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HomeMy WebLinkAbout07-3694IN THE COURT OF COMMON PLEAS 07-3(oQy Civil ~errh CUMBERLAND COUNTY, PENNSYLVANIA Heather M. Wilt Greenmont Drive Enola, PA 17025 Law Office of Sam Streeter, PLLC. and Mr. Sam Streeter, attorney P.O. Box 420670 Houston, TX 77242 Plaintiff(s) & Addresses Defendant(s) & Addresses PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. Writ of Summons shall be issued and forwazded to (X) Attorney ()Sheriff. Deanna Lynn Saracco, Esquire 76 Greenmont Drive Enola, Pennsylvania 17025 Phone 717-732-3750 SazaccoLaw@aol.com ~~ Signature of Attorney Dated: 5/20/07 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. nn K• othonotary Dated: (v oho c'~oo By: D ty (~ ~6~91 ~_ =~ n ~ ~ op ~_: ~ ~., r== ~ ~ ~ Ge U _ ' ti`r ca ~ j ~ ~ O IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Heather M. Wilt Plaintiff, v. Civil Action No. 07-3694 COMPLAINT AND DEMAND FOR JURY TRIAL Law Office of Sam Streeter, PLLG, and Mr. Sam Streeter, an individual debt collection attorney, Defendants. PRAECIPE TO DISCONTINUE Pursuant to Pa. RC.P. 229 WITHOUT PREJUDICE And now comes Plaintiff, by and through her counsel, Deanna Lynn Saracco, and files this Praecipe to Discontinue, without Prejudice, the above captioned matter. After further investigation, the Plaintiff believes that the issues in this case will be better served as both an individual and class action, pursuant to federal law, specifically, 15 U.S.C. §1692 et seq., known as the Fair Debt Collection Practices Act. The Plaintiff intends raise the federal causes of action and add a class allegation. The Defendant will not be prejudiced since the complaint will remain virtually the same and FDCPA actions are routinely pursued in federal court. This case should be discontinued without prejudice and you may mark this case CLOSED. Respectfu ~ b fitted, Dated: 7/23/07 Deanna Lynn Saracco, Attorney far Plaintiff 76 Greenmont Drive, Enola, PA 17025 717-732-3750, Fax, 717-728-9498 Certificate of Service: I hereby certify that I served, via U.S. Mail, postage prepaid, to the defendant as follows: Ron Turo, Turo Law Office 28 South Pitt Street Carlisle, PA 17013 Dated: 7!23/0? Deanna Lynn Saracco ~~ ~ ~ i' ~s~l tYr - ' '~ _ . 4 t ~~ ' ~ ~ ~rM /