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Home My WebLink About13-4367 Supreme Co u } k a o.: Pennsylvania r Cou of. "Pleas For Prothonotary Use Only: G ii- CoyerxS-h WIr - . ° Docket No: 0 -�- County /3 - The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by lmv or rules of court. Commencement of Action: S Complaint Writ of Summons n Petition Transfer from Another Jurisdiction 0 Declaration of Taking E. C Lead Plaintiff s Name: Lead Defendant's Name: T V� t r-Ll b �J�t113 V l �T Z� L l I Are money damages requested? &Yes El No Dollar Amount Requested: within arbitration limits O (check one) Eloutside arbitration limits N Is this a Class Action Suit? Yes AKJ No Is this an MDJAppeal? Q Yes 0 No A Name of Plaintiff /Appellant's Attorney: W t V&VL V _D L VCK/ ) Check here if you have no attorney (are n Self-Represented [Pro Se] Litinant} 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 F1 Buyer Plaintiff Administrative Agencies Malicious Prosecution El Debt Collection: Credit Card Board of Assessment r Motor Vehicle 0 Debt Collection: Other Q Board of Elections F7 Nuisance Dept. of Transportation Premises Liability El Statutory Appeal: Other S Product Liability (does not include E mass fort) Employment Dispute: Slander/Libel/ Defamation Discrimination C Q Other: n Employment Dispute: Other Q Zoning Board 'j' ED Other: I [] Other: O MASS TORT El Asbestos N 0 Tobacco [] Toxic Tort - DES E] Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS E] Toxic Waste Q Other: El Ejectment Q Common Law /Statutory Arbitration B El Eminent Domain /Condemnation n Declaratory Judgment 0 Ground Rent 0 Mandamus Landlord /Tenant Dispute [] Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY n Mortgage Foreclosure: Commercial El Quo Warranto M Dental n Partition Q 0 Replevin Legal n Quiet Title 0 Other: Medical Q Other: Other Professional: Updated 1/1/2011 NICHOLAS J. GIAMBILIS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNA. Vs. NO VICTOR PEREZ - ZALATELCO and L L l 3 -7 - FVM PARTNERS, LLC PRAECIPE FOR WRIT OF SUMMONS To the Prothonotary: Please issue writ of summons against Victor Perez - Zalatelco and FVM Partners, LLC. C v� William A. Duncan, Esquire DUNCAN & HARTMAN, P.C. Attorney for Plaintiff ID # 22080 1 Irvine Row, Carlisle, PA 17013 717- 249 -7780 CZ Victor Perez - Zalatelco and - a z w :„ L FVM Partners, LLC ;z P1 1237 Lowther Street Camp Hill, PA 17011 Nicholas J. Giambilisan r 7 Graham Road Newville, PA 17241 a-93 �� Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS Court of Common Pleas NICHOLAS J. GIAMBILIS Plaintiff Vs. No. 13 -4367 CIVIL TERM VICTOR PEREZ - ZALATELCO and FVM PARTNERS, LLC 1237 LOWTHER STREET CAMP HILL, PA 17011 In CivilAction -Law To: VICTOR PEREZ - ZALATELCO and FVM PARTNERS, LLC You are hereby notified that the Plaintiff, NICHOLAS J. GIAMBILIS, has commenced an action in Civil Action -Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) David D. Buell, Prothonotary Date July 26, 2013 Deputy Attorney: WILLIAM A. DUNCAN, ESQ. Address: DUNCAN & HARTMAN, P.C., 1 IRVINE ROW, CARLISLE, PA 17013 Attorney for: Plaintiff Telephone: 717 - 249 -7780 Supreme Court ID No. 22080 THE PROTHONOTARY' 2013 AUG 30 AM f:.f z T RE: Nicholas J. Giambilis CUMBERLA140 COUNTY Plaintiff PENNSYLVANIA No. 13-4367 CIVIL TERM vs. Victor Perez-Zalatelco and FVM Partners, LLC ACCEPTANCE OF SERVICE I, William C. Kollar, Attorney for Defendants in above captioned matter, do hereby accept service of the WRIT OF SUMONS issued by the Cumberland County Prothonotary's Office in o•M., this matter on day of , 2013. William C. Kollas, Attorney for Defendants i SWORN TO AND SUBSCRIBED before me, the day and year aforesaid. FNOTARIAL SEAL CAROLE A ROSE LQ 0, Notary Public Notary Public LOWER LLEN TWP.CUMBERLAND CNTY y mmission Expirts Dec 6,2015 i I I 1 NICHOLAS J. GIAMBILIS, Plaintiff V. VICTOR PEREZ-ZALATELCO and FVM PARTNERS, LLC Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 13-4367 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 T' As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, NICHOLAS J. GIAMBILIS, Plaintiff, certifies that (1) a notice of intent to serve the subpoena with a copy of the subpoena attached with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty (20) days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date: William • D ncan, Esq. Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NICHOLAS J. GIAMBILIS Plaintiff File No. VICTOR PEREZ—ZA,ITELCO and FVM PARTNERS, LLC Defendant 13-4367 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DENISE .CASS, REALTOR — HIGH ASSOCIATES (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All files and. documents related to the listing, sale and settlement of Yankee Doodle Diner from Aly M. Aly t/d/b/a as New Riverview Diner to Victor Perez—Zalatelco and FVM Partners, LLC, together with all Leases pertaining thereto :.r. . at 1 Irvine Row, Carlisle, PA 17013 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: William A. Duncan, Esq. ADDRESS: 1 Irvine Row Carlisle, PA 17013 TELEPHONE: 717-249-7780 SUPREME COURT ID # 22080 ATTORNEY FOR: Nicholas J. Giainbilis BY THE COURT . ILAlb Prothonotary, Civil Division NICHOLAS J. GIAMBILIS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNA. V. NO. 13-4367 VICTOR PEREZ-ZALATELCO and FVM PARTNERS, LLC Defendant NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Nicholas J. Giambilis, Plaintiff, intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: l William Dunc. , Esq., Attorney NICHOLAS J. GIAMBILIS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNA. V. NO. 13-4367 VICTOR PEREZ-ZALATELCO and FVM PARTNERS, LLC Defendant CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, DENISE CASS, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the subpoena issued on have been produced. Date: DENISE CASS