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HomeMy WebLinkAbout07-10516- Thomas, Thomas & Hafer, LLP By: R. Burke McLemore, Jr., Esquire Identification No.: 26797 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7647 Attorneys for PLAINTIFFS UNITED STATES FIDELITY & GUARANTY INSURANCE COMPANY (USF&G) and FIDELITY AND GUARANTY INSURANCE COMPANY, as Subrogees of TIMOTHY MARTZ, Plaintiffs V. CHRISTOPHER BEAUVERD, 406 South Market St., Mechanicsburg, PA 17055, and JEANINE L. THOMAS, 30 McKelvey Rd., Dauphin, PA 17018, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA -14-,07- /6"%l PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a Writ of Summons upon Defendants, Christopher Beauverd and Jeanine L. Thomas, in the above-captioned matter. Respectfully submitted, THOMAS & FER, LLP Date: February 26,2007 By: Burke McLemore, Jr., omev I.D. No.: 26797 P.19,- Box 999 Harrisburg, PA 17108 (717) 255-7647 e-mail: bmclemore@tthlaw.com C:) rv m'n yab WRIT OF SUMMONS TO: JEANINE L. THOMAS, Defendant You are hereby notified that UNITED STATES FIDELITY & GUARANTY INSURANCE COMPANY and FIDELITY & GUARANTY INSURANCE COMPANY, as Subrogees OF TIMOTHY MARTZ, have commenced an action against you. Date: ,? 60b Prothonotary By: Deputy Thomas, Thomas & Hafer, LLP By: R. Burke McLemore, Jr., Esquire Identification No.: 26797 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7647 UNI I tU 5 RTES FIDELITY & GUARANTY INSURANCE COMPANY (USF&G) and FIDELITY AND GUARANTY INSURANCE COMPANY, as Subrogees of TIMOTHY MARTZ, V. Plaintiffs CHRISTOPHER BEAUVERD, 406 South Market St., Mechanicsburg, PA 17055, and JEANINE L. THOMAS, 30 McKelvey Rd., Dauphin, PA 17018, Defendants D7- !DS) Civil SHERIFF'S INSTRUCTIONS TO THE SHERIFF OF CUMBERLAND COUNTY: Kindly serve a copy of the Writ of Summons upon Defendant, JEANINE L. THOMAS, at 30 McKelvey Rd., Dauphin, PA 17018. 1 am requesting a return of service. Respectfully submitted, THOMA?B, THOM494t4iAFER, LLP Date: February 26,2007 By, Attorneys for PLAINTIFFS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA R. Burke McL o , Jr., squire Attorney I.D. : 26797 Harrisburg, PA 171 (717) 255-7647 ti Thomas, Thomas & Hafer, LLP By: R. Burke McLemore, Jr., Esquire Identification No.: 26797 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7647 UNITED STATES FIDELITY & GUARANTY INSURANCE COMPANY (USF&G) and FIDELITY AND GUARANTY INSURANCE COMPANY, as Subrogees of TIMOTHY MARTZ, V. Plaintiffs CHRISTOPHER BEAUVERD, 406 South Market St., Mechanicsburg, PA 17055, and JEANINE L. THOMAS, 30 McKelvey Rd., Dauphin, PA 17018, Defendants Attorneys for PLAINTIFFS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 41.7- 16 5N PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a Writ of Summons upon Defendants, Christopher Beauverd and Jeanine L. Thomas, in the above-captioned matter. Respectfully submitted, Date: February 26,2007 THOMAS,,-,T_I09AS & By: R. Burke cLemi Attomey I. No.: K-O. Box 9'99 re, LLP uire (717) 255-7647 e-mail: bmclemore@tthlaw.com C=:) p r7l a) fil- M vJ WRIT OF SUMMONS TO: CHRISTOPHER BEAVUVERD, Defendant You are hereby notified that UNITED STATES FIDELITY & GUARANTY INSURANCE COMPANY and FIDELITY & GUARANTY INSURANCE COMPANY, as Subrogees OF TIMOTHY MARTZ, have commenced an action against you. Date: D Pr onotary By: Deputy n c- N C-5 0 23 '? OD (10) . a Thomas, Thomas & Hafer, LLP By: R. Burke McLemore, Jr., Esquire Identification No.: 26797 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7647 UNITED STATES FIDELITY & GUARANTY INSURANCE COMPANY (USF&G) and FIDELITY AND GUARANTY INSURANCE COMPANY, as Subrogees of TIMOTHY MARTZ, V. Plaintiffs CHRISTOPHER BEAUVERD, 406 South Market St., Mechanicsburg, PA 17055, and JEANINE L. THOMAS, 30 McKelvey Rd., Dauphin, PA 17018, Defendants SHERIFF'S INSTRUCTIONS TO THE SHERIFF OF CUMBERLAND COUNTY: 61- /05! Clvi l Kindly serve a copy of the Writ of Summons upon Defendant, CHRISTOPHER BEAUVERD at 406 South Market St., Mechanicsburg, PA 17055. 1 am requesting a return of service. Respectfully submitted, Date: February 26,2007 THOMAS, THOMAS & HAFER, LLP By: tsu a McLe o , Jr., A orne I. D. 6797 P. x Harrisburg, PA 8 (717) 255-7647 Attorneys for PLAINTIFFS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA uire SHERIFF'S RETURN - NOT FOUND N CASE NO: 2007-01051 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND US FIDELITY & GUARANTY INS CO VS BEAUVERD CHRISTOPHER ET AL 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 BEAUVERD CHRISTOPHER but was unable to locate Him in his bailiwick. He therefore returns the WRIT OF SUMMONS NOT FOUND , as to the within named DEFENDANT BEAUVERD CHRISTOPHER 406 SOUTH MARKET STREET MECHANICSBURG, PA 17055 PER FATHER, DEFENDANT LIVES IN DELAWARE. Sheriff's Costs: Docketing Service Not Found Surcharge 31luIb, So answers- 18.00 9.60 5.00 R. Th as Kline 10.00 Sheriff of Cumberland County THOMAS THOMAS & HAFER 03/20/2007 Sworn and Subscribed to before me this day of A. D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2007-01051 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND US FIDELITY & GUARANTY INS CO VS BEAUVERD CHRISTOPHER ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: THOMAS JEANINE L but was unable to locate Her deputized the sheriff of DAUPHIN serve the within WRIT OF SUMMONS County, Pennsylvania, to On March 20th , 2007 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: So answe :,?- Docketing 6.00 Out of County 9.00 Surcharge 10.00 R. Thomas Mine Dep Dauphin County 37.25 Sheriff of Cumberland County Postage .63 62.88 ./ 31 U u l C ,,,, 03/20/2007 THOMAS THOMAS & HAFER Sworn and subscribe to before me this day of in his bailiwick. He therefore A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania United States Fidelity & Guaranty Insurance Co vs. Christopher Beauverd et al 07-1051 civil SERE: Jeanine L. Thomas No. Now, Februaiy 27, 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to copy of the original So answers, Sheriff of Sworn and subscribed before me this day of , 20 20 , at o'clock M. served the COSTS SERVICE $ MILEAGE AFFIDAVIT the contents thereof. County, PA Office of t4e c*4Pxrff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania UNITED STATES FIDELITY & GUARANTY vs County of Dauphin THOMAS JEANINE L Sheriff's Return No. 0325-T - - -2007 OTHER COUNTY NO. 07 1051 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for THOMAS JEANINE L the DEFENDANT named in the within PRAECIPE FOR WRIT OF SUMMONS and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, March 15, 2007 AS PER AN UNNAMED SOURCE WHO LIVES AT RESIDENCE, DEF HAS NOT LIVED OUT ADDRESS FOR OVER 2 YEARS Sworn and subscribed to before me this 15TH day of MARCH, 2007 NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept 1, 2010 So Answers, c- Sheriff;e-f-.pauphin County, Pa. ifs ,?? /? .-_ _ '•, ??/,.l By/ De ty Sheriff Sheriff's Co'sts:$37.25 PAID BY COUNTY REDMOND