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Home My WebLink About13-5058 Supreme Coin t of`Pe r ". � For Prothonota Use O nly: Cour, NICo ^ mmornPleas ry v ?� I. l Co er CiviV et ` � _ r, Docket No: T CUM - RL'AND G 1 :. ►. � :� County 13 5_(J � C �� V Z i The information collected on this form is used solely court administration purposes. This form does not supplement or replace the filing and sen)ice ofpleadings or other papers as required by law or rules ofcourt. Commencement of Action: S 0 Complaint 0 Writ of Summons Petition Cl Transfer from Another Jurisdiction 0 Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: DAN PARSON MICHAEL E. SHIPE T Dollar Amount Requested: 0within arbitration limits I Are money damages requested? ED Yes No Y g 9 (check one) Ix' outside arbitration limits 0 N Is this a Class Action Suit? 0 Yes R No Is this an MDJAppeal? ® Yes [@ No A Name of Plaintiff /Appellant's Attorney: VINCENT M. MONFREDO, ESQUIRE 0 Check here if you have no attorney (are a Self - Represented [Pro Se] Litigant) L 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 inctude.hidgments) CIVIL APPEALS 0 Intentional 0 Buyer Plaintiff Administrative Agencies Cl Malicious Prosecution 3 Debt Collection: Credit Card 0 Board of Assessment 0 Motor Vehicle ❑ Debt Collection: Other 0 Board of Elections rij Nuisance 0 Dept. of Transportation 0 Premises Liability 0 Statutory Appeal: Other S 01 Product Liability (does not include mass tort) El Employment Dispute: E U Slander/Libel /Defamation Discrimination 0 C J Other: Employment Dispute: Other 0 Zoning Board Other: T I pl Other: O MASS TORT C! Asbestos N 0 Tobacco 0 Toxic Tort -DES i Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑� Toxic Waste Ejectment 0 Common Law /Statutory Arbitration Q Other: Eminent Domain /Condemnation 0 Declaratory Judgment B 1 Ground Rent 0 Mandamus E Landlord /Tenant Dispute 0 Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY El Mortgage Foreclosure: Commercial 0 Quo Warranto 0 Dental Partition 0 Replevin 0 Legal 0 Quiet Title !IJI Other: 0 Medical ❑ Other: ❑ Other Professional: Updated 1/1/2011 DANIEL PARSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW MICHAEL E. SHIPE and MIRIAM V. SHIPE Defendants : JURY TRIAL DEMANDED: `oz w PRAECIPE FOR WRIT OF SUMMONS "� cr% S:_ To the Prothonotary: CD Please issue a writ of summons in the above captioned action. Writ of Summons shall be issued and forwarded to the Sheriff of Cumberland County at One Courthouse Square, Carlisle, Pennsylvania 17013. Date: August 26, 2013 Respectfully submitted, ROMIN ER & AA�SSOCIATES Vincent M. Monfredo, Esquire 155 South Hanover Street 91 l 7 S' d Carlisle, PA 17013 (717) 241 -6070 Supreme Court ID # 206671 C'v�, 3 s� A WRIT OF SUMMONS y y�ya To The Above Named Defendants: Michael E. Shipe Miriam V. Shipe 4 Westminster Court 4 Westminster Court Carlisle, PA 17013 Carlisle, PA 17013 YOU ARE NOTIFIED THAT THE ABOVE -NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. 0, �( �, 12U_e ll - Prothonotary Date: x-111 3 BY' eputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson +'?= Sheriff kN,%v PA TI , Jody S Smith Chief Deputy ��"� '013 SEP 25 AM 11- 42 Richard W Stewart M Solicitor OFFiCECi, THE CUMBERS AMD G001"', PEN14SYLVI"'A Daniel F Parson, Jr Case Number vs. 2013-5058 Michael Shipe (et al.) SHERIFF'S RETURN OF SERVICE 09/13/2013 04:39 PM- Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Miriam V Shipe, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Summons as"Not Served" at 12 Westminster Court, North Middleton, Carlisle, PA 17013. Per defendant's daughter the defendant is deceased. 09/20/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Michael Shipe, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Writ of Summons as"Not Found"at 12 Westminster Court, North Middleton, Carlisle, PA 17013. Per the defendant's mother the defendant is in SCI Retreat which is located in Luzerne County. SHERIFF COST: $58.02 SO ANSWERS, L� - September 20, 2013 RbNW R ANDERSON, SHERIFF ic?CountySuite Sheriff,Teleosott.Inc. DANIEL PARSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : NO: 13-5058 MICHAEL E. SHIPE and • f w MIRIAM V. SNIPE m ` ;Defendants : JURY TRIAL DEMANDED ,.a' PRAECIPE TO REISSUE WRIT OF SUMMONS To the Prothonotary: Please reissue the attached writ of summons in the above captioned action. Writ of Summons shall be issued and forwarded to Vincent M. Monfredo, Esquire at Rominger& Associates located at 155 South Hanover Street, Carlisle, PA 17013. Date: October 22, 2013 Respectfully submitted, ROMINGER& ASSOCIATES /�f incent M. Monfredo, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID #206671 4-ll. r7C170/ 7i WRIT OF SUMMONS e (3 Cl/ To The Above Named Defendants: Michael E. Shipe 1"'z Inmate#KK7157 Miriam V. Shipe SCI Retreat 4 Westminster Court 660 State Route 11 Carlisle, PA 17013 HunLock Creek, PA 18621 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. 14-1f Prothonotary Date: as Q By: �2 l� /a � 3 Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ��c��tr�# �� Jody S Smith �. �� 2813 NOV 15 F ; Chief Deputy Richard W Stewart m CUMBERLAND COUNTY Solicitor OFFICE OF THE SwliERIFr tP EN N S Y LVA N i A Daniel F Parson, Jr Case Number vs. Michael Shipe (et al.) 2013-5058 SHERIFF'S RETURN OF SERVICE 10/22/2013 Sheriff Ronny R Anderson, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit: Michael Shipe, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Luzerne, Pennsylvania to serve the within Writ of Summons according to law. 10/29/2013 The requested Writ of Summons served by the Interim Sheriff of Luzerne County upon Michael Shipe, personally, at SCI Retreat, 660 State Road, Route 11, Hunlock Creek, PA 18621. Brian Szumski, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.46 SO ANSWERS, November 07,2013 RON R ANDERSON, SHERIFF (c)^ountySulte Sheriff,Telemft,im, TDD (570) 825-1860 FAX: (570) 825-1849 Luzerne County Sheriffs Department Luzerne County Courthouse 200 North River Street Wilkes-Barre, Pennsylvania 18711 (570) 825-1651 CUMBERLAND COUNTY 13-5088 DANIEL F.PARSON,JR. VS MICHAEL SHIPE,ET AL STATE OF PENNSYLVANIA LUZERNE COUNTY SS: SCOTT LAMOREAUX , DEPUTY SHERIFF, for SHERIFF of said county, being duly sworn according to law, deposes and says, that on WEDNESDAY the 29TH day of OCTOBER 20 13 at 10:25 A. M., prevailing time, he served the within SUMMONS upon MICHAEL SHIPS the within named, by handing to HIM personally, atHIS PLACE OF INCARCERATION, SCI RETREAT,HUNLOCK CREEK, in the County of Luzerne, State of Pennsylvania, a true and attested copy and making known the contents thereof. Sworn to and subscribed before me �22 this 20 Sheriff of Luzerne County a � -L� Notary . COMMO-MWEALTH OF P YLVANIA NOTARIAL SEA PATRICIA E.BENZI,Notary Public by Kingston Boro.,Luzerne County .y Commission Expires December 24,2013 eputy Sheri uzerne County, Pe syly, a i r fEp �J F `d��TA 2014 F11: 31 pI/ s 4'LvCC14Nr ' DANIEL PARSON : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, . PENNSYLVANIA v. : NO. 13-5058 MICHAEL E. SHIPE and MIRIAM V. SHIPE, : CIVIL ACTION -LAW Defendants: : JURY TRIAL DEMANDED. PRAECIPE TO THE PROTHONOTARY: Please withdraw the appearance of Vincent M. Monfredo, Esquire and Rominger & Associates on behalf of Plaintiff in the above-captioned matter. ROMINGER& ASSOCIATES Dated: January v& , 2014 By: dr - incent M. Monfredo, Esquire Supreme Court ID # 206671 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 (717) 241-6878 IAMB EfsLAND yLVA, 1! `r SMIGEL,ANDERSON&SACKS,LLP Jefferson J.Shipman,Esquire River Chase Office Center,3`d Floor jshipman @sasllp.com 4431 North Front Street Darryl J.Liguori,Esquire Harrisburg,PA 17110 dliguori@saslip.com (717-234-2401 David W.Park,Esquire dparknsasllp.com Attorneys for Plaintiff DANIEL PARSON IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, : PENNSYLVANIA v. : NO. 13-5058 MICHAEL E. SHIPE and MIRIAM V. SHIPE, : CIVIL ACTION- LAW Defendants: JURY TRIAL DEMANDED. PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Jefferson J. Shipman, Esquire, Darryl J. Liguori, Esquire, David W. Park, Esquire and Smigel, Anderson & Sacks, LLP, on behalf of Plaintiff Daniel Parson in the above-captioned matter. Respectfully submitted, SMIGEL,ANDERSON & SACKS,L.L.P. Date: January 30, 2014 By: ,r i '4i J.ffer% J. Shi man, Esquire—ID #51715 r arryl J. Liguori, Esquire—ID #91715 David W. Park, Esquire—ID #315905 4431 North Front Street, 3rd Floor Harrisburg, PA 17110 (717) 234-2401 Attorneys for Plaintiff Daniel Parson DANIEL PARSON Plaintiff V. MICHAEL E. SHIPE and MIRIAM V. SHIPE, Defendants FILEO-OFFICE THE PROTHONOTARY 2011i NOV 114 Ali 11: 114 CUMBERL.AND COUNTY PENNSYLVANIA : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 13-5058 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED. PRAECIPE TO THE PROTHONOTARY: Please mark Plaintiffs Writ of Summons in the above -captioned action discontinued and withdrawn with prejudice. Date: November 12, 2014 By Respectfully submitted, SMIGEL, ANDERSON & SACKS, L.L.P. so J. Shipman, E quire A omey I.D. No. 51785 River Chase Office Center, 3rd Floor 4431 North Front Street Harrisburg, PA 17110-1778 (717) 234-2401 Attorneys for Plaintiff DANIEL PARSON Plaintiff v. MICHAEL E. SHIPE and MIRIAM V. SHIPE, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 13-5058 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED. CERTIFICATE OF SERVICE I, Jefferson J. Shipman, Esquire, attorney for the Plaintiff in the above -captioned matter, certify that I this day served a copy of the foregoing Praecipe to Withdraw upon the person(s) indicated below by depositing a copy of the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, and addressed as follows: James Smith, Claim Representative State Farm Insurance Post Office Box 106114 Atlanta, GA 30348-6114 Date: November 17—', 2014 By: SMIGEL, ANDERSON & SACKS, L.L.P. Jeffe 'so ipman, Esq ire — ID #51785 443 North ront Street Harrisburg, PA 17110 (717) 234-2401 Attorneys for Plaintiff