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Home My WebLink About00-06257 , ,~ - .~~ ~ -~"'" KATHLEEN MARSHALL TRIMMER HULL, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 00-6257 CIVIL ACTION-LAW CYNTHIA SHADE, Defendant JURY TRIAL OF TWELVE DEMANDED RULE TO SHOW CAUSE AND NOW this 3/41" day of oc.Ok, ,2001, a rule is issued upon the Plaintiff to show cause why Plaintiffs counsel should not be permitted to withdraw his representation. p...lJq. ~~fl>~ ,)~~f't~ J. ~ ~,O\ , I I I I !' ,q'" -, = ~., ~~""'...,.--~----~,.." ~- ~",-- _"C'. _J ~,. ,_ ,.," , '_'"'<' O~~._ "-;,j<)'[!',RY U i nCT 3! Ai'; 10: I l CUIVj8~:H~1\;'tD COUNTY PENNSYLv'~NIA ~l ,__~_,,~__w ~_~ ~~~!IJ!~ ~_ JlUflt!IT .... '"-~_ ~'-,- rll9,..4I,J",,_<_~_ I " _I;i>;o;", . , KATHLEEN MARSHALL TRIMMER HULL, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 00-6257 CIVIL ACTION-LAW CYNTillA SHADE, Defendant JURY TRIAL OF TWELVE DEMANDED ORDER AND NOW, this _ day of , 2001, Plaintiffs counsel MARTSON DEARDORFF WILLIAMS & OTTO, by George B. Faller, Jr., Esquire, is hereby granted leave of the Court to withdraw their appearance. It is hereby further ordered that Defendant's counsel, are prohibited from entering any type of judgment of non pros for a period of thirty (30) days from the date of this Order to allow Plaintiff to fmd new counsel. BY THE COURT, J. j ....... ~.~~'" --'c Fi.\FILES\DATAFILE\Gendoc.cur\~016Spet.llnlm Created: 10/22101 02:33:38 PM ! Revised; IO/2S/OI09:36:S9AM ' .1016S.1 . . KATHLEEN MARSHALL TRIMMER HULL, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 00-6257 CIVIL ACTION-LAW CYNTHIA SHADE, Defendant JURY TRIAL OF TWELVE DEMANDED PETITION TO WITHDRAW AS COUNSEL 1. Petitioner represents the Plaintiff as a result of a writ of sununons which was filed on September 13, 2000. 2. Defendant is represented by Brian N. Zulli, Esquire of NEALON & GOVER, P.C. 3. The Defendant has ruled the Plaintiff to file a Complaint on or about January 22, 2001. 4. The Defendant had also served interrogatories and a request for production of documents upon the Plaintiff on February 13,2001. 5. Plaintiff s counsel has been unable to secure adequate cooperation from his client to provide the information needed to file the Complaint and respond to the discovery. 6. Plaintiffs counsel seeks the Court's approval to withdraw his appearance pursuant to Pa. RC.P. 1012. 7. Plaintiffs counsel's withdrawal at the present time can be accomplished without material adverse affect on the interest of the client. 8. Defendant's counsel, Brian N. Zulli, Esquire, was consulted on October 18, 2001, and has indicated that he has no objection to the Petition being granted. WHEREFORE, Plaintiffs counsel requests that the Court grant its leave to withdraw its appearance and enter an appropriate Order. By George B. Faller, r., Esquire I.D. Number 49813 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: October 25,2001 Attorneys for Plaintiff < - VERIFICATION ~"""Il.l!l'''''".''nb~ George B. Faller, Jr., Esquire, of the firm of MARTSON DEARDORFF WILLIAMS & OTTO, attorneys for Plaintiff in the within action, certifies that the statements made in the foregoing Petition to Withdraw as Counsel are true and correct to the best of his knowledge, information and belief. He understands that false statements herein are made subject to the penalties of 18 Pa< C.S. Section 4904 relating to unsworn falsification to authorities. Geo (};; aller, Jr., Esquire . ~~ . , CERTIFICATE OF SERVICE I, Nicho1e 1. Myers, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Petition to Withdraw as Counsel was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Brian N. Zulli, Esquire NEALON & GOVER 2411 North Front Street Harrisburg, P A 17110 Mrs. Kathleen Marshall Trimmer Hull 673 Sand Spur Drive Etters, P A 17319 MARTSON DEARDORFF WILLIAMS & OTTO By<icU'A~ Nichole 1. Myers Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: October 25, 2001 ~_. -~~ . " ',,," 1~~..' E _ -~. r '-' '.' <'~1u=1ij~-- dh8 ' - " ..-'- -,~,&,ij !ll;il1 Kli_ilfJfiI1~I~1II ,-, ~."<" -~ -- ~~~." "<~~ ~ '~.... ~''''''r-~''1'1r''IIJlIltllJii "" .-"-. =, ~,'~ 8 s: -0 co rnf'T1 Z'" ~~; [:: c:: '" ~S .-:::' :< :~-w-~ ", r.,,} c:> o '1 --l ~F;::: , ,-,., ...~~~ .:~?(~ ~"'(-n '~ :;: ':OJ -< o n -j N 01 -:; w ~ ID ~ .~~ , ~" - ,-~- -, ~i , F:\FILES\DATAFILE\Gendoc.cur\! 0 165pra.lInlm Created: 09/13/0002:45:31 PM Revised: 09/13f0003:01:2IPM 10165 KATHLEEN MARSHALL TRIMMER HULL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. C(!:rc1d57 c!;;;J CIVIL ACTION-LAW v. CYNTHIA SHADE, Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue a writ of summons against Defendant and have the Sheriff serve it on Cynthia Shade at 125 Cambridge Drive, Mechanicsburg, P A 17055. By George B. Faller, Jr., Esq e I.D. Number 49813 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff Date: September 13, 2000 .. -'''':->\--_~;: tllltiWnm ... ""jrrm~~'" ,- ~,I"'''~!l@~'\$_~'k!i!!~ ,-~ .,- ~...~;'-..:J_-' " 0 C::' C C--) ~ ("'::> & 0.....[:. ;:---- :c0 -nee. '. ~ '0- 1'11)," '''~j .. . ~ . I . -;;'''' ".- 'f ~ G ~ ...:::. c..,-" "'-'J C '-< . ...' .' ~ c- - ~ ~X2~ Q ~ (9 :"J :-t) .~ ~:-::-; (l ~ ~ r0 :::P -< .....l .b cJf ~ ~ <:;' C ~ (> -,~. ~'" ',.,,' , ,"',.. ".' "J I I , 1 " " - ,.,., ,',-,' , ~--" " r Commonwealth of Pennsylvania County of Cumberland Kathleen Marshall Trirnrner Hull, Plaintiff VB. Court of Common Pleas No. __<!'Q:::~_2_~?_S;_:i,,'!!1.__'!'~E!lmmhh__ 19____ Cynthia Shade, In _~i.yH_1ic;;tj.QIL1fl.!'Lm_______mm_______ Defendant To Cynthia- Sha~- u______ u__ _n__ - __ __ _u___ You are hereby notified that _~t~_~sbELLl_~Jiu1JL___________.________________________________________________ the Plaintiff has commenced an action in __~!~J..A~!2.rU;~!!:____n_n____________nn___n_nn against you which you are required to defend or a default judgment may be entered against you. (SEAL) .~sL_r_~j._~_8~__~~------------------------- Prothonotary Date _.5.eptrobeJ::..13._.2.QOO_______ XlL___ By '-"~~,' ':Jl1U~_!:I.~mi~W~jI..s:~>\!}g~liwAi@.1ii'Siit","P;,ii~'r;i>;1WE~a;:",mf"c-ti'"~~tlLd~..'!1lttl!lL~.!."'L"B\"'H.j,;!,tJh('"~~Mtiiljllil:iII""""~ .Illill.'K'li'i'\G''''d'''''''' ~', - ~ ",,.-,,, ~ ,'~" "~i .j . . () rtr H Gl () ~ ~ ...., PJ 8 ~ ~ '1 :> ? ...., ~ ,\:l ::Y 0 ....- Qj p: ~ 0 rn PJ 1r <1J () <1J I N ~ rn ....- PJ ~ Ch "" <1J IT ~ <: r C/l 0\ g W - ....- tv I 0: "" ~ 5f if 111 W ;;9 ....- '" "l fl ...., 'tJ >- w cg. <X> PJ g. '1 ~ S "" ~ I--' rn () PJ I--' I--' w I--' IT - ~ 5f ....- ..... j ...., C/l <1J ....- <: i'1- 0 IT '1 0 I--' ..... ~ '1 :> I--' ~ ..... w <1J Ch I ~ ~ i .... Ii' 'tJ f{ rtr Ch w == I--' 0 . Ch PJ ..... ~ '" ~ ....- ~ w i'1- Qj rn ~ ..... '1 - ~. Ch ~ :0 Ch I '1 I <1J I--' I - ,. -~ '" , ,.,-- ,;;;~- ;~.~' ,~~,~ ~ ~-~ ~ . " ' ...' '"""'~ ~ 1:>-d>.1.!i!l'--'--' SHERIFF'S RETURN - REGULAR CASE NO: 2000-06257 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HULL KATHLEEN MARSHALL TRIMMER VS SHADE CYNTHIA CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon SHADE CYNTHIA the DEFENDANT at 1500:00 HOURS, on the 22nd day of September, 2000 at 125 CAMBRIDGE DRIVE MECHANICSBURG, PA 17055 by handing to CYNTHIA SHADE a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.82 .00 10.00 .00 34.82 So Answers: r~~~ R. Thomas Kline me this :ilL-- day of 09/26/2000 MARTSON DEARDORFF WILLIAMS By, ~ l#- Duty Sheri Sworn and Subscribed to before (Y,:r;;:p..., :2 {)7f'CJ A. D. q'fL-- C. n"o~" # Prothonotary , .. - '-~ '.-''- .'c':":- ~ . "'>: I ! .. , , -, KATHLEEN MARSHALL TRIMMER HULL, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 00-6257 CYNTHIA SHADE, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Cynthia Shade, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER By: ...b~ ~ David J. Freed, Esquire Atty. 1.0.#76622 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 -,. .,0,'" "", . CO,', - .' .."~' _, ',T"'__ , CERTIFICATE OF SERVICE AND NOW, this 19th day of January 2001, I hereby certify that I have served the foregoing Praecipe entering my appearance on the following by depositing a true and correct copy of the same in the U.S. Mail, post prepaid, addressed to: George B. Faller, Jr., Esquire Ten East High Street Carlisle, PA 17013-3093 F! ~~~ David J. Freed, Esquire I:: I:, I I' ,(! , , I r:. , .' , " . _. -: :,].;_'-,", ~',:_ :..'- - I ~-:_"'." _ - -', '''0,:- .. 0#_ _-' ....." ... , - . v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 00-6257 KATHLEEN MARSHALL TRIMMER HULL, Plaintiff CYNTHIA SHADE, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer a judgment of non pros. Respectfully submitted, NEALON & GOVER By: ~~~. David J. Freed, Esquire Atty. I.D. 76622 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 RULE TO THE PLAINTIFF: A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros. DATm t/J"-lol (j~:k; .J k>.~ Prothonotary ^_.' "<""--,: ,,; ",>,- ',L,e_",'''"',_,, -""C "~-'_ ' 1 " ... .~ '"'-... ~" , .. . CERTIFICATE OF SERVICE AND NOW, this ~ ~..6f,day of January, 2001 I hereby certify that I have served the foregoing Rule to File a Complaint on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: George B. Faller, Jr., Esquire Ten East High Street Carlisle, PA 17013-3093 ~~\llL-\ David J. Freed, Esquire - , , KATHLEEN MARSHALL TRIMMER HULL V. CYNTHIA SHADE ,~-o' ~,_" ~ ~,. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-6257 CIVIL : CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 29TH day of APRIL, 2003, it appearing to the Court that Defendant's Petition for Ru1e to Show Cause is incomplete in that the Exhibits referred to therein are not attached thereto, the petition is denied without prejudice to refile. Kathleen Marshall Trimmer Hull 673 Sand Spur Drive Etters, Pa. 17319 Michael S. Ferguson, Esquire 2411 North Front Street Harrisburg, Pa. 17110 :sld Edward E. Guido, J. . ~ "/_30,0-3 ~ q.. " i I j 1 j '1- --. - ,~"" I, , -~f"'f~' . ,18I!'l ._~ ~.,- -- Jl'l'.., "'~ ..- """ IIJ, )j)l "'->0,,.-''''['_<_'''_1,.' """" ",,-" . .. ,. ~~-~~,~- .. ~ ." _-,_. ., _0" ",,~" -, .",. ~- ...... ~Hj~D-OFFICE 0.:: !-;' '--', ,ICr'/CTARY 03 e:pr~ 30 AH 9: :1! cu' ',",'," . '. "'7)' /'\/1,"-';"1";' '(';'/UJ' f.'t!I:'\ll_ ........... ''--, '" '"'",,,oA.), '. PENNSYLVAJ\lIA ln~~. ~ll!!IIlUJ1~,^ ~ f.~fJj\~..,-;--~~{'- l~~ . ~!j-'T-~'-', ,"l!WIL,u. ,,--- _:. I' ", - - ."", ,-."~--. ~~. " ,'4 -'0_.;"" "~""""'-~-_">'''_' ,-,:,' "-;-"",-_~..,,,,.,_.- .",,:' ,-," :,~";".;,,,;C; ,1",.., ,., , "'", v. ~ APR Z 5 ZOO3 IN THE COURT OF COMMON PLEAS U CUMBERLAND COUNTY, PENNA. NO. 00-6257 KATHLEEN MARSHALL TRIMMER HULL, Plaintiff CYNTHIA SHADE, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED ORDER AND NOW this day of , 2003, a Rule is issued upon the Plaintiff to show cause, if any, why the Defendant should not be permitted to mark this docket as settled, satisfied and discontinued. This rule is returnable with days after service. BY THE COURT: J. '.," ~.- ..,,--,'- --"",",>,,,,,.;,,-..,, "'--'<'b".i~-';;,~,hr.';.,~_ '.',--. - - -~. - fIn KATHLEEN MARSHALL TRIMMER HULL, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 00-6257 CYNTHIA SHADE, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED RULE TO SHOW CAUSE AND NOW, comes Cynthia Shade by and through her attorneys Nealon & Gover, P.C. who aver as follows: 1. On September 13, 2000 a Writ of Summons was issued by Cumberland County Prothonotary's Office beginning the above-captioned action. 2. On January 22, 2002 a Rule was issued upon the plaintiff to file a Complaint within 20 days or suffer judgment of non-pros. 3. On October 25, 2001 Plaintiff's counsel, George Faller, Jr., filed a petition to withdraw as counsel citing inadequate cooperation on behalf of his client. 4. On October 3, 2001 a Rule to Show Cause was issued by the Honorable Edward Guido regarding the petition to withdraw as counsel. 5. At some point after that permission was granted to Mr. Faller to withdraw as counsel. 6. On June 17, 2002 the Plaintiff, Kathleen Marshall Trimmer Hull, entered into an agreement with the Defendant in this case and settled this matter for $1,500.00. A copy of the Release of this matter is set forth as Exhibit "A." . ~." ~ --, ,'. , . ~,,~ '. -', ~ " .' -""--,,'" ~' ,-",""~- ~ '; ': - ',- ~"i~- 7. On that same date the plaintiff signed a Praecipe to discontinue the matter asking the Prothonotary of Cumberland County to mark the above-captioned matter settled, satisfied and discontinued. 8. On June 20, 2002 the Prothonotary of Cumberland County returned the Praecipe to Discontinue to this office indicating that they would not accept a Praecipe to Discontinue with the Plaintiff's signature on it. A copy of that response is attached as Exhibit "C." 9. On July 1, 2002 a letter was sent to Ms. Hull at her last known address, requesting her to come to our office so that we could comply with the Prothonotary's request. 10. Ms. Hull did not make arrangements to come to this office and sign such documentation. 11. On January 2, 2003 the undersigned counsel sent another letter to Ms. Hull requesting that she complete a discontinuance, have it notarized and sent back to me. See Exhibit "D." No response was received from Ms. Hull. WHEREFORE, the Defendant request a Rule to Show Cause to be issued upon the Plaintiff as to why the docket should not be marked settled, satisfied and discontinued. ,~-~ , __" -,- -" - - C:_'-,,-e,,' "' _ Fi..' ,__-~ Respectfully submitted, NEALON & GOVER, P.C. Date: ..11(1(0'$ By: ""MuCI1!l.R Michael S. FergUSO~Uire Attorney 1.0. No. 83882 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 '"",,,;,,-- .c. ,',' ,_', _:: -. "' ~" _<C' ~,_ > -, . ,--,' ,p', CERTIFICATE OF SERVICE AND NOW, this 18th day of April, 2003, I hereby certify that I have served the foregoing Rule to Show Cause on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Kathleen Marshal Trimmer Hull 673 Sand Spur Drive Etters, PA 17319 ShPY11~ Eileen S. Smith, Secretary ~~ -~ ~"" f,~ i,1 !-: I; !r ,,; !: ~ " ~; ,: ", ~ "",- "'>.-' ",-,~ -J' ;;:. J- ~~_~_:U. ~ .,. ~ " "-~;."- b.I"" l_nll,mIl . _ ~~__, <, ." _c,',," " -~-, - --~ - jj ;.;aiiiilii. "H~ " _ p =_ _ , ,'"-,, "",,,,",',, '" "",,'''' 0 0 0 C G, ...." $: ". :::;:! -0'''1''1 ~ f;l;bl lilfi:::-; ;:0 2::1.) t'..' ..~, :71 c%~~ "":lC) ~ ~3~i 2., -0 )>r-' ._~. ~T' ::t: 20 z''': om '._"( , 1;;> Pc:: -l Z ::0 ~ -< co -< -', '';-;''';." -,',,'-, "'"c'-'-;"- -- ,~' .',' , - hf>-<i~': KATHLEEN MARSHALL TRIMMER HULL, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 00-6257 CYNTHIA SHAlDE, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED ORDER AND NOW this 7~ day of ~, 2003, a Rule is issued upon the Plaintiff to show cause, if any, why the Defendant should not be permitted to mark this docket as settled, satisfied and discontinued. This rule is returnable with do days after service. J. Distribution Kathleen Marshall Trimmer Hull 673 Sand Spur Drive Etters, PA 17319 Michael S. Ferguson, Esquire Nealon & Gover, P.C. 2411 North Front St. Harrisburg, PA 17110 .. ~ ~ ..]'.61'0..) ~. ~ ~~ ~, - ,~_" ,0' 1~7'.' .,.d" .,. - -'_"" "9,~,"",c'- '~""_'.~_', ' '."... ".,j c';'<~ ;..,' .< ",~;",-,=,,~,," 'LIT (X~ -I', :c -Oi:FjCE 1~'i,'nTI,n\1 ,__,fJl 03li';~.Y - "] F.i:': L: \ 5 Cu' 'I'll;" , ,. . ' ,[" 'Isrv ,,_,,-..'\'''';''' ,i..; 1.,.,.../0 III i pm\IS'ILVANIA -""',' .~, _,J1'_<i~'O._ 1'''' ! nlJ1iiI11f"'jlii ",0,.. "_.,'; :"'."-,Yf":.:.J,,,..>, -- ",:'N ",--- ; '" - ", .~., , ,',- . ",~, ',,-'- -',,-, " "V' ,,' - '," -......"'0 KATHLEEN MARSHALL TRIMMER HULL, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 00-6257 CYNTHIA SHADE, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED RULE TO SHOW CAUSE AND NOW, comes Cynthia Shade by and through her attorneys Nealon & Gover, P.C. who aver as follows: 1. On September 13, 2000 a Writ of Summons was issued by Cumberland County Prothonotary's Office beginning the above-captioned action. 2. On January 22, 2002 a Rule was issued upon the plaintiff to file a Complaint within 20 days or suffer judgment of non-pros. 3. On October 25, 2001 Plaintiff's counsel, George Faller, Jr., filed a petition to withdraw as counsel citing inadequate cooperation on behalf of his client. 4. On October 3, 2001 a Rule to Show Cause was issued by the Honorable Edward Guido regarding the petition to withdraw as counsel. 5. At some point after that permission was granted to Mr. Faller to withdraw as counsel. 6. On June 17, 2002 the Plaintiff, Kathleen Marshall Trimmer Hull, entered into an agreement with the Defendant in this case and settled this matter for $1,500.00. A copy of the Release of this matter is set forth as Exhibit "A.n .,LO ',',--"' ~ll. 7. On that same date the plaintiff signed a Praecipe to discontinue the matter asking the Prothonotary of Cumberland County to mark the above-captioned matter settled, satisfied and discontinued. Please see attached Exhibit "B." 8. On June 20, 2002 the Prothonotary of Cumberland County returned the Praecipe to Discontinue to this office indicating that they would not accept a Praecipe to Discontinue with the Plaintiff's signature on it. A copy of that response is attached as Exhibit "C." 9. On July 1, 2002 a letter was sent to Ms. Hull at her last known address, requesting her to come to our office so that we could comply with the Prothonotary's request. 10. Ms. Hull did not make arrangements to come to this office and sign such documentation. 11. On January 2, 2003 the undersigned counsel sent another letter to Ms. Hull requesting that she complete a discontinuance, have it notarized and sent back to me. See Exhibit "D." No response was received from Ms. Hull. WHEREFORE, the Defendant request a Rule to Show Cause to be issued upon the Plaintiff as to why the docket should not be marked settled, satisfied and discontinued. [I" , "__~ .,.,'''__ ,,','. ." .-'__ri~'" Date: SIt 103 By: "'" ,,' . l~ I" Respectfully submitted, NEALON & GOVER, P.C. -Mte-k Michael S. Ferguson, Esquire Attorney I.D. No. 83882 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 " ,-,,,-,,,-,-,,'" . ~. -,--, ',,' ~,~ - c' __ .~ ' __.~,_" .. "'1 " - - '4_""'''" KATHLEEN MARSHALL TRIMMER HULL, Plaintiff . v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 00-6257 CYNTHIA SHADE, Defendant CIVIL ACTION. LAW JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above-captioned matter settled, satisfied and discontinued. Respectfully submitted, Date: lQ-/:t--Q/ "....................;......._...."..... ......'- '.'~"" ..:!i"'__,"'__""""'"~'"'''!I!I.l,;' NEALONft< GOVER, :P.'C. ATTORNEYS AT LAW 2411 NORTH FRONT STREET HARRISBURG, PA 17110 TELEPHONE (717) 232-9900 FACSIMILE (717) 236-9119 BRIAN N. ZULLI bzulIi@nealon-gover.com June 17,2002 Curtis R. Long, Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 RE: Hull v. Shade Docket No. 00-6257 Dear Mr. Long: Enclosed please find an original and one copy of a Praecipe to discontinue in the above-referenced matter. Please timestamp the copy and return to us in the enclosed self-addressed, stamped envelope. Thank you. Very truly yours, ~ S f1urA Eileen S. Smith, Secretary NEALON & GOVER, P.C. Enclosures I., I ;)..6- LUL. ~ ~ ~cr?,.~ 2- P~OPL L.c..);-+l ~ I . PUu~J- .{'I?~~. l.0E'- ~l --Jo kw'L.- ~ ~.0'L~ ~*;t2-2pP~""'L ~'-IL..0 S:1'9~ ---fl...-'L- I- '() ~ECfr:- 6/L- ~~ k- Pa.uCr'- ~. A}b/2..U~1 ~/9"'ecL ~..xL ~~C ....-_......~....~..........."."...v^. - .ilL < -""""~AI'i..\!.~..Ii<ltil':ILlI.-i!l'lIDh~'j!",L ,. , NEALONIX .GOVER,~. ATTORNEYS AT LAW 2411 NORTH FRONT STREET HARRlsEURG. PA 17110 . . TELEPHONE (717) 232-9900 FACSIMllE (717) 236-9119 Michael S. Ferguson mferguson@nealon-gover.com January 2, 2003 Kathleen Marshall Trimmer Hull 673 Sand SpurDrive Etters, PA 17319 . ~ RE: Hull v. Shade Cumberland County Docket No. 00-6257 Dear Ms. Hull: Unfortunately we have not completely wrapped up this case. The Prothonotary's Office refused to accept your Praecipe to Discontinue due to the fact that you were not represented by counsel at the time. They require that if an individual does sign a Praecipe to Discontinue, it be notarized. Therefore, I have included a Praecipe to discontinue with this letter and ask that you take it before a notary public and sign it there. After you have completed that if you could put it in the prepaid envelope that accompanies this letter and send it back to me I would appreciate it. If you have any questions you can either contact myself or my secretary Eileen. Have a nice holiday season. Very truly yours, 1tc~~.~~- Michael S. Ferguson NEALON & GOVER, P.C. MSF/ess Enclosures ,'....C<~' ~"""'"~...... - ~~~ , ~"'~,,~,-~~,"'"~',I,,'-"', - " KATHLEEN MARSHALL TRIMMER HULL, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 00~6257 CYNTHIA SHADE, Defendant CIVIL ACTION. LAW JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE -'" TO THE PROTHONOTARY: Please mark the above-captioned matter settled, satisfied and discontinued. Respectfully submitted, NEALON & GOVER, P.C. By: Date: Michael S. Ferguson, Esquire Attorney 1.0. No. 83882 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 Date: . Kathleen Marshall Trimmer Hull, Plaintiff "~" , :"""" ,.'.' - '.--":'< ' ." ." ,'~ ' :'~~" ~" CERTIFICATE OF SERVICE AND NOW, this 1st day of May, 2003, I hereby certify that I have served the foregoing Rule to Show Cause on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Kathleen Marshal Trimmer Hull 673 Sand Spur Drive Etters, PA 17319 ~JI~l~J~ Ei een S. Smith, Secretary ". _~, , ,~", ," ,,'i "., FC,,,. ...".' ",r:, :, ;~; --,,'--;' ; :;,--" 1Ii!'!lf 1 j UJ rrL4~..,~,l~LJ],.lJl. .ll}JI" " ~f!f(",,1?{lL. "<'h-~'c,."iJ",<,.~,:\ "_, __ __" ,.~~ " ,- .<," ',~,"--, , --" All ~,;', ..;i....;' __ ". , --,--''', " .. ,~,'",',"'..,.' () c:; 0 C (....; -n ;''''. :1:. .-; ,,"'. "T) CD :;:,~... ;. '" rrl!':-J -< f';j ;'-'- Z::::u I 1',-1 Z~. . " ':':::J (j) -> f'o.) . , ~~.G: ~~~:.; (~) <~_.J -0 .. -,-, :F-:;,C) () .<'_:'1 W :::::;;fn >(:: ~._.,. :;-;! :z- en --< -c .-J -~ F<T , , ,'" ",' r-'.' ',': k'~ --;,'';'< ' '....,' '_''' ,""C"""" ~'__',',;;', "0 ~,,,', ,',0 '\ KATHLEEN MARSHALL TRIMMER HULL, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 00-6257 CYNTHIA SHADE, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED ORDER AND NOW this ~~ day of ~ ,2003, a Rule to Show Cause previously issued by this Court on May 7, 2003 is hereby made absolute and that the docket in this matter be marked settled, satisfied and discontinued by the Prothonotary. J. Distribution /Kathleen Marshall Trimmer Hull 673 Sand Spur Drive Etters, PA 17319 P'Michael S. Ferguson, Esquire Nealon & Gover, P.C. 2411 North Front St. Harrisburg, PA 17110 1 LM~tl RX~ 01-31-03 ", ",,',^ ----- ~",.c'__,__ ",,,--, ~""A ~<" ,v.;"O "~" I,):':: r!":: H!l ., I l;....1 ,.'1.1,.. ,j ~. .>> ~,- ~,~ D-()~:FlCE '.', W", "',Tf.c\\( . , "~:, "i,:~" 1I'\i'1 P>: ? n? ; j, ew. tl.... CUMC:::CC1:Jiu COUNTY PENNSYLVANIA , ".";" ~ ", "-~ ~, }. ., , u __, _ "'~~''';!- ,~,",:' "',"' ~,,,, 'r.""" ~", ~~",i, ":, '. ''',' '. """'-"',--,." -- '" ~ .-, , ~ ''''''"',,,, , ,~" ,,," 'r ,~,," 't;:, KATHLEEN MARSHALL TRIMMER HULL, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 00-6257 CYNTHIA SHADE, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED MOTION TO MAKE RULE ABSOLUTE TO: The Honorable Edward Guido AND NOW, comes Cynthia Shade, by and through her attorneys Nealon & Gover, P.C. who avers as follows: 1. On May 2, 2003 Defendant filed a Rule to Show Cause requesting that a Rule be issued upon the Plaintiff to show cause, if any, why the Defendant should not be permitted to mark this docket as settled, satisfied and discontinued. 2. A Rule was issued by this Honorable Court on May 7, 2003. The Rule was returnable with 20 days of service. See attached Exhibit "A." 3. On June 20, 2003 the undersigned sent to the Plaintiff the Order issued by the Court via certified mail. See attached Exhibit "B." 4. The certified letter was then signed for on June 25, 2003 by Tara Trimmer. Se attached Exhibit "C." 5. More than 20 days have elapsed since the Rule was served upon the Plaintiff in this matter and no response has been received by the undersigned. WHEREFORE the Defendant respectfully requests in this matter that the Rule previously issued be made absolute. "<>.<,'^" ~ I ~l j?-d'..3 Date: l " '~" " .. ^' (:: Respectfully submitted, NEALON & GOVER, P.C. By: 1U;f.~, A Mic=-;::r~, Esquire Attorney I.D. No. 83882 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 , ", ," ~^',: v. IN THE COURT OJ: C . A CUMBERLAND COUNTY, PENNA. NO. 00-6257 CIVIL ACTION - LAW JURY TRIAL DEMANDED KATHLEEN MARSHALL TRIMMER HULL, Plaintiff CYNTHIA SHADE, Defendant ORDER AND NOW this 7 ~ dayof ~ , 2003, a Rule is issued upon the Plaintiff to show cause, if any, why the Defendant should not be permitted to mark this . docket as settled, satisfied and discontinued. This rule is returnable with ,;,lO days after service. BY THE COURT: /s/ ~~ e ~ / , J. Distribution Kathleen Marshal! Trimmer Hull 673 Sand Spur Drive Etters, PA 17319 Michael S. Ferguson, Esquire Nealon & Gover, P.C. 2411 North Front St. Harrisburg, PA 17110 TRUE COPY FROM RECORD tn T I'lstimon'j whereof, I hare unto set my hand and the seal of said Coon at Carlisle, PI. Tn. bI ~ day of~ .1-/Jl9J .' iLL- ()_ ~t~ . Prothon_ ..... ~~ " if i tlt~!f';'" NEAlDN' GOVER,~ ATTORNEYS AT LAW 2411 NORTH FRONT STREET HARRIsBuRG, PA 17110 TELEPHONE (717) 232-9900 FACSIMILE (717) 236-9119 Michael S. Ferguson mferguson@nea1on-gover.com June 20, 2003 Via Certified Mail Kathleen Marshall Trimmer Hull 673 Sand Spur Drive Etters, PA W~19 RE: Hull v. Shade Cumberland County Docket No. 00-6257 Dear Ms. Hull: Enclosed please find a copy of the May 7, 2003 Order indicating that you have 20 days from date of service in whioh to respond to our Motion to have this matter disoontinued. If you do not respond within 20 days of service, I will then file a motion in which to have this matter marked settled, satisfied and discontinued with the Cumberland County Prothonotary's Office. If you have any objeotions to this being marked settled, satisfied and discontinued you need to make such objections within the next 20 days. If you have any questions you should contact counsel with regards to your options. Michael S. Ferguson NEALON & GOVER, P.C. MSF/ess Enclosures """"""""2'" ~'~ ',',". . Complete ~ems i, 2. and 3. Also complete item 4 if Restricted Delivery is desired. pnnt your name and address on the reverse SO that we can return the card to you. Attach this card to the bael< 01 the mailplece, or on the front If space permits. 0;ji;;:~~ u73~~~(\' ~/fl%lcr Article ",,' ..~ + ~. R eived bY (please Print Cfe,arly) --r , " .C;,..-<L\VI~ C. Signature X~ 7ft. o Agent AddresSee DYes DNa D. Is delivery address differeOt from item 1 '1 If YES, enter delivery address below: '3. ,~~~ Type '1dgertified Mail ~~press Mail l;J-:-Reglste~ ~eturn Receipt for Merchandise o 'n.ured Mail 0 G.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes ~",'.'. ,', ,', '~--' ~, , ,,,''- _ "",""," O_".i,<".,~ 'c.' CERTIFICATE OF SERVICE AND NOW, this '2 r~ day of July, 2003, I hereby certify that I have served the foregoing Motion to Make Rule Absolute on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Kathleen Marshal Trimmer Hull 673 Sand Spur Drive Etters, PA 17319 1U~ Michael S. Ferguson, Esquire l,' ,. i" '1' I: j;; " ~ ,: "'''','",'",'"0--' ;;<< ><, <'A,'"C,,"<' "," j:,;, .., "- ~. "0.,"',;,';': , ;',k'. ~, ,';, ,c',. -, ~. " ,~ "'"""''-'''',,<w '"<, " C,) '-;1 "'7l ;1-:1 ~jj;i~ :~; -< c- ,~7'