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HomeMy WebLinkAbout06-6284 r ' Type of Pleading: Custody Complaint Prepared By: Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 Supreme Court ID # 32112 Phone: 717-737-0100 Fax: 717-975-0697 Email: dianeradcliff@comcast.net Attorney for Alan B. McCausland IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN B. McCAUSLAND Plaintiff NO. CIVIL TERM v. CIVIL ACTION - LAW NANCY C. McCAUSLAND Defendant IN CUSTODY CUSTODY COMPLAINT 1. The Plaintiff is Alan B. McCausland, who is or will be residing at 8 South 15th Street, Camp Hill, Cumberland County, PA. 2. The Defendant is Nancy C. McCausland, residing at 135 North 17th Street, Camp Hill, Cumberland County, PA. 3. Plaintiff seeks custody of the following children: NAME PLACE OF RESIDENCE AGE D.O.B. Hannah A. McCausland 8 South 15th Street 14 5/9/1992 Camp Hill, PA 17011 Sarah E. McCausland 8 South 15th Street 11 7/4/1995 Camp Hill, PA 17011 - 1 - , " lo. COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS Judicial District, County Of Cumberland NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT COMMON PLEAS No. 0'tP 284 NOTICE OF APPEAL Civil Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case referenced below. NAME OF APPELLANT MAG. DIST. NO. 09-3-02 NAME OF D.J. Vivian Cohick CITY STATE ZIP CODE 17015 IN THE CASE OF (Plaintiff) Carlisle PA ober 13 2006 Thomas J. Jones DOCKET No. (Defendant)" VB Geor e Sneed SIGNATURE OF APPELLANT OR ATTORNEY OR AGENT CV-l11-06 This block will be signed ONLY when this notation is required under Pa. If appellant R.C.P.D.J. No. 10088. This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty SUPERSEDEAS to the judgment for possession in this case. (20) days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONL Y when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be seNed upon appellee. PRAECIPE: To Prothonotary Enter rule upon Thoma s J. J one s Name of appellee(s) appellee(s), to file a complaint in this appeal (Common Pleas No. 06- 6284 Ci vi]) within twenty (20) days after service of rule or suffer entry of judgment of non pros. RULE: To Thomas J. Jones Name of appel/ee(s) , appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of the mailingcr J ~ . Date: Oct 27 ,2006 ~. ~_~,&,. y~' . /' I Signature of U.onatary or~ !J YOU MUST INCLUDE A COpy OF THE NOTICE OF JUDGMENTrrRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-02 WHITE - COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE YELLOW _ APPELLANT'S COPY PINK - COPY TO BE SERVED ON APPELLEE GOLD - COPY TO BE SERVED ON DISTRICT JUSTICE PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF ; ss AFFIDAVIT: I hereby (swear) (affirm) that! served D , upon the District Justice designated therein on a copy of the Notice of Appeal, Common Pleas (date of service) ,20 D by personal service D by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) , on ,20 D by personal service D by (certified) (registered) mail, sender's receipt attached hereto, (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF , 20_. Signature of affiant Signature of official before whom affidavit was made Title of official ~~:p ~~ ~ ~ A' ~ (j.. ~ CN, ~\ My commission expires on ,20_, (") S; s.:-.. 33~F (J' .C" ~( ~i~: 7' ~ '"" = = c::f"' o C"') -l N -.J o -n ~ m:!J "FYi :nO 0(1, :::;:l-f; :;.'- ::!J ~o ,Srn -I ?O ~ ):JI> :::l!: Ui \D OOMMONWEAL TH OF PENNSYLVANIA COUNTY OF: ctJIIBlm"(..aJIID NOTICE OF JUDGMENTrrRANSCRIPT CIVIL CASE ... Mag. Disl. No.: 09-3-02 PLAINTIFF: NAME and ADDRESS rJOJ1BS, DallAS J. 2989 UOLA ROAD TIlE HAPPy BBUBBPD ~ZSLB, PA 17013 VS. DEFENDANT: NAME and ADDRESS fiJ1BBD, GBORGB 256 RZCBLAJm ROAD CARLZSLB, PA 17013 L Docket No.: CV-0000111-06 Date Filed: 8/30/06 -, MDJ Name: HOll. VIVID COBICl: Address: PO BOX 155 27 W BZG SPRZBG AVE BBWVJ:LLB, PA Telephone: (717) 776-3187 17241 ~ -, GEORGE SJ1BBD 256 RI""..QD ROAD CARLZSLB, PA 17013 ~ THIS IS TO NOTIFY YOU THAT: Judgment: POR PLAZRTZPP (Date of Judgment) ~ Judgment was entered for: (Name) JOBS, '!"BODS J. ~ Judgment was entered against: (Name) SJ1BBD, CDORCi1B in the amount of $ 160.6'6 o Defendants are jointly and severally liable. o Damages will be assessed on Date & Time o This case dismissed without prejudice. 10/13/06 Amount of Judgment $ 69.03 Judgment Costs $ 91.63 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 160.66 Post Judgment Credits $ Post Judgment Costs $ --------- - ------------ Certified Judgment Total $ o Amount of Judgment Subject to AttachmenV42 Pa.C.S. 98127 $ o Portion of Judgment for physical damages arising out of residential lease $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARYICLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COpy OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAYBE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. /0 /3 6b Date , Magisterial District Judge I certify that this is a true and correct copy of t record of the proceedings containing the judgment. Date , Magisterial District Judge My commission expires first Monday of January, 2012 AOPC 315-06 SEAL DAD PRZRTBD: 10/13/06 4:29:00 PH ~~~ ~J cx:\-. ~~ 0 ~ ~) ~ ) ~ () ~~ t -~_. "'" = = 0..... ~ ~.,...i f-n- ~!"! 8 '.~J~~; .~~~~ '~ ---, :0 =< o CJ -i N -.J :J:"', -:a. en \..D ~ \ ~, ~ ~ ~ ~ \~ u.s. I?ostal Service CERlTlFIED MAIL RECEIPT (DomcJtic Mall Only; No 'r"'1/ /11,'(' COV( r,/(/, P"'dcl('(fJ ::r .J] ~ LO PDstage . ~. .39 2.40 1. 85 3.70 8.34 Postmark ',Here !:::: M ::r ::r n.J ::ertified Fee .J] Returr Receipt Fee i c:::J (Endorsement Required) i c:::J Restricted Delivery Fee r c:::J (Endorsement Required) . r-- Total Postage & Fees L $ c:::J M LO n.J Sent To Thomas J. Jones ~ -~!;~~~~'iii~p'p-y"-B~~k~-~'p-~~----------------'---------'----'-- ~ 'ciiY2>"9tt)~+;gn.-b l'a-- -RCia a-- --.- ---- ----- -- --..- -- --- -..- -- -- ------ -... PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO RLE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ; ss AFFIDAVIT: I hereby (swear) ~ that I served ~ a copy of the Notice of Appeal, Common Pleas 06- 6284, upon the District Justice designated therein on (date of service) October 27, 20~, 0 by personal service iii by (certified) (r~) mail, sender's receipt attached hereto, and upon the appellee, (name) Thomas J. J one s ' on October 27 ,20~ 0 by personal service ~ by(certified)(r~)mail, sender's receipt attached hereto, (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME T 2 DAY OF October ,20.ll.6.-. ~ ;:- ~ S~"""fflof._f Notary Public Title of official My commission expires on ,20_. U.S. Postal Service CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL CONNIE J TRITT, Notary Public Carlisle Bore., Cumberland County M Com~!~].?n Exp~~~.OClober 5, 2008 ::r ITl ::r n.J 'li t'J\1/\l...\St\JN3d 'U~. rnj-i'-', '-'-::>''''1"\ I 1'-11 :..' ..' '..'Clr".! tv .J] Return Receipt Fee c:::J (Endorsement Required) c:::J c:::J .39 2.40 1. 85 ~-- ::r .J] Postage $ ~ LO Certitied Fee Postmar1< ~'Here :..;.1' Restricted Delivery Fee (Endorsement Required) 62 : I ~ld LZ 1:10 900l .'...............~~."..A> AWIOi'~OH.LOQd 3Hl :10 30I:HQ:-<131I:l c:::J .-=t LO n.J Sent To M ___DJ_~_tx:i_c_t__.M_agis_t:.r.a_t_e_..viY:Lan...Co.hi. 1 Street, Apt. No.; g .~~.~i5.5_..._.__2.7...__H.,___.B.ig._.SP_r.ing__.Av.e__....._ I"'- Ci~~;Jti1e, PA 17241 - . Total Postage & Fees $ 4.64 -<<_._--_.-~-~--_.~_._~-,.-.~---.~.._.+---~.-. ,OF PENNSYLVANIA J,/!ON PLEAS NOTICE OF APPEAL FROM DISTRICT JUSTICE JUDGMENT A District, County Of Cumberl COMMON PLEAS No. NOTICE OF APPEAL C~vil . ~ . is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on /<late and in the case referenced below. 2)6 Richland Road DATE OF JUDGMENT I IN THE CASE OF (Plaintiff) October 13. 2006 I Thoma s J. Jones DOCKET No. MAG. DI5T. NO. 09-3.02 CITY Carlisle NAME OF D.J. Vi via!: ZIP CODE 1 7 () 1. :': (Defendant)" G'eor.' Lr-'r~e ..:1 vs . 6t:::. ;.~) L\o;;.. , 'u- SIGNATURE OF APPELLANT OR ATTORNEY OR AGENT CV-1II-06 ~r This block will be signed ONLY when this notation is required under Pa. If appellant was Claimant (see Pa. R.C.P.D.J. No. 1001(6) in action R.C.P.D.J. No. 10088. This Notice of Appeal, when received by the District Justice, will operate as a before a District Justice, A COMPLAINT MUST BE FILED within twenty SUPERSEDEAS to the judgment for possession in this case. (20) days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONL Y when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be seNed upon appellee. PRAECIPE: To Prothonotary Enterrule upon Thomas J. J oqes' Name of appellee(s) appellee(s), to file a complaint in this appeal (Common Pleas No. 06- 6284 Ci vi D within twenty (20) days after service of rule or suffer entry of judgment of non pros. ,/: _, .:/ ~t Signature of appellant or attorney or agent RULE: To Thomas J. Jones Name of appellea(s) , appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by. pers~)l).~1 service or by certified or registered mail. ,. (2) If you. do not:file a,compl2,l!nt within this time, a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU. (3) The da.~e of service of this rule' if $~ice was by mail is the date of the mailing. 0". ..1.1 t ~notary or DiJPint Date: Oct:~: 27 " ,.~2006 '< YOU Ml:JSTINCLU~A COPY:QF.tHE NOTICE OF JUDGMENTITRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. AOPC 312-02 WHITE - COURT FILE TO BE FILED WITH PROTHONOTARY GREEN - COURT FILE YELLOW - APPELLANT'S COpy PINK - COPY TO BE SERVED ON APPELLEE GOLD - COPY TO BE SERVED ON DISTRICT JUSTICE " . t:? - Com l/... 4-1A-/ I MIl AVlT- @ Commonwe~llth of Pennsylvania Court of Common Pleas County of Cumberland Common Pleas No 06-6284 November 14,2006 Plaintiff. Thomas J. Jones 2989 Enola Road Carlisle, PA 17015 against Defendant. George Sneed 256 Richland Road Carlisle, PA 17013 On March 27. 2006 and March 28, 2006 I, Thomas J. Jones, transported 2 full colonies of honeybees to the residence of the defendant to pollinate his orchard. On June 5, 2006 I removed the 2 full colonies of honeybees from the premises having satisfied the defendants pollination needs. On June 6, 2006 I mailed the defendant my invoice #36246-10 in the amount of$64.oo. On July 17, 2006 I mailed the defendant my overdue notice of monies owed. The last week of July I received a check from the defendant in the amount of $32.00. On August 11,2006 I mailed the defendant a registered letter with his uncashed check #2694 explaining my invoice of June 6, 2006. After giving the defendant ample time to respond, on August 30, 2006 I filed a Civil Complaint #CV-OOOO111-06 at Magistrate District # 09-3-02,The Honorable Vivian Cohick presiding. A hearing was held on September 12, 2006 and on September 13,2006 a total judgment in the amount of $160.66 was entered against the defendant. en'em1 ~~ are true and accu t. ~!Y\ COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DAWN M. SHUGHART, Notary Public 80m of COI1Isle, Cumbel1and COunty My ComrrllUlon ElCPIre..!,,~. 28, 2006 f. ,~ : .: ,; f. /-'. :';', )1(: ,~' ~ to! ~ :t ;. /! .i,', .:ro" .j \ '\', ',J? .::{, f~' ,~ i;; .1 ','; .d1 -""", j.... I ' A , ~ ~ '"-', ., ,:.-t: 1/."":4 ~: ~:-:> "'-:> , ,=;' ~~ ~ c~: ~:::; -/1 --I 'y ri1 f7J -'0 ('r": ::? ,C..: -:-,rL:. c.r; 'R' !~ht :B ..,.::: .. , ........4J -t::- . COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUllBDI.UIJ) Mag. Dis!. No.: 09-3-02 MDJ Name: Hen. VIVID COBICX Address: PO BOX 155 27 W Bla SPRI.a AVE _VILLa, PI. Telephone: (717) 776-3187 17241 aBORaB SBI5lW 256 RIMIT.:IUIJ) ROAD CARLISLB, PA 17013 THIS IS TO NOTIFY YOU THAT: Judgment: I'OR PLADr.l"II'P ~ Judgment was entered for: (Name) ~ Judgment was entered against: (Name) in the amount of $ 160. 'ti D Defendants are jointly and severally liable. D Damages will be assessed on Date & Time D This case dismissed without prejudice. NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rJoBBS, TBODS J. 2989 BROLA ROAD TBB HAPPy BBBBBPD. ~ISLB, PA 17013 VS. DEFENDANT: NAME and ADDRESS fiBBED, aBORGB 256 RI('1IT.:IUIJ) ROAD CARLISLB, PA 17013 L Docket No.: CV-0000111-06 Date Filed: 8/30/06 -, -.J -, -.J 10/13/06 (Date of Judgment) JODS, TBODS J. SDBD, (DORGB Amount of Judgment $ 69.03 Judgment Costs $ 91.63 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 160.66 Post Judgment Credits $ Post Judgment Costs $ ----------- ----------- Certified Judgment Total $ D Amount of Judgment Subject to Attachment/42 Pa.C.S. 98127 $ D Portion of Judgment for physical damages arising out of residential lease $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARYICLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. /0 13 6b Date , Magisterial District Judge I certify that this is a true and correct copy of t record of the proceedings containing the judgment. Date , Magisterial District Judge My commission expires first Monday of January, 2012 AOPC 315-06 DAD PRIlft'ED: 10/13/06 SEAL 4:29:00 PH t' Ol-\WEAL TH 0." PENN'S",! l': CoyJN '* 'tN4 COUNTY OF CUMBERLAND ('OOKf TOW"StlU' [)Jni.l~SO~ 'mwlI;smp '4I'WVIl.l.F. ROItOlIQ'i "ORTII ~Ewm~ 'IOW'IISflIP sOt, TII SI,WIOt\ TO~SltIP rt.:l\" T()~"&III" wlS, Pl;~~sOOJ<<) TOWNSH'P Vivian J. Co..ck MAGISTERIAl. DISTRICT JUDGE Magisterial D1.tritt 09-3.02 J7 W. Bil SprinK Avenue P. O. BOI 155 ~flnille. PA 17141 OFF IC' F.: "lEL 71i.77C'>-:l11l7 M,X 7J'1-77C'>.lt;!ll~ October 13. 2006 Opinion on CV -1 I 1..()6 I believe this is a case of lack of communication between two gentlemen based on a history of working together. Because a price was never discussed or agreed upon. the full amount ofS64.00 plu... postage tC:lr collection in the amount of $5.03 is due. In addition, the filing cost in the amount of S60.()() and because the certified mail was not accepted. the additional (,,'onstablc tee ofS31.63. Total judgment is fi>r $160.66. I /\ ~'t(J.'- ~ G-r:. I ~.k~ :{ "./.!;'; o c ~ t-..) C'::> ,= '0"> 25 ....;::;: v""l f ,~ ~~.'" I LJ .,:;'" -, ) :< THOMAS J. JONES, trading and doing business as THE HAPPY BEEKEEPER, Plaintiff v. GEORGE SNEED, Defendant TO: Curtis R. Long, Prothonotary : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : NO. 06-6284 CIVIL TERM PRAECIPE Please enter the appearance of Joseph A. Layman, Jr., Esquire, on behalf of Plaintiff in the above-captioned matter, and please mark the docket "Settled and Discontinued" with prejudice. Neither party claims costs against the other. Date: December /.3 , 2006 J eph A. Laym , r., Esq . e Supreme Court No. 21229 200 North Third Street, 13th Floor Harrisburg, Pennsylvania 17101 Telephone: 717-234-5350 Attorney for Plaintiff aJ~ r~ Wayne . Shade, Esquire Supreme Court No. 15219 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Defendant o c ~. ~ .:~ r-) C::) c:=> cf" o f"!1 c-> , ?; ~ j;"" ~ :t-n n'~ -o~ ~~4 ~l ~l;~~ ~--\ 55 ~ ~ ::; - - 0' .x:-