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HomeMy WebLinkAbout03-3885 F:\FILESIDA T AFlLElGenerallDocumenls\l 094S_I_ writlhad Created: S/S/0311:S2AM Revised: sls/03 3:46PM ROLAND P. FREUND and JOSEPHINE L. FREUND, his wife, and MICHAEL V. ARNOLD and CARLA C. ARNOLD, his wife, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. CIVIL ACTION- EQUITY NO. 03~ 380) !j1A"fy ROSHAN SABAR, d/b/a THE PEACE CENTRE, and THE PEACE CENTRE, INC., and VIRGINIA E. KLAGES, Individually, Defendants PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue a writ of summons against Roshan Sabar, lIS Homers Road, Carlisle, Pennsylvania, 17013, as Defendant in the above captioned action and forward same to the Cumberland County Sheriff for service. Please issue a writ of summons against The Peace Centre, Inc., lIS Homers Road, Carlisle, Pennsylvania, 17013, as Defendant in the above captioned action and forward same to the Cumberland County Sheriff for service. Please issue a writ of summons against Virginia E. Klages, 7843 East Buena Terra Way, Scottsdale, Arizona, 85250, as Defendant in the above captioned action and please return the same to our office for service. MARTSON DEARDORFF WILLIAMS & OTTO By 0\l\)Q Carl C. Risch, Esquire ID Number 75901 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: August 6, 2003 Attorneys for Plaintiffs ~ ~ '... ~ ~() <>0 ~) \~ ~. ~ 1:71- <0-1 'j"\ ~ c) s:::, -'cl ';(, " ~ ~ v P ;:[J/if _.Ih ~--::': & ~ r-:' , ~'7: I. :.~~ - 5::':" o V" r -~ ~~i; ..'... ;:- {jl '~ c..5 ::,. :::; \2> Commonwealth of Pennsylvania Connty of Cumberland WRIT OF SUMMONS Roland P. Freund and Josephine L. Freund, his wife, and Michael V. Arnold and Carla C. Arnold his wife Plaintiff Court of Common Pleas Vs. No. 2003-3885 Equity In EquityAction-Law Roshan Sabar, D/B/A The Peace Centre and The Peace Centre, Inc., 115 Horners Road, Carlisle PA 17013 Virigina E. Klages, Individually 7843 East Buena Terra Way, Scottsdale, Arizona, 85250 Defendant To Roshan Sabar, D/B/A The Peace Centre, The Peace Centre, Inc., and Virginia E. Klages, Individually, You are hereby notified that Roland P. Freund and Josephine L. Freund, his wife, and Michael V. Arnold and Carla C. Arnold, his wife the Plaintiff has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date August 11, 2003 CURTIS R. LONG Prothonotary Bylt~ /f~9'r Deputy Attorney: Name: Carl C. Risch, Esq. Address: Ten East High Street Carlisle PA 17013 Attorney for: Plaintiff Telephone: 717-243-3341 Supreme Court ID No. 75901 TRuE COpy '" Testimony IVh FROM FlECO atId the seal Of ~f. I here unto RD Silld Coon <it l'~ "set my haflfl day 01 ".,r ,SII.l. p, . SHERIFF'S RETURN - NOT SERVED CASE NO: 2003-03885 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FREUND ROLAND P ET AL VS SABAR ROSHAN DBA THE PEACE CEN R. 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: SABAR ROSHAN D/B/A THE PEACE CENTRE but was unable to locate Him in his bailiwick. He therefore returns the WRIT OF SUMMONS NOT SERVED , as to the within named DEFENDANT , SABAR ROSHAN D/B/A THE PEACE CENTRE 115 HORNERS ROAD CARLISLE, PA 17013 SERVICE STOPPED PER INSTRUCTIONS FROM ATTORNEY CARL RISCH. Sheriff's Costs: Docketing Service Affidavit Surcharge So 18.00 3.45 .00 10.00 .00 31.45 Thomas Kline Sheriff of Cumberland County MDW&O 08/21/2003 Sworn and subscribed to before me this :J"7 Ii!' day OfO-'-1.u.J JAJo-3 __ A. D . (~t'-'-' Q Iv, , ~f.,. . , ~ Prothonotary SHERIFF'S RETURN - NOT SERVED CASE NO: 2003-03885 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FREUND ROLAND P ET AL VS SABAR ROSHAN DBA THE PEACE CEN R. 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: PEACE CENTRE INC but was unable to locate Them in his bailiwick. He therefore returns the WRIT OF SUMMONS NOT SERVED , as to the within named DEFENDANT , PEACE CENTRE INC 115 HORNERS ROAD CARLISLE, PA 17013 SERVICE STOPPED PER INSTRUCTIONS FROM ATTORNEY CARL RISCH. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So answe:r:.!;l: -~ R. Thomas Kline Sheriff of Cumberland County MDW&O 08/21/2003 Sworn and subscribed to before me this .1 7 e: day of ()"1/~ ..241(7 A.D. '-~ 0- Iru 11-...~ ~ Prothonotary SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2003-03885 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FREUND ROLAND P ET AL VS. SABAR ROSHAN DBA THE PEACE CEN R. Thomas Kline , Sheriff of Cumberland County, pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,KLAGES VIRGINIA E by United States Certified Mail postage prepaid, on the 12th day of August ,2003 at 1530:00 HOURS, at 7843 EAST BUENA TERRA WAY SCOTTSDALE, AZ 85250 , a true and attested copy of the attached WRIT OF SUMMONS Together with The returned receipt card was signed by VIRGINIA E. KLAGES 08/15/2003 on Additional Comments: Docketing Service Certified Mail Surcharge 6.00 .00 4.42 10.00 .00 20.42 R. Thomas Kline' Sheriff of Cumberland County Sheriff's Costs: So Paid by MDW&O on 08/21/2003 . Sworn and subscr~ed to before me this :1.1 It- day off I"r._r c2lw1Y A.D. n Q. 7hup..j ~ .... ~onotary Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS Roland P. Freund and Josephine L. Freund, his wife, and Michael V. Arnold and Carla C. Arnold his wife Plaintiff Court of Common Pleas Vs. No. 2003-3885 Equity In EquityAction-Law Roshan Sabar, D/B/A The Peace Centre and The Peace Centre, Inc., 115 Horners Road, Carlisle PA 17013 Virigina E. Klages, Individually 7843 East Buena Terra Way, Scottsdale, Arizona, 85250 Defendant To Roshan Sabar, D/B/A The Peace Centre, The Peace Centre, Inc., and Virginia E. Klages, Individually, You are hereby notified that Roland P. Freund and Josephine L. Freund, his wife, and Michael V. Arnold and Carla C. Arnold, his wife the Plaintiff has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date August 11, 2003 CURTIS R. LONG Prothonotary By 4~~::t~f# Attorney: Name: Carl C. Risch, Esq. Address: Ten East High Street Carlisle P A 17013 Attorney for: Plaintiff Telephone: 717-243-3341 Supreme Court ID No. 75901 TRUE COpy FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Cou at Carr Ie, Pa~ ThIS,!lJ~~ of ~/ Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS Roland P. Freund and Josephine L. Freund, his wife, and Michael V. Arnold and Carla C. Arnold his wife Plaintiff Court of Common Pleas Vs. No. 2003-3885 Equity In EquityAction-Law Roshan Sabar, D/B/A The Peace Centre and The Peace Centre, Inc., 115 Horners Road, Carlisle PA 17013 Virigina E. Klages, Individually 7843 East Buena Terra Way, Scottsdale, Arizona, 85250 Defendant To Roshan Sabar, D/B/A The Peace Centre, The Peace Centre, Inc., and Virginia E. Klages, Individually, You are hereby notified that Roland P. Freund and Josephine L. Freund, his wife, and Michael V. Arnold and Carla C. Arnold, his wife the Plaintiff has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date August 11, 2003 CURTIS R. LONG Prothonotary By ~ $~/Jnk Deputy '//~/Lf Attorney: Name: Carl C. Risch, Esq. Address: Ten East High Street Carlisle P A 17013 Attorney for: Plaintiff Telephone: 717-243-3341 Supreme Court ID No. 75901 r c;f "V'f f' , /(If' . Comp/ele items 1, 2, and 3. Also complete Item 4 W RestrIcted Delivery's desired. . Print your neme and address on the reverse so that we can return the card to you. . Attach this card to the back ot the mail piece, or on the front W space permits. 1. ArticleAdd_to: Virginia E. Klages 7843 East Buena Terra Way Scottsdale. AZ 85250 ~~(~~, fl'JRec~(Printrl,!"J ~ Ie. ~O~ivery V \~~:\1.. K. (,If).~" 'i5{IJY"J D. Is "'Ivery address d~from Item 1? C1 Yes If YES, enter delivery addr'9S$ below: D No 3. Service Type JQ Certified Mall 0 Expraoa Mail o Registered 0 Return Receipt for Merchandise o Insured Mall 0 e,o.o. 4. Restricted Delivery? (Extra Fao) 0 Yes 7002 2410 0007 8504 bb8b 03-3885 civ PS Form 3811 , August 2001 Domesllo Ralum Receipt 102595-02-M-1035 , ROLAND P. FREUND and JOSEPHINE L. FREUND, his wife, and MICHAEL V. ARNOLD and CARLA C. ARNOLD, his wife, Plaintiffs v. ROSHAN SABAR, d/b/a THE PEACE CENTRE, and THE PEACE CENTRE, INC., and VIRGINIA E. KLAGES, Individually, To the Prothonotary: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - EQUITY : NO. 03 - 3885 EQUITY PRAECIPE Please mark the above captioned matter settled and discontinued. Date: / _ 15 - 0 (., f:\FILESIDA T AfILEIGenerallCurrentll 099S,l,pra MARTSON DEARDORFF WILLIAMS & OTTO By (' 1 J.y-A- 5' r1-- Christopher E. Rice, Esquire 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiffs .. , . CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Robert G. Frey, Esquire FREY & TILEY 5 South Hanover Street Carlisle, P A 17013 MARTSON DEARDORFF WILLIAMS & OTTO I) L ~(' (' ....-') By I... L.- it~" / ,( J1lc...~ M. Price Te East High Street Carlisle, P A 17013 (717) 243-3341 Dated: q );'5) 0 c-, f'-:) c~ c C1 (,