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Home My WebLink About09-2386JOAN DUFOUR and ASHLEY RYAN DUFOUR, Plaintiffs V. TIMOTHY L. DEUTSCH t/d/b/a TIM'S TOWING & REPAIR and TIM'S TOWING, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 2009- CIVIL TERM CIVIL ACTION PRAECIPE EQR ISSUANCE OF A WRIT OF SUMMONS TO CURTIS R. LONG, PROTHONOTARY: Please issue a Writ of Summons against the defendant, TIMOTHY L. DEUTSCH t/d/b/a TIM'S TOWING & REPAIR and enter our appearance on behalf of the plaintiffs, JOAN DUFOUR and ASHLEY RYAN DUFOUR. Please direct the Sheriff to serve the defendants as follows: TIMOTHY L. DEUTSCH t/d/b/a TIM'S TOWING & REPAIR and TIM'S TOWING 50 SLUSSER LN. SUGARLOAF, PA 18249 Respectfully submitted, IRWIN & McKNIGHT, P.C. By: v Marcus A. McKnig t, III, Esquire Supreme Court I.D. No: 25476 Matthew A. McKnight, Esquire Supreme Court I.D. No: 93010 60 West Pomfret Street, Carlisle, PA 17013 (717) 249-2353 Date: April 15, 2009 To: TIMOTHY L. DEUTSCH t/d/b/a TIM'S TOWING & REPAIR and TIM'S TOWING You are hereby notified that JOAN DUFOUR and ASHLEY RYAN DUFOUR., plaintiffs, have commenced an action against you which you are required to defend or a default judgment may be entered against you. By: Date: - , 2009 i 4671n." S PROTH NO Y DEPUTY FILEG-t r rub OF THE ? ?+? ? ?" ° NARY 2009 APR 15 PH 3: 22 Ch.#LQL 1 I 78.50 pd by m??SnS Rec. ? aa3'78? Sheriffs Office of Cumberland County R Thomas Kline 1100" tr at 1:1ANlvrt, Edward L Scho ?p Sheriff Ronny R Anderson Jody S Smith Chief Deputy OFFICF ' '"E Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/16/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Timothy L. Deutsch, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Luzerne County, PA to serve the within Writ of Summons according to law. 04/16/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Tim's Towing, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Luzerne County, PA to serve the within Writ of Summons according to law. 04/24/2009 02:44 PM - Luzerne County Return: And now April 24, 2009at 1444 hours I, Michael Savokinas, Sheriff of Luzerne County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Timothy Deutsch by making known unto Timothy Deutsch personally at State Route 924 Humboldt, its contents and at the same time handing to him personally the said true and correct copy of the same. 04/24/2009 02:44 PM - Luzerne County Return: And now April 24, 2009at 1444 hours I, Michael Savokinas, Sheriff of Luzerne County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Tim's Towing by making known unto Timothy Deutsch, owner at State Route 924 Humboldt, its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $53.44 SO AN§WERS,/? May 11, 2009 2009-2386 Joan Dufor v Tim's Towing MAS KLINE, SHERIFF n f.F?T ` i _- - C"1 w 972862.doc DICKIE, MCCAMEY & CHILCOTE, P.C. BY: Charles E. Haddick, Jr., Esquire ATTORNEY I.D. NO. 55666 BY: Christine L. Line, Esquire ATTORNEY I.D. NO. 93257 Plaza 21, Suite 302 425 North 21st Street Camp Hill, PA 17011 717-731-4800 (Tele) 888-811-7144 (Fax) JOAN DUFOUR AND ASHLEY RYAN DUFOUR, ATTORNEY FOR: DEFENDANTS TIMOTHY L. DEUTSCH T/DB/A TIM'S TOWING & REPAIR AND TIM'S TOWING IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA, DISTRICT Plaintiffs, V. TIMOTHY L. DEUTSCH T/D/B/A TIM'S TOWING & REPAIR AND TIM'S TOWING, Defendants. NO. 2009-2386 CIVIL ACTION JURY TRIAL DEMANDED PRAECIPE FOR CHANGE OF ADDRESS TO THE PROTHONOTARY: Kindly enter the new address of Dickie, McCamey & Chilcote, P.C., and Charles E. Haddick, Jr., Esquire and Christine L. Line, Esquire, counsel for Defendants, Timothy L. Deutsch t/d/b/a Tim's Towing & Repair and Tim's Towing as follows: Dickie, McCamey & Chilcote, P.C. C*) ? Q Plaza 21, Suite 302 .-4 425 North 21S` Street zco rn- Camp Hill, PA 17011 { ;0 -Orn to C3 C3 y? -n =o z v Respectfully Submitted, DICKIE, MCCAMEY & CHILCOTE, P.C. Date: June 28, 2011 By: r., Charles E. Haddick, Jr., Esquire Attorney I.D. No. 55666 Christine L. Line, Esquire Attorney I.D. No. 93257 Plaza 21, Suite 302 425 North 21 st Street Camp Hill, PA 17011-2223 717-731-4800 Attorney for Defendants, Timothy L. Deutsch t/d/b/a Tim's Towing & Repair and Tim's Towing 2 I CERTIFICATE OF SERVICE AND NOW, this 06 day of fal j,-e-- , 2011, I, Charles E. Haddick, Jr., Esquire, hereby certify that I did serve a true and correct copy of the foregoing PRAECIPE FOR CHANGE OF ADDRESS upon all counsel of record by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill, Pennsylvania, addressed as follows: By First-Class Mail: Marcus A. McKnight, III, Esquire LAW OFFICES OF IRWIN & MCKNIGHT 60 West Pomfret Street Carlisle, PA 17013 (Plaintiff Counsel) es E. Haddick, Jr., Esquire .t 1054432.doc DICKIE, MCCAMEY & CHILCOTE, P.C. BY: Charles E. Haddick, Jr., Esquire ATTORNEY I.D. NO. 55666 BY: Christine L. Line, Esquire ATTORNEY I.D. NO. 93257 Plaza 21, Suite 302 425 North 21st Street Camp Hill, PA 17011 717-731-4800 (Tele) 888-811-7144 (Fax) JOAN DUFOUR AND ASHLEY RYAN DUFOUR, Plaintiffs, ATTORNEY FOR: DEFENDANTS TIMOTHY L. DEUTSCH T/DB/A TIM'S TOWING & REPAIR AND TIM'S TOWING IN THE COURT OF COMMON P OF CUMBERLAND COUNTY, PENNSYLVANIA NO.2009-2386=s V. TIMOTHY L. DEUTSCH T/DB/A TIM'S TOWING & REPAIR AND TIM'S TOWING, Defendants. CIVIL ACTION JURY TRIAL DEMANDED PRAECIPE TO REMOVE i ?r rr TO THE PROTHONOTARY: Kindly remove from the docket the Motion to Compel Plaintiff's Authorizations and Brief in Support filed by Defendant Timothy L. Deutsch t/d/b/a Tim's Towing & Repair and Tim's Towing. Upon receipt of our Motion to Compel, Plaintiff provided us with executed Authorizations. Respectfully Submitted, DICKIE, MCCAMEY & CHILCOTE, P.C. Date: September 28, 2011 By: _ ( ( ? ?/j , ?/ 6 1 W/-, ?/ Charles E. Haddick, Jr., Esquire Attorney I.D. No. 55666 Christine L. Line, Esquire Attorney I.D. No. 93257 Plaza 21, Suite 302 425 North 21 st Street Camp Hill, PA 17011-2223 717-731-4800 Attorney for Defendants, Timothy L. Deutsch t/d/b/a Tim's Towing & Repair and Tim's Towing 2 CERTIFICATE OF SERVICE AND NOW, September 28, 2011, I, Christine L. Line, Esquire, hereby certify that I did serve a true and correct copy of the foregoing PRAECIPE TO REMOVE upon all counsel of record by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill, Pennsylvania, addressed as follows: By First-Class Mail: Marcus A. McKnight, III, Esquire LAW OFFICES OF IRWIN & MCKNIGHT 60 West Pomfret Street Carlisle, PA 17013 (Plaintiff Counsel) ( (it " Christine L. Line, Esquire JOAN DUFOUR and IN THE COURT OF COMMON PLEAS OF ASHLEY RYAN DUFOUR, CUMBERLAND COUNTY,PENNSYLVANIA Plaintiffs , V. 2009-2386 CIVIL TERM TIMOTHY L.DEUTSCH t/d/b/a CIVIL ACTION TIM'S TOWING& REPAIR and TIM'S TOWING, , Defendant , PRAECIPE TO SETTLE AND DISCONTINUEry c To the Prothonotary: -o s•-' - . =_"iD - -c�M Please mark the above-captioned case settled and discontinued. cn> = =C Respectfully submitted, . IRWIN & Mc IGHT,P. . ciiP5 ght,III,Esqui reetia 17013 Date: September 1'0, 2013 .z JOAN DUFOUR and : IN THE COURT OF COMMON PLEAS OF ASHLEY RYAN DUFOUR, : CUMBERLAND COUNTY,PENNSYLVANIA Plaintiffs , V. 2009—2386 CIVIL.TERM TIMOTHY L.DEUTSCH t/d/b/a CIVIL ACTION TIM'S TOWING&REPAIR and TIM'S TOWING, , Defendant , CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire,hereby certify that a copy of attached Praecipe to Settle and Discontinue was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class,postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Attention: Christine Line Dickie McCamey& Chilcote,P.C. 1200 Camp Hill Bypass,Ste.205 Camp Hill,PA 17011-3700 IRWIN&Mc GHT,P.C. By: arcus A./McKnight, ,Esquire 60 West P mfret Street arlisle, PA 17013 (71 -2353 Supreme Court . Date: September 10, 2013