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Home My WebLink About05-1644 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. O~ - 1~4~ C;u~l '---r~ RONALD E. BEATTY Plaintiff ALINE T. ANTHONY Defendant : CIVIL DIVISION - LA W NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 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, 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 MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE P A 17013 (717) 249-3166 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05; -1<..41 C,'o: L~~ CIVIL DIVISION - LAW RONALD E. BEATTY Plaintiff ALINE T. ANTHONY Defendant COMPLAINT The Plaintiff, RONALD E. BEATTY, by his attorneys, KNUPP, KODAK & IMBLUM, P.c., brings this action of Assumpsit against the Defendant to recover the sum of SIXTEEN THOUSAND, ONE HUNDRED SEVENTY-EIGHT DOLLARS AND NINETY-FIVE CENTS ($16,178.95), along with interest thereon from October 15,2003, upon a cause of action of which the following is a statement: 1. The Plaintiff, RONALD E. BEATTY, is an adult individual residing at 4605 'Marblehead Street, Harrisburg, Dauphin County, Pennsylvania 17109. 2. The Defendant, ALINE T. ANTHONY, is an adult individual with a last known address at 50 Drexel Place, New Cumberland, Cumberland County, Pennsylvania 17070. COUNT I PROMISSORY NOTE 3. Plaintiff incorporates Paragraphs 1 and 2 herein as if fully and at length set forth. F:\USER\BONN IEJo\COMP\ WO RK\beatty-comp. wpd: 18Mar05 4. Plaintiff did, over a period of time, loan certain monies to Defendant as fully and at length set forth in a true and correct copy of a Reaffirmation of Debt and Promissory Note signed by the Parties on or about October 15,2003. A true and correct copy of said Reaffirmation of Debt and Promissory Note is attached hereto, marked as Exhibit "A" and made a part hereof. 5. The total monies loaned to Defendant by Plaintiff as set forth above totaled the sum of Fifteen Thousand, Forty-Eight Dollars and Eighty-Five Cents ($15,048.85), as reaffirmed by Defendant in the writing attached hereto as Exhibit "A" and made a part hereof. 6. Defendant did pay the total sum of Seventy ($70.00) Dollars on account, leaving a balance due and owing in the sum of Fourteen Thousand, Nine Hundred Seventy-Eight Dollars and Eighty-Five Cents ($14,978.95). 7. Plaintiff has frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant has refused and neglected and still refuses and neglects to pay said amount of any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of FOURTEEN THOUSAND, NINE HUNDRED SEVENTY-EIGHT DOLLARS AND EIGHTY-FIVE CENTS ($14,978.85), together with interest thereon from October 15,2003. F:\USER\BONN IE] O\COMP\ WO RK\beatty-comp. wpd: 18Mar05 3 COUNT II UNPAID RENT 8. Plaintiff incorporates Paragraphs 1 through 7 herein as if fully and at length set forth. 9. Defendant did rent living quarters from Plaintiff for a period of six (6) months, with the rental fee being set at the rate of Two Hundred ($200.00) Dollars per month. 10. Defendant has failed to pay to Plaintiff any of the rental monies due and owing. 11. Defendant is indebted to Plaintiff for the amount of One Thousand, Two Hundred ($1,200.00) Dollars in unpaid rental fees, plus interest from January 31, 2004. 12. Plaintiff has frequently demanded payment from Defendant of said amount due and owing as aforesaid, but Defendant has refused and neglected and still refuses and neglects to pay said amount of any part thereof. WHEREFORE, Plaintiff brings this suit to recover from Defendant the sum of FOURTEEN THOUSAND, NINE HUNDRED SEVENTY-EIGHT DOLLARS AND EIGHTY-FIVE CENTS ($14,978.85), together with interest thereon from October 15, 2003 under Count I of this Complaint; AND, the sum of ONE THOUSAND, TWO HUNDRED ($1,200.00) DOLLARS, plus interest thereon from January 31, 2004 under Count II of this Complaint, F :\USER\BONNIEJ O\COMP\ WORK\beatty-comp. wpd: 18Mar05 4 FOR THE TOTAL AMOUNT due and owing by Defendant to Plaintiff in the amount of SIXTEEN THOUSAND, ONE HUNDRED SEVENTY-EIGHT DOLLARS AND NINETY-FIVE CENTS ($16,178.95), plus interest as set forth hereinabove. Respectfully submitted, KNUPP, KODAK & IMBLUM, P.c. ~~ Robert D. Kodak ------------ 407 North Front Street Post Office Box # 11848 Harrisburg, P A 17108-1848 (717) 238-7151 Attorney ID No. 18041 Attorney for Plaintiff F:\USER\BONNIEJO\COMP\ WORK\beatty-comp.wpd: 18Mar05 5 10/16/03 Date 4/12/01 5/14/01 6/20/01 8/1/01 8/3/01 9/5/01 9/12/01 9/28/01 10/14/01 11/10/01 12/11/01 1/13/02 1/22/02 2/13/02 3/11/02 4/16/02 5/16/02 6/6/02 7/20/02 8/9/02 8/19/02 5/15/03 6/2/03 6/7/03 6/24/03 8/7/03 Reaffirmation of Debt and Promissary Note Num Transaction Increase C Decrease Opening Balance 8,400.00 Aline Anthony 96.94 Aline Anthony 83.79 Transfer To Personal Loan 118.22 MAC Withdrawl 300.00 Aline 15.00 cat: Clothing Transfer To Personal Loan 114.49 Aline Anthony 1,300.00 memo: Loan Transfer To Personal Loan 89.11 Transfer To Personal Loan 77.32 Transfer To Personal Loan 73.58 Transfer To Personal Loan 88.01 Aline Anthony 150.00 memo: Payment toward debt Transfer To Personal Loan 79.17 Transfer To Personal Loan 62.90 Transfer To Personal Loan 89.03 Transfer To Personal Loan 75.60 Transfer To Personal Loan 48.00 Transfer To Personal Loan 108.18 Transfer To Personal Loan 48.80 Belco Community Credit Union 15.93 memo: Transfer - Final Interest Payment Don's Performance Corner 1,660.96 memo: Overhaul Transmission - '97 Jeep Wrangler Lander Wren Insurance 365.01 memo: Auto Insurance - Jeep Wrangler Aline T. Anthony 100.00 memo: Check ~624 - 6/2/2003 Cassel's Auto Body Shop 2,279.37 memo: repair '97 Jeep Wrangler U-Haul Center Of Harrisburg 100.90 memo: [J-Haul rental 1 day, 38 mi Balance 8,400.00 8,303.06 Payment 8,219.27 Payment 8,337.49 Interest 8,637.49 Loan 8,622.49 Reimbursement 8,736.98 Interest 10,036.98 Loan 10,126.09 Interest 10,203.41 Interest 10,276.99 Interest 10,365.00 Interest 10,215.00 Payment 10,294.17 Interest 10,357.07 Interest 10,446.10 Interest 10,521.70 Interest 10,569.70 Interest 10,677.88 Interest 10,726.68 Interest 10,742.61 Interest 12,403.57 Loan 12,768.58 Loan 12,668.58 Payment 14,947.95 Loan 15,048.85 Loan I, Ronald E. Beatty do certify that the above is a true and accurate accounting of financial transactions with Aline T. Anthony and state that the outstanding balance as of today is $15,048.85 :iut A1- Signed /;[ Date (; /I&/u 3 , I, Aline T. Anthony, do certify that, to my knowledge, the above is a true and accurate accounting of my debt outstanding with Ronald E. Beatty as of this date. I recognize an outstanding balance of $15,048.85 and hereby reaffirm this obligation and my intention to fulfill it. Signed~ ~ Date 10 (I SiD ::) VERIFICATION I, RONALD E. BEATTY, verify that the statements made in the aforegoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. S4904, relating to unsworn falsification to authorities. I 'jg !n(jel} f ,/ &~ Ronald E. Beatty Dated: J! 24 It):;- 3040256 F:\USER\BONNIEJO\CO MP\ WO RK\beatty-comp. wpd: 18Mar05 (:J "'<l G t ?i>- ll( f'-." 0 (") = \t ~ ~:; (:;.::> ." ~11 --1 ::r.: :r.:., CI( :,t... rnp """- ;;::J :9PJ - 0- 0< 1'.' ~ , ". '\ ~ w ~:~ (~~ lU Q0 -':) .;2~r?\ l)J ~ __.(.;0 v-> \ ... -' w u ._~ '-.. ~':;;:'- ~ ~-:t (.,.' '~'J 1- :< -~ (.? CASE NO: 2005-01644 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BEATTY RONALD E VS ANTHONY ALINE T CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE ANTHONY ALINE T DEFENDANT was served upon t e at 50 DREXEL PLACE at 1927:00 HOURS, on the 11th day of A ril 2005 NEW CUMBERLAND, PA 17070 MARIE LEESE, MOTHER by handing to a true and attested copy of COMPLAINT & NOTICE together ith and at the same time directing Her attention to the contents th reof. Sheriff's Costs: Docketing Service Postage Surcharge 18.00 12.58 .37 10.00 .00 40.95 Sworn and Subscribed to before this 14--(( Yrl. ~ L day of A.D. ~ / Protho 0 i~1J' So Answers: 11"~'-"-'-" ~";;",';':.:--', -,:,.. '5>..r._.~'.A' : ~'.-~';'''''''''''-';'''~ ~ - ~ R. Thomas Kline 04/12/2005 KNUPP KODAK \ ! Sheri , RONALD E. BEATTY Plaintiff : IN THE cpURT OF COMMON PLEAS : CUMBERI\.AND COUNTY, PENNSYLVANIA v. : NO. 2005 1644 CIVIL ALINE T. ANTHONY Defendant : CIVIL DI SION - LAW TO: PROTHONOTARY, COURT OF COMMON PEAS CUMBERLAND COUNTY, PENNSYLVANIA P CIPE FOR DEFA LT MENT Enter judgment in favor of Plaintiff and against Defendant(s ALINE T. ANTHONY, named for failure to file within the required time an Answer to the Comp aint in the above-captioned case and assess the Plaintiffs damages as follows: Amount claimed in Plaintiffs Complaint $16,178.95 Interest from October 15,2003 at the legal rate of 60 per annum $1.536.96 Total $17,715.91 It is hereby certified that a written notice of intention to fil this Praecipe was mailed to the Defendant(s) and his attorney of record, after the default 0 and at least ten (10) days prior to the date ofthe filing of this Praecipe. See Exhibits A & Batt ched. KNUPP, ODAK & IMBLUM, P.C. By DATED: odak, Attorney for Plaintiff \ q\r? I 5 \udgment entered and damages assessed as above.1 Prothonotary ALlNE T ANTHONY C/O CHARLES & MARIE LEESE 50 DREXEL PLACE NEW CUMBERLAND PA 17070 LAW OFFICES OF KNUPP, KODAK & IMBLUI'J!, P.C. CAMERON MANSION 407 NORTH FRONT STREEt POST OFFICE BOX 11848 HARRISBURG, PA 17108-1848 Telephone: 717/238-7159 Facsimile: 717/238-7158 email: kki.law@Verizon.net I I I I ! ! I I ! I Fu r h"L c:' ,r, :", t,~ LF l..d! f Robert Ewing Knupp (1909-1976) Robert H. Maurer (1923-1998) .. Robert L. Knupp Robert D. Kodak Gary J. Imblum May 2, 2005 RE: VS: \ I \ I I Aline T. Anthony \ No. 2005-01644 Civil, Court of Common Plea Cumberland County, Commonwealth of Penn ylvania Our File No. 3040256 Ronald E. Beatty Dear Ms. Anthony: In accordance with Pennsylvania Rules of Civil Pro dure 237.1 (a)(2), we are enclosing herewith a Notice of a Praecipe for Entry of Defau t Judgment. According to the records as they are found in the Office of the Prothonotary 0 Cumberland County, you have not filed responsive pleadings to the Complaint filed a ainst you to the above term and number, nor has any attorney entered an appearance 0 your behalf. Accordingly, we are forwarding to you the enclosed N tice which indicates that if you do not take action as set forth in this Notice, we, at the e piration of time indicated therein, will request the Office of the Prothonotary of Cumber and County to enter Judgment against you in the amount as set forth in said Com laint. Very truly yours, KNUPP, KODAK&ltUM' P.c. Robert D. Kodak, Esq\ THIS LETTER IS AN ATTEMPT TO COLLECT A AEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR ~HAT PURPOSE RDKlkqb I, \ enclosure cc: RONALD E BEATTY 4605 MARBLEHEAD STREET HARRISBURG PA 17109 I , I , \ . FILE CGPY v. : IN THE COURT OF COMMON PLEAS : CUMBElllAND COUNTy, PENNSYLVANIA : NO. 200~-OI644 CIVIL . , : CIVIL D\rVISION - LAW , , RONALD E. BEATTY Plaintiff ALINE T. ANTHONY Defendant IMPORTANT NOTICE TO: ALINE T. ANTHONY, Defendant(s) DATE OF NOTICE: MAY 2.2005 YOU ARE IN DEF AUL T BECAUSE YOU HA VB F ED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND ILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CL S SET FORTH AGAINST YOu. UNLESS YOU ACT WITIllN TEN (10) DAYS FROM 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 LA R AT ONCE. IF YOU DO NOT HA VB ALA WYER, GO TO OR TELEPHONE THE OFFICE SET ORTHBELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING LAWYER. I IF YOU CANNOT AFFORD TO HIRE A LAWYER, THI~~FFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES T MAY OFFER LEGAL SERVICES TO ELIGillLE PERSONS AT A REDUCED FEE OR 0 FEE. CUMBERLAND COUNTY BAR ASSOCI TION TWO LillERTY AVENUE CARLISLE PA 17013 (717) 249-3 I 66 ~ D -.(J ~ p 'i C> i!=- CY r - -- ~ -U ..- ,..., p:: 1"-., ~ -c:: >-> D c ., ~ c-, cFl -- -"'1 \U ~ E hi ~ ~ --- _..,~ '-l.... co - ;~) ~~ {....., -~ .. , .. RONALD E. BEATTY Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2005-01o/M CIVIL CIVIL DIVISION - LAW ALINE T. ANTHONY Defendant To ALINE T. ANTHONY. Defendant(s) You are hereby notified that on (Judgment) has been entered against you in the abov -caption I I I I I I , 2~ the following case. Judgment entered in the amount of $17.715.91. DATE: r: /1 riDS I I Prothonot I I hereby certifY that the name and address of the proper ~erson(s) to receive this notice is: \ ALINE T. ANTHONY L C/O CHARLES & MARIE LEESf 50 DREXEL PLACE \ NEW CUMBERLAND P A 1707~ i I I I \ AI ALINE T. ANTHONY. Defendido/a Defendidos/as Por este medio se Ie esta notificando que el de del 20 ~ el/la siguiente(Fallo) ha sido anotado en contra suya en el caso me cionado en el epigrafe. I I Protonotario \ I I Certificao que la siguiente direccion es la del defendido/a segUn indicada en el cetificado de residencia: \ I I I I I I I , FECHA: ALINE T. ANTHONY C/O CHARLES & MARIE LEESE 50 DREXEL PLACE NEW CUMBERLAND PA 17070 Abogado del Demandante , I I I I I I I I I I I