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HomeMy WebLinkAbout01-4780CHARLENE M. SHEARER and MERVIN E. SHEARER, her husband, Plaintiffs Vo SHERATON VALLEY FORGE HOTEL, RADISSON VALLEY FORGE HOTEL, and GF MANAGEMENT, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM - LAW E)I'- c/'78C) PRAECIPE FOR ISSUANCE OF A WRIT OF SUMMONS TO CURTIS R. LONG, PROTHONOTARY: Please issue a Writ of Summons against the defendants, Sheraton Valley Forge Hotel, Radisson Valley Forge Hotel and GF Management, and enter my appearance on behalf of the plaintiffs, Charlene M. Shearer and Mervin E. Shearer. Please direct the Sberiffto serve the defendants as follows: GF Management, A Limited Partnership Sheraton Valley Forge Hotel Radisson Valley Forge Hotel 1160 First Avenue King of Prussia, PA 19406 Respectfully submitted, Date: August 13, 2001 By: IRVON, Mci{NIGHT & HUIT~I~S 60 West P:mfret sitgr~;t,~-~ii~i~,~ 1;013 (717) 249-2353 - Supreme Court I.D. No: 25476 To: SHERATON VALLEY FORGE HOTEL, RADISSON VALLEY FORGE HOTEL, and GF MANAGEMENT, A Limited Partnership You are hereby notified that Charlene M. Shearer and Mervin E. Shearer, plaintiffs, have commenced an action against you which you are required to defend or a default judgment may be entered against you. PROTItOINOTARY Date:/--/at ~'uyP/~5 ' ,2001 By: DEPUT~~ / SHERIFF'S RETURN CASE NO: 2001-04780 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SHEARER CHARLENE ET AL VS SHERATON VALLEY FORGE HOTEL ET - OUT OF COUNTY R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: SHERATON VALLEY FORGE HOTEL but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of MONTGOMERY County, Pennsylvania, serve the within WRIT OF SUMMONS to On August 28th , 2001 , this office was in receipt of the attached return from MONTGOMERY Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Montgomery Co 65.00 .00 102.00 08/28/2001 Sheriff of Cumberland County IRWIN MCKNIGHT & HUGHES Sworn and subscribed to before me this /~' day of ~ ~/ A.D. ' ! Prothonotary ! ' SHERIFF'S RETURN - CASE NO: 2001-04780 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SHEARER CHARLENE ET AL VS SHERATON VALLEY FORGE HOTEL ET OUT OF COUNTY R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT , RADISSON VALLEY FORGE HOTEL but was unable to locate Them in his bailiwick. deputized the sheriff of MONTGOMERY County, serve the within WRIT OF SUMMONS , Sheriff or Deputy Sheriff who being says, that he made a diligent search and to wit: He therefore Pennsylvania, to On August 28th , 2001 , this office was in receipt of the attached return from MONTGOMERY Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 08/28/2001 So : R.r'Thomas Kline Sheriff of Cumberland County IRWIN MCKNIGHT & HUGHES Sworn and subscribed to before me this /2~'3~ day of ~ ~ A.D. ' ; Prothonotary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-04780 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SHEARER CHARLENE ET AL VS SHERATON VALLEY FORGE HOTEL ET R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT GF MANAGEMENT A LIMITED PARTNERSHIP but was unable to locate Them in his bailiwick. deputized the sheriff of MONTGOMERY County, serve the within WRIT OF SUMMONS · Sheriff or Deputy Sheriff who being says, that he made a diligent search and · to wit: He therefore Pennsylvania, to On August 28th , 2001 , this office was in receipt of the attached return from MONTGOMERY Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 08/28/2001 So answer R. ne Sheriff of Cumberland County IRWIN MCKNIGHT & HUGHES Sworn and subscribed to before me this /~_~ day of ~ ~; A.D. · ! Prothonotary' ' Ih The Court of Common Pleas of Cumberland County, Pennsylvania C~arlene M. Shearer, et. al. ' ., VS. a~ ~ ServeSherat°~%.. Valley ~brge Hotel, et. ~ Hote~u-  [~O~,_She,raton Valley Forge 01-4780 Civil 8/14/01 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Montgcmery County to execute this Writ, this deputation being made at th[l~sk of the Plaintiff. LAST DAY FOR SERVICE, -I ..i ". Sheriff of Cumberland County, PA Now, ,.-~o'~ .G')a. ~/ .,~. .... ~-~ o/ '- 0 wimin ~o q ~ Affidavit of Service ,20 o i , at o?c/J'- o'clock _ ,r~ M. served the by handing to '~,,'W~-~M',,~ _/rT~oC_l?,~-r.,-{ a ('~/-.L~ copy of the original and made known to / Sworn and subscribed before COSTS SERVICE $ MILEAGE AFFIDAVIT In The Court of Common Pleas of Cumberland County, Pennsylvania Charlene M. Shearer, et. al. · VS. ' ServeSherat. on Valley Forge Hotel,. et. al. ['~5 ~ R~ldisson Valley Forge Hot~b. 01-4780 Civil ,..., , I, SHERIFF OF CUS,~ERLAND COUNTY, PA, do hereby deputize the Sheriff of Montgcmery County to execute this Writ, this deputation being made at the ~k of the Plaintiff. LAST DAY FOR SERVICE -I ' % ~ ~I· - Sheriff of Cumberland County, PA Affidavit of Service Now, within ,20o! _, at o?¢j-- o'clock ~ M. servedthe upon by handing to _~,-t ~v,~t,~ //~ ~__ ~y~j/~/ t:~ a copy of the originalz,.4r.~r'T' ..~ m.,.:., mad made lmown to ~ ~, v ~. ~e contems ~ere~ ~i .......... $hefiffof ~~ Counw, PA Sworn and subscribed before 9-- } COSTS SERVICE MILEAGE AFFIDAVIT Charlene M. Shearer, et. al. VS. Sheraton Valley Forge Hotel,l'~}. al. Serve: ~GF Management In The Court of Common Pleas of Cumberland County, Pennsylvania 01-4780 Civil 8/14~01 , I, SHERIFF OF CUMBERLAND coUNTy, PA, do hereby deputize the Sheriff of Montgr~nery County to execute this Writ, this deputation being made at th~~k of the Plaintiff. LAST DAY FOR SERVICE - ! ' %~0 % Sheriffof Cumberland County, PA Affidavit of Service NoW,~?-'~,~/~ .._~5~).~.~ , 20., ,at o~-- o'clock wi~in ~, ~ upon ~ M. served the Sworn and subscribe/al, before ~ ) me this o7~/ day oj'Ut.x3,.~ /, 20_© COSTS SERVICE MILEAGE AFFIDAVIT DEVLIN & DEVIN By: Ramon D. Townsend, Esquire Attorney ID#: 50371 Suite 200 100 West Elm Street Conshohocken, PA 19428 Attorney for Defendants CHARLENE M. SHEARER and MERVIN E. SHEARER, her husband VS. SHERATON VALLEY FORGE HOTEL RADISSON VALLEY FORGE HOTEL And GF MANAGEMENT COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 01-4780 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Defendants, Sheraton Valley Forge Hotel, Radisson Malley Forge Hotel and GF Management regarding the above-captioned matter. DEVLIN & DEVINE RAMON D. TOWNSEND, ESQUIRE Attorney for Defendants DEVLIN & DEVIN By: Ramon D. Townsend, Esquire Attorney ID#: 50371 Suite 200 100 West Elm Street Conshohocken, PA 19428 Attorney for Defendants CHARLENE M. SHEARER and MERVIN E. SHEARER, her husband : VS. : ; SHERATON VALLEY FORGE HOTEL: RADISSON VALLEY FORGE HOTEL : And GF MANAGEMENT : ; COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 01-4780 PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please enter a Rule on plaintiff in the above-entitled matter to file a Complaint within twenty (20) days or suffer judgment of non pros. DEVLIN & DEVINE BY: RAMON D. TOWNSEND, ESQUIRE Attorney for Defendants, RULE TO FILE COMPLAINT TO THE WITHIN PLAINTIFF: You are hereby ruled to file a Complaint within twenty (20) days after service hereof. CHARLENE M. SHEARER and : IN THE COURT OF COMMON PLEAS OF MERVIN E. SHEARER, her husband, Plaintiffs SHERATON VALLEY FORGE HOTEL,: RADISSON VALLEY FORGE HOTEL, : and GF MANAGEMENT, : Defendants : : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-4780 CIVIL TERM CIVIL ACTION - LAW PRAECIPE TO SETTLE AND DISCONTINUE To Curtis R. Long, Prothonotary: Please mark thc above-captioned case settled and discontinued and issue a Settlement Certificate to Marcus A. McKnight, III, Esquire, at 60 West Pomfret Street, Carlisle, Pennsylvania 17013. Respectfully submitted, I~GHES ou west/~omtret Street Carlisle, Pennsylvania 17013 (717) 249-2353 Date: June 3, 2002 CHARLENE M. SHEARER and : IN TItE COURT OF COMMON PLEAS OF MERVIN E. SHEARER, her husband, Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4780 CIVIL TERM SHERATON VALLEY FORGE HOTEL,: RADISSON VALLEY FORGE HOTEL, : and GF MANAGEMENT, : Defendants : CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certi~ that a copy of attached Praecipe to Settle and Discontinue was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Ramon D. Townsend, Esquire DEVLIN & DEVINE 100 West Elm Street, Ste. 200 Conshohocken, PA 19428 Date: June 4, 2002 By: IRWIN, McKN GHT & HUGHES Marcus A./McKnight, {II~F~re 60 West Pomfret Street "-/ Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No. 25476