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HomeMy WebLinkAbout12-3687 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AMY TAYLOR AVERY 431 Black Latch Lane Camp Hill, PA 17011 JULIANA GERIS 2956 Fort Lee Street Oak Hill, Virginia 20171 Plaintiffs GILBERT PROKOP, JR. 5237 Strathmore Drive Mechanicsburg, PA 17050 JAYME CASHMAN 5237 Strathmore Drive Mechanicsburg, PA 17050 LOUISE CARA ROSS 17 Glenwood Road Dillsburg, PA 17019 Defendants and File No: 12- 3 OV (21Vil?Cfwt v. Civil Action - Law and JURY TRIAL DEMANDED • tw rya MCX) C_ and -? rv - ?- ? --- ?. 777 PRAECIPE FOR ISSUANCE OF A WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a writ of summons in the above-captioned civil action. Respectfully Submitted, A?OM & KUTULAKIS, LLP Jaspn P. Ktttfl' A rney ID # 80411 2 West High Street Carlisle, PA 17013 (717) 249-0900 (os 41o3.15 PQ RWY 0#ya-75 &e d '7&CPs7 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AMY TAYLOR AVERY 431 Black Latch Lane Camp Hill, PA 17011 JULIANA GERIS 2956 Fort Lee Street Oak Hill, Virginia 20171 Plaintiffs GILBERT PROKOP, JR. 5237 Strathmore Drive Mechanicsburg, PA 17050 JAYME CASHMAN 5237 Strathmore Drive Mechanicsburg, PA 17050 LOUISE CARA ROSS 17 Glenwood Road Dillsburg, PA 17019 Defendants and V. and and File No: 12- 310bl C ivi Rerh Civil Action - Law JURY TRIAL DEMANDED WRIT OF SUMMONS You are notified that Amy Taylor Avery and Juliana Geris have commenced an action against you. Date: -bowie( iJ71?ueu Prothonotary Deputy Prothonotary IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AMY TAYLOR AVERY 431 Black Latch Lane Camp Hill, PA 17011 and JULIANA GERIS 2956 Fort Lee Street Oak Hill, Virginia 20171 Plaintiffs File No: 12- 3(0$7 C'?vi1?P.t'N'1 v. Civil Action - Law GILBERT PROKOP, JR. 5237 Strathmore Drive Mechanicsburg, PA 17050 and JURY TRIAL DEMANDED JAYME CASHMAN ; 5237 Strathmore Drive Mechanicsburg, PA 17050 and LOUISE CARA ROSS 17 Glenwood Road Dillsburg, PA 17019 Defendants WRIT OF SUMMONS You are notified that Amy Taylor Avery and Juliana Geris have commenced an action against you. Date: (o?loZ-?/o1 ha'jcl D "ut # Prothonotary jt".F'=te 1 AWj- Deputy Prothonotary IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION AMY TAYLOR AVERY 431 Black Latch Lane Camp Hill, PA 17011 JULIANA GERIS 2956 Fort Lee Street Oak Hill, Virginia 20171 Plaintiffs GILBERT PROKOP, JR. 5237 Strathmore Drive Mechanicsburg, PA 17050 JAYME CASHMAN 5237 Strathmore Drive Mechanicsburg, PA 17050 LOUISE CARA ROSS 17 Glenwood Road Dillsburg, PA 17019 Defendants and V. and and File No: 12- 310$7 CjvilTetr?n Civil Action - Law JURY TRIAL DEMANDED WRIT OF SUMMONS You are notified that Amy Taylor Avery and Juliana Geris have commenced an action against you. Date: //"/ bavid 17.- el Bt. Prothonotary 11-1"ZA'&'2."0.??"-'1- Deputy Prothonotary Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY4-_, of 4orr?b rn cn ? <G' ;r c-, G Ull Amy Taylor Avery vs. Case Number Gilbert Prokop, Jr. (et al.) 2012-3687 SHERIFF'S RETURN OF SERVICE 06/14/2012 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: Louise Cara Ross, but was unable to locate her in is bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Writ of Summons according to law. 06/29/2012 06:25 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 9, 2012 at 1825 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Jayme Cashman, by making known unto Gilbert Prokop, Jr., adult in charge at 5237 Strathmore Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the sa E time handing to him personally the said true and correct copy of the same. T BITNER, DEPUTY 06/29/2012 06:25 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 2012 at 1825 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Gilbert Prokop, Jr., by making known unto himself personally, at 5237 Strathmore D Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing him personally the said true and correct copy of the same. BITNER, 07/09/2012 York County Return: And now, July 9, 2012 I, Richard P. Keuerleber, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Louise Cara Ros the defendant named in the within Writ of Summons and that I am unable to find her in the County of Y rk and therefore return same NOT FOUND. Request for service at 17 Glenwood Road, Dillsburg, Pennsylvania 17019 the Defendant was not found. SHERIFF COST: $89.45 July 12, 2012 SO ANSWERS, NNY R ANDERSON, SHERIFF ,.C.? GvU^:'j SUit9 ^E?of nC. SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber PETER J. MA C Sheriff Reuben B Zeager Richard Chief Deputy, Operations Chief Deputy, A n AMY TAYLOR AVERY vs. Case Numb r GILBERT PROKOP, JR., ETAL (et al.) 12-3687 CI L SHERIFF'S RETURN OF SERVICE 06/26/2012 10:30 AM - DEPUTY MICHAEL DONOVAN, BEING DULY SWORN ACCORDING TO LAW, ATTEMPTED SERVICE TO THE DEFENDANT, TO WIT: LOUISE CARA ROSS AT 17 GLENWOOD ROAD, DILLSBURG, PA 17019. THE DEFENDANT WAS FOUND TO HAVE MOVED. 07/09/2012 I, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STA HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: LOUISE CARA ROSS, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED WRIT OF SUMMONS (WOSM) AS "NOT FOUND AT 17 GLENWOOD ROAD, DILLSBURG, PA 17019. PER POST OFFICE CHECK, MAILING ADDRESS IS P.O. BOX 572, DILLSBURG, PA 17019. WE NOT SERVE ATA P.O. BOX. SHERIFF COST: $130.45 SO ANVERS, July 09, 2012 RICFTARD P KEUERLEBER, NOTARY Affirmed and subscribed to before me this - i 9TH day of JULY 2012 ZIFF OM & YsUITULAKIS Jason P. Kutulakis, Esquire Attorney I.D. #: 80411 2 West High Street Carlisle, PA 17013 (717) 249-0900 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUN`T'Y, PENNSYLVANIA - CIVIL DIVISION AMY TAYLOR AVERY, and JULIANA GERIS PLAINTIFFS P. FILED-OFFICE O THE PROTHONOTAR" 2112 JUL 26 PM I : 3 7 CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION-LAW FILE NO. 12-3687 JURY TRIAL DEMANDED CARA ROSS DEFENDANTS RAA=RCIPE TO REISSUE X111 DE SINHOW TO THE PROTHONOTARY: Pursuant to Pa R.C.P. 401(b)(1), please reissue the Writ of Summons in the above- captioned matter. GILBERT PROKOP, JR., and JAYME CASHMAN, and Respectfully submitted, ABOM&KU?TILA"S, L.L.P. Date: It 2-- t D. Jason P. Kutulakis, Es, Attorney I.D. No. 804 2 West High Street Carlisle, PA 17013 (717) 249-0900 r IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNi,SYLVANI CIVIL DIVISION AMY TAYLOR AVERY 431 Black Latch Lane Camp Hill, PA 17011 JULIANA GERIS 2956 Fort Lee Street Oak Hill, Virginia. 20171 Plaintiffs GILBERT PROKOP, JR. 5237 Strathmore Drive Mechanicsburg, PA 17050 JAYME CASHMAN 5237 Strathmore Drive Mechanicsburg, PA 17050 LOUISE CARA ROSS 17 Glenwood Road Dillsburg, PA 17019 Defendants and V. and and File No: 12- 3(p$'J ??? 1 Civil Action - Law JURY TRIAL DEMANDED C? c t. y ?i ' rw C 9= c' -v rv n PRAECIPE FOR ISSUANCE OF A WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a writ of summons in the above-captioned civil action. Respectfully Submitted, 4AOM & KUTULAKIS, LLP Jasfn P. Kil?e- Arney ID # 80411 2 West High Street Carlisle, PA 17013 (717) 249-0900 c? CD U ?ABOM & KU l ULAKIS Jason P. Kutulakis, Esquire Attorney I.D. #: 80411 2 West High Street Carlisle, PA 17013 (717) 249-0900 T'CtC E 20,12 AUG -8 PM 2. 33 "UMERLAN'D Co a'11'1( PENNSYLVANIA IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLV - CIVIL DIVISION AMY TAYLOR AVERY, and JULIANA GERIS PLAINTIFFS V. GILBERT PROKOP, JR., and JAYME CASHMAN, and CARA ROSS CIVIL ACTION-LAW FILE NO. 12-3687 JURY TRIAL DEMANDED DEFENDANTS AND NOW, come the Plaintiffs, Amy Taylor Avery and Juliana Geris, by and through counsel, Jason P. Kutulakis, Esquire of ABOM & KUTULAKIS, L.L.P., and moves This Honc Court to enter an Order of Court allowing service of original process by publication, and in su] thereof avers the following: 1. On June 12, 2012, Plaintiff filed a Writ of Summons with This Honorable Court to ini an action against Gilbert Prokop, Jr., Jayme Cashman and Louise Cara Ross. 2. On June 12, 2012, undersigned counsel requested service of Original Process be made i Gilbert Prokop, Jr. and Jayme Cashman at 5237 Strathmore Drive, Mechanics Cumberland County, Pennsylvania by the Cumberland County Sheriffs department. IF 3. On June 12, 2012, undersigned counsel requested service of Original Process be made up Louise Cara Ross 17 Glenwood Road, Dillsburg, York County, Pennsylvania by the Y County Sheriffs department. 4. On June 29, 2012, a Writ of Summons was personally served upon Gilbert Prokop, Jr. 5237 Strathmore Drive, Mechanicsburg, Cumberland County, Pennsylvania. 5. On June 29, 2012, a Writ of Summons was served via adult in charge upon Jayme by leaving said document with Gilbert Prokop, Jr. at 5237 Strathmore Drive, Cumberland County, Pennsylvania. 6. The York County Office of the Sheriff attempted to serve Defendant, Louise Cara Ross at her last known address, 17 Glenwood Road, Dillsburg, Pennsylvania, three (5) times: J 18, 2012; June 19, 2012; June 21, 201.2; June 25, 2012 and June 26, 2012. 7. Call back cards were left at the residence on June 18, 2012, June 19, 2012, June 21, 2012 June 25, 2012 and received no response was received. 8. On June 26, 2012, the York County Office of the Sheriff attempted to serve Defenc Louise Cara Ross, at her last known address and was informed by the landlord that Ms. had been evicted approximately one (1) year prior. 9. On July 9, 2012, the Cumberland County Office of the Sheriff notified undersigned counsel that Defendant, Louise Cara Ross, could not be located. See, Sheriffs Return hereto as "Exhibit A." 10. On June 25, 2012, the United States Postal Service notified the York County Office of Sheriff that the mailing address for Ms. Ross at 17 Glenwood Road, Dillsburg, was P.O. Box 572, Dillsburg, Pennsylvania 17019. 11. Undersigned counsel has searched numerous free databases on the internet for addresses by which services may be made without success. I 12. The Plaintiff cannot serve Defendant, Louise Cara Ross, by the methods prescribed original process in the Pennsylvania Rules of Civil Procedure due to Defendant Ross of the York County Sheriff. 13. The Plaintiff respectfully requests This Honorable Court's permission to proceed service by publication pursuant to Pa.R.C.P. Rule 430. 14. If the relief requested is granted, the Plaintiff will publish notice in the York County Record and Dillsburg Banner in the form set forth in Pa.R.C.P. Rule 430(b)(1). WHEREFORE, the Plaintiff respectfully requests that This Honorable Court enter Order of Court allowing service by publication pursuant to Pa.R.C.P. Rule 430. Respectfully submitted, ABOM & KUTULA"S, LLP DATE: I ? ( " )l Jas n P. Kuthlakis, I No. 80411 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 4?,?1tfi of yet:r?Grr/,T?,4 Jody S Smith. _. _, . Chief Deputy Richard W Stewart SOi1CltOr Ci'rF? tE ,w 'F-;G ;`EP.IFF Amy Taylor Avery Case Numb r vs. 2012-3687 Gilbert Prokop, Jr. (et al.) SHERIFF'S RETURN OF SERVICE 06/14/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent se rch and inquiry for the within named defendant, to wit: Louise Cara Ross, but was unable to locate her i his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Writ of Summons according to law. 06/29/2012 06:25 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on Jun 29, 2012 at 1825 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Jayme Cashman, by making known unto Gilbert Prokop, Jr., adult in charge at 523 Strathmore Drive, Mechanicsburg, Cumberland County Pennsylvania 17050 its contents and at the am time handing to him personally the said true and correct copy of the same. ERT BITNER, 06/29/2012 06:25 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on Jun 29, 2012 at 1825 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Gilbert Prokop, Jr., by making known unto himself personally, at 5237 Strathmore Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handin to him personally the said true and correct copy of the same. n BITNER, 07/09/2012 York County Return: And now, July 9, 2012 I, Richard P. Keuerleber, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Louise Cara Ross the defendant named in the within Writ of Summons and that I am unable to find her in the County York and therefore return same NOT FOUND. Request for service at 17 Glenwood Road, Dillsburg, Pennsylvania 17019 the Defendant was not found. SHERIFF COST: $89.45 SO ANSWERS, July 12, 2012 R ANDERSON, SHERIFF !c} counfySuiie Sherff. Teleosofl. Inc. SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber PETER J. MA GAN, ESQ. Sheriff Solicitor Reuben B Zeager Richard E Rice, II Chief Deputy, Operations Chief Deputy, Administration AMY TAYLOR AVERY Case Numb r vs. 12-3687 CIVIL GILBERT PROKOP, JR., ET AL (et al.) SHERIFF'S RETURN OF SERVICE 06/26/2012 10:30 AM - DEPUTY MICHAEL DONOVAN, BEING DULY SWORN ACCORDING TO LAW, ATTEMPTED SERVICE TO THE DEFENDANT, TO WIT: LOUISE CARA ROSS AT 17 GLENWOC ROAD, DILLSBURG, PA 17019. THE DEFENDANT WAS FOUND TO HAVE MOVED. 07/0912012 I, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, S- HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: LOUISE CARA ROSS, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. T SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED WRIT OF SUMMONS (WOSM) A "NOT FOUND" AT 17 GLENWOOD ROAD, DILLSBURG, PA 17019. PER POST OFFICE CHECK, MAILING ADDRESS IS P.O. BOX 572, DILLSBURG, PA 17019. WE NOT SERVE AT A P.O. BOX. SHERIFF COST- $130.45 July 09, 2012 SO P --.0 She o ea/ uly N Yota ont co "I My Co y'` Tber, PennaNvan0Q(+.e_aFeb. 7.20,3 --- ....................... NOTARY Affirmed and subscribed to before me this 9TH day of JULY 2012 :,cuntySuite Sherit Teieosoft Inc CERTIFICATE OF SERVICE AND NOW, this ? day of August, 2012, I, Shannon Freeman, of Abom & LLP, hereby certify that I did serve a true and correct copy of the foregoing Motion for Service Publication by depositing, or causing to be deposited, same in the United States Mail, first mail, postage prepaid addressed to the following: Gilbert Prokop, Jr. 5237 Strathmore Drive Mechanicsburg, PA 17050 Jayme Cashman 5237 Strathmore Drive Mechanicsburg, PA 17050 Louise Cara Ross 17 Glenwood Road Dillsburg, PA 17019 Louise Cara Ross P.O. Box 572 Dillsburg, PA 17019 h' ?j C S neon Freema u IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA - CIVIL DIVISION AMY TAYLOR AVERY, and JULIANA GERIS PLAINTIFFS v. GILBERT PROKOP, JR., and JAYME CASHMAN, and CARA ROSS DEFENDANTS -3 CIVIL ACTION-LAW ~ =--' ' ~; ,~; --- _-^, ~ . -~ .,. FILE NO. 12-3687 ` - ~-~4 _~ -.,.~ .. .... :~~ ~:, ~~ . . JURY TRIAL DEMANDED ORDER OF COURT AND NOW, this /'/~ day ~~c wi '~ , 2012, pursuant to the Motion of Plaintiffs rimy Taylor Avery and Juliana Geris, by and through their counsel, Jason P. Kutulakis, Esquire of ABOM & KUTULAKIS, L.L.P., the Plaintiffs are hereby authorized to serve Defendants with original process by publication in the York County Legal Record and Dillsburg Banner in the manner set forth in Pa.R.C.P. Rule 430. Distribution• Jason P. Kutulakis, Esquire Abom & Kutulakis, L.L.P., 2 West High Street, Carlisle, PA 17013 J Gilbert Prokop, Jr. / 5237 Strathmore Drive ~/ Mechanicsburg, PA 17050 BY THIS COURT: / Jayme Cashman ,/ 5237 Strathmore Drive Mechanicsburg, PA 17050 Louise Cara Ross 17 Glenwood Road Dillsburg, PA 17019 Louise Cara Ross P.O. Box 572 Dillsburg, PA 17019 Ma~le~ CAP' aI,~I~D~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy PR0-rHCN(1 TAP 2012 SEP -b AM 10: 14 Richard W Stewart Solicitor 0I=p,'. CUMVERLAND COUEdl'` PENNSYLVANIA Amy Taylor Avery vs. Case Number . Gilbert Prokop, Jr. (et al.) 2012-3687 SHERIFF'S RETURN OF SERVICE 08/14/2012 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: Louise Cara Ross, 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. 08/21/2012 12:051 PM - York County Return: And now August 21, 2012 at 1205 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: Louise Cara Ross by making known unto Jamie Ross, Husband of Lousie Cara Ross at 35 Stoney Run Road, Apartment 23, Dillsburg, Pennsylvania 17019 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.45 SO ANSWERS, August 28, 2012 RON R ANDERSON, SHERIFF Ci ccun ySote Sh.c.- f, I eleo oif. In,.. SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber PETER J. MANGAN, ESQ. Sheriff Solicitor Reuben B Zeager Richard E Rice, li Chief Deputy, Operations Chief Deputy, Administration AMY TAYLOR AVERY Case Number vs. 12-3687 CIVIL GILBERT PROKOP, JR., ET AL (et al.) SHERIFF'S RETURN OF SERVICE 08/21/2012 12:05 PM - DEPUTY BRET NEWCOMER, BEING DULY SWORN ACCORDING TO LAW, SERVED THE RE UESTED WRIT OF SUMMONS (WOSM) BY HANDING A TRUE COPY TO A PERSON RE RESENTING THEMSELVES TO BE JAMIE ROSS, SPOUSE, WHO ACCEPTED AS "ADULT PE SON IN CHARGE" FOR LOUISE CARA ROSS AT 35 STONEY RUN ROAD, APARTMENT 23, DILLSBURG, PA 17019. SHERIFF COST: $46.87 August 23, 2012 ?? >I? .?teww?? BRET NEWCOMER, DEPUTY SO A S, RICHARD P KEU RLEB R, SHERIFF COMMONWEALTH OF PENNSYLVANIA Notarial Seal Shelia E. Cook, Notary Public Springettsbury Twp., York County My Cammtsbn Expires Feb. 1, 2013 Member, Pennsylvania Association of Notaries ---------- ---- -- --- - ----- - -- --- - -- -- _--- --- NOTARY Affirmed and subscribed to before me this 23RD day of AUGUST 2012 (c) Count,,Suite Sheriff, TeleoWo Inc.