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HomeMy WebLinkAbout07-6991HCR MANORCARE, INC., Plaintiff V. VERNON E. STEPHENS, and JEANNIE STEPHENS Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007- & ?,9f CIVIL TERM PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a Writ of Summons in the above-referenced case on behalf of the Plaintiff, HCR ManorCare, Inc., to the Defendants, Vernon E. Stephens and Jeannie Stephens. Date: ' RIEN, BARIC & SCHERER David A. Baric, Esquire I.D. # 44853 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff Please serve the Defendants as follows: Vernon E. Stephens Jeannie Stephens 940 Walnut Bottom Road 2 Dogwood Lane Carlisle, Pennsylvania 17013 Carlisle, Pennsylvania 17015 r-3 W__ ti HCR MANORCARE, INC., Plaintiff V. VERNON E. STEPHENS, and JEANNIE STEPHENS Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007- 0q) CIVIL TERM PRAECIPE FOR LJS PENDENS TO THE PROTHONOTARY: Please index the above action as a Lis Pendens against the following real property: ALL that certain lot of ground situate in the First Ward of the Borough of Carlisle, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: ON the north by an alley; on the east by property formerly of George Kerr; on the south by East Penn Street; and on the west by property formerly of Lewis Faber, Sr., having a distance of 15 feet in front and extending in depth an even width a distance of 120 feet to the said alley, and being improved with a two story frame dwelling house known as No. 161 East Penn Street, Carlisle, Pennsylvania. BEING the same premises which Charles E. Stephens and Ethel L. Stephens, his wife by deed dated October 8, 1963, and recorded in the office of the Recorder of Deeds at Carlisle, Pennsylvania in Deed Book '71)% Vol. 20, Page 889, granted and conveyed to Vernon E. Stephens, grantor herein. I hereby certify that this action affects the title to or other interest in the above-described real property. Respectfully Submitted, N, BARK SCH David A. Baric, Esquire I.D. # 44853 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff . CERTIFICATE OF SERVICE I hereby certify that on November 20, 2007, I, David A. Baric, Esquire of O'Brien, Baric & Scherer, did serve a copy of the Praecipe for Lis Pendens, by first class U.S. mail, postage prepaid, to the parties listed below, as follows: Vernon E. Stephens 940 Walnut Bottom Road Carlisle, Pennsylvania 17013 Jeannie Stephens 2 Dogwood Lane Carlisle, Penns lvania 17015 l David A. Baric, Esquire CERTIFICATE OF SERVICE I hereby certify that on November 20, 2007, I, David A. Baric, Esquire of O'Brien, Baric & Scherer, did serve a copy of the Praecipe for Lis Pendens, by first class U.S. mail, postage prepaid, to the parties listed below, as follows: Vernon E. Stephens 940 Walnut Bottom Road Carlisle, Pennsylvania 17013 Jeannie Stephens 2 Dogwood Lane Carlisle, Penns Ivania 17015 l David A. Baric, Esquire roTi i CIO 5 x'11 ; ?.J Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS HCR Manorcare Inc. Plaintiff Court of Common Pleas Vs. No 2007-6991 Civil Term Vernon E. Stephens 940 Walnut Bottom Road Carlisle, PA 17013 Jeannie Stephens 2 Dogwood Lane Carlisle, PA 17015 In CivilAction-Law Defendant To Vernon E. Stephens and Jeannie Stephens, You are hereby notified that HCR Manorcare, Inc. the Plaintiff(s) 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. ? A (SEAL) CurtidR. Long, Prot far Date November 20, 2007 By Deputy Attorney: David A. Baric, Esq. Name: O'Brien, Baric & Scherer Address: 19 West South St. Carlisle, PA 17013 Attorney for: Plaintiff Telephone: (717) 249-6873 Supreme Court ID No. 44853 SHERIFF'S RETURN - NOT SERVED CASE NO: 2007-06991 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HCR MANORCARE INC VS STEPHENS VERNON E ET AL 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: STEPHENS JEANNIE but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , STEPHENS JEANNIE 2 DOGWOOD LANE NOT SERVED , as to CARLISLE, PA 17015 AT LEAST FIVE ATTEMPTS AT SERVICE MADE, BUT NO ONE WAS HOME. NEIGHBOR ADVISES THEY COME HOME LATE AT NIGHT AND LEAVE EARLY. Sheriff's Costs: So answerer Docketing 6.00 - Service 9.60 Affidavit .00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 X2/3116 7 25.60 O' BRIEN BARIC & SCHERER 12/21/2007 Sworn and Subscribed to before me this day of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2007-06991 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HCR MANORCARE INC VS STEPHENS VERNON E ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon STRPHFNS VFRNON E the DEFENDANT , at 2024:00 HOURS, on the 19th day of December-, 2007 at 129 WALNUT BOTTOM ROAD SHIPPENSBURG, PA 17257 VERNON STEPHENS by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Additional Comments SUMMONS WAS SERVED IN THE PRESENCE OF CYNTHIA NIEB, NURSE FOR VERNON STEPHENS. Sheriff's Costs: Docketing Service Affidavit Surcharge /:zl3l?G? 18.00 19.20 .00 10.00 .00 47.20 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 12/21/2007 O'BRIEN BARIC AND SCHERER By: eputy Sheriff A. D. HCR MANORCARE, INC., Plaintiff V. VERNON E. STEPHENS, and JEANNIE STEPHENS : Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007- 6991 CIVIL TERM PRAECIPE TO REISSUE TO THE PROTHONOTARY: Please reissue the Writ Of Summons issued in the above matter. Respectfully submitted, O' RIEN, BARIC CHE Date: January 23, 2008 David A. Baric, Esquire I.D. 44853 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 dab.dir/manorcare/stephens/reissuewrit.pra t J r 1 w t.? ? ` 4 SHERIFF'S RETURN - NOT FOUND CASE NO: 2007-06991 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HCR MANORCARE INC VS STEPHENS VERNON E ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT STEPHENS JEANNIE but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT 2 DOGWOOD LANE STEPHENS JEANNIE NOT FOUND , as to CARLISLE, PA 17015 ALTHOUGH NUMEROUS ATTEMPTS WERE MADE, WE WERE UNABLE TO SERVE DEFENDANT PRIOR TO EXPIRATION. Sheriff's Costs: Docketing 18.00 Service 25.92 Not Found 5.00 Surcharge 10.00 Postage n .58 .21?u/Of `7, 59.50 So answers: R. Thomas Kline Sheriff of Cumberland County OBRIEN BARIC SCHERER 02/27/2008 Sworn and Subscribed to before me this day of A. D. r- . '-,. Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS Court of Common Pleas HCR Manorcare Inc. Plaintiff Vs. No 2007-6991 Civil Term Vernon E. Stephens 940 Walnut Bottom Road Carlisle, PA 17013 Jeannie Stephens 2 Dogwood Lane Carlisle, PA 17015 In CivilAction-Law Defendant To Vernon E. Stephens and Jeannie Stephens, You are hereby notified that HCR Manorcare, Inc. the Plaintiff(s) 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) Curti R. Long, Prot Date November 20, 2007 By Deputy Attorney: David A. Baric, Esq. Name: O'Brien, Baric & Scherer Address: 19 West South St. Carlisle, PA 17013 Attorney for: Plaintiff Telephone: (717) 249-6873 Supreme Court ID No. 44853 8Z .E d h Z Nvr $OOZ d31b3HS 3H1 ?'0 301. 30 L N 0 e es? Z h