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HomeMy WebLinkAbout13-1483 l ✓ L_I � ; i Andrew C. Spears, Esquire Attorney ID# 87737 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road, Suite 2 Harrisburg, PA 17110 Telephone: (717) 238 -2000 Attorney for Plaintiffs Fax : (717) 233 -3029 E -mail: Spears @hhrlaw.com IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2013 q p DV I j Civil Action (XX) Law Nora Yanc and Timothy Yanc, her Christine Eberts Husband 1355 Old Quaker Road 835 Erford Road Etters, PA 17319 Camp Hill, PA 17011 versus West Shore School District 507 Fishing Creek Road New Cumberland, PA 17070 Plaintiffs & Address Defendants & Addresses PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT Please Issue A Writ of Summons in the above - captioned action. X _ Writ of Summons Shall be issued and forwarded to ( )Attorney (XX)Sheriff Andrew C. Spears Esquire Handler Henning & Rosenberg LLP 1300 Linglestown Road Suite 2 Harrisburg PA 17110 Signature 8T _(717 2 -20 00 Supreme Court ID No. 87737 Narne /Address /Telephone No. of Attorney Date: March 18. 2013 a WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANTS: YOU ARE NOTIFIED THAT THE ABOVE -NAMED PLAINTIFFS HAVE COMMENCED AN ACTION AGAINST YOU -I Prothonotary Date Deputy Cheer, here if reverse Is used for additional information PR07 HON - 5 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson f ILED-UF Fr iCE Sheriff OF THE PROTNoN0TAR'i Jody S Smith 15 � 9: 23 Chief Deputy t* Richard w Stewart CUMBERLA COUNTY Solicitor 0" T s►�Rtrfi PENHS' It„ A llA Nora J. Yanc(et al.) vs. Case Number Christine Eberts(et al.) 2013-1483 SHERIFF'S RETURN OF SERVICE 03/22/2013 Sheriff Ronny R Anderson, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit:West Shore School District, but was unable to locate the Defendant in the Sheriff's bailiwick.The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Writ of Summons according to law. 03/22/2013 Sheriff Ronny R Anderson, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit: Christine Eberts, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Writ of Summons according to law. 03/28/2013 09:40 AM-The requested Writ of Summons served by the Sheriff of York County upon Don Zimmerman, Coordinator of Child Safety,who accepted for West Shore School District, at 507 Fishing Creek Road, New Cumberland, PA 17070. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. 04/01/2013 09:05 AM-The requested Writ of Summons served by the Sheriff of York County upon Christine Eberts, personally, at 6 Sarah Drive, Dover, PA 17315. Richard P. Keuerieber, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST:$53.46 SO ANSWERS, April 11, 2013 RON R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc, SHERIFF'S OFFIdE OF YORK COUNTY Richard P Keuerleber PETER J.MANGAN, ESQ. Sheriff solicitor Reuben S Zoagler Richard E Rice,11 Chief Deputy, Operations Chief Deputy,Administration NORA YANC(et al.) Case Number vs. 2013-1483 CIVIL CHRISTINE EBERTS let al.) SHERIFF'S RETURN OF SERVICE 03/28/2013 09:40 AM-DEPUTY MICHAEL DONOVAN, BEING DULY SWORN ACCORDING TO LAW,SERVED THE REQUESTED WRIT OF SUMMONS(WOSM)BY HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE DON ZIMMERMAN, COORDINATOR CHILD SAFTY, WHO ACCEPTED AS"ADULT PERSON IN CHARGE"FOR WEST SHORE SCHOOL DISTRICT AT 507 FISHING CREEK ROAD, NEW CUMBERLAND, PA 17070. MICHAEL 12110NOVAN, DEPUTY 04101/2013 09:06 AM-DEPUTY TODD STAHL, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED WRIT OF SUMMONS(WOSM)BY""PERSONALLY"HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT,TO WIT: CHRISTINE ESERTS AT 1355, OLD QUAKER ROAD, ETTERS, PA 17319. O * C3 STA L, DE SHERIFF COST. $84.12 1 AS ACTING SHERIFF FOR April 08,2013 RICHARD P KEUERLEBER, SHERIFF gAMwNftMj OF fflffi ftLvw Nnts in!SIM Shaft L C=k NftV PW* OW of Yo*.Yak 01N* jMft:L=7 -------------- NOTARY X, Affirmed and subscribed to before me this 8TH day of APRIL 2013 ic)CountySuile Sheriff,Teleosoft Inc t HE PRO T'HONUTAR f` 2013 APR 22 P11 U PENR�'AN0 COUNTY PENNSYLVANIA MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Donald L. Carmelite, Esquire ID No. 84730 4200 Crums Mill Road Harrisburg, PA 17112 717-651-3504 Our File No. 15064-00479 Attorney for Defendants NORA YANC and TIMOTHY YANC COURT OF COMMON PLEAS her husband CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs No. 2013-1483 VS. CHRISTINE EBERTS and WEST SHORE CIVIL ACTION—LAW SCHOOL DISTRICT JURY TRIAL DEMANDED Defendants PRAECIPE FOR A RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Kindly issue a Rule directing Plaintiffs,Nora Yanc and Timothy Yanc, to file a Complaint in the above- referenced matter within twenty (20) days of service thereof or risk a judgment of non pros. MARSHALL'DENNEHEY WARNER COLEMAN & GOGGINN By: Donald L. Carmelite, Esquire Attorney for Defendant ID# 84730 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 Dated: April 19, 2013 717-651-3504 MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Donald L. Carmelite, Esquire ID No. 84730 4200 Crums Mill Road Harrisburg, PA 17112 717-651-3504 Our File No. 15064-00479 Attorney for Defendants NORA YANC and TIMOTHY YANC COURT OF COMMON PLEAS her husband CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs No. 2013-1483 VS. CHRISTINE EBERTS and WEST SHORE CIVIL ACTION—LAW SCHOOL DISTRICT JURY TRIAL DEMANDED Defendants RULE AND NOW, this ova day of rl , 2013, upon consideration of the foregoing Praecipe, Plaintiffs, Nora Yanc and Timothy Yanc, are hereby ordered to file a Complaint within twenty (20) days hereof or suffer judgment of non pros. BY THE PROT ONOTARY: By: �� MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Donald L. Carmelite, Esquire ID No. 84730 4200 Crums Mill Road Harrisburg, PA 17112 717-651-3504 Our File No. 15064-00479 Attorney for Defendants NORA YANC and TIMOTHY YANC COURT OF COMMON PLEAS her husband CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs No. 2013-1483 VS. CHRISTINE EBERTS and WEST SHORE CIVIL ACTION—LAW SCHOOL DISTRICT JURY TRIAL DEMANDED Defendants CERTIFICATE OF SERVICE I, Donald L. Carmelite, Esquire, of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on April 19, 2013, a copy of Defendants' Rule for Complaint via First Class United States mail,postage prepaid as follows: Andrew C. Spears, Esquire Handler Henning & Rosenberg, LLP 1300 Linglestown Road, Suite 2 Harrisburg, PA 17110 Attorney for Plaintiff Donald L. Carmelite �f E I-t . t'r,JT, OtQ7rrt 211I3 OCT 18 P I: 5 9 CUMBERLAND COUNTY PENNSYLVANIA NORA YANC and TIMOTHY YANC • COURT OF COMMON PLEAS her husband • CUMBERLAND COUNTY, PENNSYLVANIA • Plaintiffs : No. 2013-1483 vs. • CHRISTINE EBERTS and WEST SHORE : CIVIL ACTION—LAW SCHOOL DISTRICT • JURY TRIAL DEMANDED Defendants • PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-referenced matter as SETTLED, DISCONTINUED and ENDED with Prejudice. Respectfully submitted, Handler Henning & Rosenberg, LLP By: Andrew . Spears, Esquire 1300 Linglestown Road, Suite 2 Harrisburg, PA 17110 Attorney for Plaintiffs Dated: 10 I tr`t3 }, Andrew C.Spears,Esq. Attorney ID#87737 HANDLER,HENNING&ROSENBERG,LLP 1300 Linglestown Road,Suite 2 Harrisburg,PA 17110 Telephone: (717)238-2000 Attorney for Plaintiffs Fax: (717)233-3029 E-mail: Spears @hhrlaw.com NORA YANC and TIMOTHY YANC,her • IN THE COURT OF COMMON PLEAS Husband, • CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs • v. • NO. 2013-1483 Civil CHRISTINE EBERTS and WEST SHORE SCHOOL DISTRICT, • CIVIL ACTION-LAW Defendants • CERTIFICATE OF SERVICE On this 17th day of October, 2013, I hereby certify that a true and correct copy of Plaintiffs' Praecipe to Settle, Discontinue and End was served upon the following by depositing same in the United States Mail, in Harrisburg,Pennsylvania: Allison Domday, Esquire Marshall,Dennehey, Warner,Coleman&Goggin 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 Attorney for Defendants HANDLER,HENNING&ROSENBERG,LLP • Andrew C.c'EstftliS , ire I.D.No.: 87737 Attorney for Plaints