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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