HomeMy WebLinkAbout99-03947ry
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HOWARD C. GOUSE,
Plaintiff
V.
MARINO R. MAGARO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. S 1999 -3
9?7 C?
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PRAECIPE FOR WRIT OF SUMMONS
TO THE PROTHONOTARY:
Please issue a Writ of Summons in the above-captioned action to be served by the
Sheriff on the Defendant at the following address:
Marino R. Magaro
816 South Humer Street
Enola, PA 17025
The address of the Plaintiff is 400 Adams Street Extension, Enola, PA, 17025.
Respectfully submitted,
Date: ,?(?,Jfi , 1949
ADLE VAL
By
ROBERT F. CLARAVAL, ESQUIRE
125 Locust Street
P.O. Box 11933
Harrisburg, PA 17108-1933
(717) 233-4780
Supreme Court ID# 19222
Attorney for Plaintiff
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Commonwealth of Pennsylvania
County of Cumberland
Howard C. Gouse
400 Adarrs Street Extension
Enola, PA 17025
Va.
Marino R. Magaro
816 South Huner Street
Enola, PA 17025
Court of Common Pleas
No. __ 99_ 3947_ Civil ------------------ 19
III ---Civil -Action- --Law
--------------------------------
To ---amino l3,-_Md9 X52---------
You are hereby notified that
Howard C. Gouse
•------------------------------------------------°-----------------------------------------------
the Plaintiff ha S commenced an action in ---------------------------------
against you which you are required to defend or a default judgment may be entered against you.
(SEAL)
Curtis R' ---------------------
Prothonotary
Date June 28,
------- - ------------- 19_92 By ¢ x -3
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Deputy
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HOWARD C. GOUSE,
Plaintiff
V.
MARINO R. MAGARO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3947 CIVIL
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PRAECIPE FOR APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of Richard H. Wix, Esquire, of the
firm of Wix, Wenger & Weidner, on behalf of Defendant Marino R.
Magaro in the above-captioned matter.
WIX, WENGER & WEIDNER
By ??Q N
Richard H. Wix, I.D. #07274
Attorneys for Defendant
4705 Duke Street
Harrisburg, PA 17109-3099
(717) 652-8455
Dated: July 9, 1999
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03947 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GOUSE HOWARD C
VS.
MAGARO MARINO R
JODY SMITH Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within WRIT OF SUMMONS was served
upon MAGARO MARINO R the
defendant, at 9:50 HOURS, on the 1st day of July
1999 at CUMBERLAND CO. SHERIFF'S DEPT. 1 COURTHOUSE SQUARE
Carlisle, PA 17013 ,CUMBERLAND
County, Pennsylvania, by handing to MARINO R. MAGARO
a true and attested copy of the WRIT OF SUMMONS
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing
Service
Affidavit 18.00
9,92
.00
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Surcharge 8.00 omas iz ne; 5 eri r
$3b.32 O
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BE
RT F. CLARAVAL
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1/1999
by
epu y S eri
Sworn and subscribed to before me
this 1,4?+- day of
19? A.D. 'IN - a. rjj-
1 ono ary
HOWARD C. GOUSE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-3947 Civil
CIVIL ACTION -LAW
MARINO R. MAGARO,
Defendant : JURY TRIAL DEMANDED
AND NOW, this day of r '- - y 12000 a
Rule is hereby issued on the Plaintiff/Respondent Howard Gouse why Robert F. Claraval should not
be permitted to withdraw as his attorney in this matter.
Service of this Rule shall be made upon Mr. Gouse and counsel for the Defendant by
regular mail.
Rule returnable days from date of service.
BY THE COURT:
as-oo
Judge 13
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HOWARD C. GOUSE,
Plaintiff
V.
MARINO R. MAGARO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3947 Civil
CIVIL ACTION - LAW
: JURY TRIAL DEMANDED
PETITION TO WITHDRAW AS COUNSEL
1. The Plaintiff in the above matter is Howard Gouse who resides at 400 Adams
Street Extension, Enola, Pennsylvania, 17025.
2. On July 30, 1998 Mr. Gouse retained Robert F. Claraval, Esquire as his
counsel under a contingency fee agreement to pursue those persons responsible for a motor vehicle
accident which occurred on September 4, 1997.
3. Attorney Claraval investigated the crash, obtained chiropractic records, filed
a Writ of Summons and negotiated a settlement with State Farm Insurance Companies who is the
carrier for the Defendant.
4. Mr. Gouse has now revoked his agreement to settle the case for the amount
previously agreed upon.
5. Accordingly, Robert F. Claraval, Esquire cannot continue to represent Mr.
Gouse and has advised him of the same.
WHEREFORE, it is respectfully requested that this Honorable Court issue an Order
permitting Robert F. Claraval to withdraw as counsel. A proposed order is attached as Appendix
A. In the alternative, a Rule to Show Cause is attached as Appendix B.
Respectfully submitted;
Date: d
ADLER & CLARAVAL
By
Robert F. Claraval, Esq.
125 Locust Street
P.O. Box 11933
Harrisburg, PA 17108-1933
(717) 233-4780
Attorney I.D. #19222
Attorney for Plaintiff
HOWARD C. GOUSE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-3947 Civil
MARINO R. MAGARO, :CIVIL ACTION -LAW
Defendant JURY TRIAL DEMANDED
CERTIFICATE OF S RVI
I hereby certify that I have this day served a true and correct copy of the attached
Petition to Withdraw as Counsel by first class mail, postage prepaid, addressed to the following
persons:
Howard Gouse
400 Adams Street Extension
Enola, PA 17025
Richard H. Wix, Esq.
Wix, Wenger & Weidner
4705 Duke Street
Harrisburg, PA 17109-3099
ADLE rR& CLARAVAL
Date: *00 BY t? {116 ??? ? (?Q1C<Ilbo
DENISE I. WILLIAMS, Secretary
For Robert F. Claraval
HOWARD C, GOUSE,
Plaintiff
V.
MARINO R. MAGARO,
Defendant
AND NOW, this
IN THE COURT' OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3947 Civil
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
day of
2000 it
is hereby ORDERED that Robert F. Claraval, Esquire is permitted to withdraw as counsel for
Plaintiff in the above captioned action.
BY THE COURT:
Judge
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IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
HOWARD C. GOUSE,
Plaintiff
V.
MARINO R. MAGARO,
Defendant
File No. 99-3947 Civil
PRAECIPE AND RULE TO FILE
R A COMPLAINT
A BILL OF PARTICULARS
TO THE PROTHONOTARY/CLERK OF SAID COURT:
Issue rule on Plaintiff to file a Comp]a'nr
in the above case within twenty days after service of the rule or
suffer a judgement of non pros.
DATE: March 8, 2000 Signature:
Print Name: Richard
Attorney for: Defendant
Address: 4705 Duke
Harrisburg. PA 17109-1099
Telephone No: (717) 652-8455
Supreme Court ID No.: 07274
m 1 n7.4n aOGC,
NOW, II IMCJ'? , 29: _/,?RULE ISSUED AS ABOVE.
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Prothonotary
By:
Deputy
(NOTE: File in duplicate)
PROTHON.-12
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HOWARD C. GOUSE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-3947 Civil
CIVIL ACTION -LAW
MARINO R. MAGARO,
Defendant JURY TRIAL DEMANDED
AND NOW, this 30A day of kp 2000 it
is hereby ORDERED that Robert F. Claraval, Esquire is granted permission to withdraw as counsel
for Plaintiff in the above captioned action by the filing of a Praecipe in this matter.
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HOWARD C. GOUSE, -
Plaintiff
V.
MARINO R. MAGARO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3947 Civil
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
1. On February 15, 2000 Robert F. Claraval filed a Petition to Withdraw as
counsel in the above captioned matter.
2. On February 22, 2000 Judge Guido issued his Rule to Show Cause, a copy
of which is Appendix A, providing 10 days for Mr. Gouse to respond.
3. A copy of the Order was served by regular mail upon Mr. Gouse by letter
dated February 24, 2000.
4. Mr. Gouse verified receipt of the Order by telephone call to Robert F.
Claraval's office.
5. As of the date of the filing of this Motion Mr. Gouse has not responded in any
way.
WHEREFORE, it is respectfully requested that this Honorable Court issue an Order
permitting Robert F. Claraval to withdraw as counsel. A proposed order is attached as Appendix
B.
Respectfully submitted;
ADLER & CLARAVAL
?I O o
Date: 2--7/ By ?W
Robert F. Claraval, Esq.
125 Locust Street
P.O. Box 11933
Harrisburg, PA 17108-1933
(717) 233-4780
Attorney I.D. #19222
Attorney for Plaintiff
HOWARD C. GOUSE,
Plaintiff
V.
MARINO R. MAGARO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3947 Civil
CIVIL ACTION -LAW
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I hereby certify that I have this day served a true and correct copy of the attached
Motion to Make Rule Absolute by first class mail, postage prepaid, addressed to the following
persons:
Howard Gouse
400 Adams Street Extension
Enola, PA 17025
Richard H. Wix, Esq.
Wix, Wenger & Weidner
4705 Duke Street
Harrisburg, PA 17109-3099
ADLER & CLARAVAL 1 1
Date: ?a) By ?? ?1 Cti rvv?
DENISE I. WILLIAMS, Secretary
For Robert F. Claraval
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MAR 3 1 200Q?
HOWARD C. GOUSE,
Plaintiff
V.
MARINO R. MAGARO,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3947 Civil
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
Please with draw my appearance as counsel for Plaintiff Howard C. Gouse in the
above captioned action pursuant to Judge Edward Guido's Order dated April 3, 2000
Respectfully submitted;
Date: A ?n c / o a oc o
ADLER & CLARAVAL
By- Robert F. C araval, Esq.
125 Locust Street
P.O. Box 11933
Harrisburg, PA 17108-1933
(717) 233-4780
Attorney I.D. #19222
Attorney for Plaintiff
HOWARD C. GOUSE,
Plaintiff
V.
MARINO R. MAGARO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3947 Civil
CIVIL ACTION -LAW
JURY TRIAL DEMANDED
I hereby certify that 1 have this day served a true and correct copy of the attached
Praecipe to Withdraw as Counsel by first class mail, postage prepaid, addressed to the following
persons:
Howard Gouse
400 Adams Street Extension
Enola, PA 17025
Richard H. Wix, Esq.
Wix, Wenger & Weidner
4705 Duke Street
Harrisburg, PA 17109-3099
ADLER & CLARAVAL
Date: I? VU By IJom G 1,V tM ???t 11u1
DENISE I. WILLIAMS, Secretary
For Robert F. Claraval
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HOWARD C. GOUSE, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
Plaintiff,
VS. No. 99 - 3947
MARINO R. MAGARO,
Defendant. CIVIL ACTION - LAW
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Plaintiff, Howard C. Gouse, in the
above-captioned matter
Respectfully Submitted,
IRA H. WEINSTOCK, P.C.
800 North Second Street
Harrisburg, PA 17102
Phone: 717-238-1657
By: I t
JOHN B. DO GHE Y
CERTIFICATE OF SERVICE
AND NOW, thisatr'k day of 2000, I, JOHN B.
DOUGHERTY, Esquire, attorney for the Plaintiff, hereby certify that I served the within
PRAECIPE TO ENTER APPEARANCE this day by depositing the same in the United States
mail, postage prepaid, in the post office at Harrisburg, Pennsylvania, addressed to:
By First Class Mail:
Richard H. Wix, Esquire
WIX, WENGER & WEIDNER
4705 Duke Street
Harrisburg, PA 17109-3099
By: !? [ A. /u?t.i. 'LL-t--
JOHN B. DOUG RTY)
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HOWARD C. GOUSE, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
VS.
MARINO R. MAGARO,
Plaintiff
No. 99 - 3947
Defendant. : CIVIL ACTION - LAW
PRAECIPE
TO THE PROTHONOTARY:
Please mark the above-captioned matter settled, discontinued and ended.
Respectfully Submitted,
IRA H. WEINSTOCK, P.C.
800 North Second Street
Harrisburg, PA 17102
Phone: 717-238-1657
By: 4'L
JOHN B. Dd G :TY
DISCONTINUANCE
AND NOW THIS 1 1 "-day of , 2000, the above-captioned
case is hereby marked settled, discontinued and ended.
PROTHONOTARY:
By: l c r 2 r
CERTIFICATE OF SERVICE
AND NOW, this day ofn t
DOUGHERTY, Esquire, attorney for the Plaintiff, Hereby cy ert I saved tlhe withi
PRAECIPE this day by depositing the same in the United States mail, postage prepaid, in the
post office at Harrisburg, Pennsylvania, addressed to:
By First Class Mail:
Richard H. Wix, Esquire
WIX, WENGER & WEIDNER
4705 Duke Street
Harrisburg, PA 17109-3099
By:??. /?cVt!
HN 13. DOUGHE TY
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