HomeMy WebLinkAbout08-3138F:\FILES\CGents\12997 Knott\12997. Lpralkdm
Created: 9/20/04 0:06PM
Revised: 5/19/08 10:54AM
12997.1
George B. Faller, Jr., Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER.
MARTSON LAW OFFICES
I.D. 49813
Katie J. Maxwell, Esquire
I.D. 206018
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
CATHERINE E. KNOTT, as Executrix
of the Estate of JEROME KNOTT,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
STONEBRIDGE LIFE INSURANCE
COMPANY,
Defendant
NO. 68- 3t 3 O C;? L?ErL.•-?-?
CIVIL ACTION - LAW
: JURY TRIAL DEMA]VDED
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please issue a writ of summons against Stonebridge Life Insurance Company, 2700 West
Plano Parkway, Plano, Texas 75075-8200, as Defendant in the above-captioned action and return
same to our office for service.
MARTSON LAW OFFICES
By °? - -
Katie M. Ma 11, Esquire
I.D. Number 206018
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Date: May 19, 2008
. %.
Commonwealth of Pennsylvania
County of Cumberland
WRIT OF SUMMONS
Court of Common Pleas
CATHERINE E. KNOTT, AS
EXECUTRIX OF THE ESTATE
OF JEROME KNOTT
Plaintiff
Vs. No 08-3138 CIVIL TERM
STONEBRIDGE LIFE INSURANCE
COMPANY
2700 WEST PLANO PARKWAY
PLANO, TEXAS 75075-8200 In CivilAction-Law
Defendant
To STONEBRIDGE LIFE INSURANCE COMPANY,
You are hereby notified that CATHERINE E. KNOTT, AS EXECUTRIX OF
THE ESTATE OF JEROME KNOTT, 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.
1
(SEAL) Cu is R. Long, no ry
Date MAY 19, 2008 By
Deputy
Attorney:
Name: KATIE M. MAXWELL, ESQUIRE
Address: MARTSON LAW OFFICE
10 EAST HIGH STREET
CARLISLE, PA 17013
Attorney for: Plaintiff
Telephone: 717-243-3341
Supreme Court ID No. 206018
CATHERINE E. KNOTT, AS EXECUTRIX IN THE COURT OF COMMON PLEAS OF
OF THE ESTATE OF JEROME KNOTT, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
: NO. 08-3138 CIVIL TERM
vs.
STONEBRIDGE LIFE INSURANCE CIVIL ACTION - LAW
COMPANY,
Defendant.
ENTRY OF APPEARANCE
Please enter the appearance of Brian P. Downey and Natalie Grill Einsig as
counsel for Defendant Stonebridge Life Insurance Company in the above action.
Date: June 11, 2008
Brian P. Downey (PA 59891)
Natalie Grill Einsig (PA 89791)
PEPPER HAMILTON LLP
100 Market Street, Suite 200
Post Office Box 1181
Harrisburg, PA 17108-1181
Telephone: 717.255.1170
Fax: 717.238.0575
Email: downeyb@pepperlaw.com
einsign@pepperlaw.com
Attorneys for Defendant
Stonebridge Life Insurance Company
CERTIFICATE OF SERVICE
I certify that on June 11, 2008, I caused a true and correct copy of the foregoing
Entry of Appearance to be served upon counsel of record by United States mail, first class
postage prepaid, addressed as follows:
Katie M. Maxwell, Esquire
Martson Law Office
10 East High Street
Carlisle, PA 17013
Natalie Grill Einsig (PA 89791)
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CATHERINE E. KNOTT, AS EXECUTRIX IN THE COURT OF COMMON PLEAS OF
OF THE ESTATE OF JEROME KNOTT, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
NO. 08-3138 CIVIL TERM
vs. :
STONEBRIDGE LIFE INSURANCE CIVIL ACTION - LAW
COMPANY, :
Defendant.
PRAECIPE FOR RULE TO FILE COMPLAINT
TO THE PROTHONOTARY:
In accordance with Pa. R. Civ. P. 1037(a), please issue a Rule upon the Plaintiff to
file a complaint in this matter within twenty (20) days of service or suffer a judgment of non
pros.
1,41-- 43J 2?-?
Brian P. Downey (PA 59891)
Natalie Grill Einsig (PA 89791)
PEPPER HAMILTON LLP
100 Market Street, Suite 200
Post Office Box 1181
Harrisburg, PA 17108-1181
Telephone: 717.255.1170
Fax: 717.238.0575
Email: downeyb@pepperlaw.com
einsign@pepperlaw.com
Attorneys for Defendant
Date: June 13, 2008 Stonebridge Life Insurance Company
CERTIFICATE OF SERVICE
I certify that on June 13, 2008, I caused a true and correct copy of the foregoing
Praecipe for Rule to File Complaint to be served upon counsel of record by United States mail,
first class postage prepaid, addressed as follows:
Katie M. Maxwell, Esquire
Martson Law Office
10 East High Street
Carlisle, PA 17013
Natalie Grill Einsig (PA 89791)
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CATHERINE E. KNOTT, AS EXECUTRIX
OF THE ESTATE OF JEROME KNOTT,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
vs.
NO. 08-3138 CIVIL TERM
STONEBRIDGE LIFE INSURANCE
COMPANY,
Defendant.
CIVIL ACTION - LAW
RULE TO FILE COMPLAINT
AND NOW, this ' day of June, 2008, upon praecipe of Defendant, a
Rule is hereby entered against the Plaintiff to file a complaint within twenty (20) days of service
or suffer a judgment of non pros.
P Aary/ y Pro otary
(SEAL)
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CATHERINE E. KNOTT, AS EXECUTRIX
OF THE ESTATE OF JEROME KNOTT,
Plaintiff,
VS.
STONEBRIDGE LIFE INSURANCE
COMPANY,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-3138 CIVIL TERM
: CIVIL ACTION - LAW
PRAECIPE TO ENTER JUDGMENT OF NON PROS
TO THE PROTHONOTARY:
Please enter judgment of non pros in favor of defendant and against plaintiff for
plaintiff's failure to file a complaint in this action within the required time. Plaintiff was served
with a rule to file complaint on or about June 20, 2008, and plaintiff's complaint was due to be
filed on or before July 10, 2008.
The undersigned counsel for defendant hereby certifies that defendant's written
notice of intention to file praecipe for entry of judgment of non pros (the "Important Notice")
was mailed to plaintiff's counsel, Katie M. Maxwell, Esquire, 10 East High Street, Carlisle, PA
17013, on September 23, 2008, which is after the failure to file a complaint and at least 10 days
prior to the filing of this praecipe. A copy of this Important Notice is attached to this praecipe.
Brian P. Downey (PA 59891)
Natalie Grill Einsig (PA 89791)
PEPPER HAMILTON LLP
100 Market Street, Suite 200
Post Office Box 1181
Harrisburg, PA 17108-1181
Telephone : 717.2 5 5.117 0
Fax: 717.238.0575
Email: downeyb@pepperlaw.com
einsign@pepperlaw.com
Date: October 14, 2008
Attorneys for Defendant
Stonebridge Life Insurance Company
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CATHERINE E. KNOTT, AS EXECUTRIX
OF THE ESTATE OF JEROME KNOTT,
Plaintiff,
vs.
STONEBRIDGE LIFE INSURANCE
COMPANY,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 08-3138 CIVIL TERM
: CIVIL ACTION - LAW
NOTICE OF INTENTION TO FILE
PRAECIPE TO ENTER JUDGMENT OF NON PROS
TO: Catherine E. Knott, as Executrix of the Estate of Jerome Knott
c/o Katie M. Maxwell, Esquire
Martson Law Office
10 East High Street
Carlisle, PA 17013
DATE OF NOTICE: September 23, 2008
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO FILE A
COMPLAINT IN THIS CASE. UNLESS YOU ACT WITHIN TEN 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 OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO A 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 BAR ASSOCIATION
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone: 800.990.9108
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rian P. Downey (PA 59891)
Natalie Grill Einsig (PA 89791)
PEPPER HAMILTON LLP
100 Market Street, Suite 200
Post Office Box 1181
Harrisburg, PA 17108-1181
Telephone: 717.255.1170
Fax: 717.238.0575
Email: downeyb@pepperlaw.com
einsign@pepperlaw.com
Attorneys for Defendant
Date: September 23, 2008 Stonebridge Life Insurance Company
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CERTIFICATE OF SERVICE
I certify that on September 23, 2008,1 caused a true and correct copy of the
foregoing Notice of Intention to File Praecipe to Enter Judgment of Non Pros to be served upon
counsel of record by United States mail, first class postage prepaid, addressed as follows:
Katie M. Maxwell, Esquire
Martson Law Office
10 East High Street
Carlisle, PA 17013
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Natalie Grill Einsig (PA 89791)
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CERTIFICATE OF SERVICE
I certify that on October 14, 2008,1 caused a true and correct copy of the
foregoing Praecipe to Enter Judgment of Non Pros to be served upon counsel of record by
United States mail, first class postage prepaid, addressed as follows:
Katie M. Maxwell, Esquire
Martson Law Office
10 East High Street
Carlisle, PA 17013
Natalie Grill Einsig (PA 89791)
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CATHERINE E. KNOTT, AS EXECUTRIX
OF THE ESTATE OF JEROME KNOTT,
Plaintiff,
VS.
STONEBRIDGE LIFE INSURANCE
COMPANY,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-3138 CIVIL TERM
CIVIL ACTION - LAW
NOTICE OF ENTRY OF JUDGMENT OF NON PROS
TO Catherine E. Knott, as Executrix of the Estate of Jerome Knott
c/o Katie M. Maxwell, Esquire
10 East High Street
Carlisle, PA 17013
Pursuant to the requirements of Pa. R.C.P. No. 236, you are hereby notified that on
02bber Wf? , 2008, judgment of non pros was entered against you for
failure to file a complaint.
Date:
P onotary
Counsel for Defendant certifies that the name and address of the
proper party/person to receive this notice is:
Catherine E. Knott, as Executrix of the Estate of Jerome Knott
c/o Katie M. Maxwell, Esquire
10 East High Street
Carlisle, PA 17013