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Home My WebLink About09-3201ZACHARY A. HYNDMAN Plaintiff V. MARY ANNE BAUM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009- 3,161 CIVIL TERM CIVIL ACTION-LAW PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a Writ of Summons in the above-referenced case on behalf of the Plaintiff, Zachary A. Hyndman, to the Defendant, Mary Anne Baum. O'BRIEN, BARIC & SCHERER Date: /n), i [. 2ooi A . _ _ MifWadl A. Scherer, Esquire I. D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Please serve the Defendant as follows: Mary Anne Baum 3948 Enola Road Newville, Pennsylvania 17241 D-19 FILH- OF THE AIRY 2009 MAY 20 AM 9: 4 2 7?r- 3-6 pd a#-y ei# Iy4 79 R.0 a- a, S 3 8'!5' Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS Court of Common Pleas ZACHARY A. HYNDMAN Plaintiff Vs. No 09-3201 MARY ANNE BAUM 3948 ENOLA ROAD NEWVILLE, PENNSYLVANIA 17241 In CivilAction-Law Defendant To MARY ANNE BAUM, You are hereby notified that ZACHARY A. HYNDMAN, 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. n (SEAL) Cifi-tis R. Lo othonjary Date May 20, 2009 By Deputy Attorney: MICHAEL A. SCHERER, ESQUIRE Name: Address: 19 WEST SOUTH STREET, CARLISLE, PA 17013 Attorney for: Plaintiff Telephone: (717) 249-6873 Supreme Court ID No. 61974 Sheriffs Office of Cumberland County R Thomas Kline ?M01r et CaatbsEdward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFCE w T sKERIFf Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/22/2009 04:00 P - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on May 22, 2009 at 600 hours, he served a true copy of the within Writ of Summons, upon the within named defenda it, to wit: Mary Anne Baum, by making known unto Wayne Baum, husband of defendant at 3948 Enola Road Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handinc to him personally the said true and correct copy of the same. SHERIFF COST: $37 May 26, 2009 SO ANSWERS, R THOMAS KLINIE. SHERIFF puty Sheriff 2009-3201 Zachary H v Mary Anne Baum C) v Co C;. _ Mx. , s y l + Johnson, Duffle, Stewart & Weidner By: C. Roy Weidner, Jr. I.D. No. 19530 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 crw@jdsw.com ZACHARY A. HYNDMAN, Plaintiff V. MARY ANNE BAUM, Defendant APPEARANCE NO. 2009-3201 CIVIL ACTION - LAW JURY TRIAL DEMANDED AND NOW, this 3 id day of June, 2009, enter the appearance of C. ROY WEIDNER, JR., I.D. 19530, on behalf of Defendant in the above captioned suit. JOHNSON, DUFFIE, STEWART & WEIDNER Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA By: Roy Weidner, Jr. :367805 5774-525 k CERTIFICATE OF SERVICE AND NOW, this 3rd day of June, 2009, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 JOHNSON, DUFFIE, STEWART & WEIDNER By: --;v? ichelle H. Spangler :367805 5774-525 4 r) OF THE 2009 JUN -4 Ph 2: 4 2 Cuwl6t. IL i t! Yw IiV A ?i T 1 c?t'iN a`?VA? A Johnson, Duffie, Stewart & Weidner By: C. Roy Weidner, Jr. I.D. No. 19530 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 crw@jdsw.com Attorneys for Defendant ZACHARY A. HYNDMAN, Plaintiff V. MARY ANNE BAUM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-3201 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO ISSUE RULE TO FILE COMPLAINT TO THE PROTHONOTARY: AND NOW, this /? Cray of July, 2009, please issue a rule to Plaintiff to file his complaint within twenty (20) days of the date of service thereof, or suffer judgment of non pros. JOHNSON UFFIE, ST By: C. Roy Weidner, Jr. RULE TO FILE COMPLAINT TO THE PLAINTIFF: AND NOW, this 144` day of July, 2009, a Rule is hereby issued to you to file your complaint in the above-captioned action within twenty (20) days of the date of service hereof, or suffer judgment of non pros. AROTHONO By: Deputy M CERTIFICATE OF SERVICE AND NOW, this / 34?day of July, 2009, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 JOHNSON, DUFFIE, STEWART & WEIDNER By: ichelle H. Spangler :371337 5774-525 FiLf E. ~ , Johnson, Duffie, Stewart & Weidner By: C. Roy Weidner, Jr. I.D. No. 19530 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 crw@jdsw.com ZACHARY A. HYNDMAN, Plaintiff v. MARY ANNE BAUM, Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-3201 CIVIL ACTION -LAW JURY TRIAL DEMANDED Defendant DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT AND NOW, this ~ day of August, 2009, comes Defendant Maryanne Baum, through her undersigned attorneys, and answers Plaintiffs complaint as follows: 1. Admitted in Part. Denied in Part. Plaintiff's name and adult status are admitted. The remainder of this averment is denied in that after a reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of said averment. 2. - 4. Admitted. 5. - 6. Denied. 7. - 14. Denied. After a reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of said averment. ti 9 NEW MATTER - MVFRL 15. Defendant is entitled to the restrictions on Plaintiff's ability to recover damages provided in the Motor Vehicle Financial Responsibility Law. WHEREFORE, Defendant demands that Plaintiff's complaint against her be dismissed. :373311 5774-525 JOHNSON, DUFFIE, STEWART & WEIDNER y , 1 VERIFICATION The undersigned says that the facts set forth in the foregoing answer are true and correct. This verification is made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsifications to authorities. arva ne Baum Dated: U ~ G Q ~ ~ r CERTIFICATE OF SERVICE AND NOW, this ~~'~day of August, 2009, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 JOHNSON, DUFFIE, STEWART & WEIDNER By: ichelle H. Spangler :373311 5774-525 ., ~,,- ,~ _~r 717,E t "~`,~?V ~~ ~ ti's ~~ ~,~ LtG'~~.~ ;i. ~ ll'r~~~~ ~t~- Johnson, Duffie, Stewart & Weidner By: C. Roy Weidner, Jr. I.D. No. 19530 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 crw@jdsw.com Attorneys for Defendant ZACHARY A. HYNDMAN, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2009-3201 V. CIVIL ACTION - LAW MARY ANNE BAUM, JURY TRIAL DEMANDED n Defendant M PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY: r Please mark the above captioned action settled and discontinued, including all counterclaims, crossclaims and joinders of additional parties. BARIC SCHERER JOHNSON, DUFFIE, STEWART & WEIDNER 'i .. i By: By: Mi h el A. Scherer U. Roy Wei ner, Jr. DISCONTINUANCE CERTIFICATE AND NOW, this 3rd day of 2989, the above captioned action has been settled and discontinued. DAVID D. BUELL, PROTHONOTARY By: Deputy :411977