The URL can be used to link to this page

Home My WebLink About10-4881SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor International Portfolio Inc. vs. Sharon G. Shields u~itr ~t ~1~~~htr1 ~~ ~~ . ~ l.T,~ .4 'C~.'Ir Q'fFl~ ~~c 7HE ~MERIFF ~,: !_ ° i ~ t r.7, f ~vG- ~ r , , ,"f:~ ~,,F , _,, EY ~i Case Number 2010-4881 SHERIFF'S RETURN OF SERVICE 08/02/2010 07:19 PM -Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on August 2, 2010 at 1919 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Sharon G. Shields, by making known unto herself personally, at 1310 Ritner Highway #10, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $33.40 August 03, 2010 ~s~/'/ RONALD HOOVER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Sheriff. Teleosoft. Inc. F:\FILES\C icnu\ 13997 Sheilds\13997. Lpral Revised: 8/11/10 2:27PM Daniel K. Deardorff, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY MARTSON LAW OFFICES I.D. 17837 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Z61o I?U? 1`3 w _ & FALLER INTERNATIONAL PORTFOLIO, INC., IN THE COURT OF COMMON PLEAS OF Plaintiff COUNTY, PENNSYLVANIA v. NO. 10-4881 CIVIL ACTION - LAW SHARON G. SHIELDS, AKA, SHARON GRACE SHIELDS, Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON LAW OFFICES on behalf of the Defendant in the above matter. Respectfully Submitted, MARTSON LAW OFFICES By ? (JC . Daniel K. Deardorff, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Sharon G. Shields Date: August 12, 2010 CERTIFICATE OF SERVICE I, Ami J. Thumma, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: George Twardy, Jr., Esquire TWARDY AND ASSOCIATES, LLC 1026 Winter Street Suite 400 Philadelphia, PA 19107 MARTSON LAW OFFICES By Abla 11-? iJ.Th a 10 East High Street Carlisle, PA 17013 (717) 243-3341 Dated: August 12, 2010 PTILES1Cheets113997 Sheddv113997.1.emt Revised: 8/13/10 8:21AM Daniel K. Deardorff, EsquireC IbtdG ?' • 3(p MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES r? I.D. 17837 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant INTERNATIONAL PORTFOLIO, INC., IN THE COURT OF COMMON PLEAS OF Plaintiff COUNTY, PENNSYLVANIA V. NO. 10-4881 CIVIL ACTION - LAW SHARON G. SHIELDS, AKA, SHARON GRACE SHIELDS, Defendant JURY TRIAL DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER TO PLAINTIFF'S COMPLAINT TO: INTERNATIONAL PORTFOLIO, INC., Plaintiff, and their attorney, GEORGE TWARDY, JR., ESQUIRE YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. AND NOW comes Defendant, SHARON G. SHIELDS, by and through her attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and hereby responds to Plaintiff's Complaint as follows: 1-2. Admitted. 3-9. Denied as stated. Defendant cannot remember going to the hospital then. If she did, it was related to problems arising from a work injury that occurred on September 24, 2007, and she would not be liable. Proof is demanded. WHEREFORE, Defendant demands that the Complaint be dismissed. ti NEW MATTER 10. Paragraphs 3-9 of this Answer are incorporated herein by reference as New Matter. WHEREFORE, Defendant demands that the Complaint be dismissed. Respectfully Submitted, MARTSON LAW OFFICES 010 By ?-z Daniel K. Deardorff, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Sharon G. Shields Date: August 12, 2010 r VERIFICATION The foregoing Answer with New Matter is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. aron G. Shields F:\FUM\Cbctn\13997 Sheilds\13997.1.aml CERTIFICATE OF SERVICE I, Ami J. Thumma, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Answer with New Matter was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: George Twardy, Jr., Esquire TWARDY AND ASSOCIATES, LLC 1026 Winter Street Suite 400 Philadelphia, PA 19107 MARTSON LAW OFFICES By IW( AMJU -.4 - Ami J. Th a 10 East High treet Carlisle, PA 17013 (717) 243-3341 Dated: August 12, 2010 TWARDY & ASSOCIATES, LLC BY: George Twardy, Jr., Esquire Identification No. 52883 1026 Winter Street Philadelphia, PA 19107 (877) 440-8182 IMF ??r u;Ijv 2? P 3: 4?I GUt??'66M*4?% r Plaintiff INTERNATIONAL PORTFOLIO, INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY v. SHARON G. SHIELDS a/k/a SHARON GRAY SHIELDS No. 10-4881 REPLY OF PLAINTIFF, INTERNATIONAL PORTFOLIO, INC. TO NEW MATTER OF DEFENDANT 10. Denied. As the averments contained in this contain conclusions of law, no response is required pursuant to the Pennsylvania Rules of Civil Procedure. Consequently, those averments are therefore deemed denied. WHEREFORE, Plaintiff, International Portfolio, Inc. demands judgment in its GEORGE TWARDY, JR., ESQUIRE Attorney for Plaintiff favor and against Defendant, together with costs and interest and whatever else the Court deems just and proper. TW DY & ASSOCIATES, LLC TWARDY & ASSOCIATES, LLC BY: George Twardy, Jr., Esquire Identification No. 1026 Winter Street Philadelphia, PA 19107 (215) 440-8722 INTERNATIONAL PORTFOLIO, INC Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY V. SHARON G. SHIELDS a/k/a SHARON GRAY SHIELDS No. 10-4881 CERTIFICATION OF SERVICE 1, George Twardy, Jr., Esquire, attorney for Plaintiff, International Portfolio, Inc. hereby certify that a true and correct copy of Plaintiff's Reply to New Matter of Defendant was served upon the below counsel via first-class mail, postage prepaid: Daniel K. Deardorff, Esquire Martson, Deardorff, Williams, Otto, Gilroy & Faller 10 East High Street Carlisle, PA 17013 aT ND A SSOCIATES, LLC WARDY, J IRE Attorney for Plaintiff ®avicCRD. Bug" Prothonotary Office of the Prothonotary Cum6erfancf County, annsyfvania 7(irkS. Sofionage, ESQ Solicitor 11)-4/881 CIVIL TERM ORDER OF TERMINATION OF COURT CASES 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 G CarCi Ce, TA 0 (Phone 717 240-6195 0 rFax 717 240-6573