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Home My WebLink About09-8770 w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PA PUBLIC WORKS EQUIPMENT CIVIL DIVISION COMPANY, LLC, _ 1124 McLaughlin Road ?9 - $ 7`10 Bridgeville, PA 15017 Plaintiff, TYPE OF PLEADING: PRAECIPE FOR WRIT OF SUMMONS vs. IN CIVIL ACTION JAY FARNHAM 507 North York Street Mechanicsburg, PA 17055 AND FARNHAM INSURANCE AGENCY, 507 North York Street Mechanicsburg, PA 17055 Defendants. FILED ON BEHALF OF: PLAINTIFF COUNSEL OF RECORD FOR THIS PARTY: MARK F. McKENNA, ESQUIRE PA ID# 30297 T RESA B. O'BRIEN, ESQUIRE A ID# 77665 McKENNA & ASSOCIATES, P.C. 436 Boulevard of the Allies Suite 500 Pittsburgh, PA 15219 (412) 471-6226 if Alb IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PA PUBLIC WORKS EQUIPMENT COMPANY, LLC, 1124 McLaughlin Road Bridgeville, PA 15017 Plaintiff, vs. JAY FARNHAM 507 North York Street Mechanicsburg, PA 17055 AND FARNHAM INSURANCE AGENCY, 507 North York Street Mechanicsburg, PA 17055 Defendants. CIVIL DIVISION PRAECIPE FOR WRIT OF SUMMONS PROTHONOTARY/CLERK OF COURT: Kindly issue a Writ of Summons in Civil Action against the Defendants, Jay Farnham and Farnham Insurance Agency, in the above-captioned matter. Writ of Summons shall be issued and forwarded to Attorne Sheriff lease circle choice). o- )7/, 09 DATE McKENNA & ASSOCIATES, P.C. BY: ?QPz? (b CNbZ..(I ?' MARK F. McKENNA, ESQUIRE (PA ID# 30297) THERESA B. O'BRIEN, ESQUIRE (PA ID# 77665) Attorneys for Plaintiff 436 Boulevard of the Allies, Suite 500 Pittsburgh, PA 15219 412-471-6226 000000 F'I"I 2:.i *qa. oo p? ATTY UG* ) O'7 4 3 ,SIR P-r* 2,35-31.1 WRIT OF SUMMONS TO: Jay Farnham You are notified that the above-named Plaintiff has commenced an action against you. (a a O DAT P othonotary/Clerk, Civil Divis n by: DEPUTY WRIT OF SUMMONS TO: Farnham Insurance Agency You are notified that the above-named Plaintiff has commenced an action against you. ml/.tl A,12,4,t? k), Zza DA E Nrthonotary/Clerk, Civil Di ' ion by: DEPUTY SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ?'-' Of C11jr4be" 14 ^cF E ?t '? c -!^EkiRF 2016 JO -6 AM g: 44 Ma'am PA Public Works Equipment Company, LLC Case Number s. JayvFarnham 2009-8770 SHERIFF'S RETURN OF SERVICE 12/23/2009 04:25 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 2009 at 1625 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Farnham Insurance Agency, by making known unto Dona Teeter, Office Manager at 507 North York Street, 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. 12/29/2009 04:14 PM - Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on December 29, 2009 at 1614 hours, she served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Jay Farnham, by making known unto himself personally, at 507 North York Street, Mechancisburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $53.00 December 30, 2009 (rj GOLIMYSUItC Shenf'f_ TPtecsott, Inc- SO ANSWERS, R THOMAS KL By HERIFF By De y Sheriff DEVLIN ASSOCIATES, P.C. BY: JOHN GERARD DEVLIN, ESQUIRE I.D. 32858 1515 Market Street, Ste. 2010 Philadelphia, PA 19102 (215)-564-6740 Our File No.: 431-2039o-JGD/p 9! FD-i),,'Ff0"E fy T c p ?,1?- _nV TAP 2010 AIN -8 PFD 4: 09 PA PUBLIC WORKS EQUIPMENT COMPANY LLC V. JAY FARNHAM, and JAY FARNHAM INSURANCE AGENCY COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: o9-8770 JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance as counsel for Jay Farnham Insurance Agency and Jay Farnham in the above captioned matter. DE, LINASSOCIATES, P.C. a V A J n Gera in, Esquire DEVLIN ASSOCIATES, P.C. BY: JOHN GERARD DEVLIN, ESQUIRE I.D. 32858 1515 Market Street, Ste. 2010 Philadelphia, PA 19102 (215)-564-6740 Our File No.: 431-2039o-JGD/p PA PUBLIC WORKS EQUIPMENT COMPANY LLC V. JAY FARNHAM, and JAY FARNHAM INSURANCE AGENCY TO THE PROTHONOTARY: ALED-?a--F,+r, 0.1= T,1-1-. CE 7 2010 , All -8 F? ? G 9 :COURT OF COMMON PLEAS : CUMBERLAND COUNTY : DOCKET NO.: 09-8770 JURY TRIAL DEMANDED Please enter a Rule upon plaintiff to file a Complaint within twenty (20) days hereof or suffer the entry of a Judgment of Non Pros. DEVLIN A4Sj WI,0ES, P.C. BY: RULE TO FILE COMPLAINT AND NOW, this 8`f` day of J Ln. , 2010, a Rule is hereby granted upon plaintiff to file a Complaint herein within twenty (20) days after service hereof or suffer the entry of a Judgment of Non Pros. 'D)D W 9 2.rnVt 00 OT P-y Gerard Devlin, Esquire .t trney for Defendants, ay Farnham and Jay Farnham Insurance Agency DEVLIN ASSOCIATES, P.C. BY: JOHN GERARD DEVLIN, ESQUIRE I.D. 32858 1515 Market Street, Ste. 2010 Philadelphia, PA 19102 (215)-564-6740 Our File No.: 431-2039o-JGD/p PA PUBLIC WORKS EQUIPMENT COMPANY LLC V. JAY FARNHAM, and JAY FARNHAM INSURANCE AGENCY OF TI.F?LEt7k?t ?T Y 2010 JAI", -8 Q 9 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 09-8770 JURY TRIAL DEMANDED DEMAND AND PERFECTION OF DEMAND FOR JURY TRIAL TO THE PROTHONOTARY: Answering defendants, Jay Farnham Insurance Agency and Jay Farnham, hereby demands a trial by jury by 12 individual men and women, and hereby perfect their demand for jury trial by the payment of the jury trial fee. DEVLIA ASSOCIATES, P.C. BY: Dated: January 5, 2010 McKENNA & ASSOCIATES, P.C. BY: MARK F. McKENNA, ESQUIItE ID #30297 436 Boulevard of the Allies, Suite 500 Pittsburgh, PA 15219 (412) 471-6226 -phone (412) 471-6658 -fax mmckenna@consolidated.net FiEt) - ` ;fir z'r',c u> r ~ ~-~` E ~~ pt ~~ Y 210 ~~`~ 17 ~i~i 2~lN F i'EI ~~i ~ ~s~fl.4;wi`~lir~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PA PUBLIC WORKS EQUII'MENT COMPANY, LLC; Plaintiff, CIVIL DIVISION 09-8770 CIVIL TERM vs. JAY FARNHAM and FARNHAM INSURANCE AGENCY; Defendants, vs. GETTEL ENTERPRISES, INC., NORTHLAND DISTRIBUTING & MANUFACTURING INC., PAUL W. GETTEL i/t/d/b/a Cars by Gettel, Inc., G. LEE SOURER and MARIAN SOURER, ERIE INSURANCE EXCHANGE t/a ERIE INDEMNITY and ERIE INSURANCE COMPANY, Additional Defendants. TYPE OF PLEADING: CERTIFICATE OF MERIT AS TO DEFENDANT JAY FARNHAM JURY TRIAL DEMANDED CERTIFICATE OF MERIT AS TO DEFENDANT JAY FARNHAM I, Mark F. McKenna, counsel for Plaintiff, certifies that: / an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by this defendant in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; AND/OR the claim that this defendant deviated from an acceptable professional standard is based solely on allegations that other licensed professionals for whom this defendant is responsible deviated from an acceptable professional standard and an appropriate licensed professional has supplied a written statement to the undersigned that there is a basis to conclude that the care, skill or knowledge exercised or exhibited by the other licensed professionals in the treatment, practice or work that is the subject of the complaint, fell outside acceptable professional standards and that such conduct was a cause in bringing about the harm; OR expert testimony of an appropriate licensed professional is unnecessary for prosecution of the claim against this defendant. Respectfully submitted, DATED: ~ /1/ %!~ McKENNA & ASSOCIATES, P.C. BY: MARK F. McKENNA, ESQUIItE Attorneys for Plaintiff CERTIFICATE OF SERVICE The undersigned herein certifies that a true and correct copy of Plaintiff's Certificate of Merit as to Defendant Jay Farnham was forwarded via U.S. first class mail, postage prepaid, to the following this 14"' day of May 2010: John Gerard Devlin, Esquire DEVLIN ASSOCIATES, P.C. 1515 Market Street, Ste 2010 Philadelphia, PA 19102 Keith O. Brenneman, Esquire SNELBAKER & BRENNEMAN, P.C. 44 West Main Street Mechanicsburg, PA 17055 McKENNA & ASSOCIATES, P.C. BY: MARK F. McKENNA, ESQUIRE Attorneys for Plaintiff DEVLIN ASSOCIATES, P.C. BY: JOHN GERARD DEVLIN, ESQUIRE I.D. 32858 1515 Market Street, Ste. 2010 Philadelphia, PA 19102 (215)-564-6740 Our File No.: 431-2039o-JGD/p PA PUBLIC WORKS EQUIPMENT COMPANY LLC V. JAY FARNHAM, and JAY FARNHAM INSURANCE AGENCY V. GETTEL ENTERPRISES INC. NORTHLAND DISTRIBUTING & MANUFACTURING INC. PAUL W. GETTEL i/t/d/b/a Cars by Gettel, Inc. G. LEE SOUDER and MARIAN SOUDER ERIE INSURANCE EXCHANGE t/a ERIE INDEMNITY ERIE INSURANCE COMPANY COURT OF COMMON PLEAS : CUMBERLAND COUNTY DOCKET NO.: o9-8770 JURY TRIAL DEMANDED M co zrr) C= rr_- to r az- -,Z;r-- ?? v 1 < ,-; PRAECIPE TO EXCHANGE VERIFICATIONS TO THE PROTHONOTARY: Kindly exchange the affidavit of John Gerard Devlin, Esquire, with that of Jay Farnham, to the Joinder Complaint. Respectfully submitted, DE?John OCIATES, P.C. BYGerard Devlin, Esquire VERIFICATION I, Jay Farnham am (title of deponent) of Jay Farnham Insurance Agency and I am authorized to make this Verification on behalf of the defendant Jay Farnham Insurance Agency. No one person has personal knowledge of all of the matters stated in the foregoing Joinder Complaint, the facts therein have been assembled by authorized employees and counsel for the defendants and I am informed that the facts stated therein are true to the best of our knowledge, information and belief. 6-8-Zot? (name of deponent and date) Our File No.: 431-203go-JGD/p VERIFICATION I, Jay Farnham, hereby deposes and says that the facts set forth in the attached Joinder Complaint are true and correct to the best of my knowledge, information and belief; and that I understand that the statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. 4- e- 2 0 1 (Signature) Dated Our File No.: 431-2039o-JGD/p DEVLIN ASSOCIATES, P.C. BY: JOHN GERARD DEVLIN, ESQUIRE I.D. 32858 1515 Market Street, Ste. 2010 Philadelphia, PA 19102 (215)-564-6740 Our File No.: 431-2039o-JGD/p PA PUBLIC WORKS EQUIPMENT COMPANY LLC COURT OF COMMON PLEAS : CUMBERLAND COUNTY V. JAY FARNHAM, and JAY FARNHAM INSURANCE AGENCY GETTEL ENTERPRISES INC. NORTHLAND DISTRIBUTING & MANUFACTURING INC. PAUL W. GETTEL i/t/d/b/a Cars by Gettel, Inc. G. LEE SOUDER and MARIAN SOUDER ERIE INSURANCE EXCHANGE t/a ERIE INDEMNITY ERIE INSURANCE COMPANY : DOCKET NO.: o9-8770 JURY TRIAL DEMANDED ;;tnl C= ' -? cnr ? t- - < c- ) C-1 - C3 CA.) PRAECIPE TO EXCHANGE VERIFICATIONS TO THE PROTHONOTARY: Kindly exchange the affidavit of John Gerard Devlin, Esquire, with that of Jay Farnham, to the Answer and New Matter. Respectfully submitted, D VLIN ASSOCIATES, P.C. John Gerard Devlin, Esquire VERIFICATION I, Jay Farnham am (title of deponent) of Jay Farnham Insurance Agency and I am authorized to make this Verification on behalf of the defendant Jay Farnham Insurance Agency. No one person has personal knowledge of all of the matters stated in the foregoing Answer and New Matter, the facts therein have been assembled by authorized employees and counsel for the defendants and I am informed that the facts stated therein are true to the best of our knowledge, information and belief. (name of deponent and date) Our File No.: 431-2039o-JGD/p VERIFICATION I, Jay Farnham, hereby deposes and says that the facts set forth in the attached Answer and New Matter are true and correct to the best of my knowledge, information and belief, and that I understand that the statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. I 1 6 41-40 (Signature) Dated: Our File No.: 431-2039o-JGD/p