HomeMy WebLinkAbout06-6033LINDA C. TILL, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COiJNTY,
PENNSYLVANIA
VS.
JAMES M. GOODYEAR, JR.,
DEFENDANT CIVIL ACTION -LAW
NOTICE
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 IMPORTANT
RIGHTS. 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
(717) 249-3166
Respectfully submitted,
By:
Howell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Attorney for Plaintiff
LINDA C. TILL, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY,
PENNSYLVANIA
VS. :
NO. f~4- G o 33 ~~~ ~~--.
JAMES M. GOODYEAR, JR.,
DEFENDANT CIVIL ACTION -LAW
COMPLAINT
Identification of the Parties
1. Plaintiff Linda C. Till is an adult individual residing at 320 East Meadow Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. Defendant James M. Goodyear, Jr., is an adult individual residing at 520
Boulevard Avenue, Dickson City, Lackawanna County, Pennsylvania 18519-1708.
3. The parties were married September 12, 2001 and are litigants in a divorce case
pending to Cumberland County Docket Number 2005-3782.
Defendant's History of Domestic Violence From 1999 to 2005
4. At the time of their marriage Plaintiff was unaware of Defendant's history of
domestic violence against women.
5. On November 28, 1999 Defendant was arrested by the Pennsylvania State Police
on five (5) counts including two counts of simple assault, one count of recklessly
endangering another person, one count of terroristic threats, and one count of harassment
and stalking committed against his then wife, Lisa A. Goodyear.
6. On November 28, 1999 the Defendant assaulted his then wife, Lisa A. Goodyear,
and placed a pistol in her side and attempted to put it inside her mouth which caused a
bruise on her jaw while telling her he would kill her and then himself.
1
7. On August 16, 2000 a Final Order of Court granting a protection from abuse
petition was issued in Cumberland County Docket Number 7172 S 1999 against the
Defendant in favor of Lisa A. Goodyear and was in effect through November 1, 2000.
On June 24, 2002 Defendant was suspected of stalking Lisa A. Goodyear and
police came to Plaintiff s business to locate her husband, the Defendant to inquire about
this allegation.
9. This allegation followed the Defendant's receipt of a letter from Lisa Goodyear
informing him that he was not to trespass at her residence.
10. From the time of the parties' marriage on September 12, 2001 through June 9,
2005 Defendant repeatedly engaged in choking, strangling, grabbing, shoving, pushing
the Plaintiff.
11. On or about August 2002 Defendant was driving a minivan at 65 miles per hour
in a 45 MPH zone when Plaintiff asked him to slow down but he decided to increase his
speed to 75 MPH before slamming on the brakes and leaving the car in the lane of travel
while he removed the key and started to walk away.
12. On or about June 11, 2004 the Defendant knocked Plaintiff down the stairs
outside their bedroom leaving a large bruise on her right arm of 2" x 6".
13. In April 2005 the Defendant chased Plaintiff s seventeen (17) year old daughter
inside her home, kicked in her bedroom door in and grabbed her by her face because he
was angry.
14. In May 2005 the Defendant told Plaintiff he would "take her down" unless she
complied with his demands.
2
15. On June 7, 2005 at Plaintiff s place of employment Defendant grabbed at
Plaintiff's neck causing Plaintiff's employee to call the West Shore Regional Police
Department.
16. On June 7, 2005 the Defendant pushed and shoved Marilyn J. Mullen out of the
way as he lunged for the Plaintiff in a rage and the West Shore Regional Police
Department issued a criminal citation against the Defendant.
17. On June 9, 2005 Plaintiff filed a Petition for Protection from Abuse in
Cumberland County Docket Number OS-2985 against the Defendant.
18. On June 13, 2005 Plaintiff obtained a Temporary Protection from Abuse Order
against the Defendant.
19. Interspousal immunity in a claim for damages in a tort action is no longer
recognized in Pennsylvania by virtue of the Pennsylvania Supreme Court in Hack v.
Hack, 495 Pa. 300, 433 A.2d 859 (1981) and even if the parties are litigants in a pending
divorce action a separate cause of action for personal injury is appropriate in accordance
withMazzone v. Mazzone, 24 Pa. D. & C. 3d 397 (1981).
Count I: Assault on July 28, 2005
20. After a Protection from Abuse Order was entered against the Defendant on June
13, 2005 the Defendant violated this Order on July 28, 2005.
21. On July 28, 2005 Plaintiff was on the tennis court with a minor child at Fisher
Park in Upper Allen Township, Cumberland County, Pennsylvania.
22. Defendant appeared at Fisher Park in Upper Allen Township and confronted the
Plaintiff on or about the tennis court because he was upset about an item of personal
property.
23. Defendant lunged at Plaintiff and grabbed Plaintiff s tennis racket from under her
arm which bruised her left arm before he raised the racket to strike the Plaintiff and cause
serious bodily harm.
24. Plaintiff was pushed in the encounter by Defendant and screamed.
25. Bystanders began to approach the parties and the Defendant ran away.
26. Defendant was charged with simple assault and harassment by the Upper Allen
Township Police Department on July 28, 2005.
27. Plaintiff s apprehension in being struck by a raised tennis racket was reasonable
and Defendant's act of grabbing and raising the tennis racket constituted an affirmative
act in his attempt to carry out the threatened harm.
28. As a direct result of Defendant's illegal conduct she has suffered symptoms of
depression, stress and anxiety which continue to cause her ongoing physical and
emotional harm.
29. The conduct of Defendant was so negligent, reckless, wanton, irresponsible,
willful, outrageous and/or malicious that Defendant should be punished by an assessment
of punitive damages in an amount to deter the Defendant from any repetition of similar
actions in the future.
30. The tort of assault occurs whenever an actor intentionally causes an imminent
apprehension of a harmful or offensive bodily contact with another person. Sides v.
Cleland, 436 Pa. Super. 618, 648 A.2d 793 (1994) citing Restatement (Second) of Torts
§21.
4
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter
judgment for compensatory and punitive damages against the Defendant in an amount in
excess of Thirty Five Thousand and 00/100 Dollars ($35,000.00) plus interest and costs.
Count II: Battery on July 28, 2005
31. After a Protection from Abuse Order was entered against the Defendant on June
13, 2005 the Defendant violated this Order on July 28, 2005.
32. On July 28, 2005 Plaintiff was on the tennis court with a minor child at Fisher
Park in Upper Allen Township, Cumberland County, Pennsylvania.
33. Defendant appeared at Fisher Park in Upper Allen Township and confronted the
Plaintiff about 35 feet from the tennis court because he was upset about an item of
personal property.
34. Defendant lunged at Plaintiff and grabbed Plaintiff s tennis racket from under her
left arm causing bruising and then raised it to strike the Plaintiff and cause serious bodily
harm.
35. Plaintiff was pushed in the encounter and screamed.
36. Bystanders began to approach the parties and the Defendant ran away.
37. Defendant was charged with simple assault and harassment by the Upper Allen
Township Police Department on July 28, 2005.
38. As a direct result of Defendant's illegal conduct she has suffered symptoms of
depression, stress and anxiety which continue to cause her ongoing physical and
emotional harm.
5
39. The conduct of Defendant was so negligent, reckless, wanton, irresponsible,
willful, outrageous and/or malicious that Defendant should be punished by an assessment
of punitive damages in an amount to deter the Defendant from any repetition of similar
actions in the future.
40. The tort of battery occurs whenever an individual is actually subjected to a
harmful or offensive contact by another person. Dalrymple v. Brown, 549 Pa. 217, 701
A.2d 164 (1997).
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter
judgment for compensatory and punitive damages against the Defendant in an amount in
excess of Thirty Five Thousand and 00/100 Dollars ($35,000.00) plus interest and costs.
Count III: Assault on June 7, 2005
41. Plaintiff and Defendant were located at Plaintiff s place of employment at 309
South 10~" Street, Lemoyne, Cumberland County, Pennsylvania 17043.
42. At approximately 4:30 PM Plaintiff and Defendant were involved in a verbal
dispute which escalated to physical violence when Defendant pushed an employee and
lunged for Plaintiff's neck to strangle her.
43. Plaintiff's employee called 911 and the Defendant left the building.
44. Plaintiff was afraid to return to her own home and secured lodging at a local hotel
at the cost of $271.20 for the period June 7, 2005 -June 11, 2005.
45. Plaintiff was advised by the police to obtain a protection from abuse petition and
she met with Mid Penn Legal Services on June 9, 2005 to complete the petition.
6
46. As a direct result of Defendant's illegal conduct she has suffered symptoms of
depression, stress and anxiety which continue to cause her ongoing physical and
emotional harm.
47. The conduct of Defendant was so negligent, reckless, wanton, irresponsible,
willful, outrageous and/or malicious that Defendant should be punished by an assessment
of punitive damages in an amount to deter the Defendant from any repetition of similar
actions in the future.
48. Plaintiff experienced pain and suffering as a direct result of'Defendant's attack
and a claim is made for compensation.
49. Plaintiff's apprehension in being strangled was reasonable and Defendant's act of
lunging towards her neck constituted an affirmative act in his attempt to carry out the
threatened harm.
50. The tort of assault occurs whenever an actor intentionally causes an imminent
apprehension of a harmful or offensive bodily contact with another person. Sides v.
Cleland, 436 Pa. Super. 618, 648 A.2d 793 (1994) citing Restatement (Second) of Torts
§21.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter
judgment for compensatory and punitive damages against the Defendant in an amount in
excess of Thirty Five Thousand and 00/100 Dollars ($35,000.00) plus interest and costs.
Count IV: Battery on June 7, 2005
51. Plaintiff and Defendant were located at Plaintiff s place of employment at 309
South 10`h Street, Lemoyne, Cumberland County, Pennsylvania 17043.
7
52. At approximately 4:30 PM Plaintiff and Defendant were involved in a verbal
dispute which escalated to physical violence when Defendant pushed an employee and
lunged for Plaintiff's neck.
53. Plaintiff's employee called 911 and the Defendant left the building.
54. Plaintiff was afraid to return to her own home and secured lodging at a local hotel
at the cost of $271.20 for the period June 7, 2005 -June 11, 2005.
55. Plaintiff was advised by the police to obtain a protection from abuse petition and
she met with Mid Penn Legal Services on June 9, 2005 to complete the petition.
56. As a direct result of Defendant's illegal conduct she has suffered symptoms of
depression, stress and anxiety which continue to cause her ongoing physical and
emotional harm.
57. The conduct of Defendant was so negligent, reckless, wanton, irresponsible,
willful, outrageous and/or malicious that Defendant should be punished by an assessment
of punitive damages in an amount to deter the Defendant from any repetition of similar
actions in the future.
58. Plaintiff experienced pain and suffering as a direct result of Defendant's attack
and a claim is made for compensation.
59. The tort of battery occurs whenever an individual is actually subjected to a
harmful or offensive contact by another person. Dalrymple v. Brown, 549 Pa. 217, 701
A.2d 164 (1997).
8
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter
judgment for compensatory and punitive damages against the Defendant in an amount in
excess of Thirty Five Thousand and 00/100 Dollars ($35,000.00) plus interest and costs.
Count V: Assault on March 23, 2005
60. On March 23, 2003 the Plaintiff left her home and stayed at a local hotel to escape
verbal abuse and the threat of physical violence by the Defendant.
61. On March 24, 2005 the Plaintiff returned to her home because the Defendant
assured her he had calmed down and no longer posed a threat to her.
62. On March 23, 2005 the Plaintiff and Defendant were inside the home located at
320 East Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055
when the Defendant started to verbally abuse Plaintiff.
63. Defendant was screaming and arguing with the Plaintiff claiming he "wanted to
kill her".
64. Plaintiff attempted to hide in the bedroom but Defendant pursued her into the
room and with both hands grabbed her around her throat, threw her to the bed and then
lay down on top of the Plaintiff.
65. Defendant choked the Plaintiff telling her he "wanted to kill her".
66. Plaintiff and Defendant struggled on the bed until Plaintiff was able to escape and
run out of the room and into the street.
67. Plaintiff was running on Autumnwood Drive when the Defendant caught up to her
and grabbed her by the collar of her shirt.
68. Defendant then began to drag Plaintiff back to the home until he was surprised by
a passer by in an automobile which caused him to let go of the shirt.
9
69. Plaintiff ran away from the Defendant to the home of Glenn and Joanne Davis.
70. Defendant pursued the Plaintiff to the Davis' home where she had sought refuge.
The Defendant entered the Davis' home and attempted to chase her into the basement
before Glenn Davis was able to convince him to calm down and behave rationally.
71. Plaintiff sought medical treatment and incurred medical bills as a result of the
treatment.
72. As a direct result of Defendant's illegal conduct she has suffered symptoms of
depression, stress and anxiety which continue to cause her ongoing physical and
emotional harm.
73. The conduct of Defendant was so negligent, reckless, wanton, irresponsible,
willful, outrageous and/or malicious that Defendant should be punished by an assessment
of punitive damages in an amount to deter the Defendant from any repetition of similar
actions in the future.
74. Plaintiff experienced pain and suffering as a direct result of Defendant's attack
and a claim is made for compensation.
75. As a direct result of Defendant's illegal conduct she has suffered symptoms of
depression, stress and anxiety which continue to cause her ongoing physical and
emotional harm.
76. The conduct of Defendant was so negligent, reckless, wanton, irresponsible,
willful, outrageous and/or malicious that Defendant should be punished by an assessment
of punitive damages in an amount to deter the Defendant from any repetition of similar
actions in the future.
10
77. The tort of assault occurs whenever an actor intentionally causes an imminent
apprehension of a harmful or offensive bodily contact with another person. Sides v.
Cleland, 436 Pa. Super. 618, 648 A.2d 793 (1994) citing Restatement (Second) of Torts
§21.
Count VI: Battery on March 23, 2005
78. On March 23, 2003 the Plaintiff left her home and stayed at a local hotel to escape
verbal abuse and the threat of physical violence by the Defendant.
79. On March 24, 2005 the Plaintiff returned to her home because the Defendant
assured her he had calmed down and no longer posed a threat to her.
80. On March 23, 2005 the Plaintiff and Defendant were inside the home located at
320 East Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055
when the Defendant started to verbally abuse Plaintiff.
81. Defendant was screaming and arguing with the Plaintiff claiming he "wanted to
kill her".
82. Plaintiff attempted to hide in the bedroom but Defendant pursued her into the
room and with both hands grabbed her around her throat, threw her to the bed and then
lay down on top of the Plaintiff.
83. Defendant choked the Plaintiff telling her he "wanted to kill her".
84. Plaintiff and Defendant struggled on the bed until Plaintiff was able to escape and
run out of the room and into the street.
85. Plaintiff was running on Autumnwood Drive when the Defendant caught up to her
and grabbed her by the collar of her shirt.
11
86. Defendant then began to drag Plaintiff back to the home until he was surprised by
a passer by in an automobile which caused him to let go of the shirt.
87. Plaintiff ran away from the Defendant to the home of Glenn and Joanne Davis.
88. Defendant pursued the Plaintiff to the Davis' home where she had sought refuge.
The Defendant entered the Davis' home and attempted to chase her into the basement
before Glenn Davis was able to convince him to calm down and behave rationally.
89. Plaintiff sought medical treatment and incurred medical bills as a result of the
treatment.
90. As a direct result of Defendant's illegal conduct she has suffered symptoms of
depression, stress and anxiety which continue to cause her ongoing physical and
emotional harm.
91. The conduct of Defendant was so negligent, reckless, wanton, irresponsible,
willful, outrageous and/or malicious that Defendant should be punished by an assessment
of punitive damages in an amount to deter the Defendant from any repetition of similar
actions in the future.
92. Plaintiff experienced pain and suffering as a direct result of Defendant's attack
and a claim is made for compensation.
93. As a direct result of Defendant's illegal conduct she has suffered symptoms of
depression, stress and anxiety which continue to cause her ongoing physical and
emotional harm.
12
94. The conduct of Defendant was so negligent, reckless, wanton, irresponsible,
willful, outrageous and/or malicious that Defendant should be punished by an assessment
of punitive damages in an amount to deter the Defendant from any repetition of similar
actions in the future.
95. The tort of battery occurs whenever an individual is actually subjected to a
harmful or offensive contact by another person. Dalrymple v. Brown, 549 Pa. 217, 701
A.2d 164 (1997).
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter
judgment for compensatory and punitive damages against the Defendant in an amount in
excess of Thirty Five Thousand and 00/100 Dollars ($35,000.00) plus interest and costs.
Count VII: False Imprisonment
96. On March 23, 2005 Defendant chased Plaintiff outside her home located at 320
East Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055.
97. Outside the home Defendant grabbed Plaintiff by the collar and forcibly began to
drag her back to the home.
98. Plaintiff desired to escape Defendant's grasp and struggled against him to prevent
Defendant from dragging her back into the home.
99. Defendant's actions in grabbing and dragging the Plaintiff were deliberate.
100. Defendant's actions in grabbing and dragging the Plaintiff were intended to
confine Plaintiff to an area of his choosing.
101. Plaintiff experienced pain and suffering as a direct result of Defendant's attack
and a claim is made for compensation.
13
102. As a direct result of Defendant's illegal conduct she has suffered symptoms of
depression, stress and anxiety which continue to cause her ongoing physical and
emotional harm.
103. The conduct of Defendant was so negligent, reckless, wanton, irresponsible,
willful, outrageous and/or malicious that Defendant should be punished by an assessment
of punitive damages in an amount to deter the Defendant from any repetition of similar
actions in the future.
104. A claim for false imprisonment arises if a person: (1) acted intentionally to
confine an individual within fixed boundaries; (2) the intentional acts did directly or
indirectly confine the individual; and (3) the individual was conscious of the confinement
or is harmed by it. Gagliardi v. Lynn, 446 Pa. 144, 285 A.2d 109 (1971) citing
Restatement (Second) of Torts at §35.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter
judgment for compensatory and punitive damages against the Defendant in an amount in
excess of Thirty Five Thousand and 00/100 Dollars ($35,000.00) plus interest and costs.
Count VIII: Intentional Infliction of Emotional Distress
105. Defendant's actions on March 23, 2005, June 7, 2005, and July 28, 2005
constitute a pattern of abusive behavior against Plaintiff.
106. Defendant's actions are a pattern of violence against at least two spouses, the
Plaintiff herein and Lisa Goodyear.
107. Plaintiff incorporates by reference ¶1 through ¶106 as though fully set forth.
108. Defendant's actions are extreme and outrageous that is intentional and/or reckless.
14
109. Defendant's actions were designed to inflict severe emotional distress on the
Plaintiff.
110. In order to state a claim for intentional infliction of emotional distress, an
individual must allege facts that establish the conduct of another person: (1) that is
extreme and outrageous; (2) that is intentional or reckless; and (3) that causes severe
emotional distress. Hoy v. Angelone, 456 Pa. Super. 596, 691 A.2d 476 (1997).
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter
judgment for compensatory and punitive damages against the Defendant in an amount in
excess of Thirty Five Thousand and 00/100 Dollars ($35,000.00) plus interest and costs.
Respectfully submitted,
BY:
St en Howell, Esquire
owell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Attorney for Plaintiff
15
Verification
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A.
Section 4904 relating to unsworn falsification to authorities.
BY: a`~:~CT-~
Linda C. Till
Date:
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LINDA C. TILL,
PLAINTIFF
VS.
JAMES M. GOODYEAR, JR.,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
N0.06-6033 CIVIL TERM
CIVIL ACTION -LAW
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the complaint in this matter.
Respectfully submi
By:
Howell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Attorney for Plaintiff
Date: March 22, 2007
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2006-06033 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
TILL LINDA C
VS
GOODYEAR JAMES M JR
R. Thomas Kline Sheriff or Deputy Sherif who being
duly sworn according to law, says, that he made a diligen search and
and inquiry for the within named DEFENDANT to wit:
GOODYEAR JAMES M JR
but was unable to locate Him in his bailiwick. He th efore
~ac lCa w~~iLw~
deputized the sheriff of DAUPHIN County, Penns vania, to
serve the within COMPLAINT & NOTICE
On January 17th 2007 this office was in receip o
attached return from DAUPHIN
Sheriff's Costs: So answer
Docketing 18.00 _-
Out of County 9.00
Surcharge 10.00 R. Thomas Kline
Lackawanna/Notary 40.40 Sheriff of Cumberland C n
Postage 3.21
80.61 ~',f~9~o~ `-~~
01/17/2007
STEVEN HOWELL
Sworn and subscribe to before me
this day of ,
ty
A.D.
~n The Court of Conlgnon Pleas of Cumberland County, P
Linda C. Till
VS.
James M. Goodyear Jr. 06-6033 ~
No.
Now Nov~nber 8 , 200 6 ~ I, SHERIFF OF CUMBERLAND C
hereby deputize the Sheriff of Lackawanna County to exec
deputation being made at the request and risk of the Plaintiff.
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Sheriff of Cumberland
Now,
within
upon
at
by handing to
a
and made known to
So answers,
Sworn and subscribed before
me this day of , 20
Affidavit ®f Service
20 , at
o'clock
the
Sheriff of
COSTS
SERVICE ~
MILEAGE
AFFIDAVIT
copy of the original
sylvan~a
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is Writ, this
.y, PA
1. served the
thereof.
County, PA
SHERIFF'S RETURN - NOT SERVED
CASE NO: 2006-00549 T ~
COMMONWEALTH OF PENNSYLVANIA 4
COUNTY OF Lackawanna County
TILL LINDA C.
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VS
GOODYEAR JR. JAMES M.
ROBERT MOORS Deputy Sheriff, who being ly sworn
according to law, says, that he made a diligent search and 'nquiry for
the within named DEFENDANT to wit:
JAMES M
JR but was
.
.
GOODYEAR
unable to locate Him in his bailiwick. He therefore ret ns the
COMP,INTERR,REQUEST
NOT SE ED as to
ed DEFENDANT GOODYEAR JR. JAMES M.
hi
n nam
the wit
520 BOULEVARD AVE
DICKSON CITY, PA 18519
NOT SERVED 12/20/06
ATTEMPTS
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So answers:
John Szymanski, Sheriff
Sheriff's Costs:
Docketing 35~~ID •00 By•
Service ~
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Surcharge .00 Deputy Sheriff
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Sworn and subscribed to before me
this _ day of `~~
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NOTARIAL SEAL
Franoa DI liionz+o. Notary Pub1~
SccanWn City. Ladcawame Cou.~ty
y commission explna Jn123, Zo10
LINDA C. TILL,
PLAINTIFF
VS.
JAMES M. GOODYEAR, JR.,
DEFENDANT
. IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.06-6033 CIVIL TERM
CIVIL ACTION -LAW
PRAECIPE TO DISCONTINUE WITH PREJUDICE
TO THE PROTHONOTARY:
Please mark the above captioned actions as SETTLED and DISCONTINUED
WITH PREJUDICE upon Motion by Plaintiff's Counsel of Record.
Respectfully submitted,
By:
'~iowell Law Firm
619 Bridge Street
New Cumberland, PA 17070
(717) 770-1277
Supreme Court ID 62063
Attorney for Plaintiff
Date: May 23, 2007
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2006-06033 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
TILL LINDA C
VS
GOODYEAR JAMES M JR
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:
GOODYEAR JAMES M JR
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of MONROE
serve the within COMPLAINT & NOTICE
County, Pennsylvania, to
On April 13th 2007 this office was in receipt of the
attached return from MONROE
Sheriff's Costs: So answer _
Docketing 18.00
Out of County 9.00
Surcharge 10.00 R. Thomas Kline
Dep Monroe County 23.24 Sheriff of Cumberland County
Postage 1.74
61.98 / y~I~i~d7
04f13/2007
STEVEN HOWELL
Sworn and subscribe to before me
this day of ,
A.D.
G70955 REC 3/22/07 $150.00 T ~ TOTAL X23.24 PD PLFF REFOND #12b.7b
'CANT, CLERK EXP 4/23/07
in The Court of Common Pleas of Cumberland County, Pennsylvania
Linda C. Till
Janes M. Goodyear Jr.
~,~ 06-6033 civil
N o .
Now, March 23 , 2007
hereby deputize the Sheriff of
Monroe
I, SHERIFF OF CUMBERLAND COUNTY, PA, do
deputation being made at the request and risk of the Plaintiff.
JAMES M. GOODYEAR JR.
31 BULLPINE ROAD
EAST STROUDSBURG, PA 18301
20 , at o'clock M. served the
Affidavit of Service
Now,
within
upon
at
by handing to
a
and made known to
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~~CKSON ~ tom, ~~
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Sworn and subscribed before
me this ~,Tg day of APRIL , 20~_
'~E~ Nnra M~~~
BURG BORO, M.ORROE COUNTY
4 7.
County to execute this Writ, this
Sheriff of Cumberland County, PA ~ ..
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copy of the original
the
So answers, /
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Sheriff of
COSTS
SERVICE _
MILEAGE _
AFFIDAVIT
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County, PA