HomeMy WebLinkAbout06-3271JAMES D. MURICEAK and
CAROL A. MURICEAK,
Plaintiffs
V.
JASMIN OSOJKIC,
ERMINA OSOJKIC, SABRIJA 0.
OSOJKIC and MUJESIRA OSOJKIC,
Defendants
CUMBERLAND COUNTY, PENNSYLVANIA
COURT OF COMMON PLEAS
NO. o(o -
CIVIL ACTION - LAW
NOTICE TO DEFEND
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 claim or relief requested by the Plaintiff. You may lose money or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE OR KNOW A LAWYER, THEN YOU SHOULD GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166 or (800) 990-9108
NOTICIA
LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al
partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita or
en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a
las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara
medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier
queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus
propiedades o otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATEMENTE. SI NO
TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEQUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
JAMES D. MURICEAK and CUMBERLAND COUNTY, PENNSYLVANIA
CAROL A. MURICEAK, COURT OF COMMON PLEAS
Plaintiffs
V. NO.
JASMIN OSOJKIC, f
ERMINA OSOJKIC, SABRIJA O.
OSOJKIC and MUJESIRA OSOJKIC,
Defendants : CIVIL ACTION - LAW
COMPLAINT
AND NOW, come Plaintiffs, James D. Muriceak and Carol A. Muriceak, by and through
their attorney, Robert B. Lieberman, Esquire, and file this Complaint against Jasmin Osojkic,
Ermina Osojkic, Sabrija O. Osojkic and Mujesira Osojkic, and in support thereof avers as
follows:
Plaintiffs, James D. Muriciak and Carol A. Muriceak, husband and wife, are adult
individuals residing at 440 Springhouse Road, Camp Hill, Cumberland County, Pennsylvania
17011.
2. Defendants, Jasmin Osojkic and Ermina Osojkic, husband and wife, are adult
individuals residing at 400 Pawnee Drive, Mechanicsburg, Cumberland County, Pennsylvania
17050.
3. Defendants, Sabrija O. Osojkic and Mujesira Osojkic, husband and wife, are adult
individuals residing at 1460 Rt. 57, Port Murray, New Jersey 07865.
4. On or about January 12, 2005, Plaintiffs, James D. Muriceak and Carol A.
Muriceak, (hereinafter sometimes referred to as "Sellers") and Defendants, Jasmin Osojkic,
Ermina Osojkic, Sabrija O. Osojkic and Mujesira Osojkic, (hereinafter sometimes referred to as
"Buyers") signed a written Sales Agreement for the sale of the real property known as 6002
1/0 us iQN i e F 1z:
/77 eC i, /P /vic s 13V,-G
BRIJA O. OSOJKIC
N 55-33/212 7L 12.1
JESIRA OSOJKIC 9482645207
1460
RT. 57
PORT MURRAY, NJ .07865.4043 G eq?
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EXHIBIT "B"
Robert Drive, Hampden Township, Cumberland County, Pennsylvania 17055. A true and
correct copy of the Sales Agreement is attached hereto and made a part hereof as Exhibit "A".
5. Pursuant to the terms of the Sales Agreement, Buyers paid a deposit in the amount
of Five Thousand ($5,000.00) Dollars to Sellers. The deposit was paid by Defendants, Sabrija O.
Osojkic and Mujesira Osojkic, by check dated January 4, 2005, and deposited into the trust
account of Ronald D. Butler, P.C. A true and correct copy of said check is attached hereto and
made a part hereof as Exhibit "B".
Pursuant to the request of R. Mark Thomas, Esquire, attorney for Buyers, the
Sales Agreement was amended so that Ermina Osojkic was listed as the only buyer. On or about
January 24, 2005, Sellers and Ermina Osojkic signed the Amended Sales Agreement for the sale
of the real property known as 6002 Robert Drive, Hampden Township, Cumberland County,
Pennsylvania 17055. A true and correct copy of the Amended Sales Agreement is attached
hereto and made a part hereof as Exhibit "C"
9. Subsequently, Buyers refused to purchase the real property pursuant to the terms
of the Sales Agreement and Amended Sales Agreement and there exists a dispute between
Buyers and Sellers as to the disposition of the deposit.
10. Pursuant to the terms of the Sales Agreement and Amended Sales Agreement,
Plaintiffs are entitled to the $5,000.00 deposit upon Defendants' failure to make settlement by
paying the purchase money in full on or before February 10, 2005.
11. On or about November 3, 2005, Ronald D. Butler, P.C. t/d/b/a Butler Law Firm
filed a Bill in Equity for an Interpleader to No. 05-5732.
12. By Order dated November 9, 2005, Judge Kevin A. Ness granted the Bill in
Equity for Interpleader and granted permission to Ronald D. Butler, P.C. t/d/b/a Butler Law Firm
to transfer the $5,000.00 deposit then held in its trust account to the Court pending resolution of
this matter.
WHEREFORE, Plaintiffs, James D. Muriceak and Carol A. Muriceak, respectfully
requests this Honorable Court to enter a judgment in their favor and against Defendants, Jasmin
Osojkic, Ermina Osojkic, Sabrija O. Osojkic and Mujesira Osojkic, to enter an order directing
the Prothonotary of Cumberland County to release the funds held in escrow to Plaintiffs to
satisfy said judgment and to grant all other relief as is appropriate.
Respectfully submitted,
By:
Robert B. Lieberman, Esquire
l.D.#olo fq
500 North Third Street, 12`h Floor
Harrisburg, PA 17101
(717) 236-1485
a." I
FAX N0.
FROM :DROTHERandSISTER FOOD SERV]_ES FAX NO.
:'175yggp,
of a/2oa5 13 OD FAI_j719RB0bl8 A1alitlcollpon
. IC, 1005 4:19116 7172367777
Jan. 12 2005 05:06PM P1
Jan. 12 2095 05:13PM P1
NO. 745 F.Wd[V1
ti.
Ting AGR OF 5ALS f>xda wd mmad iam this dty of
3aanw.1005. bemacu JAMES A. MMCUX and CAROL A. MURC&tt[. hls in*. 04440
SprinSooaa Read. Camp Full, POWWAvania 11011. pause afdle fintpatOWAbm8itteftrad
do ss VSwUw" , and 7ASMW QMWC and ARM NA Q3QWG hie wilt, of 400 Paaees Dtiw,
mwb=iosu v& pan,sylvtmla 17050, and UARRUA 0.OSOJW and MUIWVA OBQ=
Ws wife; of 1460 Rt. 57, Yon MWMY, New Jaaay 07865, patios of ito wound Prot "Mimft
al'arred m at "auyt"l.
TLe 3d1ar apow to sell end convey and dw Bw a savas to podum the 10011 Nate
siuwk is H=Pbm Towtuldp, CtmlbwlMd County, Pmwlvaoia, kwwn as 6002 PAbon Dtfv&
uWchtmicebbwS. Powasylvsola 17035 on the AM*w!M bane sad omid'niona;
1, gda. Suyet agrees to pay m conddeuzim for Nld Pes®isa the mm of Olm
Attidred Tmety-PSve Thmsand Five Rmadtad (5135,500,00) DOUtra. Soft a w wjed ffw mat it
chedr in %c amount of'P1ve T1u+usand (65,000.00) DuUam hiss bem depodw in Ow awt
acmlme of dhelt stomeys, Botha Lew Phan.
2. oiN. Tbia A fraammt is aubjeel to the ibnawlni< eou*4gaootim:
(9) 116 AVIPWWnt 19 a gftS mt Vft Httysa obcaip AS It MIYWS WK a
satis&mry borne iaapeotion report on the pteparty.
(b) 7Si3 Agoon w is contluasat upoa Buyer obtatni gg 9 Httyds 0011 a
awtvictory sw#v oft e prvpaty.
EXHIBIT "All
FROM
FAX N0.
FROM :FJRDTHERandS;STER FOOD SEPO ES fAx Np, :72''SSBa&3$
U1:'11/9M 12:95 FAY 197382505.8 Atlacciccoapou
JAN.10ADD5 4:20PM 7172167i77
Jan. 12 2005 05:06PM P2
Jar,. 12 2005 OS:IAPM P2
NO, 45 f,GUQVA
Buys macs stake s good tbith attempt to s0* oil of rheas ocudupwAm ott or be6ro Jamtmy
21. y00S. Da tits avant dw all of ssutb coutitsoemalae have rot baaa sable by 7aaaary 21, 2005,
dyad either 99D& to Dwyer may dm*m this Aareamtem nail ad void.
1. SdaMM a<1. LtPtat me tktluta of 9se Httyar to mats aetdamsms by Psyinp
pan:basa money JAM on cr befem F66mny 10, 2005. WA A{reatouri alts!! be tt nW= tod aid
tbs ammtat paid by Sayer shall bs farteibd as liquidated dmoagaa It is tmdottttood sad
rimed that if any of the afor"aid aeaalupmic a are not aatietle4 dte dwaait wilt be rettteaad
O. Ngo-ReA Tah,re llxhaa. The pbmtbtas. hodng me paamsaamt I&!shmmNs, @W
811 t vm sbrabbery and plans and all stasm windows, itoem dam and MI" atattoe,f am in of
on the ptemima as oonsidesed pat of the teal *am The We abw Io9oludes 60 abed,
reMfesuor and gas !lteplaea
1. ImAdM351S. Rail estate "nofet Wass shalt be dteidsd **MW bataresn Hagar
wed Shcer•
6. app Foasearlon :ball bavm by 9a11arw H at setdeaaeet.
However, Seller resolves a:& dgAt so tba exclusive vae of dz r" as p mV for a period ofap to
an (6) moaft f6dowing uttlemenl•
7. mdw=. The tanea, lasts, tratar attd. aewarmm sad all o9m
periodic,imms end cZwSm upon tbs above des ibad pteotiees shall be appexdonmd d the fte
of sealemmt-
S. RjiF..f sma. Sel10r shall beff h9k of :oa from fte of o4m oaana* mil time
of eettwmem to dis event of damn= to the ptopeny by fits or other easaaby. Buyer dat have
•a_
FROM : FAX NO. :
FROM :BROTHCP.AntlS!STER FOOL SERVICES FAX NO, ;"I-?5PEeP
UY!t1!2UU? 1Y:00 F.td 26768049618 etlantldoepon
,nN.1C.2405 <;2aPM 7!72357777
the opttoa of rtatyoding this Agc=aet and rocaivbty NO
Jan. 12 2005 05:06PM P3
Jan. :2 2005 05:14AM P3
NO, 745 P. Y`
Mousy Paid en soeamt or of
sane bas du pgperw in its thew eeswuVn witb 2ba prersode of atw imuzews recovery
obtainablaby S*lW-
9. Tif7t. SsUa sbsu convoy to 8twer by agecial warm M dead good and
marketable title (wbisla tan be card" by Buyada attomoy or imsered st antndwd 10204 by s situ
eaao?aoy"Vastly 1> S tit).ee iu P mtaylowus) dubjest to bulldht8. ZOM3* amd deed
mcli6ttnae sad euamtews of rocmd or viaibla by tespacdon
to, " ..."..f rJ In am menial ddacU are farad In the d& sod WPQI d to
War. dum if am* delbcts are mat msedby Seller within uxty (Stn dsya the ooattsei sw
boceme null aw Vold at the opdon of Huger. Seller tt ?sse ID the sppliaseiom of ae tand? of tLa
pur"c =may as required TO the' peyaumt of liana Dud ftIc mrbrtoesa at asulm] M
it. DMd Buyer teaervas the tight w aetify SaDar u atgy titaepsler m aasllaameoi a
to the exact nom Zhu shall appear an the dead to the gym, tw.
12. AM & DW Agreemaot sball be bindioa upon and hum to the bUOM Of ft
p"a hsrma, dwk respootlve papnal apreamthtives and W4 W.
IN WIThTAS `VHM$ OF. the parties haw h4mvito an tbair has& aad "s the
qty wd year drat above egitwL
?(?ITNBSS: .?7 (,,
r!? e
.6.
FROM : FAX NO. : Jan. 12 2005 05:07PM P4
FFO1,1 :BR=THERindS:STEP FOOD SERVICES FAX NO, :?175SG9Ti5
01/11/2086 14:08 FAS 10730250018 A[laotlcCOUPOU
1Ah.10,:005 4:20FN 7172167777
Jan. 12 20M 05:15PM P4
NO. 145 P. u"
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FAX NO.
FROM :BR0THERan4!STER FOOD SERUICES FAX, NO. :71755888.',5
rRom F'W NO.
ON. 21 ? „ a i 91 b± ' : TO I7
Feb. 09 2005 10:32AM P1
Jan. 25 2005 12:51PM P1
Jan. BA 3005 03:S4PM PI
o o9S P.
TW$ A0A2V )n' OF SALE made Gad ealcmd into eks Sow dw of
Irttsbry, 2005, between I.AM85 D. IvILIRICPAK and CAROL A. MURlCBAZ. his wlb, of to
SptinghouYe RNA Camp !Gill, Penmylvamb 17011, ylMJN of the Antptn 0tenieefhrtethted
to is "ShcIWI. ant 1 ANUNA OSOJKJC of 400 PPim Drive. Moehatriesbwg, PlmoaylvUda
17050, Duty altlta lettmd pat Qtarnna0er:eiemrd to o "t3nyaf'),
The Selka UZTCN to Bell attd Gamey ltd the t)tiyar agrees to purchase *A rant UtW
cttum in Nompdaa Townshm Cumbutand County, Pwrahanle, k w%% tta 0002 Rabat ntfY&
Maehrvmburs, PaaftIvanis 11059 tm the fallowing k:T= and eogdldons:
1. Psico Bayer &Wm to PaY at mtsidwblioe &r add pmesim dw sum of OtM
Hurdred Thiaty-Fl%e Tbeusand Vivo Huudmd (5135.500.00) Dollars. Safer aekaea9edpr dte a
eheeb ;n the amount of Eive 73otuand (S.S.D00.00) pollee has basal deDssiadla ffie aoe
seecum of && ataorrmys, butler Law Firm
2. nLisS. This ASHIPI lrtt is sobjaet to the following 009fiagrdsa:
(a) TLis Agteetneot it Goyingoot Uxm Buyer obtainng at super cost a
astiafmwy homy kntpwwrl repmt on the property.
(b) 'ibis Ags®ement is evalingant upon Buyer obtaining at Huysia Volt a
weisfsetory survey of the property.
Buyer mua make a good faith attempt to aatbtfy all of these contingencies on s be@rce Ltcuemy
29, 2mf. In Ste event dw all of auelt oontiup rim as have not beta satisfied 3v I&JUNy U. 2005.
dtee either Seller or Buys may declare Ihir As "tuarnt tall and void.
FXHW:._r1¦L,
FROM
FAX NO. : Feb. 09 2005 10:33AM P2
FROM :BROTHERandSISTER FOOD SERVICES FAX NO. :?P55GSS35 Jan. 25 2005 12:51PM P2
i. .,. ?..?? ..u,w.• 4w' 'L is ...
7. SWUM4i. upon tt:t Win of the Buyer to miles taplmad by Psylns the
pwohieo money is Will on or before Febmery, lLO, 1003 - *& Agrwnenr shall be taamlaatad and
the amount paid by &a Buyer "ll be tb, relied as liquidated daosgsa It ie usgaaesod and
tyseed thM It any ofrhe afbreaoid coatiuiaec'cs are not'Idsilsad, ON deposit will be rosined
4. She phuttbtug, :uatit•; and yeMenent light flxtrrea, ad
all trees, ahr ibbors' and plum and all stora windows. storm dean and relapd ZNVAM app is or
on the pree foes are aottadeted part of the real MM Its agile alto inehtdee the shod,
reiNSoratec sad so llroplaoe.
S. tm,efor Ta,? Real eetata truss fir taxes aball be divided equally hatwaan Buys
and smile,
6. Romeadom Poiltaeton shill be situ by Sella to Aoyee at eetuomm
I3evwar. seller rasarvao the right to the axehative use of the two tar sarase for a boded er tae to
rite (d) atomho following sonlomeet.
7. The races, re:ds. water ona sever saes and a>J adios
periodic claims seat rharltea upon the above described premises seen be apportioned at t>se trace
of eattletaeot
s. R+'v er "•e• Sclla shall bear risk of bas ftpre Qto or occur oeeuslry mad, grey,
of satiemmt. to du crud of daraje to the pmpcrty by tare or odter eaattaky, BW W shall hWc
tM option oftveeittdint Ible Agres:nenc and aer..vtg sty pansy ysid on uma?e er of
acceptias the proeorty in Its Ibso condition 44.1 & pracesdc of N%V IaattrglCe raepVely
obtainable by Saw.
FROM 7 FAX NO. : Feb. 09 2005 10:33AM P3
FROM :ERCTI-ERandSISTER FOOD SERVICES FAX NO. :71755888 5
Jan. 25 2M 12:52PM P3
FROM t1 l b FAW,, NO, Jan. 24 2086 03:SSPM P3
", c 7177i677i
.ago a
9. tj?, Bdhr shad] oamay l0 8uyr by apeeul v?elsuty Bleed /yam estd
mark"bls twe (mbleh m bb eemmsd by buyeds stretney or insured at atQdmd rstee by a tide
tOMWY Mdrly WWW tltlss in Peoosylvanis) sopjb:¢ w ?uHdhM seatey ra 4410
resektiooa sad si"mists of record or A 11ble by in6DSetlon,
10. xnleetiee ar'"'e, In else msserisl dedets are NNW in she We and reprpd to
Seller, than if sash d?lboM 00 emt culed by Scher within slny W) OM the alAllebt si en
beeonse nun sad Vold Y the epuoo olBsyer. Ssllu a0nla ro dle ippnoadop et a aslsah of Sfie
pvcham many as mquhed to the Payment of Dou end msumbmam is aey mmo.
1 t, LADLEM Buyer MEMO to ysy to scuff 0 WOW equm to W ISSNI &es
an& so be 4mmed by SleLr in oonnecaon wish this sraamim. V0+ ?'O ?.rGa e
>fsw Ar G.gYee.J .-f1o- by boyar a.?d Se//e%
It. lmstdb This Ayreamees shall be bindm$ upon ad i6two to Ibe bit"St eadb
putims kerve, thtif reapeetive prsonsl ,aprs snsauva and aselgea
IIJ %TCNBSS WlitRmW, eta patties lava hestoueto ad %* hands and mu t'he
day red YW &61 abosv wiltm.
WITMISS:
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VERIFICATION
We, James D. Muriceak and Carol A. Muriceak, Plaintiffs herein, hereby
certify that the facts set forth in the foregoing Complaint are true and correct according to the
best of our knowledge, information and belief.
We understand that any false statements herein are made subject to penalties of
18 Pa. C.S. §4904 relating to unworn falsification to authorities.
Jm Muriceak
Date:
t
Carol A. Muriceak
Date:
0` !
JAMES D. MURICEAK and
CAROL A. MURICEAK,
Plaintiffs
V.
JASMIN OSOJKIC,
ERMINA OSOJKIC, SABRIJA O.
OSOJKIC and MUJESIRA OSOJKIC,
Defendants
CUMBERLAND COUNTY, PENNSYLVANIA
COURT OF COMMON PLEAS
NO.
CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I, Robert B. Lieberman, Esquire, hereby certify that on the ? day of June, 2006, I
served a true and correct copy of the foregoing Complaint by depositing same in the United
States Mail, postage prepaid, certified mail, return receipt requested in Harrisburg, Pennsylvania,
addressed as follows:
Sabrija O. Osojkic
1460 Rt. 57
Port Murray, New Jersey 07865
Mujesira Osojkic
1460 Rt. 57
Port Murray, New Jersey 07865
Robert B. Lieberman, Esquire
I.D.#a761q
500 North Third Street, 12a' Floor
Harrisburg, PA 17101
(717) 236-1485
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JAMES D. MURICEAK and
CAROL A. MURICEAK,
Plaintiffs
V.
JASMIN OSOJKIC,
ERMINA OSOJKIC, SABRIJA O.
OSOJKIC and MUJESI A OSOJKIC,
Defendants
CUMBERLAND COUNTY, PENNSYLVANIA
COURT OF COMMON PLEAS
NO. 06-3271 Civil Term
CIVIL ACTION - LAW
NOTICE TO PLEAD
TO: James D. Muriceak and Carol A. Muriceak, Plaintiffs:
You are hereby notified to file a written response to the enclosed New Matter and
Counterclaim within twenty (20) days from service hereof or a judgment may be entered against
you.
R. Mar Thomas, Esquire
Attorney No. 41301
101 South Market Street
Mechanicsburg, PA 17055
Telephone: 717-796-2100
JAMES D. MURICEAK and
CAROL A. MURICEAK,
Plaintiffs
V.
JASMIN OSOJKIC,
ERMINA OSOJKIC, SABRIJA O.
OSOJKIC and MUJESIRA OSOJKIC,
Defendants
CUMBERLAND COUNTY, PENNSYLVANIA
COURT OF COMMON PLEAS
NO. 06-3271 Civil Term
CIVIL ACTION - LAW
ANSWER. NEW MATTER AND COUNTERCLAIM
AND NOW the Defendants, JASMIN OSOJKIC, ERMINA OSOJKIC, SABRIJA O.
OSOJKIC and MUJESIRA OSOJKIC, by and through their counsel, R. Mark Thomas, Esquire,
and file this Answer, New Matter, and Counterclaim, and in support thereof respectfully
represent:
Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
9. Admitted in part, denied in part. It is admitted that neither the Sales Agreement
nor the Amended Sales Agreement were consummated, but the failure to
complete the agreement was not due to Buyers' refusal, but ultimately was due to
the Sellers' termination of the agreement on February 10, 2005.
10. Denied. This allegation is a conclusion of law to which no responsive pleading is
required and therefore same is denied. By way of further answer, Defendants are
entitled to the return of their $5,000.00 deposit since the sale of the property was
not completed due to Sellers' refusal.
11. Admitted.
12. Admitted.
WHEREFORE, Defendants, JASMIN OSOJKIC, ERMINA OSOJKIC, SABRUA O.
OSOJKIC and MUJESIRA OSOJKIC, pray that this Honorable Court will enter an Order
directing that the Prothonotary of Cumberland County release the funds held in escrow to the
Defendants and not to the Plaintiffs.
NEW MATTER
13. The answers set forth in Paragraphs 1 through 12 are hereby incorporated herein
as if set forth at length.
14. The original Sales Agreement was prepared by counsel for the Sellers and was
signed by Buyers who were not represented by legal counsel.
15. The Sales Agreement called for settlement on or before February 10, 2005, which
was only twenty-nine (29) days from the date of execution of the Sales
Agreement.
16. Buyers, Jasmin Osojkic and Ermina Osojkic were first time home buyers and did
not realize that twenty-nine (29) days was a short time within which to apply for
and receive financing.
17. Subsequent to the execution of the original Sales Agreement, for reasons
unknown to anyone other than the Buyers' lender, the Sales Agreement had to be
modified, so that ERMINA OSOJKIC would be the only identified Buyer.
18. Buyers, although approved for financing through a responsible lender, namely
New Century Mortgage Corporation, did not have the funds available from the
lender to settle on or before February 10, 2005.
19. Sometime during the middle of February 2005, Sellers advised Buyers that Sellers
were going to terminate the Sales Agreement due to Buyers inability to settle on
time.
20. On March 1, 2005, counsel for Sellers sent correspondence to the Buyers advising
them in writing that the Sales Agreement was terminated and that Sellers already
sold the property to a new buyer.
21. Buyers requested the return of their Five Thousand Dollar ($5,000.00) deposit,
but were informed that Sellers were going to keep same pursuant to the Sales
Agreement.
COUNTERCLAIM
22. The answers set forth in Paragraphs 13 through 21 are hereby incorporated herein
as if set forth at length.
23. Paragraph 2 of the Sales Agreement states that the Sales Agreement is contingent
upon Buyers obtaining, at Buyers' cost, a satisfactory home inspection report on
the property.
24. Buyers promptly engaged a certified home inspector to conduct an inspection of
the property which was the subject of the Sales Agreement.
25. On or about January 20, 2005, Buyers received a home inspection report which
listed forty-one (41) deficiencies, some of which would be costly to correct.
26. Although the Sales Agreement was contingent upon a satisfactory home
inspection report, the Sellers refused to discuss the home inspection report with
Buyers.
27. Buyers did not receive the radon inspection report until late January 2005 and the
test results indicated radon levels above 4.0 pCi/L, as recommended by the
Environmental Protection Agency.
28. Under the terms of the Sales Agreement, if the contingencies had not been
satisfied with respect to either Sellers or Buyers, either party had a right to
terminate this Sales Agreement by declaring same to be null and void.
29. Since the Sales Agreement was voidable at the request of either party, Sellers
should not be allowed to keep the Five Thousand Dollar ($5,000.00) deposit paid
by the Buyers.
WHEREFORE, Defendants prays that this Honorable Court will enter judgment in favor
of the Defendants and against the Plaintiffs and direct the Prothonotary to release the Five
Thousand Dollars ($5,000.00) to the Defendants.
Respectfully submitted,
Z;e
R. Mark Thomas, E quire
ID #41301
101 South Market Street
Mechanicsburg, PA 17055
Telephone: (717) 796-2100
Attorney for Defendants
VERIFICATION
1 verify that the statements made in the foregoing document are true and correct to the best
of my knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Fa. C.S. §4904, relating to unsworn falsification to authorities.
Date:
?1 ??s? Oros ki t
i
VERIFICATION
I verify that the statements made in the foregoing document are true and correct to the best
of my knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. //
Data
OY/0b ' Of 50.of/d4 OSDJ FCC
VERIFICATION
1 verify that the statements made in the foregoing document are true and correct to the best
of my knowledge, information and belief. I understand that false statements herein are made
subiect to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities.
Date -\y -??
6 r^1 69S k, C-
VERIFICATION
I verify that the statements made in the foregoing document are true and correct to the best
of my knowledge, information and belief. I understand that false statements herein are made
subiect to the penalties of 18 Ila. C.S. §4904, relating to unsworn falsification to authorities.
Dater
CERTIFICATE OF SERVICE
I, R. Mark Thomas, Esquire, hereby certify that I have served a true and correct
copy of the within document on the following by depositing a true and correct copy of the
same in the U.S. Mail at Mechanicsburg, Pennsylvania, First Class Postage pre-paid,
addressed to:
Robert B. Lieberman, Esquire
500 North Third Street, 12th Floor
P. O. Box 1004
Harrisburg, PA 17108-1004
Dated: -7 JZ I IA90fa
R. Mark Thomas, Esq.
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JAMES D. MURICEAK and
CAROL A. MURICEAK,
Plaintiffs
V.
JASMIN OSOJKIC,
ERMINA OSOJKIC, SABRIJA O.
OSOJKIC and MUJESIRA OSOJKIC,
Defendants
CUMBERLAND COUNTY, PENNSYLVANIA
COURT OF COMMON PLEAS
NO. 06-3271
CIVIL ACTION - LAW
PLAINTIFFS' REPLY TO DEFENDANTS'
NEW MATTER AND ANSWER TO COUNTERCLAIM
AND NOW, come Plaintiffs, James D. Muriceak and Carol A. Muriceak, by and through
their attorney, Robert B. Lieberman, Esquire, and file this Reply to Defendants' New Matter and
Answer to Counterclaim and in support thereof avers as follows:
REPLY TO NEW MATTER
13. No response is required.
14. Admitted in part and Denied in part. It is admitted only that Sellers' prior counsel
prepared the Sales Agreement. Sellers are without sufficient information or knowledge to
determine whether or not Buyers received any legal counsel. As such, said allegations are
denied and strict proof thereof is demanded at trial.
15. Denied. The document speaks for itself.
16. Denied. Sellers are without sufficient information or knowledge to respond to the
allegations made in this paragraph. As such, said allegations are denied and strict proof thereof
is demanded at trial. By way of further response and explanation, the Sales Agreement was
signed by all four (4) Defendants, not just Jasmin Osojkic and Ermina Osojkic.
17, Admitted in part and Denied in part. It is admitted only that at Buyers' request,
Sellers' counsel modified the Sales Agreement so that Ermina Osojkic would be the only
identified Buyer. Sellers are without sufficient information or knowledge to form a belief as to
the truth of the remaining allegations. As such, said allegations are denied and strict proof
thereof is demanded at trial.
18. Denied. Sellers are without sufficient information or knowledge to form a belief
as to the truth of the allegations made in this paragraph. As such, said allegations are denied and
strict proof thereof is demanded at trial.
19. Admitted in part and Denied in part. Sellers notified the Buyers that Sellers were
terminating the Sales Agreement due to Buyers' default sometime after February 15, 2006.
20. Admitted in part and Denied in part. The document speaks for itself.
21. Admitted in part and Denied in part. Sellers did not "keep" the deposit. The
$5,000.00 deposit was held in escrow by attorney Ronald D. Butler, Esquire, until he received
permission to transfer said funds to the Court. It is admitted only that Buyers requested the
deposit but that Sellers also made a claim to the deposit monies.
WHEREFORE, Plaintiffs respectfully request this Honorable Court to dismiss
Defendants' New Matter and to grant all other relief which it deems appropriate.
ANSWER TO COUNTERCLAIM
22. No response is required.
23. Denied. The document speaks for itself.
24. Denied. Sellers are without sufficient information or knowledge to form a belief
as to the truth of the allegations made in this paragraph. As such, said allegations are denied and
strict proof thereof is demanded at trial.
25. Denied. Sellers are without sufficient information or knowledge to form a belief
as to the truth of the allegations made in this paragraph. As such, said allegations are denied and
strict proof thereof is demanded at trial.
26. Denied. The document speaks for itself. By way of further response and
explanation, Buyers did not contact Sellers to discuss the home inspection report or any other
contingency prior to January 21, 2005, or for that matter prior to the February 10, 2005,
settlement date. Sellers had no obligation to discuss any inspection reports with Buyers after the
January 21, 2005, deadline. Paragraph 2 of the Sales Agreement required Buyers to make a good
faith attempt to satisfy the home inspection contingency by January 21, 2005. Thus, Buyers right
to cancel the Sales Agreement pursuant to this paragraph terminated on January 21, 2005.
Buyers subsequent failure to close on the property by February 10, 2005, constituted breach of
the agreement and resulted in forfeiture of their deposit to Sellers. Sellers were will within their
rights to terminate the Sales Agreement for Buyers failure to settle by February 10, 2005.
27. Denied. Sellers are without sufficient information or knowledge to form a belief
as to the truth of the allegations made in this paragraph. As such, said allegations are denied and
strict proof thereof is demanded at trial.
28. Denied. The allegations made in this paragraph constitute a conclusion of law to
which no response is required. To the extent a response is deemed to be required, said
allegations are specifically denied. By way of further response and explanation, Buyers did not
contact Sellers to discuss the home inspection report or any other contingency prior to January
21, 2005, or for that matter prior to the February 10, 2005, settlement date. Paragraph 2 of the
Sales Agreement required Buyers to make a good faith attempt to satisfy the home inspection
contingency by January 21, 2005. Thus, Buyers right to cancel the Sales Agreement pursuant to
this paragraph terminated on January 21, 2005. Buyers subsequent failure to close on the
property by February 10, 2005, constituted breach of the agreement and resulted in forfeiture of
their deposit to Sellers. Sellers were will within their rights to terminate the Sales Agreement for
Buyers failure to settle by February 10, 2005.
29. Denied. The allegations made in this paragraph constitute a conclusion of law to
which no response is required. To the extent a response is deemed to be required, said
allegations are specifically denied. By way of further response and explanation, Buyers right to
terminate expired January 21, 2005. Buyers did not terminate by January 21, 2005. Buyers then
breached the Sales Agreement by failing to close on February 10, 2005. Sellers were well within
their contractual rights to terminate the contract and are entitled to retain the deposit.
WHEREFORE, Plaintiffs, James D. Muriceak and Carol A. Muriceak, respectfully
requests this Honorable Court to dismiss Defendants' Counterclaim, enter a judgment in their
favor and against Defendants, Jasmin Osojkic, Ermina Osojkic, Sabrija O. Osojkic and Mujesira
Osojkic, and direct the Prothonotary of Cumberland County to release the funds held in escrow
to Plaintiffs to satisfy said judgment and to grant all other relief as is appropriate.
Respectfully submitted,
B f?
Robert B. Lieberman, Esquire
I.D. # 07089
500 North Third Street, 12w Floor
Harrisburg, PA 17101
(717) 236-1485
JAMES D. MURICEAK and
CAROL A. MURICEAK,
Plaintiffs
V.
JASMIN OSOJKIC,
ERMINA OSOJKIC, SABRIJA O.
OSOJKIC and MUJESIRA OSOJKIC,
Defendants
CUMBERLAND COUNTY, PENNSYLVANIA
COURT OF COMMON PLEAS
NO. 06-3271
CIVIL ACTION - LAW
CERTIFICATE OF SERVICE
I, Robert B. Lieberman, Esquire, hereby certify that on the 17th day of August, 2006, I
served a true and correct copy of the foregoing Plaintiffs' Reply to Defendants' New Matter
and Answer to Counterclaim by depositing same in the United States Mail, postage prepaid in
Harrisburg, Pennsylvania, addressed as follows:
R. Mark Thomas, Esquire
101 South Market Street
Mechanicsburg, PA 17055
Robert B. Lieberman, Esquire
I.D. # 07089
500 North Third Street, 12"' Floor
Harrisburg, PA 17101
(717) 236-1485
VERIFICATION
We, James D. Muriceak and Carol A. Muriceak, Plaintiffs herein, hereby
certify that the facts set forth in the foregoing Plaintiffs' Reply to New Matter and Answer to
Counterclaim are true and correct according to the best of our knowledge, information and belief.
We understand that any false statements herein are made subject to penalties of
18 Pa. C.S. §4904 relating to unsworn falsification to authorities.
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J s D. Muriceak
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Carol A. Munce
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66 -3A71
CERTIFICATE OF SERVICE
I hereby certify that I served a copy of the foregoing document upon the
person(s) indicated below by depositing a copy of the same in the United States mail,
postage prepaid, at Lemoyne, Pennsylvania, on l(o ?lP
Stephen Held, Esquire
Handler, Henning & Rosenberg, LLP
1300 Linglestown Road
Harrisburg, PA 17110
Attorneys for Plaintiffs
DUFFIE, STEWART & WEIDNER
A
'Jefferson J. Shipman,/Esgt
Attorney I.D. No. 51785
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
Telephone (717) 761-4540
Attorneys for Defendants
280270
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JAMES D. MURICEAK and
CAROL A. MURICEAK,
Plaintiffs
V.
JASMIN OSOJKIC,
ERMINA OSOJKIC, SABRIJA O.
OSOJKIC and MUJESIRA OSOJKIC,
Defendants
CUMBERLAND COUNTY, PENNSYLVANIA
COURT OF COMMON PLEAS
NO. 06-3271 Civil Term
CIVIL ACTION -LAW
ACCEPTANCE OF SERVICE
I , R. MARK THOMAS, ESQUIRE, hereby accept service of the Complaint, in the above
captioned case, on behalf of my clients, SABRIJA OSOJKIC, and MUJESIRA OSOJKIC.
Dated: R/, 969,61
R. Mark Thomas, Esquire
Attorney No. 41301
101 South Market Street
Mechanicsburg, PA 17055
Attorney for Defendants
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SHERIFF'S RETURN - REGULAR
IM CASE NO: 2006-03271 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MURICEAK JAMES D ET AL
VS
OSOJKIC JASMIN ET AL
TIMOTHY REITZ
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
OSOJKIC JASMIN
DEFENDANT
was served upon
the
, at 0942:00 HOURS, on the 3rd day of July , 2006
at 12 CLOVER LANE
MECHANICSBURG, PA 17050
JASMIN OSOJKIC
by handing to
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Postage
Surcharge
4-
Sworn and Subscibed to
before me this
of
So Answers:
18.00
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8.80
.39
10.00 R. Thomas Kline
.00
37.19/ 07/05/2006
,7y„o(, ROBERT LIEBERMAN
By: day De ty Sher.' f f
v'
A.D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-03271 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
MURICEAK JAMES D ET AL
VS
OSOJKIC JASMIN ET AL
TIMOTHY REITZ
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
OSOJKIC ERMINA
the
DEFENDANT , at 0942:00 HOURS, on the 3rd day of July 2006
at 12 CLOVER LANE
MECHANICSBURG, PA 17050
ERMINA OSOJKIC
by handing to
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing Her attention to the contents thereof.
Sworn and Subscibed to By: -? ?l`
7
before me this day De 0 ty Sher/
.00
16.00./ 07/05/2006
.2 y,01, ROBERT LIEBERMAN
Sheriff's Costs: So Answers:
Docketing 6.00 l'
Service .00 -?
Affidavit .00
Surcharge 10.00 R. Thomas Kline
of
A. D.
JAMES D. MURICEAK and IN THE COURT OF COMMON PLEAS
CAROL A. MURICEAK, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
V.
NO. 06-3271 Civil Term
JASMIN OSOJKIC,
ERMINA OSOJKIC, SABRIJA O.
OSOJKIC and MUJESIRA OSOJKIC,
Defendants CIVIL ACTION LAW
MOTION AND STIPULATION TO SETTLE CASE
AND NOW, comes Plaintiffs, JAMES D. MURICEAK and CAROL A. MURICEAK, by
and through their attorney, Robert B. Lieberman, Esquire, and Defendants, JASMIN OSOJKIC,
ERMINA OSOJKIC, SABRIJA O. OSOJKIC and MUJESIRA OSOJKIC, by and through their
attorney, R. Mark Thomas, Esquire, and in support thereof avers as follows:
1. That Plaintiffs, James D. Muriceak and Carol A. Muriceak, husband and wife, are
adult individuals, residing at 440 Springhouse Road, Camp Hill, Cumberland County,
Pennsylvania.
2. That Defendants, Jasmin Osojkic and Ermina Osojkic, husband and wife, are
adult individuals, residing at 400 Pawnee Drive, Mechanicsburg, Cumberland County,
Pennsylvania.
3. That Defendants, Sabrija O. Osojkic and Mujesira Osojkic, husband and wife, are
adult individuals, residing at 1460 Rt. 57, Port Murray, New Jersey.
4. On or about June 9, 2006, Plaintiffs filed a Complaint against Defendants in the
Prothonotary's Office of Cumberland County, Pennsylvania.
5. That the aforesaid Complaint requested that Defendants be required to pay
Plaintiffs the sum of $5,000 which amount represented a deposit for the purchase by Defendants
from Plaintiffs of a property situate at 6002 Roberts Drive, Hampden Township, Cumberland
County, Pennsylvania.
6. That pursuant to the terms of the Sales Agreement, the prospective buyers paid a
deposit in the amount of $5,000 to the prospective sellers. The aforesaid sum was deposited into
the trust account of Ronald D. Butler, Esquire.
7. That subsequently the buyers refused to purchase the property pursuant to the
terms of the Agreement and a dispute arose between the buyers and sellers as to the disposition
of the deposit.
8. That Ronald D. Butler, Esquire filed a Bill in Equity for an Interpleader in the
Prothonotary's Office of Cumberland County, Pennsylvania on or about November 3, 2005,
requesting an order to transfer the aforesaid $5,000 deposit to Court.
9. That on or about November 9, 2005, the Honorable Kevin A. Hess entered an
order directing Ronald D. Butler, Esquire to transfer the $5,000 deposit held in his trust account
to the Court which amount is presently being held in the Prothonotary's Office of Cumberland
County. A copy of the aforesaid order dated November 9, 2005, is attached hereto and marked
as "Exhibit A."
10. That counsel Robert B. Lieberman, Esquire on behalf of Plaintiffs and counsel R.
Mark Thomas, Esquire on the behalf of Defendants have reached an agreement for the division
of the aforesaid $5,000 security deposit (see attached Stipulation).
? t
WHEREFORE, Plaintiffs, JAMES D. MURICEAK and CAROL A. MURICEAK, and
Defendants, JASMIN OSOJKIC, ERMINA OSOJKIC, SABRIJA O. OSOJKIC and MUJESIRA
OSOJKIC, hereby request an Order directing the Prothonotary of Cumberland County to divide
the $5,000 deposit as set forth in the attached Stipulation.
Respectfully submitted,
Robert B. Lieberman, Esquire
500 North Third Street, 12th Floor
P.O. Box 1004
Harrisburg, PA 17108-1004
(717) 236-1485
Attorney for Plaintiffs
Respectfully submitted,
R. Mark Thomas, Esquire
101 South Market Street
Mechanicsburg, PA 17055
(717) 796-2100
Attorney for Defendants
RONALD D. BUTLER, P.C. CUMBERLAND COUNTY, PENNSYLVANIA
t/d/b/a BUTLER LAW FIRM, COURT OF COMMON PLEAS
Plaintiff
V. NO. CAS- 01U c (,?
JAMES D. MURICEAK, CAROL A.
MURICEAK, JASMIN OSOJKIC and
ERMINA OSOJKIC, SABRIJA O.
OSOJKIC and MUJESIRA OSOJKIC,
Defendants BILL INEQUITY
ORDER
AND NOW, this 0 day of e 2005, upon consideration of the Bill in
Equity for an Interpleader filed by Ronald D. Butler, P.C. t/d/b/a Butler Law Firm, it is hereby
ORDERED that the Bill in Equity for an Interpleader is granted and IT IS FURTHER
ORDERED that Ronald D. Butler, P.C. t/d/b/a Butler Law Firm is granted permission to transfer
the $5,000.00 deposit currently held in its trust account to the Court pending resolution of this
matter.
To:
Ronald D. Butler, Esquire
500 North Third Street
P.O. Box 1004
Harrisburg, PA 17108
R. Mark Thomas, Esquire
101 South Market Street
Mechanicsburg, PA 17055
James D. Muriceak
Carol A. Muriceak
440 Springhouse Road
Camp Hill, PA 17011
exHisiT:A:
BY TH COURT:
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JAMES D. MURICEAK and
CAROL A. MURICEAK,
Plaintiffs
V.
JASMIN OSOJKIC,
ERMINA OSOJKIC, SABRIJA O.
OSOJKIC and MUJESIRA OSOJKIC,
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-3271 Civil Term
: CIVIL ACTION LAW
STIPULATION
AND NOW, this (O day of , 2007, IT IS
HEREBY STIPULATED AND AGREED by and between Robert B. Lieberman, Esquire,
attorney for Plaintiffs, JAMES D. MURICEAK and CAROL A. MURICEAK and R. Mark
Thomas, Esquire, attorney for Defendants, JASMIN OSOJKIC, ERMINA OSOJKIC, SABRIJA
0. OSOJKIC and MUJESIRA OSOJKIC, that the trust deposit in the amount of $5,000 being
held by the Prothonotary of Cumberland County be divided as follows: $3,000 shall be paid to
Plaintiffs and $2,000 shall be paid to Defendants.
It is further agreed that the check payable to Plaintiffs shall be mailed to Robert B.
Lieberman, Esquire, 500 North Third Street, 12th Floor, Harrisburg, Pennsylvania 17101 and the
check payable to Defendants shall be mailed to R. Mark Thomas, Esquire, 101 South Market
Street, Mechanicsburg, Pennsylvania 17055.
Robert B. Lieberman, Esquire R. Mark Thomas, Esquire
Attorney for Plaintiffs Attorney for Defendants
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JAMES D. MURICEAK and
CAROL A. MURICEAK,
Plaintiffs
V.
JASMIN OSOJKIC,
ERMINA OSOJKIC, SABRIJA O.
OSOJKIC and MUJESIRA OSOJKIC,
Defendants
JUL S 6 2007 eIN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 06-3271 Civil Term
CIVIL ACTION - LAW
ORDER OF COURT
AND NOW, this Z c,' day of 2007, following
review and consideration of the Stipulation signed by counsel for Plaintiffs and counsel for
Defendants, IT IS HEREBY ORDERED AND DECREED that the Prothonotary of Cumberland
County shall immediately issue checks from the trust deposit being held in this case as follows:
a check in the amount of $3,000 payable to Plaintiffs and a check in the amount of $2,000
payable to Defendants. The aforesaid checks shall be mailed to counsel for the parties: Robert
B. Lieberman, Esquire for Plaintiffs and R. Mark Thomas, Esquire for Defendants.
BY THE COURT:
if LOU
A'b" V-;
JAMES D. MURICEAK and
CAROL A. MURICEAK
Plaintiffs,
VS.
JASMIN OSOJKIC, .
ERMINA OSOJKIC, SABRUA O.
OSOJKIC and MUJESIRA OSOJKIC,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 06-3271 Civil Term
CIVIL ACTION - LAW
PRAECIPE TO WITHDRAW. SETTLE & DISCONTINUE
To the Prothonotary:
On behalf of the Plaintiffs, please mark the Complaint filed against Defendants to the
above-captioned term and number as withdrawn, settled and discontinued.
Dated: July 26, 2007
By-
R ert B. Lieberman, Esquire
Atty. ID #07089
500 N. 3'd Street, 12th Floor
Harrisburg, PA 17101
(717)236-1485
Attorney for Plaintiffs
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