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Home My WebLink About03-5286 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003 - 5;!.l((o C.I vit CIVIL ACTION - LAW JURY TRIAL DEMANDED JOHN R. HENSEL and SHARON A. HENSEL, His Wife, 408 South Old State Road, Apt. 8 Norwalk, OH 44857 McDERMITT CONCRETE, INC. and vs. CACO THREE, INC. tld/b/a McDERMITT CONCRETE, INC. Plaintiffs 83 Hunterstown Road P. O. Box 3219 Gettysburg, PA 17325, Defendants PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue a Writ of Summons in the above-captioned action. Said Writ of Summons shall be issued and forwarded to the Sheriff, for service upon the Defendants, McDERMITT CONCRETE, INC. and CACO THREE, INC. tld/b/a McDERMI Stephen M. Greecher, Jr. TUCKER ARENSBERG, P.C. 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 Date: October 6, 2003 WRIT OF SUMMONS TO THE ABOVE-NAMED DEFENDANTS: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED AN ACTION AGAINST YOU. ~ cJ:_ Deputy ( ) Check here if reverse is used for additional information 63043.1 p(lk:~~<e.~ ~~ ~ ~ '" C)O "\ (") C-:. e'\- ,~. -Of', \{1 9~q ,I Y\ 0- 'a r;' -'--~ . ~ :iC: :2 ,. f ~ ~ @ B -"'::) ", CI ~ :> ..- ..J SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-05286 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HENSEL JOHN R ET AL VS MCDERMITT CONCRETE INC R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: MCDERMITT CONCRETE INC but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of ADAMS County, Pennsylvania, to serve the within WRIT OF SUMMONS On October 16th , 2003 , this office was in receipt of the attached return from ADAMS Sheriff's Costs: Docketing Out of County Surcharge Dep Adams County So .~:;:::?' 18.00 9.00 10.00 19.70 .00 56.70 10/16/2003 TUCKER ARENS BERG R( Thomas Kline Sheriff of Cumberland County SWARTZ Sworn and subscribed to before me this .;z3"^- day of (])ct;;k oL.Vll.'l A. D. C)14I.L- 0 }/-1, L~<.. ~. ( Prothonotary' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-05286 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HENSEL JOHN R ET AL VS MCDERMITT CONCRETE INC R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: CACO THREE INC T/D/B/A MCDERMITT CONCRETE INC but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of ADAMS County, Pennsylvania, to serve the within WRIT OF SUMMONS On October ~L6th , 2003 , this office was in receipt of the attached return from ADAMS Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 10/16/2003 TUCKER ARENSBERG So answe_r....- . /. ..- -~-.? ~~~---- ~ R. Thomas Kllne r Sheriff of Cumberland County SWARTZ Sworn and subscribed to before me this Jj...,..t day of (9~ ;LllV3 A.D. ~ I "'tV- Q )~" UJf0 ' -f Prothonotar1 In The Court of Common Pleas of Cumberland County, Pennsylvania John R. Hensel et ell VS. McDermitt Concrete Inc et al SERVE: McDermitt Concrete, Inc. No. 03-5286 civil Now, October 9. 2003 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Adams County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~,//-p<?e h7:' .,,~~c~~~r _..6~R 'l . Sheriff of Cumberland County, P A Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, P A Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ .'\..L,JIl.i\) ~ , ~,' ~L~id3 is S 11 : II 'V 0 I 130 [DOl 0.. -. A !.. ,', .... , .::l/\I.=.V:;', .. "!\;"'..' Cld r-'. ~\; ZE I! sllJa Ai~: i ~~IU3i". "'",J j",LUC .~ l , , I f l o MASON DIXON BUSINESS FORMS, INC. 33000026 DATE RECEIVED DATE PROCESSE SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE,GETTYSBUAG,PA17325 _TRIICTIONS: _ "'NSTl'lUCTlONS FOR SERVICE OF PROCESS BY THE SHERIFF" on IIlo r_ 0I1Ilo I... (No.5) copy 01 'hi, form. _ '- or print Ioglbly, lnourlng _Nty oI.n_. Do ""'_ _ _. AC80 &NY.' 1. PLAINTlFFIS/ 2. COURT NUMBER JOHN R. HENSEL and SHARON A. HENSEL, His Wife 2003-5286 Civil 3. DEFENDANTIS/ .. TYPE OF WRIT OR COMPLAINT: MCDERMITT CONCRETE, INC., IT AL Writ of Surrmons in Civil Actio 5. NAME OF INDIVIDUAL. COMPANY. CORPORATION. ETC.. TO SERVICE OR DESCRIPTION OF PROPERTY TO BE lEVIED. ATTACHED OR SOLO. SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN SERVE . ttDermitt Concrete, Inc. AT 8. ADDRESS (Street Of RFD. A~Mlrtmenl No., City, Boro. Twp.. State and ZIP CODE) 83 Hunterstown Rd., Gettysburg, PA 17325 7. INDICATE UNUSUAL SERVICE: 0 PERSONAL 0 PERSON IN CHARGE 0 DEPUTIZE 0 CERT. MAllO REGISTERED MAli. 0 POSTED 0 OTHER Now, , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. 8. SPECIAlINSTl'lUCTIONS OR OTHER INFORMATION THAT WIlL ASSIST IN EXPEDITING SERVICE. SHERIFF OF ADAMS COUNn NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN-Any deputy sheriff IeYylng upon or attaching any' property under within writ may leave same without a watchman, in custody 01 whomever is found in possession, after notifying person of levy or attachment. without llability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof. 9. SfONATUAE of ATTORNEY or other OAKlINATOA requesting service on beha" of: 10. TELEPHONE NUMBER ". DATE 1l[ PLAINTIFF Stephen M. Greecher, Jr., Esq. 0 DEFENDANT (717) 234-4121 SPACE BELiW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE 12. I aCknOwledge receipt of the writ SIGNATURE of Authorized ACSD Deputy or Clerk and Title 1'3. Date Received 114. Expiration I Hearing dat or compl.int .. Indica'.. abovo. 10-10-03 15. I hereby CERTIFY and RETURN that I 0 have personally served, IX have served person in charge, 0 have legal evidence of service as shown in "Remarks" (on reverse) o have posted the above described property with the writ or complaint described on the Indivklual, company, corporation, etc., at the address shown above or on the individual, company, corporatton, etc., at the address Inserted below by handing/or Posting a TRUE IlI'M:I ATTESTED COPY therof. 16. 0 I hereby certify and return a NOT FOUND because I am unable to locate the individual. company, corporation, etc., named above. (See remarks below) 17. Name and tllte of Individual setved 1'" A permn ~ IU....... and diKretiOn I Read Orde Ginger French, Office Manager ::::::"l""1." 1';...""""'''''''.' 0 19. Address of where served (comptete only II different than shown above) (Street or RFD. Apartment No.. City, Bora, Twp., 20. Date of Service 21. Time Slot. lII1d ZIP CODE) 22. ATTEMPTS I 0... I MIIoo I Cop.lnt. 23. Advance Colts I 24. $m.m Bn. SJeciff IWA72 D... MI1eo I Cop.lnt'l 128 10/10/2003 2:04pm Dolo I MIIoo Cop.lnt'l Dolo I MIIoo 1 Cop.lnt.1 D.t. I Mil_ I Cop.ln'. 27. ToIol CooIo I 28. llilfiItltiUi>tift REFUND $19~~ 10/14/03 $130.30 Ck. #10027 ;/ ~~~ /-TQ By_lOop. _ _.... or Typo) 00.. Kpvin Miller 10/10/2003 RAm:l~rMMA'N !1f~/10/2003 28. AFFIRMED and sublCrlbed to before me this day 0' ~....... MY COMMISSION EXPIRES I ACKNOWlEDGE RECEIPT OF THE _"''8 RETUIlH BlGNATUIlE OF AUTHORIZED ISSUING AUTHORITY AND TITLE. --.. OF ADAMS COUNTY 139. Qete Received PROTHONOTARY 33000(l?t) SHERIFF'S RETURN OF SERVICE ( 1 ) The within upon defendant by mailing to by prepaid, a true and attested copy thereof at , the within named mail, return receipt requested, postage on the The return receipt signed by defendant on the is hereto attached and made a part of this return. ( ) (2) Outside the Commonwealth, pursuant to Pa. R.C.P.405 (c) (1) (2), by mailing a true and attested copy thereof at in the following manner: ( ) (a) to the defendant by ( ) registered ( ) certified mail, return receipt requested, postage prepaid, addressee only on the said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities that Defendant refused to accept the same. The returned receipt and envelope is attached hereto and made a part of this return. And thereafter: ) (b) To the defendant by ordinary mail addressed to defendant at same address, with the return address of the Sheriff appearing thereon, on the I further certify that after fifteen (15) days from the mailing date, I have not received said envelope back from the Postal Authorities. A certificate of mailing is hereto attached as a proof of mailing. ( ) ( 3) By publication in the Adams County Legal Journal, a weekly publication of general circulation in the County of Adams, Commonwealth of Pennsylvania, and the Gettysburg Times, a daily newspaper published in the County of Adams, Commonwealth of Pennsylvania and having general circulation in said County for successive weeks of The Affidavits from said Adams County Legal Journal and Gettysburg Times, are hereto attached and made part of this return. ( ) ( 4) By mailing to by mail, return receipt requested, postage prepaid, on the a true and attested copy thereof at The Authorities marked is hereto attached. ( ) (5) Other returned by the Postal In The Court of Common Pleas of Cumberland County, Pennsylvania John R. Hensel et al vs. McDermitt Concrete Inc et al SERVE: Caco Three, Inc. t/d/b/a McDermitt Concrete, Inc. No. 03-5286 civil Now, October 9, 2003 ,I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Adams County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~r'/ ~.~' r ~""'"'~...~....-...;? Sheriff of Cumberland County, P A Affidavit of Service Now, ,20_, at 0' clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ " .', ." ,\ . lv,J ~<'; :,..i .:i.:Htl3\.;'S S 11 ; \I '\j 0 \ no (Gill a3^13J :;'^ , . .-~, j C":, \.'J ?€ \1 9\ tJ~ i,l'.! I"~ ;jjlc. ; '" ~,l '; / ( ! ! o MA.SON DIXON BUSINESS FORMS, INC. 33000026 DATE RECEIVED DATE PAOCESSEC SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE,GETTYSBURG,PA17325 IIlSTIIIICTIONII: See "INSTRUCTIONS FOR SERVICE Of PROCESS BY THE SHERIFF" on !he _ of !he lut (No.5) copy of Ihil form. _ typo or ptlnt Ieglbly. Insu~ng _lily 01 aN _. Do llOl_llIlY _. ACBD EMV.' 1. PLAINTIFFISI 2. COURT NUMBER JlN R. HEN3EL and SHARON A. HENSEL, His Wife 2003-5286 Civil 3. DEFENDANTISI .. TYPE OF WRIT OR COMPLAINT: MCDERMITT CONCRETE, INC" ET AL Writ of SUnmons in Civil Action s. NAME OF INDIVIDUAL. COMPANY. CORPOAATION. ETC.. TO SERVICE OR DESCRIPTlON Of PROPERTY TO BE LEVIED. ATTACHED OR SOlO. SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN SERVE . Caco Three, Inc. t/d/b/a MCDermitt Concrete, Inc. 6. AOORESS (Sfle<< or RFD. Apar1man1 No.. CIly. Boro. Twp.. Sla.. and ZIP CODE) 83 Hunterstown Rd" Gettysburg, PA AT 7. INDICATE UNUSUAL SERVICE: 0 PERSONAL 0 PERSON IN CHARGE 0 DEPUTIZE 0 CERT. MAtL 0 REGISTERED MAIL 0 POSTED 0 OTHER Now, , I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. SHERIFF OF ADAMS COUHTY 6. SPECtAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE. NOTE ONLY APPUCABlE ON WRIT OF EXECUTION; N.S. WAIVER OF WATCHMAN-Any deputy sheliff krvying upon or attaching any property under within writ may leave same without a watchman, in custody of wI'lomever is found in possession, after nOllfytng person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal 0' any such property belore sheriff's Hie thereof, 9. SIGNATURE of ATTORNEY or other ORIGINATOR requesting service on behalt of; 10. TELEPHONE NUMBER 11. DATE Q[PLAINTlFF Stephen M. Greecher, Jr., Esq. o DEFENDANT (717) 234-4121 SPACE BELiW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE 12. I acknowledge recetpt 01 the writ SIGNATURE of Authorized ACSD Deputy or Cleek and Title 1'3. Date Received 1'4. Expiration I Hearing date or complaint ..Indicated lIbove. 10-10-03 15. I hereby Cl!ATtFY and RETURN that I 0 have personally served, K. have served person in charge, 0 have legal evidence of service as shown in "Remarks" (on revefse) o have posted the above described property with the writ or complaint described on the Individual, company, corporallon, etc., at the address shown above or on the individual, company, corporation, etc., atth. addr8s8 Inserted below by handing/or Posting a TRUE.nd ATTESTED COPY therof. 16. 0 I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, COtporatlon, etc., named above. (See remarks below) 17. Name and tille of IndMdual served 1'8. A per.i:ln of....... and dlaeretlon I Read Order Ginger French, Off ice Manager ::::. ~L,;",'" :go .......nt'. "",., 0 19. AddrNS or wh". I8fV8d (complete only if different than shown above) (Street or AFO, Apartment No.. City, Boro, Twp., 20. Date or Service 21. Time Stat. and ZIP CODE) 10/10/2003 2:04PM 22. ATTEMPTS I 23. Adv.nce Colts Dote I Mllaa 'Dap.,nt. 124 D... I Mil.. 25, I Dap.,nt., 126 Data I MIlaa Dap.lnt., Data I MlIu I Dop.!"t'l Dote I Mil.. I Dap.lnt. 27. T.... CooIa I 26. COST DUE OR REFUND 2~~/~- Kevin Miller 10/10/2003 Slgnaturw 01 _ Data RAYMOND W. NEWMAN 10/10/2003 AFFIRMED and eubac:rlbed to _ ... Ihil N/A day 01 _PublIc 8IlERIFF OF _ COUHTY MY COMMISSION EXPIRES I ACKNOWLEDGE RECEIPT Of THE 8HEIlIfF'S IlETURN _TUAI! Of AUTHORIZED ISSUING AUTHORITY AND TITLE. 139. Dete R_ PROTHONOTARY 33000026 SHERIFF'S RETURN OF SERVICE ( ) ( 1 ) The within upon defendant by mailing to by prepaid, a true and attested copy thereof at , the within named mail, return receipt requested, postage on the The return receipt signed by defendant on the is hereto attached and made a part of this return. ) (2) Outside the Commonwealth, pursuant to Pa, R.C.P.405 (c) (1) (2), by mailing a true and attested copy thereof at in the following manner: ) (a) \0 the defendant by ( ) registered ( ) certified mail, return receipt requested, postage prepaid, addressee only on the said receipt being returned NOT signed by defendant, but with a notation by the Postal Authorities that Defendant refused to accept the same. The returned receipt and envelope is attached hereto and made a part of this return. And thereafter: ( ) (b) To the defendant by ordinary mail addressed to defendant at same address, with the return address of the Sheriff appearing thereon, on the I further certify that after fifteen (15) days from the mailing date, I have not received said envelope back from the Postal Authorities. A certificate of mailing is hereto attached as a proof of mailing. ( ) ( 3 ) By publication in the Adams County Legal Journal, a weekly publication of general circulation in the County of Adams, Commonwealth of Pennsylvania, and the Gettysburg Times, a daily newspaper published in the County of Adams, Commonwealth of Pennsylvania and having general circulation in said County for _~_~__~_~~ ~~_~__ successive weeks of The Affidavits from said Adams County Legal Journal and Gettysburg Times, are hereto attached and made part of this return. ( ( 4) By mailing to by mail, return receipt requested, postage prepaid, on the a true and attested copy thereof at The Authorities marked is hereto attached. ( ) (5) Other returned by the Postal EMMA PEARSON BERKEY, Plaintiff7petitioner, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN CUSTODY RICHARD DUANE BERKEY, JR., NO: 02-5286 Defendant/Respondent PETITION TO MODIFY CUSTODY ORDER AND NOW, this ?\JL'day of February, 2004, the Petitioner, Emma Pearson Coons (formerly Emma Pearson Berkey), by and through her attorney, Andrew C. Spears, Esquire, and the law firm of Metzger, Wickersham, Knauss & Erb, P.C., files the within Petition of which the following is a statement: 1. Petitioner is Plaintiff Emma Pearson Coons (formerly Emma Pearson Berkey), natural mother (hereinafter "Mother") of the following Minor Children: Taylor Andrew Pearson Berkey, dob: 6/25/97; Nathan Wade Berkey, dob: 5/3/99; and Kiera Lynne Berkey, dob: 4/25/01. Mother currently resides at 39 North Spring Street, Shippensburg, Cumberland County, Pennsylvania. 2. Respondent is Defendant Richard Duane Berkey, Jr., natural father (hereinafter "Father") of the Minor Children. Father currently resides at: 3366 Allport Highway, Morrisdale, Clearfield County, Pennsylvania, 16858. 3. On or about August 14,2003, a Stipulated Custody Agreement and Order was entered by this Honorable Court. 297615-1 4. The Custody Order dated August 14,2003 is attached as Exhibit A and incorporated herein by reference and provides, inter alia, that the custody of the Minor Children shall be exercised between the parties as follows: a. Mother and Father shall have shared legal custody of the Minor Children; b. Mother shall have permanent physical custody of the Minor Children; c. Father shall have partial physical custody of the Minor Children every other weekend from Friday, 6:00 p.m., until Sunday, 6:00 p.m. 5. Since the entry of said Order, there have been sil,'llificant changes in the custodial circumstances, and Mother is now concerned about whether Father's mental stability is sufficient to care for the Minor Children and to continue to have shared physical custody and shared legal custody ofthe Minor Children. 6. The Custody Agreement was entered into on August 14,2003. Since that time Father has had sporadic visitation with the Minor Children. 7. Further, Mother has now learned that Father has been diagnosed with post- traumatic stress disorder, as well as several anxiety disorders. 8. As a result of these disorders, Father has told Mother that he is unable to work or to seek gainful employment. 9. Mother has concerns for the Minor Children's safety when they are with Father due to Father's post-traumatic stress disorder and anxiety disorders, and she is worried that Father may endanger the health and well-being ofthe Minor Children when they are in his custody. 10. Mother is concerned about Father's ability to make sound decisions on behalf of the Minor Children due to his medical conditions. 297615-1 11. The best interest of the Minor Children will be best served if this Honorable Court will modify the aforementioned Custody Order. 12. Mother respectfully requests that said Custody Order be modified, granting primary legal custody of the Minor Children to Mother, primary physical custody ofthe Minor Children to Mother, and partial physical custody of the Minor Children to Father with supervision until such time as he has shown an ability to care fix the Minor Children. WHEREFORE, Petitioner Emma Pearson Coons respectfully requests that this Honorable Court grant the modifications to the Custody Order as set forth above. Respectfully submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. ~ l Andrew . pears Supreme Court LD. No. 87737 3211 North Front Street Harrisburg, P A 17110-0300 (717) 238-8187 Attorneys for PlaintifflPetitioner -- Date: ~ ,fie) ,01 2976t5-J VERIFICATION I, Emma Pearson Coons, verify that the statements made in the foregoing Petition to Modify Custody Order are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. ?/ '/ ~~<-(- <:: X::::>.7?~ Emma Pearson Coons Dated: ~. J\J -\.J'1 2976t5-1 CERTIFICATE OF SERVICE AND NOW, this X~ay of February, 2004, I, Andn:w C. Spears, Esquire, of Metzger, Wickersham, Knauss & Erb, P.C., attorneys for Plaintiffi'Petitioner, hereby certify that I served a copy of the within Petition to Modify Custody Order this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Richard Duane Berkey, Ir. 3366 Allport Highway MorrisdaIe, PA 16858 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. C _J- _ Andrew C. Spears, Esquire Attorney Id. No. 87737 3211 North Front Street P.O. Box 5300 Harrisburg, P A 17110-0300 (717) 238-8187 Attorneys for PlaintifflPetitioner 297615-1 (.J ~ CI') 7d \ D "'" () () C~:> ~ c: C:~~ -n ~- .-j < -" 8 -':1!-: :rl1 rTJ rllr= ,~. v.) ~ ~ ;:-:-1 f'.' -r,r2j :::J . :U (/ ...- s;~ C~ ~ ~ r;~ [:., -0 :c .'H ~ }> r'". -,'.. (;!(,) /. ..-:,.. IT1 ..() t ~~~; ~ C-Y :--{ ~ c5 t / ,-~..~ :3 .~~: cOon .-< , --c.... Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-5286 CIVIL TERM JOHN R. HENSEL and SHARON A. HENSEL, His Wife, v. CIVIL ACTION - LAW McDERMITT CONCRETE, INC. and CACO THREE, INC. tld/b/a McDERMITT CONCRETE, INC., JURY TRIAL DEMANDED Defendants PRAECIPE TO DISCONTINUE TO PROTHONOTARY, CUMBERLAND COUNTY: Please mark the above captioned action settled and discontinued with prejudice. By: ~~~~: t?f !:;-J 0 S ep Attorney' 0.-3 111 North Front Street P. O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 ATTORNEYS FOR PLAINTIFFS o ~i C' '.c] -<. "" = = c.n (/J p"'j .'-0 N W o -n ~.." rn- r: -"-JIT, :by t~~ "J-- ':.;.>'"0 '-:.,-m 8 ~> :~ -n ::Ie: <:? o Cf'