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Home My WebLink About09-1339{- 4" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA - CIVIL DIVISION NARCISO A. AND MARNIE L. RODRIGUEZ-CAYRO ; HUSBAND & WIFE; ; 40 MAYBERRY LANE ; CIVIL ACTION - LAW MECHANCISBURG, PA, 16509 ; 09- 120A CIVIL TERM PLAINTIFFS, ; vs. JOHN F. AND HOLLY A. MIRA, HUSBAND & WIFE, 2401 ASCOTT WAY MECHANICSBURG, PA 17055, AND CYNTHIA ARMOUR-HELM, BROKER OF RECORD CATHIE HEIKA, ASSOCIATE BROKER MARK YON, AGENT EXIT REALTY CAPITAL AREA 4999 JONESTOWN ROAD, SUITE 202 HARRISBURG, PENNSYLVANIA 17109, AND EXIT REALTY CAPITAL AREA 4999 JONESTOWN ROAD, SUITE 202 HARRISBURG, PENNSYLVANIA 17109 K & C REALTY, INC 4505 FARGREEN ROAD HARRISBURG, PA 17111 AND DEFENDANTS NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth 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 judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any 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, TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association, 2 Liberty Avenue, Carlisle, Pennsylvania Telephone number 717-249-3166 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA - CIVIL DIVISION NARCISO A. AND MARNIE L. RODRIGUEZ-CAYRO HUSBAND & WIFE, 40 MAYBERRY LANE MECHANCISBURG, PA, 16509 PLAINTIFFS, VS. JOHN F. AND HOLLY A. MIRA, HUSBAND & WIFE, 2401 ASCOTT WAY MECHANICSBURG, PA 17055, CYNTHIA ARMOUR-HELM, & CATHIE HEIKA, & MARK YON, C/O EXIT REALTY CAPITAL AREA 4999 JONESTOWN ROAD, SUITE 202 HARRISBURG, PENNSYLVANIA 17109, EXIT REALTY CAPITAL AREA C/O CYNTHIA ARMOUR-HELM 4999 JONESTOWN ROAD, SUITE 202 HARRISBURG, PENNSYLVANIA 17109 K & C REALTY, INC C/O CYNTHIA ARMOUR-HELM 4505 FARGREEN ROAD HARRISBURG, PA 17111 AND AND AND DEFENDANTS CIVIL ACTION - LAW 3 ;09- /3 3 9 CIVIL TERM 3 3 3 s PRAECIPE FOR WRIT OF SUMMONS PURSUANT TO PA ICE 1007 (1) AND WRIT OF SUMMONS ISSUED TO: JOHN AND HOLLY MIRA; CYNTHIA ARMOUR-HELM; CATHERINE A. HEIKA; MARK V. YON; EXIT REALTY-CAPITOL AREA; AND K&C REALTY INC. 09 ! 33Q C;vi 1 By (Deputy) You are hereby notified that Narciso A. and Mamie L. Rodriguez-Cayro have commenced an action against you. Date: March 4, 2009 (Name of rothonotary or Clerk) PA Attorney ID No. 86046 RUBEN & ARoNsON, LLP 321 N. Front Street Harrisburg, PA 17101 Telephone No.: 717-233-2435 Facsimile No.: 717-233-24.65 ' .,sq. w -? ?. v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA - CIVIL DIVISION NARCISO A. AND MARNIE L. RODRIGUEZ-CAYRO HUSBAND & WIFE, 40 MAYBERRY LANE MECHANCISBURG, PA, 16509 VS. PLAINTIFFS, JOHN F. AND HOLLY A. MIRA, HUSBAND & WIFE, 2401 ASCOTT WAY MECHANICSBURG, PA 17055, AND CYNTHIA ARMOUR-HELM, BROKER OF RECORD CATHIE HEIKA, ASSOCIATE BROKER MARK YON, AGENT EXIT REALTY CAPITAL AREA 4999 JONESTOWN ROAD, SUITE 202 HARRISBURG, PENNSYLVANIA 17109, EXIT REALTY CAPITAL AREA 4999 JONESTOWN ROAD, SUITE 202 HARRISBURG, PENNSYLVANIA 17109 K & C REALTY, INC 4505 FARGREEN ROAD HARRISBURG, PA 17111 AND AND DEFENDANTS CIVIL ACTION - LAW 09-1339 CIVIL TERM PRAECIPE TO DISCONTINUE LAWSUIT PURSUANT TO PA. R.C.P. 229 On March 3, 2009 Plaintiffs initiated the above captioned action by filing a Praecipe for Writ of Summons. Subsequent to the initiation of the underlying lawsuit, Plaintiffs and Defendants were able to amicably resolve their differences. Accordingly, Plaintiffs seek to discontinue the underlying civil action. espectfyll3C sum-, ,Narciso ("llek") A.?z-Cayro, E3quire PAID NO. 86046 Ruben & Aronson, LLP 321 N. Front Street Harrisburg, PA 17101 Office No. 717-233-2435 Facsimile No. 717-233-2465 ??:? -. `? 'T7 ? r??, ? r?~ -:; ? ; r C ? _ _ r,? ?. Cv CERTIFICATE OF SERVICE I, Nick A. Rodriguez-Cayro, hereby certify that on the 26`h day of March 2008, a true and correct copy of the attached Praecipe to Discontinue was served via First Class U.S. Mail, postage prepaid, and facsimile on the following: JOHN F. AND HOLLY A. MIRA, HUSBAND & WIFE, 2401 ASCOTT WAY MECHANICSBURG, PA 17055, CYNTHIA ARMOUR HELM, BROKER OF RECORD CATHIE HEIKA, ASSOCIATE BROKER MARK YON, AGENT EXIT REALTY CAPITAL AREA 4999 JONESTOWN ROAD, SUITE 202 HARRISBURG, PENNSYLVANIA 17109, EXIT REALTY CAPITAL AREA 4999 JONESTOWN ROAD, SUITE 202 HARRISBURG, PENNSYLVANIA 17109 K & C REALTY, INC 4505 FARGREEN ROAD HARRISBURG, PA 17111 RespectfAut Narciso g z-Cayro Pa. I.D. No. 86046 Ruben & Aronson, LLP Counsel for Plaintiffs 321 North Front Street Harrisburg, PA 17101 Office No. (717) 233-2435 Facsimile No. (717) 233-2465 C' ?=? .? .._ ? --+ ? _ --?, W '?.3 "; rr? [ ?wa .s t.1"! -136 s Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy cr ofit?nbrr Edward L Schorpp Solicitor Jody S Smith 0MCE Cr ' u<RIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/12/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within name defendant, to wit: Holly A. Mira, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint and Notice according to law. 03/12/2009 ° R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within name defendant, to wit: K & C Realty, but was unable to locate them in his bailiwick He therefore deputized the heriff of Dauphin County, PA to serve the within Writ of Summons according to law. 03/12/2009 R. Thomas Kline, Sheriff w o being duly sworn according to law states that he made a diligent search and inquiry for the within name defendant, to wit: Cynthia Armour-Helm, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Writ of Summons according to law. 03/12/2009 ° R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within name defendant, to wit: Exit Realty, but was unable to locate them in his bailiwick. He therefore deputized the heriff of Dauphin County, PA to serve the within Writ of Summons according to law. 03/12/2009 ° R. Thomas Kline, Sheriff w o being duly sworn according to law states that he made a diligent search and inquiry for the within name defendant, to wit: Catherine Heika, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Writ of Summons according to law. 03/12/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within name defendant, to wit: Mark Yon, but was unable to locate him in his bailiwick. He therefore deputized the Sh riff of Dauphin County, PA to serve the within Writ of Summons according to law. 03/13/2009 11:55 AM - Shawn Harriso , Deputy Sheriff, who being duly sworn according to law, states that on March 13, 2009 at 1155 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: John F. ira, by making known unto John F. Mira personally, at 2401 Ascott Way, Mechanicsburg, Cumberla d County, Pennsylvania its contents and at the same time handing to him personally the said true an correct copy of the same. 03/26/2009 o R. Thomas Kline, Sheriff, ho being duly sworn according to law, states that on March 26, 2009 at 1536 hours this Complaint and tice upon defendant Mark Yon is returned not served per request from attorney Nick A. Rodriguez Cayro. 03/26/2009 ® R. Thomas Kline, Sheriff, ho being duly sworn according to law, states that on March 26, 2009 at 1536 hours this Complaint and tice upon defendant Catherine Heika is returned not served per request from attorney Nick A. Rodriguez Cayro. 03/26/2009 R. Thomas Kline, Sheriff, ho being duly sworn according to law, states that on March 26, 2009 at 1536 a hours this Complaint and tice upon defendant Exit Realty Capital Area is returned not served per request from attorney Nick A. Rodriguez-Cayro. 03/26/2009 ` R. Thomas Kline, Sheriff, who being duly sworn according to law, states that on March 26, 2009 at 1536 hours this Complaint and Notice upon defendant Cynthia Armour-Heim is returned not served per request from attorney Nick A. Rodri uez-Cayro. 03/26/2009 ° R. Thomas Kline, Sheriff, who being duly sworn according to law, states that on March 26, 2009 at 1536 hours this Complaint and N tice upon defendant K & C Realty is returned not served per request from attorney Nick A. Rodriguez Cayro. 03/26/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that on March 26, 2009 at 1536 hours this Complaint and Notice upon defendant Holly A. Mira is returned not served per request from attorney Nick A. Rodriguez Cayro. SHERIFF COST: $174.22 April 09, 2009 2009-1339 NARCISO A. RODRI, VS JOHN F. MIRA .YRO By SO ANSWERS, R THOMAS KLINE, SHERIFF Deputy Sheriff ALED-4` RCE OF THIE PROTHONOTARY 2049 APR -9 PM 2: 17 PENNSYILVA"NA