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HomeMy WebLinkAbout14-5170 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS NOTICE OF APPEAL Judicial District, County Of FROM MAGISTERIAL DISTRICT JUDGE JUDGMENT COMMON PLEAS No. ly— J / 7Q Cjy. NOTICE OF APPEAL -te 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 Q PPFL��. R1 L�W MAGODI'NO.3 —0 NAM"_ v ° ,r"I�.. ,nq i \ . ADDS OF_APP LANT M CITY b �� PA I� v TES.,�� ZIP CODE DATE O JUDM T� IN THE CASE OF lain ft) � 1� Defendan 2 vs N` i '�� y�`�J►Y) DOCKET No. 1 ^ SIGNATURE OF APPELLANT OR ATTORNEY OR AGENT This block will bb signed ONLY when this notation is required under Pa. If appellant was tlaimant (see Pa. R.C.P.D.J. No. 1001(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. 7� �.f,f)within twenty(20)days after s ce of rule or suffer entry of judgment of non pros. Signature of appellant or attorney or agent RULE: To 1\ '" AffK:,rappellee(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) l4bu' do not file a complaint within this time, a JUDGMENT OF NON PROS MAYBE ENTERED AGAINST YOU. LL =(3) Thi date of service of this rule if service was by mail is the date of the mailing. 20 Date: { `�{ {�S t�i�t,�3 V {9 V�1/ � Signature of Prothonotary or Deputy 110 YOU MUST INCLUDE A COPY OF THE NOTIC�,&LIW%MgIQT4 4WkRIPT FORM WITH THIS NOTICE OF APPEAL. 0HOH{_O8 d AOPC 312-05 X3/65 3S COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript CIVII COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ-09-3-05 William Stauffer MDJ Name: Honorable Mark Martin V Address: 507 North York Street Ginger Riland Mechanicsburg, PA 17055 Telephone: 717-766-4575 Ginger Riland Docket No: MJ-09305-CV-0000073-2014 74 Keefer Way Case Filed: 8/12/2014 Mechanicsburg, PA 17055 Cross Complaint Docket No(s): MJ-09305-CV-0000094-2014 Disposition Summary (cc-cross complaint) Docket No Plaintiff Defendant Disposition Disposition Date MJ-09305-CV-0000073-2014 Ginger Riland William Stauffer Judgment for Plaintiff 08/26/2014 MJ-09305-CV-0000094-201400 William Stauffer Ginger Riland Judgment for Plaintiff 08/26/2014 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Ginger Riland $0.00 $0.00 $0.00 Ginger Riland $0.00 $1,450.00 $1,450.00 William Stauffer $0.00 $2,596.91 $2,596.91 William Stauffer $0.00 $0.00 $0.00 . .._....... _ _......_ __...... .. . _w...._.... ...�_.M.,. _._-... ._ Judgment Finding (*Post Judgment) In the matter of Ginger Riland vs. William Stauffer on MJ-09305-CV-0000073-2014, on 8/26/2014 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $2,477.91 $2,477.91 Filing Fees $0.00 $119.00 $119.00 Grand Total: $2,596.91 In the matter of William Stauffer vs. Ginger Riland on MJ-09305-CV-0000094-2014, on 8/26/2014 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0700 $1,402.50 $1,402.50 Filing Fees $0.00 $47.50 $47.50 Grand Total: $1,450.00 MDJS 315 Page 1 of 3 Printed:08/27/2014 12:30:32PM William Stauffer Docket No.: MJ-09305-CV-0000094-2014 V. Ginger Riland 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 JUDGMENTITRANSCRIPT 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,SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. oe cu,� 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 MDJS 315 Page 2 of 3 Printed:08/27/2014 12:30:32PM William Stauffer Docket No.: MJ-09305-CV-0000094-2014 V. Ginger Riland Participant List Plaintiff(s) William Stauffer 100 S. 15th Street Camp Hill, PA 17011 Defendant(s) Ginger Riland 74 Keefer Way Mechanicsburg, PA 17055 MDJS 315 Page 3 of 3 Printed:08/27/2014 12:30:32PM c.n PROOF OF SERVICE OF NOTICEOF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST 8E FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF AFFIDAVIT: I hereby (swear) (affirm) that I served ss a copy of the Notice of Appeal, Common Pleas (date of service, , 20 sender's .receipt attached.hereto, and upon the , 20 ILI_ Eby personal servicen sender's receipt attached hereto. (SWORN)WFIRMErl) AND SUBS BEFORE ME THIS_It AY 0E5'0- 20 Vri 9‘ Signature of official e ofe whom affidavit was made My commission expires on , 20)3 Commonwealth a PA NOTARIAL SEAL Kimberly A. Maher, Notary Public Upper Allen Twp., Cumberland County Mycomrnission expires Nov. 9, 2015 AOPC 312A - 05 cl No,, upon the Magisterial District Judge designated therein on NI by personal service E by (certified) (registered) mail, ( - appellee, (name) 'on by‘ertifiedD(registered) Ups-RQDKI- - vvLT-4. s rievirc Peq ve- Signatu f i nt ( Shipment Receipt: Page #1 of 1 THIS IS NOT A SHIPPING LABEL. PLEASE SAVE FOR YOUR RECORDS. SNIP DATE: WED, SEP 3, 2814 EXPECTED DELIVERY DATE: NUR, SEP 4, 2014 EOD SHIP FROM: GINGER PILO') 74 KEEFER WAY MECHANICSBURG PA 17855 (717) 701.3053 SHIP TO: WILLIAM STAUFFER 188515TH SI CAMP HILL PA 17811-5581 RESIDENTIAL SHED THROH: 763 THE UPS STORE '3 HECHANICSBURGIPPUG,PA 17855 (717) 795-8818 SHIPMENT INFORMATION: UPS GROUND RESIDENTIAL 0,85 LBS ACTUAL WT 1.00 LBS BILLABLE W1 DIMS: 12.0819.68X2.00 SIG REO (W/DELU CONFIRM) E-MAIL NOTIFICATION: DELIVER TRACKING NUMBER: 2863E414202021584 SHIPMENT ID: MMA83B4MH88EG SHIP REF 1: - - SHIP REF 2: KM DESCRIPTION OF GOODS: DOC SHIPMENT :HAM-- --- -> - - GROUND RESIDENTIAL 518.91 SERVICE OPTIONS $4,30 FUEL SURCHARGE 50.76 CMS PROCESSING FEE $0,20 TOTAL $16.17 COMPLETE ONLINE TRACKINGT ENTER THIS ADDRESS IN YOUR NEB BROWSER TO TRACK. HTTP,//THLUPSSTORE.COM (SELECT TRACKING. ENTER SHIPMENT ID „) SHIPMENT QUESTIONS', CONTACT SNIPPED THROUGH ABOVE. sKIPMENTID: MMA8334MHBOEG 1111111111111111111111111111101111111111111111111111111111 111111111111111 Poemred by iShip(r) 09)03/201109:26 09 Pacific Tire N MEM egnAiO WSTem and mace pa,Wkoof t. Pvptm Ile:otted Inn 'h. atpnattNGa datthemmedits marry mImo bpMO,kd. The UPS Store atit amailat UpStpMn m tt m m t= 7013 3020 0002 U.S. Postal ServiceTrn CERTIFIED MAILTM RECEIPT (Domestic Mail Only; No Insurance Coverer: P wided) g:os— For delivery information visit our website at wwv;.Jsps.cmno)140 Postage Certified Fee Return Receipt,Fee (Endorsement Required) Restricted belivery,Fee (Endorsement Required) Total Postage & Fees ell ttt �$ ostmark Here Sent To Street, ApL No.; or PO Box No. City, State, ZIP+4 PS Form 3800, August 2006 COUNTY OF See Reverse for Instructions OF PENNSYLVANIA rtt AFFIDAVIT: I hereby (swear) (affirm) that I served ss 2014S T�,r� �,. EP 15 ppy j CUMBERLAND PC NNS YL D NIANT ��N1,�Y APPEAL AND RULE TO FILE COMPLAINT ,YS AFTER filing of the notice of appeal. Check applicable boxes.) a copy of the Notice of Appeal, Common Pleas No. , upon the Magisterial District Judge designated therein on (date of service; , 1'420 j NI by personal service i sender's receipt attached hereto, and upon the appellee, (name) i0 ! by personal serviceEj sender's receipt attached hereto. (SWO W (AFFIRMED) AND SUBSCRIBED BEFORE ME AY OF,- e7 j THIS •L Signature of officia';efofe wAdee o a i.avitvvas made Common Wealth of PA NOTARIAL SEAL Parvin M. Mehrtash, Notary Public Upper Allen Twp., Cumberland County My Commission_Expires March 07, 2016 Title of official My commission expires on O [] by (certified) (registered) mail, 4 rr3tftQ on l (1-r by6rtifie' (registered) rrlail, Us PS Signature `t ffiant Y S )4T-3 ( a, ) AT , i i 4 . , -_il_..kt.i-‘ 6 .. -tL ssio . r C...c4.,s e_ ±1.12___WX6,0_snr- i tet_SICSilams_g_se Ctoe1.3...,1:,,,,N r) i •,9 • 4 , \S I ' +0___+_1._ . Lko LA) lei (.,<.' IA ID W1/4 t. CI %OSA/6_ es.< prAic ..) Loci..6 vir:t p a I, V‘• lOvt--k 6 NI tort t_., A 1 e) < tt) ' . 0 a ' 4 " - 4 , pV. g - kt vv) e... 1A7i^t,,,, 4) . c.-.<- X_ (7191 c % ... N, A 0 • — • ,. . e -, . A . . .._ ,_ . ?\ . k. 4 A A. ... . b6 • . . A. Al . A t....< 4t_ C.-At ' \ 63I w'f..-. • - , • L kik. 10 .. - _ A , • • . - A. 4. , . • , . w• • li _ , , • _ .. (.1„, in 6- II .b.- _ o- r • S. 'a '. 0 II, il ...... _%C.‘-a_t—il_c_N__ • • a, .1/40 yvk 0 vve ‘.1 , Ai ' . & A , _________ 14.— ' ive_ rc, _ , A & A 0 & 1 st—Ls5-14-1- rIc 4- csVt-10,R_ .;". < . _ \' v.) 0 .......\A c,.., % k --Vo ill - a ' , 0 ko * Ld21-‘0A 1 / . a_ , Si- I * . . --.-V6CLO A , ,_ . cis ti) 44. 4 THE FRO' HONG I 21314 SEP 26 PM 2:3 CUMBERLAND COUNTY PENNSYLVANIA PROOF OF SERVICE OF NOTICE OF APPEAL -AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ' ;ss AFFIDAVIT: I hereby (swear) (affirm) that I served S1%' a copy of the Notice of Appeal, Common Pleas No. , upon the Magisterial District Judge designated therein on (date of service) 7 , 20 2 3, by personal service El by (certified) (registered) mail, senilder's 'receipt attached hereto, and upon the appellee, (name) , on a R ; yt 7 , 20 3.by personal service by (certifiedl(registered) mail, sender's receipt attached hereto. (SWORN)eFIRMED) AND SUBSCRIBED BEFORE ME THIS a6 'DAY OF -, 20 )V Signature of 'clef before whom affidavit ws Thade Title of official My commission expires on 42 .2 AOPC 312A - 05 2o/Y Signature of affiant IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM STAUFER § CAUSE NUMBER: 14-5170 100 S. 15th Street § Camp Hill, PA 17011 § Plaintiff, v. GINGER RILAND 74 Keefer Way Mechanicsburg, PA 17055 § Defendant DEFENDANT GINGER RILAND'S PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT NOTICE: YOU MUST FILE AN ANSWER TO THESE PRELIMINARY OBJECTIONS WITHIN 20 DAYS OR A JUDGMENT MAY BE ENTERED AGAINST YOU. AND NOW comes Ginger Riland, the Defendant in this appeal, files these Preliminary Objections to Plaintiff's Complaint. I. Preliminary Objections Pursuant to Pa. RC.P. 1028 (a)(2) - Failure of a Pleading to Conform to Law or Rule of Court 1. Plaintiff's complaint in this matter is written by hand and single-spaced. 2. Plaintiffs Complaint is at, best, difficult to read. 3. Plaintiff's Complaint violates Pa.R.C.P. 204.1, which reads as follows: Rule 204.1. Pleadings and Other Legal Papers. Format. All pleadings, motions and other legal papers must conform to the following requirements: (1) The document shall be on 8 1/2 inch by 11 inch paper. (2) The document shall be prepared on white paper (except for dividers and similar sheets) of good quality. (3) The first sheet shall contain a 3 -inch space from the top of the paper for all court stampings, filing notices, etc. (4) The text must be double spaced, but quotations more than two lines long may be indented and single spaced. Margins must be at least one inch on all four sides. (5) The lettering shall be clear and legible and no smaller than point 12. The lettering shall be on only one side of a page, except that exhibits and similar supporting documents may be lettered on both sides of a page. WHEREFORE, Defendant moves the Court to order Plaintiff to re -write his Complaint in accordance with Pa.R.C.P. 204.1 within 20 days of the entry of this order. Failing to do so, Plaintiff's Complaint shall be struck. IL Preliminary Objections Pursuant to Pa. R.C.P. 1028 (a)(2) — Failure of a Pleading to Conform to Law or Rule of Court and to Pa.R.C.P. 1028(a) (3) for lack of specificity 4. Plaintiff's Complaint is hereby incorporated by reference and attached as exhibit "1". 5. As shown in the attached exhibit, Plaintiff has not written a Complaint, but has submitted an ill-defined and disjointed set of grievances. 6. Plaintiff has not made any claim for damages. 7. Pennsylvania is a fact pleading state, and under the system of fact pleading, a pleader must define issues, with every act or performance essential to that end set forth in the complaint. 8. Pa.R.C.P. 1028(a) (3) allows for Preliminary Objections to be raised against a pleading for failure to plead with sufficient specificity. 9. The purpose of Rule 1028(a)(3) is to ensure that an adverse party's rights and ability to answer and defend will not be unduly impaired by the pleader's lack of clarity in stating the grounds of the suit. 10. Defendant has not stated in a concise and summary form, the material facts on which his claim is based, as required by Pa. R.C.F. 1019(a) and as such, is a violation of Pa. R.C.P. 1028(a)(2). 11. Defendant's ability to answer and defend herself is impaired by Plaintiff's complete lack of specificity in stating and otherwise setting -forth the nature and occurrences of the actions of which he accuses Defendant. WHEREFORE, Defendant moves the Court to order Plaintiff, within 20 days of this order, to amend his Complaint and set -forth the nature of his Complaint against Defendant, including damages. Failing to do so, Plaintiff's Complaint shall be struck, III. Preliminary Objections pursuant to Pa. R.C.P. 1028 (a)(4) — Legal Insufficiency of a Pleading 12. Plaintiffs Complaint makes no claim for damages. 13. As such, Defendant is unable to evaluate Plaintiff's complaint or formulate a defense. WHEREFORE, Defendant moves the Court to order Plaintiff, within 20 days of this order, to amend his Complaint and set -forth the nature of his Complaint against Defendant, including damages. Failing to do so, Plaintiff's Complaint shall be struck. IV. Preliminary Objections Pursuant to Pa. R.C.P.1028 (a)(2) — Failure of a Pleading to Conform to Law or Rule of Court 14. Plaintiffs Complaint contains no verification. 15. P.R.C.P. 1024 requires that every Complaint contain a verification WHEREFORE, Defendant moves the Court to order Plaintiff, within 20 days of this order, to amend his complaint and add verification. Failing to do so, Plaintiffs Complaint shall be struck. Respectfully Submitted; Ginger Riland 74 Keefer Way Mechanicsburg, PA 17055 Tel: (717) 701-3053 IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM STAUPER § CAUSE NUMBER: 14-5170 100 S. 15th Street Camp Hill, PA 17011 Plaintiff, v. GINGER RILAND 74 Keefer Way Mechanicsburg, PA 17055 Defendant CERTIFICATE OF SERVICE 101 I, Ginger Riland, hereby certify that on the 13 day of 0 CTOWL—, a copy o Defendant's Preliminary Objections to Plaintiff's Complaint was sent by first class mail, postage prepaid to Defendant, addressed as follows: Mr. William Stauffer 100 S. 15th Street Camp Hill, PA 17011 Respectfully submitted, JAANAil__RjaL Ginger Riland 74 Keefer Way Mechanicsburg, PA 17055 Tel: (717) 701-3053 In the court of Common Please for Cumberland County, Pennsylvania William Stauffer 100 S. 15th Street Camp Hill, PA 17011 Plaintiff, V. Ginger Riland 74 Keefer Way Mechanicsburg, PA 17055 Defendant Complaint Cause Number 14-5170 Now comes William Stauffer, the Plaintiff in this appeal, Files these Preliminary Objections to Defendant's Complaint. 1. William Stauffer (hereafter "Plaintiff') is an individual residing at 100 S. 15th Street Camp Hill, PA 17011. 2. Ginger Riland (hereafter "Defendant ") is an individual residing at 74 Keefer Way Mechanicsburg, PA 17055 3. This Complaint is filed in response to the Defendant's Appeal of a Judgment entered in Cumberland Co. MDJ Court 09-3-05, cause number MJ -09305 -CV -0000073-2014. 4. On or about May 1, 2013 Plaintiff reported a theft of equipment and power tools that happened at an indeterminate time shortly before the report was made. 5. The stolen items included tools owned by the Plaintiff only as supported by the police report. 6. Defendant was reimbursed through her home owners insurance for her tools allegedly stolen. This money was not given to Plaintiff to replace his tools. 7. The Plaintiff purchased his own tools for the operation of his grounds maintenance business. 8. A Home Depot account was opened, which only the Plaintiff paid on. Total Amount paid on this account was $1,135.00 for which Plaintiff has receipts for. 9. The items stolen that the Plaintiff has receipts that he paid for are as follows: A) Stihl Hedge Trimmer $275.59 on 9/06/13 B) Echo Hedge Trimmer $289.99 on 6/15/13 C) Echo Hedge Trimmer $307.39 on 6/05/13 10. The Stihl Back Pack Blower the Defendant is claiming was purchased by the Plaintiff with his own Debit Card for $499.95 which Plaintiff has a statement receipt for. 11. The Defendant's Highland Gardens receipts shows the Signature of the Plaintiff as received by him and paid for by Cash by the Plaintiff on 5/28/13 and 7/3/13. 12. At the time the Plaintiff left the premises of 74 Keefer Way Mechanicsburg, PA 17055. There was a balance of $700.00 left on the Home Depot account which the Plaintiff agreed to pay. 13. The following Items were charged to the Home Depot account after Plaintiff left the premises, by the Defendant and not the Plaintiff, as states in her claim. A) Honda 21' Mower $599+ Tax B) Milwaukee M18 Hammer Drill $299.00+ Tax C) Milwaukee 18V Battery $99.00 +Tax D) Echo Gas Blower $259.00 + Tax Total= $1,331.36 14. The Echo Gas Chainsaw the Defendant is claiming was purchased by the Defendant, and then she submitted the receipt to her homeowners insurance for reimbursement and then returned the item to the store for a refund price of $389.00 +Tax. 15. Defendant purchased two (2) Galaxy Phones for $699.60 each on Plaintiff's T Mobile Phone plan with a two year contract, Which Plaintiff is paying for. These phones are in the Defendant's Possession. Plaintiff requests these phones be returned to him, including all accessories. 16. Defendant is in possession of Harley Davidson Memorabilia items belonging to the Plaintiff. Plaintiff request that these items be returned to him: A Harley Davidson pocket watch and two (2) Special Edition Harley Davidson V rod models. Wherefore, Plaintiff respectfully requests this court grant judgment in his favor and against Defendant for the return of the Galaxy Phones, and Harley Davidson Memorabilia as well as all court costs. Respectfully, William Stauffer 100 S. 15th St Camp Hill, PA 17011 Tel: (717) 343-8366 f it's for the garden we have it" 423 S..18th St., CAMP HILL, PA 17011 i -hone: 717-737-8633 7 • . v„) s • it_ i NAME , (fc'S , • /'-ir J ADDRESS ,/ t v t * /4-ici, • www.highlandgardens.org ) Customer's Phone 123772 WHEN WANTED /SOLD BY -C:r, Quantity CASH C.O.D. CHARGE ON ACCT. MDSE, RETD. PAID OUT TERMS INVOICE DATE — DESCRIPTION Dept. Price AMOUNT , -,4- i,„, i 7.,... i -i , ir---,---7-- 4---- /ft,- -"‘ '' . s• ---,r 1,.• ,../ r• r /..,/ -„, i :.../ •1,:: f.--- - JJ• 7." f) !','C/(I TAX TOTAL SALE '*7 Date ' ) q :4) SERVICE CHARGE: ALL-PKST DUE ACCOUNTS SUBJECT TO LEGAL MAXIMUM — 75c Minimum Per Month "if it's for the garden we have it" 423 S. 18th St., CAMP HILL, PA -17011 Phone: 717-737-8633 • NAME ADDRESS WWW.highlandgardens.org • ' 123461 .) '.1.- ..; —'' 0 ) L', (.0 WHEN WANTED " Customers Phone SOLD BY •;.-, ..,..,,1;,, •./.• .,..::..-...---,...— CASH '.7•-• ' C.O.D. • CHARGE .• ON ACCT. MDSE. RETD. PAID OUT 'TERMS I.NVOJCEs7;pLIAT..2 Quantity DESCRIPTION - Dept. Price AMOUNT c / . •-•' .,-- / — 1 i - i . - :ze ,/..,,..„; 7-, ,...,..../..-.7 z:, -,< J. , - ,-- /.-r-,.. ,;.--) - . -2 • . t....-1 (13 • • ..„.I....., ...., --..„.....„. e -,, 4./ ' titt9(K.,c_--NIA., tv__,),,q,.5 (fru k.-}etc-isiqvvxd ,ic....„( .,.",, -.. u ) r ) / .. , , I ..r. .. ( --- 1, -1 f':, g-:-. .- - / - -'), 1 )'T / ,. r„ c,,./ ,t e , , ( 1 .1' ,'''..."';-7-1:',/ I ( (.:,' ,/ ://••• Q:' '• ) 0, i ( ?:_-,ceiTt ) "1---- - ' I ,- — (y, /- A. - 1 4 ' 7 —1 I , a ... : ..._ .... .• ..,-• i ......,...... . ..,INti ...„..1„-:.,,,, 1 .. 1 1-,., ..„ / .,-,..,P.,,..„..„,..,,,, ' ,, ; : .-: ?! , - 1.-t.) ri..-.,). .. . ... . • ') /....71/. ( 1.(;-.(i.>' II ii - ..'' • . I ' : • . • t i TAX >-•-• I.,/1 • 2 (........) TOTAL SALE LiP-") „,", ' .. •c•,7t <-,-.... . A . . 1 ...,:...:........-......., ..,'":./ 4...,., ...,) -:,-..; ReceDate ived by .••.,..1i..-,..•; • ' • - - .::_.., " ,,,,,,,:::,...••••-• -' •?"'" '-, f •••/ f / . .... \„,,. () ..i.,<: \ %•'''''. ..<-' SERVICE CHARGE: ALL PAST DUE ACCOUNTS SUBJECT TO LEGAL MAXIMUM — 750 Minimum Per Month NAME -- — --- -- ... .,. vr. ..v ISGIVIW /t 423 5. 18th St., CAMP HILL, PA 17011 Phone: 717-737-8633 R - r• ADDRESS - , www.highlandgardens.org 124182 - WHEN WANTED Customer's Phone . SOLD BY .../r ./-.s. CASH C.O.D. CHARGE ON ACCT. MDSE. RETD. PAID OUT TERMS INVOICE DATE ..„Quantity - w*, DESCRIPTION Dept. Price AMOUNT T • TAX J 55_ (DCS TOTAL SALE 1 6, 5.+ . :1 -l- Received by - • ' ..` `� Date SERVICE CHARGE: ALL PAST DUE ACCOUNTS SUBJECT TO LEGAL MAXIMUM — 75e Minimum Per Month Mt, 1 tfidt!�i :i •.:115> in!I if_, it: E4'; C?try tir..117 Sc, T -MOBILE 9042 3628 CAPITAL CITY MALL DR CAMP HILL, PA 17011-7017 (717) 761-2983 Fax (717) 761-1054 WILLIAM STAUFFER Installment Purchases Quantity Unit SKU Register #10 Trans #1503 04-12-2014 14:55:14 Mobile #: 7173438366 Account No: 320815229 Sales Rep#: 3119597 EACH 000000610214635587 Description SAM G900T GALAXY S 5 16GB WHIlk. KIT Serial # 353300061130511 Mobile Number: 7178022486 Not Discount Eligible Sale Amount TAX 660.00 @ 6% Installment Purchases Total Price Down Payment (Reflects Any Discounts) 0.00 T 660.00 660.00 39.60 699.60 0.00 39.60 39.60 Purchases Not on Installment Installment Purchases Down Payment Total TAX 660.00 @ 6% Total Paid Today EIP BALANCE PAYMENT Plan Id : 20131011440921 Visa -- 5038 045528 Reference # - 1122005382 0.00 0.00 39.60 39,60 475.00 -39.60 Device Recovery Handset(s) Details RMA Serial No# Make Model Quote Amount($) Device Status JMP60750001916867 356420058605650 Samsung SGH-M919 Galaxy S 4 16GB black 475.00 N/A It's your phone, make it your own with T—Mobile accessories' Shop for cases, chargers, headsets, memory and more at your T—Mobile store, or visit us online at www.T—Mobile.com. • Service availability and usage limits vary - see your plan for details. Partial minutes rounded up, and data usage rounded up to nearest KB. Data roaming not available for prepaid plans. 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For Int'I Talk &Text add-on feature, international calling is unlimited to landlines in select countries if added to an unlimited domestic calling plan, but decrements minutes if added to a limited minute plan (domestic overage rates apply); text messaging applies to mobile phones only -- other types of international messages (e.g. picture messages) are charged per message. See www.T-Mobile.com for lists of countries. • If I haven't signed up for a specific data plan, I will be charged for all data used on a per MB basis(rounded up to the nearest MB) unless I opt out of data service. If I have the 200MB Data (web) Plan, I will be charged we per MB for overage. Data plans may also have throughput and other limits, including Rate Plan Allotments. Domestic Off -Network data Allotments are: (1) 5MB if my data plan has 1MB to I99MB of full speed data; (2) 10MB if my data plan has 200MB to 1.99GB of full speed data; (3) 50 MB if my data plan has 2GB to 4.99GB of full speed data, or if my data plan has Unlimited Nationwide 4G data; (4) 100MB if my data plan has 5GB to 9.99GB of full speed data; (5) 200MB if my data plan has 10GB of data and above; or (6) 10MB if 1 use T -MOBILE 9042 Register #I0 3628 CAPITAL CITY MALL DR CAMP HILL, PA 17011-7017 CASH SALE AVAIL CR: DATE: 5/09/13 CM[ 4]SM[ 4]P0[ ] DEL[ 0] INVOICE: 391500 : 0 'Yesterday' File PAGE [ 1] CUSTOMER: 3438366 CUSTOMER: SOLD [BILL STAUFFER ] SHIP [BILL STAUFFER 1 TO [6354 MERCURY DR ] TO [6354 MERCURY DR ] [MECHANICSBURG, PA 17050 ] [MECHANICSBURG, PA 17050 ] [ I [ ] ATTN OF[ I Line Part Number Description Qty Net Total T 141 GT225 ECHO TRIMMER 1.0 159.99 159.99 T REM SN -S53912363947 1. 140 X480000021 2 LINE RAPID LOADER A 1.0- 22.90 22.90CRT 142 99944200240 GT ECHO MATIC HEAD 1.0 '21.49 21.49 T REM SUPERCEDES 99944200240 REM XXXXXXXXXXXX4086..APPR.. 000000 REM NAME..STAUFFER WILLIAM C Form of Payment: DEBIT Sub -Total.: 158.58 Discounts.: 0.00 Tax Code: 6 6.000% Tax.: 9.51 Invoice Total: 168.09 Selection: . Continue search, Page, End CASH SALE AVAIL CR: DATE: 6/05/13 CM[ 4]SM[ 41P0[ ] DEL1 0] INVOICE: 394305 : 0 'Yesterday' File PAGE 1 1] CUSTOMER: 3438366 CUSTOMER: SOLD [BILL STAUFFER ] SHIP [BILL STAUFFER ] TO [6354 MERCURY DR ] TO [6354 MERCURY DR ] [MECHANICSBURG, PA 17050 ] [MECHANICSBURG, PA 17050 ] ( 1 [ ] ATTN OF[ ] Line Part Number Description Qty Net Total T 141 HC -152 ECHO HEDGE TRIMMER 1.0 289.99 289.99 T REM SN -S94012035815 1. REM XXXXXXXXXXXX4086..APPR.. 000000 REM NAME..STAUFFER WILLIAM C Form of Payment: DEBIT Tax Code: Selection: . Continue search, Page, End Sub -Total.: 289.99 Discounts,: 0.00 6.000% Tax.: 17,40 Invoice Total: 307.39 CASH SALE AVAIL CR: INVOICE: 372906 : 0 'Yesterday' File CUSTOMER: 3438366 DATE: 6/15/12 CM[ 4]SM[ 4]P0( SOLD [BILL STAUFFER TO [6354 MERCURY DR [MECHANICSBURG, PA ATTN OF[ Line Part Number 141 HC150 REM SN -S76112240030 CUSTOMER: ) SHIP ] TO 17050 Description ECHO 20 HEDGE TRIMMER 1. Form of Payment: DEBIT Tax Code: Selection: - Continue search, Page, End [BILL STAUFFER [6354 MERCURY DR [MECHANICSBURG, PA J DEL [ O] PAGE [ 1] 17050 Qty Net Total T 1.0 289.99 269.99 T Sub -Total.: 269.99 Discounts.: 0.00 6 6.000% Tax.: 17.40 Invoice Total: 307.39 Receipt Lookup Credit Services - Receipt LookUp Receipt Image Transaction Identifier: [4120, 10/03/2013, 17, 99011 Page 1 of 1 Printed on: 09/17/2014 17:22:05 More saving. More doing:" —6000 CARLISLE FIKE, MECH 17055 STORE MANAGER TEDD TERRY (717)795-9602 4120 00017 99014 10/03/13 12:42 PM CASHIER VICTORIA - VZ75PP PAYMENT ON ACCOUNT XXXXXXXXXXXX6023 AUTH CODE 003032 XXXXXXXXXXXX4086 AUTH CODE 931669 HOME DEPOT TOTAL DEBIT 200.00 TA $200.00 200.00 PAYMENTS ARE TAKEN BY HOME DEPOT AS A CONVENIENCE TO YOU AND NOT DEEMED MADE UNTIL RECEIVED BY CREDITOR. SEE ACCOUNT TERMS. t ct 1 p -eve S / 3 C5D https://webapps.homedepot.com/RLUWebApp/ 9/17/2014 Receipt Lookup Page 1 of 1 Credit Services - Receipt LookUp Receipt Image Transaction Identifier : [4120, 06/03/2014, 16, 7658] Printed on: 09/17/2014 17:23:50 More saving. More doing:" 6000 CARLISLE PIKE, MECH PA 17055 STORE MANAGER TEDD B TERRY(717)795-9602 4120 00016 76584 06/03/14 12:52 PM CASHIER BROCK - BA52J6 PAYMENT ON ACCOUNT xXXxxXXxxXXX6023 HOME DEPOT 500.00 AUTH CODE 003564 TA TOTAL $500.00 CASH 200.00 XXXXXXXXXXXX4086 DEBIT 300.00 AUTH CODE 832815 PAYMENTS ARE TAKEN BY HOME DEPOT AS A CONVENIENCE TO YOU AND NOT DEEMED MADE UNTIL RECEIVED BY CREDITOR. SEE ACCOUNT TERMS. https://webapps.homedepot.corri/RLUWebApp/ 9/17/2014 Receipt Lookup Credit Services - Receipt LookUp Receipt Image Transaction Identifier : [4120, 05/02/2014, 16, 4753] Page 1 of 1 Printed on: 09/17/2014 17:23:41 ore saving. ore doing:" 6000 CARLISLE PIKE, MECH PA 17055 STORE MANAGER TEDD B TERRY(717)795-9602 4120 00016 47536 05/02/14 07:02 PM CASHIER CLIFFORD - CLH022 PAYMENT ON ACCOUNT XXXXXXXXXXXX6023 HOME DEPOT 200.00 AUTH CODE 002750 TA TOTAL $200.00 XXXXXXXXXXXX4086 DEBIT 200.00 AUTH CODE 660746 PAYMENTS ARE TAKEN BY HOME DEPOT AS A CONVENIENCE TO YOU AND NOT DEEMED MADE UNTIL RECEIVED BY CREDITOR. SEE ACCOUNT TERMS. Pit https://webapps.homedepot.com/RLUWebApp/ 9/17/2014 Keceipt Lookup Credit Services - Receipt LookUp Receipt Image Transaction Identifier : [4120, 03/03/2014, 16, 9966] Page 1 of 1 Printed on: 09/17/2014 17:23:30 More saving. More doingr 6000 CARLISLE PIKE, MECH PA 17055 STORE MANAGER TEDD B TERRY(717)795-9602 4120 00016 99669 03/03/14 09:29 AM CASHIER CLARK — CLS959 PAYMENT ON ACCOUNT XXXXXXXXXXXX6023 AUTH CODE 003623 XXXXXXXXXXXX4086 AUTH CODE 732601 HOME DEPOT TOTAL DEBIT 60.00 TA $60.00 60.00 PAYMENTS ARE TAKEN BY HOME DEPOT AS A CONVENIENCE TO YOU AND NOT DEEMED MADE UNTIL RECEIVED BY CREDITOR. SEE ACCOUNT TERMS. https://webapps.hornedepacorn/RLUWebApp/ 9/17/2014 Receipt Lookup Credit Services - Receipt LookUp Receipt Image Transaction Identifier : [4120, 02/02/2014, 17, 8606] Page 1 of 1 Printed on: 09/17/201417:23:20 More saving. More doing:" 6000 CARLISLE PIKE, MECh PA 17055 STORE MANAGER TEDD 8 TERRY(717)795-9602 4120 00017 86060 02/02/14 10:43 AM CASHIER EVAN - EBK19I PAYMENT ON ACCOUNT XXXXXXXXXXXX6023 HOME DEPOT 25.00 AUTH CODE 002671 TA TOTAL $25.00 XXXXXXXXXXXX4086 DEBIT 25.00 AUTH CODE 860406 PAYMENTS ARE TAKEN BY HOME DEPOT AS A CONVENIENCE TO YOU AND NOT DEEMED MADE UNTIL RECEIVED BY CREDITOR. SEE ACCOUNT TERMS. https://webapps.homedepot.com/RLUWebApp/ 9/17/2014 Receipt Lookup Credit Services - Receipt LookUp Receipt image Transaction identifier: [4120, 01/03/2014, 19, 5763] Page 1 of 1 Printed on: 09/17/2014 17:23:11 ore saving. ore doing:" 6000 CARLISLE PIKE, MECH PA 17055 STORE MANAGER TEDD B TERRY(717)795-9602 4120 00019 57638 01/03/14 12:31 PM CASHIER JENNIFER - JEK103 PAYMENT ON ACCOUNT XXXXXXXXXXXX6023 HOME DEPOT 50.00 AUTH CODE 003918 TA TOTAL $50.00 XXXXXXXXXXXX4086 DEBIT 50.00 AUTH CODE 630636 PAYMENTS ARE TAKEN BY HOME DEPOT AS A CONVENIENCE TO YOU AND NOT DEEMED MADE UNTIL RECEIVED BY CREDITOR. SEE ACCOUNT TERMS. https://webapps.homedepot.corn/RLUWebApp/ 9/17/2014 Receipt Lookup Credit Services - Receipt LookUp Receipt Image Transaction Identifier : [4120, 12/03/2013, 16, 4105] Page 1 of 1 Printed on: 09/17/2014 17:22:54 ore saving. More doing.° 6000 CARLISLE PIKE, MECH PA 17055 STORE MANAGER TEDD B TERRY(717)795-9602 4120 00016 41059 12/03/13 04:29 PM CASHIER CLARK - CLS959 PAYMENT ON ACCOUNT XXXXXXXXXXXX6023 HOME DEPOT 50.00 AUTH CODE 003709 TA TOTAL $50.00 XXXXXXXXXXXX4086 DEBIT 50.00 AUTH CODE 231100 PAYMENTS ARE TAKEN BY HOME DEPOT AS A CONVENIENCE TO YOU AND NOT DEEMED MADE UNTIL RECEIVED BY CREDITOR. SEE ACCOUNT TERMS. https://webapps.homedepot.com/RLUWebApp/ 9/17/2014 Kecetpt Lookup - Credit Services - Receipt LookUp Receipt Image ,• Transaction Identifier : [4120, 11/01/2013, 17, 2278] Page 1 of 1 Printed on: 09/17/2014 17:22:14 More saving. More doing:" 6000 CARLISLE PIKE, MECH PA 17055 STORE MANAGER TEDD TERRY (717)795-9602 4120 00017 22784 11/01/13 04:39 PM CASHIER CLARK - CLS959 PAYMENT ON ACCOUNT XXXXXXXXXXXX6023 HOME DEPOT 50.00 AUTH CODE 001861 TA TOTAL $50.00 XXXXXXXXXxXX4086 DEBIT 50.00 AUTH CODE 361390 PAYMENTS ARE TAKEN BY HOME DEPOT AS A CONVENIENCE TO YOU AND NOT DEEMED MADE UNTIL RECEIVED BY CREDITOR. SEE ACCOUNT TERMS. httpsilwebapps.homedepot.com/RLUWebApp/ 9/17/2014 UPPER ALLEN TOWNSHIP POLICE August 8, 2014 To Whom it May Concern: 100 GETTYSBURG PIKE MECHANICSBURG, PA 17055-5604 (717) 795-2445 www.UpperAllenPolice.com JAMES ADAMS Chief of Police I am writing in reference to a request for a copy of our investigative report concerning the Theft by Unlawful Taking in which William Stauffer was the Victim. Please be advised that departmental policy prohibits the release of reports of this nature to any party except the Office of the District Attorney of Cumberland County or other police agencies. However, this incident was investigated by Officer Robert Powers on May 1, 2013 and Incident Number UAT20130500005 was assigned. Attached is a list of items reported stolen. If you require additional verification or information, please contact the investigative officer named above. Sincerely, James Adams Chief of Police JA/jb A Pennsylvania Accredited En z en Upper Allen Township Police Incident Report Commonwealth of Pennsylvania Incident Number: UAT20130500005 Date Printed: 8/8/20141:15:40 PM Upper Allen Township Police 100 Gettysburg PK Mechanicsburg, PA 17055 Work: (717) 795-2445 Fax: (717) 790-9410 Incident Information Victim Name: Stauffer, William Incident Number UAT20130500005 Locked Report No Status Under Investigation Classification: Adult Reporting Officer Powers ,Robert - 2316 - Upper Allen Township Police Date Of Birth: Date/Time Reported 05/0112013 09:30:00 Date/Time Started 04/28/2013 08:00:00 Date/Time Ended 05/01/2013 09:00:00 IngaentLocation 74 KEEFER Way Mechanicsburg, PA 17055 Synopsis Unknown persons entered an unsecured storage shed and a Carmate storage trailer and stole equipment. Date/Time Cleared Cleared By Weather Family Violence Gang Indicator Victim Information Victim Name: Stauffer, William Victim Type: individual Address: Rhone: Classification: Adult Sex: Male Date Of Birth: Social Security Number, Injury Level: Hospital: Suspect (Relationship): Victim Condition: 8!8120141:15:43 PM Page 1 of 4 Involved Property/Evidence Type Property LosslEtc. Stolen/Etc. Classification: Article Property: Equipment, measuring devices, and tools - HC150 Description: Echo Hedge Trimmer, red Owner Stauffer, William Property Value: $290.00 Type Property Loss/Etc. Stolen/Etc. Classification: Article Property: Equipment, measuring devices, and tools Description: Honda Harmona Self Propelled Mower, red Owner: Stauffer, William Property Value: $366.00 Type Property Loss/Etc. StolenlEtc. Classification: Article Property: Equipment, measuring devices, and tools - Stihl Description: Edger, white and orange Owner Stauffer, William Property Value: $110.00 Type Property Loss/Etc. Stolen/Etc. Classification: Article Property: Equipment, measuring devices, and tools - Stihl Description: Leaf blower, orange & white Owner. Stauffer, William Property Value: $250.00 Type Properly LossJElc Stolen/Etc. Classification: Article Property: Equipment, measuring devices, and tools - Stihl Description: Trimmer, orange & white Owner Stauffer, William Properly value: $110.00 Type Property Loss/Etc. Stolen/Etc. Classification: Article Property: Equipment, measuring devices, and tools - Stihl - 025 Description: Chain Saw, 16" chain, orange & white Owner. Stauffer, William Properly Value $300.00 Type Properly Loss/Etc. Stolen/Etc. Classification: Article Properly: Equipment, measuring devices, and tools - Stihl 8/8/2014 1:15:43 PM Page 2 of 4 Involved Property/Evidence Description: HL Long Hedge Trimmer, 4 ft, orange & white Owner: Stauffer, William Property Value: $150.00 Type Property Loss/Etc. StolenlEtc. Classification: Article Property: Equipment, measuring devices, and tools - Stihl Descriptlon: HT - KM 4ft Chain Saw Ext. Owner: Stauffer, William Property Value: $260.00 Type Property Loss/Etc. Stolen/Etc. Classification: Article Property: Equipment, measuring devices, and tools - Stihl Description: FS 55 Accessory Motor Owner. Stauffer, William Property Value: $340.00 Type Property LosslEtc. Stolen/Etc. Classification: Article Property: Equipment, measuring devices, and tools Description: Hand Grinder, green Owner. Stauffer, William Property Value: $100.00 Type Property Loss/Etc. Stolen/Etc. Classification: Article Property: Equipment, measuring devices, and tools Description: 5 HP Air Compressor, gray, 25 foot hose Owner Stauffer, William Property Value: $180.00 Type Property Loss/Etc. Stolen/Etc. Classification: Article Property: Equipment, measuring devices, and tools - Stihl Description: Leaf Blower, orange & white . Owner Stauffer, William Property Value: $250.00 Type Property Loss/Etc. Stolen/Etc. Classification: Article Property: Equipment, measuring devices, and tools Description: Hand Grinder, green Owner Stauffer, William Property Value: $100.00 8/8/2014 1:15:43 PM Page 3 of 4 Involved Property/Evidence Type Property Loss/Etc. Stolen/Etc. Classification: Article Property. Equipment, measuring devices, and tools Description: Husqvarna Self Propelled Mower Owner Stauffer, William Property Value: $359.00 Type Property Loss/Etc. Stolen/Etc. Classification: Article Property: Equipment, measuring devices, and tools - Stihl Description: Weed Wacker, orange & white Owner: Stauffer, William Propeny Value: $420,676.00 Type Property Loss/Etc. StolenlEtc. Classification: Article Property: Equipment, measuring devices, and tools Description: Milwaukee Impact Screw Gun Owner: Stauffer, William Popery Value: $250.00 Type Property Loss/Etc. Destroyed/DamagedNandalized ClassifiCation: Article Property: Other Description: Padlock damaged Owner. Stauffer, William Property Value: 8/8/2014 1:15:43 PM Page 4 of 4 In the court of Common Pleas for Cumberland County, Pennsylvania William Stauffer 100 S. 15th Street Camp Hill, PA 17011 Plaintiff, V. Ginger Riland 74 Keefer Way Mechanicsburg, PA 17055 Defendant Complaint Cause Number 14-5170 r —4 CIT 3:) Now comes, William Stauffer, who respectfully shows the Honorable court the following: 1. William Stauffer (hereafter "Plaintiff') is an individual residing at 100 S. 15th Street Camp Hill, PA 17011. 2. Ginger Riland (hereafter "Defendant ") is an individual residing at 74 Keefer Way Mechanicsburg, PA 17055 3. This complaint is filed in response to the Defendant's Appeal of a Judgment entered in Cumberland Co. MDJ Court 09-3-05; cause number MJ -09305 -CV -0000073-2014. rn c�- 4. Defendant purchased two (2) Galaxy Phones for $699.60 each on Plaintiff's T Mobile Phone plan with a two year contract, Which Plaintiff is paying for. These phones are in the Defendant's Possession. Plaintiff requests these phones be returned to him, including all accessories. 5. Defendant is in possession of Harley Davidson Memorabilia items belonging to the Plaintiff. Plaintiff request that these items be returned to him• A Harley Davidson pocket watch and two (2) Special Edition Harley Davidson V rod models. Wherefore, Plaintiff respectfully requests this court dismiss the Defendant's claim and grant judgment in his favor. Respectfully, William Stauffer 100 S. 15th St Camp Hill, PA 17011 Tel: (717) 343-8366 In the court of Common Pleas for Cumberland County, Pennsylvania William Stauffer 100 S. 15th Street Camp Hill, PA 17011 Plaintiff, V. Ginger Riland 74 Keefer Way Mechanicsburg, PA 17055 Defendant Cause Number 14-5170 Verification William Stauffer, Deposes and says, Subject to the penalties id 18 pa. C.S.4904 relating to unsworn falsification to authorities, that he makes this verification by his authority and that the facts set forth in this complaint are true and correct to the best of his knowledge, information and belief. William Stauffer In the court of Common Pleas for Cumberland County, Pennsylvania William Stauffer 100 S. 15th Street Camp Hill, PA 17011 Plaintiff, V. Ginger Riland 74 Keefer Way Mechanicsburg, PA 17055 Defendant Cause Number 14-5170 Certificate of service I, William Stauffer, hereby certify that on the /,,4A day of e;7z/ey,1/60-,,.20/9 a copy of the Plaintiff's Complaint was sent by first class mail, postage paid to the Defendant, addressed as follows: Ginger Riland 74 Keefer Way Mechanicsburg, PA 17055 Respectfully, William Stauffer In the court of Common Pleas for Cumberland County, Pennsylvania William Stauffer 100 S. 15th Street Camp Hill, PA 17011 Plaintiff, V. Ginger Riland 74 Keefer Way Mechanicsburg, PA 17055 Defendant Cause Number 14-5170 Answer to Defendant's Complaint 0r tea GO tit Now comes William Stauffer, the Plaintiff in this appeal, Files these Objections to Defendant's Complaint. 1. William Stauffer (hereafter "Plaintiff') is an individual residing at 100 S. 15th Street Camp Hill, PA 17011. 2. Ginger Riland (hereafter "Defendant ") is an individual residing at 74 Keefer Way Mechanicsburg, PA 17055 3. This answer is filed in response to the Defendant's Appeal of a Judgment entered in Cumberland Co. MDJ Court 09-3-05; cause number MJ -09305 -CV -0000094-2014. 4. On or about May 1, 2013 Plaintiff reported a theft of equipment and power tools that happened at an indeterminate time shortly before the report was made. 5. The stolen items included tools owned by the Plaintiff only as supported by the police report. 6. Defendant was reimbursed through her home owners insurance for her tools allegedly stolen. This money was not given to Plaintiff to replace his tools. Wherefore, Plaintiff respectfully requests this court dismiss the Defendant's claim and grant judgment in his favor. Respectfully, William Stauffer 100 S. 15th St Camp Hill, PA 17011 Tel: (717) 343-8366 In the court of Common Pleas for Cumberland County, Pennsylvania William Stauffer 100 S. 15th Street Camp Hill, PA 17011 Plaintiff, V. Ginger Riland 74 Keefer Way Mechanicsburg, PA 17055 Defendant Cause Number 14-5170 Verification William Stauffer, Deposes and says, Subject to the penalties id 18 pa. C.S.4904 relating to unsworn falsification to authorities, that he makes this verification by his authority and that the facts set forth in this answer are true and correct to the best of his knowledge, information and belief. William Stauffer In the court of Common Pleas for Cumberland County, Pennsylvania William Stauffer Cause Number 14-5170 100 S. 15th Street Camp Hill, PA 17011 Plaintiff, V. Ginger Riland 74 Keefer Way Mechanicsburg, PA 17055 Defendant Certificate of service I, William Stauffer, hereby certify that on the /07 day oflewembe.e/0( a copy of the Answer to Defendant's Complaint was sent by first cla s mail, postage paid to the Defendant, addressed as follows: Ginger Riland 74 Keefer Way Mechanicsburg, PA 17055 Respectfully, William Stauffer In the court of Common Pleas for Cumberland County, Pennsylvania Ginger Riland 74 Keefer Way Mechanicsburg, PA 17055 Defendant, V. William Stauffer 100 S. 15th Street Camp Hill, PA 17011 Plaintiff Cause Number 14-5170 Answer to Plaintiffs Complaint Now comes Ginger Riland, the Defendant in this appeal, Files these Objections to Plaintiff's Complaint. 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. His tools as well as mine. 5. Denied. Items on police report included his tools as well as mine. 6. Denied. Tools owned by Defendant. Insurance reimbursed for her tools only. 7. Denied. Plaintiff paid for tools in partial. 8. Denied. Defendant paid parts of the bill. 9. Admitted. Defendant is not claiming that any of these items belong to her. 10. Admitted. Plaintiff paid by credit card after Defendant gave him cash to purchase item. 11. Denied. Defendant paid by cash. 12. Denied. The balance was much higher and Plaintiff did not pay balance of the bill. 13. Denied. Items purchased at least 1 year prior to when Plaintiff left the premises. 14. Admitted in part to purchasing item. After reasonable investigation Defendant denies as to allegations that she returned the chain saw. 15. Admitted. Defendant has attempted to return phones on several occasions and can provide proof. 16. Denied. Defendant has none of these items and has no knowledge as to where they are. Wherefore, Defendant respectfully requests this court dismiss the Plaintiff's claim and grant judgment in her favor including court costs. u��IslHW In the court of Common Pleas for Cumberland County, Pennsylvania Ginger Riland 74 Keefer Way Mechanicsburg, PA 17055 Defendant V. William Stauffer 100 S. 15th Street Camp Hill, PA 17011 Verification Cause Number 14-5170 Ginger Riland, Deposes and says, Subject to the penalties id 18 pa. C.S.4904 relating to unsworn falsification to authorities, that she makes this verification by her authority and that the facts set forth in this answer are true and correct to the best of her knowledge, information and belief. Ginger Riland (240-/