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HomeMy WebLinkAbout14-4891 Supreme Court-lofrPennsylvania Court'0 6mmon, leas For Prothonotary Use Only: 'I t. f . yl% 1'l t f/ Civil Cover Sheet �'\ - t• Docket No: �f Cumberland'` , County The informution collected on this form is used solely for court administration purposes. This forni 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 0 Complaint x Writ of Summons ❑ Petition E m 0 Transfer froAnother Jurisdiction 0 Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T Post Acute Medical, LLC Sara C. Harper I Are money damages requested? 0 Yes D No Dollar Amount Requested: Dwithin arbitration limits O (check one) []outside arbitration limits N Is this a Class Action Suit? 0 Yes El No Is this an MDJAppeal? 0 Yes 0 No A Name of Plaintiff/Appellant's Attorney: Robert J. Tribeck, Esquire and John R. Martin, Esquire 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 A9ass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS 0 Intentional 0 Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Debt Collection: Credit Card 0 Board of Assessment 0 Motor Vehicle 0 Debt Collection: Other Board of Elections Nuisance 0 Dept.of Transportation Premises Liability in Statutory Appeal:Other S 0 Product Liability(does not include 0 Employment Dispute: E mass tort) El Slander/Libel/Defamation Discrimination C 0 Other: Employment Dispute: Other E] Zoning Board T+ El Other: I x© Other: O MASS TORT Breach of Contract 0 Asbestos N 0 Tobacco 0 Toxic Tort-DES 0 Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ID Toxic Waste 0 Other: El Ejectment 0 Common Law/Statutory Arbitration B 0 Eminent Domain/Condemnation 0 Declaratory Judgment 0 Ground Rent 0 Mandamus 0 Landlord/Tenant Dispute 0 Non-Domestic Relations 0 Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure:Commercial Quo Warranto 0 Dental El Partition 0 Replevin El Legal 0 Quiet Title Other: 0 Medical 0 Other: 0 Other Professional: Updated 1/1/2011 POST ACUTE MEDICAL, LLC IN THE COURT OF COMMON PLEAS OF 3500 Market Street, Suite 102 CUMBERLAND COUNTY, Camp Hill, PA 17011 1PENNSYLVANIA 1 Plaintiff, M ci V. Civil Action No. r SARA C. HARPER C) FCOY 6 Redwood Place lo Camp 4- Hill, PA 17011 Defendant 1/5 75 19 PRAECIPE FOR WRIT OF SUMMONS j ) TO THE PROTHONOTARY: Please issue a Writ of Summons against the Defendant in the above-captioned action. The Writ shall be issued and returned to the undersigned counsel of record. Robert J. Tribeck, Esquire Supreme Court ID No. 74486 John R. Martin, Esquire Supreme Court ID No. 204125 RHOADS & SINON LLP One South Market Square P. O. Box 1146 Harrisburg, PA 17108-1146 Date: (717) 233-5731 Attorneys for Plaintiffs WRIT OF SUMMONS TOTHEABOVE NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. bA�Xm q. 4Prihonotary apc bb. u 952867.1 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY. OFF1Cii OF H r - (/t' X7 C ANDCOU AtN>✓$ L VAIv/ NT Y Post Acute Medical, LLC vs. Sara C Harper Case Number 2014-4891 SHERIFF'S RETURN OF SERVICE 08/19/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Sara C Harper, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Writ of Summons according to law. 08/25/2014 09:16 AM - The requested Writ of Summons served by the Sheriff of York County upon Sara C Harper, personally, at 6 Redwood Place, Camp Hill, PA 17011. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, September 18, 2014 RONO R ANDERSON, SHERIFF (c) CountySuite Sheriff, Te!eosoft, !nc SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber Sheriff Michael S. Hose Chief Deputy, Operations POST ACUTE MEDICAL, LLC vs. SARA C. HARPER PETER J. MANGAN, ESQ. Solicitor Richard E Rice, II Chief Deputy, Administration Case Number 14-4891 CIVIL SHERIFF'S RETURN OF SERVICE 08/25/2014 09:16 AM - DEPUTY TAYLOR ECK, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED WRIT OF SUMMONS (WOSM) BY "PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT: SARA C. HARPER AT 6 REDWOOD PLACE, CAMP HILL, PA 17011. TAYLOR E K,DEPUTY SHERIFF COST: $45.40 SOA ERS, September 17, 2014 RICH RD P K UERLEBER, SHERIFF COMMONWEALTH OF PENNSYLVAN A Itiotiriai Seal Lisa L. Thorpe, Notary Public City of York, York County My Commissron Expires Aug. 12, 2017 MEMBER, PENNSYLVANIA ASSCTIATION OF NOTARIES Affirmed and subscribed to before me this 17TH day of SEPTEMBER NOTARY 2014 (C) CourdySuiie Sherif, Telecsoit: Robert J.Tribeck,Esquire i�`i — 3�a Attorney I.D.No.74486 a' 1 s - John R. Martin,Esquire �' L1 �. Attorney I.D.No.204125 . �d5 RHOADS&SINON LLP r- I '1 i One South Market Square P.O. Box 1146 Harrisburg,PA 17108-1146 Phone: (717) 233-5731 Attorneys for Plaintiffs POST ACUTE MEDICAL, LLC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff, PENNSYLVANIA v. Civil Action No. 2014-4891 SARA C. HARPER Defendant PROOF OF SERVICE Attached hereto as Exhibit "A" is a true and correct copy of the Sheriff's Return of Service of the Writ of Summons, which was served upon the above-referenced Defendant on August 25, 2014. Respectfully submitted, RHOADS & SINON LLP By: ��-- Robert J. Tribeck, Esquire Supreme Court ID No. 74486 John R. Martin, Esquire Supreme Court ID No. 204125 RHOADS & SINON LLP One South Market Square P. O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Plaintiffs 966045.1 EXHIBIT "A" 690169.1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ,tiitil" Jody S Smith Chief Deputy Richard W Stewart Solicitor Post Acute Medical, LLC vs. Case Number Sara C Harper 2014-4891 SHERIFF'S RETURN OF SERVICE 08/19/2014 Sheriff Ronny R Anderson, being duly svmrn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Sara C Harper, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Writ of Summons according to law. 08/25/2014 09:16 AM -The requested Writ of Summons served by the Sheriff of York County upon Sara C Harper, personally, at 6 Redwood Place, Camp Hill, PA 17011. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, September 18, 2014 RON R ANDERSON, SHERIFF tier SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber oFs op,, p, PETER J. MANGAN ESQ. Sheriff y r `� ' Solicitor Michael S. Hose �y Richard E Rice, II Chief Deputy, Operations ca' Chief Deputy,Administration POST ACUTE MEDICAL, LLC vs. Case Number SARA C. HARPER 14-4891 CIVIL SHERIFF'S RETURN OF SERVICE 08/25/2014 09:16 AM- DEPUTY TAYLOR ECK, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED WRIT OF SUMMONS(WOSM) BY"PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT: SARA C. HARPER AT 6 REDWOOD PLACE, CAMP HILL, PA 17011. TAYLOR ECK, DEPUTY SHERIFF COST: $45.40 SOA ERS, MIL � , September 17, 2014 RICHARD P K UERLEBER, SHERIFF COMMONWEALTH OF PENNSYLVANIA i iota.lai Seal Lisa L. Thorpe, Notary Public City of York, York County My Commission Expires Aug. 12,2017 MEMBER,PEUN4SYLVA8L1 ASaCgATION Of NOTARIES NOTARY Affirmed and subscribed to before me this f � 17TH day of SEPTEMBER 2014 / / / /0—'9 721 irso• Ir.e. CERTIFICATE OF SERVICE I hereby certify that on this 1st day of October, 2014, a true and correct copy of the foregoing document was served by means of United States mail, first class, postage prepaid, upon the following: Sara C. Harper 6 Redwood Place Camp Hill, PA 17011 d AA._,Q)),6210.A