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HomeMy WebLinkAbout04-0739 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LEEANN KRAFT, 20 East Stony Lane, Apartment E Dover, York County, PA 17315 VS, DANIEL PISCOTTY 6503 Salem Park Circle Mechanicsburg, Cumberland County, PA 17050 and STEVENS. ANDERSON 150 ChaJnsaw Road Dillsburg, York County, PA 17019 Civil Action Law File NO, Oq ~' '73 ~ Jury Trial Demanded PRAECIPE FOR SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue summons in Trespass in the above case. Writ of Summons shall be issued and forwarded to Sheriff for service. Date: ,~///~/~,~/ Gary D. Madz, Esquir,~ Counsel for Plaintiff/ 96 South Georg?,,~treet Suite 430~ York, PA J,~401 Supreme Court ID Number: 35554 SUMMONS IN CIVIL ACTION TO: DANIEL PISCOTTY AND STEVEN ANDERSON YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Prothonotary/Clerk, Civil Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LEEANN KRAFT VS. DANIEL PISCOTTY and STEVENS. ANDERSON : Civil Action Law : File No. 04-739 : : Jury Trial Demanded .PRAECIPE TO REISSUE WRIT OF SUMMON,~ TO THE PROTHONOTARY/CLERK OF SAID COURT: Please re-issue the Writ of Summons in Trespass in the above case. Date: ary D. Martz, Eso~e Counsel for Plai. p~ff 96 South Ge.o,'~e Street, Suite 430 York, PA ~1-7'401 (717) 852'-8379 Supreme Court ID Number: 35554 THOMAS, THOMAS & HAFER, LLP 305 North Front SOeet P.O. Box 999 Harrisburg, PA 17108 W. Darren Powell, Esquire Attorney I.D. 68953 717-237-7154 Attorneys for Defendant LEEANN KRAFT, Plaintiff DANIEL PISCOTTY and STEVENS. ANDERSON, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 04-739 CIVIL TERM : CIVIL ACTION - LAW : JURY TRIAL DEMANDED ENTRY OF APPEARANCF TO THE PROTHONOTARY: Please enter my appearance on behalf of Defendant Daniel J. Piscotty in the abpve-capt oned case. Respectfully submitted, THOMAS HAFER, W. Darren Powell, EsquTFe I.D. Number: 68953 305 North Front Street P.O. Box 999 Harrisburg, PA 17101 (717) 237-7154 Attorney for Defendant CERTIFICATE OF SERVlCF hereby certify that a copy of the foregoing document was served upon the following, by enclosing a true and correct copy in an envelope addressed as follows, postage prepaid: Gary D. Martz, Esquire Martz & Gailey 96 South George Street, Suite 430 York, PA 17401 Steven S. Anderson 150 Chainsaw Road Dillsburg, PA 17050 W. Darren Powell, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17101 (717) 237-7154 THOMAS, THOMAS & HAFER, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 W. Darren Powell, Esquire Attorney I.D. 68953 717-237-7154 Atiomeys for Defendant LEEANN KRAFT, Plaintiff DANIEL PISCOTTY and STEVENS. ANDERSON, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 04-739 CIVIL TERM : CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE A COMPLAINT TO THE PROTHONOTARY: Kindly issue a Rule on Plaintiff to file a Complaint in the above case within twenty (20) days after service hereof or suffer a judgment of non pros. Respectfully submitted, I.D. Number: 68953 305 North Front Street P.O. Box 999 Harrisburg, PA 17101 (717) 237-7154 Attorney for Defendant Daniel Piscotty THOMAS, THOMAS & HAFEIL LLP 305 North Front Street P.O. Box 999 Hamsburg, PA 17108 W. l)arren Powell, Esquire Attorney I.D. 68953 717-237-7154 Attorneys for Defendant LEEANN KRAFT, Plaintiff DANIEL PISCOTTY and STEVENS. ANDERSON, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 04-739 CIVIL TERM : CIVIL ACTION - LAW : JURY TRIAL DEMANDED RULE TO FILE A COMPLAINT TO: LeeAnn Kraft, Plaintiff Gary D. Martz, Esquire Martz & Gailey 96 South George Street, Suite 430 York, PA 17401 You are hereby ruled to file a Complaint against Defendants within twenty (20) days of service of this Rule or a judgment of non pros will be entered against Plaintiff pursuant to Pa.R.C.P. 1037(a). [//~j~,~_-"~ · Prothonotary CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing RULE TO FILE A COMPLAINT was served by depositing the same in the United States M prepaid, at Harrisburg, Pennsylvania, on the ~ ~"'~' day of a/~p~ , 2004, on all counsel of records as follows: Gary D. Martz, Esquire Martz & Gailey 96 South George Street, Suite 430 York, PA 17401 Steven S. Anderson 150 Chainsaw Road Dillsburg, PA 17050 I.D. Number: 68953 305 North Front Street P.O. Box 999 Harrisburg, PA 17101 (717) 237-7154 Attorney for Defendant Daniel Piscotty IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LEEANN KRAFT VS. DANIEL PISCOTTY and STEVENS. ANDERSON Civil Action Law File No. 04~739 : Jury Trial Demanded NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth against you in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a default judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any ether claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service PA Bar Association P.O. Box 186 Harrisburg, PA 17108 800-692-7375 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LEEANN KRAFT : Civil Action Law VS. File No. 04-739 DANIEL PISCOTTY and STEVEN S, ANDERSON : Jury Trial Demanded AVISO Usted Ha Sido Demandado en la corte. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia escrita en persona o por abogado y presentar en la Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la corte puede decidir en su contra sin mas aviso o notificacion por cualquier dinero reclamado en la demanda o por cualiquier otra queja o compensacion reclamados por el Demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SlGUIENTEOFICINA. ESTAOFIClNAPUEDEPROVEERLEINFORMACIONACERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVIClOS DE UN ABOGADO, ES POSlBLE QUE ESTA OFIClNA LE PUEDA PROVEER INFORMAClON SOBRE AGENClAS QUE OFREZCAN SERVlCIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Lawyer Referral Service PA Bar Association P.O. Box 186 Harrisburg, PA 17108 800-692-7375 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY LEEANN KRAFT VS. DANIEL PlSCOTTY and STEVENS. ANDERSON PENNSYLVANIA Civil Action Law File No. 04-739 Jury Trial Demanded PLAINTIFF'S COMPLAINT Plaintiff LeeAnn Kraft is an adult individual residing at 20 Stony Lane, Apartment E, Dover, York County, Pennsylvania 17315. 2. Defendant Daniel Piscotty is an adult individual residing at 6503 Salem Park Circle, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Defendant Steven $. Anderson is an adult individual residing at 150 Chainsaw Road, Dillsburg, York County, Pennsylvania 17019. 4. On April 14, 2002, Plaintiff was the owner and operator of a 1998 Ford Taurus with Pennsylvania Registration Number BHD-9413. 5. On April 14, 2002, Defendant Daniel Piscotty was the owner and operator of a 1990 Buick Lasabre with Pennsylvania Registration Number DYP- 3498. 6. On April 14, 2002, Defendant Steven Anderson was the owner and operator of a 1992 Ford Bronco with Pennsylvania Registration Number EDR- 4846. 7. On April 14, 2002 at or about 7:15 p.m., Plaintiff was lawfully proceeding southbound on S.R. 15 near the intersection with West Lisburn Road in Mechanicsburg, Upper Allen Township, Cumberland County, Pennsylvania when Defendant Daniel Piscotty negligently and carelessly allowed his vehicle to strike Plaintiff's vehicle in the rear, pushing Plaintiff's vehicle into the vehicle in front of Plaintiff's vehicle on the roadway and causing injuries and damages to Plaintiff as are hereinafter set forth. 8. On April 14, 2002 at or about 7:15 p.m., Defendant Steven Anderson negligently and carelessly allowed his vehicle to strike Defendant Daniel Piscotty's vehicle in the rear, pushing Defendant Daniel Piscotty's vehicle into Plaintiff's vehicle, causing injuries and damages to Plaintiff as are hereinafter set forth. 9. Said accident and the resulting injuries and damages to Plaintiff were caused solely by the negligence and carelessness of Defendant(s) and were due in no manner whatsoever to any act or failure to act on the part of Plaintiff. 10. Solely as a result of said accident and the negligence and carelessness of Defendant(s), Plaintiff has suffered personal injuries including, but not limited to, the following: injuries to her neck and back with associated symptoms. 11. Solely as a result of said accident and the negligence and carelessness of Defendant(s), Plaintiff has been forced to incur medical expenses in treatment of the injuries suffered by her in this accident, the sum of which medical expenses has exceeded or may exceed the sum recoverable under the Pennsylvania Motor Vehicle Financial Responsibility Law, and Plaintiff will or may continue to incur medical expenses in the future treatment of injuries suffered by her in this accident. 12. Solely as a result of said accident and the negligence and carelessness of Defendant(s), Plaintiff has suffered a loss of eamings and an impairment of her earning capacity; said loss of earnings and impairment of her earning capacity will or may exceed the sum recoverable under the Pennsylvania Motor Vehicle Financial Responsibility Law, and Plaintiff will or may continue to incur a loss of earnings and an impairment of her earning capacity into the future. 13. As a further result of said accident and the negligence and carelessness of Defendants, Plaintiff has suffered and in the future will or may continue to suffer from mental and physical pain and suffering, a loss of enjoyment of life, embarrassment, humiliation, anxiety, and a limitation in her pursuit of daily activities, all to her great loss and detriment. 14. Plaintiff was covered by the full tort option on her motor vehicle ~nsurance policy in effect on the date of this accident. 15. This matter is alleged to exceed the applicable limits of arbitration and a jury trial is hereby demanded. COUNT I - LEEANN KRAFT V. DANIEL PlSCOTTY 16. The allegations set forth in paragraph numbers one through fifteen (1 - 15) are incorporated herein by reference thereto. 17. The negligence and carelessness of Defendant Daniel Piscotty in the operation of his motor vehicle at the time of this accident consisted of, but is 3 not limited to, the following: a) Failure to have his vehicle under proper control; b) Failure to keep a proper lookout for the presence of other motor vehicles on the roadway and surrounding traffic conditions; c) In continuing to operate his vehicle in a direction towards Plaintiffs motor vehicle when Defendant saw, or in the exercise of reasonable diligence should have seen, that further operation in that direction would result in a collision; d) Following Plaintiffs vehicle too closely in violation of the provisions of the Pennsylvania Motor Vehicle Code found at 75 Pa.C.S.A. § 3310; e) Failure to operate his vehicle at such a speed and with such control that he could bring his vehicle to a stop within his assured clear distance ahead in violation of the provisions of the Pennsylvania Motor Vehicle Code found at 75 Pa.C.S.A. § 3361; f) Operating his vehicle with careless disregard for the rights and safety of other individuals lawfully proceeding on the roadway, including Plaintiff, in violation of the provisions of the Pennsylvania Motor Vehicle Code found at 75 Pa.C.S.A. § 3714; 4 18. g) Negligence and carelessness at law; and h) Being otherwise careless and negligent under the circumstances and as discovery may reveal. Said accident and the resulting injuries and damages to Plaintiff were caused solely by the negligence and carelessness of Defendant Daniel Piscotty and/or the negligence and carelessness of Defendant Piscotty was a substantial factor in causing the accident and Plaintiff's injuries and damages. WHEREFORE, Plaintiff LeeAnn Kraft respectfully requests this Honorable Court to enter judgment against Defendant Daniel Piscotty in an amount in excess of Twenty-five Thousand Dollars ($25,000), plus costs and interest as allowed by law. COUNT II - LEEANN KRAFT V, STEVEN ANDERSON 19. The allegations set forth in paragraph numbers one through fifteen (1 - 15) are incorporated herein by reference thereto. 20. The negligence and carelessness of Defendant Steven ^nderson in the operation of his motor vehicle at the time of this accident consisted of, but is not limited to, the following: a) b) c) Failure to have his vehicle under proper control; Failure to keep a proper lookout for the presence of other motor vehicles on the roadway and surrounding traffic conditions; In continuing to operate his vehicle in a direction towards 5 Defendant Piscotty's motor vehicle and Plaintiff's motor vehicle when Defendant saw, or in the exercise of reasonable diligence should have seen, that further operation in that direction would result in a collision; d) Following Defendant Piscotty's vehicle and Plaintiff's vehicle too closely in violation of the provisions of the Pennsylvania Motor Vehicle Code found at 75 Pa.C.S.A. § 3310; e) Failure to operate his vehicle at such a speed and with such control that he could bring his vehicle to a stop within his assured clear distance ahead in violation of the provisions of the Pennsylvania Motor Vehicle Code found at 75 Pa.C.S.A. § 3361; f) Operating his vehicle with careless disregard for the rights and safety of other individuals lawfully proceeding on the roadway, including Plaintiff, in violation of the provisions of the Pennsylvania Motor Vehicle Code found at 75 Pa.C.S.A. § 3714; g) Negligence and carelessness at law; and h) Being otherwise careless and negligent under the circumstances and as discovery may reveal. 21. Said accident and the resulting injuries and damages to Plaintiff were caused solely by the negligence and carelessness of Defendant Steven 6 Anderson and/or the negligence and carelessness of Defendant Anderson was a substantial factor in causing the accident and Plaintiff's injuries and damages. WHEREFORE, Plaintiff LeeAnn Kraft respectfully requests this Honorable Court to enter judgment against Defendant Steven Anderson in an amount in excess of Twenty-five Thousand Dollars ($25,000), plus costs and interest as allowed by law. Respectfully submitted, Gary D. Martz,/~quire Counsel for J~raintiff 96 South G/~orge Street, Suite 430 York, PA 17401 (717) 852-8379 Supreme Court ID Number: 35554 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LEEANN KRAFT VS. DANIEL PISCOq-I'Y and STEVEN $. ANDERSON : Civil Action Law : File No. 04-739 : Jury Trial Demanded VERIFICATION I verify that the foregoing facts are true, upon my personal knowledge or information and belief. This verification is made subject to the penalties of Pa.C.S. Section 4904, relating to unsworn falsification to authorities. / Date: ~///'~/O ~ Kraft LEEANN KRAFT VS. DANIEL PISCOTTY and STEVENS. ANDERSON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil Action Law File No. 04-739 Jury Tda[ Demanded CERTIFICATE OF SERVICE I HEREBYCERTIFYthatlhavethis ~,~'~'/~ayof .,/~ ,2004, serveda true and correct copy of the foregoing Complaint by placing a copy in the United States First Class Mail, directed to the office address of the following: W. Warren Powell, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17101 Attorney for Defendant Daniel Piscotty By: Gary D. Martz, re Martz & Gaile~/LP Counsel fo/r,,,Plaintiff 96 S. Ge/e'rge Street, Suite 430 York, PA 17401 (717) 852-8379 I.D. No. 35554 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LEEANN KRAFT VS. DANIEL PlSCOTTY and STEVENS. ANDERSON : Civil Action Law : : File No. 04-739 : Jury Trial Demanded ,PRAECIPE TO REISSUE WRIT OF S;UMMON~ TO THE PROTHONOTARY/CLERK OF SAID COURT: Please re-issue the Writ of Summons in Trespass i~ the above case. Date: /Y Gary D. Ma, rtz, E~F~'re Counsel for P~tiff 96 South ~G~orge Street, Suite 430 York, P~d' 17401 (717) 862-8379 Supreme Court ID Number: 35554 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LEE,ANN KRAFT Civi) Action Law vs. File No. 04-739 D,ANIEL PI$COTTY and STEVENS. ANDERSON : Jury Trial Demanded _ACCEPTANCE OF SERVICI= I, Lori Renaldi-Waqar, accept service of the Complaint (on behalf of STEVEN ANDERSON) and certify that I am authorized to do so. Date: 'Z/~//~"!) /© ~ Lod Renaldi-Waqar Claims Representative (~ ~,,,~grie Insurance Group 01 Lou se Drive, P.O. Box 2013 Mechanicsburg, PA 17055-0710 LEEANN KRAFT, Plaintiff DANIEL PISCOTTY and STEVENS. ANDERSON, Defendants : IN THE COURT OF COMMON PLEAS : CUMBFRLAND COUNTY, : PENNSYLVANIA : NO. 04-739 CIVIL TERM : CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE FOR DISCONTINUANCE To the Prothonotary: Please mark the above case settled and discontinued. Gary D. Mart~ Martz & Gaile~" 96 South C.~rge Street, Suite 430 York, PA ~ 17401 Attorney for Plaintiff CERTIFICATE OF SERVICE hereby certify that a copy of the foregoing document was served upon the following, by enclosing a true and correct copy in an envelope addressed as follows, postage prepaid: Dated: May~, 2004 Gary D. Martz, Esquire Martz & Galley 96 South George Street, Suite 430 York, PA 17401 305 North Front Street P.O. Box 999 Harrisburg,, PA 17101 (717) 237-'7154 SHERIFF'S RETURN - REGULAR CASE NO: 2004-00739 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KRAFT LEEANN VS PISCOTTY DANIEL ET AL RONALD HOOVER , Cumberland County, Pennsylvania, Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 23rd day of February , by handing to together with says, the within WRIT OF SUMMONS PISCOTTY DANIEL DEFENDANT , at 2112:00 HOURS, at 6503 SALEM PARK CIRCLE MECHANICSBURG, PA 17050 DANIEL PISCOTTY a true and attested copy of WRIT OF SUMMONS 2004 and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 7.59 Affidavit .00 Surcharge 10.00 .00 35.59 Sworn and Subscribed to before me this /9 ~ day of -J~. 2~0~ A.D. ,-~ So Answers: R. Thomas Kline o5/1 /2oo4 MARTZ & GAILEY By: SHERIFF' S CASE NO: 2004-00739 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CI/MBERLAND KRAFT LEEANN VS PISCOTTY DANIEL ET AL RETURN - OUT OF COUNTY R. Thomas Kline , duly sworn according to law, says, that he made and inquiry for the within named DEFENDANT ANDERSON STEVENS but was unable to locate Him deputized the sheriff of YORK serve the within WRIT OF SUMMONS Sheriff or Deputy Sheriff a diligent , to wit: in his bailiwick. County, who being search and He therefore Pennsylvania, to On May 14th , 2004 attached return from YORK Sheriff's Costs: Docketing 6.00 Out of County 9.00 Surcharge 10.00 Dep York County 61.00 .00 86.00 05/14/2004 MARTZ & GAILEY Sworn and subscribed to before me this /~ day of ~ ~2~ A.D. , this office was in receipt of the So answers: R. Thomas Kline Sheriff of Cumberland County COUNTYOFYORK ~- ~o .j _~0 ...~u'PFICE OF THE SHERIFF .'~.¥,c~cAL,~ t~ ~ ~ ~ ~KET ST, YORK, PA 17401 ~ ~SHERIFFSE~ F ~~O~WT O~URN T~U ~ COPIES ~ff~ft __ u~-/j~ c~vilterm mn et al Writ of Stmrr~ns -'~ '_~. ~:3 COUNTY OF YORK ' OF THE SHERIFF (717) 771-9601 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN I PLAINTIFF/SI Leeann Kraft 2. CgqRT.~trI.~ B E R. u~-/.~ civil term 4. TYPE OF WRiT OR COMPLAINT 3. DEFENDANTISl Daniel Piscotty et al Writ of S~m,ons SERVE ~' 5 NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, A3~'ACHED, OR SOLD. Steven S. Anderson 6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT. NO., CITY, BORO, TWP., .~TA~E.M~ID ZIP COQuet---- ~/~o//~/'~' /'t/.* ~/ -lm azns w myra9 7. INDICATE SERVICE: ~ PERSONAL rt PERSON IN CHARGE ~I~DEPUTIZE (~i~i[3DC~:J'.;.~L [3 1ST CLASS MAIL g3 POSTED Q OTHER NOW Febn]a~; 20 ,2004 I, SHERIFF OF ~ COUNTY, PA, do hereby deputize the sheriff of York COUNTY to executeAb~' ~W. y4r_~ake return t~..~j~., ccording to law. This deputization being made at the request and risk of the plaintiff. -~'~ ~~_..~..~-. ~ SHERIFF OF ~ COUNTY 8. SPECIALINSTRUCTIONSOROTHERINFORMATIONTHATWILLASSISTINEXPEDITINGSERVICE:0UT OF COUNTYo~berland ADV FEE PD BY CUMBERLAND CTY SHERIFF NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B, WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after ~otifying person of levy or attachment, without liability on the part of such depuly or the sheriff to any plaintiff herein for any less, destruction, c~ removal of any Ixoparty before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY~I~IC.~t~OR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED GARY D. MARTZ,96 S. GEORGE ST. YORK PA I~ 17401 717-852-8379 03-19-2004 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOV~ (This area must be completed if notice is to be mailed). CUMBERLAND COUNTY SHERIFF'S DEPT. 13. I acknowledge receipt of the writ 14. DATE RECEIVED 15. Expiration/Hearing Date orcomplai~tasindicatedabove, RONDA M. AHRENS / RAT 02-23-2004 03-20-2004 16. HOWSERVED: PERSONAL( ) RESIDENCE( ) POSTED( ) POE( ) SNERIFF'SOFFICE( ) OTHER( ) SEE REMARKS BELOW 17.j~ I hereby cedify and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.) 187NAMEANDT~TLE~F~ND~VIDUALSERVED~L~STA~DRESsHERE~FN~TSH~AB~VE(Re~a~nshipt~Defendaot) 19. Date of Se~vice 20. TimeofService 23 Advance Costs 24. Service Costs [ 25.. N/F 26. Mil~j 27. Postege[28~SubTotaJ 29. Pound 30. Notary [31.Surctlg.[32. Tot. Costs[ 33 C~stsOuee~refund]_~l~k~N.~ 34F$'u~n. OOn CI ?..~..~ ~.~, I I 12.0o I . I( /.OOl · oretg COU ty osts I $$. Advance Costs136. Sel¥iceCosts 37. Notary Cert. 38. M age/Postage/No Found 39 Tota Costs 40. Cos s Oua or Refund I 41. AFFIRMED and subsc~bed to be/om me this 1 0 44. Signature of IMyCom . ' / 48. S~natum~Foreign ~ C~n~ Sh~ff 50. I ACKNO~E~E RECEIPT OF THE SHERIFF'S RETURN SIGNATURE SO ANSWERS 45. DATE 47. DATE 5-10-04 49 DATE 51 DATE RECEIVED