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Home My WebLink About03-5278Robin Stahr, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No.: 03, 5'978 G Adam Byro, : Civil Action - Law Defendant Jury Trial Demanded PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a Writ of Summons in the above-captioned action. Writ of Summons shall be issued and forward to Sheriff for service upon Adam Byro at 15 Church Street, Mechanicsburg, Penns lvania 17055. Dated: lb Kir S. Sohonage, Esquire Saidis, Shuff, Flower & Lindsay Attorney I.D. # 77851 26 West High Street Carlisle, PA 17013 Phone: 717.243.6222 Attorney for Plaintiff WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE NAMED PLAINTIFF HAS SAIDIS COMMENCED AN ACTION AGAINST YOU. SHUFF, FLOWER & LINDSAY it ATMRMYS•A7•LAW ? ? ®? 26 W. High Street Dated: CY{?ua[i u 6. o?M3 / Carlisle, PA .. Pro notary " lBy: `uu. - Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Robin Stahr, Civil Action - Law Plaintiff V. Docket No. 03-5278 Adam Byro, Defendant PRAECIPE TO WITHDRAW APPEARANCE SAIDIS SHUFF, FLOWER & LINDSAY ATTORNRYS•Ar•LAW 26 W. High street Carlisle, PA To the Prothonotary: AND NOW, this / IP -tAday of 2004, please withdraw the appearance of the Law Firm of Saidis, Shuff, Flower & Lindsay and Kirk S. Sohonage, Esquire as the attorney of record for the Plaintiff, Robin Stalin A true and correct copy of the Order making the Rule to Show Cause Absolute granting the Petitioners Leave of Court to Withdraw is attached hereto, incorporated herein by reference and marked as Exhibit "A". SAIDIS, 15HUFF, FLOWER & LINDSAY By: ;ohonage, Esquire Supreme Ct. I.D. # 77851 26 West High Street Carlisle, PA 17013 Phone: ('717) 243-6222 CERTIFICATE OF SERVICE I, Adele Group certify that on I (0 day of 2004, I served a true and correct copy of the within PRAECIPE TO WITHDRAW APPEARANCE on the below- named parties, by depositing same in the United States mail, first class, postage prepaid, addressed as follows: Robin Stahr 110 North East Street Carlisle, PA 17013 SAIDIS,, SHUFF, FLOWER & LINDSAY By: 4 Adele Group SAIDIS SHUFF, FLOWER & LINDSAY ATIr7Nry@y$•AT•LAW 26 W. High street Carlisle, PA JUN 8 0 2004 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Robin Stahr, Civil Action - Law Plaintiff V. Docket No. 03-5278 Adam Byro, Defendant ORDER AND NOW, this 4 -rv day of , 2004, this Court hereby makes the RULE TO SHOW CAUSE ABSOLUTE and grants Petitionei"s Leave of Court to Withdraw from representing the Plaintiff in the above-noted matter. ?rr-2c. J. SAIDIS SHUFF, FLOWER & LINDSAY ArroxNevs•Anuw 26 W. High Street Carlisle, PA ATTEST TRUE COPY FROM RECORD to Taatilrwy whereof, l here unto set my hand and me" of Said at Carlisle, ft. fhi - TT" day p won y Prothonot" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Robin Stahr, Civil Action - Law Plaintiff V. Docket No. 03-5278 Adam Byro, Defendant PETITION TO MAKE RULE ABSOLUTE AND NOW, come the Petitioners, Saidis, Shuff, Flower & Lindsay and Kirk S. Sohonage, Esquire, and file the within Petition to Male the Rule Absolute that had been issued by this court on the 15ei day of June 2004, and in support thereof avers the following: 1) Plaintiff failed to respond and Show Cause why this Court should not grant the moving parties Leave of Court to Withdraw from representing the Plaintiff in the above-noted action. WHEREFORE, Petitioners request this Honorable Court make the Rule Absolute SAIDIS SHUN, FLOWER & LINDSAY AMRNEYS•AT•LAW 26 W. High Street Carlisle, PA and grant them Leave to Withdraw from representing the Plaintiff, due to the Plaintiff s failure to respond to the Rule. Date: & . Lg, aI Respectfully submitted, Saidis, Sh ; Flower & Lindsay By ///, /,/ KirWS' Sohonage, Esquire Attorney ID #77851 26 West High Street Carlisle, Pennsylvania 17013 Phone: 717.243.6222 Attorney for Plaintiff r-, ?, {-- ?? o - = .? -„ > ?? -_, - ??- . r , rr? _? r gin; _ - ; ? ?i f _?? _ 'ii 1 ?_ -_.. , _.? f ? .. ? -i Q7 -< ?, "'i ? ? ? ? w w 0 ?-- 0 ?° SHERIFF'S RETURN - REGULAR CASE NO: 2003-05278 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STAHR ROBIN VS BYRO ADAM RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon BYRO ADAM the DEFENDANT at 2100:00 HOURS, on the 13th day of October 2003 at 15 CHURCH ROAD MECHANICSBURG, PA 17055 ADAM BYRO a true and attested copy of WRIT OF SUMMONS by handing to together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.90 Affidavit .00 Surcharge 10.00 .00 34.90 Sworn and Subscribed to before m//e?? this /(, `l day of V ,. ?tiQ3 A.D. p , p,.., - / Pfrathonotary So Answers: az R. Thomas Kline 10/14/2003 SAIDIS SHUFF FLOWER LINDSAY By: ? /J11? --- ty Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Robin Stahr, Civil Action - Law Plaintiff V. 'Docket No. 03-5278 Adam Byro, Defendant PETITION FOR LEAVE OF COURT TO WITHDRAW APPEARANCE AND NOW, this O day of June 2004, comes the law firm of Saidis, Shuff, Flower & Lindsay, and Kirk S. Sohonage, Esquire, and files this Petition for Leave of Court to Withdraw Appearance and in support thereof aver the following: 1. The law firm of Saidis, Shuff, Flower & Lindsay had been engaged to represent the interests of Robin Stahr in a personal injury action against Adam Byro. 2. Attorney Kirk S. Sohonage, Esquire, was assigned to handle this matter and in the course of his representation of Ms. Stahr did file a Praecipe for Writ of Summons on October 6, 2003, which Writ was issued on the same day and did SAIDIS SHUFF, FLOWER & LINDSAY ATTORN NS-AT-LAW 26 W. High Street Carlisle, PA toll the Statute of Limitations. 3. Subsequent to the writ of Summons being issued, differences arose between the law firm, the attorney of record end the Plaintiff. 4. As a result, on April 22, 2004, the: Plaintiff, Robin Stahr, discharged as her attorneys, the law firm of Saidis Shuff Flower & Lindsay and Kirk S. Sohonage, Esquire, and Stahr requested both parties file to withdraw their representation of her with regard to the above-noted case. Please see a copy of the discharge notice, which is attached hereto, made a part hereof and marked as Exhibit "A." 5. None of the parties involved, the law firm, attorney or plaintiff, desires future representation of the plaintiff by the firm or the attorney with regard to this case. WHEREFORE, the law firm of Saidis, Shuff, Flower & Lindsay and Kirk S. Sohonage, Esquire, respectfully request this Honorable Court grant them leave to withdraw their appearance in the above-noted matter. Saidis Shuff Flower & Lindsay By: Kirk S. Sohonage, Esquire Supreme Ct. I.D. # 77851 26 West High Street Carlisle, PA 17013 (P) 717.243.6222 (F) 717.243.6510 SAIDIS SHUFF, FLOWER & LINDSAY ATTORNM-AT•LAW 26 W. High Street Carlisle, PA 2 LAW OFFICES FLOWER & LINDSAY SAIDIS, SHUFF, A PROFESSIONAL CORPORATION 26 WEST HIGH STREET Cep HILL OFFICE: L L C P H JOHN E SLIKE CARLISLE, PENNSYLVANIA 17013 PHONE: (717) 243-6222 - FACSIMILE: (717),143-6486 STREET I 2 CAS HILL, PA REST LL, P 317011 -3405 ROBERT C. SAIDIS GEOFFREY S. SHUFF TELE EMAIL: attorney@ssfl-law.cOm m TELEPHONE: FACSIMILE: (717)737-3407 JAMES D. FLOWER, JR www.ssfl-Iaw.co Y A CAROL J. LINDS C.d is«m c«ffi<a creanos' ? I LMANt MATTHEW J «'« wshu R< KIRK S. SOHONAGE THOMAS E. FLOWER REPLY TO CAR -LISLE LINDSAY GINGRICH MACLAY JACLYN SMITH April 22, 2004 Saidis, Shuff, Flower & Lindsay ATTN: Kirk S. Sohonage, Esquire 26 West High Street Carlisle, Pennsylvania 17013 RE.- CLIENT FILE RELEASE/DISCHARGE STAHR V. 1VIONI FURST DOCKET No. 03-5278 CIVIL ACTION - LAW STAHR V. ADAM BY GYRO To Whom It May Concern: I, ROBIN STAHR, authorize Saidis, Shuff, Flower & Lindsay to release to me my client files and records regarding Matter Numbers Adam Byro-021198 and Monique Furst-021982. I understand that by reason of this release I S have discharged&SaLindsay is, Sh ff, Flower any and Lindsay as my attorneys and further release Saidis, uff, Flower from all regarding its representation of me in these matters. I also understand that I will not be responsible for any outstanding amounts owed to Saidis, Shuff, Flower & Lindsay and agree to close all accounts I may have with the law firm. Further, I hereby discharge as my attorneys in the above-noted matters the law firm of Saidis, Shuff, Flower & Lindsay, Kirk S. Sohonage, Esquire, and Joseph L. Hitchings, Esquire, and request those orneys file to withdraw their representation me in e respective matters. Date Signed: bin St Witness IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Robin Stahr, Plaintiff V. Adam Byro, Defendant Civil Action - Law Docket No. 03-5278 CERTIFICATE OF SERVICE SAIDIS SHUFF, FLOWER & LINDSAY ATfORNEYS•AT•LAW 26 W. High Street Carlisle, PA On this 0 Mday of Qz?' I , 2004, I, Adele Group, hereby certify that I served a true and correct copy of the foregoing RULE To SHOW CAUSE AND THE PETITION FOR LEAVE OF COURT TO WITHDRAW APPEARANCE via United States Mail, first-class, postage prepaid addressed as follows: Robin Stahr 110 North East Street Carlisle, PA 17013 Saidis, Shuff, Flower & Lindsay ai&) Adele Group n ? ?, -? T (= Y t ?? ?? ?? i? -y) ?? Li) -l. (L? ?? `.`_ji 1 ; - ca `- :: ?' t.a -a e JUN 1 0 2004 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Robin Stahr, Civil Action - Law Plaintiff Adam Byro, V. Docket No. 03-5278 Defendant RULE TO SHOW CAUSE AND NOW, on this '7 day of Tin c , 2004, a Rule is entered on the Plaintiff to Show Cause why the Petition for Leave of Court: to Withdraw Appearance should not be la granted. Rule returnable }days from service. BY THE COURT, C/ J. SAIDIS SHOFF, FLOWER & LINDSAY ArrONNEYS•AT•IAW 26 W. High Street Carlisle, PA ? s? ?C A1.P„?s. '' t?^?^? z?? :? ±?;? s i ??nr aaoa o? ?,???r?.c?wo??;.ood ?w. ?o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Robin Stahr, Civil Action - Law Plaintiff Adam Byro, V. Docket No. 03-5278 Defendant PETITION TO MAKE RULE ABSOLUTE AND NOW, come the Petitioners, Saidis, Shuff, Flower & Lindsay and Kirk S. Sohonage, Esquire, and file the within Petition to Make the Rule Absolute that had been issued by this court on the 15`h day of June 2004, and in support thereof avers the following: 1) Plaintiff failed to respond and Show Cause why this Court should not grant the moving parties Leave of Court to Withdraw from representing the Plaintiff in the above-noted action. WHEREFORE, Petitioners request this Honorable Court make the Rule Absolute SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA and grant them Leave to Withdraw from representing, the Plaintiff, due to the Plaintiff s failure to respond to the Rule. Date: 6 tg e4 Respectfully submitted, 5aidis, Shu ; Flower _& Lindsay By: ///J? Kir . Sohonage, Esquire Attorney ID #77851 26 West High Street Carlisle, Pennsylvania 17013 Phone: 717.243.6222 Attorney for Plaintiff h) r ?? (. __ _v_ _L_1 it L? ( ` __ ?'l1 _,_ Lim ? ??.T: _:J L; ail) - ? _ 1-i ' ?? - r? ?;., .. JU2004 Adam Byro, Robin Stahr, Civil Action - Law Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY AWORNEYSeAT-LAW 26 W. High Street Carlisle, PA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Docket No. 03-5278 Defendant ORDER AND NOW, this r(t day of '1 , 2004, this Court hereby makes the RULE TO SHOW CAUSE ABSOLUTE and grants Petitioner's Leave of Court to Withdraw from representing the Plaintiff in the above-noted matter. ATTEST cz m CA- w a- O °o N Curtis R. Long Prothonotary OffilC Of the Protbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor .03-S278 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573