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Home My WebLink About95-06689 '>- ~ - ~ . -7 o , ~ ~ € p! J '0- 00 '--' ~ equipment in that the plaintiff never proved ownership and Plaintiffs never secured a landlords waiver from Defendants. The Defendants believe they are entitled to be compensated for storinQ the equipment, if it is PlaintiffFl' equipment, for a period in excess of seven months, during which period no one contacted the Defendants WHEREFORE, the Defendants pray this Court: 1. Order the plaintiff to prove ownership of said equipment. 2. compensate the Defendants at the rate of $350 per month for each month that the equipment was left at the Defendants' premises. COUNTERCLAIM 10. All allegations of the Defendants Answer are incorporated herein by reference. 11. The Defendants believe that the plaintiff acted negligentlY and wrongfully if they in fact were owners of said equipment in not pursuing or checking up on its whereabouts for a period in excess of seven months. 12. The Defendant had to pay mortgage payments, interest, real estate taxes and insurance on the building in which the equipment was kept. all at their expense, and as such provided a substantial benefit to the Plaintiff if they are in fact determined to be owners of said equipment. 13. The Defendants bel ieve and aver they should be compensated at the rate of equipment from November 1, $350 1995 per month for storing said until the court makes a i':; I.D '- -'" f:-: j"": i~ ~:')..~ n .. ,~.. ( ) '.1 \.J: , r-' ... ,'- , i ('. (J(' <=> ....;..\ (~l ' . ; IJI (~-., L!t: ' ....... .j , , ~ 1.. i -., I' ,':) :....1 '-' Co' U ~f " .v~ ...,....... WI 00 HUU' CUTlfY THAT ntl WITHIN ......t.UIE AN. CO..leTCO" 0' THC.OIl191""'" ,aLtO I~N .fHII AcrION. . .. BY tl~Wol? 1 DOUGLAS. DOUGLAS & DOUGLAS 'fOU AU "(lfU ,UOUllIlO TO 'ILl A ".nn" Il[SPOHU 10 fU' (tICLOun "IfIUM 1"t1ll:"" 1101 pA"1 '11014 Utl.,lct .tI1IttO, 011 A JUDGMtNT .,..., .[ ~,.t"IO"'Il"If"". 'WOU. ., ---. ...--..-. "tfCRHIt ATTOItI~E':; I'T LAW ","w "'''~.i'''''r'' to. 0 fll)' ~.". GEOI{GE F. DOUGLAS, III, ESQUIRE ATTOI{NEY I.D. # 61HH6 DOUGLAS, DOUGLAS & DOUGLAS 27 West High St. P.O. Box 261 Carlisle, Pa. 17013 Telephone: 717-243-1790 Attorney for Plaintiff MARIE MAGARO, IN THE COURT OF COMt-"ION PLEAS ADMINISTRATRIX, CTA, OF THE ESTATE OF DAVID W, MAGARO OF CU1\IBERLAND COUNTY, PENNA, YS. ALAN W. BAILEY and DONNA j, BAILEY, his wife CIVIL ACTION LAW ACTION IN REPLEVIN NO. NOTICE You have been sued in Court. If you wish to defend against the class 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 attorne)' 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 YOl: by the Court without further notice for any money claimed in complaint or for any other claim or relief requested by the plaintiff. You may luse money or pruperty or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYEl{ AT ONCE, IF YOU DO NOT HAVE A LA \ "YER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTI-I BELOW TO FIND our WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor Cumberland County COl1l't I-louse I Court House Square Carlisle, Pa. 17013 717-240-6200 DOUGLAS, DOUGLAS & DOUGLAS k-V.rI ( tk\I~\~/:. 'l( GEORGEI'. DOUG LA. , III, ESQUIRE Attorne)' for Plaintiff c:m,II'I,AINT COUNT I . REPLEVIN \. The plaintiff, Marie Magaro, Administratrix, c:r.A. of the Estate of David W. Magro, is the sole owner of Variety Amuselllcnts which is authorized to do business in the Commonwealth of Pennsylvania, and has its principal place of busines located at 116 E. Allen St., Mechanicsburg, Cumberland County, Penna. 17055. 2. The defcndants, Alan W. Bailey and Donna J. Bailcy, are husband and wifc, and they rcside together at 2700 Sheridan Road, York, l'a. 17.\02. 3. The defendants leased a building they owncd at 6 Silver Drive in Mechanicsburg, Pa., to Bobby Green and Dennis Burd, hcreinafter referrcd to as tenants. .\. The tenants contactcd Variet\' Amusements and requested various game machines be placcd in thc building, which they were leasing, and which was known as Decibels, and was located at the said 6 Silver Drive, Mechancisburg, I'a. 5, The plaintiff owns and is cntitled to the immediatc posscssion of the following personal property: a. Three pool tablcs @$1,000 b. Two pinball machines: 0) Terminator (2) Legal Wcapon c. Five vidco games: (1) Namc Cosplallcr (2) Final Blow !-louse (3) Ivlortal Combat (4) Williams NBA Jam (5) Atari Warriors d. Row BC 100 Change Machinc TOTAL $3,000.00 $1,500,00 $1,500.00 $1,101l.0D $1,100.00 $1,10D.00 $1,100.00 $1, 100.00 $ 500.00 $12,000,00 6. The value of the said propcrty is $12,000.00. 7. Defendant has wrongfully detaincd the said property since approximately July 15, 1995, and still wrongfully detains said property at 6 Silver Drive, Mechanicsburg, Pa. 8. On July 27, 1995, plaintiff dcmanded in writing that defendant return said property to plaintiff. but defcndant refused and still refuses to EASTERN DISTRIBUTORS CO. 500 NORTH 12th 5 TR~ PHILADELPHIA, ~12J TElE. (215) 627-1000 INVOICE NO. t.-2blQ31I)l INVOICE INVOICE OAT E 0'1/20/'l1 SOLD TO VAI1IF.TY al<115F."EfIT'l SHIP TO VARIETY A~U9F~FNTS . \ lib r:AST ^LLF.~I :IIO:CIU ~I T C ~P llPr. I'AVE "Ar.~l1n ST. flA 17(\~5 lib FA5T nLr::N MECHAfITr.5fl\lFlr. nAVE I~Ar.AFlC1 ST. Ph 170S~ .1 CUSTOMER' SHIPPING DATI TERMS SHIP VIA ORDER NO. OROIlA DA T8 SLBIQ .' 28'l000 0'111'1/'11 IIn 30 I'AY5 ""11 nFL 87Ub3 00/20/'11 01 -. SPECIAlIHSTnUCTIOHS: I\/L#120bS2 - ITEM NO. DESCRIPTION QTY,ORO. aTY. SHIPPED DTY.OK.ORD. UNIT PRICE EXTENSION . /1350 PAPTY 7.(1(.1E PI" 1 I 0 2buO.00 2/,uo.001 N ~UOOqO u<,12 TEq~1J fiA Ton TJ PT'" 1 1 0 ;>703.nO ?70J.00 N 77':1'171 /- ,,.." . (J( .._--~ /' ) . ~Df., 1 rd' ( \ I '2 <(, '. , , ~~ . ..----/ / ---- - - SALES TOTAL SALEST/JIJ( FREIGHT 53Q3.00 331.oFj 11l0.Gn PAY THIS AMoum +- SAI-11.lle E, P. A DIVISION OF EASTERN MUSIC SYSrEMS CORP. " " pV>.ltnlff'S E)l.\"\\B\l \A , . NOTICE TO PAY RENT OR QUIT .' mbd/JtlpJ "'-:;1('" TM lkc.,.j,~b . reNANTlNPOSSBSSlON: . . You atO bcrcby notllled th~ the renl illIOw dueBDd payable on tbc~rcmlsllS now held an oceup1ecl by you. befog ~oio premlac:llituJfed in tho City or. dlfl ,Xed,,,.. c; / ~..ltJ(^ !fl';~~ ;';f. Countyof' C t1. ~lB L-,fitatoof p~(Cm",!w\y knOwn as 7 . C.,'/IIf'~ YJL..~-:: ~.J"cst-,lAg~ (J/J I7D5S". YourBCCOUD1lsd~tlnthclllllo~oCS5alO.oO .!'dPatheren1tbrthe I I ) periodfrom .JJ.j..J.19tf. 10 1~/?'1/9'J. (U~ ,.4S1JD I<:l. If 1'1 N tete c1wpur1:l due in tho amount on . g DO, 00 , You ~ bllrcby l'Clluired to pay AId rem III tiII1 within.:....5- daya. Your flllIure to do to win JnOlII1 thai lcgaI procecdblSS will be lnsIituted '8l""1It you to tllllOVer posse:asion of aid premlo.. to dedaro the' fori'cIiure of tho Leuo or Rental ~ under which you occupy said premises and to recover rents and d8'1'~gt'I. together with court coBt4 sad attorney'. f'eoI!, ICCOI'dIns to the terma of your Loue or Rental A8feemcnt. Datedthe ~~T? dayof I :e t'~ 19 91. .I PROOF OF SERVICE I, tho undenignod, be\D8 at IClIISt 18 YIllI[IJ of 180, dOCllarc'undcr peaa1ty orpDfjury that I Iel'Ved the Notlco to Pay Rent'orQult. ofwhldl this is a true copy, OIl the aboVl)o . mClltlonod TIIIInt Iu POues&on in tho "'.lmI!I'(a) Indicted below: 011 /~ /;1 '.19.tL, ihandcd theNotiootothetCllallt. 1 handed the'Natice to a person ofsultable ago and discretion at tho 1.cIIWlt'a 1"llS~lIslnuaon .19_, . 1 posted thO,ljotlce In a c:onspiaJ,01JS place at the tenant'. resld~ on 1~3 . 19..zL., Bxllcuted aD /;)/13 -1-1 J-fy , 191L. at Itv;cshu..<. .. ~ J4j PA. ..;; 11180( DEFENDANT' . , EXHIBIT 8 _ J. ;~~ "k.i....~..... o~oz ....Il;ouoo( &i.t=:n> '.-' , ot-:.I:-' . 0..>- Ca:-IU) .~...",,,, ,c:w~ffi ,.' 1=:0:"- , => ~u ,,,,,,'\-' .."U' ~.,. :~;{<, ._" r ~ :,'-, .~:~,~ "'-:~:::~:: '~','" ?:._~::';.-'>~ .i"', _.",h,;>. .... "i. .',,', .J " ~, " ;.,,^ .,t~~-~~; . \ ,~' .rl :f ~~ 0: -n ~ ~ 'X~ Q. 9 0 "! 0 Ot.) ~ "-' YOU "I HnUt IUQUIIIO TO 'IU A WIllnUt IIU,OHSl TO IHr. IHCLOSlD WITHIN '''I"T't (101 DAYS '1011II .ElVler: ..[.to' 01 A JUOQN[HY ..At I[ :-!!~~..t.. ~Q"I"IT YOU. " ~._-~-~. ...tfOIlNn o V) I' ~ ~ l, I"'Il C"6 N) ~ ~ 0- C N ~ '::!I~ ~cL '<: " " . " DOUGLAS, DOUGLAS & DOUGLAS ATTonHCYS "'1' LAW WE DO HUUT cUTIn THAT THI WITHIN II A TJlUI AND co..tct CO" 0' THI OIlIGINAL ,.IUD IN 'HII ACTION. ~. ," "' ".,. "'QH .,"'[(1 .,.,.1.. 1-0.'14' GEORGE F. DOUGLAS, Ill, ESQUIRE A'rrORNEY \.D, # 61HH6 DOUGLAS, DOUGLAS & DOUGLAS 27 West High St. 1',0. Box 261 Carlisle, Pa. 17013 Telephone: 717-243.1790 Attorney for Plaintiff MARIE MAGARO, IN THE COURT OF COMMON PLEAS ADMINISTRATRIX, c:r,A., OF THE ESTATE OF DAVID W, " , MAGARO OF CUMBERLAND COUNTY, PENNA, VS, ALAN W, BAILEY and DONNA J, BAILEY, his wife CIVIL ACTION LAW ACTION IN REPLEVIN , 'll.-.- NO. 9,t- {.. (., P9 elL'1 l't""", NOTICE You have been sued in Court. If you wish to defend against the class 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 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 Fourth Floor Cumberland County Court House I Court House Square Carlisle, Pa, 17013 717-240.6200 DOUGLAS, DOUGLAS & DOUGLAS C\ ? / :)~_ (nC \ Q/l- L"'_ EORGE 1', DOUGLA ,III, ESQUIRE Attorney for Plaintiff . GEORGE F. DOUGLAS, III, ESQUIRE A'ITORNEY 1.1). # 61H86 DOUGLAS, DOUGLAS & DOUGLAS 27 West High St. P.O. Box 261 Carlisle, Pa, 17013 Telephone: 717-243.1790 Attorney for Plaintiff 0'- ., "'(f.t. .-. ,~, :: . r ~:.' I. , ,t. :~ :; ~;' ~ , ,--, "'-. '. J ~';-, '11 :; -. -,:-"';J .r.: ~ -- ~- ... ".' ." . , h' " r. ., , :"i_~~ . ::;; MARIE MAGARO, IN THE COURT OF C01..tMON PLEAS ADMINISTRATRIX, CTA, OF THE ESTATE OF DAVID W. MAGARO OF CUt\II3ERLAND COUNTY, PENNA. VS. ALAN W. BAILEY and DONNA J. BAILEY, his wife CIVIL ACTION LAW ACTION IN REPLEVIN NO, 95 - ~(, ~ <j C,:"..J. ::rJ-Nr- NOTICE You have bccn sued in Court. If you wish to defend against the class set forth in the following pages, you must lake action within twenty (20) days after this complaint and notice are scrved, b)' entering a written appearance personally or by attorncy and filing in writing with the Court your defenscs or objections to the claims sct forth against you. You arc warncd that if you fail to do so, the case may proceed without YllU and a judgment may be entered against you by the Court without further notice for any money claimed in complaint or for any other claim or relief requestcd by the plaintiff. You may lose money or propcrty 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 OFHCE SET FORTI ( BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELl'. Court Administrator Fourth Floor Cumberland County Court I-louse I Court House Square Carlisle, Pa. 17013 717.240-6200 TRU::: CO?y rHOI'A f, ~..\ ,; ';"J In Tostimonywhcfhr,f I ~'_'!t' C:i .'", Il," ;:,,1 .lId the sl<dl or ,;;,id C:lJ'i ;" I, ."",':1" , rhis .:'J"- ittJ. day 01..'], /J.l.":' , ;; ;.;:;- ~ /') ./2__ , .- (, -q ~('11'!~--- l" . f).,,..~. . . 'J" r 101.' . ,.";1I"J DOUGLAS, DOUGLAS & DOUGLAS ':"\ 'i /' ../~'l.l'" '/. ( (J~~\J ~ J /: .U..... ,EORGE F. DOUGLA., III. ESQUmE Atlonll'Y for Plaintiff . COI\IPI.AINT COUNT I . REPLEVIN 1. The plaintiff, Marie t\lagal'O, Administratrix, CT.A, of the Estate of David W, Mallro, is the sole owner of Variety Amu~ements which is authorized to do business in the Commonwealth of Pennsylvania, and has its principal place of busines located at 116 E. Allen St., t\lechanicsburg, Cumberland County, Penna, 17055. 2, The defendants, Alan W. Bailey and Donna J. Bailey, are husband and wife, and they reside together at 2700 Sheridan Road, York, Pa. 17402. 3. The defendants leased a buildinll the)' owned at 6 Silver Drive in Mechanicsburg, Pa" to Bobby Green and Dennis Burd, hereinafter referred to as tenants. 4. The tenants contacted Variety Amusements and requested various lIame machines be placed in the building, which they were leasing, and which was known as Decibels, and \\'as located at the said 6 Silver Drive, Mechancisburg, Pa. 5. The pl.lintiff owns and is entitled tu the immediate posscssion of the following personal property: o. c-:.. ~ ~, - c. ,...., a. Three pool tables @5I,OOO b. Two pinball machines: (I) Terminator (2) Legal Weapon c. Fiw video games: (I) Name Cosplattcr (2) Final Blow I-louse (3) Mortal Combat (4) Williams NBA Jam (5) Atari Warriors d. Row Be 100 Change f\.lachine TOTAL $3,000.0(};::. .' $1,500.00/ '~ v- $1,500.01,)":: ': ~ ~ = " :'~ L.O <.n $1,100.00 $1, lOO,OO $1,100.00 $1,100.00 $ I, lOO.OO $ 500.00 $12,000.00 6. The value of the said property is $12,1l0li.00. 7, Defendant has wl'llngfully detained the said propert)' since approximately July 15,1995, and stillll'rongfully detains said property at (, Silver Drive, t'vlechanicsburg, l'a, H. On July 27, 19lJ5, plaintiff dcmanded inll'riting that defendant return said propl'l'ty to plaintiff, but defendant refusl'd and still refuses to 11'0.110'1 'YIN"^'....NNJ.. -:".".....:1 ",<lIla1f '0 .. fI .&,..... MOl" ..." MW'l !-'i .AJHWOUY 5.,'DnOO ~ 5.,'DnOO 'SI"DnOO ,;',,'Vi;,,:,<j 11..0"'. '_ ", '...~Fl- :"'~'!~'f .----._....11 -;.":,.--:~:/':\'~~7t.g:' 'nOA U"IW8V".lIj".i~';..'-'c:;';-;.~-, II n.. UtJ_tonr , 10 1IO.....:';~\":'t.''.: j':j}', 1:11.\11' ,,{..IU lAva .onAJiIIllU'luau.'"". '.::era QUO,,", )tU 01. U_Ot1UI MUll'. Ff,m, " 1'''' 01 GUlna.. AI.II'" ...,.0' p-l-?!\. .., .. ~.:_", '.t. .~/ . GEORGE F. DOUGLAS, 111, ESQUIl{f~ ATTOI{NEY 1.0. # 61HR6 DOUGLAS, DOUGLAS & DOUGLAS 27 West High St. P.O. Box 261 Carlisle, Pa. 17013 Telephone: 717-243.179ll Attorney for Plaintiff MARIE MAGARO, IN THE COURT OF COMMON PLEAS ADMINISTRATRIX, eTA, OF TI-IE ESTATE OF DAVID W. MAGARO OF CU~IBERLAND COUNTY, PENNA, \'5. ALAN W. BAILEY and DONNA J. BAILEY, his wife CIVIL ACTION LAW ACTION IN REPLEVIN NO. q 5' - Go (, t'( C.,."..<t T~........ DOUGLAS, DOUGl.AS & DOUGLAS ":'\ ? --- T:'iU~ COpy FROM RECO;~I.O.^" y " ( t I~~'.',)! 'L(. L'-_ 1:. ; o:,;:imony whereof. I here unto :;ot my hand .EORGI~ F. DOUGLAS, III. ESQUIRE ],' . :he sGaI of said Court at Carli~I:~. Pa. Alll1rney for Plaintiff ",~ --",:J ",,<lday oL~. 19 'I ~ ~~l ;J~~.~o:~;~'-' NOTICE You have been sued in Court. If you wish to defend against the class set forth in the following pages, you must take action within twenty (2ll) 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 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 I-fA VE A LAWYER OR CANNOT MFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WI-fERE YOU CAN GET LEGAL HELl'. Court Administrator Fourth 1'1001' Cumberland County Court House I Court (-Iollse Square Carlisle, Pa. 17013 717-240-6200 COt\IPLAINT COUNT I - REPI.EVIN 1. The plaintiff, Marie Magaro, Administratrix, c:r.A. of the Estate (If David W. Magro, is the sole owner of Variety Amusements which is authorized to do business in the Commolll\'eallh of Pennsylvania, and has its principal place of busines located at 116 E. Allen St., Mechanicsburg, Cumberland County, Penna. 17055. 2. The defendants, Alan W. Bailey and Donna J. Bailey, are husband and wife, and they reside together at 2700 Sheridan Road, York, Pa. 17402, 3. The defendants leased a building they owned at 6 Silver Drive in Mechanicsburg, Pa., to Bobby Green and Dennis Burd, hereinafter referred to as tenants, 4. The tenants contacted Variety Amusements and requested various game machines be placed in the buildin!;. which they were leasing, and which was known as Decibels, and was located at the s.lid C1 Silver Drive, Mechancisburg, Pa, 5. The plaintiff oll'ns and is entitled to the immedi.lte possession of thc following personal property: a. Thrce poollables @'$l,OOl1 $3,000.00 -- . - "" ~ b. Two pinball machines: ,- . r (I) Terminator $1,500.00 ,'. ''''LJ ~. ., (2) Legal Weapon $1,500.00 " ':.; ~. c. Five video games: I~..~' :~ ~ u' (1) . _.. .... Name Cosplaller $1, lOO.OO r,' .: ': --v (2) Final BIoII' I-louse $1,100.00 ~. ... = -l-J" (3) Mortal Combat $1,100.00 ' ~ u:> ..,., (4) Williams NBA Jam $1,100,00 (5) Atari Warriors $1,100.00 d, Row BC 100 Change Machine $ 500.00 TOTAL $12,000.00 6. The value of the said pl'llperty is $12.000.00. 7, Defendant has wrongfully detained the said property since approximately July 15, (995, and still w\'llngfully detains said property at 6 Silver Drive, Mechanicsburg, I'a. H. On July 27, 19l)5, plaintiff demanded in writing that defl'ndant return said property to plaintiff. but ddl'ndant rdusl'd and still refuses to ,,,,,IJ. Olll. UJ."'. "011+ .;. ,7 MY' .lY OUNWOUY UN'GU' ..._-~'..., '''a';<lt~I'.' bMq. " :II AlItl1 un.,enr w "'0. ~""IM IJlo\lIII' ..0., .na I'" UNlai ....U. GJV01'1U J~l ~, JlMO.'" ..",.up w J1U 01 a."nOJ. '.,.... I." IIOA s...,onoo '9 5'0'10000 '5...10noo ~~{f~~!~~;::C 'r ,c; ~.':~:~;' "f ~- ", \ ,';. ," /,'.'~ .<t" ~.L ;",:~,,'" "",'. -.'.:; .:. -., _m.r ., "it'- ,", A'.... tt-i'.',--: GEORGE F. DOUGLAS, III, ESQUllH~ ATTORNEY I.D. # 61HH6 DOUGLAS, DOUGLAS & DOUGLAS 27 West l'li~h St. 1'.0, Box 261 Carlisle, Pa. 171113 Telephone; 717-243-1790 Attorney for Plaintiff MARIE MAGARO, IN THE COURT OF COMMON PLEAS ADMINISTRATRIX, CTA, OF THE ESTATE OF DAVID \\'. MAGARO OF CUMBERLAND COUNTY, PENNA. V5. ALAN W, BAILEY and DONNA J. BAILEY, his wife CIVIL ACTION LAW ACTION IN REPLEVIN NO. NOTICE You have been sued in Court. If you wish to dcimd against the class set forth in the followin~ pages, you must take action within twenty (20) da)'s after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writin~ with the Court your defenses or objectiuns to the claims set forth against yuu. You are warned that if you fail to du so, the case may procced withuut yuu and a judgment may be entered against you by the Cuurt withuut further notice fur any money claimcd in complaint or for any other claim or relief requested by the plaintiff. You ma)' lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOU!{ LAWYER AT ONCE, IF YOU DO NOT I'IAVE 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 Administratur Fuurth Fluor Cumberland Cuunty Court House I Cuurt House Square Carlisle, Pa. 17013 717-240-6200 DOUGLAS, DOUGLAS & DOUGLAS ':\ 7 ___ L" 1': /. ( t I~"-".) : '1 /. _ l'- - , C,I:ORC,I: I.. DOUGLi\~, III, I:SQUIRI: Attorney for Plaintiff