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HomeMy WebLinkAbout03-0845UNITED CHURCH OF CHRIST HOMES, INC., A PENNSYLVANIA NOT FOR PROFIT CORPORATION, Plaintiff VS. WILLIAM J. MOORE, SR., EXECUTOR OF THE · ESTATE OF MARY DUNNE ISRAEL,DECEASED · Defendant . · iN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW · NO.: 03 -- a'Y TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter the appearance of JOHN E. FEATHER, JR., ESQ., of Feather and Feather, P.C., 22 West Main Street, Annville, Pennsylvania 17003, as attorney for the Plaintiff in the above- captioned case. Respectfully submitted, FEATHER AND FEATHER, P.C. Attorney for Plaintiff Date: BY: ~ JI3'HN E. FEATHER, JR.,~Esciuire ID #15756 22 West Main Street Annville, PA 17003 (717) 867-1200 UNITED CHURCH OF CHRIST HOMES, INC., A PENNSYLVANIANOT FOR PROFIT CORPORATION, Plaintiff VS. WILLIAM J. MOORE, SR., EXECUTOR OF THE ESTATE OF MARY DUNNE ISRAEL,DECEASED Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW · NO.: o PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue a Writ of Summons upon the Defendant in the above case. Please forward the Writ to the Sheriff for Service upon the Defendant at his address RR #2, Box 270, New Bloomfield, Perry County, Pennsylvania 17068. FEATHER AND FEATHER, P.C. I! Date: ~.~/~q/o ~ BY: · / J~HN E. FI~ATHER, JR., Esquire ID # 15756 22 West Main Street Annville, PA 17003 (717) 867-1200 Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS UNITED CHURCH OF CHRIST HOMES INC A PENNSYLVANIA NOT FOR PROFIT CORPORATION Plaintiff Vs. WILLIAM J. MOORE, SR EXECUTOR OF THE ESTATE OF MARY DUNNE ISRAEL, DECEASED Defendant Court of Common Pleas No. 03-845 In CivilAction-Law To WILLIAM J. MOORE, SR, EXECUTOR OF THE ESTATE OF MARY DUNNE ISRAEL, DECEASED. You are hereby notified that UNITED CHURCH OF CHRIST HOMES, INC the Plaintiff has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) CURTIS R. LONG Prothonotary Date 02/25/03 By~/~Deput~; - ~ Attorney: Name: JOHN E. FEATHER, JR., ESQUIRE Address: 22 WEST MAIN STREET ANNVILLE, PA 17003 Attorney for: Plaintiff Telephone: (717) 867-1200 Supreme Court ID No. 15756 TRUE COPY FROM RECORO 'r~stiraony wh~reo[, I ,~ere unto sol my hanc SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-00845 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNITED CHURCH OF CHRIST HOMES VS MOORE JR WILLIAM J EXEC ESTATE 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: MOORE SR WILLIAM J EXEC ESTATE OF MARY DUNNE ISRAEL DECEASED but was unable to locate Him deputized the sheriff of PERRY serve the within WRIT OF SUMMONS in his bailiwick. He therefore County, Pennsylvania, to On March 5th , 2003 , this office was in receipt of the attached return from PERRY Sheriff's Costs: 18.00 9.00 10.00 16.00 .00 53.00 03/05/2003 FEATHER & FEATHER Docketing Out of County Surcharge Dep Perry County ~Th. ~ R. omas Kline Sheriff of Cumberland County Sworn and subscribed to before me this ;0~-~ day of ~ A.D. Prothon6tgr~ SHERIFF'S RETURN In the Court of Common Pleas Of the 41st Judicial District of Pennsylvania-Perry County Branch United Church of Christ Homes NO. 03-845 Ys William J. Moore, Sr. Executor of Estate of Mary Dunne Israel, deceased RR2 Box 270 New Bloomfield, Pa. 17068 Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a diligent search and inquiry for the within named Defendant(s) to wit William J. Moore, Sr., but was unable to locate him/her in his bailiwick. He therefore returns the to the within Writ of Summons to the above named Defendant(s) Willaim J. Moore, St, at RR2 Box 270 New Bloomfield, Pa. 17068 NOT FOUND. Defendant is in Florida until May 2003. Address is 1809 Farm Trail Sanibel Island, Fla. 33957 Sworn and subscribed to before me this q4.-/q day of /~I ,2003. can r_.. l'~ace Sheriff of Perry County IIARGARLrr F. FLICKINGER, NOTARY PUEiLiC ~ BLOOUFIELO BORO., PERRY COUrdTY COMMISSION EXPIR[S FEB. In The Court of Common Pleas of Cumberland County, Pennsylvania United Church of Christ Homes Inc VS. Williom J. Moore Sr. exec estate of Mary Dunne Israel, de~eased SERVE: same No. 03-845 civil Now, February 28, 2003 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Perry 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 ,20 , at o'clock M. served the upon by handing to- a and made known to copy of the original S 0 answers, the contents thereof. Sworn and subscribed before me this ~ day of ,20 Sheriff of County, PA COSTS SERVICE MILEAGE AFFIDAVIT UNITED CHURCH OF CHRIST HOMES, INC. A PENNSYLVANIA NOT FOR PROFIT CORPORATION, Plaintiff VS. WILLIAM J. MOORE, SR., EXECUTOR OF THE ESTATE OF MARY DUNNE ISRAEL, DECEASED Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · CIV1L ACTION - LAW : NO: 03-845 PRAECIPE TO REINSTATE THE WRIT OF SUMMONS TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please reinstate the Writ of Summons in the above-captioned case. Please forward the reinstated Writ of Summons to the Sheriff for service upon the Defendant at tiffs address R.R. #2, Box 270, New Bloomfield, Perry County, Pennsylvania 17068. Respectfully submitted, FEATHER AND FEATHER, P.C. DATE: . FEATHER, JR., ~S~. 756 Main Street Annville, PA 17003 (717) 867-1200 SHERIFF'S RETURN - CASE NO: 2003-00845 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNITED CHURCH OF CHRIST HOMES VS MOORE JR WILLIAM J EXEC ESTATE OUT OF COUNTY R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT , to wit: MOORE SR WILLIAM J EXEC ESTATE OF MARY DUNNE ISRAEL DECEASED but was unable to locate Him deputized the sheriff of PERRY serve the within WRIT OF SUMMONS , Sheriff or Deputy Sheriff who being says, that he made a diligent search and He therefore Pennsylvania, in his bailiwick. County, to On May 23rd , 2003 attached return from PERRY Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Perry County 22.00 .00 59.00 05/23/2003 FEATHER & FEATHER Sworn and subscribed to before me this /~ day of~ ~2~'~O A.D. rothonotary ' , this office was in receipt of the Sheriff of Cumberland County In The Court of Common Pleas of Cumberland County, Pennsylvania United Claurch of Christ Homes Inc William J. Moore Sr exec of estate of Mary Dunne Israel, deceased SERVE: s~ne No. 03-845 civil Now, May 14, 2003 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Perry 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 HOW, May 22 within Writ of Summons ,20 03.. ,at 12:50o'clock P M. servedthe HpOR William J. Moore, Sr. at POE: Moores Insurance Center Square New Bloomfield Boro, PA 17068 byhandingto William J. Moore, Sr. a True & Attested copyofthe origfinal Him and made known to Writ of Summons the contents thereof. So answers, Donald E. Smith County, PA Sworn and subscribed before methis.:~_ day of /}96~2. ,?0 03 I ~ NOTARt^L$~AL~ ] (J I I~.~'T~.mmNGm, nOT~PU~UC I I ~L~nE~ BO~O., I ~COMMISStONEXPIRESFEB. 16.2004 I COSTS SERVICE MILEAGE AFFIDAVIT SIRLIN GALLOGLY & LESSER, P.C By: Jori C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee GUARD INSURANCE GROUP. VS. MELRETTA SIMPSON T/A MELRETTA'S COMMERCIAL SERVICES and PNC BANK, NATIONAL ASSOCIATION, G A RNLqI-IF, F, : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND : : NO. 2600-L-2001 J.D. : 845-03 E.D. TO THE PROTHONOTARY: ENTRY OFAPPEARANCE Kindly enter my appearance on behalf of PNC Bank, National Association, Garnishee, in the above-captioned matter. Date: