The URL can be used to link to this page

Home My WebLink About09-2581J. Ronaldo Legaspi, Esquire I.D. #200240 Goldberg Katzman, P.C. 320 Market Street Harrisburg, PA 17101 LISA RENSHAW and EARL RENSHAW, her husband, Plaintiffs V. HELEN C. GOLD, D.P.M., and ZLOTOFF, GILFERT, GOLD & ASSOCIATES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0A - 01581 O V i 1 Texts PRAECIPE TO ISSUE WRIT OF SUMMONS Please issue a Writ of Summons against the Defendants names above in this matter. Goldberg Katzman, P.C. J. onal pi, Esquire 320 Market Street Harrisburg, PA 17101 (717) 234-4161 Date: April 23, 2009 L 21119 A, . 24 iii 11: 41 U Ty, Moo po Am, (xv- qsj loo aayaal J. Ronaldo Legaspi, Esquire I.D. #200240 Goldberg Katzman, P.C. 320 Market Street Harrisburg, PA 17101 LISA RENSHAW and EARL : IN THE COURT OF COMMON PLEAS RENSHAW, her husband, : CUMBERLAND COUNTY, Plaintiffs : PENNSYLVANIA V. : CIVIL ACTION - LAW HELEN C. GOLD, D.P.M., and l?? vi 1 TiEt ZLOTOFF, GILFERT, GOLD & NO. CA - 61W ASSOCIATES, Defendants WRIT OF SUMMONS TO: Helen C. Gold, D.P.M., Zlotoff, Gilfert, Gold & Associates 5108 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 YOU ARE NOTIFIED THAT THE ABOVE-NAMES PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. othonotary 4- Date: 4144 kc, J, Ronaldo L.egaspi, Esquire I.D.#200240 Goldberg Katzman, P.C. 320 Market Street Harrisburg, PA 17101 LISA RENSHAW and EARL RENSHAW, her husband, Plaintiffs V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW HELEN C. GOLD, D.P.M., and ZLOTOFF, GILFERT, GOLD & ASSOCIATES, Defendants NO. bq- 9581 WRIT OF SUMMONS TO: Zlotoff, Gilfert, Gold & Associates 5108 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 O,ivl t `rirlk YOU ARE NOTIFIED THAT THE ABOVE-NAMES PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Aothonotary Date: 4,14/09 I . PETITION TO ALLOW THE APPEARANCE OF LARRY M. WARANCH, ESQUIRE PRO HAC VICE NOW COMES Defendants Helen C. Gold, D.P.M. and Zlotoff, Gilfert, Gold & Associates, Marc T. Levin, Esquire Attorney I.D. No. 70294 RHOADS & SINON LLP One South Market Square, 12th Floor P.O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Defendants LISA RENSHAW and EARL RENSHAW, her husband, v. Plaintiffs HELEN C. GOLD, D.P.M., and ZLOTOFF, GILFERT, GOLD & ASSOCIATES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-2581 a professional corporation, by and through their attorney, Marc T. Levin, Esquire of Rhoads & Sinon LLP, and respectfully petition this Court to allow the appearance of Larry M. Waranch, Esquire, pro hac vice and in support thereof, aver as follows: Larry M. Waranch, Esquire, is a duly licensed attorney in the state of Maryland since 1978 and in Washington, DC, since 1985. 2. Mr. Waranch is a member of the law firm of Waranch & Brown, LLC, is in good standing with each of the Courts above, has never been disciplined, and does not have any disciplinary actions pending against him. 3. Mr. Waranch has been retained by Defendants to defend them against the claims of Plaintiffs in the above-captioned action. 741933.1 4. Marc T. Levin, Esquire, is an attorney with the law firm of Rhoads & Sinon LLP, and is licensed to practice law in the Commonwealth of Pennsylvania, License No. 70294, has never been disciplined by the Commonwealth of Pennsylvania and does not have any pending disciplinary actions against him. 5. Mr. Levin will act as local counsel and adviser to the lawyers of Waranch & Brown, LLC, and counsel them on the Rules of Court for the Court of Common Pleas for Cumberland County, Pennsylvania, the Pennsylvania Rules of Civil Procedure and the corresponding case law. 6. The undersigned hereby certifies that as evidenced by his signature below that he has sought the concurrence of Plaintiff's counsel, J. Ronaldo Legaspi, Esquire, and he has concurred in the instant Petition to allow the appearance of Larry M. Waranch, Esquire, pro hac vice. WHEREFORE, your Petitioners, Defendants Helen C. Gold, D.P.M. and Zlotoff, Gilfert, Gold & Associates, a professional corporation, respectfully request that this Honorable Court allow the entry of Appearance of Larry M. Waranch, Esquire, for the herein matter and before this Honorable Court pro hac vice. Respectfully submitted, RHOADS & LLP By: Marc T. Levin Attorney I.D. 70294 One South Market Square P. O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Defendants 2 VERIFICATION Larry M_ Waranch, deposes and says, subject to the penalties of 18 Pa. C.S- §4904 relating to unworn falsification to authorities, that be makes this verification by its authority and that the facts set forth in the Petition to Allow the Appearance of Larry M. Waranch, Esquire pro hac vice are true and correct to the best of his knowledge, information and belief. ?f ??1d5 bate -?L ItA, , ??) I'. _IC_ La. M. aranch CERTIFICATE OF SERVICE I hereby certify that on this day of 2009, a true and correct copy of the foregoing Motion to Appear Pro Hac Vice was served by means of United States mail, first class, postage prepaid, upon the following: J. Ronaldo Legaspi, Esquire Goldberg Katzman, P.C. 320 Market Street Harrisburg, PA 17101 W. Z2:?4a6'0? Teresa H. Laughead CF THr_ A, 2009 MAY 12 A 11: 3 ? CVR"??'.. AL y ?, Sheriffs Office of Cumberland County R Thomas Kline t'oV at C111rib"'44Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy `RIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/29/2009 01:15 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 29, 2009 at 1315 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Helen C. Gold, D.P.M., by making known unto Susann Rhoads, Superviser at 5108 E. Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050, its contents and at the same time handing to her personally the said true and correct copy of the same. 04/29/2009 01:15 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 29, 2009 at 1315 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Zlotoff, Gilfert, Gold & Associates, by making known unto Susann Rhoads, Superviser ai 5108 E. Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050, its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $57.02 SO ANSWE S,? April 30, 2009 2009-2581 Lisa Renshaw v Helen Gold R THOMAS KLINE, SHERIFF uty Sheriff _N -T1 ;(:i7-' co M co Marc T. Levin, Esquire Attorney I.D. No. 70294 RHOADS & SINON LLP One South Market Square, 12th Floor P.O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Defendants LISA RENSHAW and EARL RENSHAW, her husband, v. Plaintiffs HELEN C. GOLD, D.P.M., and ZLOTOFF, GILFERT, GOLD & ASSOCIATES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-2581 PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Marc T. Levin, Esquire and Rhoads & Sinon LLP as counsel for Defendants, Helen C. Gold, D.P.M. and Zlotoff, Gilfert, Gold & Associates, in the above-captioned matter. Respectfully submitted, RHOADS & SINON LLP By: / Marc T. Levin, squire One South Market Square P. O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Defendants 741764.1 CERTIFICATE OF SERVICE I hereby certify that on this Y" day of May, 2009, a true and correct copy of the foregoing Praecipe for Entry of Appearance was served by means of United States mail, first class, postage prepaid, upon the following: J. Ronaldo Legaspi, Esquire Goldberg Katzman, P.E. 320 Market Street Harrisburg, PA 17101 W zd?-& Teresa H. Laughead R J t: OF THE t? i i-'! i:FF?'x' 2009 MAY I I PSI 1: 06 iWy 't -e Marc T. Levin, Esquire Attorney I.D. No. 70294 RHOADS & SINON LLP One South Market Square, 12th Floor P.O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Defendants LISA RENSHAW and EARL RENSHAW, her husband, v. Plaintiffs HELEN C. GOLD, D.P.M., and ZLOTOFF, GILFERT, GOLD & ASSOCIATES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-2581 PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Kindly issue a Rule upon Plaintiff to file a Complaint within twenty (20) days or suffer a judgment of non pros. Respectfully submitted, Date: l r d 9 RHOADS & S1NO L By. cam-. Marc T. Levin Attorney I.D. 70294 Attorneys for Defendants RULE TO FILE A COMPLAINT TO: J. Ronaldo Legaspi, Esquire Goldberg Katzman, P.E. 320 Market Street Harrisburg, PA 17101 You are hereby ruled to file a Complaint within twenty (20) days of receipt of this Rule or suffer a judgment of non pros. Dated: 'Sh / 1, o2 9 0 ota 741761.1 'a CERTIFICATE OF SERVICE I hereby certify that on this 0 V-? day of May, 2009, a true and correct copy of the foregoing Praecipe for Rule to File Complaint was served by means of United States mail, first class, postage prepaid, upon the following: J. Ronaldo Legaspi, Esquire Goldberg Katzman, P.E. 320 Market Street Harrisburg, PA 17101 I-Jjw? W. 01"4&4?? ... Teresa H. Laughead FLED- _: ;.'.:l ;E OF THE PRf '910NI NARY 2009 MAY i i PH 1: 06 Marc T. Levin, Esquire Attorney I.D. No. 70294 RHOADS & SINON LLP One South Market Square, 12th Floor P.O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Defendants LISA RENSHAW and EARL RENSHAW, her husband, v. Plaintiffs HELEN C. GOLD, D.P.M., and ZLOTOFF, GILFERT, GOLD & ASSOCIATES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-2581 AMENDMENT TO PETITION TO ALLOW THE APPEARANCE OF LARRY M. WARANCH, ESQUIRE PRO IYAC VICE NOW COMES Defendants Helen C. Gold, D.P.M. and Zlotoff, Gilfert, Gold & Associates, a professional. corporation, by and through their attorney, Marc T. Levin, Esquire of Rhoads & Sinon LLP, and respectfully amend their petition filed with this Court to allow the appearance of Larry M. Waranch, Esquire, pro hac vice and in support thereof, aver as follows: 7. No Judge has ruled upon any other issue in this matter or in any related matter. WHEREFORE, your Petitioners, Defendants Helen C. Gold, D.P.M. and Zlotoff, Gilfert, Gold & Associates, a professional corporation, respectfully request that this Honorable Court allow 742826.1 the entry of Appearance of Larry M. Waranch, Esquire, for the herein matter and before this Honorable Court pro hac vice. Respectfully submitted, RHOADS & SINON LL By: ?- Marc T. Levin Attorney I.D. 70294 One South Market Square P. O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Defendants 2 CERTIFICATE OF SERVICE I hereby certify that on this /6-.today of , 2009, a true and correct copy of the foregoing Amendment to Motion to Appear Pro Hac Vice was served by means of United States mail, first class, postage prepaid, upon the following: J. Ronaldo Legaspi, Esquire Goldberg Katzman, P.C. 320 Market Street Harrisburg, PA 17101 w Teresa H. Laughead 01 hi 1 i.. 2099 H Y 18 P1' i 5, 4 MAY 13 2009; LISA RENSHAW and EARL ! IN THE COURT OF COMMON PLEAS RENSHA , her husband, ; CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs CIVIL ACTION - LAW V. i NO. 09-2581 HELEN C. GOLD, D.P.M., and ZLOTOFF, ILFERT, GOLD & ASSOCIATES, Defendants ORDER ? NOW this '„ 1S' day of May 2009, the Petition to allow the appearance of Larry M. Waranch, E$quire, pro hac vice is GRANTED in the above-captioned matter. loldsa4v7'a 'r?f6l 'Al r»?? qv mw Sw IJOPD "Hi K, CRIIJ J. Ronaldo Legaspi, Esquire I.D.#200240 Goldberg Katzman, P.C. 320 Market Street Harrisburg, PA 17101 (717) 234-4161 LISA RENSHAW and EARL RENSHAW, her husband, Plaintiffs V. HELEN C. GOLD, D.P.M., and ZLOTOFF, GILFERT, GOLD & ASSOCIATES, Defendants IN THE COURT OF COMMON' PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-2581 PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Plaintiffs, Lisa and Earl Renshaw, request that this case be marked discontinued and ended. Goldberg Katzman, P.C. J. ?tojVgW LekfKpi, Esquire 32 arket Street Harrisburg, PA 17101 (717) 234-4161 Counsel for Plaintiffs Date: June 11, 2009 CERTIFICATE OF SERVICE I, hereby certify that on this date, I served the foregoing document, via U. S. Mail, postage prepaid, on the persons set forth below, namely: Marc T. Levin, Esquire Rhoads and Sinon One South Market Square P.O. Box 1146 Harrisburg, PA 17108-1146 Larry M. Waranch, Esquire Waranch & Brown, LLC 1301 York Road Suite 300 Lutherville, MD 21093 GOLDBERG KATZMAN, P.C. -C), ??' ?-- ?z -I J. Ro squire 320 Market Street Harrisburg, PA 17101 (717) 234-4161 Counsel for Plaintiffs Date: June 11, 2009 RLC,'-) { u E F THE R-30 T O ARY 2009 ?UN 12 PH 12.41