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Home My WebLink About06-2082DUNNROWICZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW NO: 66 'a08"?_ CIVIL TERM ANN KOHLER, Defendant : JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the owing pages, you must take action within twenty (20) days after this Complaint and Notice served, by entering a written appearance personally or by attorney and filing in writing with a it your defenses or objections to the claims set forth against you. You are warned that if you to do so the case may proceed without you and a judgment may be entered against you by the i without further notice for any money claimed in the Complaint or for any other claim or of requested by the Plaintiff. You may lose money or property or other rights important to 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 25 South Bedford Street Carlisle, PA 17013 (717) 249-3166 , P.C . SNEza:: By Attey or Plaintiff LAW OEF,CES II Date: April /3 , 2006 SNELBAKER & BRENNEMAN, P.C. JOHN DUNNROWICZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION- LAW NO: CIVIL TERM ROBIN ANN KOHLER, Defendant : JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, John Dunnrowicz, by his attorneys, Snelbaker & Brenneman, P.C., and avers the following causes of action: COUNTI The Plaintiff herein is John Dunnrowicz, an adult individual, who resides at 125 Old County Road, Apt. B-5, Windsor Locks, Connecticut 06096. 2. The Defendant herein is Robin Ann Kohler, an adult individual, who resides at 423 West Maplewood Avenue, Mechanicsburg, Cumberland County, Pennsylvania. On or about July 30, 2005, Plaintiff by oral contracts loaned to Defendant and her then fiancd, Casey Smith, each the sum of $1,100.00, said loans being made for their respective individual benefits by Plaintiff s check to Bill Pfaffenbichler, Jr., the owner/landlord, as a security deposit or initial rent payment for a rental apartment in Windsor Locks, Connecticut. Defendant promised and agreed to repay said loan to Plaintiff in installments of $300.00 per month commencing on September 1, 2005. 4. Defendant has failed and refused to pay any such monthly installments LAW OFFICES SNELBAKER & BRENNEMAN, P.C. Plaintiff has demanded payment of the full amount of said loan, which Defendant has failed and refused to pay. WHEREFORE, Plaintiff demands judgment against Defendant for the sum of $1,100.00 plus interest and the costs of this action. COUNT II 6. The averments contained in paragraphs 1 and 2 hereinabove are incorporated herein by reference thereto. On or about October 22, 2005, Plaintiff by oral contract loaned the sum of $15,400.00 to Defendant in order that Defendant could satisfy an encumbrance on her Jeep automobile, said loan being made by Plaintiff's check dated October 22, 2005. 8. The terms of repayment of said loan were as follows: a. Defendant promised and agreed to pay the entire net proceeds of the sale of the Jeep vehicle to Plaintiff at the time of the sale; and b. Defendant promised and agreed to pay to Plaintiff the difference between the amount of the loan and the net proceeds of sale of the Jeep vehicle in installments of $300.00 per month commencing one month after the Jeep vehicle was sold. 9. Based on information received, defendant sold the Jeep vehicle. 10. Defendant failed to pay the net proceeds of the sale of the Jeep vehicle and has failed to pay any monthly installments as promised. 11. Plaintiff has demanded payment of the full amount of said loan, which Defendant LAW has failed and refused to pay. OFRCES SNELBAKER & BRENNEMAN, P.C. WHEREFORE, Plaintiff demands judgment against Defendant for the sum of $15,400.00 plus interest and the costs of this action. COUNT III 12. The averments contained in paragraphs 1 and 2 hereinabove are incorporated herein by reference thereto. 13. On or about November 22, 2005, Plaintiff by oral contracts loaned to Defendant and her then fiance, Casey Smith, each the sum of $800.00, said loan being made by wire transfer from Plaintiffs bank account to Defendant's account at Members First Federal Credit Union, in order that said borrowers could pay a security deposit or initial rent payment for a rented apartment in Hampden Township, Cumberland County, Pennsylvania. Defendant promised and agreed to repay said loan to Plaintiff in installments of $300.00 per month commencing as of December 23, 2005. 14 Defendant has failed and refused to pay any such monthly installments. 15. Plaintiff has demanded payment of the full amount of said loan, which Defendant has failed and refused to pay. WHEREFORE, Plaintiff demands judgment against Defendant for the sum of $800.00 plus interest and the costs of this action. LAW OFFICES SNELBAKER & BRENNEMAN, P.C. It is averred pursuant to Pa. R.C.P. 1021 (c) that the amounts claimed in the foregoing Counts do not exceed the jurisdictional amount requiring arbitration referral by local rule of court. SNELBAKER & BRENNEMAN. P.C. By IZichard'C-Snelbaker, Esquire Pa. Supreme Ct. I.D. # 06355 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiff LAW OFFICES SNELBAKER & BRENNEMAN, P.C. VERIFICATION I, JOHN DUNNROWICZ, Plaintiff, in the foregoing Complaint, do hereby verify that the set forth therein within my personal knowledge are true and correct, and as to any facts not n my personal knowledge, I believe them to be true and correct based upon information ?ed. I understand that any false statements herein are subject to the penalties of 18 Pa C.S. § relating to unsworn falsification to authorities. John Dunnrowicz I'lorl-11o, X066 LAW OFFICES SNELBAKER & BRENNEMAN, P.C. ?fL ?L tddl SHERIFF'S RETURN - REGULAR CASE NO: 2006-02082 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DUNNROWICZ JOHN VS KOHLER ROBIN ANN SGT BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KOHLER ROBIN ANN the DEFENDANT , at 1500:00 HOURS, on the 17th day of April , 2006 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to ROBIN ANN KOHLER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof Sheriff's Costs: Docketing 18.00 Service 4.40 Postage .39 Surcharge 10.00 .00 32.79 3?aa?0 G Sworn and Subscribed to before me this day of A. D. So Answers: R. Thomas Kline 04/18/2006 SNELBAKER & BRENNEMAN f By' ? 1 / De ty Sheriff Prothonotary Curtis R. Long Prothonotary office of the i3rotbonotarp (Cumberfanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor o0ID "-9,6 8z. CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, 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, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573