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Home My WebLink About10-7802IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JANICE ETSHIED 54 Westerly Road Camp Hill, PA 17011, Plaintiff(s) Address(es) = . r C\j U_ "rk ?. ter, o zr q 2 v3 V 1 acz LA - cz) W;2: cx? W a cl- RASHA EL-NAGGAR 3102 Hoffer Street Harrisburg, PA 17103, -and- : TERRICK ELT 3421 Simpson Ferry Road Camp Hill, PA 17011 -and- JUSTIN CHENG 2125 West Cumberland Street Lebanon, PA 17042 -and- : KUAN FANG CHENG 2125 West Cumberland Street Lebanon, PA 17042 -and- : CHENG CHIN YUNG LO 2125 West Cumberland Street Lebanon, PA 17042 -and- : HAMPDEN DINER, LLC 3421 Simpson Ferry Road Camp Hill, PA 17011, -and- : HAMPDEN DINER 3421 Simpson Ferry Road Camp Hill, PA 17011, Defendant(s) Address(es) JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS C?rtr slr?3? L )-r 456931-1 TO THE PROTHONOTARY: Kindly issue a Writ of Summons against Defendants Rasha El-Naggar, Terrick Elt, Justin Cheng, Kuan Fang Cheng, Cheng Chih Yung Lo, Hampden Diner, LLC, and Hampden Diner. The Writ of Summons should be delivered to the Sheriff of Cumberland County for service upon the Defendants at the addresses listed above. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Date:,,, 2010 By ,r--- _ Clark DeVere, Esquire I.D. No. 68768 Andrew W. Norfleet, Esquire I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff 456931-1 METZGER, WICKERSHAM, P.C. By: Clark DeVere, Esquire Attorney I.D. No. 68768 Andrew W. Norfleet, Esquire Attorney I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 JANICE ETSHIED, Plaintiff Attorneys for Plaintiff Janice Etshied IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KASHA EL-NAGGAR, TERRICK ELT, JUSTIN CHENG, KUAN FANG CHENG, NO: k) - -7 a- CHENG CHIH YUNG LO, ; HAMPDEN DINER, LLC, and HAMPDEN DINER, Defendants JURY TRIAL DEMANDED WRIT OF SUMMONS TO: Rasha El-Naggar 3102 Hoffer Street Harrisburg, PA 17103 Terrick Elt 3421 Simpson Ferry Road Camp Hill, PA 17011 Justin Cheng 2125 West Cumberland Street Lebanon, PA 17042 Kuan Fang Cheng 2125 West Cumberland Street Lebanon, PA 17042 Cheng Chih Yung Lo 2125 West Cumberland Street Lebanon, PA 17042 zW'/ / 456931-1 Hampden Diner, LLC 3421 Simpson Ferry Road Camp Hill, PA 17011 Hampden Diner 3421 Simpson Ferry Road Camp Hill, PA 17011 You are hereby notified that the Plaintiff Janice Etshied has commenced an action against you. Dated: ? ? 456931-1 • i METZGER, WICKERSHAM, P.C. By: Clark DeVere, Esquire Attorney I.D. No. 68768 Zach D. Campbell, Esquire Attorney I.D. No. 97133 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 JANICE ETSHIED, FILED-O F-ICE E' 1 J 19 PPS 12: Attorneys for Plaintiff Janice Etshied IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v RASHA EL-NAGGAR, TERRICK ELT, JUSTIN CHENG, KUAN FANG CHENG, CHENG CHIH YUNG LO, HAMPDEN DINER, LLC, and HAMPDEN DINER, Defendants CIVIL ACTION - LAW NO: 2010-CV-7802 JURY TRIAL DEMANDED PRAECIPE TO REISSUE WRIT OF SUMMONS TO THE PROTHONOTARY: Please reissue the Writ of Summons that was issued in the above-captioned action on December 20, 2010 which is attached hereto. e9 460041-1 /000 pl.a14 -t #%4 SG bS? ,eN aS35?2o t METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Z;;; Clar ceVere, Esquire I.D. No. 68768 Zachary D. Campbell, Esquire I.D. No. 97133 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Date: January 19, 2011 Attorneys for Plaintiff 460041-1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor FILED-OFF1CE Ci THE PPC T HuE4CTARY 2011 JAN 24 PIM 1111: 17 rM.IMBERLAND CC-UNI 'Y PE;? NSYLVAI'4Ix Janice Etshied vs. Terrick Elt (et al.) Case Number 2010-7802 SHERIFF'S RETURN OF SERVICE 12/27/2010 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: Rasha El-Naggar, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Writ of Summons according to law. 12/27/2010 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: Justin Cheng, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Lebanon County, Pennsylvania to serve the within Writ of Summons according to law. 12/27/2010 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: Kuan Fang Cheng, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Lebanon County, Pennsylvania to serve the within Writ of Summons according to law. 12/27/2010 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: Cheng Chih Young Lo, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Lebanon County, Pennsylvania to serve the within Writ of Summons according to law. 01/05/2011 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: Terrick Elt, but was unable to locate him in his bailiwick. He therefore returns the within Writ of Summons as not found as to the defendant Terrick Elt. Request for service at 3421 Simpson Ferry Road, Camp Hill, Pennsylvania 17011 the defendant was not found. This location is the previous address for The Hampden Diner which is no longer in business. However, The Camp Hill Postmaster is still delivering Terrick Elt's mail to 3421 Simpson Ferry Road, Camp Hill, Pennsylvania 17011. 01/05/2011 Dauphin County Return: And now, December 30, 2010 I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Rasha El-Naggar the defendant named in the within Writ of Summons and that I am unable to find him in the County of Dauphin and therefore return same NOT FOUND. Request for service at 3102 Hoffer Street, Harrisburg, Pennsylvania 17103 is currently vacant and for sale. 01/05/2011 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: Hampden Diner, but was unable to locate them in his bailiwick. He therefore returns the within Writ of Summons as not found as to the defendant Hampden Diner. Request for service at 3421 Simpson Ferry Road, Camp Hill, Pennsylvania 17011 the defendant was not found. This location is the previous address for The Hampden Diner which is no longer in business. 01/05/2011 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: Hampden Diner, LLC, but was unable to locate them in his bailiwick. He therefore returns the within Writ of Summons as not found as to the defendant Hampden Diner, LLC. Request for service at 3421 Simpson Ferry Road, Camp Hill, Pennsylvania 17011 the defendant was not found. This location is the previous address for The Hampden Diner which is no longer in business. r, Coi.vtty5uile She. "M 7e':ecsoft. 1..-, 01/07/2011 02:03 PM - Lebanon County Return: And now January 7, 2011 at 1403 hours I, Michael J. DeLeo, Sheriff of Lebanon County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Justin Cheng by making known unto himself .0 personally, at The Lebanon County Sheriffs Office, 400 S. Eighth Street, Lebanon, Pennsylvania 17042 it,, contents and at the same time handing to him personally the said true and correct copy of the same. 01/07/2011 Lebanon County Return: And now, January 7, 2011 I, Michael J. DeLeo, Sheriff of Lebanon County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Cheng Chih Yung Li the defendant named in the within Writ of Summons and that I am unable to find him in the County of Lebanon and therefore return same NOT FOUND. 01/07/2011 02:03 PM - Lebanon County Return: And now January 7, 2011 at 1403 hours I, Michael J. DeLeo, Sheriff of Lebanon County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Kuan Fang Cheng by making known unto himself ? personally, at The Lebanon County Sheriffs Office, 400 S. Eighth Street, Lebanon, Pennsylvania 17042 it,, contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $163.00 January 21, 2011 SO ANSWERS, &Z' RON R ANDERSON, SHERIFF (c; COWI'yS:nte Sheriff. Tekrasait. Inr, WRIT OF SUMMONS NO. 10-7802 Metzger & Wickersham, P.C. Clark DeVere, Esquire JANICE ETSHIED P.O. 13ox 5300 3211 North Front Street Harrisburg, PA 17110 vs. (717) 238-8187 JUSTIN CHENG and KUAN FANG CHENG and Docket Page 33643 CHENG CHIH YUNG LO STATE OF PENNSYLVANIA) COUNTY OF LEBANON } SS: JOHN SINGLETARY, Deputy Sheriff, being duly sworn according to law, deposes and says that he served the within WRIT OF SUMMONS upon, JUSTIN CHENG, KUAN FANG CHENG, AND CHENG CHIH YUNG LO, the within named DEFENDANTS, as follows: Upon JUSTIN CHENG the within named DEFENDANT, by handing a true and attested copy thereof, personally to the defendant on January 7, 2011 at 2:03 P.M., in the Lebanon County Sheriff's Office located at 400 South Eighth Street, Lebanon (Lebanon City), Lebanon County, Pennsylvania, and by making known to the defendant the contents of the same. Upon KUAN FANG CHENG the within named DEFENDANT, by handing a true and attested copy thereof, personally to the defendant on January 7, 2011 at 11:35 A.M., in the Lebanon County Sheriff's Office located at 400 South Eighth Street, Lebanon (Lebanon City), Lebanon County, Pennsylvania, and by making known to the defendant the, contents of the same. JOHN SINGLETARY, Deputy Sheriff, being duly sworn according to law, deposes and says that after due and diligent search by him having been made in his bailiwick, and after having exhausted all known facets to locate DEFENDANT, as stipulated under Rule of Civil Procedure, Rule 430, "good faith effort," he was unable to find CHENG CHIH YUNG LO, the within named DEFENDANT, and he therefore returns "NOT FOUND," as to the said CHENG CHIH YUNG LO. Sworn to and subscribed before me SO ANSWERS, This 13T" day of JANUARY, 2011 r Notary Public DEPUTY SHERIFF By Authorization Of: NOTARIAL SEAL Lynnette Smith, Notary Public Lebanon City, Lebanon County My Commission Expires April 23, 2012 Is SHERIFF Page 1 of 2 (Ptfirlt af the Sherif r -t William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin JANICE ETSHIED VS RASHA EL-NAGGAR Sheriff s Return No. 2010-T-3794 OTHER COUNTY NO. 20107802 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 RASHA EL-NAGGAR 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, DECEMBER 30, 2010. AS PER DEPUTY HOUSE IS VACANT AND THERE IS A FOR SALE SIGN OUT FRONT Sworn and subscribed to before me this 3RD day of January, 2011 -)P?4z COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17, 2014 So Answers, 1?,?? Sheriff of Dauphin County, Pa. By Deputy Sheri Deputy: DARIN S S ERFEY Sheriffs Costs: $41.25 12/30/2010 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor atrrrt,??f?tf 0011" Q1 a a tmiJ { , t. Janice Etshied vs. Terrick Elt (et al.) Case Number 2010-7802 SHERIFF'S RETURN OF SERVICE 02/22/2011 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: Cheng Chih Yung Lo a/k/a Wendy Lo, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Lehigh County, Pennsylvania to serve the within Writ of Summons according to law. 03/08/2011 11:28 AM - Lehigh County Return: And now March 8, 2011 at 1128 hours I, Ronald W. Rossi, Sheriff of Lehigh County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Cheng Chih Yung Lo a/k/a Wendy Lo by making known unto Cindy Lo, Daughter of Defendant at 1030 Jervin Drive, Allentown, Pennsylvania 18104 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 March 11, 2011 SO ANSWERS, 6 Z RON R ANDERSON, SHERIFF Ci COUltty JUIIP..,h r t TE toft. to?f.. l"• !"' i {_tE_jt ",-J ? - si TH '' HAMILTON HAMILTON I ttFj:..' j':. ,3l ._: f: VC3, 0 2! N, 16 14 RASH A Ei_ - N G 3 ET A!.._ WRIT e SUMMONS IN CIVIL E1. SERVE: CHENC CHIN 't'UNIG AKA WENDY LO AT : 1030 JE E4:!? :l: N ?.}E_ ALi....ENT3=}t•1t' , PA ATTNY! 000 000 0000 RETURN! OF SERVICE (PURSUANT TO PARCP 405) NAME OF INDIVIDUAL S E R V Erf n !. N 0 LO __......._........._...._._.__._....._.....• -'-.__........._._....._..........._..._ ................_.__.......... _.._..................__....__..._._.. '• 2. RELATIONSHIP O DE.F'l=:P.IL;AN a ....... p..._........._...aU..._.... ...... _..._.__ ......................... ....... ............. ................. ..... ._...... ...... ?Nt??.!? e/1 __._...... ...??w..__._.............. ._.............. -'Fn I_C:it.:A1".1:3::i!`:1 [ti= l:E:Rw?.i:i_;I::::rt to ° Tt.V .N_ .............!?..... L:?.... I r -To LOCATE-. UNAKI ;f {•.d!.1MBE:=r OF ATTEMPTS TO LOCATE-: DEFE=t•'' I==t='N ' AT _...AST KNOWN ADDRESS: D._. _,..:... TIME Ll 11 1243 L3 ir-? - ,..1 _ ?. _? ....._....__.?. _. y TIME S. DATE L 5. DATE 1 ACCEPTANCE OF SERVICE: i=li'? l°??E: FRONT OF 'F'E_IE W I HEREBY ACCEPT SERVICE OF THE LEGAL PROCESS i"-EE: OUTLINED _i. E :.. , . ..._ . Ar'1 _ 1EA DOCUMENT. H SERVICE IS ACCEPTED ON BEHALF OF F i !(:... F. c: ?' D Di '1 'f E I HEREBY CERTIFY .1_I-AT I AM AUTHORIZED TO DO SO. Lo __ _ :I7 PAINTED NAME. : F AUTHORIZED AGENT S]:rNATE.IRE F - 1_} (- DEPUTY SHERIFF ? NAME PRINT S O ANSWERS ) ?Tff SHE FF SHERIFF* --4 • METZGER, WICKERSHAM, P.C. By: Clark DeVere, Esquire Attorney I.D. No. 68768 Zach D. Campbell, Esquire Attorney I.D. No. 97133 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 JANICE ETSHIED, Plaintiff v RASHA EL-NAGGAR, TERRICK ELT, JUSTIN CHENG, KUAN FANG CHENG, CHENG CHIH YUNG LO, HAMPDEN DINER, LLC, and HAMPDEN DINER, Defendants -?°??0-OEi:lCE .,._..i.H ROTHONOTAR'i 2011 JUL 13 PN 1? 41 Cs PENNSYLVICOUNTY Attorneys for Plaintiff Janice Etshied IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO: 2010-CV-7802 JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above captioned matter settled, discontinued and ended. Date: 7//aV // METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By c Clark DeVere, Esquire I.D. No. 68768 Zachary D. Campbell, Esquire I.D. No. 97133 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff 472753-1 CERTIFICATE OF SERVICE I, Clark DeVere, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and correct copy of a Praecipe to Settle, Discontinue and End with reference to the foregoing action by first class mail, postage prepaid, this Ja '4' day of July, 2011 on the following: Rasha El-Naggar 4220 Heathrow Court Apartment B Harrisburg, PA 17109 Temck Elt 117 Prince Street Harrisburg, PA 17109 Justin Cheng C/o George E. Christianson, Esquire 411 Chestnut Street Lebanon, PA 17042 Kuan Fang Cheng 2125 West Cumberland Street Lebanon, PA 17042 Cheng Chili Yung Lo 1030 Jervin Drive Allentown, PA 18104 Hampden Dinner, LLC c/o Christopher M. Reeser, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 472753-1 ,4 Hampden Dinner c/o Christopher M. Reeser, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. "?Y? ark De ere, Esquire 472753- l