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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