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Home My WebLink About04-4981JOHN GROSS & COMPANY, INC., Plaintiff PRO DEALER SERVICES, INC., d/b/a : MR. T'S INTOWN : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue a Writ of Summons against PRO DEALER SERVICES, INC., d/b/a MR. T'S INTOWN, 241 Bellevue Road, Red Lion, Pennsylvania, 17356, as Defendant in the above-captioned action and forward same together with Plaintiff's First Request for Production of Documents in Preparation for the Filing of a Complaint to the Cumberland County Sheriff for service upon Defendant. MARTSON DEARDORFF WILLIAMS & OTTO Carl C. Risch, Esquire I.D.Number: 75901 Christopher E. Rice, Esquire I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (7 l 7) 243-3341 Attorneys for Plaintiffs Date: October 1, 2004. JOHN GROSS & COMPANY, 1NC., Plaintiff PRO DEALER SERVICES, INC., d/b/a MR. T'S 1NTOWN Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CWIL ACTION NO. Oq- q'tPI JURY TRIAL OF TWELVE DEMANDED WRIT OF SUMMONS TO PRO DEALER SERVICES, INC., d/b/a MR. T'S INTOWN: You are herebynotified that JOHN GROSS & COMPANY, INC., has commenced an action against you. Prothonotary or Clerk Deputy Date: October l, 2004 JOHN GROSS & COMPANY, INC., Plaintiff PRO DEALER SERVICES, INC., d/b/a MR. T'S INTOWN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CWIL ACTION NO. JURY TRIAL OF TWELVE DEMANDED PLAINTIFF'S FIRST REOUEST FOR PRODUCTION OF DOCUMENTS IN PREPARATION FOR THE F/LING OF A COMPLAINT TO: PRO DEALER SERVICES, INC., d/b/a MR. T'S INTOWN, Defendant AND NOW, this 16th day of September, 2004, pursuant to Pa. R.C.P. 4009, as amended, comes the Plaintiff by its Attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, 10 East High Street, Carlisle, Pennsylvaaia, and requests Defendant to produce for inspection, examination and copying, at the above office, not later than thirty (30) days after service of this Request the following documents: 1. All leases, a~'eements, and contracts between Pro Dealer Services, Inc., d/b/a Mr. T's Intown, and any individual or entity for real estate, buildings, or personal property related to or used in conjunction with the operation of its business. 2. All tax returns, bank statements, and other financial records within the last four years in the possession, custody, or control of Defendant, counsel for Defendant, or any other person or entity acting on behalf of Defendant, representing or purporting to show income, ownership, disbursement, or financial status. Date: October 1, 2004 MARTSON DEARDORFF WiLLIAMS & OTTO Carl C. Risch, Esquire I.D. No. 75901 Christopher E. Rice, Esquire I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Discovery Request was served this date by attaching a copy to the Praecipe for Writ of Summons filed with the Cumberland County Court of Common Pleas, Pemasylvania, which will be served by the Sheriffto the address below: Pro Dealer Services, Inc., d/b/a Mr. T's Intown 241 Bellevue Road York PA 17356 Dated: October 1, 2004 M~TSON DE~O~ W~L~S ~ OTtO Christopher E. Rice F:~FILES~DATAFILE\General\Current\8369-26.pra.sat Created: 11/16/03 2.53PM Revised: 12/2/04 1024AM 8369 26 JOHN GROSS & COMPANY, INC., Plaintiff Vo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION[ PRO DEALER SERVICES, INC., d/b/a MR. T'S INTOWN, Defendant NO. 2004-4981 CWIL TERM JURY TRIAL O,F TWELVE DEMANDED PRAECIPE TO SETTLE AND DISCONTINUE TO THE CUMBERLAND COUNTY PROTHONOTARY: Please mark the above captioned case settled and discontinued and issue a certificate reflecting same. Date: December 2, 2004 MARTSON DEARDORFF WILLIAMS & OTTO Carl C. Risch, Esquire I.D. No. 75901 Christopher E. Rice, Esquire I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717)243-3341 Attorneys for Plaintiff CERTIFICATE OF SERVICE I, Jacqueline A. Decker, an authorized agent ofMartson DeardorffWilliams & Otto, hereby certify that a copy of the foregoing Praecipe to Settle and Discontinue was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Laurence T. Himes, Jr., Esquire GRIEST, HIMES, HERROLD, SCHAUMANN LLP 129 East market Street York, PA 17401 MARTSON DEARDORFF WILLIAMS & OTTO By (~~d~ ~(~4u~)~ne A. I})ecker Ten Wast High Street Carlisle, PA 17013 (717) 243-3341 Dated: December 2, 2004 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-04981 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JOHN GROSS & COMPANY INC VS PRO DEALER SERVICES INC D/B/A 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: PRO DEALER SERVICES INC D/B/A MR T'S INTOWN 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 AND REQUEST FOR PRODUCTION OF DOCUMENTS On November 10th, 2004 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge Dep York County 18.00 9.00 10.00 27.50 .00 64.50 11/10/2004 MDW&O So ~_._.~. ./ ~7 -/ -") //- .' _.r~ ,,/,,_...... .._' ,....,..~ .," R. homas Kline Sheriff of Cumberland County Sworn and subscribed to before me this </ c- day OfY,,, -'7 ho;;D ( /1-<-- 11 !h/I}/A/~ Prothonotary , COUN1Y OF YORK OFFICE OF THE SHERIFF SERVICE CALL (7/7) 771-9601 45 N. GEORGE ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN .1'R~~ fU~'fl'Pl"V"""'1.1lItU 12 OO....y OET~CtlANY COPES 1 PLAINTIFF/Sf John Gross & Canpany lnc 3 OEFENDANTlSI 2_ COURT NUMBER 04-498] civil -- 4_ TYPE O~ WRIT OR COMPLAINT Writ of Surrmons Pro Dealer Services lnc d/b/a Mr T's lntown < SERVE { 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ErC TO SERvE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATIACHED, OR SOLD .. Pro Dealer Services lnc d/b/a Mr T's lntown 6 ADDRESS (STREET OR RFO \NITH BOX NUMBER, APT NO. CITY. BORC. lVJP. STATE AND ZIP CODE) AT 241 Bellevue Road Red Lion, FA 17356 7. INDICATE SERVICE Q PERSONAL D PERSON IN CHARGE ~ DEPUTIZE ~~dhe 015T CLASS MAil NOW Qctober 4, , 20~ I, SHERIFF OF ~ COUN1Y, PA, York COUN1Y to execute th' to law, This depulization being made at the request and risk of the plaintiff, U POSTED U OTHER COUNTY an ~ s~ice County Sheriff. Thank you. NOTE: ONLY APPUCABLE ON WRIT OF XECUTIO . .8. WAIVER OF T MAN - Any deputy sheriff levying upon or attaChing any property under within wnl may leave same without a watchman, in custody 01 whomever is fOllnd in ssession, after nottrytng person of Jevy or attachment. without liability on the part of such deputy or Ihe sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof ' 9. T't NAME and ADDRESS of ATTORNEY lOR/GINA TOR an IGNA TURE : sf SHERIFF OF 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE 10. TElEPHONE NUMBER 11 DATE FILED ;y/ J31! I is area must be completed if notice is to be mailed) 16 HOW SERVED: PERSONAl ( (] Miles Int. 22 REMARKS: j/I6- '*"1 \1-,-,\.J1 48. Signature of Foreign County Shenrf 50. I ACKNOv.\.EDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE OF AUTHO~LZED ISSUING AUTHQRfTY AND TITLE ~ame.s ..... ature of p. Sheriff re of YOrk County Sheri. ~Ji 11 i am M. Hose 41, AFFIRMED and subscribed 10 bel .2 davof Nov. ,20 04,3, i'~i+'...' , , My C;~..~ 1. WHITE - tssumg Authority 2. PINK - Attorney 3. CANARY - Sherifrs Office 4. BLUE. She1itf's Office