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HomeMy WebLinkAbout14-5076 Supreme Co, J" 'n nsylvania Cour. Dcdmmto s-leas For Prothonotary Use Only: C i1Ci0— �1ht Docket No: CUI L N County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by laws or rules of court. Commencement of Action: S Complaint x Writ of Summons ® Petition ® Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Nancy L.Wright and William R.Wright, Jr. Her Husband Heather Brechbill T Dollar Amount Requested: ®within arbitration limits I Are money damages requested? El Yes [I No (check one) Eloutside arbitration limits O N Is this a Class Action Suit? 0 Yes IR No Is this an MDJAppeal? ® Yes El No A, Name of Plaintiff/Appellant's Attorney: Gerard C. Kramer, Esquire E-1 Check here if you have no attorney(are a Self-Represented JPro 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 ® Buyer Plaintiff Administrative Agencies Malicious Prosecution ® Debt Collection:Credit Card ® Board of Assessment z Motor Vehicle 13 Debt Collection:Other Board of Elections Nuisance 13 Dept.of Transportation S nPremises Liability Statutory Appeal:Other Q Product Liability (does not include � Employment Dispute: mass tort) E Discrimination Slander/Libel/Defamation C MJ Other: � Employment Dispute:Other 0 Zoning Board Q Other: ,I, I 1] Other: O MASS TORT M Asbestos N r] Tobacco M Toxic Tort-DES ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste 13 Ejectment Q Common Law/Statutory Arbitration B 0 Other: Declaratory.Judgment Eminent Domain/Condemnation ® Ground Rent ® Mandamus n Landlord/Tenant Dispute ®Non-Domestic Relations ® Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY Mortgage Foreclosure:Commercial ®Quo Warranto n Dental ® Partition 0 Replevin 13 Legal ® Quiet Title 13 Other: 0 Medical ® Other: Other Professional: Updated 1/1/2011 L: t7Ti,r@1 }ar:r ' it?a AUC 8 pt; 2 CU ' Eat�t YL d p N/At'�-F, PENNS , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. )1- 507ZO Civil Action (X) Law ( ) Equity NANCY L. WRIGHT AND WILLIAM HEATHER BRECHBILL R. WRIGHT, JR., HER HUSBAND 949 Raystown Circle 1466 Woods Road Lot #22 Shippensburg, PA 17257 Shippensburg, PA 17257 Plaintiffs Defendant PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Writ of Summons in the above-captioned action. X A Writ of Summons shall be issued and forwarded to ( ) Attorney (x) Sheriff. ff ii Date: 1`'i rard C. Kramer, Esquire I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 (t) (717) 232-6467 (fl gkramer@schmidtkramer.com Attorney for Plaintiffs CIZ) 3D739 '3102 b r) NANCY L. WRIGHT AND WILLIAM : IN THE COURT OF COMMON PLEAS R. WRIGHT, JR., HER HUSBAND, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : 0, V. No. �[Ul ' HEATHER BRECHBILL, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. n1 0_ : A P thonotary Date: �o� Deputy ( ) Check here if reverse is issued for additional information SCHMIDT KRAMER PC E; ` i H E P R O I hO N O T/' R .i. By: Gerard C. Kramer, Esquire 209 State Street 2014 OCT -9 i' 12: 47 Harrisburg, PA 17101 (717) 232-6300 (t) CUMBERLAND COUNTY (717) 232-6467 (f) PENNSYLVANIA gkrainer@schmidtkramer. com Attorney for Plaintiff(s) NANCY L. WRIGHT AND WILLIAM R. WRIGHT, JR., HER HUSBAND, Plaintiff . IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 14-5076 CIVIL HEATHER BRECHBILL, •CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE, AND END PLEASE mark the above -captioned action settled, discontinued, and ended, with prejudice. Date: (v-- -I)( By: Respectfully submitted, SCHMIDT KRAMER PC G and C. Kramer, Esquire .D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 (t) (717) 232-6467 (f) gkramer@schmidtkramer.com Attorney for Plaintiff(s) SCHMIDT KRAMER PC By: Gerard C. Kramer, Esquire 209 State Street Harrisburg, Pa 17101 (717) 232-6300 (t) (717) 232-6467 (f) gkramer@schmidtkramer. corn Attorney for Plaintiff(s) CERTIFICATE OF SERVICE AND NOW, this r day of C'\00Q {, 2013, I, Gerard C. Kramer, Esquire, hereby certify that I have this day served a true and correct copy of Praecipe to Settle, Discontinue, and End by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Date: ` 7- /7 Elyse Klopp Nationwide 1 Nationwide Gateway Dept 5867 Des Moines, IA 50391 Respectfully submitted, SCHMIDT KRAMER PC By: rd C. Kramer, Esquire . No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 (t) (717) 232-6467 (f) gkramer@schmidtkramer.com Attorney for Plaintiff(s) SHERIFF'S OFFICE OF CUMBERLAND COUNTY ' �-r RnnnyPkAnderaon __ Fn_c' :'"/rx'e PROTHONOTARY HE Sheriff O Jody S Smith Chief Deputy Richard W Stewart Solicitor 7814 OCT 13 WA: 06 CH T�� PENNSYLVANIA ,.` Nancy L Wright vs. Heather Brechbill Case Number 2014-5076 SHERIFF'S RETURN OF SERVICE 0E/29/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Heather Brechbill, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Writ of Summons according to Iaw. 08/25/2014 The requested Writ of Summons returned by the Sheriff of Franklin County, the within named Defendant Heather Brechbill, not found. Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. *Address was incorrectly believed to be in Cumberland County, verified with both Cumberland County Control and Franktin Couaty that this address is indeed located in Franklin County* 10/02/2014 Ronny R Anderson, Sheriff, who being duly sworn according to law, states this Writ of Summons upon defendant Heather Brechbill is returned not served per request from attorney Kramer. SHERIFF COST: $37.49 SO ANSWERS, October 02, 2014 RONNYRANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoff, SHERIFF'S RETURN - NOT FOUND CASE NO: 2014-00315 T COMMONTWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN NANCY L WRIGHT VS HEATHER BRECHBILL ANGEL LAVIENA , Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: BRECHBILL HEATHER ,but was unable to locate Her in his bailiwick. He therefore returns the WRIT OF SUMMONS , NOT FOUND , as to the within named DEFENDANT , BRECHBILL HEATHER 949 RAYSTOWN CIRCLE SHIPPENSBURG, PA 17257 ADDRESS LOCATED IN CUMBERLAND COUNTY PA Sheriff's Costs: So answers: Docketing .00 700 Service .00 l Affidavit .00 ANG LA IENA Surcharge .00 .00 DANE M ANTHONY, Sheriff .00 GERALD C KRAMER ESQ 09/25/2014 Sworn and subscribed to before me this al*Wk day o 0A.D. Notary COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL , 9 RICHARD D. McCARTY, Notary Public Chambersburg Boro., Franklin County My _Commission lEpires Jan. 29, 2015 10-06-'14 14:14 FROM - INJURY LAWYERS • October 2, 2014 •Via Fax:. 240-6397 Cumberland County Sheriffs Office • Cumber1a.nd County' Courthouse • One Courthouse. Square • ,Carlisle, PA 17013-3387 Re: Wright v. Brechbill Dear Ann:. T -195 P0002/0002 F-988 209'St ,to.street. • Harrkrkbrarg, P nnsyiverdk.17141. 71.7.888:88 /3)(117.232 64677 .virwint;s cdistidtkrarnir. cciao Please be advised thatthe above case has •been settled and we would .like to withdraw our request for service upon Heather Brechbill. 1 .you have any questions, please feel free to call. or 'write. Very truly yours, SCHMIDT KRA erard C. Kramer. Attorney at Law OCK/ fir