HomeMy WebLinkAbout09-6174IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
KASSANDRA KEFOVER, a minor, by her
parents and natural guardians,
PAUL KEFOVER AND LORI KEFOVER
PAUL KEFOVER, in his own right, and
LORI KEFOVER, in her own right,
1183 Shoreham Rd.
Camp Hill, PA 17011
Plaintiffs
V.
TIMOTHY MORRISON and
TONYA MORRISON,
4004 Glenfinnan Place
Mechanicsburg, PA 17055
Defendants
Civil T xn
CASE NO. V1
JURY TRIAL DEMANDED
PRAECIPE FOR WRIT OF SUMMONS
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Issue summon in the above case
Writ of Summons shall be issued and forwarded to the SHERIFF OF CUMBERLAND COUNTY.
Dated:.??6CA 15, 2009
Christina L. Bradley, Esqui&
FREEBURN & HAMILTON
4415 N. Front St.
Harrisburg, PA 17110
(717)671-1955
ID No.: 89107
•000•
WRIT OF SUMMONS
TO: Timothy Morrison and Tonya Morrison h/w, 4004 Glenfinnan Place,
Cumberland County, Pennsylvania 17055.
sburg,
YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED AN
ACTHON AGAINST YOU. n n
'Prothonotary/Clerk, Civil Divisi
Dated:
Deputy
FILED-0Yr:IC;'I:
OF THE PF"1 ' )NO T N,RY
2009 SEP I I Pik 1, 00
`k
# 6 # -.56 fi#j
oe,g SlIad
o r# W3? 11-7f
Sheriffs Office of Cumberland County
R Thomas Kline
Sheri
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
any ? 3«?? ?. t`t
4Ff ICE OF 'NE S"ERIFF
OF THE FR 1_'__1! TAPY
2009 SEP 18 Pty 2: t4 0
L WIi.-.'. r't<-? IJ?.JL.li??7
Kassandra Kefover
vs.
Timothy Morrison
Case Number
2009=W14
??7y
SHERIFF'S RETURN OF SERVICE
09/17/2009 05:45 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September
17, 2009 at 1745 hours, he served a true copy of the within Writ of Summons, upon the within named
defendant, to wit: Tonya Morrison, by making known unto herself personally, at 4004 Glenfinnan Place
Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to
her personally the said true and correct copy of the same.
09/17/2009 05:45 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September
17, 2009 at 1745 hours, he served a true copy of the within Writ of Summons, upon the within named
defendant, to wit: Timothy Morrison, by making known unto Tonya Morrison, wife of defendant at 4004
Glenfinnan Place Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same
time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $53.44
SO ANSWERS,
?000AI_9:L? iloo?
September 18, 2009 R THOMAS KLINE, SHERIFF
By..-
Deputy Sheriff
Christina L. Bradley, Esquire
FREEBURN & HAMILTON
ID No. 89107
4415 North Front Street
Harrisburg PA 17110
(717) 671-1955
ch risti n a b@ pa-i nj u ryl awye r. co m
F1L~D_~:.~rr=LUE
I'~ ~ Nc Pr.,~r*,,,r ~niARY
2~IQ FEB 17 ~'tl Z~ 47
n r -; ~ ~ d ~-,-Y
rr"jv~1`~~'-,.;"`1i~ Attorney for Plaintiffs
KASSANDRA KEFOVER, a minor, by
PAUL KEFOVER AND LORI KEFOVER
PAUL KEFOVER, in his own right, and
LORI KEFOVER, in her own right,
Plaintiffs
v.
TIMOTHY MORRISON and
TONYA MORRISON,
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. OAT - 1. L~~{
CIVIL ACTION -LAW
PROOF OF DEPOSIT
C'~ ~ ~ L`-T!'~.l~~
6'
AND NOW, comes Freeburn & Hamilton, PC, and files the following Proof of Deposit for
Kassandra Kefover, pursuant to Pa. R.C.P. No. 2039(b)(2), as set forth in Exhibit "A" attached
hereto. The account evidenced in Exhibit "A" is subject to a provision that no withdrawal can be
made from the account until the minor attains majority, except as authorized by a prior Order of
Court.
FREEBURN & HAMILTON
Dated: a- ~ - ~ (l D ~l~.ia"~Z,,~ ~•f~o.dl~~-~/
Christina L. Bradley, Esquire
Attorneys for Plaintiffs
4415 N. Front St.
Harrisburg, PA 17110
(717)671-1955
ID No. 89107
Exhibit "A"
~~
~~
'r ~uvt~s+t
Depot
Naval Inv Ctrl Pt, Bldg 310
Mechanicsburg PA 17055
Inquiries Call: 717-766-4153
Acct }p(]D{lDDI152 1CEFOVER,ICASSANDR
Eff: 02/08/10 Date: 02/08/10
Tlr: 0786 Time: 12:18pm
Deposit to REGULAR SAVINGS 0000
Prev Bal: 25.00
Amount: 14,391.44
New 8a1: 14,416.44
Seq: X244848
Chk hld rls 02/10/10 4,750.00
Chk hld rls 02/16/10 9,391.44
due to Large Deposit
Check Received 14,391.44
Authorized by
ID Source:
^ Drv Lic
j SigCard
^ Rnown
^ Other
10-Year Home Equity Special Rates as low
as 4.99 APR! No Prepayment Penalties!
No Points! No Closing Costs! Ask for
details.
KASSANDRA L KEFOVSR
='L~
Christina L. Bradley, Esquire
FREEBURN & HAMILTON
ID No. 89107
4415 North Front Street
Harrisburg PA 17110
(717)671-1955
christinab@pa-injurylawyer.com
Attorney for Plaintiffs
KASSANDRA KEFOVER, a minor, by IN THE COURT OF COMMON PLEAS
PAUL KEFOVER AND LORI KEFOVER :CUMBERLAND COUNTY, PENNSYLVANIA
PAUL KEFOVER, in his own right, and
LORI KEFOVER, in her own right,
Plaintiffs
NO. 09-6174
v. .
TIMOTHY MORRISON and :CIVIL ACTION -LAW
TONYA MORRISON,
Defendants
CERTIFICATE OF SERVICE
I hereby certify a true and correct copy of PROOF OF DEPOSIT was served on the date
in the in the manner fisted below, addressed as follows:
FIRST CLASS U.S. MAIL POSTATE PREPAID
Debra L. Wallace, Claims Adjustor
Erie Insurance
4901 Louise Drive
PO Box 2013
Mechanicsburg, PA 17055
FREEBURN & HAMILTON
Dated: 2T(, h ~~ ~~~
Chnstlna L. Bradley, Esq riu e
Attorneys for Plaintiffs
4415 N. Front St.
Harrisburg, PA 17110
(717)671-1955
ID No. 89107
Christina L. Bradley, Esquire
FREEBURN & HAMILTON
ID No. 89107
4415 North Front Street
Harrisburg PA 17110
(717) 671-1955
christinab@pa-injurylawyer.com
~iLCi~- '~'-
2~10FEE3c3 ~';~~li~~
CLid ~.t~ i Y
Attorney for Plaintiffs
KASSANDRA KEFOVER, a minor, by
PAUL KEFOVER AND LORI KEFOVER
PAUL KEFOVER, in his own right, and
LORI KEFOVER, in her own right,
Plaintiffs
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 09-6174
v.
TIMOTHY MORRISON and
TONYA MORRISON,
Defendants
CIVIL ACTION -LAW
PRAECEIPE TO DISCONTINUE
TO THE PROTHONOTARY:
Kindly mark the captioned matter settled and discontinued.
FREEBURN & HAMILTON
Dated: ~~) ! U
C:h~.a~~. Vha-t ~a~
Christina L. Bradley, Esqu
Attorneys for Plaintiffs
4415 N. Front St.
Harrisburg, PA 17110
(717)671-1955
ID No.: 89107
Christina L. Bradley, Esquire
FREEBURN & HAMILTON
ID No. 89107
4415 North Front Street
Harrisburg PA 17110
(717) 671-1955 Attorney for Plaintiffs
ch ristinab@pa-i njurylawyer.com
KASSANDRA KEFOVER, a minor, by IN THE COURT OF COMMON PLEAS
PAUL KEFOVER AND LORI KEFOVER :CUMBERLAND COUNTY, PENNSYLVANIA
PAUL KEFOVER, in his own right, and
LORI KEFOVER, in her own right,
Plaintiffs
NO. 09-6174
v.
TIMOTHY MORRISON and
TONYA MORRISON,
Defendants
CIVIL ACTION -LAW
CERTIFICATE OF SERVICE
I hereby certify a true and correct copy of Praecipe to Discontinue was served on the
date in the in the manner listed below, addressed as follows:
FIRST CLASS U.S. MAIL, POSTATE PREPAID
Debra L. Wallace, Claims Adjustor
Erie Insurance
4901 Louise Drive
PO Box 2013
Mechanicsburg, PA 17055
Dated: o~ ~ o~o~ 1 I D
T~
FREEBURN & HAMILTON
1 ~ly '~-t.rvz- ~ .~ ~~i
~~
Christina L. Bradley, Esquire
Attorneys for Plaintiffs
4415 N. Front St.
Harrisburg, PA 17110
(717)671-1955
ID No. 89107