The URL can be used to link to this page

Home My WebLink About14-4045 Supreme Court of Pen nt4Ofr. nsylvania CouComrnon Pleas For Prothonotary Use Only: CX�rI'CioverySh.et Docket No: �...�r. S Cu berland County t f' { The information collected on this form is'nsed solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S 0 Complaint [E Writ of Summons Petition E 0 Transfer from Another Jurisdiction Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T Thomas J. Kuhn, Jr. AA Specialty Contractors, Inc. I Are money damages requested? Q Yes El No Dollar Amount Requested: Owithin arbitration limits 0 (check one) Ooutside arbitration limits N Is this a Class Action Suit? 0 Yes ED No Is this an MDJAppeal? Yes ix, No A Name of Plaintiff/Appellant's Attorney: Katie J. Maxwell, Esquire/Martson Law Offices 0 Check.here if you have no attorney(are a Self-Represented (Pro Sel 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 0 Intentional l Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Debt Collection: Credit Card 0 Board of Assessment 0 Motor Vehicle Debt Collection: Other 0 Board of Elections 0 Nuisance 0 Dept.of Transportation 0 Premises Liability 0 Statutory Appeal:Other S 0 Product Liability(does not include E mass tort) 0 Employment Dispute: Slander/Libel/Defamation Discrimination 0 C 0 Other: El Employment Dispute: Other 0 Zoning Board T 0 Other: I Otl� O MASS TORT ✓ C�M�1�atw 0 Asbestos N 0 Tobacco `.._.l Toxic Tort-DES 0 Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste 0Ejectment Common Law/Statutory Arbitration B 0 Other: Eminent Domain/Condemnation 0 Declaratory Judgment Ground Rent Mandamus 0 Landlord/Tenant Dispute g Non-Domestic Relations 0 Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure: Commercial 0 Quo Warranto 0 Dental 0 Partition 0 Replevin 0 Legal 0 Quiet Title Other: 0 Medical 0 Other: Other Professional: Updated 111/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION Plaintiff(s)&Address(es) Thomas J. Kuhn, Jr., and Ella K. Kuhn 2145 Newville Road Carlisle, PA 17015 , Case No. 14 - �D�7 Civil Term VS. Civil Action Law Defendant(s)&Address(es) SEE ATTACHED SHEET r-n c d C . PRAECIPE FOR WRIT OF SUMMONS r TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue summons in the above case Writ of Summons shall be issued and forwarded to Attorney/Sheriff. Please Circle choice / / �GiLlitiL Date : 7//O�/�f Sig of Attorney Print Name: Katie A.Maxwell, Esquire Address: 10 East High Street Carlisle, PA 17013 Telephone#:(717) 243-3341 Supreme Court ID Number: 206018 �� WRIT �ONS TO: � YOU ARIAOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S)HAS/HAVE COMMENCED AN ACTION AGAINST YOU. 24�� 1 t.Lt—,Prothonotary/Clerk, Civil Division Date: , Deputy A fj AA SPECIALTY CONTRACTORS, INC. 4180 Chambers Hill Road Harrisburg, PA 17111 AAA SPECIALTY CONTRACTORS, INC. 402 Clinton Road Harrisburg, PA 17109 SEABOARD CONTRACTORS, LLC 1858 Bradley Drive Harrisburg, PA 17110 PRIMO DiSANTO 1858 Bradley Drive Harrisburg, PA 17110 .1 Katie J. Maxwell, Esquire Attorney I.D. No. 206018 MARTSON DEARDORFF WILLIAMS OTTO GILROY& FALLER I it MARTSON LAW UMOFFICES ��4040 ;G'�1 C` 10 East High Street t�cPiNSYL`�'�at Carlisle, PA 17013 (717) 243-3341 THOMAS J. KUHN, JR. and : IN THE COURT OF COMMON PLEAS OF ELLA L. KUHN, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : NO. 14 - 4045 CIVIL TERM AA SPECIALTY CONTRACTORS, INC., AAA SPECIALITY CONTRACTORS, INC., : SEABOARD CONTRACTORS, LLC, and : CIVIL ACTION - LAW PRIMO DiSANTO, Defendants PRAECIPE To the Prothonotary: Please change the middle initial of Plaintiff Ella Kuhn from Ella K. Kuhn to Ella L. Kuhn. MARTSON LAW OFFICES By: Katie J. Maxw 1, squire 10 East High SVeet Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs Date: ` Gb (� SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R AndersonFt, -F C` ii;,.WII� Sheriff• SCI'' vattiirn6N.i,. Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE QF THE C`i4ERI F JUL 31 37 CUMBERLAND COUNTY PENNSYLVANIA Thomas John Kuhn, Jr vs. Case Number AA Specialty Contractors, Inc. (et al.) 2014-4045 SHERIFF'S RETURN OF SERVICE 07/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: AA Specialty Contractors, Inc., but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Writ of Summons according to law. 07/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: AAA Specialty Contractors, Inc., but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Writ of Summons according to law. 07/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Seaboard Contractors, LLC, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Writ of Summons according to law. 07/10/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Primo DiSanto, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania to serve the within Writ of Summons according to law. 07/18/2014 The requested Writ of Summons returned by the Sheriff of Dauphin County, the within named Defendant AA Specialty Contractors, Inc., not found. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. 07/21/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: AAA Specialty Contractors, Inc., but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Summons as "Not Found" at 402 Clinton Road, Harrisburg, PA 17109. 07/21/2014 The requested Writ of Summons served by the Sheriff of Dauphin County upon Mary Crowley, Fiancee of Defendant, who accepted for Primo DiSanto, at 1858 Bradley Drive, Harrisburg, PA 17110. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. 07/21/2014 The requested Writ of Summons served by the Sheriff of Dauphin County upon Mary Crowley, Fiancee of Owner, who accepted for Seaboard Contractors, LLC, at 1858 Bardley Drive, Harrisburg, PA 17110. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $76.98 SO ANSWERS, July 28, 2014 (c) C,ountySuite Sheriff, Teleoseft, Inc. RONR ANDERSON, SHERIFF Shelley Ruhl Real Estate Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania County of Dauphin Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy THOMAS J. KUHN, JR. AND ELLA K. KUHN VS • ▪ AA SPECIALTY CONTRACTORS, INC. Sheriffs Return No. 2014-T-2013 OTHER COUNTY NO. 2014-4045 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for AA SPECIALTY CONTRACTORS, INC. the DEFENDANT named in the within WRIT OF SUMMONS and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, JULY 18, 2014. ADDRESS 4180 CHAMBERS HILL ROAD, HARRISBURG, PA 17111 IS NOW H&S TOWING; DEFENDANT IS NO LONGER AT THIS ADDRESS. Sworn and subscribed to before me this 22ND day of July, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, By Depu Sheriff Deputy: JESSICA KARL Sheriffs Costs: $105 7/15/2014 Shelley Ruhl Real Estate Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania :th E. I Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy THOMAS J. KUHN, JR. AND ELLA K. KUHN VS County of Dauphin AA SPECIALTY CONTRACTORS, INC. Sheriffs Return No. 2014-T-2013 OTHER COUNTY NO. 2014-4045 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry -for AAA SPECIALTY CONTRACTORS, INC. the DEFENDANT named in the within WRIT OF SUMMONS and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, JULY 21, 2014. DEFENDANT IS NO LONGER LOCATED AT ADDRESS 402 CLINTON ROAD, HARRISBURG, PA 17109; BUSINESS NO LONGER EXISTS. DEFENDANT PRIMO DISANTO IS THE FORMER OWNER. Sworn and subscribed to before me this 22ND day of July, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, Sheriff of By Deputy Sheriff Deputy: W CONWAY Sheriffs Costs: $105 7/15/2014 ShelleylRuhl Real Estale Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy THOMAS J. KUHN, JR. AND ELLA K. KUHN VS County of Dauphin AA SPECIALTY CONTRACTORS, INC. Sheriffs Return No. 2014-T-2013 OTHER COUNTY NO. 2014-4045 And now: JULY 21, 2014 at 5:48:00 PM served the within WRIT OF SUMMONS upon PRIMO DISANTO by personally handing to MARY CROWLEY * 1 true attested copy of the original WRIT OF SUMMONS and making known to him/her the contents thereof at 1858 BRADLEY DRIVE HARRISBURG PA 17110 * FIANCEE OF DEFENDANT Sworn and subscribed to before me this 22ND day of July, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, puty Sheriff Deputy: W CONWAY Sheriffs Costs: $105 7/15/2014 Mktir Shelley Ruhl Real Estate Deputy Matthew L. Owens Solicitor Commonwealth of Pennsylvania County of Dauphin ifie Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy THOMAS J. KUHN, JR. AND ELLA K. KUHN VS • ▪ AA SPECIALTY CONTRACTORS, INC. Sheriffs Return No. 2014-T-2013 OTHER COUNTY NO. 2014-4045 And now: JULY 21, 2014 at 5:48:00 PM served the within WRIT OF SUMMONS upon SEABOARD CONTRACTORS, LLC by personally handing to MARY CROWLEY * 1 true attested copy of the original WRIT OF SUMMONS and making known to him/her the contents thereof at 1858 BRADLEY DRIVE HARRISBURG PA 17110 * FIANCEE OF OWNER Sworn and subscribed to before me this 22ND day of July, 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County My Commission Expires January 8, 2018 So Answers, Sheriff offs I • Deputy -Sheriff Deputy: W CONWAY Sheriffs Costs: $105 7/15/2014 THOMAS J. KUHN, JR. AND ELLA K. KUHN Plaintiffs v. AA SPECIALTY CONTRACTORS, AAA SPECIATY CONTRACTORS, SEABOARD CONTRACTORS, LLC, AND PRIMO DISANTO Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION — LAW NO. 14-4045 JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Andrew T. Kravitz, Esquire on behalf of the Defendants in the above captioned matter. Dated: O/ c OI t t Res • tfully, submitted, rew T. Kravitz, Esquire Law Offices of Matthew L. Owen I.D. No. 80142 2595 Interstate Drive, Suite 101 Harrisburg, PA 17110 CERTIFICATE OF SERVICE I, Sunni Elmore., an employee of the Law Offices of Matthew L. Owens, Esquire LLC, do hereby certify that on this 20th day of August, 2014, I served a copy of the foregoing Praecipe for Entry of Appearance, via First Class United States mail, postage prepaid as follows: Katie J. Maxwell, Esquire MARTSON LAW OFFICES 10 East High Street Carlisle, PA J7013 Sunni Elmore