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HomeMy WebLinkAbout02-4768ERIC DESROSIERS, Plaintiff VS. THE ESTATE OF ROSS H. SMILEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. OOCK T NO.: 0;-- tt 76'5' CIVIL ACTION - LAW PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a writ of summons in the above-captioned action. Writ of Summons shall be issued and forwarded to the Cumberland County Sheriff, for service upon the Defendant. Paula J. McDermott, Esquire Killian & Gephart, LLP 218 Pine St., P.O. Box 886 Harrisburg, PA 17108-0886 (717) 232-1851 Signatur~,-~ ' Supreme Court ID No. 46664 Date: September 30, 2002 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAiNTIFF HAS COMMENCED AN ACTION AGAINST YOU. Pr~-h0notary Date: q - ~d 'Od-. '/15teputy d ERIC DESROSIERS, Plaintiff VS. THE ESTATE OF ROSS H. SMILEY, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. DOCKET NO.: 02,-- O~C ~' ~ CIVIL ACTION - LAW LIS PENDENS TO: THE PROTHONOTARY OF SAID COURT: Kindly index a Lis Pendens against Defendant, The Estate of Ross H. Smiley's property located at 101 North Enola Road, East Pennsboro Township, Cumberland County, Pennsylvania. A property description is attached hereto. Respectfully submitted, KILLIAN & GEPHART, LLP Dated: September 30, 2002 Paula J. lCfcDermott, Esquire Attorney I.D. #46664 218 Pine Street P. O. Box 886 Harrisburg, PA 17108-0886 Telephone: (717) 232-1851 DESCRIPTION and RECITAL ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at the northeasterly extremity of the arc connecting the westerly line of Enola Road with the northerly line of Susquehanna Avenue; extending thence southwestwardly on the said arc, curving toward the right, with a radius of ten feet, a distance of sixteen feet and fifty-three thousandths of a foot; thence northwestwardly along the said northerly line of Susquehanna Avenue a line curving toward the right with a radius of three hundred feet, a distance of one hundred forty-six feet and seven hundred thirty-three thousandths of a foot; thence north five degrees nine minutes thirty seconds East sixty-four feet and eight hundred eight thousandths of a foot; thence south eight-four degrees fifty minutes thirty seconds East one hundred fifty feet to the said westerly line of Enola Road, and thence along the same south five degrees nine minutes thirty seconds West ninety-four and eight hundred twenty-eight thousandths of a foot to the place of BEGINNING. HAVING ERECTED THEREON a one story concrete block garage. BEING Parcel No. 09-14-0832-266. BEING the same premises which Minnie R. Smiley, et al by Deed dated September 8, 1942 and recorded in Cumberland County, in Deed Book 12-P, page 105, conveyed unto Ross H. Smiley. Ross H. Smiley died November 24, 1993. Letters of Administration D.B.N. were issued February 16, 2001 to D. R. Smiley in Estate ~77 of 1994. CERTIFICATE OF SERVICE On this ~c, Ut day of ~ ~ g ~ ,2002, I hereby certify that I served the foregoing document by directing the Cumberland County Sheriff's Office to serve a time-stamped copy of the same on the following at the following address: The Estate of Ross H. Smiley c/o Donald R. Smiley, Administrator 115 East Columbia Road Enola, PA 17025 KILLIAN & GEPHART, LLP Paula J. McDermott, Esquire Attorney I.D. #46664 218 Pine Street P. O. Box 886 Harrisburg, PA 17108-0886 Telephone: (717) 232-1851 CERTIFICATE OF SERVICE On this ~oM~- day of .54~~ ,2002, I hereby certify that I served the foregoing document on the following by depositing a tree and correct courtesy copy in the United States Mail, postage prepaid, addressed to: Scott T. Wyland, Esquire MALATESTA HAWKE & McKEON LLP Harrisburg Energy Center 100 North Tenth Street Harrisburg, PA 17101 KILLIAN & GEPHART, LLP Paula J. M~Dermott, Esquire Attorney I.D. #46664 218 Pine Street P. O. Box 886 Harrisburg, PA 17108-0886 Telephone: (717) 232-1851 SHERIFF'S RETURN CASE NO: 2002-04768 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DESROSIERS ERIC VS SMILEY ROSS H THE ESTATE OF REGULAR RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon SMILEY ROSS H ESTATE OF the DEFENDANT , at C/O DONALD R SMILEY ENOLA, PA 17025 at 2045:00 HOURS, on the 22nd day of October 115 EAST COLUMBIA ROAD by handing to DONALD SMILEY a true and attested copy of WRIT OF SUMMONS 2002 together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 20.70 Affidavit .00 Surcharge 10.00 .00 48.70 Sworn and Subscribed to before me this ~, -~ day of A.D. YP~othonotary ~ So Answers: R. Thomas Kline 10/24/2002 KILLIA~By: & GE~ ~Dep~ty Sheriff ERIC DESROSIERS, Pl~ntiff Vo THE ESTATE OF ROSS H. SMILEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. DOCKET NO.: 02-4768 CIVIL CIVIL ACTION LAW PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly mark the above-referenced action "discontinued without prejudice". DUANE MORRIS LLP By: Paula J. l~cDermott, Esq. Attomey Id. No. 46664 305 North Front Street, 5th Floor P.O. Box 1003 Harrisburg, PA 17108-1003 (717) 237-5500 Date: May 19, 2003 Attomeys for Plaintiff HBG\114412.1 CERTIFICATE OF SERVICE On this 20th day of May, 2003, I, Nora A. Stames, a secretary with the law firm of Duane, Morals LLP, hereby certify that a tree and correct copy of the foregoing Praecipe to Discontinue was served upon the following individuals at their respective addresses by U.S. first class mail, postage prepaid, at Harrisburg, Pennsylvania: The Estate of Ross H. Smiley c/o Donald R. Smiley, Administrator 115 East Columbia Road Enola, PA 17025 Scott T. Wyland, Esquire Malatesta Hawke & McKeon LLP Harrisburg Energy Center 100 North Tenth Street Harrisburg, PA 17101 Nora A. Stames HBG\114412.1