HomeMy WebLinkAbout05-2835COMMONWEALTH OF PENNSYLVANIA
URT OF COMMON PLEAS
JUDICIAL DISTRICT
I:: AS
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS Na 0? - p?
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 District Justice on the
dale and in the case mentioned below.
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This block will be signed ONLY when this notation is required under Pa. R.C.P.JP. No
1008L
This Notice of Appeal, when received by the District Justice, will operate as a
SUPERSEDEAS to the judgment far possession in this case
aFPeelke(s)
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.JP. No. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prothonotary
Enter rule upon
(Common Pleas No
It appellant was CLAIMANT (see Pa. R.C.P.JP. No.
1001(6) in action before District justice, he MUST
FILE A COMPLAINT within twenty (20) days after
appellee(s), to file a complaint in this appeal
) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
RULE: To Si9natae W aPwih nt or ft aaoaW or agent
Kane of appellee(s) . 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 mOiL
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL SE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of mailing.
Date:
AOPC 312-SO
Signature of Prothonotary or Deputy I filing his NOTICE of APPEAL.
19_.
SiD'?aDre d RdhafD?y a oswl,r
COURT FILE TO BE FILED WITH PROTHONOTARY
? a
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 the notice of appeal. Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ; ss
AFFIDAVIT: I hereby swear or affirm that I served
CJ a copy of the Notice of Appeal, Common Pleas No. - , upon the District Justice designated therein on
(date of service) by personal service []by (certified) (registered) mail, sender's
receipt attached hereto, and upon the appellee. (name) -" on
19 0 by personal service ? by (certified) (registered) mail, sender's receipt attached hereto.
? and furtherthat i served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appeliee(s)to whom
the Rule was addressed on 119-- ? by personal service [] by (certified) (registered)
mail, sender's receipt attached hereto,
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS
DAY OF
19_._-__
Signature of affiant
Sigrzatura of o6tcre7 be/ore w@om of 1dallf was Made
Title of offiolat
my comtt&ssion expires or
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
Mag. Dist No
09-3-04
MDJ Name: Hon..
THOMAS A. PLACEY
Addrea5- 104 ;S. SPORTING HILL RD
MECHANICSBURG, PA''
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF CIVIL CASE
NAME and ADDRES$ `
FTHE MAY DEPT. STORES D/B/A HECHT'S?
111 BOULDER` INDUSTRIAL DR
BRIDGETON, NO 60344
-J
V.S.
,. s
THE MAY DEPT. STORES D/B/A HECHTIS
111 BOULDER INDUSTRIAL DR
BRIDGETON, NO 60344
DEFEND,ANT:' _ NAME and. ADDRESS
?soL?IVAN, MBG?,N A ?
'2228 GLEIM' COIIRT
ENOLA, PA 17,025
L J
F ket No.: CV-0000728-04
e Filed: 11/24/04
THIS IS TO NOTIFY YOU THAT: I
Judgment:. .. .- 11 % A- FOR'DEFEND NT
0 Judgment was entered for: (Name) RDT.T.TVAM Mlt(2AM A
0 Judgment was entered against: (Name) THE MAY DEPT STORES D/B JA HEr
in the amount of $
on: (Date of Judgment) s/i 6/ns
Defendants are jointly and severally liable. (Date & Time)
Damages will be assessed on: Amount of Judgment $ , . 00
Judgment Costs $ .00
This case' dismissed without prejudice. Interest on Judgment $ . 00 ' .
Attorney Fees $ .0
0
Total. $ .00 '
? Amount of Judgment Subject to
Attachment/,42 Pa.C.S. § 8127 $ Post Judgment Credits $
Portion of Judgment for physical Post Judgment Costs $
damages arising out of residential ------------
lease $ Certified Judgment Total $
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 THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OFJUDGMENT/TRANSCRIPT.FORM -WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL. DISTRICT JUDGES, IF THE
JUDGEMENT 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.
Date Magisterial District Judge
f'certify'that this is a true a d correct copy of the record of the p oceeding's contain mg the judgment.
5 1& 06 Date n
Magisterial Distract Judge
My commission expires first Monday of January 2010 . SEAL
AOPC 3t5-o5 DATE PRINTED: 5/16/05 1:49:25 PM
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COMMONWEALTH OF PENNSYLVANIA NOTICE OF APPEAL
COURT OF COMMON PLEAS
FROM
JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No. o "' :W-"' f 1')
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 District Justice on the
date and in the case mentioned below.
MAC. DIST. NO OR NAME OF DJ.
be 3-0?'
ADDRESS OF uANT CITY STATE ZIP CODE
III P-.,i,4 Id-e, In )t, 0/ A- Pay 410 6-3oV4-.
DATE OF JUDGMENT IN THE CASE OF (Plaintiff) (Defendarl)
4 (b?, 2 Ja S the da a/?I-f i ?,y? 0414 /1ec4? /?
CLAN NO SIGNATURE OF APPELLANT OR HIS ATTORNEY OR AGENT
CV St _R2 , 014
LT 19
This block will be sighted ONLY when tl?is notatiori is required under Pa.,,R.C.P.JA "a If appellant was CLAIMANT (see Pa. R.C.P.J.P. No.
10088.
This Notice of Appeal, when received by the District Justice, will operate as a 1001(6) in action before District Justice, he MUST
SUPERSEDEAS to the judgment for possession in this case FILE A COMPLAINT within twenty (20) days after
Signature of Prothonotary or Deputy filing his NOTICE of APPEAL.
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.J.P. No. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prothonotary
Enter rule upon Name of agoelleefs) appellee(s), to file a complaint in this appeal
(Common Pleas Na ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
RULE: To
Signature of appellant or his attorney or agent
Name of appellees)
, oppellee(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 WILL BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of mailing.
Date: ' 19
I
P
Signature of Prothonotary or Deputy
i
AOPC 312-90 COURT FILE
Ron Z. Opher, Esquire
Attorney for Plaintiff
Attorney#57507
P.O. Box 2245
Southeastern, PA 19399
(610) 902-0530
THE MAY DEPARTMENT STORES
d/b/a Hecht's
11 I Boulder Industrial Dr.
Bridgeton. MO 63044
Plaintiff
V.
MEGAN A SULLIVAN
2228 GLEIM CT
ENOLA, PA 17025
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
NO. Cl ?lL zl , 7
COMPLAINT - CIVIL ACTION
NOTICE TO DEFEND AVISO
You have been sued in court. If you wish to defend Le han demando a usted en la corte. Si usted quiere defenderse
against the claims set forth in the following pages, de estas demandadas expuestas en las paginas siguentes, usted
you must take action within twenty (20) days after tiente veinte (20) dias de plazo al partir de la fecha de la
this complaint and notice are served, by entering a demanda y la notification. Hace falta asentar una comparencia
written appearance personally or by an attorney and escrita on en persona o con un abogado y entregar a la corte
filing in writing with the court your defenses or enforma escritas sus objectiones a las demandas en contra de
objections to the claims set forth against you. You su persona. Sea avisado que si usted no se defende, la corte
are warned that if you fail to do so the case may tomara medidas y puede continuar la demanda en contra suya
proceed without you and a judgment may be entered sin previo aviso o notification. Ademas, la corte puede decidir
against you by the court without further notice for a favor del demandante y requiere que usted cumpla con todas
any money claimed in the complaint or for any other las provisiones de esta demanda. Usted puede perdes dinero o
claim or relief requested by the plaintiff. You may us propriedadedsu otros derechos importantes para usted.
lose money or property or other rights important to you . LLEVE ESTA DEMANDA A UN ABOGADO
YOU SHOULD TAKE THIS PAPER TO YOUR INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO
LAWYER AT ONCE. IF YOU DO NOT HAVE A TIENE EL DINERO SUFFICIENTE DE PAGAR TAL
LAWYER OR CANNOT AFFORD ONE, GO TO OR SERVICIO, VAYA EN PERSONA O LLAME POR
TELEPHONE THE OFFICE SET FORTH BELOW TO TELEFONO A LA OFFICINA CUYA DIRECCION SE
FIND OUT WHERE YOU CAN GET LEGAL HELP. ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Ave ASSOCIACION DE LICENCIADOS DE CUMBERLAND
Carlisle, PA 17013 2 Liberty Ave
(717) 249-3166 Carlisle, PA 17013s
(717) 249-3166
Ron Z. Opher, Esquire
Attorney for Plaintiff
Attorney #57507
P.O. Box 2245
Southeastern, PA 19399
(610) 902-0530
The May Department Stores,
d/b/a Hecht's
111 Boulder Industrial Dr.
Bridgeton, MO 63044
Plaintiff
V.
MEGAN A SULLIVAN
2228 GLEIM CT
ENOLA, PA 17025
Defendant
IN THE COURT OF COMMON PLEAS
Cumberland COUNTY, PA
No. 0 - Z U35 G V IL -Trr--?
COMPLAINT - CIVIL ACTION
COUNT ONE
1. The Plaintiff herein is The May Department Stores, d/b/a Hecht's, located at 111
Boulder Industrial Dr., Bridgeton, MO 63044.
2. The Defendant herein is MEGAN A SULLIVAN, an adult individual located at
2228 GLEIM CT, ENOLA, PA 17025.
3. Defendant borrowed from Plaintiff, by way of purchases on account
#00000061999040 the sum of $1057.47 over the course of the parties' cardholder relationship, as
of 9/28/04. A true and correct copy of an affidavit of account is attached hereto and marked Exhibit
"All
4. Under the terms of the cardholder agreement, additional interest has accrued, and
continues to accrue, from 9/28/04, at the rate of 21.6% per annum. A true and correct copy of the
relevant cardholder agreement terms is attached hereto and marked Exhibit "B".
5. In addition, Defendant agreed to be liable for Plaintiffs actual costs of collection,
including court costs and attorney's fees; said attorney's fees being contingent on recovery, at the
rate of 35%. See Exhibit "B".
6. Plaintiff has in all respects fulfilled all conditions precedent to its obligations on the
contract and for bringing this Complaint to damages.
7. Despite repeated demand by Plaintiff, Defendant has refused and continues in
failure and refusal to pay further amounts due Plaintiff.
WHEREFORE, Plaintiff demands judgment in its favor against Defendant, in the amount of
$1057.47, together with interest at the contract rate of 21.6% per annum commencing on 9/28/04,
and attorney's fees at the rate of 35%, and costs of this action.
COUNT TWO
Plaintiff also claims alternatively on the basis of quantum meruit or Quasi Contract.
Paragraphs 1 through 7 above are incorporated herein by reference as though fully
set forth.
9. Plaintiff was neither a volunteer nor an officious intermeddler.
10. Plaintiff provided said credit.
11. Plaintiff expected payment from the Defendant for said credit in the amount set
forth above.
12. The amount claimed is the fair and reasonable market value for said credit.
WHEREFORE, Plaintiff demands judgment in its favor against Defendant, in the amount of
$1057.47, together with interest at the contract rate of 21.6% per annum commencing on 9/28/04,
and attorney's fees at the rate of 35%, and costs of this action.
Dated: Monday, June 6, 2005
BY
Ron Z. Opher, Esquire
Attorney for Plaintiff
AFFIDAVIT OF ACCOUNT
STATE OF MISSOURI
ss.
COUNTY OF ST. LOUIS
BEFORE ME, the undersigned authority, on this day personally appeared the undersigned
Affiant, who swore on an oath that the following facts are true.
1. My full name is Rich Orlet.
2. I am a Recoveries Supervisor at The May Department Stores, d/b/a Hecht's, and I have full
knowledge of the books and records concerning the account of MEGAN A SULLIVAN (account
number 00000061999040), the Defendant(s) herein.
3. These records show that a total principal balance of $1057.47 together with interest at the
rate of 21.6% , commencing on 9/28/04, is due Plaintiff and payable by the Defendant(s) herein. In
addition, attorney's fees per terms of the credit card agreement are due and owing, at the rate of 35%
of principal and interest. This affidavit regarding the account of the Defendant(s) herein, which
constitutes this cause of action, are taken from the original records of entry.
4. The total amount of the account is due Plaintiff by Defendant(s) and all just and lawful
offsets, payments and credits have been allowed.
Rich Orlet, Affiant
SUBSCRIBED AND SWORN to before me on the day of , 2061/
J l?
Notary Public
CATHERINE M. RUDY
NOTARY PUBLIC - NOTARY SEAL
STATE OF MISSOURI
ST. LOUIS COUNTY
EXPIRATION: MAY 23, 2008
HECHT'S RE -MIL INSTALLMENT QPaN-ENE CREDiT PLAN AND SECUFIrIly AGREEMENT
Please read this Agreement carefuliy This Agreement means this document as supplemented from time to time by information on your agpicatiort, any sales tMlMts, rarPtpS
and any Ober documents setting forth your obligations under your Hechts account, In Ihfs Agreement `Hedtrs' means The May National Bank of Ohio, 300 Sheffield Center, Lorain
Ohio, 44051, an Affiliate- of The May Department Stores Company CUay+') and May trading arri doing business as Herts. "You' and your' mean eaar and all persons Who Sion or sub
mt an appk2ion for or use a Hechts amount 'Acmu t means any one or more accourifs theyou have with Ha ht's.ThisAgreement, tooefherwith an other documents supplememnv
orsubjegiv 4tisAoreement, explains the terms that oovem Hecht's accounts and how to use them You agree to the terns a, this Agreement bysubmitfing an application for an -Urn
signing an applfation for iu account or if either you or an authorized iser esa:the accoura in anyway.
FOUR IONDS OF ACCOUNTS Hechts offers four kids of credit accounts - the Flexibb Charge Account, the Time Option Purchase Account, the Table Ton Anmunt, and, from Eene to
time at Hacks sofa election, the Fine Jewelry AccouriL
iioW TO [SE YOUR ACCOUNT
Faidbie Charge Acc=I- f you have a faezfble' Charge Account, you tray use this accoitrit for al purchases from Hecht's subiert to usual credit atrthorizafidn procedures.
Time Opton Ptuclum AccounHf you have a Tane Option Purchase Account, you may use this aunt for purchases of individual fiems costing 5200 or more. Simply rerl -t
70P Acommr of your salesperson at the tine of purchase. Eligible Hems include appuances, iumbua, carpeting and Srw jewely.
Tahh Top A wft It you have a Table lop Accourit, you may use the amount for purchases of sirvar, china and crystal asfing $200 or more,. -
Fine Jewelry Aecnrmt-if Hechts offers and you are approved for a Fine Jewelry Amount you may use the account for purchases of tine jewelry costing S00 or more.
DPr711N6 THE ACCDllNT-tar may apply for and Hechts may approve one or more kinds of amorns for you. Mark on your appfiauon wh h account(s) you wish to open, Hechts
will notify you if your appli;aiion is approved or dedined.
INFOR9ATiON DN APPUCATION.
1. You state that information that you have given in your appr=bun is true and complete,
2 You understand that Hecht's will not return your application to you.
3. You au'Jror¢e•Hemts to check your credit and work history.
4. You acowwedg=lfiat Hecht's has given you a copy of the Open-End Credit Plan and Security AoreemenL
a. You agree to all items of this Aoteemant
If you have requested a Flexible Charge Account you ask that Hecit's send you a credit card(s).
CREDIT f.JLSi1-Your amount will have a credit limit set by Hechts. Hechts may increase or decrease your credit Inn i from. firm to time.
RETURNM CHECKS; PAYMENT F."c_SS- {f you pay by check and the checWs returned unpaid for any reason to Hechts, Hechts may essess a 'returned 'chmll fee of up to 521 to
your a=murrt Addirforieliy you agree that any returned check* may be electrorially represented for payment at your bank at any time until final paymentis made, and you agree to pay
a service mane of LT m a.D,for any instrument we prepaie on your behaff for payment purposes.
PURCHkS_,S-You auttmodze Hechts to came to your aunt all purchases tat you, or any members of your tamiy, any of her person who resides with you, or anyone visa amh-`
azwk-by you, make on yourmaccourd.
PTiO SET ?AY You on,-to pay ao atrnsxs duaan your acmu,k n?sgn v+hr, ass .ad car?u;?„; trs ?.,?::sM n orany ux-v=.....mm s!. *-e t.: Simi o
this Agreement .1who is named as a point account holder is responsible alone and together with amiyon- else signing for all amouhts due on the account You are also responsN__ for
any charges made by arty member, of yourfamoy, any other Damon who resides with you or anyone you have authorsed to use the account.
CREO T CARDS-At your recues4 Hectit's ray issue credit casda to you and others authorized by you But Heclmfs wit! issue credit arils any for your Plemble Charge Acmutd The
cards are the property of Hechts. If Hedihts asks you to return, the cards, you must do so at once. Any cards issued to ofner pesods at your request are governed by t is terms of this
Agreement. You agree to rotay Hechts at once 6 any art} is iost or siolen
yis114 h.LY ?ATEK=ni?achfs wu'Tsaridydir rimont iiysiatemenf to each anmunt wtTene4erfhereis a't add or`deba as a s? of or more "-
PAYtEENTS-You agree to pay the montimly payment reouired• on each aunt on or before lithe bayment due data shown on your montn' , sta emant. The r mmerit dus-daie will be at
tent-25 days after frig closing date a your previous billing period You :art lay more than the required payment o any iirm. Your monthly statement will show your 'New Baiancs'.
i rz: merrily payment required for the account, ar '
rRmdblL CftarQe Accauttt
WEEK BALANCE RM- 1.11 "_D MONTHLY PAYMENT
Up it, S?5 Balance in Full
525 to 51'00 m
$700" and over 15%of his Nlaw Balance rounded up to-tlie ri-_m muuiole o S10.
T16f= (?QFIQ?? °' T u ^ =s' i? coxed,at any one ume before the a-mugrls. CG^plae y sea=cat,.^ a; is „a ti i} --at, o rot :ea vac,2n rot do not
dscxeas? vattiraui?Tamase -ai time unpsid halarx:e - -- - -
Hmaie5TRAL ANC= RE(' uIRMMONTHLYPAYMENL
Up to $320 - s?q or balance cf a.. cunt, wh crever is Less.
=0 and over 6 114% of highest balance rounded up to the nit inuiftle of si
TABLE TOP ACCOUNT-Forth- purchase of cnna, gtassw•am, silver and Watanord lama; ocsfirg $200 or more, the highest balance owed at any hoe R e before ire a_cunt
is comPlaley cleared ds-Larmines time monthly payment reouired, and the payments do nor decease with a decreass in the unpaid balance.
H1uH_=S7 BALANCE REQUIRED MONTHLY PAYhf=N7
UP to 5480 520, or balance of amount. wfhichevet is less,
3480 and-over 41i6% of highest balance rounded uo to the het muldpie of _; a
ENE JEWELRY-ACCOUNT-For the p r chzse of floe jewelry costing 5500 or more, the highest balance owed at any time before the account is completely ti=ered det=_mins
the monthly payment required, and the oavments do not de case wit .a der reaseTnln= unpaid tzl ir6e.
Hlu f_5T BALANCE - REQUIRED MONTHLY PAYM=NT
I S5D0 and over 1112 of highest ba.anrr rounded up to the next multioLa of $5.
RR=RR:-For autisorrization and collection oumoss, eedes mrTEWME_d me,u4andrse, are net vend hn firs same manner z payment.
am v?uTU`?4CR--' =- `-"J- - _--- s^eUniiedStatespovamthiskmaement
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
THE MAY DEPARTMENT STORE.,
d/b/a Hecht's
Plaintiff NO. 05-2835 CIVIL
vs.
Defendant Civil Action - Law
ANSWER
COUNT ONE
AND NOW comes the Defendant and files this Answer and in support thereof responds
as follows:
1. Admitted.
2. Admitted.
3. Admitted in part and Denied in Part. It is admitted insofar as Defendant has a
balance due on the card. The terms and contents of "Exhibit A" speak for themselves. Defendant
specifically denies and disputes owing the amount of $1057.47 to plaintiff and strict proof,
explanation and evidence of the calculation of this sum is demanded.
4. Admitted. The terms and contents of "Exhibit B" speak for themselves.
5. Admitted. The terms and contents of "Exhibit B" speak for themselves.
6. The averments contained in Paragraph 6 of plaintiff's complaint constitute
conclusions of law to which no response is required.
7. Denied. Defendant has never made and outright refusal to pay.
WHEREFORE, defendant demands judgment against plaintiff and that plaintiff's
complaint be dismissed with prejudice.
COUNT TWO
8. Admitted.
9. Admitted.
10. Admitted.
11. Admitted in Part and Denied in Part. It is admitted that Plaintiff expected
payment from Defendant for said credit, however, the amount owing to Plaintiff is disputed.
12. Neither admitted nor denied. After reasonable investigation, defendant is unable
to form an opinion as to the truth of the averments contained in Paragraph 12 of plaintiffs
complaint.
WHEREFORE, defendant demands judgment against plaintiff and that plaintiff s
complaint be dismissed with prejudice.
Date: TanMe.At. ullivan
Pro Se De endant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
THE MAY DEPARTMENT STORE.,
d/b/a Hecht's
Plaintiff
NO. 05-2835 CIVIL
vs.
MEGAN SULLIVAN,
Defendant
Civil Action - Law
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Answer has been
served by first class mail, postage pre-paid upon the following :
Ron Z. Opher, Esquire
PO Box 2245
Southeastern, PA 19399
(610) 902-0530
Date: U , avu?u? '" \ 'S&L-??
Megan livan
Pro Se De endant
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Ron Z. Opher, Esquire
Attorney for Plaintiff
Attorney#57507
P.O. Box 2245
Southeastern, PA 19399
610-902-0530
THE MAY DEPARTMENT STORES
d/b/a Hecht's
V.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
DOCKET NO. 05-2835 CIVIL TERM
Plaintiff
MEGAN A SULLIVAN CIVIL ACTION -LAW
Defendant
STATEMENT OF INTENTION TO PROCEED
TO THE COURT:
I hereby certify that Plaintiff, THE MAY DEPARTMENT STORES, d/b/a Hecht's, intends to
proceed with the above-captioned matter.
At the same time, dismissal and/or termination of this case would work an undue prejudice to
Plaintiff, most particularly relative to statute of limitations issues; therefore, Plaintiff requests
that the case remain on active status.
DATED: October 21, 2008
BY
Ron Z. Opher, Esquire
Attorney for Plaintiff
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David D. Bueff f
Prothonotary
Kirks. Sohonage, ESQ
Soricitor
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Renee X. Simpson
1'` Deputy Prothonotary
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Irene E. 9dorrow
2nd Deputy Prothonotary
office of the Prothonotary
Cum6erland County, 1Tennsykania
65-,P283Y CIVILTERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 25T" DAY OF OCTOBER, 2011, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R.C.P 230.2
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY
0 ne Courthouse Square • Suite 100 • Carh'sle, PA 17013 * (717) 240-6195 • Fax(717 240-6573