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Home My WebLink About03-6509William P. Douglas, Esq. Supreme Court LD. #37926 Douglas Law Office 27 W. High St. Carlisle, PA 17013 Telephone (717) 243-1790 Cheryl Winters In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs Beverage Express a business entity with a place of business at 4957 Carlisle Pike, Mechanicsburg PA; and B & K Beverage, Inc. t/a/d/b/a Beverage Express 2209 Spring Run Road Mechanicsburg, PA 17055 Defendant No. 03--/_,,~-~9~ Civil Term Civil action law Jury Trial Demanded Praecipe to Issue a Writ of Summons Dear Mr. Long: Please issue a writ of summons against the defendants Beverage Express and B & K Beverage, Inc. t / a / d / b/a Beverage Express. date: December 17,2003 William P. Douglas, t~q. Attorney for Plain~f Commonwealth of Pennsylvania County of Cumberland Cheryl Winters In the Court of Common Pleas of Plain~'ff Cumberland County, Pennsylvania Beverage Express a business entity with a place of business at 4957 Carlisle Pike, Mechanicsburg PA; and B & K Beverage, Inc. t / a/d / b / a Beverage Express 2209 Spring Run Road Mechanicsburg, PA 17055 Defendant No. 03-- 6509 Civil Term Civil action law Jury Trial Demanded Writ of Summons To: B & K Beverage, Inc. t/a/d/b/a Beverage Express and Beverage Express a business entity You are hereby notified that Cheryl Winters has brought an action against you. date: December 17, 2003 William P. Douglas, Esq. Douglas Law Office 27 W. High St. Carlisle, PA 17013-0261 717-243-1790 Attorney for Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2003-06509 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHERYL WINTERS VS BEVEl{AGE EXPRESS ET AL HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according says, the within WRIT OF SUMMONS BEVERAGE EXPRESS DEFENDANT , at 1528:00 HOURS, at 4957 CARLISLE PIKE MECHANICSBURG, PA 17055 LEN MCKEE, MANAGER, ADULT a true and attested copy of WRIT OF SUMMONS to law, was served upon the on the 22nd day of December , __ by handing to IN CHARGE together with 2003 and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.28 Affidavit .00 Surcharge 10.00 .00 36.28 Sworn and Subscribed to before me this /2 e day of / / Prothonotary So Answers: R. Thomas Kline 12/29/2003 DOUGLAS LAW OFFICE By: Deputy S~e~r ff SHERIFF'S CASE NO: 2003-06509 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CLrMBERLAND CHERYL WINTERS VS BEVER3tGE EXPRESS ET AL RETURN - REGULAR HAROLD WEARY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon B&K BEVER3kGE INC T/A/D/B/A BEVERAGE EXPRESS the DEFENDANT , at 2048:00 at 2209 SPRING RUN ROAD MECH3kNICSBURG, PA 17055 PATRICIA ALBRIGHT, WIFE OF a true and attested copy of HOURS, on the 22nd day of December , 2003 by handing to OWNER, ADULT IN CHARGE WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 8.97 Affidavit .00 Surcharge 10.00 .00 24.97 Sworn and Subscribed to before me this /~ ~ day of (~_7~4.~.~7 ~;~_~ a.D. / / Prothonotary So Answers: R. Thomas Kline 12/29/2003 DOUGLAS LAW OFFICE Deputy LISA BELLINO APELIAN, ESQUIRE Attorney I.D. No: 55632 LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 CHERYL WINTERS V. BEVERAGE EXPRESS and B & K BEVERAGE, INC. t/a, clPo/a BEVERAGE EXPRESS ATTORNEY FOR DEFENDANTS, BEVERAGE EXPRESS CUMBERLAND COUNTY COURT OF COMMON PLEAS NO.: 03-6509 TRIAL BY JURY OF 12 DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above captioned matter on behalf of Defendant, Beverage Express. LAW OFFICE OF ROBERT J. McDADE Beverage Express LISA BELLINO APELIAN, ESQUIRE Attorney I.D. No: 55632 LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 CHERYL WINTERS V. BEVERAGE EXPRESS and B & K BEVERAGE, INC. t/a, d/b/a BEVERAGE EXPRESS ATTORNEY FOR DEFENDANTS, BEVERAGE EXPRESS CUMBERLAND COUNTY COURT OF COMMON PLEAS NO.: 03-6509 TRIAL BY JURY OF 12 DEMANDED DEMAND FOR JURY TRIAL Twelve (12) members, exclusive of alternates, are hereby demanded by Defendant, Beverage Express, in the above captioned matter. LAW OFFICE OF ROBERT J. McDADE A~ ESQVlRE At~mey for Defe.~ Be'~erage Express -- LISA BELLINO APELIAN, ESQUIRE Attorney I.D. No: 55632 LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 CHERYL WiNTERS V. BEVERAGE EXPRESS and B & K BEVERAGE, iNC. ifa, d/b/a BEVERAGE EXPRESS ATTORNEY FOR DEFENDANTS, BEVERAGE EXPRESS CUMBERLAND COUNTY COURT OF COMMON PLEAS NO.: 03-6509 TRIAL BY JURY OF 12 DEMANDED PRAECIPE TO FILE COMPLAINT TO THEPROTHONOTARY: Please enter a Rule upon Plaintiffto file a Complaint within twenty (20) days hereof or suffer the entry of a Judgment of Non Pros. LAW OFFICE OF ROBERT J. McDADE Beverage Express RULE TO FILE COMPLAINT AND NOW, this ~dday of~-'~, ~00~ a Rule is hereby granted upon Plaintiff to file a Complaint herein within (20) days after service hereof or suTer the e~y~ Pr thonotary ~ OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS ( CUMBERLAND COUNTY) CHERYL WINTERS V. BEVERAGE EXPRESS and B & K BEVERAGE, INC. t/a, d/b/a BEVERAGE EXPRESS CUMBERLAND COUNTY COURT OF COMMON PLEAS NO.: 03-6509 roi Plaintiff, Cheryl Winters c/o William P. Douglas, Esquire Douglas Law Office Suite 2 27 W. High Street Carlisle, PA 17013-1790 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a JUDGMENT OF NON PROS has been entered against you in the above proceeding and that enclosed herewith is a copy of all the Non Pros documents filed in support of the said Judgment. IF YOU HAVE ANY QU]~STIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: Lisa Bellino Apelian, Esquire at this telephone number: (610)687-8303~/~4t~__~L~ Prothonotary LISA BELLINO APELIAN, ESQUIRE Attorney I.D. No: 55632 LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 CHERYL WINTERS V. BEVERAGE EXPRESS and B & K BEVERAGE, INC. t/a, d/b/a BEVERAGE EXPRESS ATTORNEY FOR DEFENDANTS, BEVERAGE EXPRESS CUMBERLAND COUNTY COURT OF COMMON PLEAS NO.: 03-6509 TRIAL BY JURY OF 12 DEMANDED PRAECIPE FOR ENTRY OF JUDGMENT OF NON PROS TO THE PROTHONOTARY: Kindly enter a Judgment of Non Pros against the plaintiff, Cheryl Winters. I verify that a Complaint has not been filed within twenty (20) days following the service of the Rule in this matter. A tree and correct copy of the Proof of Service of Rule is attached hereto as Exhibit I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgement is to be entered or to the attorney of record, if any, after failure to file a Complaint at least ten (10) days prior to the mailing of the filing of this Praecipe. Service of the Notice of Intention to Enter Judgment of Non Pros is attached hereto and marked as Exhibit "B". LAW OFFICE OF ROBERT J. McDADE Attorney for Defendant, Beverage Express JUDGMENT OF NON PROS AND NOW, this o~~ day of~'~C.~ , 200~, JUDGMENT OF NON PROS against plaintiff, Cheryl Winters, is entered. Prothonotary D~puty Prothonotary EXHIBIT "A" LAW OFFICE OF ROBERT J. McDADE Not a Partnership - Employees of a Member Company of Zurich North America WALNUT I-I]]_,L PLAZA 150 SOUTH WARNER ROAD, SUITE 270 KING OF PRUSSIA, PA 19406 (610) 687-8303 FAX (610) 225-8160 ROBERT J. McDADE LISA BELLINO APELIAN MICHAEL W. CASEY WILLIAM E. DENGLER JOSEPH A. JULIANA JEFFREY tL LIEBESMAN MATTHEW E. McGUIRE JEFFREY W. MEEHAN MARK A. MINICOZZI KAREN SHORT NORRIS September 15, 2004 Via Certil~ed Mail - Return Receil~t Requested William P. Douglas, Esquire Douglas Law Office 27 W. High Street, Suite 2 Carlisle, PA 17013-1790 Winters v. Beverage Express, et al Cumberland County Court of Common Pleas, No. 03-6509 Our Client: Beverage Express Date of Loss: 12/17/01 Dear Mr. Douglas: Enclosed please fred a copy of the time-stamped Rule to File Complaint filed with the Court on September 13, 2004. Please note that you have twenty (20) days from the date of service in which to file a Complaint or a Judgment of Non Pros will be entered against you. If you have any questions or comments, please feel free to contact me. LBA/caw Enclosure CCi Very truly yours, Dir06t Dml. (610) 22~ B & K Beverage Beverage Express Karen M. Meyd, Claim Specialist HI, Zurich N.A. (Your File No.: 566-0087079-001) LISA BELLINO APELIAN, ESQIJIRE Attorney I.D. No: 55632 LAW OFFICE .OF ROBERT 2[. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 CHERYL WINTERS V. BEVERAGE EXPP~SS and B & K BEVERAGE, INC. ifa, d/b/a BEVERAGE EXPRESS ATTORNEY FOR DEFENDANTS, BEVERAGE EXPRESS CUMBERLAND COUNTY COURT OF COMMON PLEAS NO.: 03-6509 TR2AL BY JURY OF 12 DEMANDED PRAECIPE TO FILE COMPLAINT TO T~ PROTHONoTARy: Please enter s~ Rule upon Plaintiff to £fle a Compla/nt ~vithin twenty hereof or suffer the entry of a Judgmefit 0f Non Pros. ' LAW. OFFICE OF ROBERT I. McDAI~_~ . Be'Cerage Express RULE TO FILE COMPLAINT title a Complaint herein within (20) days after service hereof or suffer the entry o% Judgznent of Non Pros. ffO/~,~_____~ ~ Protho%tary ' ~ FROM RECORD ~,d '~.~F¢, 8, ~d C~1 at v~dtsie P~ ri Insured Mail ~-J C.O.D. 2 Art/cie Number F~s~'r~m'..'~/.[~../a~..~ 7002 0860 0003 4283 6597 ~' PSForm381:l;Aug~/st~2~bl~ ii ~, ~l~(~f~sti6ReturG~t,j~I ,~ ~, i, ,:, ,. 1, 2, ~d 3, ~so ~mplete ' . item 4 if R~tdcted Delive~ is desi~, . ~ ~ent - ~.[n~e can tatum the card to you _ /- -- ' [ ~ Add~ m A~acn this ca~ to the back of th~ m~.~ ~. B~ b~~M J ~( ~ ........... or on the front if space ~its .......... " .... · - ....... ' ~ ~am or ~live 1. ~lcle~dr~to: "~:' ' ~iv~d~d~mff~ 1? ~ Yes OFFICIAL USE Postage $ Certified Fee TelalPo~age&r-e~ $ CIt~, State, ~+ 4 . EXHIBIT "B" LAW OFFICE OF ROBERT J. McDADE Not a Partnership - Employees ora Member Company of Zurich North America WALNUT HILL PLAZA 1 $0 SOUTH WARNER ROAD, SUITE 270 KING OF PRUSSIA, PA 19406 (6to) 6s?-s3o3 FAX (610) 225.8160 ROBERT $. McDADE LISA BELLINO APELIAN MICHAEL W. CASEY WILLIAM E. DENGLER JOSEPH A. JULIANA JEFFREY R. LIEBESMAN MATTHEW E. McGUIRE JEFF1LEY W. MEEHAN MARK A. M1NICOZZI KAREN SHORT NORRIS October 29, 2004 William P. Douglas, Esquire Douglas Law Office 27 W. High Street Suite 2 Carlisle, PA 17013-1790 Winters v. Beverage Express, et al Cumberland County Court of Common Pleas, No. 03-6509 Our Client: Beverage Express Date of Loss: 12/17/01 Dear Mr. Douglas: Enclosed is the Notice of Intention to file Prae¢ipe for Entry of Judgement &Non Pros. Kindly file your Complaint in this matter within ten (I0) days of the date of this letter or suffer Judgement of Non Pros. Very truly yours, LBA:blm enclosure cc: Beverage Express LAW OFFICE OF ROBERT $. McDADE LISA BELLINO APELIAN Email: lisa.bellino, ap¢lian@zurichna, com Direct Dial: (610) 225-8174 Karen M. Meyd, Claim Specialist III, Zurich North America (Your File No.: 566-0087079-001) LISA BELLINO APELIAN, ESQUIRE Attorney I.D. No: 55632 LAW OFFICE OF ROBERT J. McDADE 150 South Warner Road, Suite 270 King of Prussia, PA 19406 (610) 687-8303 CHEKYL WINrliKS V. BEVERAGE EXPRESS and B & K BEVERAGE, INC. ifa, d/b/a BEVERAGE EXPRESS ATTORNEY FOR DEFENDANT, BEVERAGE EXPRESS CUMBERLAND COUNTY COURT OF COMMON PLEAS NO.: 03-6509 TRIAL BY JURY OF 12 DEMANDED NOTICE OF INTENTION TO FILEPRAECIPE FOR ENTRY OF JUDGMENT OF NON PROS TO: Cheryl Winters C/o William P. Douglas, Esquire Douglas Law Office Suite 2 27 W. High Street Carlisle, PA 17013-1790 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO FILE A COMPLAINT IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR RIGHT TO SUE THE DEFENDANT AND THEREBY LOSE PROPERTY OK OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Date: October 29, 2004