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HomeMy WebLinkAbout13-2406 Supreme Cou wo ;Rennsylvania Cour �of C P leas For Prothonotary Use Only: C't' a S Docket No: � ST CUMB E R LANO`J County d The information collected on this fibrin is used solely for court administration purposes. This form does not supplement or replace th filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S 0 Complaint El Writ of Summons ® Petition E Transfer from Another Jurisdiction 0 Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T GERALDINE HOCKENBERRY MARCUS A. MCKNIGHT, III , X r Dollar Amount Requested: ®within arbitration limits I Are money damages requested. ( Yes N (check one) ,x outside arbitration limits 0 N Is this a Class Action Suit? 0 Yes M No Is this an MDJAppeal? Yes Rx No A Name of Plaintiff /Appellant's Attorney: VINCENT M. MONFREDO, ESQ. Check here if you have no attorney (are a Self- Represented (Pro Se) Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are snaking more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS Intentional 0 Buyer Plaintiff Administrative Agencies Malicious Prosecution 0 Debt Collection: Credit Card 0 Board of Assessment Motor Vehicle Debt Collection: Other 0 Board of Elections 0 Nuisance 0 Dept. of Transportation S 0 Premises Liability 0 Statutory Appeal: Other ® Product Liability (does not include E mass tort) [3 Employment Dispute: 0 Slander/Libel/ Defamation Discrimination C 0 Other: 0 Employment Dispute: Other 0 Zoning Board T ® Other: ® Other: O MASS TORT 0 Asbestos N 0 Tobacco 0 Toxic Tort - DES 0 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste 0 Other: 0 Ejectment 0 Common Law /Statutory Arbitration 0 Eminent Domain /Condemnation 0 Declaratory Judgment 0 Ground Rent 0 Mandamus 0 Landlord /Tenant Dispute 0 Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto ® Dental 0 Partition 0 Replevin Legal 0 Quiet Title 0 Other: 0 Medical 0 Other: 0 Other Professional: Updated 1/112011 GERALDINE HOCKENBERRY IN THE COURT OF COMMON PLEAS OF individually and in her capacity as the : CUMBERLAND COUNTY, PENNSYLVAN Executrix of the Estate of WALTER BELCHER, Plaintiff vs. : CIVIL ACTION - LAW MARCUS A. McKNIGHT, III individually and in his capacity as a licensed attorney in the state of Pennsylvania and IRWIN & McKNIGHT P.C. a professional corporation, Defendants : JURY TRIAL DEMANDED �� ���. f om en ��• _ � 3 rn cc Car !�'s l e �Irl J ? � / PRAECIPE FOR WRIT O b" rn -...' TO THE PROTHONOTARY OF CUMBERLAND COUNTY- CD Please issue a writ of summons in the above captioned action. Writ of Summons shall be issued and forwarded to undersigned Attorney for service on the above captioned defendants. Date: Respectfully submitted, ROMINGER & ASSOCIATES Vincent M. Monfredo, Esquire 5000 Ritter Rd. Suite 202 Mechanicsburg, PA 17055 (717) 585 -2064 Supreme Court ID #206671 WRIT OF SUMMONS To The Above Named Defendants: YOU ARE NOTIFIED THAT THE ABOVE -N COMMENCED AN ACTION AGAINST YOU. L TIFF HAS P notary Date: J Cr By: Deputy -' GERALDINE HOCKENBERRY, : IN THE COURT OF COMMON PLEAS individually and in her capacity as the : CUMBERLAND COUNTY, PENNSYLVANIA Executrix of the Estate of ; WALTER BELCHER Plaintiff VS. : CIVIL ACTION - LAW NO: 2013-CV-2406-CV MARCUS A. McKNIGHT, III individually and in his capacity as a licensed attorney in °r the state of Pennsylvania and '-= IRWIN &McKNIGHT P.C. (/)r- a professional corporation r- --r;' Defendants : JURY TRIAL DEMANDED C- iz TO THE PROTHONOTARY: - PRAECIPE TO RE-ISSUE WRIT OF SUMMONS To the Prothonotary: Please re-issue a writ of summons in the above captioned action. Writ of Summons shall be issued and forwarded to Cumberland County Sheriff for service on the above captioned defendants at the following address: 60 W Pomfret St Carlisle, PA 17013 Date: f Respectfully submitted, ROMINGER & ASSOCIATES Vincent M. Monfredo;.Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID #206671 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-OFTICE Sheriff Oil- THE PRVHONO TAI,". Jody S Smith Chief Deputy 2013 JUN .14 PM 3' 95 Richard W Stewart CUMKRLAND COUNT Solicitor OFFCt OF THE VERIFF PENNSYLVANIA Geraldine Andrea Hockenberry Case Number vs. Marcus A McKnight, III (et al.) 2013-2406 SHERIFF'S RETURN OF SERVICE 06/10/2013 11:20 AM-Deputy William Cline, being duly sworn according to law, served the requested Writ of Summons by handing a true copy to a person representing themselves to be Sharon Schwalm, Office Assistant,who accepted as"Adult Person in Charge"for Irwin&McKnight P C t t West Pomfret Street, Carlisle Borough, Carlisle, PA 17013. WILLIAM CLINE, DEPUTY 06/10/2013 11:20 AM-Deputy William Cline, being duly sworn according to law, served the requested Writ of C Summons by handing a true copy to a person representing themselves to be Sharon Schwalm, Office Assistant, who accepted as"Adult Person in Charge"for Marcus A McKnight, III at Irwin& McKnight PC, 60 West Pomfret Street, Carlisle, PA 17013. 41Am ICLIN ,7M701"F SHERIFF COST: $51.24 SO ANSWERS, June 12, 2013 RbNW R ANDERSON, SHERIFF (0)CountySujto Shariff,Teleosoft,lnc. MARSHALL DENNEHEY WARNER COLEMAN&GOGGIN ;., R'0 r. Edwin A.D. Schwartz, Esquire PA Attorney ID# 75902 201113 J N 28 Pitt 2: 4,O Nicole M. Ehrhart,Esquire PA Attorney ID#200538 CUMBERLAND COUNTY 4200 Crums Mill Road, Suite B PENNSYLVANIA Harrisburg,PA 17112 717-651-3700 Email: easchwartz@mdwcg.com Attorney for Defendant GERALDINE HOCKENBERRY, IN THE COURT OF COMMON PLEAS OF individually and in her capacity as the CUMBERLAND COUNTY, PENNSYLVANIA Executrix of the ESTATE OF WALTER BELCHER, NO. 13-2406 Plaintiff CIVIL ACTION—LAW V. JURY TRIAL DEMANDED MARCUS A. McKNIGHT, III,and IRWIN & McKNIGHT, P.C., Defendants ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance on behalf of Marcus A. McKnight, III, and Irwin& McKnight, P.C., in the above-captioned matter. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN Date: �3 By: Edwin A.D. Schwartz, Esqui PA Attorney ID# 75902 Nicole M. Ehrhart, Esquire PA Attorney ID# 200538 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 717-651-3700 Email: easchwartzgmdwcg_com CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first-class postage prepaid, addressed as follows: Vincent M. Monfredo, Esquire The Law Office of Vincent M. Monfredo 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 MARSHALL, DENNEHEY,WARNER, COLEMAN & GOGGIN Date: By: EDWIN A.D. SCHWARTZ, IRE Attorney ID 75902 NICOLE M. EHRHART, ESQUIRE Attorney ID 200538 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3700 easchwartz @mdwcg.com GERALDINE HOCKENBERRY individually and in her capacity as the Executrix of the Estate of WALTER BELCHER, Plaintiff : IN THE COURT OF COMMON PLEASE OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO: 13-2406 MARCUS A. McKNIGHT, III, individually : and in his capacity as a licensed attorney in : the state of Pennsylvania and IRWIN & McKNIGHT P.C. a professional corporation, Defendants : JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please discontinue, settle and end the above captioned matter with prejudice. Respectfully submitted, Vincent M. Monfredo, Esquire Supreme Court ID # 206671 5000 Ritter Rd. Suite 202 Mechanicsburg, PA 17055 (717) 585-2064 Dated: Z' GERALDINE HOCKENBERRY : IN THE COURT OF COMMON PLEASE OF individually and in her capacity as the : CUMBERLAND COUNTY, PENNSYLVANIA Executrix of the Estate of WALTER BELCHER, Plaintiff : CIVIL ACTION - LAW v. : NO: 13-2406 MARCUS A. McKNIGHT, III, individually : and in his capacity as a licensed attorney in : the state of Pennsylvania and IRWIN & McKNIGHT P.C. a professional corporation, Defendants : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Vincent M. Monfredo, Esquire, attorney for Plaintiff, do hereby certify that a copy of the within Praecipe to Discontinue was served upon the following individual on the below date, by first class mail, addressed as follows: Edwin A. Schwartz, Esq. 4200 Crums Mill Rd. Suite B Harrisburg, PA 17112 Respectfully submitted, Vincent M. Monfredo, Esquire Supreme Court ID # 206671 5000 Ritter Rd. Suite 202 Mechanicsburg, PA 17055 (717) 585-2064 Dated: S