The URL can be used to link to this page

Home My WebLink About13-3353 Supreme CouftofTennsylvania Court'ac mo �PIeaS For Prothonotary Use Only: Cvil(Co erShe�et Docket No: vi, L. _ 5 CUMBERLAND ` � County 13 - 3 3 s �-.�- The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by Icnv or rules of court. Commencement of Action: S EJ Complaint 0 Writ of Summons 0 Petition 0 Transfer from Another Jurisdiction 0 Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: T BARBARA S. GORMAN CURTIS T. REESE& REESE CUSTOM BUILDERS, INJi Dollar Amount Requested: within arbitration limits I Are money damages requested? x Yes 0 No O (check one) []outside arbitration limits N Is this a Class Action Suit? 0 Yes x No Is this an MDJAppeal? Yes El No A Name of Plaintiff/Appellant's Attorney: R. MARK THOMAS, ESQUIRE 0 Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 0 Intentional 0 Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Debt Collection: Credit Card 0 Board of Assessment 0 Motor Vehicle 0 Debt Collection: Other 0 Board of Elections 0 Nuisance 0 Dept. of Transportation 0 Premises Liability Statutory Appeal: Other S 0 Product Liability (does not include E mass tort) El Employment Dispute: El Slander/Libel/ Defamation Discrimination C 0 Other: Employment Dispute: Other E3 Zoning Board T , Other: I Q Other: O MASS TORT BREACH OF CONTRACT 0 Asbestos N 0 Tobacco Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste 0 Other: El Ejectment 0 Common Law /Statutory Arbitration B 0 Eminent Domain /Condemnation 0 Declaratory Judgment Ground Rent 0 Mandamus 0 Landlord/Tenant Dispute Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial Quo Warranto 0 Dental 0 Partition Replevin 0 Legal 0 Quiet Title 0 Other: 0 Medical 0 Other: 0 Other Professional: Updated 1/1/2011 BARBARA S. GORMAN : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff `= _� :CIVIL ACTION at LAW - v a Zz M cc c.... ;; .: V. rn c= �.. 1 -33 ai"! CD CURTIS T. REESE and ! ��' 3 {--~ REESE CUSTOM BUILDERS, INC v 7 j- -r uo _. Defendants c n NOTICE TO DEFEND 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 AN 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 PROCEEDWITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH 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 REDUECED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1- 800 - 990 -9108 717 - 249 -3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans With Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court You must attend the scheduled conference or hearing. J / 0/7 BARBARA S. GORMAN : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff :CIVIL ACTION at LAW V . l3 - "335 3 C�,��f��. CURTIS T. REESE and REESE CUSTOM BUILDERS, INC Defendants COMPLAINT AND NOW, comes the Plaintiff, Barbara S. Gorman, by and through her counsel, R. Mark Thomas, Esquire, and files this Complaint against the above captioned Defendants and in support thereof respectfully represents: 1. Plaintiff is an adult individual who resides at 108 Monarch Lane, Mechanicsburg, Pennsylvania 17050. 2. Defendant, Curtis T. Reese, is an adult individual whose residential address is unknown, but his place of employment, Reese Custom Builders, Inc, maintains their office at 525 S. York Road, Dillsburg, Pennsylvania 17019. 3. Defendant, Reese Custom Builders, Inc. is a corporation organized and existing under the laws of Pennsylvania with its principal place of business at 525 S. York Road, Dillsburg, Pennsylvania 17019. 4. On or about August 24, 2011, the parties hereto entered an oral Agreement whereby Plaintiff would loan Defendants $7,100.00 in exchange for promises from Defendants to repay the loan in full within a couple of weeks. 5. At the time of the Agreement, Defendant Curtis T. Reese advised Plaintiff that the $7,100.00 was for the benefit of Defendant Reese Custom Builders, Inc. 6. On the basis of Defendant's promise to repay the $7,100., Plaintiff gave Defendants a check in the amount of $7,100. 7. Defendants cashed the check and obtained proceeds of $7,100. from Plaintiff's account. 8. Ten (10) months have passed without either Defendant making a payment, either partial or in full. 9. Defendant's failure to repay the $7,100. is a breach of the oral Agreement between the parties. WHEREFORE, Plaintiff prays that this Honorable Court will enter judgment in favor of Plaintiff and against each Defendant in the amount of $7,100.00 plus court costs, attorney's fees and interest as the law may allow. Respectfully submitted, Ag/-" - R. Mark Thomas, Esquire ID# 41301 101 S. Market Street Mechanicsburg, PA 17055 (717) 796 -2100 VERIFICATION I verify that the statements made in the foregoing Civil Complaint 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 unworn falsification to authorities. Date: O ZaO /.3 Qn�-� BARBARA S. GO A SHERIFF'S OFFICE OF CUMBERLAND COUNTY s —0F F r Ronny R Anderson ;f° THE Sheriff (i}} JUL s J{ pyailX.v 4�, ItiP�l7i f xya} �E!13 UL 16 iii�i 9' V�� Jody S Smith •, Chief Deputy o rI�1aR t°r , Richard W Stewart �t� Y��Af , t Solicitor OFF`E OF THE=M=R'pr Barbara S. Gorman Case Number vs. Curtis Reese (et al.) 2013-3353 SHERIFF'S RETURN OF SERVICE 06/11/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Curtis Reese, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Complaint& Notice according to law. 06/11/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Reese Custom Builders, Inc., but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Complaint& Notice according to law. 06/25/2013 06:15 PM -The requested Complaint&Notice served by the Sheriff of York County upon Curtis Reese, Owner, who accepted for Reese Custom Builders, Inc., at 525 S. York Road, Dillsburg, PA 17019. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. 06/25/2013 06:15 PM-The requested Complaint& Notice served by the Sheriff of York County upon Curtis Reese, personally, at 525 S. York Road, Dillsburg, PA 17019. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $53.46 SO ANSWERS, July 10, 2013 RON r R ANDERSON, SHERIFF (c)CountySuito Sheriff,Toleosott,Inc. SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber PETER J. MANGAN, ESQ. Sheriff Solicitor Reuben B Zeager Richard E Rice, 11 Chief Deputy, Operations Chief Deputy,Administration BARBARA S. GORMAN Case Number vs. 13-3353 CURTIS T. REESE(et al.) SHERIFF'S RETURN OF SERVICE 06/25/2013 06:15 PM-DEPUTY MICHAEL S. ECKARD, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT& NOTICE BY"PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT: CURTIS T. REESE AT 525 SOUTH YORK ROAD, DILLSBURG, PA 17019. AcF CDEPUTY 06/25/2013 06:15 PM-DEPUTY MICHAEL S. ECKARD, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT& NOTICE BY HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE CURTIS REESE, OWNER, WHO ACCEPTED AS"ADULT PERSON IN CHARGE" FOR REESE CUSTOM BUILDERS, INC.AT 525 SOUTH YORK ROAD, DILLSBURG, PA 17019. 10 CIO C CKAR , DEPUTY SHERIFF COST: $121.40 SO SWE July 08, 2013 RICHARD P KEUERLEBER, SHERIFF COMMONW 11, 9E PENNSYLVANIA "riai seal Sheila E.Co*Notary Public City of York,York County My CO MMISS on EOres Feb.1,2017 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES ---------------- --- -------------------------------------------------------------- ----- ---------------- .................. NOTARY Affirmed and subscribed to before me this 8TH day of JULY 2013 (c)CountySuite Sheriff,Teleosoft,inc. BARBARA S. GORMAN : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff , :CIVIL ACTION at LAW V. . _ Civil No. 13-3353 CURTIS T. REESE and REESE CUSTOM BUILDERS,INCA ' ' ;:..= Defendants PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT _ TO THE PROTHONOTARY: As shown on the attached certification,Notice of Intent to Enter Default Judgment on the Defendant's was served on each Defendant. More than ten (10) days have passed and neither Defendant has filed a response. Therefore, kindly enter judgment in favor of Plaintiff and against each Defendant in the amount of$7,000.00,plus costs. Respectfully submitted, �' aoad� Date R. Mark Thomas, Esquire Attorney for Petitioner 101 South Market Street Mechanicsburg, PA 17055 ID#. 41301 Telephone: 717-796-2100 G.'570 Pay , �g- Y� s rq CERTIFICATION 1,R. Mark Thomas, Esquire,hereby certify that on August 8, 2013,each Defendant was served with the attached Notice by certified mail,return receipt requested, and no response has been filed. R. Mark Thomas, Esquire Attorney for Petitioner 101 South Market Street Mechanicsburg, PA 17055 ID#. 41301 Telephone: 717-796-2100 I SENDER:COMPLETE THIS SECTION COMPLETETHIS SECTION• DELIVERY ■ Complete items 1,2,and 3.Also complete X Sig item 4 if Restricted Delivery is desired. 0 Agent ■ Print your name and address on the reverse X 1-1 Addressee so that we can return the card to you. B. R lvedrby(Printed Name) lvery ■ Attach this card to the back of the mailpiece, 1) �� C.DF`?1oj Del or on the front if space perTnits. NO I ly- J '�-/13 D. Is de 1 Article Addressed to: livery address ri 1?10 Yes If YES,enter delivery address below: CR.No 's 3. Service Type P/4- U—certifted Mall ❑Express mail 13 Registered 1"eturn Receipt for Merchandise /-0/ 0 insured Mail 0 C.O.D. 4. Restricted Delivery?(Extra Fee) 0 Yes 2. Article Number (rhansfer from service(abet) PS Form 3,811,February 2004 Domestic Retum Receipt 102595-02-M-1540 SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION• DELIVERY ■ Complete Items 1,-Z and 3.Also complete A. Sig re item 4 if Restdptea'Delivery Is desired. 0 Agent ■ Print your name and address on ther X everse 13 Addressee so that we can return the card to you. BM v Ivy( )Md Name) C D e of Delivery ■ Attach this card to the back of the mallpleoe, or on ft front If space permits. 1 1 1 1 E D. Is deliver 1. Article Addressed to: y, 0 y6s ff YES,enter delivery address below: ARI No T Rea V Uup"' I�70t 3. Service Type )FdCertified Mail 0 Express Mail 13 Registered t&Retum Receipt for Merchandise ❑Insured Mail 13 C.O.D. 4. Restricted Delivery?(Extra Fee) 0 Yes 2. Article Number (Transfer from service/abet, 7004 2510 0001 05285464 PS Form 3811.,February 2004 Domestic Return.Receipt 102595-02-M-1640 BARBARA S. GORMAN : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff V. :CIVIL ACTION at LAW CURTIS T. REESE and Civil No. 13-3353 REESE CUSTOM BUILDERS, INC Defendants , NOTICE OF PRAECIPE TO ENTER JUDGA1ENT BY DEFAULT TO: Curtis T.Reese 525 S.York Road Dillsburg,PA 17019 Date of Notice: July ,2013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES T ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PENNSYLVANIA 17013 TELEPHONE: (717)-249-3166 R. Mark Thomas, Esquire Attorney No. 41301 101 South Market Street Mechanicsburg, PA 17055 Telephone: 717-796-2100 Attorney for Plaintiff CEBTIIFICATE OF SERVICE I, R. Mark Thomas, Esquire,hereby certify that I have served a copy of the Notice of Principe to Enter Judgment by Default'on the below listed Defendant by sending such Notice both by Certified Mail,Return Receipt Requested, and by first class mail,postage prepaid, and addressed as follows: Curtis T.Reese 525 S. York Road Dillsburg, PA 17019 e DATE: July o� f, 2013 �_ R. Mark T omas, Esquire BARBARA S. GORMAN IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff :CIVIL ACTION at LAW V. Civil No. 13-3353 CURTIS T. REESE and REESE CUSTOM BUILDERS,INC Defendants NOTICE OF PRAECITE TO ENTER JUDGMENT BY DEFAULT TO: Reese Custom Builders 525 S.York Road Dillsburg,PA 17019 Date of Notice: July A-1 V 1 2013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES T ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PENNSYLVANIA 17013 TELEPHONE: (717)-24�Z-Y-66 R. Mark Thomas, Esquire Attorney No. 41301 101 South Market Street Mechanicsburg, PA 17055 Telephone: 717-796-2100 Attorney for Plaintiff CERTTF cA OF SERVICE I, R. Mark Thomas, Esquire, hereby certify that I have served a copy of the Notice of Principe to Enter Judgment by Default on the below listed Defend ant by sending such Notice both by Certified Mail, Return Receipt Requested, and by first class mail,postage Prepaid, and addressed as follows: Reese Custom Builders 525 S. York Road Dillsburg, PA 17019 DATE: July A 7 , 2013 R- Mark Thomas, Esquire e