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Home My WebLink About06-0490GENEVIEVE M. RODDY, PLAINTIFF vs. DENNIS R. HOSKINS, DEFENDANT NOTICE TO DEFENDANT NAMED HEREIN: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.???, 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 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 GENEVIEVE M. RODDY, PLAINTIFF vs. DENNIS R. HOSKINS, DEFENDANT COMPLAINT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. JG - Y96 (!,e _Tc AND NOW, comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and makes the following Complaint in this matter. 1. The Plaintiff is Genevieve M. Roddy an adult individual who resides at 414 N. 21" Street in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is Dennis R. Hoskins an adult individual who resides at 7981 Old Tramway Drive in Melbourne, Florida 32940. 3. The Defendant was married to Plaintiffs daughter, Patricia Hoskins, until her death in March of 2003. 4. In August of 2001, Plaintiff loaned Defendant the sum of $10,000.00 by issuing a payment to Commerce Bank at the request and direction of the Defendant an exchange for Defendant's promise to repay that sum to Plaintiff. 5. In November of 2002, Plaintiff loaned the Defendant the amount of $10,000.00 by issuing a check to the Defendant in that sum in exchange for Defendant's promise to repay the loan to Plaintiff. Attached hereto and marked as Exhibit A are copies of the checks described in this Paragraph and the immediately preceding paragraph. 6. Despite repeated requests from Plaintiff, Defendant has failed to repay the loans Plaintiff made to Defendant or any portion of those loans. Defendant, by his conduct, has injured Plaintiff in the amount of the loans, plus interest at the legal rate. WHEREFORE, Plaintiff prays this court to enter judgment against the Defendant in the amount of $20,000.0 I verify that the statements made in this document are true and correct. I understand that anv false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: - C' 0 C, GENEVIEVE M. RODDY r__,.,.... EXHIBIT A GENEVIEVE RODDY ata N. 21ST G ST. x;784 CAMP HILL, PA 17011 313 1971 5f2077TV r htp,-p y 11?, Commerce C'BBOk ?HgnisDurg, NA. 100 CAMP HILTE AVE, L. PA 1 JOI I 1:03130i846?: 51 207718 Lii¦ h0? 19 7 1 ,11000 ;0000 0,11 GENEVIEVE M. RODDY 4 6 1834 414 N. 21ST ST. al 5120771 1 CAMP HILL, PA 17011 L c 1 -- -T V v 1'6 l- Commerce x12.00 -t?ac?;SHEDrS+??K Ban kir? ? 77?>, t?•N BM L AivDH ?? !wr1?n_ 4.'`' .. (I.J?Yl 12 J-cva t.. IV 0%!/ 1:0313018461: 5i 207718 111• 1834 11'0 10000 11' h 4,h? l v, `-4 SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2006-00490 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RODDY GENEVIEVE M VS. HOSKINS DENNIS R R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT HOSKINS DENNIS R by United States Certified Mail postage prepaid, on the 25th day of January 2006 at 0000:00 HOURS, at 7981 OLD TRAMWAY DRIVE MELBOURNE, FL 32940 and attested copy of the attached COMPLAINT & NOTICE with a true Together receipt card was signed by SIGNATURE ILLEGIBLE 01/28/2006 . Additional Comments: Sheriff's Costs: Docketing 18.00 Cert Mail 4.64 Postage .39 Surcharge 10.00 .00 33.03 Paid by SAMUEL ANDES Sworn aqd subscribed to before me this?'-day of ,? c, aeyL A.D. 7 The returned on So answ R. Thomas Kline Sheriff of Cumberland County on 01/31/2006 ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is deatred. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attac is card to the back of the mailpiece, or o m N space permits. 1. Article Abrassed to: Dennis R. Hoskins 7981 Old Tramway Drive Melbburne, FL 32940 A. X 0 Agent B. RecaNW by (Printed Name) C. Date of Delivery D. Is delivery address different from item 17 13 Yes If YES, enter delivery address below: 0 No 3. Service Type g Certified Mall ? Express Mail 13 Registered ? Return Receipt for Merchandise ? Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 13 Yes 7005 0390 0003 2635 0371 05-490 civil PS Form 3811, February 2004 Domestic Return Receipt rozsssoz-na-tsao n GENEVIEVE M. RODDY, Plaintiff vs. DENNIS R. HOSKINS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-490 CIVIL TERM REPLY TO NEW MATTER AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and makes the following Reply to Defendant's New Matter: 7. It is admitted that the first advance of funds made to the Defendant on the loan transaction which is the basis of this action was made in August of 2001. 8. Plaintiff admits that Defendant never made a payment to Plaintiff on the loan he owes her. 9. Denied. Plaintiff's claim in this matter is not barred by the statute of limitations and Plaintiff is entitled to recover the money she loaned to Defendant. Samuel L. Ande Attorney for Plaintiff Supreme Court ID 17225 525 North 12" Street Lemoyne, PA 17043 (717) 761-5361 I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). DATE: /INA G F? ln . 6r CERTIFICATE OF SERVICE I hereby certify that on 2006, 1 served a copy of the foregoing document upon counsel for Defendant by U.S. Mail, postage prepaid, addressed as follows: James H. Turner, Esquire 4415 North Front Street Harrisburg, PA 17110 CY-1., Samuel L. Andes Attorney for Plaintiff Supreme Court ID 17225 525 North 12" Street Lemoyne, PA 17043 (717) 761-5361 _ li -J %w ?. Y: '. .' is 1 .i. ..lJ .. • < ?.. ? GENEVIEVE M. RODDY, ) Plaintiff ) VS. ) DENNIS R. HOSIGNS, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'T'Y, PENNSYLVANIA CIVIL, ACTION - LAW NO. 2006-490 CIVIL TERM PETITION FOR APPOLN't`tirFNT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Samuel L. Andes, counsel for the PLAIN'T'IFF in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the P-L N 'IFF in the action is less than $20,000.00. 3. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: Samuel L. Andes, for Plaintiff and James H. Turner, for Defendant. WHEREFORE, your petitioner prays this Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully Submitted, 4;? Samuel L. Andes Attorney for PLAIN'T'IFF ORDER OF QRT AND NOW this , 2006, in consideration of the foregoing petition, Esquire, and Esquire, > Esquire are appointed arbitrators in the above- captioned action as prayed for. By the Court, J. r.a C c ?? ?? ?. ?? ? . ?? Q ,,. ?. ?@ ? ?' c ?.' ? w ?? ?. .?..;?. GENEVIENE M. RODDY PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DENNIS R. HOSKINS, DEFENDANT 06-0490 CIVIL TERM ORDER OF COURT AND NOW, this o? day of October, 2006, the appointment of David Spotts, Esquire, to the Board of Arbitrators in the above-captioned case, IS VACATED. Stephanie E. Chertock, Esquire, is appointed in his place. By the C 0v Edgar B. Bayley, J. Iliam C. Costopoulos, Esquire Chairman Petephanie E. Chertock, Esquire Court Administrator sal cr% LL- p .n ? ?7 N ?r,? y e es C- H. I cgclcl1 Plaintiff r?nls ?. ?n?klns Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No.C(-- ?cj C, Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with delity. S 11IO,,m C. CQs alt,los Name (Chairman) Law Firm ?r3 i_ t-'1 ??r k c. I- S P e Address I--e.maini J7L' 3 City, Zip 1 tUIC N La Firm ?0I W es } Address CA,I tg1? 17 013 City, zip Signature .l o L4 A S?4 ?1R-r Name JQ b 14 E,02 PA e Law Firm 3D I Mer)uI S( Address _70y3 city, zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated) -rn -G4Vr,r n•E ?ht &A in h4 In -N, cry tA.n}-- o? ? a b. Oon :e cc-, (6 ( n -fie re -6- Date of Hearing:_` C?7 ?3wI-?7 Date of Award: 4 pr, dissents. (Insert name if applicable.) Notice of Entry of Award Y +1 Now, the day of ADr;l , 20 L 7 , at );,r-).3 , __R_.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $_ 350. 00 By: Prothonotary Deputy y Y ?Vr pef Ve r GENEVIEVE M. RODDY, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ) CIVIL ACTION - LAW DENNIS R. HOSKINS, ) NO. 06-490 CIVIL TERM Defendant ) PRAECIPE TO THE PROTHONOTARY: Please enter judgment against the Defendant Dennis R. Hoskins, and in favor of the Plaintiff Genevieve M. Roddy, in the amount of $20,000.00, in accordance with the Award of Arbitrators in this matter dated 1 March 2007, a copy of which is attached to this Praecipe. 9 May 2007 Sam-U61 L. Andes' Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 (717) 761-5361 PlainT- nr11S ?. An,, kin S Defendant In The Court of Common Pleas of Cumberland County, PennsylvaniaNo.CG' - c Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with delity. i i tore Signature cn-i s j2os S?Aofni' t. elute o In 14 • y?1 a Co Name (Chairman) Na Name Law irm. ,Y-3i !-'16Lr L. l- S f r- e e4 Address city, zip &0-? La Firm Address 64-o tgl, l -?013 city, zip Jo ? ,5w l? u e Law Firm 3o I AA# v )Lp I sl Address LK -f zip city, Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) (b ) `7`6 PlrA in hlT in `I-P)e 4-,moiA n i--- o-- 4-a[ . non ; z-e Cr, n -4-e re 6- Date of Hearing: 9- L 0-7 3-1-v7 3-1-0-7 of Award: 4 , dissents. (Insert name if a Notice of Entry of Award Now, the and day of 20 D 7 , at 1:63 , P M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ 350. OD qPVM M Tudn"rrWW, 6 "Mo set tq f By: ! dike _0 M said 1:;, r article, N Prothonotary MR ell- not ? Fiationotaq d 8 ?+ v i e.V e? f-A I•oclcl. Plaintiff nnlS K. Ans Ins Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania AqG- Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office ]with delity. Sz e V? 1 .6'm , C odryo Lt Ds Name (Chairman) 0x acs r ; r!??5 Law Firm. k-:? i M c?? k r I- S f r P f Address atv, zip # ) 01035 city, ? I zip Award C vO Kiff,-DI /70U city, zip * IN31 We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) 'n ?n _ . } n ,i'Q re 0-- . Arbit 3Vr, dissents. (Insert name if applicable.) Date of Hearing: _:?- I _ 0-7 3--t-vl Date of Award: aTp? Q-- Signature .loL,m l4 • h t-r Name Jo b Sal l? V e Law Firm Sol Mpr uIsI . Address ' i tore Nwhe i?, lltcr? IA* Firm Address CA - ?' I (-g1? , i 7 013 An IeVwrlu Notice of Entry of Award Nlovi, the day of 20_L_I_, at 1 -L.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ 350. OHO By: Prothonotary Deputy y (? ,?• "(0(of 04 o? r?zt