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Home My WebLink About94-03042 1 I j J. <0 :::t- ~ j t( (SJ f'l: H n ..:1>0 P<t/l Z~ O~ ~P<_ o . U>O E-t t..Z OD o E-tU Z I>: 0 DO H S~ ~ ~I>: :t:~ ..:I E-t ~ .~ ZDOH HUZU -::r en - ~ ::>::: c_ N '::> C--.) -~ ;:; .~:;. r? :r. => --, 2? I C!j - I) r;::j 1-rS I '~ .~ !~ I ~ -.,,:.) "" ,,~ \ - ~~ ~..;:) ~ . .:..0 ~....:.. ....... ...... . '""l- ~""" \:) .j ~ I'(") 1'\') ~ ~?J ~ lI-l +> Ii> lI-l ~ W-I1O .~ III Z -I ~ +> '0 CJ::l ~ E-t I- ... ~ ~ ~~~i~ ..~ Ql Z t/llll lI-l H 1>:.-1 Ql ~ nl~U ~P< .0 ~ ~ P< ~ UUl~i E-t 0 Z a: ~ . t/l U <l: W ~ ..:I . . ~J: t/l :> Cl H t: ~ D ~ U WI DO HEREBY CEATIN' THAT THE WITHIN II A TAUE AND COR. AECT COP\' OF THE ORIGINAL ALED tN THIS ACTION B' ATTORNEY . . LA..... OH.cf& ~ AN .....,. ..._ TO " ."In,,. ",1;0'",.. TO ~ ~1ftY If: DAYI'fM)W :W~~~NT ... MANCKE, WAGNF-R. HERSHEY & TULLY .~ ....-. ..' .. CURTIS L. MYERS, . . plaintiff . . : V. . . . . MARY G. STUM, . . Defendant . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.Q4- jo4~ ~J~ CIVIL ACTION - LAW KOTleB 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 rights important to you. 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. Court Administrator 4th Floor Cumberland County Courthouse Carlisle, PA 17013 717-240-6200 V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW CURTIS L. MYERS, plaintiff MARY G. STUM, Defendant COMPLAINT AND NOW, this 3rd day of June, 1994, comes Plaintiff curtis L. Myers by and through his attorney, John B. Mancke, Esquire, of Mancke, Wagner, Hershey & Tully, who respectfully represent: 1. curtis L. Myers is an adult individual residing at 9 Moordale Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant Mary G. stum is an adult individual residing at 1058 Alexander spring Road, carlisle, Cumberland County, Pennsylvania. 3. On October 12, 1990, defendant Mary stum entered into an agreement with CCNB Bank for the purchase of a 1979 New Moon Mobile Home and requested plaintiff curtis L. Myers to co-sign, with the express agreement that if Mary G. stum defaulted and curtis L. Myers was required to make any payment as a result of the loan of Mary G. stum with CCNB Bank, Mary Stum would be responsible to pay Curtis Myers any sum due and owing. 4. There is currently the sum of $10,560.79 which is due and owing, which has been paid by curtis L. Myers and now is due from Mary G. stum to Curtis L. Myers. . . 5. Further, the mobile home was damaged and it is estimated that there will be the sum of $2,670 charged in order to repair the trailer for damages to the trailer done by the defendant. See Exhibit "A" attached hereto and made a part hereof. 6. Further, defendant agreed to make payments pursuant to a promissory note dated January 28, 1993, which promissory note is attached hereto and made a part hereof as Exhibit "B". 7. Said defendant is in default of said loan in the amount of $1034. 8. Mary G. Stum agreed to pay the rent and taxes while living in the mobile home to Curtis Myers from August 1, 1990, at the rate of $135 per month. She has failed to pay the rental amount, for which there is $6,075 due and owing and failed to pay taxes in the amount of $328.06, which is due and owing. 9. In addition, plaintiff loaned to the defendant the sum of $1,325 for one-half cost of attempting to find the defendant's son, of which $1,325 is due and owing. 10. Defendant has borrowed a lawn mower from the plaintiff, which has never been returned, which has a value of $65. 11. In addition, as a result of failure to make payments as required, plaintiff has incurred constable costs in the sum of $64.40, for which defendant owes to the plaintiff. .' 12. Defendant refuses to make payment on the amounts that are due and owing to the plaintiff. WHEREFORE, plaintiff demands judgment against the defendant in the amount of $22,122.25, plus interest, costs and delay damages. Respectfully submitted, MANCKE, WAGNER, HERSHEY & TULLY By John Attorne I.D. No. 07212 2233 North Front street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff . . 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. section 4904, relating to unsworn falsification to authorities. -i5P )~:~ - .7 )~J Dated' ~,,)/1'l , . - , . . - , - t.... ~. .....- _.) ---.- A.. . , Quantity 118m Unit Cost Tolal / c. e~. '7:" .:c;.1~t' f /J-tJ . 0<:> ,'1-----.... jJ\ C,..,.-7 n._ 'l.f'. tJ ...:a 1(...7' .A.;,..,.... 1r'.-n.,.".....JJ-r- '>\A..'J L..._--Lf~_" J.,.....,r "} I.' ". 0'-' // ,.,.u-/'Ct.. P .......'T. /2...01/"'-'<1 .1 S. ..~..,. C'~., I " a:.t.<.d ii.~:.r.....L. Sn 6JJ. ,. , '1 ,<ao,vO ,,'..I--t....~_ - ('..I \...,..r~ ,~'l"..- . " L<--_e- --, .:J,)tJ. o,:) ,.,.J ~L..~~A -r' ;t;:.L~LN )'7-.5"0. 00 . w.~_tJ...w~ . ;;1.oo.Cu .' 't' ft.1tJ OD . Sub Total Tax .~ Name: u...-...::I Address: Authorized Signature J'l<.A.-f(.... . o SOUDER'S Plumbing, Heating & Electrical 9 Pennsylvania Avenue Newville, PA 17241 (717) 776-3536 c. -:;]1;' I ~ ::Z;'''::' -,~ ..., Exhibit "A" ~ Dale: l/ ~I <? t.J '& /~." t1 t; f Tolal PROM:ISSORY NOTE AND NO~I this ?R day of .Ta"""Q.,..Y , 1993, the Parties to this Promissory Note, CURTIS MYERS and MARY G. STUM, in consideration of the mutual covenants herein and intending to be legally bound hereby, agree as follows: 1. CURTIS MYERS is an adult individual residing at 9 'Moordale Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. MARY G. STUM, an adult individual, desires to borrow the sum of Two Thousand Dollars ($2,000.00) from CURTIS MYERS. 3. The two parties do hereby agree to the following terms of this loan: (a) CURTIS MYERS shall loan MARY G. STUM the sum of Two Thousand Dollars ($2,000.00) and she hereby acknowledges receipt of same; (b) MARY G. STUM shall pay back the loan at the rate of Ninety-four Dollars ($94.00) per month, payable on the fifteenth day of each month, for the period of twenty-four (24) months; and (c) the first payment is due no later than February 15, 1993. Exhibit "B" - . -"ml'lll~~~ti:.r~~~'!Wr""~~ ;..:....~,,~...";7~~.;f,~.~~~~~3.}::.~~~:;::.~ ~~"b~G'?]~~.r~'1.Q;:t~~;:;:..;~~1: . , . -:""t:r' .,............: ....:.:... .~. \ 'J;.tzl':.r..: ".'. ~., . _ _ ~'I(' r .}\ ~ ,O:-'~:;:_:-.'.\ " . :.~'. - - ......._.......'\". .,".........~:.:...-......_...... "'- PAGE TWO 4. This Promissory Note states the entire agreement reached between the parties hereto. IN WITNESS WHEREOF, the parties have executed and delivered this Promissory Note on the day and year first written above: /i ~~ .' a "~A~ ( ~a MYERS ~~~ MA Y ~TUM ~""''''''' .";""n,:o,'i'i:~!.......a,-""''''''''''\''i~~~''}~!Y:l:..t;w!i.' ~""~'''','' . ~-"I'.!:."t.l/:,"'r. \~(X" :1-~' ...-.... .~l.....J r;'t:'~.'" f . .... t....,' .........,"".~.' .1,.....- .... " . "~':'i""~'1 to ' - -.... ;.~ 'f:' ..' t:fT......J....r T~ .~.. '-l r:1Y. , ,. .. '.' ";"""'S'"'' o:.:!'",: ::.~~. '0' ~"'- ':'~ "" ~-:"t ~ . ,."'-,..,-...,." f, . ..,t.-.....'V~~..:-,'.... (,J..~~r.,\.1T...;it.'.:.~l ~.:',..t,.;:.. ."... ';' ~.?ir."l,~. .:~.....:..';.:':'f:.:.;. u: rl"','':-'~'~:';if.L;~': "'~"","'J\..'-;-, \....' '" ",I,,'W',:.. I,' '-. ...... ...' '" ';]I '" . " ;00..\.:.... $ . .." -~:.. 1,0'\0. . l',. ;!:..1.fG.j:?.t:"'J~.I.,;o.,;.,. ';,'~ <. t' ':',1.. .. ""'if,, CCM-lONWEALTH OF PENNSYLVANIA: COUNl'Y OF ctMBERLAND SHERIFF'S RE'IURN In The Court of Common Pleasl'of Cumberland County, Pennsylvania No. 94-3042 Civil Term Complaint in Civil Action Law and Notice Curits L. Myers VS Mary G. Stum Philip Baughman , ~IBlX~ Deputy Sheriff of Cunberland County, Pennsylvania, who being duly swom according to law, says, that he served the within Complaint in Civil Action Law and Notice upon Mary G. Stum . the defendant. at 11:00 o'clock A .M. ~ / EDST, on the , 1994 at 08 day of June lO~R Alexander Sorino Road. Carlisle . Cunber1and County, Pennsylvania, by handing to Mary G. Stum a true and attested copy of the Complaint in Civil Action Law and Notic~ and at the same time directing her attention to the contents thereof and the "Notice to Plead" endorsed thereon. Sheriff's Costs: Docketing Service Affidavit Surcharge So answers: 14.00 2.80 2.00 18.80 Pd. by Atty. 6-09-94 -r/~~""<:~~ R. Thanas Kline. Sheriff h by ~ Swom and subscribed to before me this 1'1 S< day of 9"'...... 19 9'1 A.D. g>-<t....... f2 1lW1..., ,.JI-~ . Prothonotary Deput Sheriff IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY BRANCH Curtis L. Myers Civil Division vs. No, 94-3042 Civil Term Mary G. Sturn SUGGESTION OF BANKRUPTCY To: Prothonotary Please note upon the record that Mary G. Sturn, the defendant in the above- captioned aetion, filed a Voluntary Petition in Bankruptcy with the United States Bankruptcy Court for the Middle District of Pennsylvania at Harrisburg, PA, on June 16, 1994, at 3:25 o'clock P,M" which petition was docketed to 1-94-01014. PURSUANT TO THE PROVISIONS OF 11 U.S.C, SECTION 362(A), AN AUTOMATIC STAY IS IN EFFECT FOR ALL PROCEEDINGS INVOLVING THE ABOVE-NAMED DEFENDANT(S). CERTIFICATE OF SERVICE I, Richard L. Bushman, Esquire, allorney for the above captioned defendant(s) in the bankruptcy proceeding before the United States Bankruptcy Court for the Middle District of Pennsylvania, do hereby certify that on the date set forth below I served the within "Suggestion of Bankruptcy" by depositing a copy of the same in the United States Mail, postage prepaid, at Spring Run, Pennsylvania, addressed to the parties or allorney's of record as follows: John B. Mancke Esq 2233 North Front Street Harrisburg P A 17110 Curtis Myers 9 Moonda carli~~ A Date: June 17, 1994 ,Bu man, Esquire 16767 ath Valley Road P,O, Box 51 Spring Run, P A 17262-0051 [717] 349-7657