HomeMy WebLinkAbout02-5190GORDON & WE1NBERG, P.C.
BY: PAUL M. SCHOFIELD, JR.,ESQUiRE
Identification No.: 81894
21 SOUTH 21ST STREET
PHiLADELPHIA, PA 19103
215/988-9600
THIS IS AN ARBITRATION MATTER.
ASSESSMENT OF DAMAGES HEARING
REQUIRED.
The Hartford Insurance Group, Inc.
P.O. Box 2024
Hartford, CT 06145
VS.
Thomas Kinney dba Kinney Assoc
16 West Main St.
Mechanicsburg, PA 17055
NOTICE
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO.:
YOU HAVE BEEN SUED IN COURT. 1F YOU WISH TO DEFEND AGAINST THE
CLAIMS SET FORTH 1N 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 JUDGEMENT 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.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURT HOUSE,4TH FLOOR
1 COURTHOUSE SQUARE
CARLISLE ,PA 17013-3387
717-240-6200
GORDON & WEINBERG, P.C.
BY: PAUL M. SCHOFIELD, JR.,ESQUIRE
Identification No.: 81894
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
THIS IS AN ARBITRATION MATTER.
ASSESSMENT OF DAMAGES HEARING
REQUIRED.
The Hartford Insurance Group, Inc.
P.O. Box 2024
Hartford, CT 06145
VS.
Thomas Kinney dba Kinney Assoc
16 West Main St.
Mechanicsburg, PA 17055
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO.: (SD ~ ,.,q"?~ ~
COMPLAINT IN CIVIL ACTION
1. At the special instance and request of the defendant(s), plaintiff sold to the
defendant(s) insurance coverage, on the dates, of the kinds, in the amounts and for the prices set forth
in a true and correct copy of the plaintiffs books oforiginaI entry attached hereto, made part hereof,
and marked Exhibit "A".
2. Defendant(s) accepted said insurance coverage without complaint.
3. The amounts of the premiums set forth in Exhibit "A" are the amounts which the
defendant(s) agreed to pay therefor.
4. All the credits, if any, to which the defendant(s) is(are) entitled are set forth in
Exhibit "A".
5. Plaintiffhas made demand upon the defendant(s) for payment of the amount due,
but the defendant(s) has(have) failed and refused and still refuse(s) to pay the same or any part
thereof.
WHEREFORE, plaintiff claims of the defendant(s) the sum of $4,638.53 together with
interest and attorney fees.
GORDON & WE1NBERG, P.C.
BY: ~~
JP~4.AtoU~mey .foSrC~rFtliE)D, JR.,ESQUIRE
P01I
VERIFICATION
PAUL M. SCHOFIELD, JR.,ESQUIRE, hereby states that he is the attorney for the
Plaintiff(s) in this action and verifies that the statements made in the foregoing pleading are true and
correct to the best of his knowledge, information and belief.
The undersigned understands that the statements herein are made subject to the penalties of
18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities.
U1RE
Thomas Kinney Dba Kinney Associates
16 West Main St
Mechanicsburg, PA 17055
The Hartford
P 0 Box 2024
Har¥ord. CT 06145
Statement of Premiums
Date:
Account #:
Agent/Broker:
Total Amt Due:
6/7/01
PAAAA 490155CL
Paychex Agency Inc
$4,638.53
Policy
Po#cy Pedod
WEGJF4342
11/04/99-11/04/00
'l'rans¢]ction
New Business
Payment
Canc B/A/A
Canc Audit
Service Charge
Effective Date
11 ~04~99
06/06100
09/10/00
11/04/99
Total Due on Policy Term:
Premium
$6,173.00
(725.47)
0.00
(830.00)
21.00
$4,638.53
Page 1of 1
SHERIFF'S RETURN -
CASE NO: 2002-05190 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
NOT FOUND
THE HARTFORD INSURA/qCE GROUP
VS
KINNEY THOMAS DBA KINNEY ASSOC
R. Thomas Kline ,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named defendant, DEFENDANT
KINNEY THOMAS DBA KINNEY ASSOC but was
unable to locate Him
COMPLAINT & NOTICE
in his bailiwick.
He therefore returns the
the within named DEFENDANT
, NOT FOUND , as to
KINNEY THOMAS DBA KINNEY ASSOC
NOT AT 16 W MAIN ST. FORWARDING FROM PO IS 440 MARKET ST LEMOYNE.
RESIDENT THERE SAID THAT KINNEY'S LOCATION IS UNKNOWN.
Sheriff's Costs:
Docketing 18.00
Service 16.56
Not Found 5.00
Surcharge 10.00
.00
49.56
GORDON & WEINBERG
11/06/2002
R. Thomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
this ~ day of
~ow3 ~ A.D.
PrOthonotary
GORDON & WEINBERG, P.C.
BY: PAUL M. SCHOFIELD, JR.,ESQUIRE
Identification No.: 81894
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
rl'T Hartford Insurance Group, Inc.
P.O. Box 2024
Hartford, CT 06145
VS.
Thomas Kinney dba Kinney Assoc.
100 W. Main Street
Mechanicsburg PA 17053
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO.: 02-5190-Civil Term
PRAECIPE TO REINSTATE COMPLAINT
Kindly reinstate the Plaintiffs' Complaint in Civil Action in the above-captioned matter
for an additional thirty (30) days.
GORDON & WEINBERG, P.C.
BY:
~.JLM. ~H~FIELD, JR.,ESQUIRE
Attorney for Plaintiff
SHERIFF'S RETURN - REGULAR
CASE NO: 2002-05190 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
THE HARTFORD INSUPJ~NCE GROUP
VS
KINNEY THOMAS DBA KINNEY ASSOC
BRYAN WARD , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
KINNEY THOMAS DBA KINNEY ASSOC the
DEFENDANT
, at 0854:00 HOURS, on the 28th day of January , 2003
at 320 MARKET STREET
LEMOYNE, PA 17043
by handing to
THOMAS KINNEY
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 11.04
Affidavit .00
Surcharge 10.00
.00
39.04
Sworn and Subscribed to before
me this ~0 ~ day of
~/c~Cc~C~, ~4f~9~ A.D.
So Answers:
R. Thomas Kline
01/29/2003
· Deputy-S%~eriff
GORDON & WEINBERG, P.C.
By: PAUL M. SCHOFIELD, JR.,ESQUIRE
Identification No.: 81894
21 SOUTH 21ST STREET
PHILADELPHIA, PA 19103
215/988-9600
ITT Hartford Insurance Group, Inc. :
:
VS. :
:
Thomas Kinney d~a Kinney Assoc :
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO.: 02-5190-Civil
TO THE PROTHON(
Kindly wit
prejudice.
P006
PRAECIPE TO WIT~DRAW C(H~PLAINT
TARY:
hdraw the above-captioned action, without
GORDQI~NBERG,
/~AUL M. ~A~OFIEL-D, JR.,ESQuiRE
Attorney for Plaintiff