HomeMy WebLinkAbout14-0684 Supreme Court.of Pennsylvania
Cou C.om . �n Pleas
] 1l;0�'�7Pt beet For Prothonotary Use Only:
N
County Docket No:
The inforrnarion 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 ❑ Complaint � Writ of Summons El Petition El Notice of Appeal
❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
T Wendy T. Sheaffer Richard Rodriguez
I ❑ Check here if you are a Self-Represented (Pro Se) Litigant
O Name of Plaintiff /Appellant Attorney: Andrew C. Spears
N
Are money damages requested?: ❑X Yes ❑ No Dollar Amount Requested: ❑ within arbitration limits
A (Check one) —0— outside arbitration limits
Is this a Class Action Suit? ❑ Yes N No
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
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
❑X Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance _ ❑ Dept. of Transportation
❑ Premises Liability ❑ Zoning Board
S ❑ Product Liability (does not include ❑ Employment Dispute: Statutory Appeal: Other
E mass tort) ❑
Slander/Libel/ Defamation Discrimination
El
C ❑ Other: ❑ Employment Dispute: Other
T Judicial Appeals
❑ MDJ - Landlord/Tenant
I ❑ Other: ❑ MDJ - Money Judgment
O MASS TORT ❑ Other:
❑ Asbestos
N ❑ Tobacco
❑ Toxic Tort - DES
❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
❑ Toxic Waste ❑ Ejectment
El Other: J ❑Common Law /Statutory Arbitration
B El Eminent Domain/Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ LandlordfTeriant Dispute ❑ Non - Domestic Relations
❑ Mortgage Foreclosure Restraining Order
PROFESSIONAL LIABLITY ❑ Partition ❑ Quo Warranto
❑ Dental ❑ Quiet Title ❑ Replevin
❑ Legal
❑ Medical ❑ Other: ❑ Other:
❑ Other Professional:
Pa.R.C.P, 205.5 212010
r
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA '
No. 2014
Civil Action - () Law
WENDY T. SHEAFFER RICHARD RODRIGUEZ
815 Factory Street 724 Olsen Drive
Carlisle, PA 17013 Carlisle, PA 17013
C_') �.
AMANDA RODRIGUEZ
724 Olsen Drive M
Carlisle, PA 17013���
-t''
AWILDA RIVERA
313 S. Jackson Street o f �
Youngstown, OH 44506
VERSUS
Plaintiff(s) & Defendant(s) &
Address(es) Address(es)
PRAECIPE FOR WRIT OF SUMMONS
TO THE PROTHONOTARY OF SAID COURT:
Please issue a Writ of Summons in the above - mentioned action.
Writ of Summons shall be issued and forwarded to (xx) Attorney
Andrew C. Spears, Esquire
1300 Linglestown Road - Suite 2 Signature Attorney
Harrisburg, PA 17110 Supreme Court ID #87737
Date: I ti
S
QH�
WRIT OF SUMMONS
TO THE ABOVE NAMED DEFENDANT(S)
YOU ARE NOTIFIED THAT THE ABOVE -NAMED PLAINTIFF(S) HAS /HAVE COMMENCED AN
ACTION AGAINST YOU.
Y
Prothonotary Dep y
Date:
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff ',._ r'nG l Hj
t,.ai.rtu�hrF�za ti-. .'.
Jody S Smith
Chief Deputy { � 2$ �
Richard W Stewart "�Ur' SE�{� r=+ ti
Solicitor w - „R1F;= 'EtrNSYI.VA 1{A:
Wendy T. Sheaffer Case Number
vs.
Richard Edward Rodriguez(et al.) 2014-684
SHERIFF'S RETURN OF SERVICE
02/10/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Richard Edward Rodriguez, but was unable to locate the
Defendant in his bailiwick.The Sheriff therefore returns the within requested Writ of Summons as"Not
Found"at 724 Olson Drive, Carlisle Borough, Carlisle, PA 17013. Per current resident, Heather Raisig,
has lived here since March 2013 and the Carlisle Postmaster confirms that Richard Rodriguez is not
known at the address given.
02/10/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit:Amanda Rodriguez, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Writ of Summons as"Not Found"at 724
Olsen Drive, Carlisle Borough, Carlisle, PA 17013. Per current resident, Heather Raisig, has lived here
since March 2013. The Carlisle Postmaster confirms that Amanda Rodriguez is not known at the
address given.
02/10/2014 Ronny R Anderson, Sheriff, who being duly sworn according to law, states that he served the within Writ
of Summons upon the within named defendant,Awilda Rivera, in the following manner: On February 10,
2014 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within
Writ of Summons to the defendant's last known address of 313 S. Jackson Street,Youngstown, OH
44506.The certified mail return receipt card was received by the Cumberland County Sheriffs Office
signed by Awilda Rivera on February 13, 2014.
SHERIFF COST: $83.26 SO ANSWERS,
February 24, 2014 RONN g_R ANDERSON, SHERIFF
(c)CountySuite Shenff,Teleosoft,Inc.
SENDER r%u /VERY
• Complete items 1,2,and 3.Also complete A. Signature
item 4 if Restricted Delivery is desired. 7,, ❑Agent
• Print your name and address on the reverse X&L t, , {��( ❑Addressee
so that we can return the card to you. B.B. eceived y(Pri Name) C. Date of Delivery
• Attach this card to the back of the mailpiece w '2-13-1Y
or on the front if space permits. ' �' f(4)' 1 � /Veil
D. Is delivery address different Om item 1? ❑Yes
1. Article Addressed to: If YES,enter delivery address below: ❑No
Awilda Rivera
313 S. Jackson Street I - 0q0/4--/— (og4/
Youngstown, OH 44506 3. Service Type
❑Certified Mail® ❑Priority Mall Express'
❑Registered ❑Return Receipt for Merchandise
❑Insured Mall ❑Collect on Delivery
4. Restricted Delivery?(Extra Fee) ❑Yes
2. Article Number 7 0 0 7 0710 710 0003 2 210 3962
1►tear ovm,s�pvke,e�go,
PS 1'drrn 381 .'July 1 11 • larnilertIt Ftetum Receipt
Andrew C. Spears
Attorney ID# 87737
HANDLER, HENNING & ROSENBERG, LLP
1300 Linglestown Road
Harrisburg, PA 17110
Telephone: (717) 238-2000
Fax : (717) 233-3029
E-mail: Spears@hhrlaw.com
-6h
)THONO TA k
2:114 MAR PM t:
CUMBERLAND COUNTY
PENNSYLVANIA
Attorney for Plaintiff(s)
WENDY SHEAFFER : IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
v. : NO. 14-684
: CIVIL ACTION - LAW
RICHARD RODRIGUEZ, AMANDA
RODRIGUEZ, and AWILDA RIVERA
Defendant(s)
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA:
Please re-issue the Writ of Summons in the above referenced matter. Please
instruct the Sheriff of Cumberland County to deputize the Sheriff of Northampton County to
serve the Writ upon the defendants Richard & Amanda Rodriguez at the following address:
Date:
Richard & Amanda Rodriguez
1726 11TH Street
Bethlehem, PA 18020-6543
HANDLER, HENNING & ROSENBERG, LLP
By
Andrew C. pears, Esq.
I.D. #87737
1300 Linglestown Road, Suite 2
Harrisburg, PA 17110
(717) 238-2000
Attorney for Plaintiff _e■K\
?o76;
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
OFF'sCE CF- THE 4j'E.RIFP
FILED -OFFICE
I HE PRO T ICON() ;
20/41111Y -8 PH 2: 53
CUMBERLAND COUNTY;
PENNS YLVANIA.
Wendy T. Sheaffer
vs.
Richard Edward Rodriguez (et al.)
Case Number
2014-684
SHERIFF'S RETURN OF SERVICE
03/31/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Richard Edward Rodriguez, but was unable to locate the
Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Northampton,
Pennsylvania to serve the within Writ of Summons according to law.
03/31/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Amanda Rodriguez, but was unable to locate the Defendant in the
Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Northampton, Pennsylvania to serve the
within Writ of Summons according to law.
04/09/2014 10:33 AM - The requested Writ of Summons served by the Sheriff of Northampton County upon Amanda
Rodriguez, personally, at 1726 11th Street, Bethlehem, PA 18020. Christopher Zeigler, Sheriff, Return of
Service attached to and made part of the within record.
04/09/2014 10:33 AM - The requested Writ of Summons served by the Sheriff of Northampton County upon Amanda
Rodriguez, who accepted for Richard Edward Rodriguez, at 1726 11th Street, Bethlehem, PA 18020.
Christopher Zeigler, Sheriff, Return of Service attached to and made part of the within record.
SHERIFF COST: $44.49 SO ANSWERS,
May 06, 2014 RONI[Y R ANDERSON, SHERIFF
(C) CountySuite Sheriff: Te!eoson, inc.
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
SHERIFF'S OFFICE OF 'CUMBERLAND COUNTY
4
OFFICE OF WE SRERIFF
0'L
Richard W Stewart
Solicitor
Wendy T. Sheaffer
vs.
Richard Edward Rodriguez (et al.)
Case Number
2014-684
v
0
N
0 [• Service Details:
o Category:
x Manner:
w
0
N
0
o
Notes:
SERVICE COVER SHEET
Civil Action - Writ of Summons
Deputize
Expires:
04/30/2014
Zone:
Warrant:
. LS
n erve To:
Name:
_
J Primary
= Address:
I
w
• Phone:
w
• Alternate
1— Address:
_
Phone:
n Attorney / Originator:
[Final Service:
Amanda Rodriguez
1726 11th Street
Bethlehem, PA 18020
DOB:
1
Served: ersonally• dult In Charge Posted • Other
Adult In
Charge:
Relation:
Date:
Deputy:
Name: `Andrew C. Spears
Service Attempts:
Phone:
Time:
Mileage:
717-238-2000
"'> I• -vimr!•
--4
Date:
• Time:
1D
Mileage:
g.
Deputy:
Q
z
• Now, March 31, 2014 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of. Northampton County
to execute service of the documents herewith and make return thereof according to law.
C9
tre Return To:
Cumberland County Sheriffs Office
ct One Courthouse Square
Carlisle, PA 17013
4.1
L
)CD;,
-,0 d`>
Notes / Special Instructions:
r bi
•K''
(c) CoentySnte Sheriff Teteosoft. Inc
R-Onny R Anderson, Sheriff
EXP: 04/30/2014
1726 11TH STREET, BETHLEHEM, PA 18020
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
gltl�l?t bt CuutiEr /,�4d
OFFICE OF THE SHERIFF
Richard W Stewart
Solicitor
Wendy T. Sheaffer
vs.
Richard Edward Rodriguez (et al.)
Case Number
2014-684
rService Details:
SERVICE COVER SHEET
Category:
Manner:
Notes:
Civil Action - Writ of Summons
Deputize
Expires:
04/30/2014
Zone: I
Warrant:
[Serve To:
Name:
Primary
Address:
Phone:
Alternate
Address:
Phone:
Richard Edward Rodriguez
1726 11th Street
Bethlehem, PA 18020
DOB:
[Final Service:
Served: Personally • Adult In Charge • Posted • Other
Adult In r %� w n Pootristue Charge: Lj 7 v�tz--
Lw L—q9-1 1Plei
Relation:
Date:
Deputy:
[Attorney / Originator:
Name:
Andrew C. Spears
Phone:
717-238-2000
ca
Time:
TTI
Mileage:
oC r J
Service Attempts:
Date:
. Time:
co
`D
Mileage:
v g.
Deputy:
RODRIGUEZ, RICHARD ED'
2
3
I Notes / Special Instructions:
Now, March 31, 2014 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Northampton County
to execute service of the documents herewith and make return thereof according to law.
Return To:
Cumberland County Sheriffs Office
One Courthouse Square
Carlisle, PA 17013
(c :atwitySwte $huiff Te!eosott, hu:
Ronny R Anderson, Sheriff
Northampton County
Sheriff's Department
669 Washington St, Easton, PA 18042
610-559-3084
1) ALL information in the "Plaintiff / Attorney" section MUST be filled in
completely and LEGIBLY before service can be attempted.
2) Prepare a separate "Order For Service Request" form for EACH service to be
made clearly indicating the specific defendant, garnishee, property to be
posted/ levied/ etc..
3) Location of service MUST be a valid, PHYSICAL, street address. "P.O." or
"R.D." boxes will NOT be accepted. Provide -include actual municipality if
different from "Post Office" mailing city.
4) All copies for service must be certified by Plaintiff/Attorney as "True & Correct"
in accord with Pa.R.C.P. 401(c).
5) All service shall be made in accordance with the Pennsylvania Rules Of Civil
Procedure.
6) Supply a self-addressed, stamped, envelope for Sheriffs Return of Service.
7) When the Sheriff levies or attaches property, it will routinely be left without watchman, in the custody of whomever found, upon notice of Sheriffs Levy. By signature below, the
Plaintiff/Attorney are providing written authorization for same in the manner of Pa.R.C.P. 3109(b)(1), releasing the Sheriff from any/all liability for protecting same. If Plaintiff/Attorney
demand otherwise, in the manner of Pa.R.C.P. 3109(a), the Sheriff will require bond or security in the manner of Pa.R.C.P. 3109(d) in advance.
Cr Date: ` ff` ` L Sector: 3
ORDER FOR SERVICE REQUEST
SHERIFF - CIVIL DIVISION
RECEIVED
SHERIFF'S OFFICE
COUNTY OF NORTHAMPTON
?OIM fPR 8 API 1117
TIME STAMP
SHERIFF'S OFFICE
'uWL CO- •' T D, J(PMXiTh€ {%]-- 4 QU ra'4 Q -J
Lam' =3 aul—AZIN Q® iL! ' VIS ON 010•IAMV
PLAINTIFF(S):
Wenc, T Shea Rer
DOCKET NUMBER:
20 ci-63
DEFENDANT(S): !
R'Cl ere ice) Pod rl ver
e +c l
f
SERVE UPON: n cAt() Edi` 4
`�(,� alrvPz
DATE:
oq 14-"?c'l ao+Le
LOCATION: **NO P.O. BOX OR R.D.**
(?2‘ ! l '��' 64 -re e+
I I, A!T L cr
�h (<<j EKY!^,
L?� �"
-.T..-5f
TYPE OF WRIT: c V
....). �'f/)•+orf
PLAINTIFF/ATTORNEY NAME, ADDRESS, EMAIL, PHONE:
CU)n'1 e,/''O s) 4,4
PLAINTIFF/ATTORNEY SIGNATURE:
( ) TOWNSHIP OF:
SPECIAL INSTRUCTIONS:
.,,,-.
Lam' =3 aul—AZIN Q® iL! ' VIS ON 010•IAMV
DOCKET NUMBER:
20 ci-63
LAST DAY FOR SERVICE:
*30/P47S
FEES PAID:
f
.,,,-.
INDIVIDUAL SERVED: (
Mdz R>NR00 1 CU
Z
DATE:
oq 14-"?c'l ao+Le
TIME:
1033 f
LOCATION: (IF DIFFERENT FROM ABOVE)
( ) BOROUGH OF: ( ) CITY OF:
( ) TOWNSHIP OF:
SERVED IN THE FOLLOWING MANNER:
( efendant personally served
( ) Adult family member with whom said defendant resides
( ) Adult in charge of defendant's residence
( ) Manager / Clerk of place of lodging in which defendant resides
( ) Agent or person in charge of defendant's office or usual place of business
( ) Officer of said defendant company
( ) Posted property
( ) Levy on property
( ) Other:
() Not Found
() Moved () No Answer () Vacant
() Unknown
SO ANSWERS:
SHERIFF OF NORTHAMPTON COUNTY
BY:
Deputy Sheriff
Badge #
I hereby deputize the Sheriff of
and make a return on the above and attached action according to law.
Sheriff of Northampton County
County, to execute
Date
I accept service of the i µlit'
lJ r�ad c� certify that I am authorized to do so.
Defendant of Authorized Signature)
on behalf of
1.113-4, t 1`�` 5 , --
(Mailing Address)
Date:
Date:
Time: Dep: Notes:
Time: Dep:
Notes:
Date:
Date:
Time: Dep: Notes:
Time: Dep: Notes:
ORDER FOR SERVICE REQUEST
NCSD FORM#138/rev.AUG2013
Northampton County
Sheriff's Department
669 Washington St, Easton, PA 18042
610-559-3084
1) ALL information in the °Plaintiff / Attorney" section MUST be filled in
completely and LEGIBLY before service can be attempted.
2) Prepare a separate "Order For Service Request" form for EACH service to be
made clearly indicating the specific defendant, garnishee, property to be
posted/ levied/ etc..
3) Location of service MUST be a valid, PHYSICAL, street address. "P.O." or
"R.D." boxes will NOT be accepted. Provide -include actual municipality if
different from "Post Office" mailing city.
4) All copies for service must be certified by Plaintiff/Attorney as "True & Correct"
in accord with Pa.R.C.P. 401(c).
5) All service shall be made in accordance with the Pennsylvania Rules Of Civil
Procedure.
6) Supply a self-addressed, stamped, envelope for Sheriffs Return of Service.
7) When the Sheriff levies or attaches property, it will routinely be left without watchman, in the custody of whomever found, upon notice of Sheriffs Levy. By signature below, the
Plaintiff/Attorney are providing written authorization for same in the manner of Pa.R.C.P. 3109(b)(1), releasing the Sheriff from any/all liability for protecting same. If Plaintiff/Attorney
demand otherwise, in the manner of Pa.R.C.P. 3109(a), the Sheriff will require bond or security in the manner of Pa.R.C.P. 3109(d) in advance.
(N!C Date: 9/8//tr
/tr Sector:
ORDER FOR SERVICE REQUEST
SHERIFF - CIVIL DIVISION
TIME STAMP
RECEIVED
SHERIFF'S OFFICE
COUNTY OF NORTHAMPTON
47011 RPR 8 819 11 1?
SHERIFF'S OFFICE
" . 1= _ Pain_ it.-' 1c,
;._'___
- -- - -- ----
5'4 Qe 1' Q. r� -_ 4t✓
FEES PAID: `�
7
PLAINTIFF(S):1 rec T
W y s/P� aer
INDIVIDUAL SERVED
.
DEFENDANT(S): II / / e 0
RC4C(J jdwcr(/f el,, ver
DATE:
01 ell acIti
TIME: thier
102
SERVE UPON:
�(Xi►C�' ue2 13
LOCATION: 172cC I/ **NO P.O.! OX OR R.D "•
.t�—
3-UL�
J
TYPE OF WRIT: �J
SE DIN THE FOLLOWING MANNER:
PLAINTIFF/ATTORNEY NAME, ADDRESS, EMAIL, PHONE:
Cvnie.. , d Et.`..^)%
PLAINTIFF/ATTORNEY SIGNATURE:
(
SPECIAL INSTRUCTIONS:
( ) Moved ( ) No Answer ( ) Vacant
,3L9 OfiX i .` 0 OI�Ltiv
DOCKET NUMBER:
201C -t - 6yti
LA�iDAY FOR !S"ERVICE:
'i [ 3 fll
FEES PAID: `�
7
SO ANSWERS:
SHERIFF OF NORTHAMPTON COUNTY
BY:
Deputy Sheriff
l�
Badge #
I hereby deputize the Sheriff of
and make a return on the above and attached action according to law.
Sheriff of Northampton County
County, to execute
Date
I accept se e f the 5,400/4/S on behalf of
knew Jclek and cerci at I am authorized to do so.
(Defendant &'Authorized Signatu1)
/2 gm dr
n
o ire
(Mailing Address)
Date:
Date:
Time: Dep: Notes:
Time: Dep: Notes:
Date:
Date:
Time: Dep: Notes:
Time: Dep: Notes:
ORDER FOR SERVICE REQUEST
NCSD FORM#138/rev.AUG2013
INDIVIDUAL SERVED
.
DATE:
01 ell acIti
TIME: thier
102
F?4)'
LOCATION: (IF DIFF RENT FR M ABOVE) 1
() BOROl7GH OF: () CITY OF:
() TOWNSHIP OF:
SE DIN THE FOLLOWING MANNER:
( Defendant personally served
(
) Not Found
( ) Moved ( ) No Answer ( ) Vacant
( ) Unknown
( ) Adult family member with whom said defendant resides
( ) Adult in charge of defendant's residence
( ) Manager / Clerk of place of lodging in which defendant resides
( ) Agent or person in charge of defendant's office or usual place of business
( ) Officer of said defendant company
( ) Posted property
( ) Levy on property
( ) Other:
SO ANSWERS:
SHERIFF OF NORTHAMPTON COUNTY
BY:
Deputy Sheriff
l�
Badge #
I hereby deputize the Sheriff of
and make a return on the above and attached action according to law.
Sheriff of Northampton County
County, to execute
Date
I accept se e f the 5,400/4/S on behalf of
knew Jclek and cerci at I am authorized to do so.
(Defendant &'Authorized Signatu1)
/2 gm dr
n
o ire
(Mailing Address)
Date:
Date:
Time: Dep: Notes:
Time: Dep: Notes:
Date:
Date:
Time: Dep: Notes:
Time: Dep: Notes:
ORDER FOR SERVICE REQUEST
NCSD FORM#138/rev.AUG2013
Andrew C. Spears
Attorney ID# 87737
HANDLER, HENNING & ROSENBERG, LLP
1300 Linglestown Road
Harrisburg, PA 17110
Telephone: (717) 238-2000
Fax : (717) 233-3029
E-mail: Spears@hhrlaw.com
Attorney for Plaintiff(s)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WENDY SHEAFFER,
Plaintiff(s)
v.
RICHARD RODRIGUEZ, AMANDA
RODRIGUEZ, and AWILDA RIVERA,
Defendant(s)
Dated:
14-684
Civil Action - Law
PRAECIPE
Please mark the above captioned matter settled and discontinued.
HANDLER HENNING & ROSENBERG LLP
Andrew C. •ears