HomeMy WebLinkAbout95-05355
JAMES P. SHEPPARD,
Plaintiff
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
fi5- 5355 6i4~
VS.
MARY JANE GROSS,
De fendant
NO. -1995
CIVIL ACTION - LAW
NOTICE '1'0 DEFEND
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 appeardnce 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 80, 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.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17012
(717) 240-6200
JAMES P. SHEPPARD,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
1
1
1
I
1
1
1
NO.
- 1995
MARY JANE OROSS,
Defendant
CIVIL ACTION - LAW
COMPLAINT
1. Plaintiff is James P. Sheppard, an adult individual, and a
practicing attorney with a law office located at 2037 North Second
Street, Harrisburg, Pennsylvania, 17102.
2. Defendant is Mary Jane Gross, an adult individual residing
at 941 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania,
17043.
3. Defendant retained Plaintiff to represent her in a divorce
case filed of record in Cumberland County at No. l336-C-1993 on
June 4, 1993.
4. Plaintiff properly represented Defendant in the afore-
mentioned divorce case and secured a favorable result for the
Defendant in her divorce case.
5. Plaintiff secured all of the equity in the marital home at
941 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania, for
the Defendant in her divorce action. Plaintiff secured the deed to
the said marital home on behalf of the Defendant and filed the deed
upon Defendant's promise to pay Plaintiff for attorney services
rendered from a home equity loan against the property. Defendant
received the proceeds of the home equity loan but failed and
refused to pay Plaintiff for services from the proceeds as
promised.
6. Plaintiff's attorney's fees as of the date of this action
total $2,520.57. Plaintiff has charged late fees in and interest
normally charges by his law office. The late fee balance and
interest as of the date of the filing of this Complaint are $66.75
and $110.29, respectively.
7. Plaintiff has demanded that Defendant pay for services
rendered and late fees and interest charged in this matter.
Defendant has paid six (6) $50.00 payments since February, 1994.
Plaintiff has credited those payments against the attorney's fees,
late charges and interest on Defendant's account.
S. Plaintiff has demanded that Defendant pay the total amount
owed to Plaintiff of attorney's fees, late charges and interest.
Defendant has refused and failed to pay the monies owed to
Plaintiff.
9. Defendant is not a member of the Armed Forces of the
United States of America, nor is she engaged in any way which would
bring her within the Soldiers and Sailors Relief Act of 1940, as
amended.
WHEREFORE, Plaintiff requests entry of judgment against the
Defendant in the amount of $2,697.6l, plus costs of this action,
plus fifteen (15') percont por annum interest from October 9, 1995.
Respectfully submitted,
s .
North Secon reet
Harrisburg, PA 17102
(717) 232-5551
VERIFICATION
I, James P. Sheppard, hereby state, subject to the penalties
of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities, that the averments contained in the foregoing
Complaint are true and correct to the best of my knowledge,
information and belief.
Datel
~~/fs-
JAMES P. SIIEPPAlm.
Ill.AINTIFF
IN TIlE COURT OF COMMON PLEAS
CIIMHERI.AND COUNTY. PENNSSYI.V AN II
YS.
MARY JANE GROSS
Defendant
NO. 9.')'-S ~.))- -1995
CIVIL ACTION - LAW
\1ruSLv~R 10 COMPLAINT
1. Agree
2. Agree
3. Agree
4. Disagree;
Although the Plaintifl'did secure marital property for the Defendant,
the Plaintiff has failed to notify Defcndant of the finalization of her
divorce proceedings. Furthermore, the Plnintill'has failed to produce
an itemized bill for the time incurred. despite repeated requcst on the
part ofthll Defendant.
5. Disagrcu
6. Disagree
7. Disagree
8. Disagree
9. Agree
Respectfully Submitted
\\~~~~,J
Mary Jane Gross
941 Humlllcl Avellull
Lemoynll. PA 17043
(717) 737-1711
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