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THE LAW OFFICES OF BARBARA A. FEIN, P.C.
Barbara A. Fein, Esquire / I.D. No. 53002
Kristen J. DiPaolo, Esquire / I.D. No. 79992
Suite 100, 425 Commerce Drive
Fort Washington, PA 19034
(215) 653-7450
Attorney for Plaintiff
FEDERAL NATIONAL
MORTGAGE ASSOCIATION,
Plaintiff,
V.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. /q- ?066 &'"t
WILLIAM L. MALONE,
PEGGY A. MALONE and
OCCUPANTS OF
434 7TH STREET,
NEW CUMBERLAND, PENNSYLVANIA,
Defendants.
CIVIL ACTION EJECTMENT
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 1201 DAYS AFTER
THIS COMPLAINT AND NOTICE ME 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 EY 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.
NOTICIA
LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED
QUIERE DEFENDERSE DE ESTAS DEMANDAS EIPUESTAS EN LAS
PAGINAS SIGUIENTES, USTED TIENE 1201 DIAS DE PLA20 A
PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION.
USTED DEBE PRESENTAR UNA APARIENCIA ESCRITA 0 EN
PERSONA 0 FOR AEOGADO Y ARCHIVAR EN LA CORTE SUS
DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS ENCONTRA OE
SU PERSONA. SEA AVISADO QU'e SI USTED NO SE DEFIENDE,
LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR DNA ORDEN
CONTRA USTED SIN PREVIO AVISO 0 NOTIFICACION 0 FOR
CUALQIER QUEJA 0 ALIVIO QUE ESPEDIDO IN LA PETICION
DE DEMANDA. USTED PUEDE PERDER DINERO, SUS
PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANOA A UN ABOGADO INMEDIATAMENTE. SI
NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE
PARA PAGAR TAL SERV:CIO, VAYA EN PERSONA 0 LLAME POR
TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE USTED PUEDE
CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE PA 17013
(717) 249 3166 or 1 800 990 9108
Cumberland County Court Admuustraoor
4th Floor
Cumberland County Court House
I Courthouse Squ,,rn-
Carlisle, PA 17013
17171 240-6100
CIVIL ACTION -- EJECTMENT
1. The Plaintiff, Federal National Mortgage Association, is
a corporation organized and existing under the laws of The United
States of America, and having its principal place of business at
1900 Market Street, Suite 800, Philadelphia, PA 19103.
2. (a) The Defendant, William L. Malone, is an individual
whom Plaintiff believes and therefore avers is residing at the
property address, that being 434 7th Street, within the Borough of
New Cumberland, Cumberland County, Pennsylvania, hereinafter
referred to as the "Premises".
(b) The Defendant, Peggy A. Malone, is an individual
whom Plaintiff believes and therefore avers is residing at the
property address, that being 434 7th Street, within the Borough of
New Cumberland, Cumberland County, Pennsylvania, hereinafter
referred to as the "Premises".
(c) The Defendant Unknown Occupants are individuals whom
Plaintiff believes and therefore avers are residing at the
Premises.
3. The Premises which are described at Exhibit "A" attached
hereto and incorporated herein by reference, were sold at the
Cumberland County Sheriff's Sale conducted on September 1, 1999,
after due advertisement and according to law, under and by virtue
of a Writ of Execution issued to satisfy a Judgment entered in the
Court of Common Pleas for Cumberland County at the suit of Federal
National Mortgage Association v. William L Malone and Peggy A
Malone, as Court Docket Number 99-343.
4. The Premises were purchased by the Plaintiff at the
Sheriff's Sale, said sale results being a matter of public record.
5. The Plaintiff acquired title to the Premises on the date
of and by virtue of said Sheriff's Sale, and is the real and
current entitled owner of said Premises by virtue of a Cumberland
County Sheriff's Deed Poll, to be recorded in the Cumberland County
Recorder of Deeds' Office at the earliest possible date.
6. The persons in possession of the Premises are believed to
be the Defendants in this action and are occupying the Premises
without right and without claim to title.
7. The Defendants herein named were duly served with Notices
of the Sheriff's Sale held on September 1, 1999.
8. Plaintiff has demanded possession of the Premises from
the Defendants who have refused to deliver up the possession
thereof.
WHEREFORE, the Plaintiff demands judgment for immediate
possession of the Premises, issuance of a Writ of Possession and a
judgment of its costs and disbursements in this action.
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
BY: ?t CJ?t?t 1.
qL-
8?arbara A. Fein, esquire
Attorney for Plaintiff
Attorney I.D. No. 53002
ALL THAT CERTAIN piece or parcel of land situate in the Borough of New
Cumberland, Cumberland County. Pennsylvania, being bounded and described according to a
survey made by Robert L. Reed, Registered Surveyor, dated March 9, 1981, as follows, to
wit:
BEGINNING at a point in the South side of Seventh Stteet fifty (50) feet wide at
the corner of lands now or formerly of William L. Cropf, Jr. and Brenda I. Cropf, his wife;
thence along the said side of Seventh Street, North 51 degrees 30 minutes 00 seconds East. the
distance of twenty-Sbree (23) feet to a point at the corner of lands now or formerly of John H.
Kapp; thence along said fifty lands, South 38 degrees 3 0)min feet a p00 seco East, the oint on the North side distance: of
hundredths
one hundred thirty-two and
alley (ten (10) feet wide); thence along said alley, South 51 degrees 30 minutes 00 seconds
West, the distance of twenty-three (23) feet to a point at the comer of lands now or formerly of
William L. Cropf, Jr. and Brenda 1. Cropf, his wife; thence along said lands, North 38 degrees
30 minutes 00 seconds West, the distance of one hundred thirty-two and fifty hundredths
(132.50) feet to a point, the place of BEGINNING.
HAVING THEREON ERECTED a dwelling known as No. 434 Seventh Street,
New Cumberland, Pennsylvania.
BEING THE SAME PREMISES WHICH William L. Freeman and Rebecca A.
Freeman, by deed dated January 25, 1993 and recorded January 26, 1993 in the Office of the
Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book C, Volume
36, Page 682, granted and conveyed unto William L. Malone and Peggy A. Malone, his wife.
Tax Parcel No. (25)-24-0811-020.
SEIZED IN EXECUTION as the property of William L. Malone and Peggy A.
Malone on Judgment No. 99-343.
s EXHIBIT
VERIFICATION
BARBARA A. FEIN, ESQUIRE, hereby states that she is the
Attorney for the Plaintiff in this action, that she is authorized
to make this Affidavit, and that the statements made in the
foregoing Civil Action Complaint in Ejectment are true and correct
to the best of her knowledge, information and belief.
The undersigned understands that this statement herein is made
subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to
unsworn falsification to authorities.
Dated: October 1, 1999
THE LAW OFFICES OFF BARBARA A. FEIN, P.C.
BY: " v
Barbara A. Fein, Esquire
Attorney for Plaintiff
Attorney I.D. No. 53002
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CASE NO: 1999-06066 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FEDERAL NATIONAL MORTGAGE ASSO
VS.
MALONE WILLIAM L ET AL
KATHY CLARKE , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT IN EJECTMENT was served
upon MALONE WILLIAM L the
defendant, at 16:07 HOURS, on the 11th day of October
1999 at 434 7TH STREET
NEW CUMBERLAND, PA 17070 CUMBERLAND
County, Pennsylvania, by handing to PEGGY MALONE
a true and attested copy of the COMPLAINT IN EJECTMENT
together with NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answ
O
?
Docketing 18.00 O
Service 10.54
Affidavit •00
Surcharge 8.00 omas ine, eri
$3b. b14 BARBARA FEIN
10/12/1999
by
ep eri
Sworn and subscribed to before me
this d J?L day of ?IrTJ . .
19t9L A.D.
fro ono ary??
CASE NO: 1999-06066 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FEDERAL NATIONAL MORTGAGE ASSO
vs.
MALONE WILLIAM L ET AL
KATHY CLARKE , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT IN EJECTMENT was served
upon MALONE PEGGY A the
defendant, at 16:07 HOURS, on the 11th day of October
1999 at 434 7TH STREET
NEW CUMBERLAND, PA 17070 CUMBERLAND
County, Pennsylvania, by handing to PEGGY MALONE
a true and attested copy of the COMPLAINT IN EJECTMENT
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answer??SS
r
Docketing 6.00 ? Z?? 100-.105,0F
Service .00 7
Affidavit .00
Surcharge 8.00 omTfi as Kline, 5 2
$14.00B RB2R/A9FEIN
10/1199
by
?2f (i?l t
-Uepu f? eri
Sworn and subscribed to before me
this J,)?,( day of l`. et?
19pf q A.D.
rotnonocary
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
Barbara A. Fein, Esquire / I.D. No. 53002
Kristen J. DiPaolo, Esquire / I.D. No. 79992
Suite 100, 425 Commerce Drive
Fort Washington, PA 19034
(215) 653-7450
Attorney for Plaintiff
FEDERAL NATIONAL
MORTGAGE ASSOCIATION,
Plaintiff,
V.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. ?-lwgbI 2c
WILLIAM L. MALONE,
PEGGY A. MALONE and
OCCUPANTS OF
434 7TH STREET,
NEW CUMBERLAND, PENNSYLVANIA,
Defendants.
CIVIL ACTION EJECTMENT
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 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 RAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
NOTICIA
LE RAN DEMANDADO A USTED EN LA CORTE. SI USTED
QUIERE DEFENDERSE OR ESTAS DEMANDAS EKPUESTAS EN LAS
PAGINAS SIGUIENTES, USTED TIENE (201 DIM DE PLAZO A
PARTIR DE LA FECHA DE LA DEMANDA Y LA NOTIFICACION.
USTED DEER PRESENTAR LIMA APARIENCIA ESCRITA O EN
PERSONA 0 FOR ABOGADO Y ARCHIVAR EN LA CORTE SUS
DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS ENCONTRA DE
SO PERSONA. SEA AVISADO QUE SI LISTED NO BE DEFIENDE,
LA CORTE TOMARA MEDIDAS Y PUBIS ENTRAR DNA ORDEN
CONTRA LISTED SIN PREVIO AVISO 0 NOTIFICACION 0 POR
CUALQIER QUEJA 0 ALIVIO QUE ESPEOIDO EN LA VETIC[ON
DE DEMANDA. USTED PUEDE PERDER DINERO, SUS
PROPIEDADES 0 OTROS DERECHOS IMPORTANIES PARA LISTED.
LLEVE ESTA DEMANDA A ON ABCGADO INMEDIATAMENTE. SI
NO TIENE AD0GAD0 0 SI NO TIENE EL DINERO SUFICIENTE
PARA PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR
TELEFONO A LA OFICINA CUYA DIRECCiON SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE USTED PUEDE
CONSEGUIR ASISTENCIA LEGAL.
FUMBERLAND COUNTY BAR ASSOCIATION
LIBERTY AVENUE
CARLISLE PA 17013
(717) 249 3166 or 1 800 990 9108
TRW CM In T"ft ony whemd. I here unto to my WN
M0,
,nl as x
i 0514, ps,
1 ig 7
u A a _ ,r-
Cumberland County Court Administrator
4th Floor
Cumberland County Court House
Courthouse Square
Carlisle. PA 17013
17171 240-6200
r
CIVIL ACTION -- EJECTMENT
1. The Plaintiff, Federal National Mortgage Association, is
a corporation organized and existing under the laws of The United
States of America, and having its principal place of business at
1900 Market Street, Suite 800, Philadelphia, PA 19103.
2. (a) The Defendant, William L. Malone, is an individual
whom Plaintiff believes and therefore avers is residing at the
property address, that being 434 7th Street, within the Borough of
New Cumberland, Cumberland County, Pennsylvania, hereinafter
referred to as the "Premises".
(b) The Defendant, Peggy A. Malone, is an individual
whom Plaintiff believes and therefore avers is residing at the
property address, that being 434 7th Street, within the Borough of
New Cumberland, Cumberland County, Pennsylvania, hereinafter
referred to as the "Premises".
(c) The Defendant Unknown Occupants are individuals whom
Plaintiff believes and therefore avers are residing at the
Premises.
3. The Premises which are described at Exhibit "A" attached
hereto and incorporated herein by reference, were sold at the
Cumberland County Sheriff's Sale conducted on September 1, 1999,
after due advertisement and according to law, under and by virtue
of a Writ of Execution issued to satisfy a Judgment entered in the
Court of Common Pleas for Cumberland County at the suit of Federal
Malone, as Court Docket Number 99-343.
4. The Premises were purchased by the Plaintiff at the
Sheriff's Sale, said sale results being a matter of public record.
5. The Plaintiff acquired title to the Premises on the date
of and by virtue of said Sheriff's Sale, and is the real and
current entitled owner of said Premises by virtue of a Cumberland
County Sheriff's Deed Poll, to be recorded in the Cumberland County
Recorder of Deeds' Office at the earliest possible date.
6. The persons in possession of the Premises are believed to
be the Defendants in this action and are occupying the Premises
without right and without claim to title.
7. The Defendants herein named were duly served with Notices
of the Sheriff's Sale held on September 1, 1999.
8. Plaintiff has demanded possession of the Premises from
the Defendants who have refused to deliver up the possession
thereof.
A
WHEREFORE, the Plaintiff demands judgment for immediate
possession of the Premises, issuance of a Writ of Possession and a
judgment of its costs and disbursements in this action.
THE LAW OFFICES OF' BARBARk A. FEIN, P.C.
BY:
Barbara A. Fein,)Esquir
Attorney for Plaintiff
Attorney I.D. No. 53002
ALL THAT CERTAIN piece or parcel of land situate in the Borough of New
Cumberland, Cumberland County. Pennsylvania, being bounded and described according to a
survey made by Robert L. Reed. Registered Surveyor, dated March 9, 1981, as follows, to
wit:
BEGINNING at a point in the South side of Seventh Street fifty (50) feet wide at
the corner of lands now or formerly of William L. Cropf, Jr, and Brenda I. Cropf, his wife;
thence along the said side of Seventh Street, North 51 degrees 30 minutes 00 seconds East, the
distance of twenty-three (23) feet to a point at the comer of lands now or formerly of John H.
Kapp; thence along said lands, South 38 degrees 30 minutes 00 seconds East, the distance of
one hundred thirty-two and fifty hundredths (132.50) feet to a point on the North side of an
alley (ten (10) feet wide); thence along said alley, South 51 degrees 30 minutes 00 seconds
West, the distance of twenty-three (23) feet to a point at the corner of lands now or formerly of
William L. Cropf, Jr. and Brenda 1. Cropf, his wife; thence along said lands, North degrees
30 minutes 00 seconds West, the distance of one hundred thirty-two fry hundredths
(132.50) feet to a point, the place of BEGINNING.
HAVING THEREON ERECTED a dwelling known as No. 434 Seventh Street,
New Cumberland, Pennsylvania.
BEING THE SAME PREMISES WHICH William L. Freeman and Rebecca A.
Freeman, by deed dated January 25, 1993 and recorded January 26, 1993 in the Office of the
Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book C. Volume
36, Page 682, granted and conveyed unto William L. Malone and Peggy A. Malone, his wife.
Tax Parcel No. (25)-24-0811-020.
SEIZED IN EXECUTION as the property of William L. Malone and Peggy A.
Malone on Judgment No. 99-343.
EXHIBIT
?A
a -
VERIFICATION
BARBARA A. FEIN, ESQUIRE, hereby states that she is the
Attorney for the Plaintiff in this action, that she is authorized
to make this Affidavit, and that the statements made in the
foregoing Civil Action Complaint in Ejectment are true and correct
to the best of her knowledge, information and belief.
The undersigned understands that this statement herein is made
subject to the penalties of 19 Pa. C.S.A. Section 4904 relating to
unsworn falsification to authorities.
Dated: October 1, 1999
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
BY: t 0
Barbara A. Fein, Esquire
Attorney for Plaintiff
Attorney I.D. No. 53002
u
r
OFFICE OF Tllf 'NER!FF v
OcT ?a 2 37 PM '99 it
PL?Iw: YL"?A'NIA
ti
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
Barbara A. Fein, Esquire / I.D. No. 53002
Kristen J. DiPaolo, Esquire / I.D. No. 79992
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
Attorneys for Plaintiff
FEDERAL NATIONAL
MORTGAGE ASSOCIATION,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 99-6066 CIVIL
V.
WILLIAM L. MALONE,
PEGGY A. MALONE and
OCCUPANTS OF
434 7TH STREET
NEW CUMBERLAND, PENNSYLVANIA,
Defendants.
PRAECIPE TO SETTLE, DISCONTINUE, AND END
TO THE PROTHONOTARY:
Kindly mark the above referenced matter settled, discontinued
and ended without prejudice to Plaintiff.
THE AOFF OF BA ARA A. FEIN, P.C.
BY:
iPaolo, Esquire
Attorney for Plaintiff
Attorney I.D. No. 79992
August 2, 2000
S
Q'. 'rn
i
G ,n U
EVA LIMBACHER and BRAD IN 111E COURT OP COMMOD
LIMBAC I IER, OF Cl1MBERLAND COUNTY
Plaintiff's
V. CIVIL ACTION
NO. 99-6065 Civil
BONNIE SANDERS.
Defendant JURY TRIAL. DEMANDED
RULE. RFTURNABLli
AND NOW, this day of December. 2000, a Rule is hereby entered upon the
Defendant and it is hereby ORDEiRI:D that the Defendant file answers to the Plaintirfs.
Interrogatories berore the Defendant's deposition scheduled for December 22. 2000, t9i I M ni i ip
ui •n' r u
BY PILL'' COURT:
L Y J.
I ACLU
224425 IML ?M1
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EVA LIMBACHER and BRAD
LIMBACHER,
Plaintiffs
V.
BONNIE SANDERS,
Defendant
IN THE COURT OP COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION
No. 99-6065 Civil
JURY TRIAL DEMANDED
PLAINTIFFS' PETITION TO MAKE RULE ABSOLUTI
1. On November 14, 2000, a Rule was entered upon the Defendant to show cause why
Plaintiffs' discovery should not be answered and that the Defendant pay plaintiffs' counsel fees
incurred in filing a Petition requesting answers to outstanding discovery. The Rule was ietumable
within 20 days of service. The Rule was executed by the I lonorable Kevin A. I less. Said Rule is
attached as Exhibit A.
2. The Defendant did not file a response to the Petition, but did, however, file a
response to the Plaintiffs Request for Production of Documents. Attached as Exhibit B is defense
counsel's December 7, 2000, letter without exhibits.
3. However, the Defendant has not filed a response to the Plaintiffs' Interrogatories and
the deposition of the Defendant has been rescheduled to December 22, 2000.
224425.1A)H NI1G
WHEREFORE, it is respectfully requested that Your Honorable Court enter a Rule
Absolute and Order the Defendant to file responses to the outstanding Interrogatories before
December 22, 2000, and pay counsel fees given the outstanding discovery.
ANGINO & ROVNER, P.C.
I
David L. Lutz
I.D. No. 35956
4503 N. Front Street
Harrisburg, PA 17110
(717) 238-6791
Date: Attorney for Plaintiffs
224425.1\nLl NIKi
1
I{ EXHIBIT A
EVA LIMBACHER and BRAD
LIMBACFIER,
Plaintiffs
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
V.
BONNIE SANDERS,
Defendant
RULE
CIVIL ACTION
NO. 99-6065 Civil
JURY TRIAL DEMANDED
AND NOW, this ?day of l Lgm ,-g , 2000, a Rule is hereby entered upon the
Defendant to show cause why Plaintiffs' discovery should not be answered and that the
Defendant pay Plaintiffs' counsel fees incurred in filing a Petition requesting answers to
outstanding discovery.
Rule returnable within 20 days of service.
2227I2AMLDNITG
/: N?n4 J.
b r k`T
EXHIBT B
.?'. 4;
NEALON
GOVER, PC.
ATTORNEYS AT LAW
December 7, 2000
David L. Lutz, Esquire
ANGINO & ROVNER, P.C.
4503 North Front Street
Harrisburg, PA 17110
RE: Eva and Brad Limbacher v. Bonnie Sanders
Cumberland County Docket No. 99-6065
Dear Dave:
2411 NORTH FRONT STREET
HARRISBURG, PA 17110
TELEPHONE(717)232-9900
FACSIMILE (717) 236-9119
JAMEti G. NI:ALON, III
jnealon(a! nealon-Kown.com
In anticipation of the deposition of Ms. Sanders which is currently scheduled, I
reviewed the file. I do not believe that we have responded to your Request for
Production of Documents. Please allow this letter to respond to the discovery requests.
I am enclosing the following:
1. Police Report;
2. Photographs;
3. Medical Records from Seidle Hospital;
4. Medical Records from Arlington Orthopedics;
5. Medical Records of Good Hope Family Practice;
6. Computer printout regarding Sanders' insurance
policy;
7. Allstate investigative file.
t?f-kA? )- a
David L. Lutz, Esquire
December 7, 2000
Page 2
If you have any questions regarding this, please do not hesitate to call.
Very truly your
NEALO_ 8, G E ,
James G. Nealon, III
JGN:sIs
Enclosures
CERTIFICATE OF SERVICE
1, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.C., do hereby
certify that I am this day serving a true and correct copy of the PLAINTIFFS' PETITION TO
MAKE RULE ABSOLUTE. upon defense counsel via postage prepaid first class United States mail
addressed as follows:
James Nealon, Esquire
2411 N. Front Street
Harrisburg, PA 17110
Attorney for Defendant
Dated:
224425.11nLIANI'I G
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