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HomeMy WebLinkAbout10-4188 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD A/S/O Donald and Elizabeth Dorris Hartford Plaza, Hartford, CT 06115 JUNE TERM 2010 DOCKET NO.: LO - y 88 0'?V-a le pot and DONALD AND ELIZABETH DORRIS, Individually 709 McCormick Road Mechanicsburg, PA 17055 Plaintiffs V. AMERICAN HOME SHIELD CORPORATION 1524 Highway 30 East Carroll, IA 51401-0727 and NB MECHANICAL SERVICES, INC. 6470 Allentown Boulevard Harrisburg, PA 17112 Defendants PRAECIPE FOR SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: a z c: cn.:?= to Issue summons against the above named defendants. Writ of Summons shall be issued and forwarded to Attorney/Sheriff DATE: 6/21/2010 BY: KBG Kenneth B. Grear, Esquire Kenneth B. Grear, Ltd. 20 West Third Street, 3.d Floor Media, PA 19063 (P) 610-566-5275 (F) 610-566-5497 Supreme Court ID: 81608 Z $R8L.00 PO ALF1` C# ? 3o.Z 1 E agg170 lo-14196 (iivitTe m t SUMMONS IN CIVIL ACTION TO: (1) AMERICAN HOME SHIELD CORPORATION, 1524 Highway 30 East Carroll, IA 51401-0727; (2) NB MECHANICAL SERVICES, INC., 6470 Allentown Boulevard, Harrisburg, PA 17112; YOU ARE NOTIFIED THAT THE ABOVE NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. PROTHONOTARY DATE: IgI&S11D BY: SEAL OF COURT 2 r ~ PENNSYLVANIA CIVIL DIVISION PROPERTY AND CASU TY INSURANCE COMPANY OF HARTFORD a/s/o Donald d Elizabeth Dorris Hartford Plaza Hartford, CT 06115 I and JUNE TERM 2010 DONALD AND ELIZABE H DORRIS, Individually DOCKET NO.: 10-4188 709 McCormick Road Mechanicsburg, PA 17055 Pl intiffs v. AMERICAN HOME SHIE D CORPORATION ~ ~ J 1524 Highway 30 East ~ ~ "fj Carroll, IL, 51401-0727 -~~+='` ~--• •~ • `~ , ,-n and ---- a, , c;a ; NB MECHANICAL SER ICES, INC. +== _ ~. a~ -' ' -~~ ~ 6470 Allentown Boulevard r { -- _. ~. Harrisburg, PA 17112 ~ ~F. " G - .~ I, Kenneth B. SHIELD CORP. was the above captioned z return receipt card is Date: July 9, 2010 Esquire, hereby certify that defendant; AMERICAN HOME d via certified mail return receipt requested with the Writ/Summons in Pursuant to Pa.R.C.P. 403, and a true and correct signed copy of the ed hereto, made part hereof and marked at Exhibit ~`A'~_ BY: Kenneth , Attorne~,for lain ^ Complete i#ems Item 4 ff Restri ^ Print your name . 2. and 8. /also complete Deliverq is desired. d address on the reverse -- A. signature ^ Agent X ^ Addressee so that we can ^ Attach this card t um the card to you. the back of the mallpiece, B. Recely (Crlq~ ~ ,; _ 1 ;~. G. Date of Delivery. or on the front ff pace permits. ~ :3 , 1. Article dressed t : D. ~ delivery address dHferent Iran hem 1? ^ Yes ~~~ r- c A~ ~ _ #~arne S1n~e ~,~ If YES, enter delivery address below: O No ~o~~rq ; 4th ;r~ ,~~..~ ~ ~ 6 way ~ ~~ ~~- ~. ,~ ~ ~ Q t ` /~ 1 /~ 5 y ~ - Q~ ~ Certified Mail ~ Express Mall :~ r ~ 1 1 V ^ Registered ^ Retum Receipt for Merchandise .' ^ Insured Mail ^ C_Q~_ 4. Restricted Deliveyi (Exha Fee)- ^ Yes 2' ~s~urror~sew. ;_ 708 2820 0~~1 5214 0580 ~ PS Form 3811, F.eb ary 2004 'Domestic Retum Receipt ta25ys~z.nn-tsao SHERIF Ronny R Anderson Sherfff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE OF CUMBERLAND COUNTY ~~,~~1tt, of {C',~t~br~~~~~ - ~ ,,. or~~~e c~ ~ ~E ~ -~s~~rF FI~.E~ a i' ~ ~ Z~~~ Jl.~` ~ ~ ~~ ~ 3~ ~~ V~~~~r . ~~ ' ,~ '~.~`!~ IBC;=,j ,tll?,i, Ij:~ Property and Casualty Insurance C mpany of Hartford Case Number vs. 2010-4188 NB Mechanical Services, Inc. SHERIFF'S RETURN OF SERVICE 07/01/2010 Ronny R. Anderson, S eriff who being duly sworn according to law states that he made a diligent search and inquiry for the withi named defendant, to wit: NB Mechanical Services, Inc., but was unable to locate them in his bailiwick. H therefore deputized the Sheriff of Dauphin County, PA to serve the within Writ of Summons according to law. 07/06/2010 Dauphin County Retur :And now, July 6, 2010 I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and r turn, that 1 made diligent search and inquiry for NB Mechanical Services, Inc. the defendant named in th within Writ of Summons and that I am unable to find them in the County of Dauphin and therefore eturn same NOT FOUND. Request for service at 6470 Allentown Boulevard, Harrisburg, PA 17112 oes not exist. SHERIFF COST: $37.00 SO ANSWERS, / July 14, 2010 RON R ANDERSON, SHERIFF (cj CountySuite Sheriff. Teleosoft, Inc Mary Jane Snyder Real Estate Depu William T. Tully Solicitor Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of County of Dauphin I, Jack Lotwick, She that I made diligent sea in the within SUMMO] Dauphin, and therefore lvania PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD VS NB MECHANICAL SERVICES INC. •..~.. Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Sheriff s Return No. 2010-T-2280 OTHER COUNTY N0.20104188 of the County of Dauphin, State of Pennsylvania, do hereby certify and return, and inquiry for NB MECHANICAL SERVICES INC. the DEFENDANT named S IN CIVIL ACTION and that I am unable to find him/her in the County of same NOT FOUND, JULY 6, 2010. AS PER DEPUTY TH~RE IS NO SUCH ADDRESS AS 6470 ALLENTOWN BOULEVARD, HARRISBURG, PA 17 12 Sworn an subscribed to before me this 1 TH day of July, 2010 NOTARI L SEAL Y JANE SN ER, Notary ] Highspire, D uphin County So Answers, ~~~~ Sheriff of uphin Count' R~. By Deputy S eriff Deputy: G MILLER Sheriff s Costs: $49.25 7/6/2010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o Donald and Elizabeth Dorris Hartford Plaza Hartford, CT 06115 and JUNE TERM 2010 DONALD AND ELIZABETH DORRIS, Individually DOCKET NO.: 10-4188 709 McCormick Road Mechanicsburg, PA 17055 Plaintiffs v. AMERICAN HOME SHIELD CORPORATION 1524 Highway 30 East Carroll, IL 51401-0727 and NB MECHANICAL SERVICES, INC. 6470 Allentown Boulevard Harrisburg, PA 17112 Defendants c~ ~ c ~ - a ,, ~r'~ ~.__ t +`i - _. -. ~' ~- "- ~ ':.. _-, ~ ~, PRAECIPE TO REISSUE/REINSTATE WRIT AND SUMMONS TO THE PROTHONOTARY: Kindly re-issue/re-instate the attached Writ and Summons in the above matter. Date: July 22, 2010 LD 0.: 81608- 20 est Third Street 3` Floor Media, PA 19063 O (P) 610-566-5275 A (F) 610-566-5497 $1.00 P p ~'~ ~,i ~l~olq~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o Donald and Elizabeth Dorris Hartford Plaza Hartford, CT 06115 and DONALD AND ELIZABETH DORRIS, Individually 709 McCormick Road Mechanicsburg, PA 17055 Plaintiffs V. AMERICAN HOME SHIELD CORPORATION 1524 Highway 30 East Carroll, IL 51401-0727 and NB MECHANICAL SERVICES, INC 6470 Allentown Boulevard Harrisburg, PA 17112 Defendants PRAECIPE TO REISSUE/REINSTATE WRIT AND SUMMONS TO THE PROTHONOTARY: Kindly re-issue/re-instate the attached Writ and Summons in the above matter. "ri : - r V Lam. l_ ?: C.. _Y submit , Date: September 8, 2010 JUNE TERM 2010 DOCKET NO.: 10-4188 BY: Kenn B. Gr r-- s I.D. o.:8160 20 West Third Street 3rd Floor Media, PA 19063 (P) 610-566-5275 (F) 610-566-5497 *10. co PO ATT` C* 139 6 &148 t73 SHERIFF'S OFFICE OF CUMBERLAN Ronny R Anderson Sheriff ~g,~rtit~` or ~~~~n6rrl~~~ Jody S Smith Chief Deputy ~ ~ ~ ~ ~'~ ~ ~ M ~~ Richard W Stewart '' Solicitor aFr"~ ~ ~ ' '"4 `"~R'r~ D COUN~T„Y,~~ Yy-:,. .. -0 ~t1G ~~ AM ~~' ~ ~ ~C~~i_~~;~rU AA~~~~J~~~UM~I ~s °f~~W`N~'V("Y`~ Property and Casualty Insurance Company of Hartford Case Number vs. 2010-4188 NB Mechanical Services, Inc. SHERIFF'S RETURN OF SERVICE 08/12/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: NB Mechanical Services, Inc., but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Writ of Summons according to law. 08/17/2010 Dauphin County Return: And now, August 17, 2010 I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for NB Mechanical Services, Inc. the defendant named in the within Writ of Summons and that I am unable to find them in the County of Dauphin and therefore return same NOT FOUND. Request for service at 6740 Allentown Boulevard, Harrisburg, PA 17112 is currently the location of Spray on Siding of Central PA. SHERIFF COST: $37.00 August 26, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c? CountySuite Shenft. Teleosoft, Inc. Mary Jane Snyder Charlen of Dep heaffer Real Estate Depu ;s,c~, William T. Tully ' Mi Ahae~l t`Ch;ef Deputy ~ Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD VS County of Dauphin NB MECHANICAL SERVICES INC. Sheriff s Return No. 2010-T-2743 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for NB MECHANICAL SERVICES INC. the DEFENDANT named in the within WRIT OF SUMMONS and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, AUGUST 17, 2010. OTHER COUNTY CASE # 20104188 AS PER DEPUTY DEFT IS NO LONGER AT 6740 ALLENTOWN BLVD, HARRISBURG, PA 17112, THIS ADDRESS IS NOW SPRAY ON SIDING OF CENTRAL PA So Answers, ~~°~~~ Sheriff of Dauphin County, Pa. Deputy: W CONWAY Plaintiff: PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD Sheriff s Costs: $49.25 8/16/2010 Out Of County Cost: SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~.°~A'titr ct ~Ittt~6r~l;~n~ ~ ~~ ,,Y r K ,s~ , `Yr QFF~i°E QFTNE $r ~FIF~ Property and Casualty Insurance Company of Hartford vs. NB Mechanical Services, Inc. Ff~ E~-0~~'iC~ ?~~QQ~~ ~~ A~~~~ ~~ Case Number 2010-4188 SHERIFF'S RETURN OF SERVICE 09/28/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: NB Mechanical Services, Inc., but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Writ of Summons according to law. 10/06/2010 Dauphin County Return: And now, October 6, 2010 I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for NB Mechanical Services, Inc. the defendant named in the within Writ of Summons and that I am unable to find them in the County of Dauphin and therefore return same NOT FOUND. Request for service at 6740 Allentown Boulevard, Harrisburg, PA 17112 is occupied by East Shore Therapeutic Massage and they have been doing business at this address for over one year. SHERIFF COST: $37.00 October 13, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ioi GountySuite Sheriff. TeleosoR: Inc. Charles E. Sheaffer Chief Deputy William T. Tully •':~• solicitor Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD VS County of Dauphin NB MECHANICAL SERVICES INC. Sheriff s Return No. 2010-T-3090 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for NB MECHANICAL SERVICES INC. the DEFENDANT named in the within WRIT OF SUMMONS and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, OCTOBER 6, 2010. OTHER COUNTY CASE # 20104188 7979 PAXTON STREET, HARRISBURG, PA 17111 IS EAST SHORE THERAPEUTIC MASSAGE AND THEY HAVE BEEN AT THIS ADDRESS FOR 1.5 YEARS. DEFT IS NO LONGER AT 6740 ALLENTOWN BLVD., HARRISBURG, PA 17112 So Answers, ~~~~ Sheriff of Dauphin County, Pa. Deputy: G MILLER Plaintiff PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD Sheriffs Costs: $49.25 9/30/2010 Out Of County Cost: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o Donald and Elizabeth Donis Hartford Plaza. Hartford, CT 06115 and DONALD AND ELIZABETH DORRIS, Individually 709 McCormick Road Mechanicsburg, PA 17055 Plaintiffs v. a c~ r- r-~ ~ -n _ -~ ~` ~ i ~ i c~~a a r'n -- ~ ~~7 -- ~ Ca'"~ ~ N ~~ j ~ _~' _ C:J ~{ Ca "~ c~ -rt = ~ ' ~ JUNE TERM 2010 R~ `-- r ~~ -+ .... ~, ._..- DOCKET NO.: 10-4188 AMERICAN HOME SHIELD CORPORATION 1524 Highway 30 East Carroll, IL 51401-0727 and NB MECHANICAL SERVICES, INC. 6470 Allentown Boulevard Harrisburg, PA 17112 Defendants PRAECIPE TO REISSUE/REINSTATE WRIT AND SUMMONS TO THE PROTHONOTARY: Kindly re-issue/re-instate the attached Writ and Summons in the above matter. Date: October 22, 2010 ~em~e~fB. Grear,'~squire I.D. No.: 81608 20 West Third Street 3rd Floor Media, PA 19063 (P) 610-566-5275 A (F) 610-566-5497 ~~p~~D q"r7`f ~'~ 1453 ~,~ aso~~y OF THELPRO QHONOTARY 1010 NOY 29 PM 2: 13 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o Donald and Elizabeth Dorris and DONALD AND ELIZABETH DORRIS Individually, Plaintiffs VS. AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC., Defendants JUNE TERM 2010 DOCKET NO.: 10-4188 CIVIL TERM PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter the appearance of Buzgon Davis Law Offices whose address is 525 South Eighth Street, P.O. Box 49, Lebanon, Pennsylvania 17042-0049, as attorneys for the Defendants, in the above-captioned case. DATE: November 24, 2010 BY: BUZGON DAVIS LAW OFFICES SCOTT L. ENOBLE, ESQUIRE Attorney . #72808 525 South Eighth Street P.O. Box 49 Lebanon, PA 17042-0049 (717) 274-1421 (717) 274-1752 - facsimile Email: sgrenoblekbuzgondavis.com Attorney for Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA c C PROPERTY AND CASUALTY -03 © ..? INSURANCE COMPANY OF rMW *i o rzn' HARTFORD a/s/o Donald and cotes- 'arn Elizabeth Dorris <o ? a° and JUNE TERM 2010 c X° 5: c5cr) DONALD AND ELIZABETH DORRIS DOCKET NO.: 10-4188 Individually, - `= Plaintiffs CIVIL TERM VS. AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC., Defendants PRAECIPE FOR RULE TO FILE COMPLAINT TO THE, PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: AND NOW, November 24, 2010, issue a Rule upon the Plaintiff to file their Complaint in the above matter within twenty (20) days of service of said Rule upon her or suffer a judgment of non pros. BUZGON DAVIS LAW OFFICES BY: Sco renoble, Esquire-Attorney I.D. #72808 525 uth Eighth Street-Post Office Box 49 Lebanon, PA 17042-0049 (717) 274-1421 Attorneys for Defendant RULE AND NOW, this c) day of D mber, 2010, Mule is issued in accordance with the above Praecipe. Pro ry -2- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ? PROPERTY AND CASUALTY C?f,r?'-- ?rrn INSURANCE COMPANY OF r+0 C? HARTFORD a/s/o Donald and -v =-n Elizabeth Dorris tv o? and : JUNE TERM 2010 x DONALD AND ELIZABETH DORRIS DOCKET NO.: 10-4188 Individually, Plaintiffs CIVIL TERM vs. AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC., Defendants AFFIDAVIT OF SERVICE, COMMONWEALTH OF PENNSYLVANIA ) ) ss: COUNTY OF LEBANON ) 1, Britany Hirst, an employee of the law firm of Buzgon Davis Law Offices, 525 South Eighth Street, Lebanon, Lebanon County, Pennsylvania, Attorneys for NB Mechanical Services, Inc. being duly sworn according to law, depose and say that on November 24, 2010 I mailed for filing in the Office of the Prothonotary of Cumberland County, the original PRAECIPE FOR ENTRY OF APPEARANCE and that I mailed, by First Class mail, in a postpaid envelope, a true and correct copy to Kenneth B. Grear, Esquire, 20 West Third Street, 3?d Floor, Media, PA 19063, Attorney for Plaintiff. Sworn to and subscribed before me this 24 h day of November, A.D., 2010. r +; 1 BRITANY HIRST Notary Public COMMONWEALTH OF PENNSYLVANIA F Notarial Seal Ashley M. Long, Notary Public City of Lebanon, Lebanon County M Canminion E Inn June 29, 2011 onM an noWation of Notaries -2- `' T OFFICE fIONOTAI 2618 DEC ?,2 Ph CUA$F?, 37 E)V SYLA1 A T' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o Donald and Elizabeth Dorris : and JUNE TERM 2010 DONALD AND ELIZABETH DORRIS DOCKET NO.: 10-4188 Individually, Plaintiffs CIVIL TERM vs. AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC., Defendants PRAECIPE FOR AMENDED ENTRY OF APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter the appearance of Buzgon Davis Law Offices whose address is 525 South Eighth Street, P.O. Box 49, Lebanon, Pennsylvania 17042-0049, as attorneys for the Defendant, NB Mechanical, in the above-captioned case. DATE: December 1, 2010 BY: BUZGON DAVIS LAW OFFICES S OBLE, ESQUIRE Attor .D. 972808 525 ?Vut Eighth Street P.O. ox 49 Lebanon, PA 17042-0049 (717) 274-1421 (717) 274-1752 - facsimile Email: sgrenobleAbuzgondavis.com Attorney for Defendant, NB Mechanical Services, Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o Donald and Elizabeth Dorris and DONALD AND ELIZABETH DORRIS Individually, Plaintiffs VS. AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC., Defendants t-) C CZ = = JUNE TERM 2010 60 011-'3 DOCKET NO.: 10-4188 ..,; CIVIL TERM >C= N Q PRAECIPE TO SUBSTITUTE AMENDED ENTRY OF APPEARANCE To the Prothonotary: Please substitute the attached Amended Entry of Appearance to the Entry of Appearance filed on November 29, 2010. BUZGON DAVIS LAW OFFICLS BY: SCOyf GRENOBLE, ESQUIRE Atto I.D. #72808 525 South Eighth Street P.O. Box 49 Lebanon, PA 17042-0049 (717) 274-1421 (717) 274-1752 - facsimile Email: sgrenoblekbuzgondavis.com Attorney for Defendant, NB Mechanical Services, Inc. TN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o Donald and Elizabeth Dorris and JUNE TERM 2010 DONALD AND ELIZABETH DORRIS DOCKET NO.: 10-4188 Individually, Plaintiffs CIVIL TERM vs. AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC., Defendants AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) ss: COUNTY OF LEBANON ) m ca x: ? h r- ? . rte- Z 1 N ? y C o NO -t co I, Britany Hirst, an employee of the law firm of Buzgon Davis Law Offices, 525 South Eighth Street, Lebanon, Lebanon County, Pennsylvania, Attorneys for NB Mechanical Services, Inc. being duly sworn according to law, depose and say that on December 1, 2010 I mailed for filing in the Office of the Prothonotary of Cumberland County, the original PRAFCIPE TO SUBSTITUTE AMENDED ENTRY OF APPEARANCE, and PRAECIPE FOR AMENDED ENTRY OF APPEARANCE and that I mailed, by First Class mail, in a postpaid envelope, a true and correct copy to Kenneth B. Grear, Esquire, 20 West Third Street, 3rd Floor, Media, PA 19063, Attorney for Plaintiff. BRITANY HIRST Sworn to and subscribed before me this 0 day of December, A.D., 2010. COMMONWEALTH OF PENNSYLVANLA Notarial Saar Ashley M. Long, Notary Public City of Lebanon, Expires County My Commission Expires June 29, 2011 Notary Public ' Member, Pennsylvania Aasoeiation of Notaries -2- . ti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o Donald and Elizabeth Dorris : and JUNE TERM 2010 DONALD AND ELIZABETH DORRIS DOCKET NO.: 10-4188 Individually, Plaintiffs CIVIL TERM vs. AMERICAN HOME SHIELD CORPORATION : and rn m NB MECHANICAL SERVICES INC. : ? b ? ` , , Defendants ,--.Z rv C7 c? , = o a „Q AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF LEBANON ) I, BRITANY HIRST, an employee of Buzgon Davis Law Offices, 525 South Eighth Street, Lebanon, Lebanon County, Pennsylvania, Attorneys for Defendant NB Mechanical, being duly sworn according to law, depose and say that I mailed on December 1, 2010, by regular mail, in a postpaid envelope, a true and correct copy of PRAECIPE FOR RULE TO FILE COMPLAINT AND RULE, the original of which was filed on November 29, 2010, in the Office of the Prothonotary of Cumberland County, Pennsylvania, to Kenneth B. Grear, Esquire, 20 West Third Street, 3`d Floor, Media, PA 190 , Attorney for Plaintiff. lit` BRITANY HIRST Sworn to and subscribed before me this 1st day of December, A.D., 2010. COMMON'r°VEA! TgA 0F pp-siSYLVANIA iVa?taria; E a ?! Asey L61191 P+r.,t3ry Public City of l ebar an, lire-ao County 1 1 ? L M?/ Comrrsissinn Expire "sane 29, 2011 Notary Public Member, PennsyEdania Asxeaia5on of Notaries -2- ILE-OFFICE OF THE' PR O Tt;ONoTAR'r- zO?I? J11 PIV I? 11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o Donald and Elizabeth Dorris and JUNE TERM 2010 DONALD AND ELIZABETH DORRIS DOCKET NO.: 10-4188 Individually, Plaintiffs CIVIL TERM Vs. AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC., Defendants TO: Property and Casualty Insurance Company of Hartford a/s/o Donald and Elizabeth Dorris c/o Kenneth B. Grear, Esquire 20 West Third Street, 3`d Floor Media, PA 19063 Date of Notice: January 18, 2011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE TfIE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. MidPenn Legal Services 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 BUZGON DAVIS LAW OFFICES BY: Scott L. Greno squire-,--- Attorney I.D. #72808 525 South Eighth Street Post Office Box 49 Lebanon, PA 17042-0049 (717) 274-1421 Fax: (717) 274-1752 E-mail: sgrenoble@buzgondavis.com Attorneys for Defendant, NB Mechanical Services -2- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o Donald and Elizabeth Dorris and DONALD AND ELIZABETH DORRIS Individually, Plaintiffs JUNE TERM 2010 DOCKET NO.: 10-4188 CIVIL TERM VS. AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC., Defendants AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF LEBANON ) I, BRITANY HIRST, an employee of Buzgon Davis Law Offices, 525 South Eighth Street, Lebanon, Lebanon County, Pennsylvania, Attorneys for Plaintiff, being duly sworn according to law, depose and say that I mailed on January 18, 2011, by regular mail, in a postpaid envelope, a true and correct copy of IMPORTANT NOTICE, the original of which was mailed for filing in the Office of the Prothonotary of Cumberland County, Pennsylvania on -3- January 18, 2011, to Kenneth B. Grear, Esquire, 20 Wes Third Street, 3`d Floor, Media, PA 19063, Attorney for Plaintiff. Sworn to and subscribed before me this 18th day of January, A.D., 2010. //[?' (IbUAk Notary Public BRITANY HIRST COMMONWEALTH OF PENNSYLVANIA Notarial Seal Ashley M. Long, Notary Public City of Lebanon, Lebanon County My Commission Expires June 28, 2011 Member, Pennsylvania Association of Notaries -4- . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o Donald and Elizabeth Dorris and DONALD AND ELIZABETH DORRIS Individually, Plaintiffs VS. AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC., Defendants JUNE TERM 2010 DOCKET NO.: 10-4188 CIVIL TERM AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF LEBANON ) c r^ r* ti ?" -v fn <C -0 ?Icc` CD Irn I, NATALIE K. JENKINS, an employee of Buzgon Davis Law Offices, 525 South Eighth Street, Lebanon, Lebanon County, Pennsylvania, Attorneys for Defendant NB Mechanical, being duly sworn according to law, depose and say that I mailed on March 25, 2011, by regular mail, in a postpaid envelope, the original and a copy of INTERROGATORIES OF NB MECHANICAL SERVICES, INC. DIRECTED TO DEFENDANT AMERICAN HOME . . SHIELD CORPORATION and REQUEST FOR PRODUCTION OF DOCUMENTS OF DEFENDANT NB MECHANICAL SERVICES DIRECTED TO DEFENDANT' AMERICAN HOME SHIELD CORPORATION, to David J. Alfini, 222 North LaSalle Street Suite 300, Chicago, IL 6060, and a copy to Kenneth 13. Grear, Esquire, 20 West Third Street, " Floor, _3 d Media, PA 19063, Attorney for Plaintiff q'_ _`Vel. ? NATALIE K. JENK S Sworn to and subscribed before me this 25th day ofr arch, A.D.?011. d? Notary Public NOTARIAL SEAL BRiTANY HIRST No" PUMIC CITY OF LEBANON, LEBANON COUNTY- My CoewnksiN Ey*n Jul 10, 2013 -2- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o Donald and -' Elizabeth Dorris : cz. -,,= -- = . r-{ Co C.-_ i . _..: and : JUNE TERM 2010 - ` DONALD AND ELIZABETH DORRIS DOCKET NO.: 10-4188 " Individually, =C C) Plaintiffs CIVIL TERM cri vs. AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC., : Defendants ; MOTION TO COMPEL DISCOVERY OF DEFENDANT, AMERICAN HOME SHIELD CORPORATION AND NOW, come the Defendant, NB Mechanical Services, Inc., by their attorneys, Buzgon Davis Law Offices, and files this Motion to Compel Discovery, averring as follows; I . On March 25, 2011, the undersigned counsel served Interrogatories and a Request for Production of Documents directed to Defendant, American Home Shield Corporation, upon Defendant's counsel, David J. Alfini, Esquire. A true and correct copy of the Affidavit of Service evidencing same is attached as Exhibit "A". 2. Defendant, American Home Shield Corporation, has failed to respond the Interrogatories and Request for Production of Documents. 3. Defendant's failure to reply to Defendant NB Mechanical Services Inc.'s discovery is in violation of Pa.R.C.P. 4006 and 4009.12. WHEREFORE, Defendant, NB Mechanical Services, Inc., requests your Honorable Court to enter an Order compelling Defendant, American Home Shield Corporation, to serve on Defendant"s counsel a response to the Interrogatories and Request for Production of Documents and to reimburse Defendant for counsel fees and expenses regarding this Motion. BUZGON DAVIS LAW OFFICES BY:_ -? Scott L.'"renoble, Esquire Atto I.D. 472808 52 ? outh Eighth Street Post Office Box 49 Lebanon, PA 17042-0049 (717) 274-1421 Fax: (717) 274-1752 E-mail: sgrenoble@buzgondavis.com Attorneys for Defendant, NB Mechanical Services, Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o Donald and Elizabeth Dorris and DONALD AND ELIZABETH DORRIS Individually, Plaintiffs vs. AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC., Defendants JUNE TERM 2010 DOCKET NO.: 10-4188 CIVIL TERM AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF LEBANON ) 4Fn C-- :43;" CO D I, NATALIE K. JENKINS, an employee of Buzgon Davis Law Offices, 525 South Eighth Street, Lebanon, Lebanon County, Pennsylvania, Attorneys for Defendant NB Mechanical, being duly sworn according to law, depose and say that I mailed on March 25, 2011, by regular mail. in a postpaid envelope, the original and a copy of INTERROGATORIES OF NB MECHANICAL SERVICES, INC. DIRECTED TO DEFENDANT AMERICAN HOME EXHIBIT 19 SHIELD CORPORATION and REQUEST FOR PRODUCTION OF DOCUMENTS OF DEFENDANT N13 MECHANICAL SERVICES DIRECTED TO DEFENDANT AMERICAN HOME SHIELD CORPORATION, to David J. Alfini, 222 North LaSalle Street Suite 300, Chicago, IL 6060, and a copy to Kenneth B. Grear, Esquire, 20 West Third Street, 3", Floor, Media, PA 19063, Attorney for Plaintiff. NATALIE K. JENKI S Sworn to and subscribed before me this 25th day of arch, A.D. ,011. I Notary Public NOTARIAL SEAL BRITANY HIRST Notary Public CITY Of LEBANON, LEBANON COUNTY- My Commission Expires Jul 10, 2013 -2- w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA , -_' cp - ern ? c:-- PROPERTY AND CASUALTY INSURANCE COMPANY OF t-- n4- -! c HARTFORD a/s/o Donald and o Elizabeth Dorris cars and JUNE TERM 2010 DONALD AND ELIZABETH DORRIS Individually, Plaintiffs vs. AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC., : Defendants ; DOCKET NO.: 10-4188 CIVIL TERM AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF LEBANON ) I, NATALIE K. JENKINS, an employee of Buzgon Davis Law Offices, 525 South Eighth Street, Lebanon, Lebanon County, Pennsylvania, Attorneys for Defendant NB Mechanical, being duly sworn according to law, depose and say that I mailed on July 28, 2011 by regular mail to the Cumberland County Prothonotary, in a postpaid envelope, the original and four copies of the MOTION AND ORDER TO COMPEL DISCOVERY for filing, and that I V. provided the Prothonotary with post-paid envelopes to David J. Alfini, 222 North LaSalle Street Suite 300, Chicago, IL 6060, Kenneth B. Grear, Esquire, 20 West Third Street, 3`d Floor, Media, PA 19063, Attorney for Plaintiff, and American Home Shield Corporation, P.O. Box 849, Carroll, IA 51401. NATALIE K. JE KINS ./ Sworn to and subscribed before me this 28th day of July, ., 201 , Notary Public -'NOTARIAL SEAL BRITANY HIRST Notary Public CITY Of LEBANON, LEBANONtCOUN Y My Commission Expires -2- MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: Thomas P. Wagner, Esquire Identification No.: 27145 BY: Mary C. Doherty, Esquire Identification No.: 93593 1845 Walnut Street Philadelphia PA 19103 (215) 575-4562 / (215) 575-2884 Attorneys for Defendant, American Home Shield Corporation COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o DONALD and ELIZABETH DORRIS and DONALD and ELIZABETH DORRIS, JUNE TERM 2011 ; ? , Individually CM Plaintiffs cc CD C) NO. 10-4188 ?=- AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC. Defendants ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance on behalf of Defendant, American Home Shield Corporation, in the above-captioned matter. Dated: (Ilia, Q MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: Thomas P ff agner, Esquire Mary C. Doherty, Esquire Attorneys for Defendant, American Home Shield Corporation CERTIFICATE OF SERVICE I do hereby certify that a true and correct copy of the foregoing Entry of Appearance on behalf of Defendant American Home Shield Corporation was served upon all parties via U.S. Mail on the below-noted date at the following addresses: Kenneth B. Grear, Esquire Kenneth B. Grear, Ltd. 20 West Third Street, 3rd Floor Media, PA 19063 Scott L. Grenoble, Esquire Buzgon Davis Law Offices 525 South Eight Street P.O. Box 49 Lebanon, PA 17042-0049 Dated: 57 Z -0 1 67 - 01 /7067178.v 1 MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN Thomas P. gner, Esquire BY: -?6 Mary C. Doherty, Esquire Attorneys for Defendant, American Home Shield Corporation al_ is EIL RRn-1-finNoT.Gt ,' 17 P 11 2: IN THE COURT OF COMMON PLEAS OF CUMBERLAND C009TV LAND COUNTY PENNSYLVANIA r';- NSYLVAN1A PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o Donald and Elizabeth Dorris and JUNE TERM 2010 DONALD AND ELIZABETH DORRIS DOCKET NO.: 10-4188 Individually, Plaintiffs CIVIL TERM vs. AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC., Defendants AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF LEBANON ) 1, NATALIE K. JENKINS, an employee of Buzgon Davis Law Offices, 525 South Eighth Street, Lebanon, Lebanon County, Pennsylvania, Attorneys for Defendant NB Mechanical, being duly sworn according to law, depose and say that I mailed on August 16, 2011, by regular mail, in a postpaid envelope, the original and a copy of DEFENDANT NB MF,CHANICAL'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO DEFENDANT AMERICAN HOME SHIELD CORPORATION, to Mary C. Doherty, Esquire, 1845 Walnut Street, Philadelphia, PA, 19103, Attorney for Defendant American Home Shield Corporation. Sworn to and subscribed before me this 16th day kAust. A. 201 1. : Notary Public 4v%v (?Mtro NATALIE K. JENKINS NOTAM SEAL BRITANY HIRST Notary Public CITY Of LEBANON, LEBANON COUNTY My Commission Expires Jul 10, 2013 -2- F:\dlbiLiti?,ation\titate Fa nn Ins\N13 Mechanical Service APraecipe to withdraw.doe.e - 81125/11 2:33 I'M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROPERTY AND CASUALTY INSURANCE COMPANY OF HARTFORD a/s/o Donald and Elizabeth Dorris and JUNE TERM 2010 DOCKET NO.: 10-4188 CIVIL TERM r-z to d ?c) z a bC: N C*.) o C-1 CIO --c C? DONALD AND ELIZABETH DORRIS Individually, Plaintiffs VS. AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC., Defendants To the Prothonotary: PRAECIPE Please withdraw the MOTION TO COMPEL DISCOVERY OF DEFENDANT, AMERICAN HOME SHIELD CORPORATION filed on July 29, 2011. BUZGON DAVIS LAW OFFICES BY: Scott L. Grenoble, ,s re-Attbmief I.D. #72808 t-Post Office Box 49 525 South Eighth V42-0049 Lebanon, PA 17 (717) 274-1421 Fax: (717) 274-1752 E-mail: sgrenoble@buzgondavis.com Attorneys for Defendant, NB Mechanical Services, Inc. F:Ad1b\1 itieation\Statc Farm Ins\NB Mechanical Services\Affidavil ofservice_docx 8/2„11 2A] 61M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PROPERTY AND CASUALTY INSURANCE COMPANY OF t HARTFORD a/s/o Donald and Elizabeth Dorris rco rn-n Wr- r" ;:0 and JUNE TERM 2010 `<> C;? < x© DONALD AND ELIZABETH DORRIS DOCKET NO.: 10-4188 ?o z Wi=t Individually, v rn Plaintiffs CIVIL TERM C? VS. AMERICAN HOME SHIELD CORPORATION and NB MECHANICAL SERVICES, INC., Defendants AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) ss: COUNTY OF LEBANON ) I, NATALIE K. JENKINS, an employee of Buzgon Davis Law Offices, 525 South Eighth Street, Lebanon, Pennsylvania, 17042, attorneys for NB Mechanical Services, Inc., being duly sworn according to law, depose and say that I mailed on AugustC?10, 2011, by regular mail, in a postpaid envelope, a true and correct copy of PRAECIPE (to withdraw the Motion To Compel Discovery Of Defendant, American Home Shield Corporation filed on July 29, 2011), A the original of which was mailed on August , 2011, for filing in the Office of the Prothonotary of Cumberland County, Pennsylvania, to: Kenneth B. Grear, Esquire KENNETH B. GREAR, LTD. 20 West Third Street, 3rd Floor Media, PA 19063 attorney for Plaintiffs NA ALIE K. JENKINS Sworn to and subscribed before me this JU, day of August, A.D., 2011. Not ublic Mary C. Doherty, Esquire MARSHAL, DENNEHEY, WARNER, COLEMAN & GOGGIN 1845 Walnut Street Philadelphia, PA 19103 attorney for Defendant, American Home Shield Corporation IoM NIA Notarial Seal Amy Hartranft, Notary Public City of Lebanon, Lebanon County MY Commission Expires Sept. 19, 2014 r^?mh?r. Pe.nnsvlvania Association of Notaries -2- David Et. Buea 1r'rothonotary Office of the Prothonotary Cum6erfand County, cPennsylvania ORDER OF TERMINATION OF COURT CASES �yrkS. Sohonage, T S'Q Solicitor CIVIL TERM AND NOW THIS 28Th DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE —THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 0 Suite100 ® Carlisle, r1',� 0 Phone 717 240-6195 0 Fax 71 7 240-6573