HomeMy WebLinkAbout95-06834
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
GREGORY A. MYERS,
Plaintiff
MICHAEL WALL,
NO. 95-6834 Civil Term
Defendant
NOTICE
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 claims 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
Cumberland County Court House
4th Floor
Carlisle, PA 17013
Telephone: (717) 240-6200
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-6834 Civil Term
GREGORY A. MYERS,
Plaintiff
MICHAEL WALL,
Defendant
COMPLAINT
AND NOW comes Gregory A. Myers, the Plaintiff, and
by and throuqh his counsel, Bratic & Portko, files the within
Complaint against the Defendant above captioned, whereof the
following is a more complete statement.
1. Plaintiff, Gregory A. Myers, is an adult
individual residing at 181 Easy Road, Carlisle, Cumberland
County, Pennsylvania 17013.
2. Defendant, Michael Wall, is an adult individual
residing at 208 Mill street, Mt. Holly Springs, Cumberland
County, Pennsylvania 17065.
3. At all times relevant hereto, the parties were
5. As a result of this conversation concerning
Defendant's financial difficulties, Plaintiff offered to loan
mutual friends and shared a common interest in motorcycles
and motorcycle riding.
4. On or about August 5, 1993, Defendant related to
Plaintiff that Defendant would most likely have to sell his
Harley Davidson motorcycle because he was behind on his bills
and needed immediate cash.
Defendant monies so that Defendant would not have to sell his
motorcycle.
.
6. Defendant informed Plaintiff that he needed
$4,000 and that if Plaintiff loaned him this sum, Defendant
would repay the loan in full by December of 1993.
7. As a result of their mutual promises, on or about
August 5, 1993, Plaintiff loaned Defendant the cash sum of
$4,000.
B. In December of 1993, Plaintiff contacted Defendant
about repayment of the $4,000 loan; however, Defendant
indicated that he needed more time to repay this debt.
9. Contrary to the assurances, statements and
undertakings of the Defendant, Defendant has failed to repay
the $4,000 loan or any part thereof although Plaintiff has
repeatedly made demand for the same.
COUNT I - BREACH OF CONTRACT
10. Plaintiff hereby realleges each allegation of
paragraph 1 through 9 of this complaint as if they were set
forth herein.
11. In breach of his obligation to Plaintiff,
Defendant refused and continues to refuse to repay
the $4000 which Plaintiff loaned to him in August of 1993.
12. The conduct and activities of Defendant
described herein constitute a material breach of defendant's
promise to repay the monies by December of 1993, for which
breach Plaintiff is entitled to recover damages of $4,000.
WHEREFORE, Plaintiff demands judgment against Defendant
in the amount of $4,000, plus interest and costs of
-2-
.
proceedings.
COUNT II - MISREPRESENTATIONS, FRAUD AND DECEIT
13. Paragraphs 1 through 9 are incorporated herein
by reference as if fully set forth at length.
14. During the course of conversation between the
parties on or about August 5, 1993 regarding the loan
proceeds, Defendant made the following representations,
statements and undertakings:
a. That Defendant was suffering a financial
hardship due to lack of employment;
b. That Defendant needed to raise cash immediately
to pay his bills;
c. That without the loan from Plaintiff, Defendant
would have to sell his motorcycle;
d. That Defendant was expecting to receive funds
on or before December of 1993 of a sufficient
amount to repay to Plaintiff the entire loan
proceeds;
e. That Defendant would repay the monies no later
than December of 1993;
15. Each of said statements, representations and
undertakings was material to Plaintiff and Plaintiff agreed
to loan the sum of $4000 in reliance upon each of said
representations, statements and undertakings.
16. Each of the representations, statements and
undertakings set forth hereinabove proved to be false in that
-3-
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.
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Defendant engaged in the following conduct:
a. In December of 1993, Defendant refused to repay
the loan, claiming that he needed more time;
b. After a reasonable extension of time and
through 1994, Defendant continued to refuse to
pay, claiming that Plaintiff would get his
money but that he wanted Plaintiff "to sweat a
little" before being repaid;
c. Defendant now claims, as evidenced at the
hearing before the District Justice on
October 30, 1995, that Plaintiff never loaned
him $4,000.
17. At the time Defendant made the representations,
statements and undertakings to Plaintiff, the Defendant did
so knowing that said representations, statements and
undertakings were false and untrue and would not be honored
by Defendant.
18. Defendant made the representations, statements
and undertakings to Plaintiff in willful disregard to the
truthfulness thereof or Defendant's willingness to perform in
accordance therewith.
19. Defendant refused and continues to refuse to
repay the $4,000 or any part thereof.
20. The conduct, practices and activities of
Defendant described above constitute fraud and deceit, for
which Plaintiff is entitled to damages in the amount of
-4-
.
$4,000, in that Defendant made one or more untrue statements
of material fact, or failed to disclose one or more matters
of material fact, knowing the falsity thereof or the
misleading nature of said nondisclosure, and Plaintiff relied
thereon substantially to his detriment and damage in said
amount of $4,000.
WHEREFORE, Plaintiff demands judgment against Defendant
in the amount of $4,000, plus reasonable attorney's fees and
court costs and expenses herein incurred.
COUNT III - UNJUST ENRICHMENT
21. paragraphs 1 through 9 are incorporated herein by
reference as if fully set forth at length.
22. By reason of the failure of Defendant to repay to
Plaintiff the $4000 loaned to him on or about August 5, 1993,
Defendant has been and continues to be unjustly enriched to
the extent of such amount, plus lawful interest upon such
amount.
WHEREFORE, Plaintiff demands judgment against Defendant
as follows: in the amount of $4,000 plus interest at the
legal rate of interest from August 5, 1993 and costs of suit
as allowed by law.
Date: 12/8/9S-
Respectfully submitted,
~~C~~
Stephen K. Portko, Esquire #34538
101 South Route 15
Dillsburg, PA 17019
(717)432-9706
-5-
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-6834 civil Term
GREGORY A. MYERS,
Plaintiff
MICHAEL WALL,
Defendant
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the
foregoing Complaint was furnished by
postage prepaid, on the ~ day of
U.S. Mail, first
U>UoM-f..".......
class,
, 1995,
to:
Michael Wall
208 Mill Street
Mt. Holly Springs,
PA 17065
Date: /2./?1/C; S-
BRATIC 8. PORTKO
101 South Route 15
Dillsburg, PA 17019
(7171432-9706
BY:~C~~<.J
Stephe K. Portko
Attorney for Plaintiff
VERIFICATION
I, Gregory A. Myers , hereby acknowledge that I. am a
Plaintiff In the foregoing action; that I have read the foregoing
Canplaint and the facts stated therein
are true and correct to the best of my knowledge, Information and belief.
I understand that any false statements herein are made subject to penalties of
18 Pa, C.S. H904, relating to unsworn falsification to authorities.
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Da ted:
Decanber 8
, 1995
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GREGORY A. MYERS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v.
MICHAEL WALLS,
Defendant
: NO. 95-6834 CIVIL TERM
ANSWER
AND NOW, comes the Defendant, MICHAEL WALLS, by and through his allorney,
Taylor P. Andrews, Esquire, of Andrews & Johnson, and respectfully represents as follows in
answer to Plaintiff's Complaint:
1. Admilled.
2. It is admilled that the individual who has been served with this Complaint resides
at 208 Mills Street, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. By way of
further Answer, the Defendant's name is Michael Walls, not Michael Wall.
3. Denied.
4. Denied.
5. Denied.
6. Denied.
7. Denied.
8. Denied.
9. It is denied that Defendant made any assurances, statements or undertakings as
averred; it is denied that any payment from the Defendant to Plaintiff would be a repayment;
it is ad milled that Defendant has failed to pay $4,000.00 to Plaintiff; and it is ad milled that
Plaintiff has demanded payment form Defendant.
COUNT I - BREACH OF CONTRACT
10. Answers 1 through 9 are incorporated herein by reference.
11. It Is denied that Defendant had any obligation to Plaintiff, and It is also denied
that Plaintiff loaned Defendant $4,000.00.
12. Denied.
COUNT 11- MISREPRESENTATIONS. FRAUD AND DECEIT
13. Answers 1 through 9 hereof are incorporated herein by reference.
14. (a) Denied.
(b) Denied.
(c) Denied.
(d) Denied.
(e) Denied.
15. Denied.
16. Defendant denies that the alleged representations, statements, and
undertakings occurred. so Defendant also denies that such representations, statements
and undertakings proved to be false..
(a) Denied.
(b) Denied.
(c) Admitted.
17. Defendant's answer to paragraph 14 of this answer Is incorporated herein by
reference.
.
18. Defendant's answer to paragraph 14 of this answer is incorporated herein by
reference.
19. Defendant admits that he refuses to pay $4,000.00 to the Plaintiff. Defendant
denies that any such payment would be a repayment.
20. Defendant denies engaging in the conduct, practices, and activities averred by
the Plaintiff. Plaintiff's allegation that such conduct, practices, and activities constitute fraud
and deceit Is a conclusion of law requiring no answer. It is denied that Plaintiff relied upon
Defendant's conduct, practices and activities, because the Defendant denies having engaged
in the alleged conduct, practices, and activities.
COUNT III - UNIUST ENRICHMENT
21. Answers 1 through 9 of this answer are incorporated herein by reference.
22. Denied.
WHEREFORE, Defendant demands judgment against the Plaintiff.
Respectfully submilled,
ANDREWS & JOHNSON
By
T 10.;' P. Andrews, Esquire
1I0rhey for Defendant
7 W. Pomfret Street
Carlisle, PA 17013
(717) 243-0123
.
I verify that the statements made in the foregoing Answer are true and correct to the
best of my information and belief. I understand that the statements herein are made subject
to the penalties of Pa. C.S. S 4904, relating to unsworn falsification to authorities.
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GREGORY A. MYERS,
Plaintiff
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v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION. LAW
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MICHAEL WALLS,
Defendant
: NO. 95-6834 CIVIL TERM
CERTIFICATE OF SERVICE
I hereby certify that on this date,
/2 -27
, 1995, I served a certified
copy of Defendant's Answer to Plaintiff's Complaint, on Plaintiff's counsel of record by
sending a copy by U.S. Mail, postage prepaid, as follows:
Stephen K. Portko, Esq.
101 South Route 15
Dillsburg, PA 17019
Taylor P. Andrews, Esquire
Allorney for Defendant
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1701
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C_IALl" Of 'INH.lLVAHIA
COUlIT Of C_ ,UllS
NOTICE 0' APPEAL
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JUOtCW DlnllCT
DISTIlICT JUSTICE JUDGMENT
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If appellant was CLAIMANT (see Pa. R.c.P.J.P. No.
1001 (6) In action before DIstrict JUstice, he MUST
FILE A COMPl..AINTwfthln twenty (20) days after
filing his NOTICE of APPEAL.
CV 19. C. V .2.3o-QS-
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This blodt will be s9lId ONLY "'- thl. nolation I. required under Pa. R.c.PJP. No.
10088.
This Notice of AppeoI. "'- rwceI...d by the Di.trict Ju.tic.. will operate os 0
SUPERsa>EA5 Ia tho Judgment far pas........ In thl. cOS&
S/f11afUt8 01 Rol/!onoIay or Dopuly
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE \
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IF NOT USED, detach from cq:Iy 01 notice oIl/1lPf1Bl to be served upon l/IlPfIllee}.
PRAECIPEI To Prolhonolary
Enter rule upon
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(3) The doto of service of this rule if service was by maills tho doto of moiling.
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COMMONWEALTH Of PENNSYLVANIA ,
COUN~Y OF ~,(Jl2 (: ; II
AFFIDAVIT: ~ebY swear or Ifllrm thltl served
D9. a copy 01 the Notl/;.e of Appeal, C,!!!,mon Pleas NoCfs - ~g-3"1 , upon Ihe Olstrlcl Justice designated thOle In on
(date o/aervlce) ~...~.. 'i . 19~ 0 by person I service ~ by (cerllfled) (,eglstered) mall. sender'.
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o and lurlher that"served the Rule 10 File a Complalnlaccompanylng lhe above Notice 01 Appeal upon the appellee/I) to whom
lhe Rule'wa. addressed on .19_ 0 by personal service 0 by (c.'tltled) (,eglslerod)
mall, .ender's receipt attached hereto.
SWORN (AF~EDI ANO SU~BEO BEFORE ME
THIS ,s-=- DAY OF · (),;, ~9~
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C_IMTH Of 'INHSYLYllNIA
COUll' Of C_ 'Lilli
NOTICE OF APPEAL
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JUOtCW DlITIICT
DISTRICT JUSTICE JUDGMENT I
COMMON PUllS N. 9 s- - 083 '+ ~ T eMkJ I
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NCTlCE OF APPEAL
Notice i. giwn that tho appollont ha. foIod In tho above Court of Common Plea. on appeal from the judsn-t rondoIod by the Di.trict Ju.tico on tho
cIcft and in tho coso ....dlouod below
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This Notico of AppooI. "'- rwceI...d by the Di.trict Ju.tico. will operato os 0
SUPERSEDEAS Ia tho Judgment far pas...sion in thi. co.a
SigIa/ue 01 ProIhanotaIy or OOpuly
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This see/Ion 0I1otm /0 be used ONLY when l/IlPfIllant was DEFENDANT (see PII. RC.P.J.P. No. t001(7) in action before DIstrict Jus/ice.
IF NOT USED. detach from c~ 01 notice oIl/1lPf1BI/o be served upon appellee).
PRAECIPE. To I'lothonalory
Eolo< rule upon
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(Common Pleas No.
) within twenty (20) cloy. oflor sorvico of ruIo or luffer entry of fudsn-t of non pro..
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RULE. To
(I) You are no~flod that 0 rule is hereby entered upon you Ia file 0 campIoint in this appooI withln tWllflty (20) cloy. 0110< the dote of
sorvico of thl. rule upon )oou by pooonal """ico or by cortiflod or registered moiL
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PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(ThiS proo' 01 ..rvIC. MUS T BE FILED WITHIN TEN (10) DA YS AFTER ''''''9 Ihe nollce 0' appeal. Chech applicable bo'es)
COMMONWEALTH Of PENNSYLVANlll
COUNTY OF : II
AFFIDAVIT: I hereby swear or afllrm thaI I servod
o a copy of Ihe Nolice 01 Appeel. Common Pleas No . upon Ihe Dlstrlel JusUee deslgnaled Ihereln on
(dolo 0' service) .19_. 0 by personal servIce 0 by (certified) (registered) mall. sender's
receipt attached herelo, end upon Ihe appellee. (name) . on
.19 r) by personal service 0 by (cerlified) (registered) mail, sonder"s roceipt attached hereto
o and turlher Ihall served Ihe Rule 10 File a Compla,nl accompanYing Ihe above Notice of Appeal upon Ihe oppelleeli) to whom
lhe Rule was addressed on . 19_ 0 by personal service 0 by (certified) (registered)
mall. sender's receipt attached hereto.
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS DAV OF . 19_
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GREGORY A. MYERS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMbERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-6834 Civil Term
vs.
MICHAEL WALL,
Defendant
NOTICE
I HEREBY CERTIFY that on the 28th day of December,
1995, a true and correct copy of the Important 10 Day Notice
of Entry of Default Judgment was served upon Defendant by
depositing the same in the U.S. Mail, postage prepaid,
addressed to:
Michael Wall
208 Mill Street
Mt. Holly Springs, PA 17065
Date: i~/?~/fS-
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GREGORY A. MYERS,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 95-6834 Civil Term
MICHAEL WALL,
Defendant
TO: Michael Wall
208 Mill Street
Mt. Holly Springs, PA 17065
DATE OF NOTICE:
December 28, 1995
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU
WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT
RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
ASSISTANCE OFFICE
Court Administrator
Cumberland County Court House
4th Floor
Carlisle, PA 17013
Telephone (717)240-6200
BRATIC & PORTKO
101 South U.S. Route 15
Dillsburg, PA 17019
(71~
BY: k~
Step en K. Portko
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GREGORY A. MYERS
Plaintiff
v.
MICHABL WALl.
Defendant
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Ie The Court of Cocmon Ple.s of
Cumberland County, ?er~sylvania
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95..6834
19
CIVIL ACTION - LAW
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We do sole=nlv swear (or a~~irm) that we viII support, obey and defend
the Coestitution of the ~nited States aud the Constitution or this Co~on-
vealth and that we vill discharge the duties of our ot~ice with fidelity.
AWARD
~e, the undersigned arbitrators, havi~g ~een duly appoi~ted and sworn
(or af~irmed), make the follOWing award:
(Note: If dacages for de~ay are awarded, they shall ~e
separately stated.)
INIL.
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of
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applicable. )
. Ar~itra:or, dissents. (Inser: ~ace ,.
:late of :!ear<~g: January 28, 1997
:late of Avard:
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NOTICE OF ENTRY OF AWARD
Now, the Itj'f: day of 1...,-t...~.'1
avard vas entered upon the docket aed
?arti~s or th~i= a::o~eys.
Ar~itrators' coepensatiou :0 be
paid upoe appeal:
5 ..l"lo,,,,..,
, 1991 , at I/:;J{ ,~. .:1., the above
notice :hereof gIVeD ~Y-~il :0 the
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