HomeMy WebLinkAbout02-2135Evelyn M. Noval
14 Colgate Drive
Camp Hill, PA 17011
Plaintiff
Merle H. Ryan and
Joyce M. Ryan, his wife,
29 Meadow Drive
Green Lane Faxms
Camp Hill, PA 17011
Defendant
Court of Common Pleas
Cumberland County, Pennsylvania
CMl Action - Law
TessXl - 2002
No. O.a -
Arbitration Demanded
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the daims 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 an attomey and file 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 judgement may be entered against you
by the Court without further notice for any money claimed in the Petition or for any other claim or
relief requested by the Plaintiff. You may lose money or property or other fights important to you.
YOU SHOUt D 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 WI-IF. RE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
Telephone (717) 249-3166
CLrlVIBERLAND COUNTY LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
Tdephone (717) 766-8475
NOTICA
Le han demandado a usted en h cone. 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 notification. Usted debe presentar una apariencia escrita o en persona o por abogado
y archivar en la corte en fox-ira escrita sus defensas o sus objectiones a las demandas en contra de su
persona~ Sea adisado que si usted no se defiende, la sin previo aviso o notification y por cu~quier
quja o puede perder dinero o sus propiedades o otros derechos impomantes para usted.
11 EVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE
ABOGODO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O 11 AME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCR1TA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
Tdephone (717) 249-3166
CUMBERLAND COUNTY LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17O13
Telephone (717) 766-8475
DATE: April 29, 2002
& ZIMMERMAN, P.C.
PAUL L I~EiGLER, ESQUIRE
I. D. No. 09603
355 N. 21st Street, Suite 201
P. O. Box 1080
Camp Hill~ PA 17011
(717) 731-1484
Evelyn M. Noval
14 Colgate Drive
Camp Hill, PA 17011
Plaintiff
Merle H. Ryan and
Joyce M. Ryan, his wife,
29 Meadow Drive
Green Lane Fmms
Camp Hill, PA 17011
Defendants
Court of Common Pleas
Cumberland County, Pennsylvania
Civil Action - Law
Term - 2002
No. oa. .21 ~ C,~;_4.~
Arbitration Demanded
COMPLAINT
AND NOW, comes the Plaintiff, Evelyn M. Nova] by her attorneys, ZEIGLER &
ZIMMERMAN, P.C., to file the within Complaint against Defendants Merle H. Ryan and Joyce
M. Ryan, and aver in support thereof as follows:
I. NATURE OF ACTION
1. This is an action for recovery of monies paid by Evelyn M. Nova] to Merle H.
Ryan (hereinafter "Ryan") and Joyce M. Ryan as a result of demands by Ryan for the subject
funds.
II. JURISDICTION AND VENUE
2. Jurisdiction of this court is invoked under the authorities and prindples contained
in 42 Pa. C.S. $5322.
3. Venue is properly situated in this Court under Pennsylvania Rules of Civil
Procedure 1006(a) and the authority contained therein.
III. PARTIES
4. The Plaintiff, Evelyn M. Nova] (hereinafter "Nova]"), is an adult individual born
February 18, 1919, who resides at 14 Colgate Drive, Camp Hill, Pennsylvania, 17011, and is the
sister of Merle H. Ryan.
5. The Defendants, Merle H. Ryan and Joyce M. Ryan, his wife, are adult individuals
residing at 29 Meadow Drive, Green Lane Farms, Camp Hill, Pennsylvania, 17011; Merle H.
Ryan is a brother of Nova].
IV. FACTUAL BACKGROUND
6. On or about March 27, 1996, Merle H. Ryan demanded of Nova] the sum of
$5,000, which was paid by Nova] to Merle Ryan per check number 1034 (a copy of which is
attached hereto as Exhibit "A").
7. The aforementioned check number 1034 was deposited into the Mellon Bank
account 2611075512 belonging to Defendants Merle H. Ryan and Joyce M. Ryan on or about
March 29, 1996.
8. On or about May 19, 1996, Merle H. Ryan again demanded of Nova] an
additional sum of $5,000, which was paid by Nova] to Joyce M. Ryan at Merle H. Ryan's request,
by check number 1080 (a copy of which is attached hereto as Exhibit "B").
9. The aforementioned check number 1080 was deposited into Mellon Bank
account 2611075512 belonging to Defendants on or about May 20, 1996.
10. On or about March 19, 1998, Merle H. Ryan demanded of Noval the sum of
$3,000, which was paid by Nova] to Merle H. Ryan by check number 1466 (a copy of which is
attached hereto as Exhibit "C").
11. The aforementioned check number 1466 was deposited into Mellon Bank
account 2611075512 belonging to Merle H. Ryan.
12. The aforesaid monies totaling $13,000 were never presented as a gift, but were
presented as a response to a demand by Ryan with the understanding that these monies would be
repaid to Nova].
13. At no point did Nova] suggest, imply, or otherwise convey any impression that
these monies represented a gift to Ryan.
14. Nova] has received no repayment of these monies, or any part thereof, despite a
demand to Ryan to repay the $13,000, nor has there been any other rolm of repayment in either
services rendered or other fosms of equity.
15. Therefore, Nova] has sustained monetary damages in the amount of $13,000.
WHEREFORE, the Plaintiff, Evelyn M. Noval, demands judgment against the
Defendants, Mede H. Ryan and Joyce M. Ryan, in an amount of $13,000 plus interests and costs,
together with whatever other monetary damages the Court deems proper.
DATE: April 29, 2002
Respectfully submitted,
: ZIMMERMAN, P.C.
.' QUIRE
I. D. No. 09603
355 N. 21st Street, Suite 201
P. O. Box 1080
Camp Hill, PA 17011
(717) 731-1484
VERIFICATION
I, Evelyn M. Noval, hereby acknowledge that I am the Plaintiff in this action and that the
statements made in the foregoing Complaint are tree and correct to the best of my knowledge,
information and belief.
I understand that any false statements herein are made subject to the penalties of 18 Pa.
C.S. Section 4904, relating to unswom falsification to authorities.
DATE: April 29, 2002
ve yn M. ~l~ox3al
CERTIFICATE OF SERVICE
I, Paul L. Zeigler, Esquire, of the law firm of Zeigler & Zimmerman, P.C., attorneys for
the Plaintiff, Evelyn M. Noval, do hereby certify that on this __ day of ., 2002,
I served a tree and correct copy of the foregoing Complaint upon the parties listed below by
Sherif£s service or by depositing the same in the U.S. Mail, postage prepaid, as follows:
SHERIFF'S SERVICE
Merle H. Ryan and
Joyce M. Ryan, his wife
29 Meadow Drive
Green Lane Farms
Camp Hill, PA 17011
Evelyn M. Noval
14 Colgate Drive
Camp Hill, PA 17011
Theodore A. Adler, Esquire
Reager & Adler, P.C.
2331 Market Street
Camp Hill, PA 17011
U.S. MAIL - POSTAGE PREPAID
DATE: April 29, 2002
IMMERMAN, P.C.
By: PAUL L~IGLER,
I. D. No. 09603
355 N. 21st Street, Suite 201
P. O. Box 1080
Carnp Hill, PA 17011
(717) 731-1484
JESUS J. NOVAL 1 C1 _el/,
EVELYN M. NOVAL
14 COLGATE DR, PH 717-761-5773 .~ _ 60.7238/2313 P2
CAMP HILL, PA 17011
EXHIBIT A
JESUS J. NAVAL
EVELYN M. NAVAL 10 8 0
14 COLGATE DR. PH 717-761-5773 __ ~" 60-
CAMP HIM... PA 17'011 ~ ~ ~'f "'~'~**~'~
.....q / ..~////~., ,,C'/ ~9
_P~ .._ /.
/...~-~' ~..,.~'- ~ //~
·; 031'300082'
EXHIBIT B
EVELYN M. NOVAL
14 COLGATE DR
CAMP HILL, PA 17011
~.,,.,,,~ ~_ / ,/~-
~.~HARRIS
1466
EXHIBIT C
Evelyn M. Noval
14 Colgate Drive
Camp Hill, PA 17011
Plaintiff
Merle H. Ryan and
Joyce M. Ryan, his wife,
29 Meadow Drive
Green Lane Fan-s
Camp Hill, PA 17011
Defendant
Court of Common Pleas
Cumberland County, Pennsylvania
Civil Action - Law
Term - 2002
No. x3 '
Arbitration Demanded
PRAECIPE FOR ENTRY OF APPEARANCE
TO THB PROTHONOTARY:
Please enter my appearance on behalf of the Plaintiff, Evelyn M. Noval.
Respectfully submitted,
ZEIGLER & ZIMMERMAN, P.C.
~ESQUIRE
I. D. No. 09603
355 N. 21st Street, Suite 201
P. O. Box 1080
Camp Hill, PA 17011
(717) 731-1484
DATE: April 30, 2002
CERTIFICATE OF SERVICE
I, Paul L. Zeigler, Esquire, of the law farm of Zeigler & Zimmemaan, PxC., attorneys for
the Plaintiff, EvelynM. Noval, do hereby certify that on this ! dayof q/~l,t{ ,2002,
I served a true and correct copy of the foregoing Praedpe for--En--~ of Appearance,aport the
parties listed belov~ by depositing the same in the U.S. Mail, postage prepaid, as follows:
U.S. MAIL - POSTAGE PREPAID
Evelyn M. Noval
14 Colgate Drive
Camp Hill PA 17011
Theodore A. Adler, Esquire
Reager & Adler, P.C.
2331 Market Street
Camp Hill, PA 17011
ZEIGLER & ZIMMERMAN, P.C.
I. D. No.'
355 N. 21st Street, Suite 201
P. O. Box 1080
Camp H;ll~ PA 17011
(717) 731-1484
DATE: April 30, 2002
EVELYN M. NOVAL,
Plaimiff
V.
MERLE H. RYAN and
JOYCE M. RYAN, his wife,
Defendants
To:
Evelyn M. Noval
c/o Paul L. Zeigler, Esquire
Zeigler & Zimmerman, PC
355 N 21st Street, Suite 201
Camp Hill, PA 17011
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO: 02-2135
: Civil Action - Law
:
: Arbitration Demanded
NOTICE TO PLEAD
YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE
ENCLOSED PRELIMINARY OBJECTIONS WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST
YOU.
Date:
June, 2002
Respectfully scllmitted,
REAGER &~L~.C.
2331 Market Street
Camp Hill, PA 17011-4642
(717) 763-1383
Attorneys for Defendants
EVELYN M. NOVAL,
Plaintiff
MERLE H. RYAN and
JOYCE M. RYAN, his wife,
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO: 02-2135
: Civil Action - Law
:
: Arbitration Demanded
PRELIMINARY OBJECTIONS OF DEFENDANTS,
MERLE H. RYAN AND JOYCE M. RYAN TO THE
COMPLAINT OF PLAINTIFF. EVELYN NOVAI~
A. LEGAL INSUFFICIENCY OF THE COMPLAINT
(Demurrer)
1. Plaintiff, Evelyn M. Noval (hereinafter "Noval") has filed a Complaint in which
she pleads, as her cause of action, "recovery of monies paid by Evelyn M. Noval to Merle H.
Ryan... and Joyce M. Ryan as a result of demands from Ryan for the subject funds."
(Complaint paragraph 1)
2. Noval is Merle Ryan's sister. (Complaint at paragraph 4)
3. Thc Complaint alleges that Merle Ryan "demanded" $5,000 on or about March
27, 1996, which was "paid" by Noval to Merle Ryan. (Complaint at paragraph 6)
4. The Complaint also alleges that Merle Ryan "again demanded" an additional sum
of $5,000 on May 19, 1996, which was "paid" by Noval to Joyce Ryan, allegedly at Merle
Ryan's request. (Complaint at paragraph 8)
5. The Complaint further alleges that Merle Ryan "demanded" $3,000, which Noval
alleges she "paid" on March 19, 1998. (Complaint at paragraph 10)
6. The Complaint does not allege a loan agreement or agreement of any kind
between the Plaintiff and the Defendants.
7. The Complaint does not allege any claim sounding in assumpsit.
8. The Complaint does not allege any claim sounding in tort.
9. The Complaint is legally insufficient to state a cause of action.
WHEREFORE, Defendants, Merle H. Ryan and Joyce M. Ryan, respectfully request that
their demurrer be sustained and that Plaintiff's Complaint be dismissed.
B. INSUFFICIENT SPECIFICITY INA PLEADING
10. Plaintiff alleges that there was an "understanding" that any monies given to the
Defendants would be repaid.
11. To the extent Plaintiff claims that this alleged understanding was an agreement,
the Complaint fails to state whether the agreement is oral or written.
12. The Complaint also fails to state any facts which allegedly constitute this
"understanding". In particular, there are no allegations as to when the money given to the Ryans
was to allegedly have been repaid; or when or even if the date on which payment was allegedly
due to be paid has passed.
13. The terms and conditions of any alleged "understanding" are completely absent
from the Complaint.
14. The Complaint lacks the specificity required by Rule 1019 of the Pennsylvania
Rules of Civil Procedure.
WHEREFORE, Defendants, Merle H. Ryan and Joyce M. Ryan, respectfully request that
in the event Defendants' demurrer is not sustained that Plaintiff be ordered to more specifically
plead her cause of action.
Date: June 4, 2002
Respectfull~bn~ed, ,~
Theodc/re ,al Adler, Esquire
Attorney I.D. No. 16267
2331 Market Street
Camp Hill, PA 17011
Telephone: (717) 763-1383
Attorneys for Defendants
CERTIFICATE OF SERVICE
AND NOW, this 4~ day of June, 2002, I hereby verify that I have caused a tree and correct copy
of the foregoing Preliminary Objections to be placed in the U.S. mail, first class, postage prepaid and
addressed as follows:
Paul L. Zeigler, Esquire
Zeigler & Zimmerman, PC
355 N. 21st Street, Suite 201
Camp Hill, PA 17011
THE~OD~RL~A. ~'ER, ESQUIRE
SHERIFF'S RETURN - OUT OF COUNTY
CAS~ NO: 2002-02135 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NOVAL EVELYN M
VS
RYAN MERLE H ET AL
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
RYAN MERLE H
but was unable to locate Him in his bailiwick.
deputized the sheriff of YORK County,
serve the within COMPLAINT & NOTICE
He therefore
Pennsylvania,
to
On May 31st , 2002 , this office was in receipt of the
attached return from YORK
Sheriff's Costs:
Docketing 18.00
Out of County 9.00
Surcharge 10.00
Dep York County 42.60
.00
79.60
05/31/2002
R.' Thomas Kline
Sheriff of Cumberland County
ZEIGLER & ZIMMERMAN
Sworn and subscribed to before me
this 7~ day of ~,~, ~
A.D.
Prothonotar~ !
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2002-02135 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NOVAL EVELYN M
VS
RYAN MERLE H ET AL
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
RYAN JOYCE M
but was unable to locate Her in his bailiwick.
deputized the sheriff of YORK County,
serve the within COMPLAINT & NOTICE
He therefore
Pennsylvania,
to
On May 31st , 2002 ,
attached return from YORK
Sheriff's Costs:
Docketing
Out of County
Surcharge
6.00
.00
10.00
.00
.00
16.00
05/31/2002
ZEIGLER & ZIMMERMAN
Sworn and subscribed to before me
this ~ day of~
v i Prothonotar~ ~ ~
this office was in receipt of the
Sheriff of Cumberland County
YORKTOWNE BUSINESS FOMRS o'(717) 225:0363 · FAX (~'~ 7) 225JO367
OFFICE OF THE SHERIFF
SERVICE CALL
(717) 771-9601
28 EAST MARKET ST., YORK, PA 17401
SHERIFF SERVICE
PROCESS RECEIPT and AFFIDAVIT OF RETURN ~ TYPE ONLY UNE ~. THRU
1. PLAINTIFF/S/ I 2. CI*~ _RT?i'iLq~q ER ,., 4,, .i 1
(02-2135)
g'vel~n M. Noval ~4, TYPEOFWRITORCOMPLAINT--
3. DEFENDANT/S/
Merle H. Ryan et al
SERVE
AT
5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, A3q'ACHED, OR SOLD.
Merle H. Ryan
6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO., ClT~, BORe, TWR, STATE AND ZIP CODE)
29 Meadow Drive Green Lane Farms Camp Hill, PA 17011
7. INDICATE SERVICE: [~ PERSONAL O PERSON IN CHARGE ~ DEPUT'ZE ~.¥~k~d r~ 1ST CLASS MAIL O POSTED ~ OTHER
NOW Max' 2 ,20 02 I, SHERIFFOF!~COUNTY, PA, do hereby deputize the sheriff of
York COUNTY to execute thymine return ther~3,e"/'/'/'/~, ording
to law. This deputization being made at the request and risk of the plaintiff. .~"- ~-"-~:~--~,,(~
· SHERIFF OF e~l~O~'N"'~
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE:
ADVANCED FEE PAID BY SHERIFF
L~Derland
OUT 0F COUNTY
CUMBERLAND
NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same
without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the shedff to any plaintiff
herein for any loss, destruction, or removal of any prope~y before sheri~s sale thereof.
9, TYPE NAME and ADDRESS of A~rORNEY / ORIGINATOR and SIGNATURE
ZEIGLER & ZIMMERMAN 355 N. 21ST. ST. PO BOX 1080
12. S Er-¥~ ~IOTIC~ f3~ S"E~rc~ COFIY/~)~ME AND ADDRESS BELOW: (This area must be completed if nctice is to be mailed),
CUNBERLAND CO, SHERIFF
SPACE BELOW FOR USE OF THE SHERIFF -- DO NOT WRITE BELOW THIS MNE
13. I acknowledge receipt oftbe wdt
or complaint as indicated above,
r. AHRENS 44. ~E,VED
l~._~t~oWH.dngDate
16. HOWSERVED: PERSONAL( ) RESIDENC~ POSTED( ) POE( ) SHERIFF'SOFFICE( ) OTHER( ) SEE REMARKS BELOW
17. [~ I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc, name above. (See remarks below.)
18.;,NAI~,~I'ITLE OF IND~/IDU~L SE~RVED/~ST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defenriant) 19. ~ate of Service 20. ~me of Servic~
'ntlI,,,es ,nt. IDato 33me Mimes Int. Date 33me Miles Int. I Date 33me 'Miles 'Int. J Date 33meI MilesI Int.
23. Advance Costa 24. Service Costs 26. Mileage
100.00 24.00 14.60
34. Forelgn County Costs I 35. Advance Costa 36. ServioeCosts
42. day of
28, SubTotal 30. Notary
39. Total Costa
40. Costs Due or R~fund
47. DATE ·
5-28-02
49. DATE
COUNTY OF YORK
OFFICE OF THE SHERIFF
SERVICE CALL
(717) 771-9601
28 EAST MARKET ST., YORK, PA 17401
SHERIFF SERVICE INSTRUCTIONS
PROCESS RECEIPT and AFFIDAVIT OF RETURN PLE, A~E TYPE ONLY LINE
DO NOT DETACH ANY COPIES
2. COURT NUMBER
1. PLAINTIFF/S/ I~-?1'~ rqv~l
Evely~ M. Nova1 4. T?PEOFW~ITORCOMPLAIN'(
Notice & Ccmplaint
3. DEFENDANT/S/
Merle H. Ryan et al
SERVE ~' 5. NAME~F~ND~DUA~C~MPANY~RP~RA~N~TC~sERV~RDE~R~PT~N~FPR~PER~YT~E~EV~ED~ATTAc~ED,~R~LD~
Joyce M. Ryan
8. ADDRESS (STREET OR RFO WITH BOX NUMBER, AP/. NO., CI/~, BORO,/WP., STATE AND ZIP CODE)
AT 29 Meadow Drive Green Lane Farms C~,tp Hill, PA 17011
_ __ -- York ~ ' COUNTY to execute t~k~e ~~rding
to law. This deputization being made at the request and risk of the plaintiff. ~ "¢'~-~~ COUNTY
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: C~nberland
OUT 0F COUNTY
CUMBERLAND
ADVANCED FEE PAID BY SHERIFF
NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff lev~ing upon or attaching any property under within writ may leave same
without a watchman, in custody ef whomever is found in possession, after notifying person of levy or atlachment, without liebility on the part of such deputy or the sheriff to any plaintiff
herein for any loss, destruction, or removal of any property before sheri/fs sale thereof.
9. TYPE NAME and ADDRESS of ATrORNEY / ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED
ZEIGLER & ZIMMERMAN 731-1484 5-1-02
12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be maimed).
CUMBERLAND CO. SHERIFF
SPACE BELOW FOR USE OF THE SHERIFF -- DO NOT WRITE BELOW THIS LINE
13, I acknowledge receipt of the writ 14. 5D_/~E_I~EIVED 15. Expirstion/Headng Date
or comp,aint as iodized above. R. AHRENS 6-1-02
16. HOW SERVED: PERSONA~" RESIDENC.~I~ POSTED ( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW
17. [~ I he~y ced/fy and return a NOT FOUND because I am unable to locate the individual, company, etc. name above. (See remarks below.)
18~.N~P~.ND TITLE OF INOtVIDUAL SER'~ED / ~=~ ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. D~ta of S~¥ice 20. tie of SerVLce
21.-ATr(~,lPTS~Ste 'rime~j Int. rDa~e~'~M~'le~sFnt Date ~me Miles Int. Date tie Miles Int. Date tie J~iles Int. }Date[time r~es'l Int.
22. REMARKS: ~
23. Advance Costs 24. Service Costs 25. N/F 26. Mileage
34. Foreign County Costs I 35. Advance Costs I 36. Service Costs
41. AFFIRMEDl~ubscribed to before m 7~
42. day of
28. SubTotal 29. Pound 30. Nota~J 33 CostsDueorRefund ChsckNo.
40. Costs Due or Refund
5-28-02
49. DATE
County Sheriff
J 51 DATE RECFIVFF)
TA