HomeMy WebLinkAbout03-3149WAGMAN CONSTRUCTION, INC.,
successor by Merger to CONSOLIDATED
CONSTRUCTION COMPANY,
3290 Susquehanna Trail North
York, PA 17405-7076
York County
Plaintiff
Vo
R & R ROOFING &
CONSTRUCTION, INC.,
117 Walnutdale Road
Shippensburg, PA 17257
Cumberland County
AND
FIRST SEALORD SURETY, INC.
formerly known as MOUNTBATTEN
SURETY COMPANY,
33 Rock Hill Road
Bala Cynwyd, PA 19004
Montgomery County
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: No. 03"
'.
'.
: CIVIL ACTION - LAW
:
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PRAECIPE FOR WRIT OF SUMMONS
To: Prothonotary
Please issue a Writ of Sununons in ~bove-cap_ti~.
Lemoyne, PA 17043
(717) 975-0600
WAGMAN CONSTRUCTION, INC.,
successor by Merger to CONSOLIDATED
CONSTRUCTION COMPANY,
3290 Susquehanna Trail North
York, PA 17405-7076
York County
Plaintiff
Vo
R & R ROOFING &
CONSTRUCTION, INC.,
117 Walnutdale Road
Shippensburg, PA 17257
Cumberland County
AND
FIRST SEALORD SURETY, INC.
formerly known as MOIYNTBATTEN
SURETY COMPANY,
33 Rock Hill Road
Bala Cynwyd, PA 19004
Montgomery County
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:No.
:
:
: CIVIL ACTION - LAW
:
.
:
.
:
WRIT OF SUMMONS
To: R & R Roofing & Construction, Inc. and
First Sealord Surety, Inc.
yon.
You are notified that Wagman Construction, Inc. has commenced an action against
WAGMAN CONSTRUCTION, INC.,
successor by Merger to CONSOLIDATED
CONSTRUCTION COMPANY,
V.
R & R ROOFING &
CONSTRUCTION, INC.,
AND
FIRST SEALORD SURETY, INC.
formerly known as MOUNTBATTEN
SURETY COMPANY,
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: Civil Action - Law
: No. 03-3149
PRAECIPE TO DISCONTINUE
To: Prothonotary
Please mark the above suit settled and discontinued as to Defendant, R & R
Roofing & Construction, Inc., only.
LAW~
~/~,TARUCH & RCIK
9rard J. Pis~rcik, Esq~"~~.~~
20 Erford Road, Ste 305
Lemoyne, PA 17043
(717) 975-0600
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I, Gerard J. Pisarcik, Esq., hereby certify that on the 21st day of July, 2003, I served
a true and correct copy of the Praecipe to Discontinue by Overnight Courier, upon the following:
First Sealord Surety, Inc
33 Rock Hill Road
Bala Cynwyd, PA 19004
20 Erford Road, Suite 305
Lemoyne, PA 17043
(717) 975-0600
· Attorney for Plaintiff
WAGMAN CONSTRUCTION, INC.,
successor by Merger to CONSOLIDATED
CONSTRUCTION COMPANY,
3290 Susquehauna Trail North
York, PA 17405-7076
York County
Plaintiff
R & R ROOFING &
CONSTRUCTION, INC.,
117 Walnutdale Road
Shippensburg, PA 17257
Cumberland County
AND
FIRST SEALORD SURETY, INC.
formerly known as MOUNTBATTEN
SURETY COMPANY,
33 Rock Hill Road
Bala Cynwyd, PA ! 9004
Montgomery County
Defendants
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
:
: No. 03-3149
:
:
: CIVIL ACTION - LAW
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:
:
:
.
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:
;
:
PRAECIPE TO RE-ISSUE WRIT OF SUMMONS
To: Prothonotary
Please re-issue the Writ of Summons/~ the above-captioned action.
20 Erford Road, Suite 305
Lemoyne, PA 17043
(717) 975-0600
CERTIFICATE OF SERVICE
I, Gerard J. Pisarcik, Esq., hereby certify that on the 5th day of September, 2003,
I served a true and correct copy of the Praecipe to Re-Issue Wdt of Summons by U.S. First Class
Mail, Postage Prepaid, upon the following:
First Sealord Surety, Inc
33 Rock Hill Road
Bala Cynwyd, PA 19004
LAWS, STARUCH & PISARCIK
20 Erford Road, Suite 305
Lemoyne, PA 17043
(717) 975-0600
Attorney for Plaintiff
SHERIFF'S
CASE NO: 2003-03149 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WAGMAN CONSTRUCTION INC ET AL
VS
R & R ROOFING CONSTRUCTION INC
RETURN
- OUT OF COUNTY
Thomas Kline
duly sworn according to law, says, that he made a diligent
and inquiry for the within named DEFENDANT , to wit:
Sheriff or Deputy Sheriff who being
search and
ATTORNEY GENERAL OFFICE OF
but was unable to locate Them
deputized the sheriff of DAUPHIN
serve the within WRIT OF SUMMONS
in his bailiwick.
County,
He therefore
Pennsylvania, to
On September 23rd 2003 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing 18.00
Out of County 9.00
Surcharge 10.00
Dep Dauphin Co 31.50
.00
68.50
09/23/2003
Sheriff of Cumberland County
LWAS STARUCH PISARCIK
Sworn and subscribed to before me
this 2~- day of ~-~
~ A.D.
Prothonotary'
SHERIFF'S
CASE NO: 2003-03149 P
COMMONWEALTH OF PENNSYLVA/qIA:
COUNTY OF CUMBERLAND
WAGMAN CONSTRUCTION INC ET AL
VS
R & R ROOFING CONSTRUCTION INC
RETURN
- OUT OF COUNTY
R. Thomas Kline
duly sworn according to
and inquiry for the within named DEFENDANT , to wit:
KOKEN DIANE ACTING INSUR3~NCE COMMISSIONER
, Sheriff or Deputy Sheriff who being
law, says, that he made a diligent search and
in his bailiwick. He therefore
County, Pennsylvania,
but was unable to locate Her
deputized the sheriff of DAUPHIN
serve the within WRIT.OF SUMMONS
to
On September 23rd , 2003 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing 6.00
Out of County .00
Surcharge 10.00
.00
.00
16.00
09/23/2003
LAWS
So answers:
R. Thomas Kline
Sheriff of Cumberland County
STARUCH PISARCIK
Sworn and subscribed to before me
this 2~ day of
A.D.
Prothonotary
In The Court of C, ommon Pleas of Cumberland County, Pennsylvania
Wa~nan Constr~ction Inc. et al
VS.
R & R Roofing & Construction Inc et al
SERVE: Office of Attorney General No. 03-3149 civil
Torts Litigation Unit
Now, September 11, 2003
, I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of pau~in
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
within
,20 , at o'clock __ M. served the
upon
by handing to
a
and made known to
copy of the original
the contents thereof.
So answers,
Sheriff of County, PA
Sworn and subscribed before
me this day of
,2O
COSTS
SERVICE
MILEAGE
AFFIDAVIT
The Court of Common Pleas of Cumberland County, Pennsylvania
Wa~nan Construction Inc. et al
VS.
R & R Roofing & Construction Inc et al
SERVE: Diane Koken, acting Insurance Cc~missioner No.
03-3149 civil
Now, September !1, 2003
hereby deputize the Sheriff of
, I, SHERIFF OF CUMBERLAND COUNTY, PA, do
Dauphin County to execute this Writ, ti'ds
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
NOW,
within
upon
at
by handing to
a
and made known to
Affidavit of Service
,20 ,at
o'clock M. served the
copy of the original
So answers,
the contents thereof.
Sworn and subscribed before
me this day of
,20
Sheriff of
COSTS
SERVICE
MILEAGE
AFFIDAVIT
CounW, PA
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 255-2660 fax: (717) 255-2889
Jack Lotwick
Sheriff
J. Daniel Basile
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Commonwealth of Pennsylvania
County of Dauphin
AND NOW:September 16,
COMPLAINT
OFFICE OF THE ATTORNEY GENERAL
to KATHY STEHMAN (LEGAL SEC)
of the original
: WAGMAN CONSTRUCTION INC ET AL
vs
: KOKEN DIANE, ACTING INSURANCE
Sheriff's Return
No. 2453-T - -2003
OTHER COUNTY NO. 03 3149
2003 at l:12PMServed the within
upon
by personally handing
1 true attested copy(ies)
COMPLAINT and making known
to him/her the contents thereof at 16TH FLOOR
STRAWBERRY SQUARE
HARRISBURG, PA
17101-0000
Sworn and subscribed to
)efore me this 16TH day of SEPTEMBER, 2003
PROTHONOTARY
SO Answers,
Sheriff's Costs: $31.50 PD 09/15/2003
RCPT NO 182739
HOPKINS
Mary Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 255-2660 fax: (717) 255-2889
Jack Lotwick
Sheriff
J. Daniel Basile
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Commonwealth of Pennsylvania
County of Dauphin
~ NOW:September 16,
COMPLAINT
KOKEN DIANE, ACTING INSURANCE
COMMISSIONER
to LYNNE FITZWATER
of the original
(DEPT COUNSEL)
COMPLAINT
: WAGMAN CONSTRUCTION INC ET AL
VS
: KOKEN DIANE, ACTING INSURANCE
Sheriff's Return
No. 2453-T - -2003
OTHER COUNTY NO. 03 3149
2003 at l:23PMserved the within
upon
by personally handing
1 true attested copy(ies)
and making known
to him/her the contents thereof at INSURANCE DEPARTMENT
13TH FLOOR, STRAWBERRY SQUARE
HARRISBURG, PA 17102-0000
Sworn and subscribed to
)efore me this 16TH day of~EPTEMBER, 2003
PROTHONOTARY
So Answers,
Sheri~of D~p~n-~o~nt y, ~a.
By
Deputy Sheriff
Sheriff's Costs: $31.50 PD 09/15/2003
RCPT NO 182739
HOPKINS
WAGMAN CONSTRUCTION, INC.,
successor by Merger to CONSOLIDATED
CONSTRUCTION COMPANY,
Plaintiff
R & R ROOFING &
CONSTRUCTION, INC.,
AND
FIRST SEALORD SURETY, INC.
formerly known as MOUNTBATTEN
SURETY COMPANY,
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: No, 03-3149
PRAECIPE TO RE-ISSUE WRIT OF SUMMONR
To: Prothonotary
Please re-issue the Writ of Summc In the above-~ed action.
//Gerard J. Pisarcl~, Esq.
/Atty ID~ 39181
/~ 20 Er[ord Road, Suite 305
' Lemoyne, PA 17043
(717)975-0600
CERTIFICATE OF SERVICE
I, Gerard J. Pisarcik, Esq., hereby certify that on the 9th day of October, 2003, I
served a true and correct copy of the Praecipe to Re-Issue Writ of Summons by U.S. First Class
Mail, Postage Prepaid, upon the following:
First Sealord Surety, Inc.
33 Rock Hill Road
Bala Cynwyd, PA 19004
'cE, Esq.
& Pisarcik
20 Erford Road, Suite 305
Lemoyne, PA 17043
(717)975-0600
Attorney for Plaintiff
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2003-03149 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WAGMAN CONSTRUCTION INC ET AL
VS
R & R ROOFING CONSTRUCTION INC
R. Thomas Kline
duly sworn according to law,
and inquiry for the within named DEFENDANT ,
FIRST SEALORD SURETY INC
but was unable to locate Them in his bailiwick.
deputized the sheriff of MONTGOMERY County,
serve the within WRIT OF SUMMONS
Sheriff or Deputy Sheriff who being
says, that he made a diligent search and
to wit:
He therefore
Pennsylvania, to
On October 29th , 2003 , this office was in receipt of the
attached return from MONTGOMERY
Sheriff's Costs:
Docketing 18.00
Out of County 9.00
Surcharge 10.00
Dep Montgomery Co 33.00
.00
70.00
10/29/2003
~. Thomas Kline
Sheriff of Cumberland County
LAWS STARUCH PISARCIK
Sworn and subscribed to before me
this ~ day of)~_~
A.D.
Prothonot ar~; '
SHERIFF'S RETURN
PROTHONOTARY Z- 4399
DEFENDANT: First Sealord Surety Inc.
DOCUMENT SERVED: Civil
INDIVIDUAL SERVED: Marie Kratz
RELATIONSHIP TO DEFENDANT: Person In Charge
DATE AND PREVAILING TIME: Oct. 22, 2003 ~ 08:20
LOCATION: 33 Rock Hill Rd., Bala Cynwyd, PA
Oct. 23, 2003
Notary Public
Sheriff of Montgomery County
Deputy Sheriff
Galluzzo
R. THOMAS KLINE
Sheriff
EDWARD L SCHORPP
Solicitor
OFFICE OF THE SHERIFF
One Courthouse Square
Cadisie, Pennsylvania 17013
RONNY R. ANDERSON
Chief Deputy
JOD¥ S. SMITH
Real Estate Deputy
TO:
Hon. flob~ Durante
Montgomery County Sheriff
Wa~man Construction Inc.
VS
R & R Roofing .& Construction Inc et' al
03-3149 csvll
De~ Sir:
Enclosed please fred_ writ of su~ons, reissued
First Sealord Surety Inc. f/k/a Mountbatt.~n Surety Company
to he served upon~ _
33 ~ock Hill Road
B~la Oy~wyd, PA. 19004
PLACE OF SERV!O[
NUMBER 0;; Aii~S?~S ' ~ '
·: ~ your ret~n of service.
zh you requested.
Very truly yo.ufs, , ,..../~
R. Thomas Kline, Sheriff
Cumberland County, Permsytvania