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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
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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:
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