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Home My WebLink About14-3820 Supreme Co ennsylvania Con CJ%mo ".leas For Prothonotary Use Only: t Docket No: C n County The information collected on this fibrin is used solely.for court administration purposes. This form does not supplement or replace thefiling and service of pleadings or other papers as required by low or rules of court. Commencement of Action: Mi Complaint El Writ of Summons El Petition S Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: T William E. Butler and Maryann E. Gashi-Butier McCoy Brothers, Inc. Dollar Amount Requested: within arbitration limits Are money damages requested? El Yes El No (check one) outside arbitration limits 0 N Is this a Class Action Suit? 1:1 Yes 0 No Is this an MDJAppeal? Yes 0 No A Name of Plaintiff/Appellant's Attorney: Kathleen Misturak-Gingrich, Esq. Check here if you have no attorney(are a Self-Represented (Pro Sed 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 No not include Judgments) CIVIL APPEALS 0 Intentional 0 Buyer Plaintiff Administrative Agencies Malicious Prosecution Debt Collection: Credit Card M Board of Assessment Motor Vehicle Debt Collection:Other F-1 Board of Elections Nuisance , 0 Dept.of Transportation Premises Liability n Statutory Appeal:Other S 0 Product Liability(does not include n Employment Dispute: E mass tort) Slander/Libel/Defamation Discrimination C Other: Employment Dispute:Other Zoning Board T 0Other: 1 0 Other: o MASS TORT Asbestos N Q Tobacco Toxic Tort-DES [3Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste 0 Ejectment r7l Common Law/Statutory Arbitration B1 r1il Eminent Domain/Condemnation [3 Declaratory Judgment M Ground Rent n Mandamus r1i Landlord/Tenant Dispute rq- Non-Domestic Relations 0 Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY M Mortgage Foreclosure:Commercial 13 Quo Warranto ODental F-1 Partition 0 Replevin El Legal M Quiet Title Other: [] Medical 0 Other: Faulty construction n Other Professional: of residential addition Updated 11112011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION Plaintiff(s)&Address(es) William E. Butler and Maryanne E. Gashi-Butler 155 Mount Rock Road . Newville, PA 17241 l�, Case No. _� v Civil Term VS. Civil Action Defendant(s)& Address(es) McCoy Brothers, Inc. 1514 Commerce Avenue Carlisle, PA 17013 PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue summons in the above caseC y C Writ of Summons shall be issued and forwarded to Attorne Sheriff. Please Circle choice =G -+4 l w- YVA-S C, Date: w"t- 7 f Signature of Attorney Print Name: Kathleen Misturak-Gingrich, Esq. Address: 5006 E. Trindle Road, Suite 203 Mechanicsburg, PA 17050 Telephone#:717-591-1755 Q Supreme Court ID Number: 41682 S . . . . . c pi set 8S I WRIT OF SUMMONS 301 a 011 TO: McCoy Brothers, Inc. YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAIN ) /q4-VE COMMENCED AN ACTION AGAINST YOU. Date: by t` roonotary/Clerk,Civil ivision � � Deputy Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ";U.6 -t r ice_ DI comb. l C THE P R Q T H ON iQ TA OFFICE OF THE SHERIFF 2314 JUL 1 1 Ati 10: 20 CUMBERLAND COUNTY PENNSYLVANIA William E Butler (et al.) vs. McCoy Brothers, Inc. Case Number 2014-3820 SHERIFF'S RETURN OF SERVICE 07/03/2014 01:55 PM - Deputy William Cline, being duly sworn according to law, served the requested Writ of Summons by handing a true copy to a person representing themselves to be Mercedes Kiaser, Front Desk Clerk, who accepted as "Adult Person in Charge" for McCoy Brothers, Inc..t 1 ,14 Commerce Avenue, South Middleton Township, Carlisle, PA 17015. CCINE!P EPUTY SHERIFF COST: $34.78 SO ANSWERS, July 07, 2014 (cy CountySuito Sheriff, Toleosoii, Inc. RONR ANDERSON, SHERIFF Kathleen Misturak-Gingrich, Esquire THE LAW OFFICES OF PETER J. RuSSO, P.C. 5006 E. Trindle Road, Suite 203 Mechanicsburg, PA 17050 Phone: (717) 591-1755 Email: kgingrich@pjrlaw.com SET 29 f'i 11: t;`? PENNSYLVANIA WILLIAM E. BUTLER, IN THE COURT OF COMMON MARYANN E. GASHI-BUTLER, PLEAS OF CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA v. DOCKET NO. 2014-3820 McCOY BROTHERS, INC., • Defendant CIVIL ACTION -LAW UNCONTESTED MOTION FOR ADMISSION PRO HAC VICE OF MARYANN E. GASHI-BUTLER Plaintiffs, William E. Butler, and Maryann E. Gashi-Butler, by and through their attorneys, Kathleen Misturak-Gingrich, Esquire and the Law Offices of Peter J. Russo, P.C. hereby move this honorable Court for Plaintiffs' Motion for Admission Pro Hac Vice of Maryann E. Gashi-Butler, Esquire in this action, and as grounds therefore aver as follows: 1. Pursuant to 231 Pa. Code § 1012.1, I hereby move for admission Pro Hac Vice of candidate Maryann E. Gashi-Butler, Esquire to practice before The Court of Common Pleas of Cumberland County in the above -captioned docket, No. 14 -3820 -CV, in which she and her husband, William E. Butler, are Plaintiffs. 2. The information required by Section 81.504 of the IOLTA regulations has been provided to the IOLTA Board. A copy of the fee payment certification from the IOLTA Board is attached as Exhibit "A" and incorporated by reference. 4. In support of this Motion, a verification from candidate Maryann E. Gashi-Butler, Esquire, pursuant to 231 Pa. Code § 1012.1 (c), is attached as Exhibit "B" and incorporated by reference. 5. Additionally in support of this Motion, I am supplying a sponsor verification pursuant to 231 Pa. Code § 1012.1 (d) (2), which is attached as Exhibit "C" and incorporated by reference. 6. Upon grant of Pro Hac Vice admission, Applicant does not intend to personally conduct any depositories or to represent Plaintiffs at trial. 7. Pursuant to local rule of Court C.C.R.P. 208.3 (a)(9), the concurrence of opposing counsel of record, Dean F. Piermattei, Esquire, was sought and the response of said counsel is that he concurs with the Motion for Admission Pro Hac Vice. 8. Pursuant to local rule of Court C.C.R.P 208.3(a)(2), this certifies that no judge has ruled upon any other issue in the same or any related matter. WHEREFORE, it is respectfully requested that an order be entered granting the admission Pro Hac Vice of Maryann E. Gashi-Butler, Esquire in the above -captioned proceeding. Date: Respectfully submitted, LAW OFFICES OF PETER J. Russo, P.C. hiLes Kathleen Misturak-Gingrich, Esquire Attorney I.D. No. 41682 5006 East Trindle Road, Suite 203 Mechanicsburg, PA 17050 Phone: (717)591-1755 Counsel for Plaintiffs EXHIBIT "A" ‘"t, / SUPREME COURT OF PENNSYLVANIA PENNSYLVANIA "N^^^��"�°�� .Y� LAWYERS TRUST ACCOUNT BOARD September 16, 2014 MARYANNELIZABETH GASH|-BUTLER.Esq. MARYANN ELIZABETH GASHI-BUTLER 155 MOUNT ROCK ROAD NEWVILLE, PA 17241 SENT TO MARYANN ELIZABETH GASHI-BUTLER VIA Email: MBUTLER@PRIMROSEHILLPRESS.COM Dear Attorney GASHI-BUTLER: This Ietter serves as the fee payment payment certification referenced in 204 Pa Code §81 .503 and acknowledges receipt of the $200.00 fee paid by Online Payment on this date related to your pursult for admission pro hac vice in the case identified as William E. BuUor, Maryann E. Gashi-Butler v. McCoy Brothers, Inc., no. 2014-3820, filed in Court of Common Pleas of Cumberland County. You should referto Pa Rule of CiviI Procedure 1012,1, Iocalcourt rules, and other regulations of 204 Pa Code §81.501 et seq. concerning additional requirements related to seeking pro hac vice admission. Sincerely, "crIctuue- Stephanie S. Libhart Executive Director cc: Kathleen Misfuxmk-Gingrich,Eoq. Pennsylvania Judicial Center 601 Commonwealth Avr,Ste. Z408 P0Box 62445,Harrisburg, pA 17106'2445 717/230'2001 '88Q/PA'lOLT8(724'6582)717/238-2003 FAX Administering Pennsylvania's Interest CmL' mTmstArcount(I0iTA)prngmm EXHIBIT "B" CANDIDATE'S VERIFIED STATEMENT IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE I, Maryann E. Gashi-Butler, Esquire state the following: 1. I am a member in good standing of the District of Columbia Bar and the Commonwealth of Massachusetts Bar: The District of Columbia Bar 1101 K Street, NW Washington, D.C. 20005 (202) 737-4700 http://www.dcbar.org Membership number 375915 Board of Bar Overseers 99 High Street Boston, Massachusetts 02110 (617) 728-8700 http://www.massbbo.org Membership number 545238 2. With respect to both jurisdictions in which I am licensed, I have never been suspended, disbarred, or otherwise disciplined. Nor am I subject to any disciplinary proceedings before either jurisdiction. 3 I have never before applied for admission Pro Hac Vice in any case in a court in Pennsylvania. 4. I shall comply with and be bound by the applicable statutes, case law, and procedural rules of the Commonwealth of Pennsylvania, including the Pennsylvania Rules of Professional Conduct. 5. I shall submit to the jurisdiction of the Pennsylvania courts and the Pennsylvania Disciplinary Board with respect to acts and omissions occurring during the appearance in the above -captioned matter referenced in the accompanying Motion for Admission Pro Hac Vice. 6. I have consented to the appointment of Kathleen Misturak-Gingrich, the sponsor of the accompanying Motion for Admission Pro Hac Vice, as the agent upon whom service of process shall be made for all actions, including disciplinary actions that may arise out of the practice of law in the above -captioned matter in which admission Pro Hac Vice is sought. 7. To the best of my personal knowledge, information and belief, I do hereby verify that the facts averred and statements made in the foregoing Candidate's Statement in Support of Motion for Admission Pro 1-Iac Vice are true and correct. I understand that false statements or averments therein made will subject Me to the criminal penalties of 18 Pa. C.S. A. § 4904 relating to unsworn falsification to authorities. Date: 9 <9•I 41 Maryaiin E. Gashi-Butler, Esquire 155 Mount Rock Road Newville, Pa 17241 Telephone: 717-776-7359 Email: mbutler(4rimrosehillpress.00111 SPONSOR'S VERIFIED STATEMENT IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE I, Kathleen Misturak-Gingrich, state the following: 1 After reasonable investigation, I reasonably believe Maryann E. Gashi-Butler, Esquire to be a reputable competent attorney, and am in a position to recommend her admission Pro Hac Vice in the above -captioned matter. 2. I am not acting as the sponsor of a candidate for admission Pro Hac Vice in any other cases in courts of record in the Commonwealth of Pennsylvania. 3 The proceeds from the settlement of any cause of action in which candidate Maryann E. Gashi-Butler, Esquire is granted admission Pro Hac Vice shall be received, held, distributed, and accounted for in accordance with Rule 1.15 of the Pennsylvania Rules of Professional Conduct, including the IOLTA provisions thereof, if applicable. 4. To the best of my personal knowledge, information and belief, I do hereby verify that the facts averred and statements made in the foregoing Sponsor's Statement in Support of Motion for Admission Pro Hac Vice are true and correct. I understand that false statements or averments therein made will subject me to the criminal penalties of 18 Pa. C.S. A. § 4904 relating to unsworn falsification to authorities. Date: 2 o Kathleen Misturak-Gingrich, Esquire Law Offices of Peter J. Russo, P.C. 5006 East Trindle Road, Suite 203 Mechanicsburg, PA 17050 Phone: (717)591-1755 kgingrich@pj rl aw.com WILLIAM E. BUTLER, : IN THE COURT OF COMMON MARYANN E. GASHI-BUTLER, : PLEAS OF CUMBERLAND COUNTY, Plaintiffs • . PENNSYLVANIA v. MCCOY BROTHERS, INC. Defendant DOCKET NO. 2014-3820 CIVIL ACTION -LAW CERTIFICATE OF SERVICE I, Melissa M. Mehaffey, Paralegal to Kathleen Misturak-Gingrich, Esquire, hereby certify that a true and correct copy of the foregoing Uncontested Motion for Admission Pro Hac Vice of Maryann E. Gashi-Butler, Esquire has been served upon the following via first class mail, postage prepaid, addressed as follows: Dated: q [Li Dean F. Piermattei, Esquire RHOADS & SINON, LLP 1 South Market Square 12th Floor, P.O. Box 1146 Harrisburg, PA 17108-1146 Attorneys for Defendant ehaffey, egal • i L PENNS i'LV.'.,;iA WILLIAM E. BUTLER, IN THE COURT OF COMMON MARYANN E. GASHI-BUTLER, PLEAS OF CUMBERLAND COUNTY, Plaintiffs • PENNSYLVANIA v. DOCKET NO. 2014-3820 MCCOY BROTHERS, INC. Defendant CIVIL ACTION—LAW ORDER GRANTING UNCONTESTED ADMISSION PRO HAC VICE OF MARYANN E. GASHI-BUTLER, ESQUIRE AND NOW,this Zr! day of 00-019.c 2014, upon consideration of the foregoing Plaintiffs' Uncontested Motion for Admission PRO HAC VICE of Maryann E. Gashi- Butler, Esquire, said MOTION is hereby GRANTED. BY THE COURT: J. Distribution: Kathleen Misturak-Gingrich, Esquire, LAw OFFICES OF PETER J. Russo, P.C., 5006 E. Trindle Road, Suite 203, Mechanicsburg, PA 17050 ✓ Dean F. Piermattei, Esquire, RHOADS&SIvON, LLP 1 South Market Square, 12th Flom; P.O. Box 1146, Harrisburg, PA 17108-1146 ./Maryann E. Butler, Esquire, 155 Mount Rock Road, Newville, PA 17241 ( , ies5 r12.� CL