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Home My WebLink About01-04305F IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA MELVIN L. SEIBERT, JR., Plaintiff v. FREDERICK G. WHITE, Defendant NO. 01-4305 CIVIL TERM CIVIL ACTION -LAW PRAECIPE FOR ENTRY OF JUDGMENT PURSUANT TO Pa. RC.P. NO. 1037(B)(1) TO THE PROTHONOTARY: Please enter judgment in favor of Plaintiff, Melvin L. Seibert, Jr., and against Defendant, Frederick G. White, in the amount of $12,525.00 based on the following averments: 1. Plaintiff commenced this action on July 16, 2001, by Complaint. 2. The Complaint contains a Notice to Defend within 20 days from service thereof. 3.iv/ The Complaint was served upon Defendant on September 24, 2001. S til~~~b~ c~-~.~~ tc~+- 4. On December 27, 2001, Plaintiff served a written Notice on Defendant, Frederick G. White, ~ pursuant to Pa. R.C.P. No. 237.1. A copy of said Notice is attached hereto and incorporated by reference herein. 5. Defendant, Frederick G. White, has not filed a responsive pleading to date. 6. The amount of damages as requested in the complaint are $12,525.00. WEIGLE & ASSOCIATES, P.C. Richard L. Webber, Jr., Esquire ~ Attorney for Plaintiff Attorney ID #49634 126 East King Street 5hippensburg, PA 17257 (717)532-7388 WEIGLE 6 ASSOCIATES, P.C. -ATTORNEYS AT LAW - 126 EAST KING STREET - 6HIPPENSBURG, PA 17267-1397 VERIFICATION, I verify that the statements made in the foregoing Praecipe for Entry of Judgment are true and correct. I understand that false statements herein aze made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Dated: 3l a-~l °a• Richard L. Webber, Jr., Esqui WEIGLE & ASSOCIATES, P.C. -ATTORNEYS AT LAW - t2b EAST KING STREET - SHIPPENSBURG, PA iT257-1397 1 MELVIN L. SEIBERT, JR., Plaintiff v. FREDERICK G. WHITE, Defendant TO: Frederick G. White, Defendant 267 Fickes School Road York Springs, PA 17109 DATE OF NOTICE: December 27, 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4305 CIVIL TERM CIVIL ACTION -LAW IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (]0) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Lawyer Refen•al Service 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 F'\UW FoW~~m Doc\Gedocs2001\Z09]-Ip~asipe 1 wpd LAW OFFICE OF MICHAEL J. HANFT Richazd L. Webber, Jr., Esquir~ a ~- Attorney I.D. No. 49634 19 Brookwood Avenue, Suite 106 Cazlisle, PA 17013-9]42 (717)249-5373 -~- (~~ -a~ - W g ~O R <s- ,, - ~ ~ , V ] -.; ~ - - - _~ ":~ c~ R ~c L MELVIN L. SEIBERT, JR., Plaintiff v. FREDERICK G. WHITE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O1- ~~~ CIVIL TERM CIVIL ACTION -LAW NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appeazance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are wazned that if you fail to do so the case may proceed without you and a judgment 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. YOIJ 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. Cumberland County Bar Association Lawyer Referral Service 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Dated: S /~&w~ ~ ``~ ~.~f~ Richazd L. Webber, Jr., Esquire Attorney I.D. No. 49634 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717)249-5373 MELVIN L. SEIBERT, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. O1- y3o6' CIVIL TERM FREDERICK G. WHITE, :CIVIL ACTION -LAW Defendant COMPLAINT NOW comes the plaintiff, Melvin L. Seibert, Jr., by his attorneys, Richard L. Webber, Jr., Esquire and The Law Office of Michael J. Hanft, and files this Complaint, avemng the following: 1. Plaintiff is Melvin L. Seibert, Jr., adult individual residing at 38 Fickes Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Frederick G. White, adult individual residing at 267 Fickes School Road, Yark Springs, Adams County, Pennsylvania 17372. 3. On or about January 24, 2001, Plaintiff and Defendant entered into a written agreement at Plaintiffls residence listed in Paragraph 1 above whereby Plaintiff agreed to loan Defendant the sum of $12,200.00 so that Defendant could pay Ford Motor Credit in full fora 1999 Ford Truck, VIN#1FTNF2157XEE43775 (hereinafter referred to as "the truck.). A copy of the Agreement is attached hereto, labeled as Exhibit 1, and incorporated by reference herein. 4, Ford Motor Credit had been threatening to repossess Defendants truck. 5. Under the terms of the Agreement, full payment was due from Defendant to Plaintiff by April 9, 2001. 6. The parties also verbally agreed that Defendant would deliver the title certificate for the truck to Plaintiff once the title certificate was received from Ford Motor Credit. The parties verbally agreed that Defendant would assist Plaintiff with respect to Plaintiff s business by providing hauling services for Plaintiff. 8. On January 24, 2001, immediately after the signing of the Agreement, Defendant purchased the truck. 9. To date, Defendant has not paid any monies owed to Plaintiff. 10. To date, Defendant has not delivered the title certificate for the truck to Plaintiff as verbally agreed. 11. In early February 2001, Plaintiffloaned to Defendant a CB radio and a cattle shocker. 12. The fair mazket value of the CB is $250.00. 13. The fair mazket value of the cattle shocker is $75.00. 14. Plaintiff has made numerous requests to Defendant to pay the balance in full and to deliver the fitle certificate for the truck to Plaintiff. 15. Defendant has not responded to Plaintiffs requests and Defendant refuses to communicate with Plaintiff. WHEREFORE, Plaintiff respectfully requests judgment in his favor in the amount of $12,525.00, together with costs and other appropriate relief. LAW OFFICE OF MICHAE9L J. H~ANFT gy. 2/' 2 t./oL~~// Richard L. Webber, Jr., Esquir~ Attorney I.D. No. 49634 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 Attorney for Plaintiff VERIFICATION I VERIFY that the statements set forth in the attached Complaint are true and correct to the best of my laiowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904 relating to unswom falsification to authorities. Date: jg ~~ Melvin .Seibert, 7r. P:\User AOlder\Pim~DOa\Gendocs2001\209]-lcompleint.t.wpd Mar 25 OI 02:59p MELVIN SEIHERT 7I7-~~s-szes p.2 - ----- ~, ~e SHERIFF'S RETURN - NOT SERVED CASE NO: 2001-04305 P ~-7MMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IBERT MELVIN L JR VS WHITE FREDERICK G Thomas Kline Sheriff who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT to wit: FREDERICK G unable to locate Him in his bailiwick but was He therefore returns the COMPLAINT & NOTICE NOT SERVED as to the within named DEFENDANT WHITE FREDERICK G PAPER EXPIRED. NEVER RECEIVED REQUIRED FUNDS TO DEPUTIZE ADAMS COUNTY. Sheriff's Costs: So answ rs: / Docketing 18.00 Service .00 " Affidavit .00 R. THOMAS KLINE Surcharge 10.00 SHERIFF OF CUMBERLAND COUNTY .00 28.00 MICHAEL HANFT 08/24/2001 Sworn and subscribed to before me this .Z g~ day of o21s-c9 / A . D . " ""~~"'' ""~7 Prot onotary -,~. MELVIN L. SEIBERT, JR., Plaintiff v. FREDERICK G. WHITE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O1- y3O~' CIVIL TERM CIVIL ACTION -LAW NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) dais 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 judgment 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. Cumberland County Bar Association Lawyer Referral Service 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Dated: S //S wi '~ `~ /( ,,,_~~~~ Richard L. W bber, Jr., Esquire Attorney I.D. No. 49634 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717)249-5373 ~`Ftt1~ COPY FROM R~C(~® in Testlmonp whereof, I here urroo sat my and tha of said rt Carlhde. rnls ~ ~'C~y ®rothr€a;ofi3f v MELVIN L. SEIBERT, JR, Plaintiff v. FREDERICK G. WHITE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O1- CIVIL TERM CIVIL ACTION -LAW COMPLAINT NOW comes the plaintiff, Melvin L. Seibert, Jr., by his attorneys, Richard L. Webber, Jr., Esquire and The Law Office of Michael J. Hanft, and files this Complaint, averring the following: 1. Plaintiff is Melvin L. Seibert, Jr., "adult individual residing at 38 Fickes Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Frederick G. White, adult individual residing at 267 Fickes School Road, York Springs, Adams County, Pennsylvania 17372. 3. On or about January 24, 2001, Plaintiff and Defendant entered into a written agreement at Plaintiff's residence listed in Paragraph 1 above whereby Plaintiff agreed to loan Defendant the sum of $12,200.00 so that Defendant could pay Ford Motor Credit in full fora 1999 Ford Truck, VIN#1FTNF2157XEE43775 (hereinafter referred to as "the truck.). A copy of the Agreement is attached hereto, labeled as Exhibit 1, and incorporated by reference herein. 4. Ford Motor Credit had been threatening to repossess Defendants truck. 5. Under the terms of the Agreement, full payment was due from Defendant to Plaintiff by Apri19, 2001. 6. The parties also verbally agreed that Defendant would deliver the title certificate for the truck to Plaintiff once the title certificate was received from Ford Motor Credit. 7. The parties verbally agreed that Defendant would assist Plaintiff with respect to Plaintiffls business by providing hauling services for Plaintiff. 8. On January 24, 2001, immediately after the signing of the Agreement, Defendant purchased the truck. 9. To date, Defendant has not paid any monies owed to Plaintiff. 10. To date, Defendant has not delivered the title certificate for the truck to Plaintiff as verbally agreed. 11. In eazly February 2001, Plaintiff loaned to Defendant a CB radio and a cattle shocker. 12. The fair market value of the CB is $250.00. 13. The fair mazket value of the cattle shocker is $75.00. 14. Plaintiff has made numerous requests to Defendant to pay the balance in full and to deliver the title certificate for the truck to Plaintiff. 15. Defendant has not responded to Plaintiff's requests and Defendant refuses to communicate with Plaintiff. WHEREFORE, Plaintiff respectfully requests judgment in his favor in the amount of $12,525.00, together with costs and other appropriate relief. LAW OFFICE OF MICHAEL J. HANFT By: ~f 2 1../oL~~~~ Richard L. Webber, Jr., Esquir~" ) Attorney I.D. No. 49634 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717)249-5373 Attorney for Plaintiff VERIFICATION I VERIFY that the statements set forth in the attached Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of I8 Pa. Section 4904 relating to unsworn falsification to authorities. Date: ~g 00 ~ Melvin .Seibert, Jr. F:\User Falder\Finn Docs\Gendoc52001\209]-ICanplaint.I.wpd Mar 26 O1 02:59p MELVIN SEIHERT 717-~~s-6zea p.2 MELVIN L. SEIBERT, JR., Plaintiff v. FREDERICK G. WHITE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4305 CIVIL TERM CIVIL ACTION -LAW PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint that was filed in this matter. LAW OFFICE OF MICHAEL J. HANFT Date; Gr (I ~ ~0 / By: "D ~1~:. -~ • ~/,~,~J'~/ Richard L. Webber, Ji., Esquire Attorney I.D. No. 49634 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 F:\Uur FOlder\I+irm Docs\Geudace2001\209]-lpraecipe.l.wpd c, = c -- ; -- r~ 'T3 LFi ?t t1l C1i -C7 - 7 J:: G t,-. _ _ Y (- .. =1 :. K~ .V {tit -G a.., -. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-04305 P CON~MONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND s SEIB$RT MELVIN L JR VS WHITE FREDERICK G 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: WHITE FREDERICK G but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of ADAMS County, Pennsylvania, to serve the within COMPLAINT & NOTICE On September 26th 2001 this office was in receipt of the attached return from ADAMS Sheriff's Costs: Docketing 18.00 out of County 9.00 Surcharge 10.00 Dep Adams Co 30.60 .00 67.60 09/26/2001 MICHAEL HANFT ans rs: ~=~~~ R. Thomr as Kline Sheriff of Cumberland County Sworn and subscribed to before me this a P ~ day of ~trr~/ A/n.~D . ~ ~`- Prothonot r ~~~.,~ .. In The Court of COmm®n Pleas of Cumberland. County, Pennsylvania Now, September 20, 2001 hereby deputize the Sheriff of County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit ®f Service Now, within upon at by handing to a and made known to copy of the original the contents thereof. So answers, Sheriff of Sworn and subscribed before me this day of , 20 I, SHERIFF OF CUMBERLAND COUNTY, PA, do 20 , at ,o'clock M. served the COSTS SERVICE _ MILEAGE _ AFFIDAVIT County, PA DATE.RECEIVLD SHERIFF'S ®EPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, GETTYSBURG, PA 17325 DATE RROCF_SSED INSTRUCTIONS: See "INSTRUCTIONS FOR SERVICE OF PROCESS BV SHERIFF SERVICE THE SHERIFF" on the reverse of the last (No. 5) copy of this form. Please PROCESS RECEIPT, end AFFIDAVIT OF RETURN ~ not Stec ea~ny copies.nACSD Nlliry~m all copies. 1. PLAINTIFFS! 2. COURT NUMBER MQ.UIN L. SIvIBERT JR. O1-4305 Civil Term 3. DEFENDANT/SI 4. TYPE OF WRIT OR COMPLAINT: FREDERICK G. WHITE Reinstated Co taint (Civil) SERVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD. Frederick G. White 6. ADDRESS (Street or RFD, Apartment No., City, Boro, Twp., Slate and ZIP CODE) AT 267 Fi:ckes School Road, York Springs, PA 7. INDICATE UNUSUAL SERVICE: ^ PERSONAL ^ PERSON IN CHARGE O DEPUTIZE ~ CERT. MAIL ^ REGISTERED MAIL O POSTED O OTHER Now, , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof'according to law. This deputation being made at the request and risk of the plaintiff. SHERIFF OF ADAMS COUNTY B. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN-Any tleputy sheriff lerying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, aher notityinq person of lery or attachment, without liability on the pert of such tleputy or the sheriff to any plaintiff herein far any loss, destruction or removal of any such property before sheriff's sale thereof. 9. SIGNATURE at ATTORNEY or other ORIGINATOR requesting service on behalf of: 10. TELEPHONE NUMBER 11. DATE Richard L. Webber Jr. Es ~ PLAINTIFF (717) 249-5373 f f q• ^ DEFENDANT SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE 12. I acknowledge receipt of the writ SIGNATURE of Authorized ACSD Deputy or Clerk antl TNIe 13. Date Received 14. Ezpiretion /Hearing date or complaint as indicatetl above. 15. I hereby CERTIFY and RETURN that I t~have personally served, ^ have served person in charge, ^ have legal evidence of service as shown in "Remarks" (on reverse) ^ have posted the above described property with the wrk or complaint described on the individual, company; corporation, etc., at the address shown above or on the individual, company, corporation, etc., at the address inserted below by handing/or Posting a TRUE and ATTESTED COPY therof. 16. O I hereby certify antl return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., nametl above. (See remarks below) W~ 17. Nema end title of IhtlividU81 Served t8. A person of suitable age and discretion Rfiad Order Frederick G. White plecero idi~en t^he tlefentlant'e usual ~ 19. Adtlress of where 8ervetl (complete only if different than shown above) (Street or RFD, Apartment No., City, Boro, Twp., 20. Date of Service 21. Time State and ZIP CODE) 9/24/2001 6:37PM 22. ATTEMPTS Data Mlles Dep.lnt. Date Mlles Dep.lnt. Date Miles Dap.lnt. Date Miles Dep.lnt. Date Miles Dep.lnt. 23. Advance Costs 24. 25. 26. 27. Total Costa 26.X70SRHMBCMI[REFUND X50.00 Fm.Att #3470 $30.60 Pd. 9/25/01 $119.40 Ck. #6002 SO ANSWER . AFFIRMED end subscribed to before me this By DeD. Sherlif) IPbeae P t or Type) Date day of James W. Mul er 9 24 2001 Signature of Sheriff Date RAYMOND W. NEWMA[Q 9 24 2001 ProtMndvylDepulyMOtery Public SHERIFF OF ADAMS COUNTY MY COMMISSION EXPIRES I ACKNOWLEDGE RECEIPT OF THE SHERIFF'S flETURN SIGNATURE 39. Date Received OF AllTFIORRED ISSUING AUTHORITY AND TITLE. PROTHONOTARY SHERIFF'S RETURN OF SERi/i(:E ( ) (1) The defendant by mailing to the within named by mall, retun•a receipt requested, postage prepaid, on the ___ a true and attested copy thereof at _ The return receipt signed by __ __ _ defendant on the __ __~ made a part of this return. (2) Outside the Commonwealth, pursuant to Pa. R.C.P. 405 (c) and attested copy thereof at is hereto attached and {i) (2), by walling a true In the tollowing manner: { ) (a) to the defendant by ( )registered ( ) certified wait, return receipt requested, postage prepaid, addressee only on the _ _ ___ __ __ said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities that Defendant refused to accept the same. The returned receipt and envelope is attached hereto and made a part of this return. ,4nd thereafter: { ) (b) To the defendant by ordinary mail addressed to defendant at ;,awe address, with the return address of the Sheriff appearing thereon, on the I further certify that after fifteen (15) days from the nmaillnd date, H have rroot reoeiued said envelope back from the Postal Authorities. A certificate of rreailing is hereto attached as a proof of mailing. (3) By publication in the Adams County Legal Journal, a weekly publication of general circulation in the County of Adams, Commonwealth of Pennsylvania, and the Gettysburg Times, a daily newspaper published in the County of Adams, Commonwealth of Pennsylvania and having general circulation in said County for _________.,_____________~ successive weeks of _ _ _ _.__ _ _The Affidavits from said Adams County Legal Journal and Gettysburg Times, are hereto attached and made part of this return. (4) By mailing to by, .mail, return receipt requested, postage prepaid, a true and attested copy thereof at `Aufh'+Sfit)~s marked is hereto attached. on the returned by the Postal { ) (5) DATE„-0EIVLD SHE~R1fF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, GETTY$BURG, PA 17325 DATE PROCESSED INSTRUCTIONS: See "INSTRUCTIONS FOR SERVICE OF PROCESS BY SHERIFF SERVICE THE SHERIFF" on the reverse of the last (NO.5) copy of this form. Please PROCESS RECEIPT, end AFFIDAVIT OF RETURN '~ not d~~ ny espies nACSO ENIV jof alP Copies. 1. 3. SERVE AT 5. NAME OF INDIVIDUAL, COMPANY, i!E`E~C''Y"14~EC ~x, i:7"ill;E:. SERVICE OR DESCRIPTION OF PROI 6. ADDRESS (Street or RFD, Apanment No., City, Boro, Twp., State and ZIP CODE) 2.E7f ~ac~:,es St;liae7 zdsd, Yo~it S~x•~Tlgs, ~Fi OR 7. INDICATE UNUSUAL SERVICE: ~ PERSONAL ^ PERSON IN CHARGE O DEPUTIZE O CERT. MAIL ^ REGISTERED-MAIL O POSTED O OTHER Now, , I, SHERIFF OF ADAMS COUNTY, PA:, do hereby deputize the Sheriff of County to execute this Writ and make return therof according: to law. This deputation being made at the request and risk of the plaintiff. ' SHERIFF OF ADAMS COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N. B: WAIVER. OF-WATCHMAN-Any deputy sheriN levying upon or attaching any propany Lnder within wdt may leave same without a watchman, in custody of whomever-is found in possession, after notifying person of levy or attachment, with_ out liability on the part of such deputy or the sheriff to any~plaintiH herein for any loss, destruction or removal of.any such propany before sheriff's sale thereof. 9. SIGNATURE of ATTORNEY or other ORIGINATOR requesting service-on behalf oi: ~- -; - - -10.,7ELERHONE NUMBER -~` ~. ; 11. DATE - ~ ~ PLAINT)FF / {:I..n..n ri3T{:E La 611E17~E'T.'p -.iC.,~ L,.4C,~, DEFENDANT (71 /)L~'~.~°S.SJ+ __ - .7rNVC QGLV fie' 1'Vrl-V JG Vr @Il Gpllt'r Wr\4^ - uv rw r. ~mrre oew ~~ If1'N WING 12. I acknowledge receipt of the writ SIGNATURE of Authorized ACSD Deputy dr Clark-aed-Title 13. DateRedeived 14. Expiration /Hearing date or complaint es indicated above. ~ - - 15. I hereby CERTIFY and RETURN that I C.~have personally served, ^ have served person in charge, ^ have legal evidence of service as shown in "Remarks" (on reverse) ^ have posted the above described propany with the writ or complaint described on the Individual, company, corporation, etc., at the address shown above or on the individual, company, corporation, etc., at the address insenetl below by handing/or Posting a TRUE and ATTESTED COPY therof. 16. ^ I hereby ceniN and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., named above. (See remarks below) 17. Name and title of individual served - ~ - te. A parson or suitable age and discretion Read Order - - then residing in the delendant's usual- - - ^ Place.c6abode. ~ 19. Address of Where'served (wmplete only if different than shown above) (Street or RFD, Apartment No., Ciy, Boro, Twp., 20. Date of Service 21. Time State and ZIP CODE) - 22. ATTEMPTS Date - Mllsa Dap.lnt. Date Mlles Dep.lnt. Date Miles Dep.lnt. Date Milea Dep.lnt. Date Miles Dep.lnt. 23. Advance Costs 24. 25. 26. 27. Total Coss - 23.,~Q,Q$~{~¢L,FFQ~REFUND !aUAUK3 ~'m.Att: s4dQl $3~.uU Pd: ~3 25'C1 ~1~).40 i.k, m`hu02 - - - SO ANSWER. AFFIRMED and subscribed to before me this - ~ ~ By ~~~@aee, Pr t or Type) ~ Date day or ~xi~~~e ~` e ~° f I ~tLra of ShaFilF " ~`° Date I ) ;,c ", .l ~~= ~ ~ ;~ ~l ~f.r ProthonotsrylDeputyMatery Public - ' °~ J§FfERIFP~OF ItDYJAB COUN~'1" MY COMMISSION.EXPIRES ~ )s„ ' '' " I ACKNOWLEDGE RECEIPT OF THE BNERIFF'S RETURN SIGNATURE _ ~ 39. Date Received OF AUTHORIZED ISSUING AUTHORITY AND TITLE. ~- lf~°t#.~QS ~2~1 ~ 2'81"C'7 4. TYPE OF WRIT OR COMPLAINT: ~~'~~~~~-.'~ ~l'fi. ~~ <-. ~tiERIFF°~ RETt9RN ~~ ~~VI~ (t)The defendant by malting to the within named -mail, return receipt raque~sted, postage on the a true and attested copy thereof at The return receipt signed by _ defendant on the _ _ _ made a part of this return. ( ) (2) Outside the Commonwealth, pursuant to Pa. and attested copy thereof at ___ is hereto rattaohed and R,C,~. 4tN5 (c:) (;) {b), h'~J ftva~ilfng a true in the following manner: ( ) (a) to the defendant by ( }registered { } ::ertifaetii aara9l, return receipt requested, postage prepaid, addressee only on the - _ _ _ _ said receipt being returned 1VOT signed kay° defendant, bu# c^ri#t~ a rio`a2fon i;~rr the t:'ostai .Authorities that Defendant refused to accept the same. The returned rt=ceipt a~i-;d emrelope is iattacq~od here;fo and made a part of this return. And thereafter: { } (b}'Co the defendant by ordinary mail addressed to defendant at €ar,~e acfdre;;s,'tv'sth the ;etL;rrF address of the Sheriff appearing thereon, on the I further certify that after fifteen (t 5) days from the n°~aiiane; d~te~; l h'~v~ not res;esiv~ed ~~said envelope back from the Posta! Authorities. ~. oertif3cate of Artiailinaq i~s hs>~re~~t~;ri attaoiaecM aas a proof of mailing. ( ) { 3) 8y publication in the Adams County Legal Journal, a weekly pubii,:a£'sor. of geeriraf, circulation 'sn the County of Adams, Commonwealti7 of Pennsylvan6~a, and ttae Gettysburg Times, a drily, .newspaper published in the County of Adams, Cummonwe:altl•s of ir'a nnsylvania and having gene, a1 circulation in said County for--_--_-- ------.--------_,__..--- ---------_-- successive weeks of _ -_-.-__,_--_- _ _ __ _ _ ___ _ __ _ _ - -'f°t~e Affidavits from said Adams County Legal ,iournal and Gettysburg Times, are faereto attached and made part of this return. { ) { 4) By mailing io_ by ^maAl, return receept requested, postage prepaid, _- on the _-_..-_-__-_--...~_~.___. ~~__-_- a true and attested copy thereof at `_____-_-_.,_ _._ The _-_--~ __ returned by the postal Authorities marked _~__ i__..^--__ _~_____-_-- is hereto attached. { ) { 5) Other ----- -------- - -- .~ ~. ~ ~. DATE.,9ECEIV~LD ~ - DATE PROCESSF_D SHERIFF'S ®EPARTM-ENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, GETTYSBURG, PA 17325 INSTRUCTIONS: See "INSTRUCTIONS FOR SERVICE OF PROCESS BY SHERIFF SERVICE THE SHERIFF" an the reverse of the last (NO.5) copy of this form. Please PROCESS RECEIPT, atld AFFIDAVIT OF RETURN Sype or pdnt fegfby, irrsorfrtg readaWliry w au copies. Do not detach any copies. ACSD ENV.X 1. PLAINTIFF/S/ 2. COURT NUMBER iil/i~ti'~ty i.. 5ial3~'t' JI;, 01-4~~ Cavil -i'e;~;:1 3. DEFENDANT/S/ 4. TYPE OF WRIT OR COMPLAINT: ?;~ ~:i~Czdi ~l Cs. iti~~1,~1'v t(eT.ti3 t:aC~ t40Rr`t-X31331: t,°..;i.'J13.1 SERVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD. ~'`recerici:. ~~. ~fsta 6. ADDRESS (Street or RFD, Apartment No., City, Boro, Twp., State and ZIP CODE) AT ~'~J r'i;:~;e~; Sct3oe~ ~€33ef, Y'crrk we~:°xn35 ~Ec 7. INDICATE UNUSUAL SERVICE: ^ PERSONAL ~ PERSON IN CHARGE O DEPUTIZE O CERT. MAIL ^ REGISTERED MAIL O POSTED ~ OTHER Now, , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County toYexecute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. 8. SPECIAL INFORMATION SERVICE. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.e. WANER OF WATCHMAN-Any deputy sheriff levying upon or attaching any property under within writ may. leave same wthout a watchman, in custody of whomever is found in possession, ader notifying person of levy or attachment, without liability on the pad of such deputy or the sheriff to - any plaintiff herein for any loss, destruction or removal of any such properly beore sheriN's sale thereof. 9. SIGNATURE of ATTORNEY ar other ORIGINATOR requesting service on behalf of: - ~ t0: TELEPHONE NUMBER - - 11. DATE y~~ y~~, ~!] PLAINT1kF t t t1Cs3a T'ts i.,, C~t~i3iJ~i , .3T. 3 L~tlCja ^ DEFENDANT (717) LEF`:~ 3~~J ...~. SPAC BEL01N FOR USE OF SHERIFF ONLY - DO NOT WRI'~E BELOW THIS LINE 72. f acknowledge receipt"of the writ SIGNATURE of-Authorized ACSD Deputy or Clerk and Title 13. Date Received 14. Expiration /Hearing date or complaint as indicated above. 15. I hereby CERTIFY and RETURN that 1 f'~iheve personally served, ^ have served person in charge, ^ have legal evidence of service es shown in "Remarks" (on reverse) ^ have posted the above described property with the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company, corporation, etc., at the address inseded below by handing/or Posting a TRUE and ATTESTED COPY therof. 16. ^ I hereby tartly and return a NOT FOUND because I em unable to locate the individual, company, corporation, etc., named above. (See remarks below) ya i 17. Name and tale of individual 98Natl - 1a. A person or suitable age and discretion Read Order t'r~@~2CK U. W~7$ C~: - - .- - = - , plus m aoogde o aefendanns eaeei ~ 19. Addreae of where served"(complete only if different than shown above) (Street or RFD, Apartment No., Ciry, Boro, Twp., 20. Date of Service 21. Time State end ZfP CODE) 'sI Ltitd ~~IJ1 ia. 7r'I'a 22. ATTEMPTS Date Mlles Dep.lnt. Data Miles Dep.lnt. Date Mllec Dep.lnt. Date Mlles Oep.lnt. Data Miles Dep.lnt. 23. Advance Casts 24. 25. 28. 27. Total Costs 28ltDHAli REFUND .Si3.(X3 ~at.Atty ~3tt7(} ~J'~a!(71 ~3G bt} i'd ~11t3 ~J C k tuN ;`~ . . . . . i r SO ANSWEq. - AFFIRMED and subscribed to before me Mis "~ f' `~~~'~' Bf!- igaw Pr nt or TYPe) Data day of Ja: S ~ ~`°"., *f' `1! 3~ ~i.`t):L ",~ of hb~N °', c~ [q, ure S • n Da te p~ ~1 ~~~ ~~,,)) ~~ y yy ~ rr~ I 11t~9)(i~AlRY4!•" IiY v ~>!LlM[ 'ild ;, !: j / Jl ~n}~ L.'+IVS PrpthonororyNepuryMOtery Publlc ~7~a ~~ - - „°sgERIFOF A~b~MB TOUNTK-~ MY COMMISSION EXPIRES -', Via= ~y'g f 9.: I ACKNOWLEDGE RECEIPT OF THE SNERIFF'S RETURN SIGNATURE - ' ° '",~ R 39. Date Received OF AUTHORIZED ISSUING AUTHORITY AND TITLE. , i. . , ~ ~ ..,. -sV, (~,~E. ~. -.,. Y ~ ._._, ....... SHERIFF'S RETURN OF SERVICE ( ) (1)The defendant by mailing to the within named _ mail, return receipt requested, postage on t:he a true and attested copy thereof at The return receipt signed by _ defendant on the _______ is hereto attached and made a part of this return. ( ) (2) Outside the Commonwealth, pursuant to Pa. R.C.P. 4(15 (c) (1) (2), by mailing a true and attested copy thereof at in the following manner: (a) to the defendant by { )registered { )Dart°sfied mail, return receipt requested, postage prepaid, addressee only on the _...~______ _ said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities that Defendant refused to accept the same. The returned receip4 and envelope is attached hereto and made a part of this return. And thereafter: {b) To the defendant by ordinary mail addressed to defendant at same address, with the return address of the Sheriff appearing thereon, on the ___ __ ______ I further certify that after fifteen (15) days from the malting date, I have not received said envelope back from the Postal Authorities. A certificate of mailing is hereto attached as a proof of mailing. ( ) (3) By publication in the Adams County Legal Journal, a weekly publication of general circulation in the County of Adams, Commonwealth of Pennsylvania, and the Gettysburg Times, a daily newspaper published in the County of Adams, Commonwealth ofi Pennsylvania and having general circulation in said County for _______ __ _ successive weeks of __ _ __ _ The Affidavits from said Adams County Legal Journal and Gettysburg Times, are hereto attached and made part of 4his return. { ) (4) By mailing to - _ by mail, return receipt requested, postageprepaid, a true and attested copy thereof at on the The __returned by the Postal Authorities marked _____ is hereto attached. ( ) (5) Other NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF MELVIN L. SEIBERT, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2001-04305 FREDERICK G. WHITE, Defendant PRAECIPE FOR WITHDRAW AND ENTRY OF APPEARANCE OF COUNSEL OF RECORD TO THE PROTHONOTARY: Please withdraw the appearance of RIGI3ARD L. WEBBER, ESQUIRE, as attorneyof record for Plaintiff, MELVIN L_SEIBERT, JR, in this matter. November ~, 2004 ~~C/Cii.~.t~ ~ - ~~2~%L„~~%~/ RICHARD L. WEBBER, ESQUIRE (/~ Weigle & Associates 126 East King Street Sbippensburg, PA 17257 717-532-7388 SUPREME COURT ID #49634 Please enter the appearance of NATHAN C. WOLF, ESQUIRE, as attorney for the Plaintiff in this matter. November 3 , 2004 C. WgLF, ESQUIRE a er Street, Suite 201 COURT ID #87380 ti> ~~ ~~ .~- :; ~~ ~, f;~; _, -~=-,-, M '`' ~::; - c~ ~-° =' _=,= ' << > a':1 i ~.1 L.. L4! .. y' c