HomeMy WebLinkAbout13-1093DEBORAH M. CALDWELL-DOBBINS IN THE COURT OF COMMON PLEAS
As Administrator of the Estate of OF CUMBERLAND COUNTY,
Herbert C. Caldwell, III, PENNSYLVANIA
Plaintiff '
VS : I
DAVID BECKER
Defendant CIVIL ACTION -EQUITY (REV+P~
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE
CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN
TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED BY
ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND
FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE
CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO
SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED
AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY
CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM RELIEF REQUESTED BY
THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER IMPORTANT
RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT
HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PENNSYLVANIA 17013 ~°°~~
(717) 249-3166
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By:
teven well, Esquire
Howell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063 S
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..
DEBORAH M. CALDWELL-DOBBINS,
As Administrator of the Estate of
Herbert C. Caldwell, III,
Plaintiff
VS ;
DAVID BECKER,
Defendant .
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
No.
CIVIL ACTION -EQUITY (REPLEVIN)
COMPLAINT
1. Deborah M. Caldwell-Dobbins, is an adult individual residing at 870 Lexington
Place, Lewisberry, York County, Pennsylvania 17339.
2. David Becker is an adult individual operating a business located at Becker's Service
Center, 3150 Gettysburg Road, Camp Hill, Cumberland County, Pennsylvania
17011.
3. Deborah M. Caldwell-Dobbins is the Administrator of the Estate of Herbert C.
Caldwell, III.
4. David Becker was a family friend of the Decedent and offered to hold in
safekeeping several firearms of the Decedent following his death on December 17,
2004 to prevent inadvertent access to the Decedent's minor children.
5. David Becker has executed an Affidavit stating that he has in his possession the
following six (6) firearms belonging to the Estate:
a. Smith & Wesson .357 (SN 106K587)
b. Smith & Wesson .38 (SNABJ2245);
c. Intratec Caliber 9mm (SN17875);
d. Rifle (SN 24002879);
e. Ruger Rifle (SN 183-02895) in .223 (5.56mm); and
f. WWII Handgun.
6. David Becker is believed to have in his possession a firearm described as:
a. Daniel Defense Sub-Machine Gun (Cobray M-11) in 9mm (SN 86-
0005999) which is a Class III fully automatic firearm registered with the
Bureau of Alcohol Tobacco and Firearms in its National Firearms
Registry.
7. Plaintiff has requested the return of the firearms from the Defendant.
8. Defendant has refused to return the firearms to the Plaintiff
WHEREFORE, Plaintiff requests entry of judgment in her favor for the return of
all the firearms set forth in Paragraphs 5 and 6 of this Complaint plus costs of suit and
interest at the legal rate.
Respectfully submitted,
By:
Dwell Law Firm
619 Bridge Street
New Cumberland, PA 17070
Supreme Court ID 62063
(717) 770-1277
Attorney for Plaintiff
Date: February 25, 2013
VERIFICATION
I/we verify that the statements made in the foregoing document are true and
correct. I/we understand that false statements herein are made subject to the penalties of
18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities.
BY: ,~.
orah M. Caldwell-Dob ins
Administrator of the Estate
of Herbert C. Caldwell, III
Date:
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson FILEO-OFFICE
Sheriff OF THE PROTHONOTA
Jody S Smitha��v�tn at L►«r�gr�
Chief Deputy ,, 2013 MAR 18 AM 9: 55
Richard W Stewart CORLAHDOHTY
Solicitor OFFICE OF THE$HERIFF PtNNSYLVANIA
Deborah M Caldwell-Dobbins
vs.
Case Number
David Becker 2013-1093
SHERIFF'S RETURN OF SERVICE
03/07/2013 02:17 PM- Deputy William Cline, being duly sworn according to law, served the requested Complaint&
Notice by handing a true copy to a person representing themselves to be Ray Via, Tow Truck Driver for
Business,who accepted as"Adult Person in Charge"for David Becker at Becker' Service Center, 3150
Gettysburg Road, Lower Allen, Camp Hill, PA 17011.
vVIL-LiAKA CLINE, DEPUTY
SHERIFF COST: $58.00 SO ANSWERS,
March 08, 2013 RONW R ANDERSON, SHERIFF
ic)CountySuite Sheriff,Teieosof; ,nc.