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Home My WebLink About04-4762 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O'1-I-f'tI&.J..... e(..;J~T8u-Vj CIVIL ACTION - LAW STEPHANIE HECKMAN, Plaintiff MARICIANA FRETHEIM, Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. 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 without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. 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 2 LIBERTY AVENUE CARLISLE,PA 17013 (7 17) 249-3166 -LA I ~;S/ Y Richard E. F eeburn, Esquire FREEBURN & HAMILTON 4415 North Front Street Harrisburg PA 17110 (717) 671-1955 I.D. #30965 Date: 9/17/04 Attorney for Plaintiff STEPHANIE HECKMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. MARICIANA FRETHEIM, Defendant CIVIL ACTION - LAW NOTICE USTED HA smo DEMANDADO/ A EN CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar ua apariencia esrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de dernanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. USTED DEBE LLEVAR ESTATE DOCUMENTO A SU ABOGADO l~nIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEQUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 s.~,""rro FREEBURN & HAMILTON 4415 North Front Street Harrisburg PA 1711 0 (717) 671-1955 LD. #30965 Date: 9/17/04 Attorney for Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CY-.!.f7(,.~ C:'(")'I.C-T~ CIVIL ACTION - LAW STEPHANIE HECKMAN Plaintiff MARICIANA FRETHEIM Defendant COMPLAINT AND NOW comes Plaintiff, Stephanie Heckman, by her attorneys, Freeburn & Hamilton, and files the following Complaint: 1. Plaintiff, Stephanie Heckman, is an adult individual who reside at 4627 Pine Lane, Chambersburg, Franklin County, Pennsylvania. 2. Defendant, Marciana Fretheim, is an adult individual who resides at or does business at 303 W. King Street, Shippensburg, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related occurred on or about December 5, 2002 at approximately 12:30 p.m. at an apartment building located at 7402 Lincoln Way West, St. Thomas, Franklin County, Pennsylvania. 4. At that time and place, Defendant owned, possessed and managed real property located at 7402 Lincoln Way West, St. Thomas, Franklin County, Pennsylvania including the apartment building erected thereon. 5. At that time and place, Plaintiff was a tenant of Defendant's in an apartment at 7402 Lincoln Way West, St. Thomas, Franklin County, Pennsylvania. 6. At all times relevant hereto, the front door latch for the apartment building was in a state of disrepair, would not latch properly,. 7. It is believed and therefore averred that Defendant had actual notice of or, in the alternative, should have known that the front door latch of the apartment building was in a state of disrepair would not latch properly. 8. At or about that time and place, Plaintiff exited her apartment unit into the common hallway, and found that the temperature in the hallway was very cold. Upon further investigation, Plaintiff found that the front door to the apartment building was hanging open, and that snow had accumulated on the floor inside the front door. 9. In order to close the front door, Plaintiff had to step into the snow that had accumulated inside the front door. 10. Plaintiff's foot slipped in the snow and her hand and arm went through a pane of glass in the front door. 11. The foregoing incident and all of the injuries and damages as set forth hereinafter are the direct and proximate result of the negligence, carelessness, and recklessness of Defendant, Marciana Fretheim as follows: a. In failing to exercise reasonable care to ensure the safety of business visitors such as Plaintiff; b. In failing to inspect the premises; c. In failing to adequately inspect the premises; d. In failing to discover the unsafe condition of the front door; e. In failing to repair the front door; f. In failing to adequately supervise and manage its employees; 2 g. In failing to anticipate the harm that the front door could cause; h. In permitting snow to accumulate on the floor where it posed an unreasonable risk of injury to Plaintiff and other business visitors; and 1. In failing to remove the snow from the floor and keep the floor clean and free of hazardous conditions. 12. As a result of Defendant's negligence, carelessness and recklessness, Plaintiff suffered painful and severe injuries to her nerves, bones and soft tissues, which include, but are not limited to lacerations of the left thumb as well as multiple other lacerations on the left hand and left forearm and digital nerve laceration. 13. By reason of the aforesaid injuries suffered by Plaintiff, she has suffered a heightened possibility that she will suffer other or additional injury in the future, and claim is made therefore. 14. The aforesaid injuries suffered by Plaintiff may have aggravated or been aggravated by an existing infirmity, condition or disease, resulting in a prolongation or worsening of the injuries and an enhanced risk of future harm to Plaintiff, and claim is made therefore. 15. By reason of the aforesaid injuries suffered by Plaintiff, she was forced to incur liability for reasonable and necessary medical tests, medical examinations, medical treatment, medications, hospitalizations and similar expenses in an effort to diagnose her injuries and to restore herself to health, and claim is made therefore. 16. Plaintiff has not fully recovered from her injuries and it is reasonably likely that she will incur similar expenses in the future, and claim is made therefore. 3 17. By reason of the aforesaid injuries suffered by Plaintiff, she has suffered a loss of earnings and earning capacity and is entitled to recover the value of the time, earnings and employment benefits she has lost and which she might reasonably have earned in the pursuit of her ordinary calling, and claim is made therefore. 18. By reason of the aforesaid injuries suffered by Plaintiff, she has suffered a loss or impairment of future earning capacity, and claim is made therefore. 19. By reason of the aforesaid injuries suffered by Plaintiff, she has incurred incidental costs and expenses, the exact amount of which cannot be ascertained at this time, and claim is made therefore. 20. As a result of the aforesaid injuries suffered by Plaintiff, she has undergone and in the future will undergo great physical and mental pain and suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefore. 21. As a result of the aforesaid injuries suffered by Plaintiff, she has been subjected to humiliation, embarrassment, shame, worry and anger. 22. As a result of the aforesaid injuries suffered by Plaintiff, she has been subjected to severe mental anguish, emotional distress, nervous shock, fright and horror. 23. As a result of the aforesaid injuries suffered by Plaintiff, she will continue to endure great mental anguish, emotional distress, shame, worry and anger in the future. 24. By reason of the aforesaid injuries suffered by Plaintiff, she has been deprived her enjoyment of the pleasures of life. 4 25. Plaintiff continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefore. 26. As a result of the aforesaid injuries suffered by Plaintiff, she has suffered a disfigurement, and claim is made therefore. WHEREFORE, Plaintiff, Stephanie Heckman, demands judgment in her favor and against Defendant, Marciana Fretheim, in an amount in excess of TWENTY-FIVE THOUSAND & 00/100 ($25,000.00) DOLLARS, exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. Respectfully Submitted, FREEBURN & HAMILTON By: ~ -' . Richard E. ree~uire 1.D. No. 30965 4415 North Front Street Harrisburg P A 1711 0 (717) 671-1955 Date: 9/ 17/04 Counsel for Plaintiff 5 VERIFICATION I hereby verify that the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities. Dated: 9-Z-(J/ JL AN (J "'IQ. 1t 7i Cl1 Crt .. . . ~" , ~ ~ If't .. f) 0 f_', . , ~ ;- , Vi -C::.. -V Ii'- ~-- :- '- P- ~ ~ ,.._, ~ '---i... SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-04762 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HECKMAN STEPHANIE VS FRETHEIM MARICIANA R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT FRETHEIM MARICIANA but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , FRETHEIM MARICIANA 303 WEST KING STREET SHIPPENSBURG, PA 17257 GIVEN ADDRESS IS FRANKLIN COUNTY. Sheriff's Costs: Docketing Service Not Found Surcharge So answers: 18.00 15.54 5.00 10.00 .00 48.54 R. Thomas Kline Sheriff of Cumberland County FREEBURN & HAMILTON 10/01/2004 Sworn and subscribed to before me this 5~ day of (JJeWw,. ,x1JO'( A.D. n . ....., () /n.,'.)u..> ~ pr~~otary ; ''-~ STEPHANIE HECKMAN Plain tiff v. MARICIANA FRETHEIM Defendant TO: Prothonotary ,', "'t\(- !'~ " U IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4762 CIVIL ACTION -LAW PBAB;CIPE Kindly reinstate Plaintiffs Complaint in this matter. Dated: 10/6/04 Respectfully submitted, FREEBURN & IfAMILT IN/ By: eburn, Esquire LD, No. 309 5 4415 North Front Street Harrisburg,PA 17110 (717) 671-1955 Attorney for Plaintiff ....' ~ Cl C') -\ \ --l I:. I. 1."",. "?3 ~ -0 :1;: f..t~1 -- N ORIGINAL STEPHANIE HECKMAN Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-4762 MARICIANA FRETHEIM Defendant CIVIL ACTION -. LAW PRAECIPE TO: Prothonotary Kindly reinstate Plaintiffs Complaint in this matter. Respectfully submitted, By: FREEBURN & HAMILT~ \~~ ~d E. Free rD, Esquire LD. No. 30965 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 Dated: 11/2/04 Attorney for Plaintiff 0 ,...., 0 c:::> C = -n -..,:0>' .z;- ~U' % -l Cl :c "Tl n1-'" ...::: ljFr; ',:.". r" I u'F' :ucr w 0 ~~L' :..,~) -0 ;T- -d ~~'~ \.) -- ~ ";:7'0 (t;' (3m -". -I L_ ~j ~ .::- -< WILLIAM A. ADDAMS, ESQUIRE ATIORNEY ill # 06265 27 W. HIGH ST. P.O. BOX 261 CARLISLE PA 17013 TELEPHONE 717-243-7638 YOU ~RE HEPllE8Y REQUIRED TO 'tLl A WRITTEN RESPONse TO THE ENCLOSEO WITHIN lWENT'f (20) OA YS F,.OM SIIWICI HEfIEOF OR A J'~NT MAY 1& INTIMD :'~~~ ATTORNEY sTEPHANfE..HEcKMAN......................................~..........fn..the..c.ouri.orcomm:on.Pleas..o{......' Plaintiff ~ CUMBERLAl'ID County Pennsylvania I. CML ACTION - LAW VS. MARCIANA FRETHEIM ! Case No.04-4762 Civil ..........................................................................................................."......................................................................................................... AND now comes the defendant, Marciana Fretheim, by her attorney, William A. Addams, in accordance with P A R.c.P. 1028, makes a preliminary objection to the plaintiff's complaint as follows: PRELIMINARY OBTECTION Obiection to Venue 1. The complaint filed September 21, 2004, alleges that the plaintiff, was injured as a result of a defective condition on the premises while a tenant in the apartment building owned by the defendant in St. Thomas, Franklin County, P A. 2. The Sheriff filed a "not found" return because the Shippensburg address stated in the complaint for the defendant is actually in Franklin County. 3. The complaint was subsequently reinstated and the defendant was served at her present residence in Fulton County. 4. PA R.c.P. 1006 (a) provides that "except as otherwise provided...an action against an individual may be brought in and only in a county in which the individual may be served or in which the cause of action arose...." 5. Venue does not lie in Cumberland County. 6. Franklin is the cause of action county and also the current residence of the plaintiff. r WHEREFORE, the defendant requests Your Honorable Court to order the transfer of this action to the Court of Common Pleas of the 39th Judicial District, Franklin County Branch. ~ William A. Aadams Attorney for Defendant .. WILLIAM A. ADDAMS, ESQUIRE ATTORNEY ill # 06265 27 W. HIGH ST. P.O. BOX 261 CARLISLE P A 17013 TELEPHONE 717-243-7638 sTEf>HANiE..HEcKMAN.....................................r......."fil..the..c.our:t"'o(Common:-I51eas..o{..... Plaintiff 1 CUMBERLAND County Pennsylvania CIVIL ACTION - LAW VS. Case No.04-4~'62 Civil MAROANA FRETHEIM CERTIFICATE OF SERVICE The undersigned hereby certifies that on this 24th day of November, 2004, a true and correct copy of the Preliminary Objection to Venue was served via first class mail upon the following counsel: Richard E. Freeburn, Esquire Freeburn & Hamilton 4415 North Front St. Harrisburg, PA 17110 w~~ Attorney for Defendant Dated: November 24, 2004 -. '0;::- ~) .~t f~ -:;: Q c ::".~' c1:t(j -0 ::r. ~~ N N N c:::;, <::::I .c:- ;;r.: c:.:> ....;;.: 1"..> -&:- o " :r! FI1 :n r- :om ~l)~ c' 21 if' -I:jj 90 om ~,~ .:.0 -< STEPHANIE HECKMAN Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY , PENNSYLVANIA v. NO. 04-4762 MARICIANA FRETHEIM Defendant CIVIL ACTION - LAW PRAECIPE TO: Prothonotary Kindly reinstate Plaintiffs Complaint in this matter. Respectfully submitted, \ FREEBURN & By: Riehar . Freeburn, Esquire LD. No. 30965 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 Dated: 11/30/04 Attorney for Plaintiff C' /'0.,) .- '-'= ~~: c:,:') 0 .;;.- "11 \, 0 :1:'..,. i P1 ("") rl1 P-' (/! I 11m N ::Uy <") ") , ~ ':j( . -0 :c,j ., -,7'" ,.--) :!J ~:-'"" ~. .. CjS1 ~) :r:; ~-l c..,> f:.Jl. -< ~:o a-, .< STEPHANIE HECKMAN Plain tiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-4762 MARICIANA FRETHEIM Defendant CIVIL ACTION - LAW PRAECIPE TO: Prothonotary Kindly reinstate Plaintiffs Complaint in this matter. Respectfully submitted, By: FREEBURN & HAMIL1~ S~~sf2 -- LD. No. 30965 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 Dated: 12/28/04 Attomey for Plaintiff o c <'" ""O(-p 'II r;-, Z2~: Z\;, ~;:' ~L. ):'" c: Z(~ S;c -7 ~ ~ c:;;::I c:;;::I ..r- o ....., c-> tv \.0 ~ ~:!J ';gfD 06 ~~i -0 ~o :x C5 rn -"-t ~ o < Ui STEPHANIE HECKMAN Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4762 MARICIANA FRETHEIM Defendant CIVIL ACTION - LAW PRAECIPE TO: Prothonotary Kindly reinstate Plaintiffs Complaint in this matter. RespectfuIIy submitted" By: FREEBURN & HAMILl'ON (-~~ E~) Richard E. Fn(eburn, lJ:Squire LD. No. 30965 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 Dated: 1/25/05 Attorney for Plaintiff ('><> <;:-::') c''':" W'"'( ,~ c_ C) .'fl ~~;:,~ -G n1r;~ 'TlfE\ :JJ\(" ~() ~ :'S ~I~ , lil ...,...." Z f',) 0' "D _.,~" r.~: \,,<,) ...0 'r> ~,.. ~::.. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04762 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HECKMAN STEPHANIE VS FRETHEIM MARICIANA R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: FRETHEIM MARICIANA but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On October 27th , 2004 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge Dep Franklin Co 18.00 9.00 10.00 40.80 .00 77.80 10/27/2004 FREEBURN & So an. s.~er...s-, . / .' /--c:~.? '---'::::::---~.". ,"' <.,.-.--.-- --.;-,~.;? .',:,j?::-Z:::-',-- -- R. Thomas Kline Sheriff of Cumberland County HAMILTON Sworn and subscribed to before me this J1o!? day of J. G-,-,~J-4.J C2pvl{ A.D. C~tJ . C;'rn//f'~J ~ 71 Prothonotary / SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-00250 T COMMONTWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN STEPHANIE HECKMAN VS MARCIANA FRETHEIM ROBERT WOLLYUNG Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: FRETHEIM MARCIANA but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT , NOT FOUND , as to the within named DEFENDANT , FRETHEIM MARCIANA 303 WEST KING STREET SHIPPENSBURG, PA 17257 MOVED TO 9131 WATERFALL ROAD HOUSTONTOWN PA 17229 Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 . .-, -iI .1/)' o /{//~U OBERT WOLLYUNG ROBERT WOLLYUNG, FREEBURN & HAMILTON 10/22/2004 Sworn and subscribed to before me day of tJd..('C/c/, ./ _liaI _v. MoCIdy.NoIIIy_ ". .. _. ho. Franklift County Ny '"'-'''' Expires Jan_ 29,2007 A.D. ~ Notary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04762 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HECKMAN STEPHANIE VS FRETHEIM MARICIANA R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: FRETHEIM MARICIANA but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FULTON County, Pennsylvania, to serve the within COMPLAINT & NOTICE On November 22nd, 2004 , this office was in receipt of the attached return from FULTON omas Kline riff of Cumberland County Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Fulton County 43.52 .00 80.52 11/22/2004 FREEBURN & HAMILTON Sworn and subscribed to before me this Co It: day Of()uu.] c2(JVj. A.D. ~ Cd fn.';" J ~ti- Prothonotary In The Court of Common Pleas of Cumberland County, Pennsylvania Stephanie Heckman VS. Mnriciana Fretheim Serve her persona.Lly No. 04-4762 civil N W November 8, 2004 o , , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Fill tnn County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~()/ . //#' ~r- ......~,.,c'd<'~ ~l;P~'.,{!:!:;:;~~ Sheriff of Cumberland County, P A Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this_day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ SHERIFF'S DEPARTMENT COURTHOUSE-NORTH SECOND STREET, McCONNELLSBURG, PA 17233 (717) 485-4221 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN INSTRUCTIONS. FOR SERVICE OF PROCESS. Please type or print legibly, 00 not detach any copies. 1. PLAINTIFF/SI 2. COURT NUMBER S:~pnanie ~Eck~an # 04-4762 3. DEFENDANT/SI 4. TYPE OF WAIT OR COMPLAINT: Aarician~ Fretheim Notice/Cornplaint SERVE r 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC" TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD. ..... jl'jc.ric.iana Fr2th;:.im l 6. ADDRESS (Street or RFD, Apartment No., Bora, Twp., State and ZIP Code) AT 9:31. ~i'a.terfall ROuG ;-lustO;'ltr~wn P..' ~ 7';10 7. INDICATE UNUSUAL SERVICE: 0 COMMON. OF PA 0 DEPUTIZE 0 OTHER Now, I, SHERIFF OF FULTON COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return Ihereof according 10 law. This deputation being made at the request and risk of the plaintiff. SHERIFF OF FULTON COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy orthe sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof. 9. SIGNATURE of ATTORNEY or other ORIGINATOR 10. TELEPHONE NUMBER 11. DATE 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (Thll area mUll be completed II notice II to be melled) S~ClBELOWORUSI! OF IFfERIFtlOttLV. .....I!lONCi)'l!W~I,.E HL.QWTHlS LINE 13. I acknowledge receipt of the writ SIGNATURE of authorized FCSD Deputy or Clerk and Title 14. Date Received 15. Expiration/Hearing date or complaint as indicated above. 18. I hereby CERTIFY and RETURN that I 0 have personally served, 0 have legal evidence of service as shown in "Remarks", have executed as shown in "Remarks", the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company, corporation, etc., at the address inserted below by handing a TRUE and ATTESTED COPY thereof. 17. 0 I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., named above. (See remarks below) 18. Name and~of ind'vidual shd (if tlhown above) Iw 6' cI 19. A person of SUila:rle e and discretion '" "'5 -0 1':, _ ~ 'C "I'l. then resldmg in efendant'susual ~, C- If. ,r.;: 'J K'" place of abode. 20. Address of where served (complete only if different than shown above) (Street or RFD, Apartment No., City, 21. Date or Service 22. Time Boro, Twp., State and Zip Code) SIM1E /I //O/"tj fO :05 ~ 30. REMARKS: is rmJ' D.p. In'. FOR THE 29. Gen DtlC 0" R UND $&.<1 DEFENDANT'S HUSBAND-CHARLES FRETHEIM AT THE ABOVE CITED BY "GEORGi" ASSISTANT TO RICHARD E. FREEBURN, ATTORNEY AJDi\ESS CG;V;PLp.II~T 00 31. AF 32. Signature of Dep. Sheriff 35. Signature of Sheriff 33. 0'/111(; 0 36. Dale SHERIFF OF FULTON COUNTY E E RECEIPT OF THE SHERIFF'S RETURN SIGNATURE} D ISSUING AUTHORITY AND TITLE. 39. Dale Received FCSD-1/1/91 WHITE - ISSUING AUTHORITY PINK - ATTORNEY YELLOW, BLUE & GREEN - SHERIFF'S DEPARTMENT c_ u._J,I iR. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED, DUE TO BANKRUPTCY. , ::;,:;i! '~ln] 'if1l .'".=:;;:;:::j Sheriffs Costs: Advance Costs: Sheriffs Costs: 150.00 73.53 76.47 "~ '.:'JiJ Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Garnishee TOTAL $ $ 18.00 1.45 .50 1.00 12.58 Refunded to Atty on 01/10/05 20.00 20.00 1:). 73.53 -<::. Sworn and Subscribed to before me ~/2!<' I R. Thomas Kline, Sheriff By tl CD I J 1 '_ Q .~ulo ccI4.f"'/" -C. ...J \;' ~ this 13 "'-nay of ,...}~ 2005 A.D. ~a;u- Q ~ 1# Prothonotary SE :01 "i/ I Z DO ~OOl Vd 'AlHClOJ ON\q~138\.oln:l ..HIH3HS 3Hl .:JO 3:l1.:J.:JO . I. so <:.le.- 'tb"f'l~ R..... /51SJ5 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 04-4767 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FINNEGAN TRUST, JOHN E. DAVIS, TRUSTEE, Plaintiff (s) From RICHARD NEENAN, JR., 152 REGENCY WOODS NORTH, CARLISLE, PA 17013 (1 ) You are directed to levy upon the property of the defendant (s)and to sell MISCELLANEOUS PERSONAL PROPERTY LOCATED AT 152 REGENCY WOODS NORTH, CARLISLE, PA 17013 - MERCURY SABLE - P A LICENSE # FPS 1763 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $8, 135.38 Interest Atty's Comm % Atty Paid $36.75 Plaintiff Paid Date: OCTOBER 20, 2004 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) Proth~ Q ~ ,--By: ~ J b7.AY7{...r Deputy REQUESTING PARTY: Name CRAIG A. DIEHL, ESQUIRE Address: 3464 TRINDLE ROAD CAMP fiLL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-763-7613 Supreme Court ill No. 52801 STEPHANIE HECKMAN Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-4762 MARICIANA FRETHEIM Defendant CIVIL ACTION - LAW PRAECIPE TO: Prothonotary Kindly reinstate Plaintiffs Complaint in this matter. Respectfully submitted, By: FREEBUBN &b; k~~.... / Ri~hard E. Free urn, EsqUIre \.0. No. 30965 4415 North Front Street Harrisburg,PA 17110 (717) 671-1955 Dated: 2/23/05 Attorney for Plaintiff STEPHANIE HECKMAN Plaintiff v. MARICIANA FRETHEIM Defendant TO: Prothonotary ORIINAL IN THE COURT OF COMMON PLE S CUMBERLAND COUNTY, PENNS VANIA NO. 04-4762 CIVIL ACTION - LAW PRAECIPE Kindly reinstate Plaintiffs Complaint in this matter. Dated: 3/23/05 By: Respectfully submitted, FREEBURN & HAMILTON / ard E. J.D. No. 30 65 4415 North Front Street Harrisburg, P A 17110 (717) 671-1955 Attorney for Plaintiff c--:. ,-" ';:.;;l 0 ,~~ "'" ~, -- ~ d:' ~ ~ ~.1 :;..;;.;,J rnp? t~ ".:> -nIT' "<. W :',J9 ~: \... tf ').,..; -1"] :z: -,- 5- -~ -..0 ~ ~-,;;'m ,.) <~ .r::" "n <: ~- STEPHANIE HECKMAN Plain tiff v. MARICIANA FRETHEIM Defendant TO: Prothonotary . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4762 CIVIL ACTION - LAW PRAECIPE Kindly reinstate Plaintiffs Complaint in this matter. Respectfully submitted, FREEBURN & HAMILTON By: ~d ~rn, Esquire J.D. No. 30965 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 Dated: 4/20/05 Attorney for Plaintiff ''',) ,.., c':) STEPHANIE HECKMAN Plaintiff v. MARICIANA FRETHEIM Defendant TO: Prothonotary OR/GIN~L IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4762 CIVIL ACTION - LAW PRAECIPE Kindly reinstate Plaintiffs Complaint in this matter. Dated: 5/20/05 By: Respectfully submitted, FREEBURN & HAMILTON 1 Ri ard E. Freeburn, Esquire I.D. No. 30965 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 Attorney for Plaintiff ------- ~ '-:-- ----: ;~") 0'; ~_~o>' STEPHANIE HECKMAN Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4762 MARlCIANA FRETHEIM Defendant CIVIL ACTION - LAW PRAECIPE TO: Prothonotary Kindly reinstate Plaintiffs Complaint in this matter. Respectfully submitted, FREEBURN & 'ON Richard E. R eeburn, Esquire l.D. No. 30965 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 By: ~ Dated: 6/21/05 Attorney for Plaintiff ~ q.. ..-I", ~E ~ \"l', :y~q C)\9, :;:::.,.....'('1, -(5'(::") -?, '/:r" ::.>. '(;2\ 1h :A <f: ~ ~ 2f' {~ ~~ .- - ..p STEPHANIE HECKMAN Plaintiff v. MARICIANA FRETHEIM Defendant TO: Prothonotary IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4762 CIVIL ACTION - LAW PRAECIPE Kindly mark the above-captioned matter discontinued. Respectfully submitted, FREEBURN & HAMILTON ~ /....---; By: ~ Cr/--. - Ric~d ;; Freeburn, Esquire J.D. No. 30965 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 Date: 12/2/05 Attorney for Plaintiff . CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Praecipe has been duly served on the following this 2nd day of December, 2005, by placing the same in the U.S. First Class Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: William A. Addams, Esquire 27 W. High Street PO Box 261 Carlisle PA 17013-0261 BY: ~ Georgianne . Hess, As 'stant to Richard E. Freeburn, E quire Attorney I.D. #30965 FREEBURN & HAMILTON 4415 North Front Street Harrisburg, P A 17110 (717) 671-1955 Dated: 12/2/05 Attorney for Plaintiff ~C' ":"C ~ r<'