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HomeMy WebLinkAbout03-5863 IN RE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JURORS FOR CIVIL TERM JANUARY 12, 2004 (Act 78, 1980) 2003 - 5863 Civil ORDER OF COURT AND NOW, November 6, 2003, the Jury Selection Commission for Cumberland County, with the assistance of Board of Elections, Cumberland County, Carlisle, Pennsylvania, is directed to select in random fashion 300 persons from the master list of prospective jurors for Cumberland County for the year 2004 for service as jurors to try all cases and matters which may be pending before the Court of Common Pleas, Civil Division, at a session commencing JANUARY 12, 2004. When the selection has been made, the District Court Administrator is directed to summon said prospective jurors for service as indicated above, as required by law, and to direct said prospective jurors to respond to the questionnaire submitted with the summons. :jam cc: Ralph G. Viehman, Jr., Jury Commissioner Frances J. AmicucCi, Jury Commissioner C") r""'~' c--: c.. --'';' ~ ~". '"Uo-; C:~ n"lp-', "-::;: 2" -^ , "2:C C"''' (r),:: -<. ' r:::::C. ;c- 32=, -~ z('-, ~, ~-~ >c: ~ ~ :n ;1.-;.": 1I 0 -< NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO, 87380 37 SOUTH HANOVER STREET, SUITE 201 CARUSLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT EDEN RITE AID CORPORATION, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. DAVID KONEFF, SUSAN KONEFF, : CIVIL ACTION - LAW DANIEL SEMIC, SHARON SEMIC, F & S CORPORATE ADVISORS, INC.,: NO. 02-5863 d/b/a NEW YORK SALES TAX CREDIT, FEDERAL & STATE CORPORATE ADVISORS, INC., and BRIAN EDEN, Defendants PETITION FOR LEAVE TO WITHDRAW AS COUNSEL FOR DEFENDANT BRIAN EDEN NOW COMES counsel of record for the defendant Brian Eden, Nathan C. Wolf, Esquire, and respectfully submits this Petition for Leave of Court to Withdraw as Counsel for the defendant, Brian Eden pursuant to PA.RC.P. 1012, and in support thereof, avers as follows: 1. Defendant, Brian Eden, is an adult individual who is a resident of the State of Florida, and whose last known address was whose last known address was Brian Eden, Inmate No. 39407-060, cI 0 Miami Fa, 15801 S.W. 13? Avenue, Miami, FL 33177 2. The unders~ned counsel was retained by the defendant on or about June 23, 2003. 3. Counsel has performed services for the defendant and has been compensated for such servICes. 4. Defendant Brian Eden was subsequently incarcerated and contacted the undersigned through his criminal counsel in the State of Florida, indicating that he no longer wished the undersigned to represent the defendant in the instant action. 5. The undersigned communicated with his client dire,ctly by written correspondence and sought written confirtnation from him. 6. Defendant provided the undersigned with written confirtnation that he no longer wished the undersigned to represent him in this matter. (A true and correct copy of the same is attached hereto as Exhibit A). 7. The undersigned advised opposing counsel Gordon Einhorn of the instant petition and no objection to the relief request was raised. 8. Counsel believes and therefore avers that no prejudice would be suffered by his client if the instant petition is granted, and that this Court should grant the relief requested in accordance with his client's wishes. WHEREFORE, the petitioner, Nathan C. Wolf, Esquire, resprectfullyprays that this Court grant leave for the undersigned to withdraw his representation of Defendant, Brian Eden, and to grant any further relief that the Court deems appropriate. , Esquire fi efendant Eden Su e Court ID #87380 37 outh Hanover Street, Suite 201 Carlisle, PA 17013 (717) 7A1-4436 Dated: July S ,2005 Nathan C. Wolf, Esquire 37 South Hanover Street Suite 201 Carlisle, P A 17013 Dear Mr. Wolf: In reference to tiiecivil action initiated by Rite Aid, I no longer require your services. Please take whatever steps necessary- to confinn your withdrawal. ,,- Date: 3/Q/O;-r f ( ~\ Brian Eden VERIFICATION I, the undersigned, do hereby verify that the facts set forth in this petition are true and correct to the best of my knowledge and belief. I understand that false staternents herein are made subject to the penalties of 18 Pa.CS. Section 4904, relating to unsworn falsification to authorities. Dated: July 5, 2005 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR DEFENDANT EDEN RITE AID CORPORATION, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. DAVID KONEFF, et al. Defendants : CIVIL AcrION - LAW : DOCKET NO. 02-5863 CERTIFICATE OF SERVICE I, Nathan C. Wolf, Esquire, hereby certify that I mailed a true and correct copy of the foregoing Petition for Leave to Withdraw as Counsel to the below-listed persons: Gordon A. Einhorn, Esquire Hangley, Aronchick, Segal & Pudlin 30 North Third Street, Suite 700 Harrisburg, PA 17101-1701 Attorney for Plaintiff Rite Aid Corporation DavidJ. Foster, Esquire Leslie M Fields, Esquire Costopoulos, Foster & Fields 831 Market Street Lemoyne, PA 17043 Attorneys for Defendants Koneff and Semic Brian Eden Inmate No. 39407-060 c/o Miami Fa 15801 S.W. 13? Avenue Miami, FL 33177 Dated: July S-.. 2005 ~ < ~~~,~" ' '~ ,,:";.,.- U~ ," -". ~ r-:i::-' ~~, 5.~' ~~': ~ -<. o <;; ~ ~ 'c. ,- \ tJl q. ~:Q ..,,~ -0 "(3k' -'-~, C)B 6rn __I ",. 1~ ~ '-P. tJl U\