Loading...
HomeMy WebLinkAbout13-2456 Supreme Cou' l �of�Pennsylvania Cou0f6f *C0�� o Pleas For Prothonotary Use Only: C1�i1 C�erjShdet bF g. a rr Docket No: T CU &INN6rN,0 C oun ty � � F � The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S 8 Complaint ER Writ of Summons ® Petition Q Transfer from Another Jurisdiction _;i Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: The Middletown Home Estate of Judy Phillips c/o Keystone Guardianship Servie � T Are money damages requested? Yes No Dollar Amount Requested: El within arbitration limits I (check one) outside arbitration limits N Is this a Class Action Suit? _ Yes El No Is this an MDJAppeal? © Yes ER No A Name of Plaintiff /Appellant's Attorney: Eric J. Bialas, Esq. 0 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 making 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 0 Intentional M Buyer Plaintiff Administrative Agencies Malicious Prosecution 0 Debt Collection: Credit Card El Board of Assessment Motor Vehicle xi Debt Collection: Other Q Board of Elections 0 Nuisance Unpaid nursing home bill r" Dept. of Transportation S Premises Liability d Statutory Appeal: Other Q Product Liability (does not include Employment Dispute: E mass tort) Discrimination L_I Slander/Libel/ Defamation C 0 Other: ( Employment Dispute: Other h Zoning Board T -J Other: I U Other: O MASS TORT Asbestos N 0 Tobacco -1 Toxic Tort - DES 0 Toxic Tort - Implarit REAL PROPERTY MISCELLANEOUS 0 Toxic Waste a Ejectment Common Law /Statutory Arbitration B J Other: Q Eminent Domain /Condemnation Declaratory Judgment _I Ground Rent Mandamus Q Landlord/Tenant Dispute Non - Domestic Relations F-11 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial l Quo Warranto 0 Dental 0 Partition ( Replevin lI Legal [ Quiet Title 0 Other: l3 Medical 0 Other: Q Other Professional: Updated 1/1/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION THE ODD FELLOWS HOME OF PENNSYLVANIA d /b /a THE MIDDLETOWN HOME, 999 West Harrisburg Pike �1�q5r_ �v( Middletown, PA 17057 : CASE NO. ((/ Plaintiff CIVIL ACTION- LAW AND EQUITY o C__ _ , THE ESTATE OF JUDY m�" PHILLIPS, incapacitated person, " :;o ­ rn by and through her guardian KEYSTONE GUARDIANSHIP r-- C C:) -rq SERVICES, 115 West Broad St.� Elizabethville, PA 17023'' Defendant -- PRAECIPE FOR ISSUANCE OF A WRIT OF SUMMONS To the Prothonotary: Kindly issue a writ of summons in the above case. Writ of summons shall be issued and forwarded to the ATTORNEY. Date Eric J. Bialas, Esquire Hynum Law 2608 North 3` Street Harrisburg, PA 17110 (717) 774 -1357 Supreme Court ID #312326 Attorney for Plaintiff 80\ 31 WRIT OF SUMMONS TO: JUDY PHILLIPS by and through her guardian KEYSTONE GUARDIANSHIP SERVICES. YOU ARE NOTIFIED THAT THE ABOVE -NAMED PLAINTIFF(S) HASMAVE COMMENCED AN ACTION AGAINST YOU. �u' Prothonotary/Clerk, Civil Division Date: \ J by Deputy THE PRO TH Ohl cc T AR Z�13 Pik �' Eric J. Bialas, Esquire -3 P H 2 3 Supreme Court ID #312326 CU MBERLAND 2608 N. Third Street CQ j f,� �' Y Harrisburg, PA 17110 P E NNSYLVA N IA (717) 774 -1357 Attomey for Plaintiff THE ODD FELLOWS HOME OF IN THE COURT OF COMMON PLEAS PENNSYLVANIA d /b /a CUMBERLAND COUNTY, PENNSYLVANIA THE MIDDLETOWN HOME, 999 West Harrisburg Pike Middletown, PA 17057 Plaintiff V. NO. THE ESTATE OF JUDY PHILLIPS, incapacitated person, CIVIL ACTION - LAW by and through her guardian KEYSTONE GUARDIANSHIP SERVICES 115 West Broad St. Elizabethville, PA 17023 Defendant PRAECIPE FOR LIS PENDENS TO THE PROTHONOTARY: Please issue a Lis Pendens against the real property owned by the Estate of Judy Phillips at 743 Manor Road, Camp Hill, Cumberland County, Pennsylvania, 17011. The Deed book number for the Recorder of Deed's Office of Cumberland County, PA is recorded as 00161 - 00442. The Parcel Identification Number is 09 -18- 1304 -069. 12�aa�3a I hereby certify that this action affects title to or other interest in the above - described property and is a proceeding of which purchasers of the described real property should have constructive notice. J Date: a �� Eric J. Bialas, Esquire Attorney ID 312326 Hynum Law 2608 N. Third Street Harrisburg, PA 17110 (717) 774 -1357 Attorney for the Plaintiff D-Q ICE Eric J.Bialas,Esquire Supreme Court ID#312326 OF THE PROTHONOTAR'f 2608 N.Third Street 2013 JUN —3 Pn 2: 3 7 Harrisburg,PA 17110 (717)774-1357 CUMBERLAND COUNTY Attorney for Plaintiff PENNSYLVANIA THE ODD FELLOWS HOME OF IN THE COURT OF COMMON PLEAS PENNSYLVANIA d/b/a CUMBERLAND COUNTY, PENNSYLVANIA THE MIDDLETOWN HOME, Plaintiff V. NO. 13-2456 CIVIL THE ESTATE OF JUDY PHILLIPS, incapacitated person, CIVIL ACTION- LAW AND EQUITY by and through her guardian KEYSTONE GUARDIANSHIP SERVICES Defendant ACCEPTANCE OF SERVICE 1, David Stone, Esq., counsel for Keystone Guardianship Services, accept service and acknowledge receipt of the Writ of Summons filed on May 3, 2013 for t ab ve matter. Date: Da id Ston s St Fever Stone S�a ine LaFever& eketski Pa Bar. No. 39785 414 Bridge Street New Cumberland,PA 17070 (717) 774 7435 THE ODD FELLOWS HOME OF : PENNSYLVANIA d /b /a THE MIDDLETOWN HOME, 999 West Harrisburg Pike Middletown, PA 17057 Plaintiff v. THE ESTATE OF JUDY PHILLIPS, incapacitated person, : by and through her guardian : KEYSTONE GUARDIANSHIP SERVICES 115 West Broad St. Elizabethville, PA 17023 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 13 -2456 CIVIL ACTION - LAW PRAECIPE TO WITHDRAW LIS PENDENS TO THE PROTHONOTARY: Kindly withdraw the Lis Pendens issued against the real property owned by the Estate of Judy Phillips at 743 Manor Road, Camp Hill, Cumberland County, Pennsylvania, 17011. The Deed book number for the Recorder of Deed's Office of Cumberland County, PA is recorded as 00161 - 00442. e P . rcel Identification Number is 09-18-1304-069. Date: ,Z 71 26/y Eric J. Bialas, Esquire Attorney ID 312326 Hynum Law 2608 N. Third Street Harrisburg, PA 17110 (717) 774 -1357 Attorney for the Plaintiff eA_A aa-)% V___-kt 36 3cat o CERTIFICATE OF SERVICE On this 27th day of March, 2014, I certify that a copy of the foregoing Praecipe to Withdraw Lis Pendens was served upon Defendant or their counsel by placing the same in the United States mail, first class, postage prepaid, addressed as follows: David Stone, Esq. Stone LaFever & Sheketski 414 Bridge Street New Cumberland, PA 17070 Attorney for Keystone Guardianshi ice Eric J. Bialas, Esquire 2608 North 3rd Street Harrisburg, PA 17110 Supreme Court ID #312326 (717) 774 -1357 Attorney for Plaintiff