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Home My WebLink About09-3124Edward E. Knauss, IV, Esquire Attorney I.D. No. 19199 Metzger, Wickersham, Knauss & Erb, P.C. P.O. Box 5300, 3211 North Front Street Harrisburg, PA 17110-0300 Phone: (717) 238-8187 Email: eekQrnwke corn Attorney for Plaintiffs HOWARD E. COVINGTON and : IN THE COURT OF COMMON PLEAS PATTY COVINGTON : OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs CIVIL ACTION -LAW V. NO. OQ - 51&q ?;vi l T rw, LEANNE I. MUNRO Defendant JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Kindly issue a Writ of Summons against t Defendant Leanne I. Munro. METZGER, ICKERSH AUSS & ERB, P.C. By Edward E. Knauss, IV, Esquire Attorney I.D. No. 19199 P.O. Box 5300, 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff WRIT OF SUMMONS TO: Leanne I. Munro, Defendant You are hereby notified that the above named Plaintiffs has commenced an action against you. PROTHONOTARY Dated: 5118lO9 By: 419079-1 0 2004 MAY 18 N I I- lj o t^? 1 i° 1 , n *18.50 Po /PTT{ Cit.* I o(Aa er* aasag8 qkA:-. Edward E. Knauss, IV, Esquire Attorney I.D. No. 19199 Metzger, Wickersham, Knauss & Erb, P.C. P.O. Box 5300, 3211 North Front Street Harrisburg, PA 17110-0300 Phone: (717) 238-8187 Email: eek@mwke.com Attorney for Plaintiffs Howard Covington & Patty Covin on HOWARD E. COVINGTON and IN THE COURT OF COMMON PLEAS PATTY COVINGTON OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs CIVIL ACTION NO. 2009-3124 v. LEANNE I. MUNRO Defendant :JURY TRIAL DEMANDED PRAECIPE TO REISSUE WRIT OF SUMMONS TO THE PROTHONOTARY: Please reissue the Writ of Summons filed in the above-captioned matter on May 18, 2009, a copy of which is attached hereto. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Dated: August ~ , 2009 ward E. Knauss, IV, Esquire Attorney I.D. No. 19199 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiffs 419079-1 CERTIFICATE OF SERVICE I, Edward E. Knauss, IV, Esquire, of the law fi Knauss & Erb, p, rm of Metzger, Wickersham C•, hereby certify that I served a t Praecipe to Reissue Writ of Su rue and c°rrect copy of plaintiffs' morons with reference to the foregoing action by first clas mail, postage prepaid, this day of August, 2009, on the following: s Defendant Leanne I. Munro c% Louis C. Schmitt, Jr., Es uire McIntyre, Hart e q p.0. Box 533 y & Schmitt Hollidaysburg, pA 16648-0533 Edward E. Knauss, IV, Esquire 419079-1 FlLED-~-riCE E?f ~E PRChl~.~4TA~Y 2Q09 AUG 1 ~ PM 3~ 4 4 CUM~~;:i ~~~s~ ~:;i3MY PcPdi rSYLVAr`~!A ~~ ~vp~5 ~~~,~~ Sheriff s Office of Cumberland County R Thomas Kline ~;~~{}-~ ,=-;~~-. Sheriff ^F ?i-;F ~=',,.,~.F:. ~; fl'l~F?Y Ronny R Anderson Chief Deputy Z~Q~ c~a~ ' ~ ~'i~ 2~ y -' z> ;::~ . Jody S Smith ' Civil Process Sergeant ~~~~~~ :.F rrE L..`u~~~ ~'~ rfe '~~~ `'~~ ~~ -, n,:, Edward L Schorpp Solicitor Howard E. Covington Case Number vs. Leanne I. Munro 2009-03124 SHERIFF'S RETURN OF SERVICE AM>JNDED 08/27/2009 06:42 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 27, 2009 at 1842 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Leanne I. Munro, by making known unto herself personally, at 29 Woodmyre Lane Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 August 28, 2009 SO ANSWERS, _- R THOMAS KLINE, SHERIFF 13y " ~G/C~- Deputy Sheriff Edward E. Knauss, IV, Esquire Attorney I.D. No. 19199 Metzger, Wickersham, Knauss & Erb, P.C. P.O. Box 5300, 3211 North Front Street Harrisburg, PA 17110-0300 Phone: (717) 238-8187 Email: eek@mwke.com Attorney for Plaintiffs Howard Covington & Patty Covin ton HOWARD E. COVINGTON and PATTY COVINGTON, Plaintiffs v. LEANNE I. MUNRO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. 2009-3124 JURY TRIAL DEMANDED PLAINTIFFS' REPLY TO DEFENDANT'S NEW MATTER 19. Conclusions of law, no reply required. If a reply is required, the averments are specifically denied and denied pursuant to Pa. R.C.P. No. 1029(e) and 1030(note). By way of further reply, none of the alleged defenses are applicable to the facts of this case. Plaintiffs asserts that it is Defendant's burden of proof to establish the defenses. WHEREFORE, Plaintiffs, Howard E. Covington and Patty Covington demand that Defendant Leanne I. Munro's New Matter be dismissed and that judgment be entered 428360-1 in their favor and against the Defendant as requested in the Complaint filed in this action which is incorporated herein by reference. METZGER, WICKE SHAM, KNAUSS & ERB, P.C. By: Edward E. Knauss, IV, Esquire Attorney I.D. No. 19199 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiffs Dated: November B_, 2009 428360-1 VERIFICATION I, Patty Covington, hereby certify that the following is correct: The facts set forth in the foregoing Reply to New Matter are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Reply to New Matter is that of counsel and not my own. I have read the Reply to New Matter, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Reply to New Matter is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Reply to New Matter are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Dated: ~ C ~ _~ 428360-1 VERIFICATION I, Howard E. Covington, hereby certify that the following is correct: The facts set forth in the foregoing Reply to New Matter are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Reply to New Matter is that of counsel and not my own. I have read the Reply to New Matter, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Reply to New Matter is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Reply to New Matter are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Dated: ~ f Q~ -Q~ ~~~vt~~ (~ Howard E. Covington 428360-1 CERTIFICATE OF SERVICE I, Edward E. Knauss, IV, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and correct copy of Plaintiffs' Reply to New Matter with reference to the foregoing action by first class mail, postage prepaid, this ~ day of November, 2009, on the following: Defendant Leanne I. Munro c/o Louis C. Schmitt, Jr., Esquire McIntyre, Hartye & Schmitt P.O. Box 533 Hollidaysburg, PA 16648-0533 dward E. auss, IV, Esquire 428360-1 ~,; - L'.. ~ i ti' _~r Edward E. Knauss, IV, Esquire Attorney I.D. No. 19199 Metzger, Wickersham, Knauss & Erb, P.C. P.O. Box 5300, 3211 North Front Street Harrisburg, PA 17110-0300 Phone: (717) 238-8187 3f{E! ! 17 Email: eek@mwke.com Attorney for Plaintiffs Howard Covington & Patty Covin on HOWARD E. COVINGTON and IN THE COURT OF COMMON PLEAS PATTY COVINGTON, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs : CIVIL ACTION NO. 2009-3124 V. LEANNE I. MUNRO, Defendant : JURY TRIAL DEMANDED PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY: Please mark the above case settled and discontinued. Dated: November / , 2010 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: Edw d E. Knauss, IV, Esquire Attorney I.D. No. 19199 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiffs 455005-1