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HomeMy WebLinkAbout14-1208 Supreme Cot ,oT - Tennsylvania COU of.Co mmon Pleas For. Prothonotary Use Only. Ci Cover &t ? L��,��' •w y . 41�r o i` Docket No: •. �/ County The information collected on this form is used solely for court administration purposes. This form does not supp lement or replace the filing and service ofpleadings or otherpapers as required by law or rules of court. Commencement of Action: S 0 Complaint 0 Writ of Summons Petition ® Transfer from Another Jurisdiction 0 Declaration of Taking E C Lead Plaintiff s Name: Lead Defendant's Name: Are money damages requested? ®Yes No Dollar Amount Requested: ©within arbitration limits I (check one) 13 outside arbitration limits 0 N Is this a Class Action Suit? 0 Yes IM No Is this an MDJAppeal? ID Yes 'Q" No A Name of Plaintiff /Appellant's Attorney: 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 ® Debt Collection: Other 0 Board of Elections 0 Nuisance 0 Dept of Transportation 0 Premises Liability 0 Statutory Appeal: Other S 0 Product Liability (does not include 0 Employment Dispute: E mass tort) Slander/Libel /Defamation Discrimination C 0 Och er: 0 Employment Dispute: Other 0 Zoning Board T ® Other: I 0 Other: 0 MASS TORT 0 Asbestos N 0 Tobacco 0 Toxic Tort -DES 0 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste ® Other: ©Ejectment ©Common Law /Statutory Arbitration B 0 Eminent Domain/Condemnation 0 Declaratory Judgment 0 Ground Rent Q Mandamus 0 Landlord/Tenant Dispute Non- Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto 0 Dental VPartition 0 Replevin 0 Legal 0 Quiet Title 0 Other: 0 Medical 0 Other: 0 Other Professional: Updated 11112011 a . IN THE COURT OF � (County), I I I (State) 1 6 v 9• -r Dais PLAINTIFF (Name of Plaintiff) v � v- CAUSE NO. (brandan Q) m dam, (Name of Defendant) DEFENDANT �* Complaint for Partition of Real Property C7,- CD 1. Plaintiff, P�K Q o (` �1 's (name of plain iffl, is n w, and I times mentioned in this Complaint was, a resident ofU�1� W (name of. county), 1'`A (name of state). 2. Defendant, k b- & V) (name of defendant, is no W, and at all times mentioned in this Complaint was, a resident o (name of county), (name of state). 3. Plaintiff and Defendants are owners as (specification of nature of tenancy or ownership) h of the following-described real property located / 1 GU.>S RA (address of property), f (name of city), j (name of county), . <1 (name of state): (legal description of property) � 1 p- If 1 �r * 4. (Description of interests in property sought to be partitioned of each party.) 6e.e-cA- L"As k^ {tea v e.- 1 na..rr - t e-& a s w ar j f S nA OUP uiT� f 5. (There are no liens or encumbrances appearing of record on the property, and Plaintiff has no knowledge of any parties who claim an interest in the property or who will be materially affected by the action other than Plaintiff and Defendant or Specify liens or encumbrances). IVaY, e 6. PI i iffhas obtained a fi report from /A ~ (name of title insurance company) and the report is loca _ Mo { 14 8341st (address of location o ' Ie report), (name of city), (nam_�o cou (name of state) and may be used, inspec copied by the parties to this action during normal busing rs. The report obtained at a cost of $ o Plaintiff. 7. The prosecution by Plaintiff of this partition action is for the common benefit of Plaintiff and Defendant, and Plaintiff has incurred, and will continue to incur, reasonable attorney's fees in the prosecution of this action. WHEREFORE, Plaintiff requests: 1. That defendants, and each o them, be cited to appear and answer this -- -Complaint;, - - - 2. That this Court order the partition of the above - described property according to the respective rights and interests of the parties to this action, or if more equitable, the sale of the property and a division of the proceeds between the parties according to their rights; 3. Reasonable attorney's fees incurred by Plaintiff in the prosecution othis action for the common benefit of the parties to this action; 4. Costs of suit as prescribed by law; and 5. Such other and further relief as the court may deem just and equitable. Respectfully submitted, (Name of Plaintiff) B S-0-P - (Name of Plaintiff's Attorney) State Bar No. OF COUNSEL: (Name of PI Is Attorney) Post O e Box (City, State, Zip Code) 4 1 , Telephone: STATE OF fA 1 COUNTY O FOC l c �T► -,- ',S (Print Name), am the Plaintiff in the within action for a Partition of Real Property. I have read the foregoing Complaint and know the contents thereof. The contents are true to my own knowledge except as to matters therein stated to be alleged upon information and belief, and as to those matters I believe them to be true. Subscribed and Sworn to before me on - 2 • �� • �� (date). Plaintiff's Signature N1p Notary Public March 20, 2014 Mr. Boulden, This letter is to inform you that Ms. Rebecca Travis has filed a civil complaint with the Court of Common Pleas in Cumberland County regarding your jointly owned property at 191 Konhaus Rd Mechanicsburg, PA 17050. Her complaint is for a partition of Real Estate. This letter will be sent certified mail to assure delivery and show return receipt so as to be time stamped for administrative purposes. On record is a letter from an attorney showing that the plaintiff attempted to have this matter settled in June of 2013. The letter clearly states your options in this case. If you do not take further action in a timely manner you may be summoned for court in which court fees will incur. This letter is not in any way providing you with legal advice, however it is suggested that you settle these matters outside of court as they can be costly. Enclosed is a copy of the complaint and a copy provided to us of the original attorney's letter sent to you requesting action in this matter. Any questions concerning this docket number 14 -1208 can be addressed with the Prothonotary of Cumberland County. One Courthouse Square Suite 100 Carlisle, PA 17013 717 - 240 -6195 Cc: Rebecca Travis 7013 2630 0000 1867 3311 'NI urvrrED SrA7Es rosrh SERViCE 1000 y /21 176 RETURN C. U N A3 ME i7050 U.S. POOSTRGE MECHRN'C5065RG.PP, MAR 22.'19 RMOUNT 14- 0204/ TO SENDER AIMED R WAR- *03 19 - 07 43 6 -2 $6,49°6