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HomeMy WebLinkAbout13-7282 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL 9TH Judicial District, County Of CUMBERLAND FROM MAGISTERIAL DISTRICT JUDGE JU COMMON PLEAS No. 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 Magisterial District Judge on the date and in the case referenced below. NAME OF APPELLANT MAG. DIST. NO. NAME OF MDJ LEFFLER ENERGY 09 -3 -05 MARK MARTIN ADDRESS OF APPELLANT CITY STATE ZIP CODE 102 BROWNING LN BLDG B STE 1 CHERRY HILL NJ 08003 DATE OF JUDGMENT IN THE CASE OF (Plaintift) (Defendant)' 11/13/13 LEFFLER ENERGY VS HOPE CULLEY DOCKET No. SIGNATURE OF AP LLANT OR ATTORNEY OR AGENT This block will be signed ONLY when this notation is required under Pa. If appellant was Claimant (see Pa. R.C. P. D.J. No` 1U01(6) in action R.C.P.D.J. No. 10088. This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COMPLAINT MUST BE FILED operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty (20) days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before Magisterial District Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon appellee(s), to file a complaint in this appeal Name of appellee(s) (Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or attorney or agent RULE: To appellee(s) Name of appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAYBE ENTERED AGAINST YOU. 3 The date of service of this rule if service was by mail i f M.in Date: .20 O 1330 E01 Signature of Prothonotary or Deputy YOU MUST INCLUDE A COPY OF THE NOTICE;Q;FO ,,,(� S8 IPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312 -05 CAL tV I - a010, COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ- 09 -3 -05 Leffler Energy MDJ Name: Honorable Mark Martin V. Address: 507 North York Street Hope CUlley Mechanicsburg, PA 17055 Telephone: 717- 766 -4575 9: Leffler Energy Docket No: MJ- 09305 -CV- 0000169 -2013 c/o Lloyd S Markind Esq Case Filed: 9/30/2013 102 Browning Ln Bldg B Ste 1 Cherry Hill, NJ 08003 Disposition Details P Dis osition Summary (cc- Cross Complaint) - Docket No Plaintiff Defendant Disp osition Disposition Date MJ- 09305 -CV- 0000169 -2013 Leffler Energy Hope Culley Judgment for Defendant 11/13/2013 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, SETTLS, OR OTHERWISE COMPLIES WITH THE JUDGMENT. Date Magisterial District Judge Mark Martin certify that this is a true and correct copy of the record of the proceedings containing the judgment. Date Magisterial District Judge - a ' t - 11 W312013 11:09:13AM MDJS 315 Page 1 of 2 Leffler Energy Docket No.: MJ- 09305 -CV- 0000169 -2013 V. Hope Culley Participant List Private(s) Lloyd S. Markind, Esq. Sklar - Markind 102 Browning Lane Building B - Suite 1 Cherry Hill, NJ 08003 Plaintiff(s) Leffler Energy c/o Lloyd S Markind Esq 102 Browning Ln Bldg B Ste 1 Cherry Hill, NJ 08003 Defendant(s) Hope Culley PO Box 701 Mechanicsburg, PA 17055 MDJS 315 Page 2 of 2 Printed: 11/13/2013 11:09:13AM a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LEFFLER ENERGY : No. Plaintiff TERM vs. CIVIL ACTION HOPE CULLEY Defendant CERTIFICATION OF SERVICE /COMPLIANCE MATTHEW BUTLER, of full age, hereby certifies as follows: 1. I am a paralegal employed with the SKLAR — MARKIND. 2. On / Zlq ! / � , I served copies of the Notice of Appeal from District Justice on defendant(s), HOPE CULLEY , by sending them simultaneously by regular mail to: Hope Culley 3526 Rolo Court Mechanicsburg PA 17055 I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. Dated: Zy G I MATTHEW BUTLER File No.: M 11003 86 f Markind Law Group, P.C. Lloyd S. Markind, Esquire (ID #52507) F, r d.. gt 102 Browning Lane i�[E PRO,O,1` uo i Building B, Suite 1 �t � Cherry Hill,NJ 08003 FC 30 P11 3. f File No.: M1100386 r U BERLAN, COUNTY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PEN I� YLANIA CIVIL ACTION-LAW LEFFLER ENERGY : No. 13-7282 CIVIL Plaintiff TERM VS. . CIVIL ACTION HOPE CULLEY Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty(20) days after this complaint and notice are served,by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: 717-249-3166 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientas, usted tiene veinte (2) dias de plazo al partir de la fecha de la demanda y la notificaion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra sya sin previo aviso o notificaion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE SI NO TIENE ABOGADO O SI NO TIENE EL D1NERO SUFICIENTE DE PAGAR TAL A LA OFICINA CUY A DIRECION SE ENCUENTRA ESCRITA ABAJO PARA AVERGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: 717-249-3166 Lloyd S. Markind,Esquire(ID#52507) Markind Law Group, P.C. 102 Browning Ln,Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-87.10 FILE NO.: M1100386 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION-LAW LEFFLER ENERGY 113 MAIN STREET I No. 13-7282 CIVIL TULLYTOWN PA 19007 I I Term I Plaintiff(s) I CIVIL ACTION V. I COMPLAINT I Hope Culley PO BOX 701 MECHANICSBURG PA 17055-0701 I Defendant(s) 1.Plaintiff herein is LEFFLER ENERGY located at 113 MAIN STREET, TULLYTOWN PA 19007. 2.Defendant herein is HOPE CULLEY , an individual, currently receiving mail at PO BOX 701,MECHANICSBURG PA 17055-0701. 3.Throughout the years 2011-2012 plaintiff provided oil heating services on behalf of the defendant(s). 4.Defendant(s)agreed to pay the reasonable value of these services as they were billed by plaintiff. . (A true and correct copy of the invoice is attached hereto as"Schedule"A" and made a part hereof.) 5.After credit for all payments made,the fair and reasonable value of the oil heating services provided to defendant(s)is$826.39 . 6.Although demand has been made upon the defendant(s)for payment of the balance of $826.39 the defendant(s)has failed and refused to pay same. WHEREFORE,plaintiff demands judgment against the defendant(s) in the amount of $826.39 with interest and costs of this action. Markind Law Group,P.C. Lloyd S.Markind,Esquire Attorney for Plaintiff (ID#52507) 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 Dated: r � VERIFICATION I, Lloyd S. Markind, Esquire, of the law firm of Markind Law Group, P.C., hereby state and verify that my firm is counsel for Plaintiff in this action; that we have reviewed certain documents and/or other records provided to us by Plaintiff for the filing of a Complaint in this action; that a substitute Verification executed by an officer or other employee of Plaintiff will be filed as soon as same is received; and that the Complaint filed herewith is true and correct to the best of my knowledge, information and belief. The undersigned understands that the.statement made therein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsifications to authorities. Lloyd S. Markind, Esquire Date: � File No.: M 11003 86 Exhibit A 70 � . 0 - W4W< ] E = m (D .m 0) C:) - & \ / / k \ � \ 0 � ' 3 $ cum q % 'o o / / o o � NJ 3 rn o \22 CL (A O -4 -4 \ qr w000 f.0 @ /r- 0(D / 9m9 � � m c � � fa) mm . M -4 ® ^ C� m ;KAmm 7 (D Jk 2m mmm0 J - a ¥ m mm ' \ � @2 99 � E $ :3 = 2 > m m �� £ X2 ' 2 \a » m m m @ ƒ 0 2 > 3 C CD / Z C � \( / 0 aq ƒ \ m w « & & / (D - ow # eN) = � � � - (D 0j oaN) cm # « � (C) amo > E ° -0 � \ \ S � (D § 2. k0 2 / \ .$ E 7 _ © k a `CD \ \ O/ / \ k \ ' � k ^ . � \ 2 -1CD A. � 2 % w . CL I\ " 7 � f $ o 0 22 R E G � > Ek 2 R 9 q / § E G n • mow ¢ ck 4d \ % fQUn 2 99m = ooa � m a \ ) � q $ woo � oe (D CD . 2 . am . CD A . /m \ . d_ 7 � ¢ . \ CD . @ � IQ $ w� oio e :Nwo ] 000 = wo Ya _ t. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW p r, LEFFLER ENERGY : No. 13-7282 CIVIL Plaintiff TERM X VS. CIVIL ACTION HOPE CULLEY Defendant CERTIFICATION OF SERVICE/COMPLIANCE Matthew Butler, of full age, hereby certifies as follows: 1.I am a paralegal employed with the Markind Law Group, P.C.. 2. On, I served copies of the filed Notice of Appeal on defendant(s), HOPE CULLEY and DISTRICT COURT 09-3-05, by sending them simultaneously by regular and certified mail, return receipt requested to: Hope Culley PO BOX 701 MECHANICSBURG PA 17055-0701 DISTRICT COURT 09-3-05 BARCLAY BUILDING MECHANICSBURG,PA 17055 I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. Dated: 17- Z6 /3 File No.: M1100386 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW LEFFLER ENERGY : No. Plaintiff TERM vs. CIVIL ACTION HOPE CULLEY Defendant : CERTIFICATION OF SERVICE/COMPLIANCE MATTHEW BUTLER, of full age, hereby certifies as follows: 1. I am a paralegal employed with the SKLAR-MARKIND./ 2. On f 2-`q 1 6 I served copies of the Notice of Appeal from District Justice on defendant(s), HOPE CULLEY , by sending them simultaneously by regular mail to: Hope Culley 3 526 Rolo Court Mechanicsburg PA 17055 I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. Dated: MATTHEW BUTLER File No.: M1100386 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL 9TH Judicial District, County Of CUMBERLAND FROM i MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS No. L 0a NOTICE OF APPEAL No Lice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District "edge on the date and in the case referenced below. NAME OF APPELLANT MAG.DIST.NO. NAME OF MDJ LEFFLER ENERGY 09-3-05 1 MARK MARTIN ADDRESS OF APPELLANT CITY STATE ZIP CODE 102 BROWNING LN BLDG B STE 1 CHERRY HILL NJ 08003 DATE OF JUDGMENT IN THE CASE OF(Plaintiff) (Defendant)' 11/13/13 LEFFLER ENERGY VS HOPE CULLEY DOCKET No. SIGNATURE OF P. LLANT OR ATTORNEY OR^AAGENT This block will be signed ONLY when this notation is required under Pa. If appellant was Claimant (see Pa. R.C.P.D.J. No. 1001(6) in action R.C.P.D.J. No. 1008B. This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A COMPLAINT MUST BE FILED operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty (20)days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT(see Pa.R.C.P.D.J. No. 1001(7) in action before Magisterial District Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon appellee(s),to file a complaint in this appeal Name of appellee(s) (Common Pleas No. )within twenty(20)days after service of rule or suffer entry of judgment of non pros. Signature of appellant or attorney or agent RULE: To appellee(s) Name of appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty(20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time,a JUDGMENT OF NON PROS MAYBE ENTERED AGAINST YOU. (3) The date of service of this rule if service�wa1s�by0ig the date of the mailing. Date: 20 AIN,603 001839WN Signature of Prothonotary or Deputy +i�1 :ej WV 01 330 E141 YOU MUST INCLUDE A COPY( ICI.1*, r l6„i,!JUO'bMENT/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. 3iJA -C.a :H AOPC 312-05 Y 7 I COMMONWEALTH OF PENNSYLVANIA Notice Of JUCIg111e11tlTranS cript COUNTY OF CUMBERLAND x Case Mag. Dist. No: MDJ-09-3-05 Leffler Energy MDJ Name: Honorable Mark Martin V. Address: 507 North York Street Hope CUlley Mechanicsburg,PA 17055 1,{'IGt Telephone: 717-766-4575 "` 013 Leffler Energy Docket No: MJ-09305-0"0000169'2 c/o Lloyd S Markind Esq Case Filed: 9/30/2013 102 Browning Ln Bldg B Ste 1 Cherry Hill, NJ 08003 Disposition Details to DISpOSitlOn Summary (cc-Cross Complai'nt)_._ ....___.__...___ .____ __._......._..,.__. _... ... _.� _____ . • Dj5 j1�013j2013 Docket No Plaintiff Defendant Disposition MJ-09305-CV-0000169-2013 Leffler Energy Hope Culley Judgment for Defendant E OF AP NO KGB OF ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOT1OpF TNjS GMENE THE PROTHONOTARY/CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY -fNE s RpM�N JUDGMENT/TRANSCRIPT EXCEPT OTHERWISE PROVIDED IN NOTICE OF OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JVOO'EST'DOME f S HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUS N.r M SYEllt'BS COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JU00j pGME 0 -' UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JVYS jN F REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR OR OTHERWISE COMPLIES WITH THE JUDGMENT. > s� F mr- Date Magisterial District Judge Mark Martin certify at this is a true and correct copy of the record of the proceedings containing the judgment. Date Magisterial District Judge 1 Pid- `113'ZC t MDJS 315 Page 1 of 2 Leffler Energy Docket No.: MJ-09305-CV-0000169-2013 V. Hope Culley Participant List Private(s) Lloyd S. Markind,Esq. Sklar-Markind 102 Browning Lane Building B-Suite 1 Cherry Hill, NJ 08003 Plaintiff(s) Leffler Energy c/o Lloyd S Markind Esq 102 Browning Ln Bldg B Ste 1 Cherry Hill, NJ 08003 Defendant(s) Hope Culley PO Box 701 Mechanicsburg,PA 17055 MDJS 315 Page 2 of 2 Printed: 11/13/2013 11:09:13AM t 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW LEFFLER ENERGY : No. 13-7282 CIVIL 2Qf4`�� Na4,de � Q .11'i- : TERM CO ,P4,4 Ply`�.4 4 vs. ; CIVIL ACTION '00/ l,i HOPE CULLEY : Defendant • • CERTIFICATION OF SERVICE/COMPLIANCE MATTHEW BUTLER, of full age,hereby certifies as follows: 1.I am a paralegal employed with the MARKIND LAW GROUP, P.C. 2. On 117111 , I served copies of the (Magisterial District Justice Appeal) Complaint,Notice to Defend and Verification on defendant(s), HOPE CULLEY , by sending them simultaneously by regular and certified mail, return receipt requested to: Hope Culley PO BOX 701 MECHANICSBURG PA 17055-0701 I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. Dated: V M MATTHEW BUTLER File No.: M1100386 Disclosure You are hereby advised, pursuant to the Fair Debt Collection Practices Act,that this firm is deemed to be a debt collector attempting to collect a debt and any information obtained will be used for that purpose. -IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LEFFLER ENERGY : No. 13-7282 CIVIL Plaintiff { • m trs vs. • HOPE CULLEY :CIVIL ACTION Defendant >c-.) :17.c` •• a._ ter, PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification to the Complaint in lieu of the Attorney Verification originally attached. Lloyd S. Markind, Esquire Attorney for Plaintiff ID #52507 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 Disclosure You are hereby advised,pursuant to the Fair Debt Collection Practices Act,that this firm is deemed to be a debt collector attempting to collect a debt and any information obtained will be used for that purpose. FILE NO.: M1100386 VERIFICATION , deposes and says that he/she is authorized to make this verification on behalf of the plaintiffs and that the facts set forth in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsifications to authorities. Date: l' File No.: Ml 1003 86 Hope Culley r i1 U-OFF4C P 0 Box 701 »L THE PROTHONO TAR't Mechanicsburg, PA 17055 2014JAN29 Pfl 1: 53 Defendant CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW LEFFLER ENERGY I No. 13-7282 CIVIL 113 MAIN STREET I TULLYTOWN PA 19007 I Term Plaintiff(s) CIVIL ACTION Occ- v. COMPLAINT- Hope Culley P O BOX 701 I MECHANICSBURG PA 17055 I Defendant(s) I 1. Plaintiff herein is LEFFLER ENERGY located at 113 Main Street, Tullytown PA 19007 2. Defendant herein is Hope Culley, and individual, currently receiving mail PO BOX 701, Mechanicsburg PA 17055. 3. Throughout the years of 2010-2012 plaintiff was to provide number one kerosene on an on-call bases only to the defendant. 4. Defendant agreed to pay for for the services when call upon for a delivery by plaintiff.( A copy of invoice provided by plaintiff hereto as "Schedule A") 5. Schedule A shows I called for a 100 gallons and was delivered 01/19/2012. LIHEAP made payment to account on 03/29/2012. Schedule A also shows a delivery on 05/11/2012 that was not asked for. Schedule A does not show a payment of $475 made to plaintiff after August 2012 by LIHEAP. 6. When delivery was made on 05/11/2012 I was not home. Called the next day about the delivery. Asked plaintiff to remove from my tank. I didn't not authorize transaction as per my account set up. Also being on low income I didn't have the funds to pay it. I was told by Plaintiff that I had to pay because they delivered it. 7. Tank that they filled also was locked so no delivery would be make without my knowledge. Tank was broken into to be filled. WHEREFORE, defendant does not owe for product that was not ordered per contract with plaintiff. Hope Culley Hope Culley PO BOX 701 Mechanicsburg, PA 17055 717/645-2936 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW c LEFFLER ENERGY :No. 13-7282 CIVIL Plaintiff . . TERM vs. t-'c;;) •-tl, Q • s : CIVIL ACTION '�'' ; - HOPE CULLEY Defendant • - o • • CERTIFICATION OF SERVICE/COMPLIANCE JOANN MULVIHILL, of full age,hereby certifies as follows: 1. I am a paralegal employed with the MARKIND LAW GROUP, P.C.. 2. On FEBRUARY 5,2014, I served copies of the filed Praecipe to Substitute Verification on defendant(s), HOPE CULLEY ,by sending them simultaneously by regular mail to: Hope Culley PO BOX 701 MECHANICSBURG PA 17055-0701 I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfullrls'U I am subject to punishment. .,. Dated: 1 ( � y O 4-- JO• LVIHILL File No.: M1100386