HomeMy WebLinkAbout11-1577IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Plaintiff(s) & Address(es) ,
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PejAQ" 1 <-5 b , Pic PRA CIPE OR WRIT OF SUMMONS V f .. 0 D ?
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TO THE PROTHONOTARY/CLERK OF SAID COURT: sy I &, 7
Issue summons in the above case
Writ of Summons shall be issued and forwarded to Attorne /S if . Please •rc choice
Date Signature o Attorney/
Print Name: - ; < L, o Co `j c°? Sy
Address: S i
Telephone Y33 - 3-5 --j
Supreme Court ID Number: c>?- y ?- L/ 2
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TO: 574T6 D6n 70tPRt5E5 fnc
YOU ARE NOTIFIED THAT THE Al
ACTION AGAINST YOU.
Date: 6&? /Q .2o/l
• • • • • bUMMN /
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MED PLAINTIFF(S) HASIHAVE COMMENCED AN
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Prothonotary/Clerk, Civil Division
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Timothy J Orlando
vs.
Amicus Associates, Inc. (et al.)
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70111 FEB 16 AM 10: 09
!', UMBERLAND ",bU
Case Number
2011-1577
SHERIFF'S RETURN OF SERVICE
02/11/2011 04:20 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February
11, 2011 at 1620 hours, he served a true copy of the within Writ of Summons, upon the within named
defendant, to wit: Todd W. Hoynitski t/a Harrisburg Auto Auction, by making known unto John R.
Congdon, Owner of Harrisburg Auto Auction at 1100 S. York Street, Mechanicsburg, Cumberland County,
Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct
copy of the same.
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TI BLACK, DEPUTY
02/11/2011 04:20 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February
11, 2011 at 1620 hours, he served a true copy of the within Writ of Summons, upon the within named
defendant, to wit: Amicus Associates, Inc. t/a Harrisburg Auto Auction, by making known unto John R.
Congdon, Owner of Harrisburg Auto Auction at 1100 S. York Street, Mechanicsburg, Cumberland County,
Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct
copy of the same.
TI BLACK, DEPUTY
02/11/2011 04:20 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February
11, 2011 at 1620 hours, he served a true copy of the within Writ of Summons, upon the within named
defendant, to wit: Statod Enterprises, Inc., by making known unto John R. Congdon, Owner of Statod
Enterprises, Inc. at 1100 S. York Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its
contents and at the same time handing to him personally the said true and correct copy of the same.
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TI K, DEPUTY
02/11/2011 04:20 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February
11, 2011 at 1620 hours, he served a true copy of the within Writ of Summons, upon the within named
defendant, to wit: Harrisburg Auto Auction, by making known unto John R. Congdon, Owner of Harrisburg
Auto Auction at 1100 S. York Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its
contents and at the same time handing to him personally the said true and correct copy of the same.
TIM , DEPUTY
V
02/11/2011 04:20 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February
11, 2011 at 1620 hours, he served a true copy of the within Writ of Summons, upon the within named
defendant, to wit: John R. Congdon t/a Harrisburg Auto Auction, by making known unto John R. Congdon,
Owner of Harrisburg Auto Auction at 1100 S. York Street, Mechanicsburg, Cumberland County,
Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct
copy of the same.
TIM B C , DEPUTY
SHERIFF COST: $101.44
February 14, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
jcj C011"VStMe Sh2:'..ff. Te:
FINEMAN KREKSTEIN & HARRIS, P.C.
By: JASON T. LaROCCO, ESQUIRE
IDENTIFICATION NO. 87523
Mellon Bank Center
1735 Market Street, Suite 600
Philadelphia, PA 19103
215-893-9300
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Attorney for Defendants
TIMOTHY J. ORLANDO
Plaintiff
V.
STATOD ENTERPRISES, INC., HARRISBURG
AUTO AUCTION, AMICUS ASSOCIATES, INC.
t/a HARRISBURG AUTO AUCTION, TODD W.
HOYNITSKI t/a HARRISBURG AUTO AUCTION
and JOHN R. CONGDON t/a HARRISBURG
AUTO AUCTION, jointly and severally
Defendants
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION
NO. 11-1577
JURY TRIAL DEMANDED
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of the Defendants in the above-captioned matter.
JURY TRIAL DEMAND
TO THE PROTHONOTARY:
Demand is hereby made for a jury of twelve (12) people in the above-captioned matter.
FINEMAN KREKSTEIN & HARRIS, P.C.
BY: 9?? r- n &
JA ON T. LaROCCO
March 10, 2011
Attorney for Defendants
;00406558;v1}
FINEMAN KREKSTEIN & HARRIS, P.C.
By: JASON T. LaROCCO, ESQUIRE
IDENTIFICATION NO. 87523
Mellon Bank Center
1735 Market Street, Suite 600
Philadelphia, PA 19103
215-893-9300
T(
L. Po, ,ti 14 P. r, -
Bn?S r^r,, r -
Attorney for Defendants
TIMOTHY J. ORLANDO
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff
V.
STATOD ENTERPRISES, INC., HARRISBURG
AUTO AUCTION, AMICUS ASSOCIATES, INC.
t/a HARRISBURG AUTO AUCTION, TODD W.
HOYNITSKI t/a HARRISBURG AUTO AUCTION
and JOHN R. CONGDON t/a HARRISBURG
AUTO AUCTION, jointly and severally
CIVIL ACTION
NO. 11-1577
Defendants
JURY TRIAL DEMANDED
PRAECIPE TO FILE COMPLAINT
TO THE PROTHONOTARY:
Please enter a Rule upon Plaintiff to file a Complaint within twenty (20) days hereof or
suffer the entry of a Judgment of Non Pros.
FINEMAN KREKSTEIN & HARRIS, P.C.
BY: C"Pzco -3. 01a Nct o
J "ON T. LaROCCO
March 10, 2011 Attorney for Defendants
RULE TO FILE COMPLAINT
AND NOW, this /y day of JJA r y , 2011, a Rule is hereby granted
upon Plaintiff to file a Complaint herein within twenty (20) days after service hereof or suffer the
entry of a Judgment of Non Pros.
Prothonotary
100406562;vl}
~ ..~ 1
TIMOTHY J. ORLANDO, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLANIA
v. CIVIL ACTION -LAW
STATOD ENTERPRISES, INC.,
HARRISBURG AUTO
AUCTION, AMICUS
ASSOCIATES, INC., t/a
HARRISBURG AUTO
AUCTION, TODD W.
HOYNITSKI t/a HARRISBURG
AUTO ACTION and JOHN R.
CONGDON tla HARRISBURG
AUTO AUCTION, jointly and
severally,
Defendants NO. 11-1577 CIVIL TERM
IN RE• DEFENDANTS' MOTION TO COMPEL PLAINTIFF'S
RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS
ORDER OF COURT
AND NOW, this 27~' day of August, 2012, upon consideration of Defendants'
Motion To Compel Plaintiff s Responses to Request for Production of Documents, a R
is hereby issued upon Plaintiff to show cause why the relief requested should not
granted.
RULE RETURNABLE within 10 days of service.
BY THE COURT,
Leighton Cohen, Esq.
465 Linden Street
Allentown, PA 18102
Attorney for Plaintiff
Christyle .Peck, J.
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/ Jason T. LaRocco, Esq.
Evan R. Bachove, Esq.
BNY Mellon Center
1735 Market Street
Suite 600
Philadelphia, PA 19103
Attorneys for Defendants
~~
TIMOTHY J. ORLANDO, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLANIA
v, CIVIL ACTION -LAW
STATOD ENTERPRISES, INC.,
HARRISBURG AUTO
AUCTION, AMICUS
ASSOCIATES, INC., t/a
HARRISBURG AUTO
AUCTION, TODD W.
HOYNITSKI t/a HARRISBURG
AUTO ACTION and JOHN R.
CONGDON t/a HARRISBURG
AUTO AUCTION, jointly and
severally,
Defendants .
NO. 11-1577 CIVIL TERM
IN RE• DEFENDANTS' MOTION FOR ISSUANCE OF A
COMMISSION TO OBTAIN OUT-OF-STATE DEPOSITIONS
ORDER OF COURT
AND NOW, this 27`~ day of August, 2012, upon consideration of
Motion for Issuance of a Commission To Obtain Out-of--State Depositions, a Rule
hereby issued upon Plaintiff to show cause why the relief requested should not
granted.
RULE RETURNABLE within 10 days of service.
BY THE COURT,
s~Leighton Cohen, Esq.
465 Linden Street
Allentown, PA 18102
Attorney for Plaintiff
Christylee .Peck, J.
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~ Jason T. LaRocco, Esq.
Evan R. Bachove, Esq.
BNY Mellon Center
1735 Market Street
Suite 600
Philadelphia, PA 19103
Attorneys for Defendants
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Timothy J. Orlando
Plaintiff
: No. 11 -1577
VS
CIVIL TERM
Statod Enterprises, Inc. et al. �. .
Defendant
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RULE 1312 -1 The Petition for Appointment of Arbitrators shall be substantially in It
cn•
following form: T.
THE PETITION FOR APPOINTMENT OF ARBITRATORS >c-3
TO THE HONORABLE, THE JUDGES OF SAID COURT: `f
f �
I, Jason T. LaRocco , counsel for the pIai-nt-iff-idefendant in the above
action (or actions), respectfully represents that:
1. The above - captioned action (or actions) is (axe) at issue.
2. The claim of plaintiff in the action is $ not in excess of $50,000.00
The counterclaim of the defendant in the action is not applicable.
a:•
0
The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit
as arbitrators:
Jason T. LaRocco, Esquire and Leighton Cohen, Esquire
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to
whom the case shall be submitted.
Respectfully submitted,
ORDER OF COURT
AND NOW, , 20 , in consideration of the foregoing
petition, Esq., and
Esq., and Esq., are appointed arbitrators in the above
captioned action (or actions) as prayed for.
By the Court,
KEVIN A. HESS, P.J.
4a8 .to Pty ATN/
&MSS.
01a771
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Timothy J. Orlando
Plaintiff
No. 11-1577
VS
CIVIL TERM
(ee
Statod Enterprises, Inc. et al. (- r
p Q .
Defendant u.a s- �-
7" M Sx,. l..71- -
RULE 1312 -1 The Petition for Appointment of Arbitrators shall be substantially inn [r• r
following form: . t-
�> o
C C,?
THE PETITION FOR APPOINTMENT OF ARBITRATORS >c--)
TO THE HONORABLE, THE JUDGES OF SAID COURT: - i
I, Jason T. LaRocco �' cn •
counsel for the plaintiff /defendant in the above
action (or actions), respectfully represents that:
1. The above- captioned action (or actions) is (-ar -e) at issue.
2. The claim of plaintiff in the action is $ not in excess of $50,000.00
The counterclaim of the defendant in the action is not applicable.
The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit
as arbitrators:
Jason T. LaRocco, Esquire and Leighton Cohen, Esquire
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to
whom the case shall be submitted.
Respectfully submitted,
1
ORDER OF COURT
AND NOW, 91'1,4 iGi✓/1, ,C ZA , 20 /Y , in c sideration of the foregoing
petition, ��.���� Imo j �� Esq., and
i . Veteaad
Esq., and )etl-C-d-e Esq., are appointed arbitrators in the above
captioned action or actions) as prayed for.
By the Court,
N
ACV
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_I cn 1 i 1,mo 4 %trtkseii • KEVIN A. H • : , P.J.
CCferfSo �4 PQ A7T`�
C3 li� ; es MO- *id 34A//2../ G 1o988S
~ • �� e, 1977i
In The Court of Common Pleas of Cumberland
Plaintiff
S�/Tyy r e�T ,V,,— G County, Pennsylvania No.
d Defendant Civil Action—Law.
Oath
We do solemnly swear (or affirm)that we will support, obey and defend the Constitution of the United
States and the Constitution of this Commonwealth and that we will discharge the duties of our office
with fidelity.
Signature S iQnaturz
Si-nature
Name (Chairm ) Name Name
/4*11YTOAc o -��-�15r f 4ztz5 G�.>, "%a O1;X .1WQL&oa
Law Firm Law Firm Law Firm
3
Address Address Address
Com/ kc-� C� l��•1 ►jG 1 l VMW."VwA%�74 P W 17 O S 0
City, Zip City, Zip City, dip
Award
We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the
following award: (Vote: If damages for delay are awarded, they shall be separately stated.)
av t` 82 Q C'Ile Az"t' r¢
Arb' rat r dissents:{Insert-name-if applicable:)
Date of Hearing:
(Chairman)
Date of Award: -07
Notice of Entry of Award
Now, the 01! ' — ay of ` , 20 / , at 2-If /O.M., the above award was
entered upon the docket and notice there f given by mail to the parties or their attorneys.
Arbitrators' compensation to be paid upon appeal: S
By:
Prothonotary Deputy
ff I
Lut p;1 G LU i M '•i
` PENNSYLVANIA� i I
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HIA
IN THE COURT OF COMMON PLEAS OF CPr of 4 . t D Cougriii PENNSYLVANIA
CIVIL DIVISION
vT (J . o(1 -4M%0 r.
vs. II : File No.
/IA AR (s30A tyro Aix.itGo4 dtaDefONIA---1
1,
;1- 1577
PRAECIPE AND POWER OF ATTORNEY FOR SATISFACTION AND/OR TERMINATION
To The Clerk of Judicial Records — Civil Division:
You are hereby authorized, empowered, and directed to enter, as indicated, the following
on the records thereof:
A. 1. ❑ The within suit is Settled, Discontinued, Ended and costs paid.
2. The within suit is Settled, Discontinued, Ended with Prejudice and costs paid.
3. ❑ The within suit is Settled, Discontinued, Ended without Prejudice and costs paid.
B. 1. ❑ Satisfaction of the Award in the within suit is acknowledged.
2. ❑ Satisfaction of Judgment, with interest and costs, in the within matter is acknowledged.
C. ❑ Other:
Date: i o2 2 / y
Witness (if signer is other than a registered Attorney)
Attorney or Notary
Print or type name of above signer
authorizing party
(Rev 4/09)