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Home My WebLink About11-7274A . v? DELANO M. LANTZ & ASSOCIATES By: Delano M. Lantz, Esquire Identification No. 21401 4 North Hanover Street Carlisle, PA 17013 717-422-5874 717-422-5879 (fax) Attorneys for Plaintiffs, Rose A. Cook and Faron L. Cook ROSE A. COOK and FARON L. COOK : IN THE COURT OF COMMON PLEAS OF 425 N. Mountain Road CUMBERLAND COUNTY, PENNSYLVANIA Newville, PA 17241, Plaintiffs CIVIL ACTION Go rn Go T C'-) -... M c- v. CASE NO. Crl Thai GLENN C. REXROTH and LINDA A. r c- L REXROTH, t/d/b/a TRI-BORO RENTAL, , ; STORAGE & LEASING, ' C-0 and ?= 4 GLENN C. REXROTH and LINDA A. REXROTH, Individually, 435 E. Locust Street, P.O. Box 98 Dallastown, PA 17313 and DOUGLAS M. WHITE 35 North Ridge Road Thomasville, PA 17364, Defendants PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a Writ of Summons in a civil action against Defendants, Glenn C. Rexroth and Linda A. Rexroth, t/d/b/a Tri-Boro Rental, Storage & Leasing; and Glenn C. Rexroth and Linda A. Rexroth, Individually, 435 E. Locust Street, P.O. Box 98, /A a#11 c1C X122 L-5 ?-?° H 9q? Dallastown, PA 17313; and Douglas M. White, 35 North Ridge Road, Thomasville, PA 17364. DELANO W! ANTZ & ASSOCIATES By: Delano M. Lantz I.D. No. 21401 4 North Hanover Street Carlisle, PA 17013 717-422-5874 Dated: September 20, 2011 717-422-5879 (fax) Attorneys for Plaintiffs Rose A. Cook and Faron L. Cook ROSE A. COOK and FARON L. COOK IN THE COURT OF COMMON PLEAS OF 425 N. Mountain Road CUMBERLAND COUNTY, PENNSYLVANIA Newville, PA 17241, ; Plaintiffs : CIVIL ACTION V. CASE NO. 72 7 Civil Term GLENN C. REXROTH and LINDA A REXROTH, t/d/b/a TRI-BORO RENTAL, STORAGE & LEASING, and GLENN C. REXROTH and LINDA A. REXROTH, Individually, 435 E. Locust Street, P.O. Box 98 Dallastown, PA 17313 and DOUGLAS M. WHITE 35 North Ridge Road Thomasville, PA 17364, Defendants WRIT OF SUMMONS TO: Glenn C. Rexroth and Linda A. Rexroth t/d/b/a Tri-Boro Rental, Storage & Leasing; and Glenn C. Rexroth and Linda A. Rexroth, Individually 435 E. Locust Street Dallastown, PA 17313 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS, ROSE A. COOK AND FARON L. COOK HAVE COMMENCED AN ACTION AGAINST YOU. S ?bt c)-d ?' Dave Buell, Protho otary Dated: ROSE A. COOK and FARON L. COOK IN THE COURT OF COMMON PLEAS OF 425 N. Mountain Road CUMBERLAND COUNTY, PENNSYLVANIA Newville, PA 17241, Plaintiffs CIVIL ACTION V. CASE NO. L - Civil Term GLENN C. REXROTH and LINDA A. REXROTH, t/d/b/a TRI-BORO RENTAL, STORAGE & LEASING, and GLENN C. REXROTH and LINDA A. REXROTH, Individually, 435 E. Locust Street, P.O. Box 98 Dallastown, PA 17313 and DOUGLAS M. WHITE 35 North Ridge Road Thomasville, PA 17364, Defendants WRIT OF SUMMONS TO: Douglas M. White 35 North Ridge Road Thomasville, PA 17364 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS, ROSE A. COOK AND FARON L. COOK, HAVE COMMENCED AN ACTION AGAINST YOU. Dated: Ste. d 0 Dav I, Prot onotary i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy 001,11V flt CwNbp1,1414 i V., 1 2 tJ A ...I rV_ 1"._ Richard W Stewart Solicitor oFfhE -14 THE `."ERIFc 1' Sl'?.iPrilitk,'F Rose A. Cook vs. Douglas M. White (et al.) Case Number 2011-7274 SHERIFF'S RETURN OF SERVICE 09/21/2011 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: Douglas M. White, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Writ of Summons according to law. 09/21/2011 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: Glenn C. Rexroth and Linda A. Rexroth t/d/b/a Tri-Borc Rental, Storage and Leasing; and Glenn C. Rexroth and Linda A. Rexroth, Individually, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 09/27/2011 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: Glenn C. Rexroth t/d/b/a Tri-Boro Rental, Storage & Leasing, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Writ of Summons according to law. 09/27/2011 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: Linda A. Rexroth t/d/b/a Tri-Boro Rental, Storage & Leasing, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Writ of Summons according to law. 09/27/2011 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: Linda A. Rexroth, Individually, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Writ of Summons according to law. 09/30/2011 04:05 PM - York County Return: And now September 30, 2011 at 1605 hours I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do hereby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Linda A. Rexroth by making known unto herself personally, at 465 Locust Street, Dallastown, Pennsylvania 17313 its contents and at the same time handing to her personally the said true and correct copy of the same. 09/30/2011 04:05 PM - York County Return: And now September 30, 2011 at 1605 hours I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do hereby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Linda A. Rexroth t/d/b/a Tri-Boro Rental Storage & Leasing by making known unto herself personally, at 465 Locust Street, Dallastown, Pennsylvania 17313 its contents and at the same time handing to her personally the said true and correct copy of the same. 09/30/2011 04:05 PM - Ycrk County Return: And now September 30, 2011 at 1605 hours I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do hereby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Glenn C. Rexroth t/d/b/a Tri-Boro Rental, Storage & Leasing by making known unto himself personally, at 465 Locust Street, Dallastown, Pennsylvania 17313 its contents and at the same time handing to him personally the said true and correct copy of the same. (C) Coun`;ySutte Shenff. Teleosoft_ Inc. 09/30/2011 04:05 PM - York County Return: And now September 30, 2011 at 1605 hours I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do hereby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Glenn C. Rexroth and Linda A. Rexroth t/d/b/a Tri-Boro Rental, Storage & Leasing; and Glenn C. Rexroth and Linda C. Rexroth, Individually by making known unto Glenn C. Rexroth personally, at 465 Locust Street, Dallastown, Pennsylvania 17313 its contents and at the same time handing to him personally the said true and correct copy of the same. 10/07/2011 04:05 PM - York County Return: And now September 30, 2011 at 1605 hours I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do hereby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Douglas M. White by making known unto himself personally, at 35 N. Ridge Road, Thomasville, Pennsylvania 17364 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $92.44 October 18, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (C) CCUMYSuite Sheriff. Te!eosaft. Inc. WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP BY: Michael S. Takacs, Esquire and Pennsylvania I.D. No. 78409 Attorney for Defendants The Curtis Center, Suite 1130 East Tri-Boro Construction Supplies, Inc. Independence Square West (incorrectly identified as Glenn C. Philadelphia, PA 19106 Rexroth and Linda A. Rexroth, Tele: 215 627-6900 individually and t/d/b/a Tri-Boro Rental, Jeffrey Ostergwilsonelser.com Storage & Leasing) and Douglas M. White ROSE A. COOK and FARON L. COOK, Plaintiffs, V. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION GLENN C. REXROTH and LINDA A. REXROTH, t/d/b/a TRI-BORO RENTAL, STORAGE & LEASING, and GLENN C. REXROTH and LINDA A. REXROTH,: Individually and DOUGLAS M. WHITE, Defendants. Case No. 11-7274 CJ7. r.3 . c ? CD ? .. C7 C.. r. ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of defendants, Tri-Boro Construction Supplies, Inc. (incorrectly identified as Glenn C. Rexroth and Linda A. Rexroth, individually and t/d/b/a Tri-Boro Rental, Storage & Leasing) and Douglas M. White, in the above-referenced matter. WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP I ?? i hael S. Takacs, Esquire 444_il Attorney for Defendants, Tri-Boro Construction Supplies, Inc. (incorrectly identified as Glenn C. Rexroth and Linda A. Rexroth, individually and t/d/b/a Tri-Boro Rental, Storage & Leasing) and Douglas M. White 601920.1 CERTIFICATE OF SERVICE Michael S. Takacs, Esquire, attorney for Defendants, Tri-Boro Construction Supplies, Inc. incorrectly identified as Glenn C. Rexroth and Linda A. Rexroth, individually and t/d/b/a Tri-Boro tental, Storage & Leasing) and Douglas M. White, hereby certify that on October 1$, 2011, he sent by lnited States mail, first-class., postage pre-paid, a true and correct copy of the foregoing Entry of &,ppearance to the following counsel: Delano M. Lantz, Esquire Delano M. Lantz & Associates Four North Hanover Street Carlisle, PA 17013 Attorney for Plaintiffs, Rose A. Cook and Faron L. Cook "z.'N I Michael S. Takacs, Esquire Attorney for Defendants, Tri-Boro Construction Supplies, Inc. (incorrectly identified as Glenn C. Rexroth and Linda A. Rexroth, individually and t/d/b/a Tri-Boro Rental, Storage & Leasing) and Douglas M. White 601920.1 WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP BY: Jeffrey L. Oster, Esquire Pennsylvania I.D. Nos. 204892 Attorney for Defendants The Curtis Center, Suite 1130 East Tri-Born Construction Supplies, Inc. Independence Square West (incorrectly identified as Glenn C. Philadelphia, PA 19106 Rexroth and Linda A. Rexroth, Tele: 215-627-6900 individually and t/d/b/a Tri-Boro Rental, Jeffrey. Oster(@wiIsoneIser com Storage & Leasing) and Douglas M. White ROSE A. COOK and FAR.ON L. COOK, Plaintiffs, V. GLENN C. REXROTH and LINDA A. REXROTH, t/d/b/a TRI-BORO RENTAL, STORAGE & LEASING, and GLENN C. REXROTH and LINDA A. REXROTH,: Individually and DOUGLAS M. WHITE, Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION r r c_a ' r Case No. 1 1-7274 - ° =C) STIPULATION TO AMEND CAPTION It is hereby STIPULATED by the parties, through their respective counsel, that the caption of the within action be amended to read "Rose A. Cook and Faron L. Cook, Plaintiffs, v. Tri-Boro Construction Supplies, Inc. and Douglas M. White, Defendants.". DELANO M. LANTZ & ASSOCIATES By- Delano M. Lantz, uire Attorney for Plaintiffs WILSON, LAy, MOSKOWITZ, EDELMA#/& KER LLP By: Jeffrey Oster, Esquire Attor for Defendants Dated: October/3,2011 Dated: October P-, 2011 ;rror! Unknown document nrooerty name. 'VILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP BY: Michael S. Takacs, Esquire and Jeffre L Oster Esquire y . Pennsylvania I.D. Nos. 78409 and 204892 Attorneys for Defendants The Curtis Center, Suite 1130 East Tri-Boro Construction Supplies, Inc. Independence Square West (incorrectly identified as Glenn C. Philadelphia, PA 19106 Rexroth and Linda A. Rexroth, Tele: 215 627-6900 individually and t/d/b/a Tri-Boro Rental, Jeffrey.Oster@wilsonelser.com Storage & Leasing) and Douglas M. White ROSE A. COOK and FARON L. COOK, Plaintiffs, V. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION GLENN C. REXROTH and LINDA A. REXROTH, t/d/b/a TRI-BORO RENTAL, STORAGE & LEASING, and : GLENN C. REXROTH and LINDA A. REXROTH,: Individually and DOUGLAS M. WHITE, Defendants. Case No. 11-7274 C-) c .; . ?- C.) > C) ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance as co-counsel on behalf of defendants, Tri-Boro Construction Supplies, Inc. (incorrectly identified as Glenn C. Rexroth and Linda A. Rexroth, individually and t/d/b/a Tri-Boro Rental, Storage & Leasing) and Douglas M. White, in the abov ferenced matter. WILSON, ELSE , SKOWITZ, EDELMAN & C R LLP Jeffrey L. Oster, squire Co-Counsel for efendants, Tri-Boro Const ction Supplies, Inc. (incorrectly identified as GI C. Rexroth and Linda A. Rexroth, indivi ually and t/d/b/a Tri-Boro Rental, Storage & Leasi ng) and Douglas M. White 603294.1 A CERTIFICATE OF SERVICE Jeffrey L. Oster, Esquire, co-counsel for Defendants, Tri-Boro Construction Supplies, Inc. (incorrectly identified as Glenn C. Rexroth and Linda A. Rexroth, individually and t/d/b/a Tri-Boro Kental, Storage & Leasing) and Douglas M. White, hereby certify that on October 20, 2011, he sent by United States mail, first-class, postage pre-paid, a true and correct copy of the foregoing Entry of Appearance to the following counsel: Delano M. Lantz, Esquire Delano M. Lantz & Associates Four North Hanover Street Carlisle, PA 17013 Attorney for Plaintiffs, Rose A. Cook and Fc 603294.1