Complaint on Defendant pursuant to Pa.R.Civ.P. 440(a)(1). ICN. Plaintiff failed to serve the Complaint on Defendant. 11, Although the docket reflects the filing of what appears to be a 10-day notice pursuant to Pa.R.Civ.P. 237, Defendant denies receiving said notice. 12.. Plaintiff failed to include in said 10-day notice the requisite contact information pursuant to Pa.R.Civ.P. 1018.1(c) and C.C.R.P. 1018.]-l. 13, The docket reflects Plaintiff filed a Praecipe to Enter Judgment of :Revival on or about October 19, 2012. t4. Plaintiff failed to serve or attach a certificate of service. to said praecipe in violation of Pa.R.Civ.P. 440(a)(1). 15. On or about October 19, 2012, the Cumberland County Prothonotary entered a default judgment against Defendant. 16 This Honorable Court may strike a judgment only where a fatal defect in the judgment appears on the face of the record. She Williams v. Wade, 704 a. 2d 132., 134 (Pa.Super 1997) citing U.K. LaSalle, Inc. v. Lawless, bl8 A.2d. 447 (1992). 17 Because the docket does not reflect service of the Complaint or notice under Pa.R.Civ.I'. 1018.1. a fatal defect appears on the face of the record. 18. Because the Complaint does not contain a notice to defend, default .judgment was improperly entered. See Pa.R.Civ.P. 1037(b). i 9. Alternatively., pursuant to Pa.R.Civ.P. 237.3 and governing cave law, this Honorable Court shall open a default judgment if Defendant files its petition within ten (10) days from the entry of judgment and demonstrates a meritorious defense. 20. A copy of Defendant's proposed responsive pleading showing a meritorious defense is attached hereto as Exhibit "~.." WHEREFORE, Plaintiff respectfully requests that this Honorable Court strike the. default judgment entered October 19, 2012, permitting Defendant to file a responsive pleading, including but not limited to preliminary objections, within twenty (20) days. In thc~. alternative, Defendant: respectfully requests that this Honorable Court open the default judgment, thereby allowing Defendant to file the responsive pleading attached hereto. Respectfully submitted, G !/ I David R. Gallow y Attorney LD. 87~ 2b EXHIBIT "A" David R. Galloway Attorney LD. 87326 Counse] for Defendant, Goin Postal 54 E. Main St. Mechanic ,burg, PA 17055 Telephone: 717-b97-4650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GORDOIV~ LUCE, Plaintiff NO. 12-4401 v. CIVIh, ACTION -LAW GOIN POSTAL, Defendant ANSWER TO COMPLAINT WITH NEW MATTER AND NOW, comes Defendant by and through its attorney, David R. Galloway, Esquire, and responds to the Complaint as follows: 1. Because the Complaint contains neither numbered paragraphs nor specific allegations, Defendant is unable to specifically admit or deny the statements contained therein. To the extent a response is necessary and possible, Defendant specifically denies all allegations contained in Plaintiff's Complaint. To the contrary, Plaintiff requested Defendant rebuild Plaintiff's computer and install Windows 7. Defendant properly performed all work related to that rebuild and upgrade. WIIEREFORE, Plaintiff requests that this Honorable Court dismiss Plaintiff's Complaint with prejudice and enter any other such ,relief as this Honorable Court shall deem just and appropriate. NEW MATTER 2. Defendant hereby incorporates paragraph 1, above, as if incorporated in full herein. 3. Plaintiff's Complaint is barred due to the statute of limitations. 4. Plaintiff's Complaint fails to state a cause of action upon which d~elief may be granted. 5. Plaintiff's Complaint is barred from recovery due to the doctrine of unclean hands. 6. Plaintiff's Complaint is barred from recovery due to Defendant's failure to deal in good faith. 7. Plaintiff's Complaint is barred from recovery due to the doctrine of Caches. 8. Plaintiff's Complaint is barred from recovery due to the doctrine of estoppel. 9. At all times, Defendant has acted in good faith. 10. Defendant has not acted in a grossly negligent manner. t I . Any alleged claim for punitive damages is barred or limited by United States and Pennsylvania Constitutions. 12. Defendant's alleged conduct is insufficient to support an award of punitive damages. WHEREFORE, Plaintiff requests that this Honorable Court dismiss Plaintiff's Complaint with prejudice and enter any other such relief as this Honorable Court shall deem just and appropriate. Respectfully Submitted, FULTON FRIEDMAN & GULLACE, LLP ~ ~ ~. --,~ By f-'' , _ _ David R. Gallow~°~' Attorney I.D. #87826 VERIFICATION 1 verify that the facts seC forth in this Answer a~-e true and correct tz~~ tl~i~.~ best of my knowledge, information and belief. I understand that false statements herein are made subject to the. penaltif~~; of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. 1 any authorized to make this verification on bef~Pof Goin Postal. "~ ~ gate: Oct~~~be~r ~ .2012 B Shane Kiimore VERIFICATION 1 ~~~~rify that the facts set forth in this Petition are true and correct to t}~i~x hksr of my knowledge, information and belief. I understand that false statements herein are made ~uL~ject to the pe.naltie~s of l8 Pa.C.S. § 4904, relating to unsworn falsification to authorities. I an~,+ authorized to make this verification on el~lf of Goin P~~~stal. _. Date: Oct+:~~ber 2~ , 2(I 12 ~ ,~_ ___,~_ Shane Kilmore David R. Gaaloway Attorney L1~). 87326 Counsel for Defendant, Coin Postal 54 E. Main St. Mechanicsburg, PA 17055 Telephone: 717-697-4650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA. CORDON ILLICE, Plaintiff NO. 12-4401 v. :CIVIL ACTION -LAW COIN POSTAL, Defendant CERTIFICATE OF SERVICE The; undersigned does hereby certify that a copy the following: 1 } Plaintiff's Petition to Strike and/or Open Default Judgment; and 2) Proposed Order. was served. upon Plaintiff by First Class Mail, Postage Pre-Paid, addressed as follows: Mr. Gordon Luce 1 W. Penn St., Apt. 102 Carlisle, PA 17013 ~~ ~____~-~ ,- .},,_s i -_-. David R. Galloway Attorney LD. 87326 Date: October ,~, 2012 F ,~na, ~ti ~~,,.,~,,, , , ,~>, , . ., o ~~ i' O ®.,,~` t, z ~ nn ~^~ ~1 r ~. ~~ ~ > `~~ - ~ ~ r w Z r A Z J C i ~ ~.~.~+ n z ~ ~• ~~_ r 07 -I n O ; ~, ~ ~ W `~ r ~ D p W v C r ~ ~ w ~ ~ D .: ~ r ~' ~ r n r ' ~ LJl r W i r I o r J W I A ~ i ~ ~ I i H 5 m z m D r n C / O Ci \ 1 ~ ~ m ~' ~. ~ o_,~ ~ ~ ~ =~~ ~ r ~- ~ J ~^ ~ ~ r `~ ,r~~ rr,~-~. Via rC' ~~ ~~ ,~ i N'~~5 ~~~~7~ ~" ~~ ~t~~ ~~ / r '~ l~ -~~`~ ~ ~' ri `" ..--! ~~ r't'e ~ ~ -'~.~ ~ ~ Q . ~ ~` ., ~~, ~ •~~ ,... ~ '~ ~` ~ -b ~. .. ~. 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As r rasaYt of P11!l1, a pafidrr's tes arasdes caaatt get e~naugb bktod-atrd oaryRes+ r~ they arewaleOg . f , k!gsaatry twt be able to teaive ewa~i+blood and -~at aN. teen aAren the nx~s are resting. Nerraplh~ lr~traeot [Ai2.T'F'aRH3TtJl~T O~R Ft's A li'IttfAl6 EMQI~MAI t~lAT~06lip ~E~IFEN TWO PEOPIE TO BENEFf7 rtIERE Fo~ra~-~ts~a~ eE~rtular ClirroYy Proven To Beal Neves. Ktwee Pain RELfEf Tre~eaeet tom. amok sir Plaque ' PVD a a no®reotr dimorder, ubs~ t-mee arer~eso.. Prxple~9rra~t n~rer ret:af P1~ ~ urey twe a t~mry of diabetes, ahrtrrmnl dtolestvd. beoarttls~tse, hi~b Hood ~trt, ~Y titeyge,.sraeldng Q stroke. Svraptaras 81IYxrrrt6 ~ Ctas;ic syatpmras, d PNQ ittcYrlr pteq, aeirnesa hytigetq, 6umioY nr dae~iart er the suedes of yore lemt,talves a tdghs. Comeaoniy, tixaesyeiplotts.staet ~d e~err~se:ae~pawysi~r stresal'deutet d eestli tlrr e~arlP st+r~ of ~4 ~~ ~Y ~ Promo ~- dvefA_ssresa®s tlpri, tasee tx weNooe t~ loe~e- 6mt~e:es. Over tteae, bdrerer, the symptnrtrs m Deese mare q~3P aeel~a'lea:meedree QWET~RES! ANDNDTTO"MI[Q'E i~Pt1116 186Hf9lAFEED R1E61ALtM~NFtR.Sftfi'SE~a~J15 COf~10115 CAE~6 wA`6 TO LOSE UMF3 MOIEY AS 'ID)i~ALT ~f ~f/lT/~16 A IrER~Ii-OIIT OF7iEN =MbMEY VN YYFIAT3 CIr~1NN As zzTLE vu wrr:~eAel.E ~Mr~tls ~~` ~n'rmE n ELRElSA~ ~liTlrlUTlllusFCTta~l :~ cFlrveSF'SAS:k~I ASD AS f~irClkl :~Y o» .» !t[f tlls StiClt ALfol6 .1[S f~i~lC, ID A fig MfiTH CSI OAY XTIE~fPiS TD.~ A' L~6F.R ~ O! EL~'fitlt.tiNl6 A Nfw Ot]~TE6 AND tlAVU16 R flo1A~ED tLT- SOklE7ilffi WIICN.ACOhNiTiER 1i5EliNkSNLfT1ilA~Eb/ISSfIIIiIY/Al LOI~lO1~S~fOR HEALTH 9EWERTS , YMSTElfD t]F l~SOti~. 'f[i Z$[~OM Q3 Elm EAfIIELYFI'1t~ELtl51~tE tIUAAYYFtItIIdLLtiME f~'1717tY i~IACiAI RtllpilTlONPlMMY75F.5 lfii.Y , PERS01ilALLY INSURED FOR S15,000.tlO EACH/ PER lNCIDEN'r -- contettts Iist ::: lnsurartce qualified [ .living tttiN notot~ed as parrer of ~torney tfoctxrteetts 5th Amendment claim EstoppN letter Hearth defined case of near death caries as stroke ateempts i blocked wide f~da Vascular Re:sbucRriag Y~redreals ....in aoY Case noM>ing ~ e:lieap to are the costs evahtadion court be as much or more than two eriirion costs I~revpr the price tag is shown in the estapp~e! k~ttler act beigfar less ? ALL DOCUMENTS ARE ASSIGNED TO SETi7.EMEAtT 6Y ANY OR ALL V~ ARF 1NVOLED MI T!# CASE lT'SSEIf 2 BECTON .212. CONTRAtCTIMG AMtI ~iRAMT AW tI~IORIT'1f; PRf1I~TE PAY RE~~ _ _ TE 1lSE OF F1lI~S...a... pERgONALLY ifitSfaRED FOR ;15,000.00 EAGHp PER 1NGfDENT MIEPOlITIMFi ABUSE ~6L.ECT, OR f_XPL.OfTAT1ON 2no7j.DrnilePne~wansm,~~itQaWe_a~ciaiora3aresEgy ~3 ~ ~+~ haatrdc_ g whey 11c~oe higher'atamE des of d$ahk:pnvets ~ wAhom legal ~>Zi~ae taoued E~eat ~firdtrr atsidaes on.6em t~rair sm af.ahnec g.{oou vomltaed w dte tttim~r nfag~otsaAio ta~i~r ire tlwr atttboritr. aaxdosl tt~ coituae m A®o~ the deeutnmtg SaTahuse Ter tbe.D~P~-m Tl~ ioss.of lik saom~ymd hide, $ walla ~dleaidt ~e`eau® attretmt:s,21 Coooerna>)~ the: ~ofaepoits of faaecial of the e3dterlg ~ ~ orders ao~tioe~l:stedy aA~a it tt~r®ed eke i~tle:_oe: 9zt io 20DD22 Thasmd!i'3iouttd:fb~ the3taad aETeeesd erirers atl~ older pecsoac is pattii:tilvh difficult 7n~eal~c o86rn do tnt npitet shore and'tlle ,~ wham they deli are gsonalls nEe ttaetl to iaok for.sigm of 5mr~etir! eaptanuioa 23 The rteport ir3s~ied aatiaerpaweas that irsess~aatic stilly hefiore elte:evx itamtes<na:~uts ram he deeelopal, uicludmg the foOeNr~ therisk Taeors:ior a the iaoni~es and ioatlstis d Paf. sell taxttias data ao tbnc~idetiee snd pre~ttaMaee d f~taCW cte~lsitltliea_24 Wh;k foeiher imds• of •ti aapece of fineteial ~rtatim u ntYded,'etmtn6er of risk i~totslwemmmodr ci~i1 u i~ag the ldreldrtod that as iatiYii~al tftl~ faN fe'~ M aftase. Ttesc faders Iaalntile eariiMta Isrpfrraaat, etntsWasl or plryeieal ee the ~tettrtar, ttud`a- ---"-~ alcnsuggest that the at~orlp of alarrrss au: pettipie eioac 1D she ~~r- tmiatly &eu~iv'-it~m6ias ~r rarepwm,~8 LcuL2ed steafra~d aaixdotal evidta+e.sMw ~ eies is a autt:t- ~a p-eAfes~ f-aa a~saR fsrrtrtte at t8srarle ~ oy fer that ttetattcr, Rdtrdtary atisretatls d arty tlpe. use d tiAe tiittlteis ere~lt saris atnt/ dsak eardK, of jsint atxe~st h~tarasta, affil eatetnttlea d tiaeds under isues, as wd as ~sioa d Sotcfal Secasily anti pueiaa'tiyan~als, arc fart a few eicawplea of htnc fa®Ir memhus„,~~ or the new'latst friteatf'a d a ionsb- vidfw t:aa:al~aa eN aetaatts willter~t theta tftie faa~at>e d s fidaadary raitt~eusilF /iiseatl :alaad axa `a atisuae d a laersaa'a assets o- five peesae 1~hrtttaft witreut ciettu-aet.'3'1 b[fist does the Sibk sap ahotn our Qostots''shepi~"o t 7Le$aiomsas 5.12 riffs m pwats a hsrdes whey a was thew are m "_~ dtoai: t~ohilitr aiatoeg uc_.'. They an rraponsihk txfare (loll m kad and gmdc :yon 133 7, ''Ohep dtaee v~hn rdc aaer yotn, sad tx sahessoxc, ber they ~.tw fa rmr.scn8s, sa throe uho ti»tu give sea~..Lrt eh®+do se mlla jar tlt~ ttt0t 1Yl~Y ,riff, fir tkat would be tmp~}~:~r !ma. ` In the Spirit-Filled Life Rtb1t of w2t~ Pt~r E~!e~rdsrrveda~s {'aeae<ai.Falimc, ffie foamtes ittider titers pale nwd Ctrr~ ate:itot mh• rn iemem6er;pait dtuirJi feadds (c. 7j 6m are b heed,present Iradeis who are ieapaisibk m desc.~Aar~og flies duties to pra>ntfiea:stviAUi aaaeie~ght m the o~tmn. The o{iedfetiee enmoanded +deeulrs w se>aKOre else's diieixiaits sad sahehaion tneaas _yieit5ng ttee's caotrarc apsiom m Esser of aamtiier'sc The wrOer does iaot stt~eet hfmd. m~antmtog ohedsimoe to e.+vyshiayg a ieadea awes, sties m dreistooe pcata~ to es,pha, ttsikwS Pty uikmg a tt~p, amd ebe like The ]r'T tearbcs the netx~sap tef deomustzt jl .lohn # i j _ m (lnd (Qaua. {4.3%2, t'htl 63~, and aettasi (Boor- l 2.1©, t3a1. S. L'1. Epb 3.21,. 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Sttaare-PaA-Crauli Yrtsi.r... ae avori el ewe raaraad h.iot s~11 uwe69era sirerarirars- B 9Miac antes 1Aa res+nl uare u ate, ..rmer ear e.acarerer c+Prreaar saran eas save s +iear46lrf lsreilra alit tyrr rra~l+ac V ~ Mle tlr~rer, 1ME THE 1b~ERL?YYI6 4F'T!E AYERIC/Ni 11YRY 11K RIFVOCABIE LAND TRUST /~~ ~ tFAS ill I~IFaIRl.EB TN.T TME.EOiiEY .IBDMlitl1G 'IaD fsc er ~ wwr w-s AEEIfI ' cD~F+uTEa eY +- oECeslml 6D Ai.Law ~ ~ roSTlu. ~nralls.E~ T#IAT ME lus ~ LREY 1~.AtfD A6ARKT ALL ~ERTY ilk !IY GORODY LtICE lEi.OMBS TO US AS 7NIS Q T'7LIiST MAS clT~~e~ISE ~YS ta- i:lslieRr T.lfett Si1Gfi AS T)ESE Arlo cA~l oa t>~. eE GOLiF.GTARLE ,~ ~:- DR ANt- .1YD~1EJi'!'S EYiIE ~R1-RnLE55 . wE otter a/1 EgalPeae~lt emk: DR Peaapealy w ~ a aril sabre prlapreKry Ailm art tirc-r by weueclee cle raorrs To r~artE_eT T~ tY nl, >~ ,;~.._ Ml/ T1i15 CASE ,~!„et ~' ~ TWe RFSI~TRI16 ~ l.Ei'T s3 GlUSES MDT SPECIfiEO AS 1116~ARILLY Affit>X'~D FOt EQI3AL TD TrE OlAif48ES OF_ S'3s~~S~ EVAt~L1T10N iNADE ,UPGIE • IlrARllll6r O Ad A rlEARi18 CEO ON0 PF1LSpIl14L FARlRS FDR lIOT MAVO/1i 1E'D'RS TO T~ CASE .~'iED Ai TfOS "GASE'11~5 ADO!!t A GCirIT!'ER OR P/tCDf rWT PtiIRDVlOEO .!EliTtY 301~f ME _ 6EfY1~: PO6TAL Arnr MORE TfiA/ll R MIASS Oi ABILITIES T~'! C.OI~tRM BY rR LUGf EtT~f A1fIB THAT /r0 REP~SEIRATHIES Di' oTMERllrlSf PMT Pi1RP'~iE MERE ~OIY /TONAL ACCLAIM BT liR fi01M P86TAt. ERNER AS A LE6aL "P~R7i~ NiRE RY T!E NDrldRA!!,E JE'S.SIGI! BAR ~ tR !IDlTM I~iONFR STREET ~ a•~M e~ c ~ ~~ 106 ~ t~N~,l>•,s.PA ~ T813 ON A DOC.>tlET NtIYRER W-8RtQ1~,Gif.8p0AD6;~i 2 pE{ 2 IS REQUESTED Tf3 ~~ .:~, ~. ~~ ;a 5 a ~ .~ n r ~` ^`` \~ ~ wo~ns of "~eanbr a ~Y ~ ~ . am ~ ~~ COIA~fT'P ~ , ~'~_ . y ~, ~,;~~ ~- '(here intesl ~fa~na'~ ~ i~>taZ appas~ed ~a -~ ~ . MlID baei ~:~a~ of ~~'~ 6rt~i~r peerr~s) trtwse na~s~rt) ~Y:'~cf ~ ~i~ ark ar~ee~it~ b irr they ' ~~ ~ ~ heie~idl~1 ereira~id t~a~a~ ii ~ and h~ Dy tl1iiMC~! ~ ) add. ~~rBi~ hee~er~t ti ~ ~ ~` `v 4 ~~~P~~1LTT dJE pl~t7E1RY mr~,kx tie i~rs ~~.thc ~Sertc of "'J _ ~~ /~ ,~ t~ ~ a~ aet! e~reoct ~'~- ~R _ rJ ..,,r ~, ~~f~) +~ 1~ ~° ~~ .., ~. J .~ ~. ,; -__:~ ~~ ~ ,~ ..~ ~F +~o ~ N ~+c~~rA ~s . ~~ ~{ ~ ~. 1 .~-- __. _ ~'`'~ ~~3 ~" Txr~r F~ ~ ~sss wrrns as ~ a wu T~rwis a4,~'-s3a.eew wT ~ wws ~ , dFFERED TO ~'*~ ~ dfR .dF GAT SllyiE dFF YIt~.S -~SI~D :111!leB~t THE PI[Yr~i~ IEAS A .,.,~ ~~ ~ CAD Ft~lU/-~D l~i6T G!'lVER>-0E M/Ra eiiA~ S~ Dim T~~G~OIE~TI~/E _ ;-' 1 - ! .~ G:~t~f~ wE S~1:f/ A/~I.affD ll1LES,5?AT~7lill; AM"P 1?T[~iIEY ~t GOIIR'T OFFIAL ~ ~ ear ~ r~-Y ~ ~ s~~ ae rr ^E-so a-M EsxwLL ~ ~ ~E aars~ws r=~ 11nTM TUE AGTU~- C~ aLS~iOR OTl~! .~BiE ~a r _uC'«$ R GY~I MOTBE AITEi~Q MOit irfY '11iAA TES Gil MOT ~ ALTEaEe ~ 6lI~ED ~~~ SlleNC7 _ TO StTf't~ w1G rYELL,~,®,,,,, ~ Olt /uY D 1~D GEf~[S 5......... IPERSOtf1ALLY INSURED FOR X15,000.00 EACH/ t~ER tNCtDENT ~,, : ~;~~~r ,~y~ ~.,/, , J`-" 7 Trusts RSS Estoppel Letter Banking & Collections Estoppel Letter TC~ GOIN POSTAL & Jessica Brewbaker & her multi named aliases, of Magistrate Jusice .usages located at 4",.9 East High st. Carlisle, Pa. 17013 for Goin Postal /as Shane Gilmore//// ALSO AND /OR 18 N~3rth Hanover Street ,Suite 106 ,Carlisle. Pa. 17013 for JESSICA BREWBKER REGARDING: A JUNKED OUT COMPUTER ///// DESTRUCTION BILL PAID, BY CASH ,HIRING A A SPECIALIST TO FIX A COMPUTER., SPECIAL DESIGNATED //// FOUGHT WITH , AC:iAINST ITS RUINED CONDITION BY GOIN POSTAL, AS CAUSING IT TO GO DOWN PERMANEI\ITLY ,NOT BECAUSE, OF WH,4T WE OR /NOR ,,US/NOR I, PERSONALLY WANTED NOR ORDEREC) AT ALL , NOR DO ,OR DID DO , BUT SIMPLY NEEDED THE COMPUTER FOR FIGHTING FOR MY LIFE TO SURVIVE ,AS WELL. AS ANYOR ALL ATTACKS ON US IN GEERAL ORNOR IN MY ADAVANCED DIVING WILL , ASSIGNED DIRECTLIVE USABLE TO ANY COURT, AS ADVANCED CHARGES OF TORTS ABUSE, OR AS CAUSES IN THIS CASE ,THAT WILL OR ARE ALREADY FILED „ FOR JI.JDGMENT, AS TORTS CRIMES, WITH A LIEN THAT CLAIMS DIRECTIVES TO ANY JUDGE OR ANY JUSTICES OR COURT AUTHORITIES TO PAY IF ITS MEDC)LED WITH OR IF OPTIONS CLAIMS TO INCITE: ANY PERSON SUCH AS I GORDON LUCE OR GORDON LUCEPATRIOT AS THE'+NAY IT STATES OF BEING AGAINST ME .PERSONALLY ... THE TORTS CRIMES ALONE, ARE MORE THAN A MILLION DOLLARS WORTH ,OF HEALTH StRESS RELIEF DAMAGES of INURIC')US DAMAGES CAUSED OR DONE AS TRYING ,TO MAKE IT WORK, AS IF ,YOU OR I or not AIVYOIVE ELSE FAILED .... TO DO ANYTHING ABOUT TRYING TO UNDO THE OUT OF fVIERIT NJN-NEGOTIABLE ATTEMPTS TO STUPIDLY FOR EXAMPLE :::::: PLACING WINDOWS. SEVEN AND WINDOWS VIISTA IN IT,WITHOUT BEING ORDERED BY US„NOR ME, NOR RfC1UESTED A'~ A COMPUTER REPAIR ,NOR REBUILT NEW TO HAVE THEM DESCRIBED AS WOFLK OR THINGS PLACED INTO A COMPUTER DISALLOWED IN THIS WAY AT ALL. to never ever ~~a R1=GARDLESS ,NOR TO DO SO EITHER ? 1 Property located at:OF OPERATION WAS/IS _1 WEST PENN STREET 102, CARLISLE PA. 17013- x:355 The balance due, upon this BILL as of JULY 29 2012 _WAS /IS AS UNPAID $ 1848.00 + MILLION DOLLAR BOND , CALLED BY NAME , A LEGAL COMMERCIAL LIEN WHICH , YOU ONLY YOU COIN POSTAL SIGNED , A NAME TO IT AS ATTACHED + A LOT OF OTHER SETTLEMENT DOCLIMENTS OF ILLEGAL. FORMS PRESENTABLE ,FOR UNLAW SUIT COLLECTION, OF= THE MILLION DOLLAR SETTLEMENT + TO BE A CASE OF TOTAL DESTRUCTION ,CAUSED EXCLUSIVELY BY SHANE GILMORE OF COIN POSTAL ONLY AS WAYS TO BEAT US OR ME OUT OF A COMPUTER AND OR NEEDS TO USE FOREXISTANCE MOSTLY SURVIVAL ........ NOW + ATTORNEY'S FEES ,AND + ADDED ON COURT COSTS, BESIDES ADDED , ON I::XTRA PURSUITS OF FILING, AS ,UNKNOWN, YET, A TOTAL AMOUNT DUE ,UPON DECISIIJN , OF Cc=JURY, OR ELSE, IF DEFAULTED , WILL BE INTEREST , ADDED ON :AND OTHER CHARGES OF CONTERABLE REASONS TO OVER RDE THREATENED by a RULE OF DEFAULTING or striking down THE JUDGEMENT ITS SELF ... $ 1,062,458 &_80_J100 dollars).PLUSOR MORE The per diem is $_GOING TO BE SET AT AN`( LEVEL OF UNEXCELLED AMOUNTS /100 dollars). "The DEBT :was last known as unpaid ,on _NONE OR ZERO CASH ,OR OTHER WAY'S , OF PAYING; EXCEPT, IF ITS NOT,SETTLED? IT WILL BE A SALE, OF PROPERTIES OWNED, IF THAT DOES NOT COVER !TALL, YOUR CREDIT WILL BE CHARGED The figures , in this estoppel ,are effective uattempts ,AT THE FACT THAT THE LIEN WILL NEVER CLOSE, AS ~1 LIEN ,LOF LIENS AS OF COMMERCIALTYPES NEVER CLOSE, NOR TO BE. AL fERI-D TO ESTABLISH WAYS AND CAN NEVER BE WIPED OUT, NO MATTER -WHAT IS DONE ,TO DO SO , AS ANY RULE ENTERED for or against there of ...... With So, OF, OR ABOUT- this Letter, likewise will remain affective ,until everything isr epaid in full .IT'S IN THE FILES OF JUDGEMENT FILING ALREADY .NO CHANGES, WILL EVER , BI. ALLOWED TQ THE LIEN WITHOUT CONSEQUENCE ,TO ANYONE, TRYING TO MESS WITH IT OR THIS LETTER EI1"HER ONE justify its close don or to PENTION TO OPEN OR STRIKER DEFAULTJUDGMENTFOR OR GAINST "_1S ,ME, NOR ANYONE ELSE ILLEGALLY SO EITHER ........ __GORDON LUCE & ~4LLTRUSTEES OF THE LUCE FOUNDATION A CPS FULL FLEDGED TRUST BONDING THIS HOLDING FOUNDATION __. BINDS ITS TRUSTEES, TO THESE. OBLIGATIONS , NO MATTER WHAT . Funds should be NOT BE wired toUS :SHIPPED ,TO US, IN GOLD AND SILVER , ONLY A5 HIGH GRADE COINS ,WILL ONLY BE ACCEPTED IN TACT OF ACCEPTANCE OPJLY TO COUNT ANIJ UPC)N hROPER ACCEPTNCE THEN SIGN BY ALL , TO SIGN OFF FOR GOOD & BE SERVED TO TRlJSTEE OR TRUSTEES CORDON LUCE OR ANY OFTHEREST OF THE TRUSTEE BOARD ,AS Name of Account, _NO AS OFNOW ,UNKNOWN _ Bank„ NOR ANY BANK ACCOUNT Fax a copy of your instructions to: REACH BY LAW _WELCH GOLD & SEI~GEL , Attention 2 REI=ERENCE NUMBER etc 539125.as NOT ALLOWED WITHOUT PROPER ALLOTTED proof to do so Dared: NOV 6, 2012 __ urtsetNed for & held against you anyway For: __THE LUCE FOUNDATION FOR BETTER LIVING ,OR /AND /OR BETTERLIVWG THE AMERICAN WAY A VA LAND TRUST IN WHICH BOTH INSTITUTIONS ARE, IRREVOCABLE TRUSTS (TS AS WE ARI= ObVNERS OF THE HP COMPUTER YOU SUPPOSEDLY WITH OUT I>ROOF REBUILT',OR BUILT NEW .IT BLEW UP, AND HAD TO BE JUNKED, FOR A NEW PURCHASE: , AS A BRAND NEW COMPUTER FROM OFFICE MAX STATEMENT, ENCLOSED OR ATTACHED ,YOUR SO CALLED WORK SETTLEMENT , HAD NO TAX STATEMENT, NOR OFFICIAL, STATEMENT OF W()RK,PER HOUR RATE NOR TOTAL AMOUNT , WAS nEVER DISPLAYED & WAS NEVER SUBMITTED , TO US, OR only shown to BLAME GORDON LUCE FOR IT ALL CONSTITUTES FRAUD ,CORRUPTION AND ABUSE BY INVALID DEBT ,FOR COLLECTION , BY THE FAIR DEBT COLLECTION PRACTICES ACT, AS AN INVALID DEBT ,AND VIOLATING EXTENSIVELY ,THE OLD PERSONS ABUSE LAWS, ENTAILED ,AND DESCRIBED, IN COURT EXIBITS ,AONG WITH SETTLEMENT AGREEMENTS DISHONORED , WITH TT BEING ,WOUND UP AS TERRORISTTHREATS, LIKE THROWING ME OUT THE STORE. ,ALMOST FULL FORCE VIOLENCE, IJNKNOWn WHY WITH ,CONTINOUS THREATS , AND COURT CIVIL ACTIONS ALL AGAINSTME WHEN THE NTIRE DEAL WAS NOT MINE ????? NON-JUST WAYS , AT ALL GIVEN, TO BE AN`rTHING EXCEPT GROUNDS, TO HAVE AN AR.R'EST MADE IN, LIEU OF CONSISTANT THREATS OF ABUSE ENTIRELY ::::: NON JAILED , LIKELY MIGHT BE A BETTER PLACE FOR YOU, TO COOL OFF FROM BEING A VERY VICtLENT PEKE ,INHUMANE CORRUPTION CASE ,ANYWAY ? OIJR TRUSTESES , ARE. PROTECTED FROM SUCH SCANDULOUS CORRUPT, JUNK DEFIND FINDINGS DiSCOVE'RED AS SU(_H ,YOU SEAID , PERSONALLY , WILL SUBMIT WELL. , TO THE POLICE DEPT.... T HAVE YOU on and Jor as N'ON ARRESTED ,FOR SUCH ONGOING TERRORISTIC THREATS WHICH WILL GO INTO THE JUDGEMENT PAPERS , AS THREATS OF TORTS CRIMEi ALREADY CHARGED, UNSTTLED FOR & AGAINST YOLI ANYWA By THE ORDER FOR COURT : AS. ADDED ON, UNACCEPTED CASE FOR NON BENEFIT TO GORDON LUCE PATRIOT _OR 60RDON LUCE TRUSTTEE, ONLY AS A NEGOTIATOR ONLY, FOR THE OWNERSTI-IERE OF THIS COMPUTER AS CLAIMS STATE fTS ABOUT [not personal as indicated wrongfully lied ,about fafisfying ,such as !!!! ] OR REgUESTED , TO HAVE OUR MONEY 6ACK, BUT NEVER ONCE, PAID OR NOR RETURNED AT ALL ,WAS OUR STORY UNHEARD IN BREWBAKERS COURT AS AN fM PROPERLY VIDICATEE) DEAL , AT ALI. POSING ITENRATE UNENDING THREATS OF TERROR, PHYSICALLY THROWINCi M'E PERSONALLY OUT OF A STORE OPEN TO PUBLIC USE TERORISTCALLY UNDER INSURANCE COVERAGE, BACK UP AS, YET UNPAID OR UNSETTLED FOR !!!!!! ....._ LUCE FOUNDATION FOR BETTER LIVING. AS AN IRREVOCABLE TRUST KNOWN AS A PSA TRUST Anci, ALONG WITH , A LAND TRUST IRREVOCABLY RECOGNIZED , AS A VA TRUST NAMED BETTER LIVING THE AMERICAN WAY ,DESIGNATED COMPUTER USE ONLY FOR BUSINESS USE ONLY NOT PERSONAL AS RS BEEN STATED FALSIFYING LIESTHRU OUT BY BOTH LISTED PARTEIS 3 --- - -- - - --- Lender T~r~l-f~7iE"T~f1iT5 ;Fii~~ ~E i ALA. fdlrAt~ ~A.9T7;~.MA LItfT"t~S6~A14 TiD SF171E ~1R OF ~kT As- TRUSTEE AMID TRL~T'EES M~EY AAtD YOU, "Tt^ITALLED,-A TOTAL C.,~T OF 51~~•~-~ EIMBEZZELED , FRL~lTl~IE tl`~NOL$i'Q19tE BAI~C.,i~15 CASH ~t CttECIC~,OR CREDR iCAFtD PAYMENTS ,Fi~R _AI~IEV®tSF10W111 CIAEtiA D7t STATEMENT Ni~R , WA'EIRE~T7ED GURANANTEE AS MONEY WASTE, [ WIT>'t DRAWN FRC>du! J iheshownat~unt ,'NI/iTN BO Si6lwElFYiN~ OF COURSE ItSTED S7?ATEMEETT, [ iRECEt3fRED, TO SHOW A5 BEI~.APfD.,] TO A REPAERED OR BU[LT AS:A NEW `COMPUTER t1~F:5ER11NE WORKDFCLARED AS NtfTEF7CAT10N V17HICH RELATE AS A CNIL CASE B~0116HT A6AINST`ME PER-ONALLY 1ATHEN TIME Ct~IfPUTE R. BELUNGED"T'O ALL FOl1Nl3ATtONS fiF`EEtBEVOCAIETRUST OIEY?Rm !?~i ONE, OF ETTHER IN TEiERE CON9PUTER:, 1~71!!tICl1~ BLE1N 17P El~]sAN~EI~N6FVftEY~ ENCLUDIl~'i ME fOPRDON LUCE NOW BEINGTl3REAT1~, FMCIANS~RE~_TERI301tlZED, AS A""REJECTED WQRK , S13PPi~EDLY , l~dT Di~NE WCEH NO P.RO(~F, AT All., SHOWING LE5AI.LY fr'1~i[AS DONEAT ALE ...? ASTO WMAT { COIN POSTAL] 'HAS QR'WANT5 , IS NOT~KNOWN , {!5/HEN HE HASNCTi YET PROVEN ,TO HAVE PRODUCED, AS THE DAMAGES DONEE, '°HE HAS ENTERED /CS A DEFEPIDENT NOT PLAINTIFF AT ALL 'TO SAy 1TS WITHOUT+MERIT ATALL TO ACCEPT [!?+! ~ Estoppel .Utter Review List PERSONALLY INSURED FOR 545,000.OA EArClU PIER INCIDENT Tltiis review Gst_, is provia~r7`to'inftsrm y~ , [ 601N P'C)CS'fAt OR .']ESSICA BItEWRAKEIR ~] NOW j([[ A6o~.itthis ilocament, being , in gvesEion , ~antl to assist you intS prrep~~Eion. An estoppel letter i~ to cieternsir>!e piayaff~noun~ , at a B or ~., of~ COAAPLITER BUI CT , supposedly for a cost arf $~&t80D ,SUPPOSEDLY SO F1kR DrECLARED.AS-A'LEE , {HAVING nn proof ai aU , ~fwtrat w~ tie to °the a~nputer, FUNCTIi~NA181LITY., eYrye~t`it blew up arxi uwas profes~tonr~Ily .dectareiias;p~nk., or~rio gonii~to.e~rerwork again _...jJi[j] AS ALL LIES, FRAUD, AND CDRREJPTe treatment , ~ -:for 'Proper .JlISTEFKATION TO QUALIFY FOR ENSC2"RANGE DAMAGES & A AIOTOR7~IZED SEAME'EDAND D MILLION DOLLAR LIEN UNPAED FOR ~ ONLp:EXISTS . _ 13~tfi ~te~ p~tylit Eet~ts , pride iM~ese~s„ a rrratter of course, have outstantEing EMBE?~ELED .MONEY A-TTRIBUTED AND C)WED AGAINST YOU , UMPAID'TOWARD R . Tkrese can=also ~ used far ~rpaat~e:~king~t~rations, when wirers ae+~Jor take cart o~ loar>~ tf you are'in such a :Eendi~sritior-, this eat farn~fizres"iHe-proae~s, ar~~l'a~i~t-the ~strtwr a~ittoer~s„ ar wl~rr-ever, IF COURT 1UDGE OR AUTHORITIES OF THE COURT DOES NOT ACCEPT FULL. t RESPON581LTY FOR HANDLING THE TRANSACTION APPROPRIATELY TO DELIVER US THE lUDGMNT FUNDS AND NOT ATTEMPT TO BRtOGE OUT BY DEFAULTING OR -OTHER STEPS ALL BE TAKEN , INtSTEAD, UNANNOI)NCED NOW WHAT THOSE WILL BE 4 ShareThis Printer Friendly Version PDI= Format Customize Document No related, documents.WERE EVER LEGALLY TRANSACTED, AS CONTRACTS ,NOT LEGALLY ACCEPTED !!!! AS MONEYPAiD, AS CASH ,Legally, NOi~SERVICE PARTS, IF INSTALLED OR NO'T ?? NEVER DtSCLOSED lpS Vwritten proof to Collett or not take actions to drop or NOR CAUSE US TO PAY FOR SUCH UNACCEPTED WORK' AS THAT LEAVE OUT THE HIGH DISTRESS DAMAGES TO HEALTH IMPOSED AS DAMAGES ADDED ON FROM R $ESIDES .... THEY AS EVERYTHING, TOTAL. IS , OR HAS BEEN REJECTED ,PRIMARILY BECAUSE , OF LACK OF PROPER NOTIFYING PROOF STATEMENTS , NEVER SURRENDERED FOR PAYMENTS ,MADE ,OR RECEIVED ,nor returned ! You are hereby involved as holding a ;Home » Financial ~ Banking & Collections u Estoppel -- - Letter PERSONALLY N FQR X15,000.00 EACH/ PER II~IDENT Estoppel Form Letter, Estoppel letter Canerstone Credit Union ACCOUNT NUMBER ~~~ t ____,, ~_ -- -_ NOTICE -5TH AMENDMENT CLAIM The information in this document is designed to provide an outline that you can follow when formulating business or personal ptans. It is provided as is, and isn't necessarily endorsed or approved by get free legal forms.com. Due to the variances of many local, city, county and state laws, we recommend that you seek professional Legal counsel before entering into any contract or agreement. WE HAVE AND ALL OUR PAPERS HAVE BEEN FILED IN ACCORDANCE TO THEIR TERMS ,..DATED ANDSTAMPED BY THE COURT AND CHECKED FOR APPROVAL ,_. IF WE WERE To START COUNTING /-IMf Aiuoll~l FIDES IT WOULo NOT TAKE MUCH TO ADD DP ONE MiLL10N IN COSTS ALONE AS INSURANCE CLAIMS UNPAID + INTEREST + THE MONEY EMBEZZLED FROM US TO TOP iT ALL OFF AS MUCH MUCH MORE JUST TO SAY 1ME OFFERED SETTLEINENT MINUS THESE COSTS WITH CRTIFiED ONLY GOLD OR SILVER COINS ONLY AND WHAT DID WE CET ?MORE ON GOING ADDED COSTLY ,THREATS OF ASBUSIVE INSURABLE FORMS AS INCIDENTS NOTED HERE AS PURPOSES TO COLLECT FOR ...LU(E STORE REASONS OF BEING THROWN OUT TRYING TO NEGOTIATE WITH A WILD INHUMANE BEAST ,NOT A REASONABLE MAN , TO DO ANYTHING ,BUT REFUSE ALL MAIL SENT CERTIFIED . DiD 1 HEAR OR SEE , IT STATED, WHY I SHOULD VACATE A CASE OF THIS TYPE THIS 1NAY ,FOR SSO0.00 ? \ ., ,. ~?~ ~~ •~~~ ~ ~ '~` t °~. ~ ~ ~ ~~ ~' ~`~ ` ~ ~ '~ ~ ,~ kr ~ ,,~' ~' ~~ ~` v ~ ~ ~• ~ ~}'' ~~ a~ ~~~ w° ~~ ~~~ -° ~~ ~ y~ 4~ ~`~ a~~~ -r.;r~..r~; S['ITF ~:`~~, ~ iSeYi'R TTT.'TI.n.,..- (, 9 2 ~ F'oits~t t 1ti e~ + ~. ~:~ ~~ ~ ~ fir!' _ [ ~ ._. _ ._. .___. _ PI'fTSlti R~:}I. P~F VAS`.-1!. 4 .1 ~ i•! ~g ddd E ~ t ;L ~I 8 != f' _ti00 ti I ~ .i~lP 1 ~ __.~ DI;RABLE HEALTH ( t1R~: P01~'ER OF ATTOR~'~E1 ~;.'v~ l'- ! HEALTH CARE TR:EATI~~[ENT INISTRUCT'IONS (LIVING ~'4'ILL) PART I - DIIRABI.E HEALTHCARE POWER OF ATTORNEY I. GORDI~P f~l.a3ENE LUCE, of Cumberland Co~.~nty, Pennsylvania, appourt the person named below to be my health care atient to make health and personal. care decisions forme whenever I lack the ability to understand, make or communicats~ ~; choice regarding a health care; decision as verified by my attending physician or whenever I personally inform rn~~ a*tendi ng physician. My agent may not delegate the authority to make decisions. APPOINTIWIENT ~~F HEALTH CARE AGENT I appoint the following agent: Narr}e: RONALD EUGENE LUCE Re}~ationship: San Address: 424 Water Strut, Apt. 304 Johnsonburg, PA l 581.5 Ielenhone No.: ~`+4 -?$~ - +a~:,9 If my agent is not reasonably available, or is unable or unwilling to act in a tamely manner., 1 appoint the following person as my alternative health care agent: Alternative Health Care Agent: Name: ROBERT MCKEE Relationship: ,;~~ ~ ~ s~ b6•+~:.~~:.y Address: One West Penn Street, Apt. 417 Carlisle, PA 17013 Telephone No.: 717-443-3555 SEPARATE HIPAA AIJTHOItIZAT10N EFFECTIYP', IlVIl~DIATELY Effective immediately and continuously until my death ar revocation by a writing signed by me or someone authorized to make health care treatment decisions far me, I authorize all health care providers ar other covered entities to disclose to my heath care agent, upon my agent's request, any inforrnatian, oral or written, regarding my physical or mental health, including, but not limited to, medical and hospital records and what is otherwise private, privileged, protected or personal health information, such as health information as defined and described in the Health Insurance Portability and Ai;countability Act of 19!96 ("HIPAA'~, the regulations promulgated thereunder and any other State or local laws and rules. Information disclosed by a health care provider or other covered entity may be re-disclosed and may no longer he subject to these privacy rules. Page 1 of 4 HE~.TH CA1tE _~(;~T NOAF~ My health care agent has ail of the following .powers subject to the health came tre~mment in~stnaetians that folovr in PART II: i 'to authorize, withhold or withdraw medical care and surgical procedures; 2. "I'o authorize:, withhold or withdraw nutrition (fond) or hydration (water) medically supplied by tube through my nose, stomach, intestines ox veins; 3. Ta authorize my admission to or discharge from a medical, nursing, residential or similar facility and to make agreements for my care, including hospice care andlor palliative care; 4. To hire and fire medical, social service and other support personnel responsible for my care; 5. ~'o take any legal action necessary to do what I have directed; 6. ~'o request that a physician responsible for my care issue a do-not-resuscitate (DNR) order, including an out-of-hospital DNR order, a Physician Order for Life-Sustaining Treatment (POESY) or other order effectuating my wishes and to sign any required documents and consents.. GUIDAIVTCE FOR HEALTH CARE AGENT {OPTiOI~iAL) Goals {Leave Blank if Goals Adeanately Expressed in.Remainder of Document)• If I have an end-stage medical condition ar other c xtc~eme irreversible medical condition, my goals in making medical decisions are as follows (insert your personal priorities such as comfort, care, preservation of mental functions, etc): SECTON .212. CONTRACTING AIO! 6RAiiT AUTHORITY; PRIVATE PAY RELATIONSINPS; APPROPRUITE USE OF F IJli1DS...... _ REPORTINQ AQUSE ,NEGLE , OR EXPLOITATION _ __ _. _ __ Severe Brain Damage nr Brain Disease: If I should suffer from irreversible brain damage or brain disease arith no realistic hope of significant recovery, I would consider such a condition intolerable and the application of aggressive medical care to be burdensome. I therefore request that my health care agent respond to any intervening (other and separate) life-threatening conditions in the same manner as directed for an end-stage medical condition or state of permanent unconscious as I have indicaxed below . Initials _ I agree. Deep me comfortable and allow natural deatr~ to occur. Initials , I disagree. Use all medical treatment that is needed to keep me alive. Page 2 of 4 P~~R7 II - B]~~l.iH ~~lRE ~T~E1'T .~~L~tTI[ L'~ ?~ ~.3~"~CT !~ IC~i. L~ OR I!'>E~~:~'~~T ~ ' (l:Iti"ttiG R~.1.) The following health care treatment :instructions exercise my right to make my own health care decisions. These instructions are intended to provide clear and convincing evidence of my wishes to be followed when I lack the capacity to understand, make or communicate my treatment decisions: END-STAGF. MEDICAL CONDITION OR PERMANENT LINCONSCIOI7SNESS If I have an end-stage medic~~l condition (which will result in my death, despite the introduction or continuation of medical treatment) or am permanently unconscious such as an irreversible coma or an irreversible vegetative state and there is no realistic hope of significant recovery, then I choose the following (indicate your choice by initialing your preference): Initials ~_ I do not want aggressive medical care, and give the following instructions: 1. I direct that I be given health care treatment to relieve pain or provide comfort even if .such treatment might shorten my life, suppress my appetite or my breathing, ar be habit forming. Medical or surgical treatment to relieve pain or provide comfort may be given even though I do not want it as a life prolonging procedure. 2. I direct that all life prolonging procedures be withheld or withdrawn; 3. I specifically do not want any of the following as life prolonging procedures: heart-lung resuscitation (CPR), mechanical ventilator (breathing machine), dialysis (kidney machine), surgery, chemotherapy, radiation treatment, antibiotics. OR Initials Jf ,~ I do want aggressive medical care, and give the following instructions: I wish to receive all medical and surgical treatment needed to keep me alive as long as possible, even though my doctor believes it will only delay the time of my death or maintain me in a state of permanent unconsciousness. In addition, I direct that I be given health care treatment to relieve pain or provide comfort provided that it does not hasten my death Tate Feeding Please indicate whether you want nutrition (food) or hydration (water) medically supplied by a tube into your nose, stomach, intestine, arteries, or veins if you have anend-stage medical condition or are permanently unconscious and there is no realistic hope of significant recovery. (Initial only one statement.) ~. _ ~ do want tube feedings given. OR I do not want tube feedings to be given. Page 3 of 4 Br~iii c~c ,imest'i ~e af:i^~sefi~c ilt~rt ~ ~i i~^a_~3 _ _ '~ ~ ~t mast fno~ these instrncboas_ OR _. lliese instructions are only guidance. My agent shall have final say and may override any of my instructions. If neither my agent nor my alternative agent is available, these instructions shall be followed. Leal Protection . PERSONALLY INSURED FOR Si5,000.00 EACMJ PER INCIDENT Pennsylvania law proU~;ts my health care agent and health care providers from any legal liability for their good faith actions in following my wishes as expressed in this form or in complying with my health care agent's direction. On behalf of myself, my exEx;ators and heirs, I further hold my health care agent and my health care providers harmless and indemnify them against any claim for their good faith actions in recognizing my health care agents' authority or in following my treatment instructions. SIGNATURE Having care;trlly read this document, I have signed it this~~y of ~0~.~~Cr" 20~, revoking all previous health care powers of attorney and health care treatment instructions. 1 -- w~'~~GORDON EUG~U~ _ ---- ---- WITNESS: _ ~~'L~ WITNESS: ~~1~~~~L~ .~ ~ NOTARIZATION (OPTIONAL) On this ~ y of flyY,r*~,'1~.~-=, 20~ before me personally appeared the aforesaid declarant and principal, to me known to be the person described in and who executed the foregoing instrument and acknowledged that he executed the same as his free act and deed. IN WITNESS WHEREOF, I have hereunto set my hand and af~rxed my official sE~l in the County of ~a,„w,~+rr~ rs,,, Commonwealth of Pennsylvania, the day and year fast above written. _ ~ _.~.°~ WEALTH ©F P 1Y1.~/ANIA N ARY PUBLIC ._.-_ ---=-`... !~~`~//~~ ~q, ~~~/~rst.o~~Ti~i~At SEAS p,,~{,,,, .~ VIU~~ ~.::LILL~ ~~~ r'1Gd.^... E30l0 Ct ~1:"..~L+^a,~. ft~^~~ CO'.t~j ', ~~ ~~~ ~ ~~ r.a, ~ ~ Page 4 of 4 FILEb-ter F-`{ THE P R 0 T f NOTAIN"( 2013 JAN -8 PH 12: OS David R. Galloway Attorney I.D. 87326 CUMBERLAND COUNTY Counsel for Defendant, Goin Postal 54 E. Main St. PENNSYLVANIA Mechanicsburg, PA 17055 Telephone: 717-697-4650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GORDON LUCE, Plaintiff NO. 12-4401 V. ; CIVIL ACTION - LAW GOIN POSTAL, Defendant NOTICE TO PLEAD TO THE PLAINTIFF: Gordon Luce, pro se You are hereby notified to file a written response within twenty (20) days from service hereof or a judgment may be entered against you. Respectfully Submitted, By David R. Ga loway Attorney I.D. #87326 David R. Galloway Attorney I.D. 87326 Counsel for Defendant, Goin Postal 54 E. Main St. Mechanicsburg, PA 17055 Telephone: 717-697-4650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GORDON LUCE, Plaintiff NO. 12-4401 V. CIVIL ACTION -LAW GOIN POSTAL, Defendant DEFENDANT'S PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT AND NOW, comes Defendant Goin Postal, by and through its attorney, David R. Galloway, Esquire, and preliminarily objects to Plaintiff's Complaint for the following reasons: 1. The above captioned action is an appeal from Magisterial District Court 09-2-02. 2. Magisterial District Judge Brewbaker entered judgment in favor of Defendant and against Plaintiff on June 14, 2012. 3. Plaintiff filed an appeal with the Prothonotary's Office on July 16, 2012. 4. On or about July 25, 2012, Plaintiff filed a document titled "Complaint." 5. On or about October 19, 2012, the Prothonotary entered a default judgment against Defendant. 6. By Order dated December 20, 2012, this Court struck the default judgment and granted Defendant twenty (20) days to file a responsive pleading. 7. Defendant files these preliminary objections in response to the Complaint. COUNTI Legal Insufficiency (Demurrer) - Pa.R.C.P.1028(a)(4) 8. Paragraphs 1 through 7 are incorporated herein by reference as if fully set forth. 9. Plaintiff alleges he paid Defendant to perform certain work to Plaintiff's computer. 10. After the work was performed, Plaintiff alleges the computer "failed to reboot." 11. Preliminary objections in the nature of a demurrer test the legal sufficiency of the plaintiff's complaint. Hospoder v. Schick, 885 A.2d 986, 988 (Pa. Super. 2005); Sexton v. PNC Bank, 792 A.2d 602, 604 (Pa. Super. 2002). 12. The question presented by the demurrer is whether, on the facts averred, the law says with certainty that no recovery is possible. Mistick Inc. v. Northwestern National Casualty Co., 806 A.2d 39, 42 (Pa. Super. 2002). 13. Accepting all material averments as true, the court must determine whether the complaint adequately states a claim for relief under any theory of law. Id.; Hospoder v. Schick, 885 A.2d at 988. 14. Because Plaintiff's Complaint lacks material averments necessary to state a cause of action for which recovery is possible, this Court may dismiss the Complaint. WHEREFORE, Defendant respectfully requests that this Honorable Court sustain Defendant's preliminary objections and dismiss the Complaint. COUNT II Failure of a Pleading to Conform to Rule of Court - Pa.R.C.P.1028(a)(2) 15. Paragraphs 1 through 14 are incorporated herein by reference as if fully set forth. 16. The Complaint fails to contain a caption, verification or numbered paragraphs in violation of Pa.R.Civ.P. 1018, 1022 and 1024. 17. In addition to the aforementioned deficiencies, Plaintiff failed to attach a notice to defend to the Complaint in violation of Pa.R.Civ.P. 1018.1. 18. Plaintiff failed to attach a certificate of service or otherwise indicate he served the Complaint on Defendant pursuant to Pa.R.Civ.P. 440(a)(1). WHEREFORE, Defendant respectfully requests that this Honorable Court sustain Defendant's preliminary objections and dismiss the Complaint. By- David R. Ga oway Attorney I.D. #87326 VERIFICATION I verify the facts set forth in Defendant's Preliminary Objections are true and correct 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. I am authorized to.make this verification on bob if ? Postal. Date; January , 2013 By Shanc Kilm Are David R. Galloway Attorney I.D. 87326 Counsel for Defendant, Goin Postal 54 E. Main St. Mechanicsburg, PA 17055 Telephone: 717-697-4650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GORDON LUCE, Plaintiff NO. 12-4401 V. CIVIL ACTION - LAW GOIN POSTAL, Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify a copy the following: 1) Defendant's Preliminary Objections to Plaintiff's Complaint; and 2) Notice to Plead; and 3) Proposed Order. was served, on this date, upon Plaintiff by First Class Mail, Postage Pre-Paid, addressed as follows: Mr. Gordon Luce 1 W. Penn St., Apt. 102 Carlisle, PA 17013 David R. Galloway f? Attorney I.D. 87326 Date: Januaryi% , 2013 F I L 0 FF I �1.-11 J� R k J I E P F�01 T 1-',0 1141 U i e-, , I 20, 13'r-10 23 All 11: k I CUMSERLAQ COUNTY GORDON LUCE, PENNSYLVANIIA Plaintiff v. tqzt IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT COIN POSTAL, Defendant 2012-04401 CIVIL TERM IN RE: PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT BEFORE HESS, P.J., MASLAND AND PLACEY, J.J. OPINION and ORDER OF COURT AND NOW, this 23rd day of May 2013, upon consideration of Defendant's Preliminary Objections to Plaintiffs Complaint, and following argument held on 15 February 2013, Defendant's Preliminary Objections are sustained in part and overruled in part as follows: 1. Defendant's preliminary objection in the nature of a demurrer relating to Plaintiffs Complaint is SUSTAINED; and 2. Defendant's preliminary objections, paragraph 16, relating to Plaintiffs Complaint's failure to contain a caption, verification, or numbered paragraphs, is SUSTAINED; 3. Defendant's preliminary objection, paragraph 17, relating to Plaintiffs Complaint's failure to attach a notice to defend, is SUSTAINED; 4. Defendant's preliminary objection, paragraph 18, relating to Plaintiffs Complaint's failure to attach a certificate of service or otherwise indicate that he served the Complaint on Defendant, is deemed to be MOOT. Plaintiff is permitted to file a new complaint that conforms to the Pennsylvania Rules of Civil Procedure within thirty (30) days of this Order of Court. BY TH RT, Thoma A. Placey, C.P.J. Gordon Luce Pro se David R. Galloway, Esq. for Defendant Q,ofl-ev GORDON LUCE, Plaintiff [ V. IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT GOIN POSTAL, Defendant 2012-04401 CIVIL TERM IN RE: DEFENDANT'S PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT BEFORE HESS, P.J., MASLAND AND PLACEY, J.J. OPINION and ORDER OF COURT For disposition at this time are Defendant's Preliminary Objections to Plaintiffs Complaint. In this contract case, pro se Plaintiff alleges that Defendant did not perform services on Plaintiff's computer for which Plaintiff paid Defendant. For the reasons stated in the following opinion, Defendant's Preliminary Objections will be sustained and Plaintiffs complaint will be dismissed without prejudice. STATEMENT OF FACTS The pertinent facts, to the extent that this court is able to decipher them,' viewed in the light most favorable to Plaintiff as the non-moving party, can be summarized as follows: Plaintiff paid Defendant to perform repair work on and/or build a new computer The action is on appeal from the magisterial district court, wherein Plaintiff was required to file a Civil Complaint that contained a concise statement of the facts upon which the claim was based. The magisterial district court statement of facts is markedly different from the separate, numbered paragraphs for each material allegation required at this court level. Following a trial at the magisterial district court, Magisterial District Judge Jessica Brewbaker rendered a written decision that also included a summary of the testimony. Judge Brewbaker's summary is used to shed as much light as possible onto Plaintiffs claims before this court. This summary is in conformity with the pre-computerized AOPC forms requirement. See AOPC JPCIV 1-76. 1 and to provide the computer with a Windows 7 upgrade.2 Subsequently, the computer did not work. Plaintiff purchased a new computer from OfficeMax.4 3 Plaintiff then sued Defendant.5 Magisterial District Judge Brewbaker entered judgment in favor of Defendant on 14 June 2012, on the ground that there was no evidence that Defendant violated any duty to Plaintiff.6 Plaintiff filed an appeal of Judge Brewbaker's judgment with this court on 16 July 2012 that included "Jessica Brewbaker" as a defendant.' On 25 July 2012, Plaintiff filed a Complaint, citing inter alia the Fair Debt Collection Practices Act.8 Plaintiff alleged in the initial Complaint that after he paid Defendant to perform work on his computer, the computer "blew up when it was set up and plugged in immediately."9 On 15 August 2012, Plaintiff filed a "Complaint Action Details to Computer Fraud."10 In this pleading, Plaintiff referred to a "law suit filed, to get our money back because of rejection, for having, no computer at all" and "having money stolen, or embezzeled [sic], from our account."" This document had "Example Exhibits," including what appears to be a copy of Plaintiff's receipt for the purchase of a computer 2 Brewbaker Decision, MJ-09202-CV-0000063-2012, 14 June 2012 (hereinafter Brewbaker Decision); Plaintiff's untitled "Complaint", filed 25 July 2012, at p. 2. (hereinafter First Complaint), 3 Brewbaker Decision; First Complaint, p. 2 (noting that the computer"blew up" and "hd [sic]to be junked it was totally ruined.") 4 First Complaint, p. 2; Plaintiff's"Complaint Action Details To Computer Fraud", filed 15 Aug. 2012 (hereinafter Second Complaint), Exhibit OfficeMax receipt. 5 Brewbaker Decision. 6 Brewbaker Decision. 7 Notice of Appeal, filed 16 July 2012. 8 First Complaint. 9 First Complaint, p. 2. 10 Second Complaint. 11 Second Complaint, p. 2. 2 from OfficeMax on 5 April 2012 and a bill from Holy Spirit Hospital showing charges totaling $16,735.55, appearing to have been paid in full by Medicare and MAPA.12 Plaintiff noted that the medical bill was an "Example Exhibit of Distress.03 On 14 September 2012, Plaintiff filed a notice of intent to seek default judgment against Jessica Brewbaker and Defendant.14 On 19 October 2012, the Prothonotary entered a default judgment against Defendant.'5 On 29 October 2012, Defendant petitioned this court to open and/or strike the default judgment.16 On 6 November 2012, this court issued a Rule upon Plaintiff to show cause why Defendant's petition should not be granted.17 By Order of Court dated 20 December 2012, this court struck the default judgment and directed Defendant to file a responsive pleading.18 On 8 January 2013, Defendant filed Preliminary Objections to Plaintiff's Complaint.19 Plaintiff filed a Response on or about 16 January 2013.20 On 15 February 2013, counsel for Defendant appeared in this court for oral argument relating to Defendant's Preliminary Objections, Defendant's Preliminary Objections contained two counts: (1) a demurrer for the Complaint's failure to state a cause of action for which recovery is possible, and (2) 12 Second Complaint, Example Exhibits. 13 Second Complaint, Example Exhibits. 14 Notice of Intention to File a Praecipe for Entry of Default Judgment of Revival to Jessica Brewbaker, filed 14 Sep. 2012; Notice of Intention to File a Praecipe for Entry of Default Judgment of Revival to Goin Postal, filed 14 Sep. 2012. 15 Praecipe to Enter Judgment of Revival Upon Default against Jessica Brewbaker, filed 19 Oct. 2012; Praecipe to Enter Judgment of Revival Upon Default against Goin Postal, filed 19 Oct. 2012. 16 Plaintiffs[sic] Petition to Open and/or Strike Default Judgment, filed 29 Oct. 2012. 17 Order of Court, filed 6 Nov. 2012. 18 Order of Court, filed 21 Dec. 2012. 19 Defendant's Preliminary Objections to Plaintiffs Complaint, filed 8 Jan. 2013 (hereinafter Prelim. Obj., T—). 20 Plaintiffs Response, filed 16 Jan. 2013. 3 objection to the Complaint's failure to conform to rule of court, specifically Pennsylvania Rules of Civil Procedure 440(a)(1), 1018, 1018.1, 1022, and 1024.21 DISCUSSION Preliminary objections, generally. Preliminary objections may be filed by any party to any pleading on grounds including the pleading's failure to conform to law or rule of court, insufficient specificity in a pleading, and legal insufficiency of a pleading. Pa.R.C.P. No. 1028(a). A court will only sustain preliminary objections when, "based on the facts pleaded, it is clear and free from doubt that the complainant will be unable to prove facts legally sufficient to establish a right to relief." Mazur v. Trinity Area School Dist, 961 A.2d 96, 101 (Pa. 2008). When reviewing preliminary objections, the court must accept as true all well-pleaded allegations and material facts averred in a complaint, as well as all reasonable inferences that can be drawn from those facts. Bower v. Bower, 611 A.2d 181, 182 (Pa. 1992). The court, however, "need not accept as true conclusions of law, unwarranted inferences from facts, argumentative allegations or expressions of opinion." Myers v. Ridge, 712 A.2d 791, 794 (Pa. Cmwlth. 1998). Demurrers, generally. A party may file a preliminary objection in the form of a demurrer for legal insufficiency of a pleading. Pa.R.C.P. No. 1028(a)(4). Stated another way, a demurrer is an assertion by a party that, although the facts alleged by the opposing party may be true, the facts do not entitled them to prevail in the lawsuit. In determining whether a demurrer should be sustained and the complaint dismissed, the court should consider whether, on the facts averred, the law says with certainty that no 21 Prelim, Obj., IM 15-8. 4 recovery is possible. Hoffman v. Misericordia Hospital of Philadelphia, 267 A.2d 867, 868 (Pa. 1970) (citing King v. U.S. Steel Corp., 247 A.2d 563 (Pa. 1968); Sun Ray Drug Co. v. Lawler, 79 A.2d 262 (Pa. 1951)). Accepting all material averments as true, the court must determine whether the law says with certainty that no recovery is possible. Mistick, Inc. v. Northwestern Nat'l Cas. Co., 806 A.2d 39, 42 (Pa. Super. 2002). Where the complaint shows on its face that the claim is devoid of merit, the demurrer should be sustained. Hoffman, 267 A.2d at 868. Accepting as true the averments this court is able to understand in Plaintiffs initial Complaint and in the Complaint Action Details to Computer Fraud, this court is unable to deduce any allegations in the pleadings that assert a legally cognizable cause of action. Plaintiffs description of the lawsuit as an action for "Mr. Goin Postal . . . to return that money taken from my accout [sic] as stlen [sic] money" leads this court to believe that Plaintiff expects Defendant to provide him with a refund for the services for which Plaintiff paid Defendant. This court will not entertain suggestions of such relief, particularly when Plaintiff has failed to aver facts that would show he has a legal claim against Defendant warranting such restitution. Neither the Complaint nor Complaint Action Details to Computer Fraud adequately states a claim for relief under any theory of law. Therefore, this court will sustain Defendant's preliminary objection in the form of a demurrer. Failure of a pleading to conform to rule of court, generally. A party may file a preliminary objection to any pleading for failure to conform to law or rule of court or inclusion of impertinent or scandalous matter. Pa.R.C.P. No. 1028(a)(2). Defendant has filed Preliminary Objections to Plaintiffs Complaint regarding its failure to contain a 5 caption, notice to defend, verification, or numbered paragraphs, in violation of Pennsylvania Rules of Civil Procedure 1018, 1018.1, 1022, and 1024. Caption. Every pleading must contain a caption setting forth the name of the court, the number of the action, and the name of the pleading. Pa.R.C.P. No. 1018. The caption of a complaint shall set forth the form of the action and the names of all the parties. Id. Improper captioning is a trivial detail, easily correctable by amendment; it is hardly grounds for dismissing a complaint outright. Commonwealth. ex rel. Specter v. Bauer, 261 A.2d 573, 574 n.2 (Pa. 1970). Neither Plaintiffs Complaint nor Complaint Action Details to Computer Fraud contained a proper caption. While Defendant's objection accurately points out that Plaintiff's pleadings fail to comply with Rule 1018, this mistake does not constitute grounds for dismissal with prejudice. Paragraphing. A complaint must be divided into paragraphs numbered consecutively, Pa.R.C.P. No. 1022. Generally,.the test of compliance with this rule is the difficulty or impossibility one has in answering the complaint. General State Authority v. Sutter Corp., 356 A.2d 377, 380 (Pa. Cmwlth. 1976). "A lengthy and complex paragraph does not violate Rule 1022, if the subsidiary facts fit together in a single allegation." Bethlehem Steel Corp. v. Litton Industries, Inc., 71 Pa. D. & C.2d 635, 643 (Allegheny Cnty. 1974). Where a complaint has improperly lumped numerous claims in a single paragraph, it is better to dismiss the complaint and require the filing of a new one rather than to order a more specific complaint that properly notifies the defendant of the basis of the claim, so that there will be only one complaint of record 6 II and the defendant is able to file an answer to each transaction. Hildebrant v. Kline, 66 Pa. D. & C. 431, 435-6 (Columbia Cnty. 1948). Plaintiff has failed to divide any of his pleadings into numbered paragraphs. Where Plaintiff's writing appears to be broken into sections, each section contains information beyond one material allegation, when it certainly would have been practicable for each paragraph to set forth one material allegation as required by Rule 1022. Plaintiff's pleadings contain lengthy and complex paragraphs, and any subsidiary facts cannot be made to fit together in a single allegation. This court determines that it would be difficult, if not impossible, for Defendant to answer Plaintiffs pleadings with admissions or denials of the facts averred. Plaintiff's failure to comply with Rule 1022 has significantly impaired this court's ability to decipher the facts on which Plaintiff bases his claim. This court is also unable to comprehend Plaintiff's legal claim(s). Plaintiff should note that clear presentation of factual allegations and legal claims will aid this court in any future consideration of whether Plaintiff has averred facts on which the law can provide recovery. Verification. The Pennsylvania Rules of Civil Procedure require a verification regarding the party's personal knowledge of facts averred. Specifically, a pleading containing an averment of fact not appearing of record in the action or containing a denial of fact shall state that the averment or denial is true upon the signer's personal knowledge or information and belief and shall be verified. Pa,R.C.P. No. 1024(a). The term "verified" means supported by oath or affirmation or made, subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Pa.R.C.P. No. 76. "[P]rocedural rules are not ends in themselves, but means whereby justice, as 7 expressed in legal principles, is administered." Johnston v. Shapp, 57 Pa. D. & C.2d 753, 755 (Dauphin Cnty. 1972) (quoting Esso Stand Oil Co. v. Taylor, 159 A.2d 692 (Pa. 1960)). Plaintiffs Complaint and Complaint Action Details to Computer Fraud both appear to contain averments of fact not appearing of record; however, neither pleading includes the verification required by the Pennsylvania Rules of Civil Procedure. This court does not wish to make the procedural rules into ends in themselves, but notes that the requirement of verification of averments of fact is a means by which justice can be administered. Notice to defend. Every complaint must begin with a notice to defend. Pa.R.C.P. No. 1018.1. The failure to endorse a pleading with the proper notice relieves the opposing party of the obligation to file a responsive pleading. Mother's Restaurant Inc. v. Krystkiewicz, 861 A.2d 327, 338 (Pa. Super. 2004). If such notice is not included in the complaint, the consequence is that no responsive pleading need be filed. Gerber v. Emes, 511 A.2d 193, 198 (Pa. Super. 1986). Neither Plaintiffs Complaint nor Complaint Action Details to Computer Fraud contained a notice to defend. Plaintiff's failure to include a notice to defend in either pleading simply relieved Defendant of the obligation to file a responsive pleading. This court will not impose any sanction for failure to include a notice to defend, but Plaintiff is strongly encouraged to comply with such procedural requirements when filing documents in this court in the future. 8 This court notes that Plaintiff failed to attach a certificate of service or otherwise indicate that he served the Complaint on Defendant as required by Pa.R.C.P. No. 440(a)(1); however, Defendant waived its objection on this ground. For the foregoing reasons, the following order will be entered: ORDER OF COURT AND NOW, this 23rd day of May 2013, upon consideration of Defendant's Preliminary Objections to Plaintiffs Complaint, and following argument held on 15 February 2013, Defendant's Preliminary Objections are sustained in part as follows: 1. Defendant's preliminary objection in the nature of a demurrer relating to Plaintiff's Complaint is SUSTAINED; 2. Defendant's preliminary objections relating to Plaintiff's failure to include a caption, verification, or numbered paragraphs are SUSTAINED; 3. Defendant's preliminary objection relating to Plaintiffs failure to attach a notice to defend is SUSTAINED; 4. Defendant's preliminary objection relating to Plaintiff's failure to attach a certificate of service or otherwise indicate that he served the Complaint on Defendant is deemed MOOT. Plaintiff is permitted to file a new complaint that conforms to the Pennsylvania Rules of Civil Procedure within thirty (30) days of this Order of Court. BY T Thomh K Placey, C.P.J. Distribution: Gordon Luce David R. Galloway, Esq. 9