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Home My WebLink About14-2832 d,. Supreme Co:i-i o Pennsylvania COU ,Yu pCo"mmoleas For Prothonotary Use Only: Cl< itVie Sheet Tj z - � Docket No: sTR Cuerlarid' tz%' County a 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 El Complaint [H] Writ of Summons 0 Petition Transfer from Another Jurisdiction Q Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Minto C. Kar Heather M.Woods T x Dollar Amount Requested: Elwithin arbitration limits I Are money damages requested? S Yes 0 No (check one) w outside arbitration limits O N Is this a Class Action Suit? Yes El No Is this an MDJAppeal? Yes 1] No A Name of Plaintiff/Appellant's Attorney: Matthew L. Owens, Esquire 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 El Intentional El Buyer Plaintiff Administrative Agencies Malicious Prosecution Debt Collection:Credit Card El Board of Assessment Motor Vehicle Debt Collection:Other [] Board of Elections Nuisance Q Dept.of Transportation 1] Premises Liability Statutory Appeal: Other S E] Product Liability (does not include tort) � Employment Dispute: mass E Discrimination Slander/Libel/Defamation Employment Dispute:Other Zoning Board C Other: � Other: ,I, I Other: O MASS TORT 0 Asbestos N [] Tobacco Toxic Tort-DES Q Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS Toxic Waste Q Ejectment Other: � Common Law/Statutory Arbitration B 0 Eminent Domain/Condemnation Declaratory Judgment El Ground Rent Mandamus El Landlord/Tenant Dispute Non-Domestic Relations 1l Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY Q Mortgage Foreclosure:Commercial Quo Warranto Dental Partition Replevin Legal Quiet Title 0 Other: 0 Medical Other: 0 Other Professional: Updated 1/1/2011 M1NTO C. KAR and RUMA IN THE COURT OF COMMON PLEAS TALUKDER, CUMBERLAND COUNTY PESYLVANIA Plaintiffs o VS. NO. �� • �0d lv� HEATHER M. WOODS and JOSEPH LACHWA, rn Defendants CIVIL ACTION- LAW r d , JURY TRIAL DEMANDED ' ``' ' PRAECIPE FOR WRIT OF SUMMONS z c:) { TO THE PROTHONOTARY: -• Please issue a writ of summons against Heather M. Woods and Joseph Lachwa. The Writ of Summons shall be issued and delivered to the Sheriff of Cumberland County for service. Date : 3 7 Matthew L. Owens, Esquire Attorney ID #76080 2595 Interstate Drive, Suite 101 Harrisburg, PA 17110 (717) 909-2500 Attorney for Plaintiff CLAS lU33 } ti MINTO C. KAR and RUMA IN THE COURT OF COMMON PLEAS TALUKDER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs (� vs. NO. HEATHER M. WOODS and JOSEPH LACHWA, Defendants CIVIL ACTION- LAW JURY TRIAL DEMANDED WRIT OF SUMMONS TO: Heather M. Woods 20 E. Pomfret Street Carlisle, PA 17013 Joseph Lachwa 159 S. Pitt Street Carlisle, PA 17013 YOU ARE NOTIFIED THAT THE PLAINTIFF, MINTO C. KAR AND RUMA TALUKDER, HAVE COMMENCED A CIVIL ACTION AGAINST YOU. o Date: 0 1 Prothonotary Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ettori. .li ;HE RO I HQhO 1;iR' OAF€ICE OF THE $HER,IFF ZO1II JUN —t4 PM is 15 CUMBERLAND COUNTY PENNSYLVANIA Minto Chandro Kar (et al.) vs. Heather M Woods (et al.) Case Number 2014-2832 SHERIFF'S RETURN OF SERVICE 05/23/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Heather M Woods, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Summons as "Not Found" at 20 E. Pomfret Street, Carlisle Borough, Carlisle, PA 17013. Per staff at this address the defendant has not been a resident for the the last six to eight months. The Carlisle Postmaster confirms that the defendant is not known at the address provided and were unable to provide a good forwarding address. 05/23/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Joseph Lachwa, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Summons as "Not Found" at 159 S. Pitt Street, Carlisle, PA 17013. Deputies were unable to make contact with anyone to effectuate service at this address and per the Carlisle Postmaster the defendant is not known at the address provided. SHERIFF COST: $68.51 SO ANSWERS, May 23, 2014 RON9 R ANDERSON, SHERIFF (c) CountySuile Sheriff, Teieosoft, Inc OF ' OFF/CE( 2014,1 1O'Q Tib CUBE A/,13 PEN,A S ANIA V C��Nr+ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MINTO KAR and CIVIL DIVISION RUMA TALUKDER, Plaintiffs, NO. 2014-2832 v. PRAECIPE FOR APPEARANCE HEATHER M. WOODS and (Jury Trial Demanded) JOSEPH LACHWA, Defendants. Filed on Behalf of the Defendants Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, & GUTHRIE, P.C. Firm #911 945 East Park Drive, Suite 201 Harrisburg, PA 17111 (717) 901-5916 #20723 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MINTO KAR and RUMA TALUKDER„ Plaintiffs, v. HEATHER M. WOODS and JOSEPH LACHWA„ Defendants. CIVIL DIVISION NO. 2014-2832 (Jury Trial Demanded) PRAECIPE FOR APPEARANCE TO: THE PROTHONOTARY Kindly enter the Appearance of the undersigned, Kevin D. Rauch, Esquire, of the law firm of Summers, McDonnell, Hudock & Guthrie, P.C., on behalf of the Defendants, Heather M. Woods and Joseph Lachwa, in the above case. JURY TRIAL DEMANDED Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, & GUTHRI , P.C. By: e'er - auch, Esquire ounsel for Defendants CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR APPEARANCE has been mailed by U.S. Mail to counsel of record via first class mail, postage pre -paid, this 23rd day of July, 2014. Matthew L. Owens, Esquire Law Offices of Matthew L. Owens, LLC 2595 Interstate Drive, Suite 101 Harrisburg, PA 17110 (Attorney for Plaintiffs) SUMMERS, McDONNELL, HUDOCK, & GUTHRIE, P.C. By: /4/, e 'iYi ! squire Counsel for Defendants FO-OFFICF: OF THE PR THONO-TAR Y 20i OCT -8 MI II: 53 CIIMBERI AND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MINTO KAR and CIVIL DIVISION RUMA TALUKDER, Plaintiffs, NO. 2014-2832 v. STIPULATION HEATHER M. WOODS and (Jury Trial Demanded) JOSEPH LACHWA, Defendants. Filed ori,E3ehalf of the Defendants Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK & GUTHRIE, P.C. Firm #911 c -4t945, -East Park Drive, Suite 201 Harrisburg, PA 17111 (717) 901-5916 #20723 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MINTO KAR and CIVIL DIVISION RUMA TALUKDER„ Plaintiffs, NO. 2014-2832 V. HEATHER M. WOODS and JOSEPH LACHWA, Defendants. (Jury Trial Demanded) STIPULATION AND NOW, come the parties by their attorneys, Kevin D. Rauch and Matthew L. Owens and file the following Stipulation as follows: 1. The parties agree that liability in causing the accident is admitted and there is no claim for negligent entrustment; 2. The parties agree that as a result of this stipulation to liability, there will be no claim for punitive damages; 3. As a result of stipulation to liability, the Plaintiff agrees to cap his damages with respect to the third party claim against Heather M. Woods and Joseph Lachwa at the applicable policy limits of $100,000. 4. This Stipulation shall not preclude a claim by Plaintiff for UIM or any other first party benefit LAW OFFI L. OWEN SUMMERS, McDONNELL, HUDOCK By By ens, Esquire or Plaintiffs & GUT RIE, P.C. 049 ibfk Kevin D. -auch, Esquire Counsel for Defendants CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing STIPULATION has been mailed by U.S. Mail to counsel of record via first class mail, postage pre -paid, this rh day of October, 2014. Matthew L. Owens, Esquire Law Offices of Matthew L. Owens, LLC 2595 Interstate Drive, Suite 101 Harrisburg, PA 17110 (Attorney for Plaintiffs) SUMMERS, McDONNELL, HUDOCK & GUTHRIE, P.C. D. Rauch, Esquire ounsel for Defendants