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Home My WebLink About08-1951IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STANLEY R. HOWELL 1221 State Road Duncannon, PA 17020 (Cumberland County) No. C8 - 1461 e w i ( ler'M Civil Action (X) Law ( ) Equity Plaintiff V. JOSEPH RUDA 65 Derbyshire Drive Carlisle, PA 17015 (Cumberland County) Defendant : PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Writ of Summons in the above-captioned action. X Writ of Summons shall be issued and Charles E. Schmidt, Jr. Schmidt Kramer PC 209 State Street Harrisburg, PA 17101 (717) 232-6300 aCo ca08 Date: Aa ( ) Attorney (X)Sheriff. Signature of Attof ney Supreme Court I.D. No. 19198 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Az 4, . - - ?- Proil?zi;*-i?w Date: 3427&9 By: Deputy ( X ) Check here if reverse is issued for additional information 3 R' ? O g w o ? a CA) . E SHERIFF'S RETURN - REGULAR CASE NO: 2008-01951 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOWELL STANLEY R VS RUDA JOSEPH MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon nI -,I -nnr TT the DEFENDANT , at 0940:00 HOURS, on the 31st day of March 2008 at CUMBERLAND COUNTY PRISON 1101 CLAREMONT ROAD CARLISLE, PA 17013 by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.80 Postage .58 Surcharge 10.00 00 33 .38 Sworn and Subscibed to before me this day of So Answers: 01 R. Thomas Kline 04/01/2008 SCHMIDT KRAMER By: Deputy Sheriff A. D. R SCHMIDT KRAMER PC BY: CHARLES E. SCHMIDT, JR., ESQUIRE I. D. #19198 209 State Street Harrisburg, PA 17101 (717) 232-6300 cschmidtCii schmidtkramer.com Attomeys for Plaintiff STANLEY R. HOWELL Plaintiff, V. JOSEPH RUDA Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2008-01951 : Jury Trial Demanded CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things, directed to the Pennsylvania State Police, pursuant to Rule 4009.22, Plaintiff certifies that: (1) a Notice of Intent to Serve the Subpoena with a copy.of the Subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the Subpoena is sought to be served, (2) a copy of the Notice of Intent, including the proposed Subpoena, is attached to this Certificate, (3) no objection to the subpoena has been received, and (4) the Subpoena which will be served is identical to the Subpoena which was attached to the Notice of Intent to Serve the Subpoena. SCHrA DT KRAMER PC By: Charles E. Schur dt, Jr., Esquire Attorney I.D. # 19198 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorneys for Plaintiff Date: ? I M I C)q SCHMIDT KRAMER PC BY: CHARLES E. SCHMIDT, JR., ESQUIRE I.D. #19198 209 State Street Harrisburg, PA 17101 (717) 232-6300 cschmidt (i-schmidtkramer. com STANLEY R. HOWELL Plaintiff, V. JOSEPH RUDA Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 2008-01951 : Jury Trial Demanded SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PENNSYLVANIA STATE POLICE ATTN: COMMISSIONER JEFFREY B. MILLER CUSTODIAN OF RECORDS 1800 ELMERTON AVENUE HARRISBURG, PA 17110-9758 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: 1. All requests are concerning the incident, which occurred on January 18, 2008, at 65 Derbyshire Drive, South Middleton Township, Cumberland County, Pennsylvania, in which Stanley Howell was shot at the home of Joseph Ruda. 2. All police investigation reports which relate or pertain, in any way, to the incident described above. 3. All notes, written or recorded, made or taken, during the investigation of the named incident; all drawings, diagrams, photographs (35mm or Polaroid), and video recordings made or taken, in the investigation of the named incident; and all statements taken during the investigation of the named incident; whether submitted for inclusion in the incident report or in the individual possession of the investigating troopers. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed below. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. This subpoena was issued at the request of the following person: Charles E. Schmidt, Jr., Esquire SCHMIDT KRAMER PC Attorney 1. D. # 19198 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorneys for Plaintiff BY THE COURT: Date: By: Prothonotary SCHMIDT KRAMER PC BY: CHARLES E. SCHMIDT, JR., ESQUIRE I.D. #19198 209 State Street Harrisburg, PA 17101 (717) 232-6300 cschrnid0 schmidtkramer.corn STANLEY R. HOWELL Plaintiff, JOSEPH RUDA v. Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2008-01951 Jury Trial Demanded NOTICE TO: PENNSYLVANIA STATE POLICE ATTN: COMMISSIONER JEFFREY B. MILLER CUSTODIAN OF RECORDS 1800 ELMERTON AVENUE HARRISBURG, PA 17110-9758 You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, , for the Pennsylvania State Police certify to the best of my knowledge, information, and belief that all documents or things required to be produced pursuant to the subpoena issued on produced. Date: have been for Pennsylvania State Police SCHMIDT KRAMER PC BY: CHARLES E. SCHMIDT, JR., ESQUIRE I.D. #19198 209 State Street Harrisburg, PA 17101 (717) 232-6300 cschmidtCirschmidtkramer.com STANLEY R. HOWELL Plaintiff, V. JOSEPH RUDA Defendant Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2008-01951 Jury Trial Demanded NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: JOSEPH RUDA C/O CUMBERLAND COUNTY PRISON 1101 CLAREMONT ROAD CARLISLE, PA 17013 Stanley R. Howell intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. SC T K ME PC By. Charles E. Schmidt, Jr., Esquire Attorney I.D. #19198 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorneys for Plaintiff tE, L'`4 Date: ?''j ¦ 209 state Street Har risburg,Ferinsylvania 17101 717.232.630 SchmidtKramer FAX 717.2,,2.646 ! www.schmWtkramer.com I N J U R Y L A W Y E R S Z(3 f9o May 16, 2008 Joseph Ruda c/o Cumberland County Prison 110 1 Claremont Road Carlisle, PA 17013 Re: Howell v. Ruda Dear Mr. Ruda: Please find enclosed a Notice explaining that Stanley Howell intends to serve a subpoena on the Pennsylvania State Police. You should give this document to your lawyer. If you have any questions, please telephone me at my office. Very truly yours, SCHMIDT 11?AM iR PC Charles E. Schmid , Jr. Attorney at Law CES/djc Enclosures cc: Stanley Howell IPA I r r I '. r r? Ir Q' For delivery Information visit our web site at www.usps,com, , Lri M m Postage $ Certified Fee rl 0 Return Receipt Fee Postmark Here C3 (Endorsement Required) C3 Restricted Delivery Fee (Endorsement Required) rU fU Total Postage 8 Fees I s 3. O of o Nat Apt 4.y Q , or PO Box NO. jQ t ?Q?P yv?° ` RIO 14 4 Cry, State, ZIP+4 / / • ..__. . e j / PS Form 3800 August 2006 See RcveT?e !or Instructions , l Certified Mail Provides: a Amailint !ipt ¦ A up' •dritifier for your mailpiece ¦ A re'very kept by the Postal Service for two years Important ?0 ¦ Corti led Mail ' be combined with First-Class Mail* or Priority Mail. ¦ Certified Mail is n for any class of international mail. ¦ NO INSURANCE C - IS PROVIDED With Certified Mail. For valuables, please consid ?O -or Registered. Mail. ¦ For an additional fee, a Retu ?i ',ay be requested to provide proof of delivery. To obtain Return Recei 'ease complete and attach a Return Receipt (PS Form 3811) to the artic 513 -9pplicable postage to cover the fee. Endorse mailpiece "Return Receip ". To receive a fee waiver for a dupllicdate return receipt, a USPSe post s s or Certified Mail receipt is ¦ For an additional fee, delivery may be rest 994 'he addressee or addressee's authorized agent. Advise the clerk or lilpiece with the endorsement 'Restricted Delivery'. ¦ If a postm9rk on ft Certified Mail receipt is desired, plea sent the arti- cle at the. post offige fgr-postmarking. If a postmark•on.th Certified Mail receipt is not needed, detach and affix label with postage and mail. 1MPORTANT:'Save this receipt arid ptesent It when making an Inquiry. PS Form 3800. August 2006 (Reverse) PSN 7530.02-000.9047 .` ? i- y r ova t sCHMIDT KRAMER PC BY: CHARLES E. SCHMIDT, JR., ESQUIRE I.D. #19198 209 State Street Harrisburg, PA 17101 (717) 232-6300 eschmidtna,schmidtlcramer.com Respectfully submitted, STANLEY R. HOWELL, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. 2008-01951 JOSEPH RUDA, CIVIL ACTION - LAW Defendant : JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE AND END To: CUMBERLAND COUNTY PROTHONOTARY Please mark the captioned action discontinued and ended. A Verification executed by Plaintiff is attached. Date: f 1&t / ? , Ow U MLM-OF ICE CY THrE Pr'',i HC)'0,TAPY 2010 MAR 19 AM 8: 34 Attorneys for Plaintiff PC By. . f C Charles E. Schmidt, Attorney I.D. # 19198 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorneys for Plaintiffs , Esquire 1 VERIFICATION I, Stanley R. Howell, date of birth 9 / 29 / 1988, hereby authorize my attorneys to discontinue the action pending in Cumberland County, known as Howell v. Ruda, No. 2008-01951, based on the representation that there is no liability coverage and no assets which can be recovered against Defendant Ruda. j & ?) q741 Stan ey R. Howell