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HomeMy WebLinkAbout12-0976• PENNSY1 ANGINO & ROVNER, P.C. Richard C. Angino, Esquire I.D. No. 07140 V/ Daryl E. Christopher, Esquire I.D. No. 91895 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 E-MAIL: RCA ,DANGINO-ROVNER.COM E-MAIL: DCHRISTOPHER@ANGINO-ROVNER.COM Attorneys for Plaintiff(s) RESTORECORE, INC., Plaintiff V. DANIEL M. JONES and CYNTHIA C. JONES, Defendants V. PENN NATIONAL SECURITY INSURANCE COMPANY 2 North Second Street Penn National Insurance Plaza Harrisburg, PA 17105 AND PENNSYLVANIA NATIONAL MUTUAL CASUALTY INSURANCE COMPANY 2 North Second Street Penn National Insurance Plaza Harrisburg, PA 17105 AND PENN NATIONAL INSURANCE 2 North Second Street Penn National Insurance Plaza Harrisburg, PA 17105 Additional Defendants 448234 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO./a- 97& CIVIL CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS 0 # 103.75 Q-U ATM e# 8(087? 0a'71o'7/ To the Prothonotary of Cumberland County: Please issue a Writ of Summons against the Additional Defendants: PENN NATIONAL SECURITY INSURANCE COMPANY 2 North Second Street Penn National Insurance Plaza Harrisburg, PA 17105 AND PENNSYLVANIA NATIONAL MUTUAL CASUALTY INSURANCE COMPANY 2 North Second Street Penn National Insurance Plaza Harrisburg, PA 17105 AND PENN NATIONAL INSURANCE 2 North Second Street Penn National Insurance Plaza Harrisburg, PA 17105 all in Dauphin County, Pennsylvania, and forward same to the Sheriff for Service. Respectfully submitted, ANG1NO & ROVNER, P.C. Daryl .Christopher, Esquire PA I.D. No. 91895 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 dchristopher@angino-rovner.com Date: February 10, 2012 Counsel for Plaintiff 448234 WRIT OF SUMMONS TO THE ABOVE NAMED ADDITIONAL DEFENDANTS: /0?- 996 alai (-&M PENN NATIONAL SECURITY INSURANCE COMPANY 2 North Second Street Penn National Insurance Plaza Harrisburg, PA 17105 AND PENNSYLVANIA NATIONAL MUTUAL CASUALTY INSURANCE COMPANY 2 North Second Street Penn National Insurance Plaza Harrisburg, PA 17105 AND PENN NATIONAL INSURANCE 2 North Second Street Penn National Insurance Plaza Harrisburg, PA 17105 YOU ARE NOTIFIED THAT DANIEL AND CYNTHIA JONES HAVE JOINED YOU AS AN ADDITIONAL DEFENDANTS IN THIS ACTION, WHICH YOU ARE REQUIRED TO DEFEND. THE ABOVE-NAMED DEFENDANTS HAVE COMMENCED AN ACTION AGAINST YOU. T1o?.yid 17..uel I Prothonotary Date: d/13/102 Deputy ( ) Check here if reverse is issued for additional information 448234 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson - ?? , 7'4 .?, - Fit Sheriff 1 c rt Jody S Smith 7i2 FEB 2$ A3", Chief Deputy Richard W Stewart PEWNISYLVANIA Solicitor to=???,F F,,.,..?RnFF , Cynthia C. Jones Case Number vs. 2012-976 Penn National Security Insurance Company (et al.) SHERIFF'S RETURN OF SERVICE 02/15/2012 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: Penn National Security Insurance Company, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvani, to serve the within Writ of Summons according to law. 02/15/2012 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: Penn National Mutual Casualty Insurance Company, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Writ of Summons according to law. 02/15/2012 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: Penn National Insurance, but was unable to locate them in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Writ of Summons according to law. 02/22/2012 09:40 AM - Dauphin County Return: And now February 22, 2012 at 0940 hours I, Jack Lotwick, Sheriff of Dauphin 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: Penn National Insurance by making known unto Kim Lelii, Administrative Assistant for Penn National Insurance at 2 N. Second Street, Harrisburg, Pennsylvania 17105 its contents and at the same time handing to her personally the said true and correct copy of the same. 02/22/2012 09:40 AM - Dauphin County Return: And now February 22, 2012 at 0940 hours I, Jack Lotwick, Sheriff of Dauphin 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: Penn National Mutual Casualty Insurance Company by making known unto Kim Lelii, Administrative Assistant for Penn National Mutual Casualty Insurance Company at 2 N. Second Street, Harrisburg, Pennsylvania 17105 its contents and at the same time handing to her personally the said true and correct copy of the same. 02/22/2012 09:40 AM - Dauphin County Return: And now February 22, 2012 at 0940 hours I, Jack Lotwick, Sheriff of Dauphin 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: Penn National Security Insurance Company by making known unto Kim Lelii, Administrative Assistant for Penn National Security Insurance Company at 2 N. Second Street, Harrisburg, Pennsylvania 17105 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $69.45 February 24, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF Mtfiro- of Jack Duignan Chief Deputy William T. Tully • Solicitor Michael W. Rinehart Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania DAVID M. & CYNTHIA C. JONES VS County of Dauphin PENN NATIONAL INSURANCE Sheriff s Return No. 2012-T-0560 OTHER COUNTY NO. 2012-976 And now: FEBRUARY 22, 2012 at 9:40:00 AM served the within WRIT OF SUMMONS TO ADDITIONAL DEFENDANT upon PENN NATIONAL INSURANCE by personally handing to KIM LELII 1 true attested copy of the original WRIT OF SUMMONS TO ADDITIONAL DEFENDANT and making known to him/her the contents thereof at PENN NATIONAL INSURANCE PLAZA 2 N. 2ND ST HARRISBURG PA 17105 ADMINISTRATIVE ASSISTANT Sworn and subscribed to So Answers,! before me this 22ND day of February, 2012 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17, 2014 Pa. By Deputy Sheriff Deputy: DARIN S SHE EY Sheriffs Costs: $79.75 2/17/2012 (ptfirt the '&hvrr-,ff Jack Duignan Chief Deputy William T. Tully Solicitor Michael W. Rinehart Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: t717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania DAVID M. & CYNTHIA C. JONES VS County of Dauphin PENN NATIONAL INSURANCE Sheriff s Return No. 2012-T-0560 OTHER COUNTY NO. 2012-976 And now: FEBRUARY 22, 2012 at 9:40:00 AM served the within WRIT OF SUMMONS TO ADDITIONAL DEFENDANT upon PENN NATIONAL SECURITY INSURANCE by personally handing to KIM LELII 1 true attested copy of the original WRIT OF SUMMONS TO ADDITIONAL DEFENDANT and making known to him/her the contents thereof at PENN NATIONAL INSURANCE PLAZA 2 N. 2ND ST HARRISBURG PA 17105 ADMINISTRATIVE ASSISTANT Sworn and subscribed to before me this 22ND day of February, 2012 So Answers, C____ -)P? Z COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17, 2014 Sher' auphin, Pa. By 1-7 -1 Deputy Sheriff Deputy: DARIN S SHERFEY Sheriffs Costs: $79.75 2/17/2012 q0tfir-9 of the ?$4crff Jack Duignan Chief Deputy William, T. Tully Solicitor Michael W. Rinehart Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax:(717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania DAVID M. & CYNTHIA C. JONES VS County of Dauphin PENN NATIONAL INSURANCE Sheriff s Return No. 2012-T-0560 OTHER COUNTY NO. 2012-976 And now: FEBRUARY 22, 2012 at 9:40:00 AM served the within WRIT OF SUMMONS TO ADDITIONAL DEFENDANT upon PENNSYLVANIA NATIONAL MUTUAL CASUALTY by personally handing to KIM LELII 1 true attested copy of the original WRIT OF SUMMONS TO ADDITIONAL. DEFENDANT and making known to him/her the contents thereof at PENN NATIONAL INSURANCE PLAZA 2 N. 2ND ST HARRISBURG PA 17105 ADMINISTRATIVE ASSISTANT Sworn and subscribed to before me this 22ND day of February, 2012 -)P? So Answers, 1? °By COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17, 2014 Pa. Deputy Sheriff Deputy: DARIN S SHE EY Sheriffs Costs: $79.75 2/1.7/2012 AK if