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HomeMy WebLinkAbout02-4084(Petitioner) Christine R. Strouse VS. (Respondent) John T. Olscwa Jr. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : ACTION IN EQUITY : NO. 0,~-~ qO~'/t/ NOTICE TO DEFEND TO THE RESPONDENTS NAMED HEREIN: You have been sued in Court. If you wish to defend against the ctaims set forth in the following pages, you must take action within twenty (20) days after this Petition 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 Petition or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other fights 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. Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 (717)249-3166 Le han demandado a usted enla corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partie de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objectones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, las 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. (Petitioner) VS. (Respondent) Christine R. Strouse John T. Olscwa Jr. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : ACTION IN EQUITY : NO. ]petition to Obtain Title of an Abandon Vehicle (State the Facts of the case) On December 15, 2000, I lent John T. Olscwa Jr. $3500 with which to purchase the 1988 Chevrolet Beretta, VIN #1G1LV11W4JY563863, of which I am now petitioning the court to obtain title. He was my boyfriend, and he lived with me at the time. This loan was under an oral agreement between John and me that he would repay me the entire $3500, interest-free, as he could. He estimated that he would be able to repay me at least $100 per month, and I accepted this repayment schedule. In accordance with these terms, we put the vehicle title in his name with me as First Lienholder. Our agreement was that when l~e had repaid me in full the $3500, I would sign off the title and he would own the car free and clear. I am in possession of this vehicle title. He then obtained a job, used the car, and spent his money drinking in bars without me and going to dinner at expensive restaurants and to concerts with friends for the next year and five months, rather than repay me. In November, 2001, he struck a guardrail, causing damage to the passenger side front bumper cover, fender, door, and quarter panel; the repair estimates for which averaged approximately $1400. At several times throughout this period, I asked for at least one payment on the principal loan and threatened to repossess the car, but he never paid me anything for it. On May 16, 2002, I came home from work to find that he and all his possessions were gone from my residence. The next day, he called me and told me he had packed all his things in the Beretta, driven it to Florida, and was staying temporarily with his grandmother near Tampa. He never repaired the $1400 body damage nor paid me one cent toward the original $3500 principal loan for the car. In recent conversations with John, he has agreed to the above facts, admitted that the car should be mine, and indicated that he will give it to me ifI travel to Florida and obtain it. I am petitioning the court for an order to first transfer the title from his name to mine, so that I may then legally demand possession of the car, in case he changes his mind about relinquishing it to me after I travel to Florida--- action that would be characteristic of his past behavior. I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. - PlaintifI' CHRISTINE R. STROUSE, PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN T. OLSCWA, JR. RESPONDENT AND NOW, this entry of an order on the within petition, IS DENIED? Edgar B. Bayley(~. · 02-4084 EQUITY ORDER OF COURT day of September, 2002, the request for the C.R. Strouse, Pro se 852 Louise Ct. Enola, PA 17015-1506 ~ A lawsuit in equity must be started by a complaint, not a petition. Pa. Rule of Civil Procedure 1501. The complaint must then be served with the cause of action thereafter to proceed in accordance with the rules relating to a civil action.