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Home My WebLink About04-3414 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 0'1- '31{1 'f CI. i I Civil Action - ( X ) Law ( ) Equity SHERYL L. ABRAHAM 2309 S.w. 41" Street Cape Coral, FL 33914 versus LEONCIO W. RAMIREZ Jr. San Martin 3438 S.M.P., Lima Peru and THOMAS J. ABRAHAM 2309 S.w. 41" Street Cape Coral, FL 33914 JURY TRIAL DEMANDED Piaintiff(s) & Address(es) Defendant(s) & Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. X Writ of Summons shall be issued and forwarded to ( Howard B. Krug, Esquire PURCELL. KRUG & HALLER 1719 North Front Street Harrisburq, PA 17102 (717) 234-4178 Name I Address I Telephone No. of Attorney Su eme Court 10 No. 16826 Date '7/,"'(o'f WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: LEONCIO W. RAMIREZ YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED AN ACTION AGAINST YOU. f!oC~ .,f~ Date: 4 l'(:rJaJl( by ~/t~ ( ) c~'~ere if reverse is issued for additional information. Prothon. - 55 ~D "'" - ::s.\::..- . ~ --- \J1 (jJ ~. --0 GJ ~ -c:: -....'J --..s:> ~ '1 v. <:\ -~ ~ o I- ~" IJ r"~' (~ ,j ."," (.' i",-)- SHERYL L. ABRAHAM and THOMAS J. ABRAHAM, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3414 CIVIL vs. : CIVIL ACTION - LAW : JURY TRIAL DEMANDED LEONCIO W. RAMIREZ, Defendant PRAECIPE Kindly reissue the Writ of Summons filed on July 14, 2004 in the above- captioned matter. PURCELL, KRUG & HALLER owar 10 #1 2 1719 North Front Street Harrisburg, PA 17102 (717)234-4178 By Dated: ?- M,oj o ~ ~',;,~ "(".:Ie' ' en,' ",;"-''-,1 ~,-,; ;- ~;,'? S7: ~- ~ ",- (/) ~ N ..0 '?;.E:'i >,.~; -'~ =< "J:'iP' ::!{; ~ ::?.,., r11r: "0.. ~) -f.:) J.. (.~'? ='i:4~ ~B .!~. rrl () .'-\ J,s .-< Ct) .' w Howard B. Krug, Esquire - PA Atty. ID No. 16826 PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 Telephone: (717) 234-4178 emai1: hkrua@pkh.com SHERRY L. ABRAHAM and THOMAS L. ABRAHAM, plaintiffs/Movants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No, 04-3414 Civil LEONCIO W. RAMIREZ, Defendant/Respondent JURY TRIAL DEMANDED MOTION FOR SPECIAL SERVICE PURSUANT TO PA. R. C. p, 430 AND NOW, comes plaintiffs, Sherry L. and Thomas J. Abraham, by and through their attorneys, Purcell, Krug & Haller, and files the following Motion for Special Service: 1. Movant 1 is Sherry L. Abraham, Plaintiff in the above captioned action. 2. Movant 2 is Thomas J, Abraham, Plaintiff in the above captioned action. 3, Respondent is Leoncio W. Ramirez, Defendant in the above captioned action. 4. On July 25, 2002 Respondent rear-ended Movant's vehicle at the intersection of Hartzdale Drive and Old Gettysburg Road, and Respondent left the scene. 5. When Movant located Respondent, police were called and a police report was filed listing Respondent, a resident of Peru, as the driver of the rental vehicle involved in the accident, 6. Movant 1 was injured as a result of this accident. 7. On July 14, 2004, Movants filed a \~rit of Summons with the Court, 8, On July 14, 2004, a process server, Pedro Delgado Rodriguez, was hired to serve the Writ of Summons on Respondent in Peru. 9. After several attempts, Mr. Rodriguez learned that Respondent had not resided in Peru for greater than two years and was actually residing in New York City, See Affidavit of Pedro Delgado, attached hereto as Exhibit RAff. 10. On August 16, 2004, Mr. Rodriguez was contacted by Respondent via telephone. Respondent refused to provide his address in the united States and asked that Mr. Rodriguez leave a copy of the Writ with his relative in Peru for forwarding to Respondent, 11. A Choicepoint comprehensive national investigation was conducted. Addresses were listed for Respondent in New York City at 2341 93rd Street and 2641 93rd Street, East Elmhurst, New York. 12. On August 26. 2004 a New York process server, Douglas Allen, was engaged to serve the writ of Summons on Respondent at the Elmhurst addresses found, but service has not been effectuated. 13. The U.S. Department of State and the Department of Homeland Security were contacted to determine if they kept track of Peruvian aliens, and Homeland Security advised that they did not track such persons once they were in the Country. 14. The New York Department of Motor Vehicles was contacted to see if Respondent could be located; however, no response has been received in five (5) weeks. Respondent presented a Peruvian driver's license at the time of the accident, 15, On August 18, 2004 contact was made with the U.S. Immigration Department, which advised that unless Respondent signed a release or counsel for Movants also represented Respondent, no information could be provided. 16, Movants believe and aver that Respondent is aware of the law suit filed and is trying to avoid service of the Writ. See Affidavit of Pedro Delgado attached hereto as Exhibit "A", 17. The Affidavit of Plaintiffs' counsel setting forth the attempts to locate Respondent described above is attached hereto as Exhibit "B", 18. Plaintiffs' desire to serve Defendant by mailing to Defendant's Peruvian and New York addresses and by publishing the Notice attached hereto as Exhibit "C", 19. It is believed that Defendant is hiding his whereabouts. 20. The relief requested is authorized by Pa. R.C.P. 430. 21. The Writ of Summons was reinstated for an additional ninety (90) days on September 29, 2004. WHEREFORE, Plaintiffs respectfully requests this Honorable Court to enter an order permitting service of the Writ of Summons by publication and by regular mail addressed to Defendant's Peruvian and New York addresses. PURCELL, ::-:=-- . d B. Kr ,EsqUlre North Front Street Harrisburg, PA 17102 717 234-4178 Attorney for plaintiffs/Movants Date: /O-I't-CI-! 09/27/2004 19:42 4012946421 ACE INTL SERVICES PAGE 02 ll~~Jl1'e~\o nb ~i. .,CI, " ~ ....e e~ ,Sl< nr,;\' I \"'!'.,\i.K: ....-.......a....1 .-,....- SHERYl.:". ABRAtlAM Ind THOMAS J. ABfWWoI, Platntiffs ____."~. '1 : IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLV~IA "" ,NO. 04.3414 CIVil : CIVIL ACTION. LAW : JURV T~IAL OEMAND :,\-".r4d So(1. fib 1'...,1'G "'fl. c.nv. N. IOSO" .....nt.O Tell..: 2.&70." . 2.&701" LEONCIOW. RAMIREZ, MADAVIT OF RETURN OF NO 8eRVIC~ Service upon Defenclaflt. LeonciO W. Ramirez, of the Writ 01 summon. - attempted at Jr. San M8rt1n 3436 dittrid SI/I Marlin de POm!lS, Lima, Peru. SelVIee WIll not made for \he foIIQwing ....50n(.): 1, on Auguat 18, ~ at 011:40 houl1I. I had an irowrvl8W with Mr J()8(l Slmanez Ortiz: (LlOncio Ramir.Z:'1 uncia). Ha e"plaine<llNit Leonc;io Wilfredo Ramirez: VaIMqUeZ hBS been living In the United SlateS. IoAr Samanez c:larlllad Mr. Ramirez. hlgally residing in America foIlh1t Io$l IAllaral ~ra. He doet not live in Peru. Mr. Samanez accepted · er:/(1'/ of the eerII\cIe dQOUrTIentB indicllting he would gilte the documeolfl to MllQIllly Mecllllit. Mr. ~1'e%'1 sister 2. On August 115, 2004et 16:30 hourI, I contac:llld MegelyMedalit Ramirez Valllllquez. Mr. Ramirez'. 8lster via phOne (Peru Ph0n8No. !l38--1<44e) She indlc8ted ehe would c:ell her brother, Leonclo Remlrez, and Inform him that she h,1 the ..Nice doCUments. She aleo lltated th8t: .... wou1d give Mr. Reminrz: my ",pl\one number, 3. On August 18, 2004 lit 22:15 hours, I received a talephone catt from tne Unllad $tatM. ",. pereon identified him..lI.. Mr. Leoncio W. Remlre%. He eeid he is In New Yoril ClIy, but did not wllnt to give me his edel...,. in the USA or phon. n\lmber. He asked If I could give 1he do<;ument:to hll uncle. Mr. s.manez, and hill uncle could sign a document stating he would fOlW8rd ltIe doCJJmtnts to Mr. Leoncio W. RamiI'VZ:. [ understand that the stlltements herein .re made subject to 18 PII. C.S.A. 5 41104 relating to UMwom fMIi11catiOn to authoritill5 and ItIlI! criminal penalties are provided thereunder 101 fa_ ltaWmlllllS. Padro RODRIGUEZ D. .1.018.1825 I... . LEGALlZ1\C10N 1\ LA VLf,LTA - .N_.:...$.flA>DJ.!l)"A~W ....,... EXHIBIT I A 09/27/2004 19:42 4012945421 ACE INTL SER\iICES CJ:":Cl~~C.'O. ,;t', p, ,l~."IJ. ,;,,7 ,,;'p[.~<'l '.". ,.', ".N'.'!:"..> .' r~!;SL!"rt Ij,., ;, ,',.' :~("'i',ES~()"DE 1\ PIODMO A1\O:URO D~ N)Dll:tCJUr.1I ;.c"" n,,'.,',," (,,,,,. u.":.l, C"C";.6,S., .".....---". ",u~_.._.."n ~~F. 't':":,;'::':" I,P, f!?.t-t~ S:N ;,::;;';1-11."- !"SOG:',3P.~.:,;. ;:i\[) ~o61\! ~!.. :;:,,;0". .i:e 0E:' :.r..c\Jl..\r:t-!'l'0 n" C,:8 ,'0 R'Il J):'J: cc~,; 21 'X' '"11'.0 1'~3 riel ~, ... < ".,\,), ~___.___~...,,,-,,~~_.~-----,,,,,,.,,,,""L'" .,....,.. _,,_.._u_.~ PC: ,; ~:"'f".;l''';':.', n nF. ,lUIc:-:r'l<r \)~;, 1,[.,) ;;00.'."" ..,.,....____dL.,. /1 / /1 ( II Ii ' . /~ \ ~qfta e ,~ ~6GAC'" -- ,=--,,-' PAGE 03 03/27/2004' 13:4'2 4012346421 ACE INTL SERVICES PAGE 01 Aa! International Services, Inc. Fax Transmittal 11 0 Spring Street East Greenwich, RI 02818 TEL.: (401) 398-0954 E-MAil: info@acelnternationalservices.com Send to: Purcell, Krug . Haller from: Patricia Attention: Tricla Date: 9/21104 Office Location: Office Location: East GreenwICh, Rl Fax Number: (717) 234-0409 Fax Number: (401) 398-1087 Total pages, including (:Oller: 3 Re: Affidavit of Return of no service Dear: Tricia Here is the copy of the affidavit. Original should be here some lime this week, at which time I will get in the mail to you. The second page is in Spanish as I indicated today in our phone conversation. Regards Patricia IMPORTANT: Thl. message is in,ended fo< tho u.o 01 the Individual 0< entity to which it I. odd,o..od, and may contaJn Information that is privileged, connde:r\tlaJ and exempt from disclosure under ~pllcablt law. If ,he read or of ,hi' mes.agols no< ,he in,ended ,o<lplent or the emplOV"e or agent responslblo for delhiorlng - I - Howard B. Krug, Esquire PA Atty. 1D No. 16826 PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 Telephone: (717) 234-4178 email: hk~uG@pkh.com SHERRY L. ABRAHAM and THOMAS J. ABRAHAM, plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 04-3414 Civil LEONCIO W, RAMIREZ, Defendant JURY TRIAL DEMANDED AFFIDAVIT I, Howard B. Krug, Esquire, being duly sworn, state the following: 1, My name is Howard B. Krug and I represent plaintiffs in the above captioned matter. 2. On July 14, 2004, I filed a Writ of Surrnnons for the accident that occurred on July 25, 2002 in the above captioned action, utilizing the Peruvian address provided to police by Defendant at the time of the auto accident. 3. On July 14, 2004 my office contacted Christine Anderson, Director of Operations with ACE International Services, Inc. with regard to hiring a process server in Peru. 4. On that same date, her process server for Peru, Mr. Rodriguez, was engaged and ultimately forwarded an Affidavit of Return of No Service, providing information he received from Defendant's relatives at the address in Peru. (Said Affidavit is attached hereto as Exhibit "A".) 5. As a result of Mr. Rodriguez's information, we performed a debtor discovery and found that two addresses were listed for Defendant in New York City at 2341 93~ Street, and 2641 93~ Street, East Elmhurst, New York. EXHIBIT I~ 6. The U,S. Department of State and the Department of Homeland Security were contacted to determi~e if they had information regarding this Peruvian alien, and Homeland Security advised that they did not track such persons once they were in the Country. 7. The New York Department of Motor Vehicles was also contacted to see if Respondent could be located; however, no response has been received as of this date. S, On August lS, 2004, contact was made with the U.S. Immigration Department, which advised that unless Defendant signed a release or counsel for Plaintiffs also represented Defendant, no information could be provided. 9, On August 26, 2004, a New York process server, Douglas Allen, was engaged to serve the Writ of Sunwons on Defendant at the Elmhurst addresses found. [As of this date, service has not been effectuated.] H nd not 10, I firmly believe that Defendant is revealing his true whereabouts. l Sworn to and subscribed before me this f~ day of (jJtJopA ' 2004. ~ap~~l~ COMMONWEALTH OF PENNSYLVANIA Notarial Seal Angela S. Shaffer, Notary Public City Of HaIfisburg, Dauphin County My Commission Expires Jan. 12, 2008 Member, Pennsylvania Association Of Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLl\ND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 04-3414 Civil NOTICE SHERRY L. ABRAHAM & THOMAS J. ABRAHAM, Plaintiffs vs. LEONCIO W, RAMIREZ, Defendant TO: LEONCIO W, RAMIREZ YOU ARE HEREBY NOTIFIED that Plaintiffs, Sherry L. And Thomas J. Abraham, filed a Writ of summons, against you in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No. 04-3414 Civil, wherein plaintiffs seek monetary damages. NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend, you must enter a written appearance personally or by attorney and file your defenses or objections in writing with the court. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court withou1: further notice for the relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE 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, CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD ST, CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 EXHIBIT I_C CERTIFICATE OF SERVIC~ I, ANGELA S, SHAFFER, an employee for the law firm of purcell, Krug & Haller, counsel for Plaintiffs, hereby certify that service of the MOTION FOR SPECIAL SERVICE PURSUANT TO PA. R. C. P. 430 was made on the following via regular mail on October 18, 2004: Leoncio W. Ramirez Jr. San Martin 3438 S.M.P., Lima Peru Leoncio w. Ramirez 2341 93rd Street New York, NY 11366 and Leoncio W, Ramirez 2641 93rd Street New York, NY 11369 ~hMIA.J,~&-^ ~haffe C) 0) '" (~,:";) f: ::~ _t'- r~ C,;- (') -q --( -.,- Hi -.-; UJ () -' :i} ." :I IT") ~ Howard B. Krug, Esquire PA Atty. 1D No. 16826 PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 Telephone: (717) 234-4178 email: hk~uG@Dkh.com SHERRY L. ABRAHAM and THOMAS L, ABRAHAM, Plaintiffs/Movants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 04-34:~4 Civil LEONCIO W. RAMIREZ, Defendant/Respondent JURY TRIAL DEMANDED ORDER AND NOW, upon consideration of Plaintiffs' Motion for Special Service pursuant to Pa,R.C,P. 430, Plaintiffs' Motion is GRANTED. Plaintiffs shall serve Defendant by publication and mailing by regular mail addressed to Defendant's Peruvian and New York addresses. Service shall be deemed complete upon publication of the Notice attached as Exhibit "C" to Plaintiffs' Motion once in the Cumberland Law Journal and once in The Sentinel and by regular mail to each of the following addresses: 1. Jr San Martin 3438 SMD Lima, Peru 2. 2341 93rd Street East Elmhurst, NY 11366 3, 2641 93rd Street East Elmhurst, NY 11366 ~~~ L.::1' 'C~ ()\ .O~ 10' {\.U BY THE COURT: tJekb<<- .2' 2""'Y , ~(u, r1i / J. S'1 :0\ s:~ DO ~ln Ii", Howard B. Krug, Esquire 10 No. 16826 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 SHERYL L. ABRAHAM and THOMAS J. ABRAHAM, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3414 CIVIL vs. LEONCIO W. RAMIREZ, Defendant : CIVIL ACTION.. LAW : JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE BY PUBLICATION I, Howard B. Krug, Esquire, counsel for Plaintiffs, Sheryl L. Abraham and Thomas J. Abraham, hereby certify that pursuant to the Honorable Kevin A. Hess' Order dated October 26, 2004, Defendant, Leoncio W. Ramirez, was served by publication in The Sentinel on November 3,2004, by publication in The Cumberland Law Journal on November 12, 2004, and by regular mail to the Defendant's Peruvian and New York addresses on November 2,2004. The Proof of Publication of the notice of action required by Pa. RC.P. 430 for The Sentinel is a1tached hereto as Exhibit "A" and for The Cumberland Law Journal is attached hereto as Exhibit "B". The U.S. Postal Service Certificates of Mailing are attached hereto as Exhiibit "C". PURCELL'KRU~R /0-- By: ~ \-- "--- H B. Krug, Esquire I.D. O. 16826 1719 North Front Street Harrisburg, PA 1?1 02 (717) 234-4178 Attorney for Plaintiffs Dated: oil P;II>~ PROOF OF PUBLICATI'ON State of Pennsylvania, County of Cumberland Tammy Shoemaker, Classified Sales Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following date(s) November 03, 2004 COPY OF NOTICE OF PUBLICATION WMOIt_ NO"RCE 1 1ttTHE-~~""EAS QIlCU_~~,PIlNN8'LY~, . CIViL:~ -~w' " " j ,. ..,......Clvll , ~. . J'IIOTJCE >, === L OAAHAM. THOMAS". ABRAttA". ft. i. ....ClCJw. FtAIMIZ ~ 1:0.;J4~1Q ".,.1JJtI8Z ~~~.' 'NQTIfJE!)...,~.,' ',$hfirry L, " """',....",4I!~.~.aWritofSummons. . ~~in_~o'OoinmonPleaaof . ' ~ County, Pennaytvanla, dockelld toNe. _~. whel'8ln PIlIntlff8I88\( m~netarv '. "Mts&:rl"'_~8IGItD YOOlfAWBftN'!OED'IH'COURT. If you WiII'I to defend, you ritu8t enter a wrlllen appearance pttI1IOI'IaJIy 'or by .atfDrnJy and file YOllr defBnl!81 or .~ In wrItIngwlth the court. You are warl)8C;t that If you fa" ......CMemay proce8d without you anct.......... "".,erwa.red.,.lnst you wlthoutfurther /lOb'. tile relief requesled by the Plaintiffs. You may 1018 money or property or other rights Import to you. . YOU SHOU\...IUAI.CEJ:.PAPER:rO YOUR LAWYe$ ATlMCE:'nr, VOtJ DONOT HAVE A LAWYER OR ' CANNOI' , "OQNE, GO TO OR TEL~E , THE OFF Sltt FOJmi BELOW. TfI1$ oPF=ICE _ CAN P , YOU~TH INF<>m4ATfON ~UT HIRFlINGA' W't:t~. IF YOU CAN NOTAFf"OPfD TO HI E~ 'a.' fl'f,lQE'M~YBEA8LE'To, P~IDE '( "ORWrATluNABOUT, I AGlNCIEat A't MA OFFER LEGAL SERVlC~S TO EUGIU PeRSONS AT A REDUCED Fee OR NO FEE. , . , CUMBERlAND COUNTY BAR ASSOCIATION 32 S. BEDFORD ST. , CARLI8U, PA 17013 (717) 249-3166 (800) 990-9106 Affiant further deposes that he/ she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place imd character of PUbliCationareW~ ) Sworn to and subscribed before me this 03rdday of November, 2004 C)U"dJ.ia.J My commission expires: q) /~t COMMONWEALTH OF PENNSYLVANIA Notarial Seal Christina L. Wolfe, Notary Public Cartisle Boro, CtnlberIand County My Commission Expires Sept 1, 2008 '\Ilell'''er P"nnsylvania Association Of Notaries EXHIBIT I A PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the officia11egal periodical for the publication of aU legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz NOVEMBER 12, 2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true:. ,.. S RN TO AND SUBSCRIBED before me this 12 day of NOVEMBER. 2004 NOTARI L SEAL LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Er.pires March 5, 2005 d.l~)~~ EXHIBIT I ~, CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law No. 04-3414 Civil SHERRY L. ABRAHAM & TIlOMAS J. ABRAHAM, Plaintiffs vs. LEONCIO W. RAMIREZ, Defendant NOTICE TO: LEONCIO W. RAMIREZ YOU ARE HEREBY NOTIFIED that Plaintiffs, Sherry L. and Thomas J. Abraham. filed a Writ of Summons, against you in the Court of Com- mon Pleas of Cumberland County, Pennsylvania, docketed to No. 04- 3414 Civil, wherein Plaintiffs seek monetary damages. NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend, you must enter a written appearance personally or by attomey and file your defenses or objections in writ- ing with the court. You are warned that if you fail to do so the case may proceed without you and ajudgment may be entered against you by the Court without further notice for the relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PA- PER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET FORTIl BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA- TION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER. TIllS OFFICE MAY BE ABLE TO PROVIDE YOU WITIl IN- FORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERV- ICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Nov. 12 2 EXHIBIT I 132. Re: Sherry L. Abraham and Thomas J. Abraham v. Leoncio W. Ramirez No. 04-3414 Civil NOTICE U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3811) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Leoncio W. Ramirez 2341 93rd Street East Elmhurst, NY 11366 Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Leoncio W. Ramirez 2641 93rd Street East Elmhurst, NY 11366 Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Leoncio W. Ramirez 3605 Northern Boulevard EXHIBIT Astoria, NY 11101 l i ~I Re: Sherry L. Abraham and Thomas J. Abraham v. Leoncio W. Ramirez No. 04-3414 Civil NOTICE U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service IForm 3817) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Leoncio W. Ramirez Jr San Martin 3438 SMD Lima, Peru Postmark: Qz ~t--f,f!3 po~ II i~)~.::=:;_ . :;;;;;ar.-............. . ~........... PIfNfV BOWES . -.,' 02 1A $ 00.900 . . 0004338187 NOV 02 201d~ MAILED FROM ZIP CODE t:!' ~I ..-."/'" ~~~' Db'oSS\'O'<> EXHIBIT I s ,,,-' c:.:;) () 1',:::-' .1 ...i...'- ),- -,- ::;:j ,...t)o".. C''') r;ifll "or;: rTl (-J W I' '..' I , -';) ) ~fl ... 1 ,""r'! .J,,:' , 1'.) (.,) , ..'J ... ,. ~"'''''~ SHERYL L. ABRAHAM and THOMAS J. ABRAHAM, Plaintiffs IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA vs. NO. 04-3414 CIVIL LEONCIO W. RAMIREZ, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE Please mark the above captioned matter settled, satisfied and discontinued with prejudice. BY: B I o. 6826 71 9 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney for Plaintiffs Date: May 25, 2005 _~J_ -.,..' -