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HomeMy WebLinkAbout01-7175TO YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU BY ATTORNEY FRANKEL' BARE & ASSOCIATES ATTORNEYS AT LAW 14 WEST KING STREET YORK, PENNSYLVANIA 17401 WE DO HEREBY CERTIFY THE WITHIN IS A TRUE AND RECT COPY OF THE ORI( FILED IN THIS ACTION BY ATTORNEY FRANKEL. BARE ASSOCIATES ATTORNEys AT LAW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BURTON L. BUSH, JR., 655 Carroll Drive Hummelstown, PA 17036 Plaintiff NANDA RAMASWAMY 12 Edgewood Drive Mechanicsburg, PA 17055 and PAUL C. ENDERS 307 Market Street Halifax, PA 17032 and KENDA S. ENDERS 307 Market Street Halifax, PA 17032 Defendants Civil Action - Law PRAECIPE FOR SUMMONSES TO THE PROTHONOTARY/CLERK OF SAID COURT: X Date: Issue summons in Civil Action Law above case. - in the Writ of Summonses shall be issued and forwarded~ / / /I(~/C~/0! Ste,,n D/S~rh,ba~h, Esquire Att~fney/fg~ Plai~j~ffs I.D~/No:/6~338 14~/VVes~ )ling S~reet P.¢). Bo~/1389 Y~lrk, F~ 17405-1389 (717) 854-3836 SUMMONSES IN CIVIL ACTION TO: Nanda K. Ramaswamy, 12 Edgewood Drive, Mechanicsburg, PA 17055; Paul C. Enders, 307 Market Street, Halifax, PA 17032; and Kenda S. Enders, 307 Market Street, Halifax, PA 17032. YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU.~,c~ ~. :CC-q/ Prothonotary/Cle. rk, Civil Di~sion Date: ~-~-0[ By .~lz.~ /Z ~.~,, m:~home\bqa\litigat~statefrm~ramaswamy\entryofappearance.wpd Draft #1 January 23, 2002 Bfigid Q. Al ford, Esquire Supreme Cour~ I.D. #38590 Seffr~y E. Piccola, Esquire Supreme Court LD. #18015 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Stxeet Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 At~m~,s for De f~ndant Nanda Ramaswamy BURTON L. BUSH, JR., Plaintiff NANDA RAMASWAMY, PAUL C. ENDERS and KENDA S. ENDERS, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 01-7175 Civil Term : CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE Kindly enter the appearances ofBrigid Q. Alford, Esquire, and Boswell, Tintner, Piccola & Wickersham on behalf of Defendant Nanda Ramaswamy. Respectfully submitted, By: Brigi~ Q. ~ford, E~quir~J Supreme Court I.D. #38590 Jeffzey E. Piccola, Esquire Supreme Court I.D. #18018 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Ramaswamy Date: CERTIFICATE OF SERVICE I do hereby certify that I have served a tree and correct copy of the foregoing Praecipe for Entry of Appearance by placing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Steven D. Stambaugh, Esquire 14 West King Street Post Office Box 1389 York, PA 17405-1389 Paul C. Enders 307 Market Street Halifax, PA 17032 Kenda S. Enders 307 Market Street Halifax, PA 17032 By: BrigidtQ. Al~rd, Es~tuire ~ BURTON L. BUSH, JR. Plaintiff NANDA RAMASWAMY, PAUL C. ENDERS and KENDA S. ENDERS, Defendants IN THE COURT OF COMMON PLEAS NO. 01-7175 CIVIL CIVIL ACTION - LAW JURY TRIAL DEMANDED TO: Prothonotary Please enter the appearance of Richard H. wix, Esquire, of the firm of Wix, Wenger & weidner, on behalf of Defendants Paul C. Enders and Kenda S. Enders in the above-captioned matter. WIX, WENGER & WEIDNER Richard H. wix, Esq., I.D. #07274 Attorneys for Defendants Enders 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 Dated: February 8, 2002 FRANKEL BARE & ASSOCIATES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BURTON L. BUSH, JR., Plaintiff V. NANDA RAMASWAMY and PAUL C. ENDERS and KENDA S. ENDERS Defendants Case No: 01-7175 Civil Civil Action - Law PRAECIPE TO SA TISFY TO THE PROTHONOTARY: Please mark the above captioned case settled and satisfied and discontinued. Date: February /~, 2002 FRANKEL, BARE & ASSOCIATES IS_.~~quire /~orn~Y¢ for Plaintiff lV4 W~fst King Street P.O. Box 1389 York, PA 17405-1389 (717) 854-3836 FRANKEL. BARE & ASSOCIATES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION BURTON L. BUSH, JR., Plaintiff Case No: 01-7175 Civil Civil Action - Law NANDA RAMASWAMY and : PAUL C. ENDERS : and : KENDA S. ENDERS : Defendants : CERTIFICATE OF SERVICF I, Rachelle L. Seeds, of the law firm of FRANKEL, BARE ASSOCIATES, attorneys for Plaintiffs, do hereby certify that I am this day serving a copy of the foregoing Praecipe to Satisfy upon the counsel of record in the following manner. BY REGULAR MAIL: Brigid Q. Alford, Esquire BOSWELL, TINTNER, PICCOLA & WlCKERSHAM 315 North Front Street P.O. Box 741 Harrisburg, PA 17108-0741 (Counsel for Ramaswamy) Date: February~ 2002 Richard H. Wix, Esquire WiX, WENGER & WEIDNER 4705 Duke Street Harrisburg, PA 17109 (Counsel for Enders Defendants) ,..-PR'~KEL, BAR~ .~ ASS~;[~TES/'/ ~a'~helle L. Seu~,' P~ra-'~al ~teven D. Stambaugh, Esquire I.D. # 64338 Attorney for Plaintiffs 14 West King Street, PO Box 1389 York, PA 17405-1389 (717) 854-3836 SHERIFF'S RETURN - CASE NO: 2001-07175 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BUSH BURTON L JR OUT OF COUNTY VS RAMASWAMY NANDA ET AL R. Thomas Kline , duly sworn according to law, says, that he made and inquiry for the within named DEFENDANT ENDERS PAUL C Sheriff or Deputy Sheriff who being a diligent search and , to wit: but was unable to locate Him deputized the sheriff of DAUPHIN serve the within WRIT OF SUMMONS in his bailiwick. County, He therefore Pennsylvania, to On January 22nd , 2002 this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin County 6.00 9.00 10.00 38.50 .00 63.50 01/22/2002 SO answej~: f/J~' R~. Thomas Kline Sheriff of Cumberland County FPJkNKEL BARE & ASSOC. Sworn and subscribed to before me this .~o ~ day of~ ~Z 6~3 ~ A.D. w t Prothonotary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-07175 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BUSH BURTON L JR VS R3dvS~SWAMY NANDA ET AL R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT ENDERS KENDA S but was unable to locate Her deputized the sheriff of DAUPHIN serve the within WRIT OF SUMMONS , Sheriff or Deputy Sheriff who being says, that he made a diligent search and in his bailiwick. County, , to wit: He therefore Pennsylvania, to On January 22nd , 2002 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 01/22/2002 R.z Thomas Kline Sheriff of Cumberland County FR3~NKEL BARE & ASSOC Sworn and subscribed to before me this 3~ ~ day of ~ o%4r~ ~L A.D. , ~ Prothonotary~ SHERIFF'S RETURN - REGULAR CASE NO: 2001-07175 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BUSH BURTON L JR VS RAMASWAMY NANDA ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon RAMASWAMY NANDA the DEFENDANT at 1214:00 HOURS, at 12 EDGEWOOD DRIVE MECHANICSBURG, PA 17055 UMA R3%MASWAMY, SISTER on the 4th day of January , 2002 by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18 00 6 50 00 10 00 00 34 50 Sworn and Subscribed to before me this ~D ~ day of /~ o~ A.D. /-P~rothOfi~tary , ,. So Answers: R. Thomas Kline 01/22/2002 FRANKEL BA~ ~ ~eputy ~herlff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania County of Dauphin AND NOW: January 11, SUlqMONS ENDERS PAUL C to KENDA, WIFE of the original : BUSH BURTON L JR vs : ENDERS KENDA S Sheriff's Return No. 0039-T - -2002 OTHER COUNTY NO. 01-7175 at 8:40AM served the within upon by personally handing 1 true attested copy(ies) SU~R~ONS and making known 2002 to him/her the contents thereof at 307 MARKET ST HALIFAX, PA 17032-0000 Sworn and subscribed to before me this llTH day of JANUARY, 2002 So Answers, Sheriff of Dauphin County, Pa. Deputy Sheriff Sheriff's Costs: $38.50 PD 01/08/2002 RCPT NO 158550 NMILLER Mary Jane Snydcr Real Estate Deputy William T. Tully Solicitor Dauphin County Hanisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255~2889 Jack Lotwick Sheriff J. Daniel Basil¢ Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania County of Dauphin AND NOW: January 11, SUMMONS ENDERS KENDA S to HER of the original 2002 at : BUSH BURTON L JR vs : ENDERS KENDA S Sheriff's Return No. 0039-T - -2002 OTHER COUNTY NO. 01-7175 8:40AM served the within upon by personally handing 1 true attested copy(les) SUMMONS and making known to him/her the contents thereof at 307 MARKET ST HALIFAX, PA 17032-0000 Sworn and subscribed to before me this llTH day of JANUARY, 2002 PROTHONOTARY So Answers, Sheriff of Dauphin County, Pa. Deputy Sheriff Sheriff's Costs: $38.50 PD 01/08/2002 RCPT NO 158550 NMILLER In The Court of Common Pleas of Cumberland County, Pennsylvania Burton L. Bush Jr. Nanda R~nasw~ny et al SERVE: Kenda S. Enders No~ 01 7175 civil ]~ow, January 2, 2002 hereby deputize the Sheriff of Dauphin deputation being made at the request and risk of the Plaintiff. , I, SHERIFF OF CUMBERLAND COUNTY, PA, do County to execute this Writ, this Sheriff of Cumberland County, PA Affidavit of Service Now, ., 20 , at o'clock M. served the within upon by handing to a and made known to copy of the orig/nal So answers, the contents thereof. Sworn and subscribed be£ore me this day of ,20 Sheriff of County, PA COSTS SERVICE MILEAGE AFFIDAVIT tn The Court of Common Pleas ofC ~amberland County, Pennsylvania Burton L. Bush Jr. VS. Nanda R~naswamy et al SERVE: Paul C. Enders No. 01 7175 civil NOW, January 2, 2002 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Walt, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA within Affidavit of Service ., 20 , at o'clock M. served the up on at by handing to a and made lmown to copy of the original SO answers. the contents thereof. Sworn and subscribed befbre me this __ day of ~ 20 Sheriffof COSTS SERVICE MILEAGE AFFIDAVIT County, PA