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
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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