The URL can be used to link to this page

Home My WebLink About05-0929 ORIGINAL IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 0) , q J..- '1 Civil Action - (X) Law ( ) Equity Sharon Clouser and David Clouser 170 Simmons Road Mechanicsburg PA 17055 versus Ash1ee R. Anderson 1073 Lancaster Blvd, Apt. 15 Mechanicsburg PA 17055 Upper Allen Township 100 Gettysburg Pike Mechanicsburg PA 17055 Lower Allen Township 1993 Hummel Avenue Camp Hill PA 17011 P1aintiff(s) & Address Defendant(s) & Address PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue Writ of Summons in the above-captioned action. ;.[ W", ,fS'mmoo. ..,f> "" f=", "d f'~"~~" 1'1 Sheriff Richard E. Freeburn, Esquire ~ / Q 4415 North Front Street '/---..-. Harrisburg, PA 17110 Signature of ttorney (717)671-1955 Supreme Court ID No. 30965 Date: 2/18/05 WRIT OF SUMMONS TO THE ABOVE-NAMED DEFENDANTIS): ASHLEE R. ANDERSON; UPPER ALLEN TOWNSHIP; LOWER ALLEN TOWNSHIP YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. b' t.d,A Prothonotary Date: d/ ;}/~,r- {X-7 B, t. /J).~' '/Yl~ Deputy ~ fl.- -'" f'\ ~ ~"'tt er.,\ ,\ ~ "L;-- ~ \) I;) ~ ~ 0; :', R(y ~ C,) SHARON CLOUSER AND DAVID CLOUSER, Plain tiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY , PENNSYLVANIA NO. 05-929 v. ASHLEE R. ANDERSON; UPPER ALLEN TOWNSHIP; LOWER ALLEN TOWNSHIP, Defendants CIVIL ACTION - LAW ACCEPTANCEOFSER~CE I, Robert P. Reed, Esquire, accept service of the Writ of Summons on behalf of Defendant, AshIee R. Anderson, and certify that I am authorized to do so. Date: ;< - l- '/ - cYc5- ~~M Robert P. Reed, Esquire 1983 Mannsville Road EIliottsburg PA 17024 (717) 582-3008 It.. ~ CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Acceptance of Service, has been duly served on the following this 28th day of February, 2005, by placing the same in the U.S. First Class Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Robert P. Reed, Esquire 1983 Mannsville Road Elliottsburg PA 17024 '\ BY: ~ Georgiann J. Hess, sistant to Richard E. Freeburn, Esquire Attorney 1.D. #30965 FREEBURN & HAMILTON 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 IU Dated: 2/28/05 Attorney for Plaintiffs SHARON CLOUSER AND DAVID CLOUSER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 05-929 v. CIVIL ACTION - LAW ASHLEE R. ANDERSON; UPPER ALLEN TOWNSHIP; LOWER ALLEN TOWNSHIP, Defendants PRAECIPE TO: Prothonotary Kindly reissue the Writ of Surnmons in this matter. Respectfully subrnitted, FREEBURN & HAMILTON By: Ri . Freeburn, Esquire J.D. No.3 965 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 Dated: 3/16/05 Attorney for Plaintiffs .--------/ SHARON CLOUSER AND DAVID CLOUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-929 v. ASHLEE R. ANDERSON; UPPER ALLEN TOWNSHIP; LOWER ALLEN TOWNSHIP, Defendants CIVIL ACTION - LAW CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Richard E. Freeburn, Esquire certifies that: 1. A Notice of Intent to serve a subpoena with a copy of the subpoena attached thereto was rnailed or delivered to Defendant 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 the Certificate; 3. No objection has been received by counsel for Defendant; and 4. The subpoena to be served is identical to the subpoena attached to the Notice of Intent. FREEBURN & HAMILTON \..\ Richard E. Freebu I.D. No. 30965 4415 North Front Street Harrisburg PA 17110 (717) 671-1955 Date: 4/6/05 Attorney for Plaintiffs SHARON CLOUSER AND DAVID CLOUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-929 v. ASHLEE R. ANDERSON; UPPER ALLEN TOWNSHIP; LOWER ALLEN TOWNSHIP, Defendants CIVIL ACTION - LAW NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Robert P. Reed, Esquire 1983 Mannsville Road Elliottsburg PA 17024 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 rnade, the subpoena may be served. FREEBURN & HAMILTON - /- 1~ Richard E. Freebum, Esquire J.D. No. 30965 4415 North Front Street Harrisburg PA 17110 (717) 671-1955 Date: 2/22/05 Attomey for Plaintiffs SHARON CLOUSER AND DAVID CLOUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-929 v. ASHLEE R. ANDERSON; UPPER ALLEN TOWNSHIP; LOWER ALLEN TOWNSHIP, Defendants CIVIL ACTION - LAW SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: The Motorists Insurance Group, 2674 Monroeville Blvd, Monroeville PA 15146-2344 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docurnents or things: Any and all documents in connection with Claim No. 3-652395, including but not limited to notes, memos, reports, adjuster diaries, drawings, graphs, charts, workbooks, audiotape, compilations of data, statements, photographs, videotape and motion pictures, but excluding mental impressions, conclusions or opinions respecting the value or merit of the claim. at Freeburn & Hamilton, 4415 N. Front Street, Harrisburg PA 17110 You may deliver or rnail legible copies of the documents or produce things requested by this subpoena, together with the certificate of cornpliance, to the party rnaking this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies of 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 cornpelling you to cornply with it. THIS Subpoena WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Richard E. Freeburn, Esquire Freeburn & Hamilton 4415 N. Front Street Harrisburg PA 17110 (717) 671-1955 J.D. No. 30965 Attorney for Plaintiffs Date: By the Court: Prothonotary Deputy CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Notice of Intent to Serve Records Subpoena, has been duly served on the following this 22nd day of February, 2005, by placing the same in the U.S. First Class Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Robert P. Reed, Esquire 1983 Mannsville Road Elliottsburg PA 17024 BY: ii ~'\l~ L lJ.vlj Georgianne' J. Hess,(}tssistant to Richard E. Freeburn, Esquire Attorney J.D. #30965 FREEBURN & HAMILTON 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 Dated: 2/22/05 Attorney for Plaintiffs CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena, has been duly served on the following this 6th day of April, 2005, by placing the same in the U.S. First Class Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Robert P. Reed, Esquire 1983 Mannsville Road Elliottsburg PA 17024 BY: JW , ~ Georgianne . Hess, As 'stant to Richard E. Freeburn, Esquire Attorney J.D. #30965 FREEBURN & HAMILTON 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 Dated: 4/6/05 Attorney for Plaintiffs 0 ....' <;f\ C-:':') I~',~ ~'.~:~ a' -C"1" J'" ~ -z::> P1~ /" \ -0 fil :oq -J C) , , .,u{S"" "r-: '," 0 ("):''-! :.;.:. ,,() -f."crt r:-? ,.) ..-1 ~..,.\ ct1 ?5 _/'~ U;> .-< SHERIFF'S RETURN - REGULAR . CASE NO: 2005-00929 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CLOUSER SHARON ET AL VS ANDERSON ASHLEE R ET AL RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon LOWER ALLEN TOWNSHOP t e DEFENDANT , at 1409:00 HOURS, on the 3rd day of March 2005 at 1993 HUMMEL AVENUE CAMP HILL, PA 17011 by handing to TOM VERNAN, ASSISTANT MANAGER, ADULT IN CHARGE a true and attested copy of WRIT OF SUMMONS together 'th and at the same time directing His attention to the contents the eof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 11.10 .00 10.00 .00 27.10 So Answers: .......,'"1., ~ i/C .4./1'",,,.,. ;fl,' ,~_:..1' j ..' ~.,.f! R. Thomas Kline 03/16/2005 FREEBURN & HAMILTON m of Sworn and Subscribed to before By: A.D. ~ CASE NO: 2005-00929 P SHERIFF'S RETURN - REGULAR .. - COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CLOUSER SHARON ET AL VS ANDERSON ASHLEE R ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS UPPER ALLEN TOWNSHIP DEFENDANT was served upon t e , at 1306:00 HOURS, on the 3rd day of March , 2005 at 100 GETTYSBURG PIKE MECHANICSBURG, PA 17055 JO ANN KINTZ, BOOKKEEPER by handing to ADULT IN CHARGE a true and attested copy of WRIT OF SUMMONS together ith and at the same time directing Her attention to the contents the eaf. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 8.14 .00 10.00 .00 24.14 Sworn and Subscribed to before day of ~r So Answers: ?" /'J/1J' 1~ '";;,,,' ,"';.'-'#.,.. /~- <7' ~.......t:;....<.....",;....--"._.,.. R. Thomas Kline 03/16/2005 FREEBURN & HAMILTON By:a~ Deputy Sheriff SHERIFF'S RETURN - REGULAR , - CASE NO: 2005-00929 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CLOUSER SHARON ET AL VS ANDERSON ASHLEE R ET AL GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon ANDERSON ASHLEE R t e DEFENDANT , at 2100:00 HOURS, on the 15th day of March , 2005 at 1073 LNCASTER BLVD APT 15 MECHANICSBURG, PA 17055 by handing to ROBIN CLOUSER, MOTHER a true and attested copy of WRIT OF SUMMONS together ith and at the same time directing Her attention to the contents th reof. Sheriff's Costs: Docketing Service Postage Surcharge So Answers: 18.00 8.88 .37 10.00 .00 37.25 .Y' fi /J~ ",. R. Thomas Kline 03/16/2005 FREEBURN & HAMILTON Sworn and Subscribed to before By: me this i I<t~ day of A.D. r 'It SHARON CLOUSER AND DAVID CLOUSER, Plaintiffs v. ASHLEE R. ANDERSON; UPPER ALLEN TOWNSHIP; LOWER ALLEN TOWNSHIP, Defendants TO: Prothonotary o~~ ~~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY , PENNSYLVANIA NO. 05-929 CIVIL ACTION - LAW PRAECIPE Kindly mark the above-captioned matter settled and discontinued. By: Date: 1/17/06 Respectfully submitted, FREEBURN & HAMILTON ~w Richard E. Freeburn, Esquire I.D. No. 30965 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 Attorney for Plaintiffs , CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Praecipe has been duly served on the following this 17th day of October, 2006, by placing the same in the U.S. First Class Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Robert P. Reed, Esquire 1983 Mannsville Road Elliottsburg PA 17024 Peter C. Buckley, Esquire FOX ROTHSCHILD, LLP 2000 Market Street, 10th Floor Philadelphia PA 19103 Christine E. Munion Esquire 100 W. Elm Street, Ste. 200 Conshohocken PA 19428 Georgian J. Hess, Richard E. Freebum, Attomey I.D. #30965 FREEBURN & HAMILTON 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 Juv BY: Dated: 10/17/06 Attomey for Plaintiffs o c: < ~ft} 4:- :..-.. ~" t<: ~~~2 .~. '..~ Z ~ ~ <::::> = <::T' g -t ~ ~""'"' f1'lr;; ~6 ~:r{ ~o Om ..'-\ ~ v::> -0 :3C W .. W N