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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 : . 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 .- : : : . .- .- : ; : 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