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Home My WebLink About05-3183SCHMIDT, RONCA & KRAMER, P.C. BY: Scott B. Cooper, Esquire I.D. #70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorneys for Plaintiff scoopeit@srklaw.com Christina Sheaffer, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : CIVIL ACTION - LAW V. Tammy Samsel, No. OS- 3183 l_.1Ut Defendant JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 SCHMIDT, RONCA & KRAMER, P.C. BY: Scott B. Cooper, Esquire I.D. #70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorneys for Plaintiff scooner(&srklaw.corn Christina Sheaffer, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION - LAW Tammy Samsel, : No. Defendant : JURY TRIAL DEMANDED AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accibn dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accibn como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mds aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes Para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Scott B. Cooper, Esquire I.D. No. 70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 speterson@srklaw.com Attorney for Plaintiff CHRISTINA SHEAFFER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW TAMMY SAMSEL, NO. 05 Defendant l : JURY TRIAL DEMANDED COMPLAINT AND NOW COMES, the Plaintiff, Christina Sheaffer, by and through her attorneys SCHMIDT, RONCA AND KRAMER, P.C. and hereby avers as follow: 1. The Plaintiff, Christina Sheaffer, is an adult individual who resides at 6 Adams Street, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant, Tammy Samsel, is an adult individual who at all times relevant hereto has lived at 17 North York Road, Dillsburg, York County, Pennsylvania 17019. 3. The facts and occurrences hereinafter took place on or about July 6, 2003 on Wertzville Road in East Pennsboro Township, Cumberland County Pennsylvania. 4. At the aforementioned time and place, the Plaintiff was an operator of a 1988 Oldsmobile. 1 5. At the aforementioned time and place, the Defendant was traveling in the same direction operating a 1991 Kia, behind the Sheaffer vehicle. 5. At the aforementioned time and place, the Defendant, Tammy Samsel, rear-ended the Sheaffer vehicle, causing the injuries to Christina Sheaffer set forth below. COUNT I CHRISTINA SHEAFFER V. TAMMY SAMSEL NEGLIGENCE 6. Paragraphs 1 through 6 of the Plaintiff's Complaint are incorporated by reference and made a part thereof as if set forth in full. 7. The accident was caused by the negligence, carelessness and recklessness of the Defendant, and was in no way caused or contributed to by the Plaintiff. 8. The carelessness, negligence and recklessness of the Defendant consisted of the following: a. inattentiveness; b. failing to keep a reasonable look out for other vehicles lawfully on the roadway; c. failing to have her vehicle under proper and adequate control; d. failing to apply her brakes in time to avoid the collision with the Sheaffer vehicle; e. negligently applying her brakes; f. failing to observe the Sheaffer vehicle lawfully on the roadway; 2 g. failing to operate her vehicle in accordance with existing traffic conditions and traffic controls; h, operating her vehicle so as to create a dangerous situation for other vehicles on the roadway; i, operating her vehicle so that she could not stop within the assured clear distance ahead and; j. careless driving. 10. As a direct and proximate result of the accident and the Defendant's carelessness, negligence and recklessness, the Plaintiff, Christina sustained injuries which are serious and may be permanent including, but not limited to: a. lumbar strain; b. thoracic pain; and c. head pain. 11. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff has been advised and, therefore avers, that the aforementioned injuries may be permanent in nature and effect and, thus, a claim for these injuries is made. 12. As a direct and proximate result of the accident, the Plaintiff, and others on her behalf, have incurred medical expenses for the injuries she has sustained, and may continue to incur medical expenses into the future, and thus, a claim for these expenses is made. 3 13. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff has undergone in the past, and may continue to undergo in the future, great pain and suffering, and thus, a claim for these losses is made. 14. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff may have suffered a permanent diminution of her ability to enjoy life and life's pleasures, and thus, a claim for these losses is made. 15. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff has suffered a real loss of wages, and may have suffered an impairment of her future earning power and capacity, and thus, a claim for these losses is made. WHEREFORE, Plaintiff Christina Sheaffer demands judgment on the Defendant Tammy Samsel in an amount in excess of Thirty-Five Thousand ($35,000.00) Dollars and in excess of an amount requiring compulsory arbitration. Respectfully Submitted, SCHMIDT, RONCA & KRAMER, P.C. Scott B. Cooper, Esquire I.D. No. 70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff 4 VERIFICATION BASED UPON PERSONAL KNOWLEDGE AND INFORMATION SUPPLIED BY COUNSEL I, Christina Sheaffer, hereby verify that I am the Plaintiff in the foregoing action and that the attached Complaint is based upon the information which has been gathered by my counsel in preparation of this lawsuit. The language of the Complaint is that of counsel and is not mine. I have read the Complaint, and to the extent that it is based "upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Complaint is that of counsel, I have relied upon counsel in making this Verification. I understand that intentional false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsifications made to authorities. Date: 1 ft VIC-, qO Al K Christina Sheaffer H/ G ftl??. 'r ri G? t? 6 n? r.i c,n 43 Richard B. Druby, Esquire Attorney I.D. No. 61904 NESTICO, DRUBY & HILDABRAND, LLP 840 East Chocolate Avenue Hershey, PA 17033 (717) 533-5406 Attorney for Defendant ................................................................................ CHRISTINA SHEAFFER, Plaintiff V. TAMMY SAMSEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 05-3183 CIVIL TERM JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of undersigned counsel on behalf of Defendant, Tammy Samsel. Respectfully submitted, NESTICO, DRUB" HILDABRAND, LLP By: Richard B. Druby, Esgl[ir,?/ Attorney I.D. No. 6190 840 East Chocolate Avenue Hershey, PA 17033 (717) 533-5406 Attorney for Defendant CERTIFICATE OF SERVICE I, Amanda K. Dove, of the law firm of Nestico, Druby & Hildabrand, LLP, hereby certify that on the 201' day of July, 2005, a copy of the foregoing document was sent via First Class U.S. Mail, postage paid, to the following: Scott B. Cooper, Esquire Schmidt, Ronca & Kramer, PC 209 State Street Harrisburg, PA 17101 ADvy)& 4C ,? Amanda K. Dove -° ?? ?; o -r+ C-: u? „{ t.- q ; ` S -n i ? t ...3 i'T e N y ' ?? -fit ?i > ; > ?. rt fr7 =t `.?' Richard B. Druby, Esquire Attorney I.D. No. 61904 NESTICO, DRUBY & HILDABRAND, LLP 840 East Chocolate Avenue Hershey, PA 17033 (717) 533-5406 Attorney for Defendant ............................................................................... CHRISTINA SHEAFFER, Plaintiff V. TAMMY SAMSEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 05-3183 CIVIL TERM JURY TRIAL DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER After reasonable investigation, Defendant is without knowledge or information sufficient to form beliefs to the truth of the averments and they are therefore denied. 2. Admitted. 3. Denied. The allegations of Paragraph No. 3 are specifically denied. 4. Denied. The allegations of Paragraph No. 4 are specifically denied. 5. Denied. The allegations of Paragraph No. 5 are specifically denied. 6. (Incorrectly designated as Paragraph No.5) Denied. The allegations of Paragraph No. 6 are specifically denied. COUNTI 7. (Incorrectly designated as Paragraph No. 6) Paragraphs 1-6 above are incorporated herein by reference. 8. (Incorrectly designated as Paragraph No. 7) Conclusion of law, to which no response is required. To the extent a response is required, the allegations of Paragraph No. 8 are denied. 9. (Incorrectly designated as Paragraph No. 8) Conclusion of law, to which no response is required. To the extent a response is required, the allegations of Paragraph No. 9 including sub-paragraphs (a)-(j) are specifically denied. 10. Conclusion of law, to which no response is required. To the extent a response is required, the allegations of Paragraph No. 10 are specifically denied. 11. Denied. The allegations of Paragraph No. 11 are specifically denied. 12. Denied. The allegations of Paragraph No. 12 are specifically denied. 13. Denied. The allegations of Paragraph No. 13 are specifically denied. 14. Denied. The allegations of Paragraph No. 14 are specifically denied. 15. Denied. The allegations of Paragraph No. 15 are specifically denied. WHEREFORE, Defendant deman ds that Plaintiffs Complaint be dismissed with prejudice and the judgment be entered in her favor and against the Plaintiff, plus cost of this Action. NEW MATTER 16. Paragraphs 1-15 above are incorporated herein by reference. 17. Plaintiff has failed to state a claim upon which relief can be granted. 18. Plaintiff's claims are barred, in whole or in part, by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. 19. Plaintiff's claims may be barred, in whole or in part, by the selection of a limited tort option on applicable policies of insurance. 20. Plaintiff may have failed to mitigate her damages. 21. Defenses reserved pursuant to Pa.R.C.P. 1030(b) and all other defenses not required to be pleaded or hereby reserved. 22. Plaintiffs claims may be barred, in whole or in part, by any applicable statute of limitations. 23. If Plaintiff sustained damages as alleged, which is denied and of which strict proof is demanded, the same were caused by conditions for which Defendant is not responsible and/or the damages were not causally related to an accident involving Plaintiff and Defendant. 24. If the Plaintiff sustained damages as alleged, which is denied and of which strict proof is demanded, the same were caused by persons or parties over whom Defendant had no responsibility, authority or control. Respectfully LLP By: Pfichard B. Druby, E ui Attorney 1. D. No. 61 840 East Chocolate Avenue Hershey, PA 17033 (717) 533-5406 Attorney for Defendant VERIFICATION 1, Tammy Samsel, verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: / "a?8'u1005 Tam Samsel CERTIFICATE OF SERVICE 1, Richard B. Druby, of the law firm of Nestico, Druby & Hildabrand, LLP, hereby certify that on the 291h day of July, 2005, a copy of the foregoing document was sent via First Class U.S. Mail, postage paid, to the following: Scott Cooper, Esquire SCHMIDT, RONCA & KRAMER, P.C. Attorneys at Law 209 State Street Harrisburg, Pa 1710 Richard B. Druby ?- f ? ? ci? ? 3° _i ? -?? _ is Y_i } ^- 11 ! i? ?. 4r3 e __ _ ?. CHRISTINA SHEAFFER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. I : I CIVIL ACTION - LAW TAMMY SAMSEL, Defendant NO. 05-3183 JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER 16. Paragraph 16 is not directed toward answering Plaintiff, and therefore, no response is required. By way of further answer, if a response is deemed required, the Plaintiff incorporates the averments of her Complaint as if set forth in full. 17. Paragraph 17 of Defendant's New Matter is a conclusion of law to which no response is required. To the extent a response is required, the allegations of paragraph 17 are denied and strict proof is demanded thereof from the Defendant at trial. 18. Paragraph 17 of Defendant's New Matter is a conclusion of law to which no response is required. To the extent a response is required, the allegations of paragraph 17 are denied and strict proof is demanded thereof from the Defendant at trial. 19. Paragraph 19 of Defendant's New Matter is a conclusion of law to which no response is required. To the extent a response is required, the allegations of paragraph 19 are denied and strict proof is demanded thereof from the Defendant at trial. By way of further answer, Plaintiff had full tort at the time of this accident. (See Declaration Sheet attached hereto as Exhibit «A".) 1 20. Paragraph 20 of Defendant's New Matter is a conclusion of law to which no response is required. To the extent a response is required, the allegations of paragraph 20 are denied and strict proof is demanded thereof from the Defendant at trial. 21. Paragraph 21 of Defendant's New Matter is a conclusion of law to which no response is required. To the extent a response is required, the allegations of paragraph 21 are denied and strict proof is demanded thereof from the Defendant at trial. 22. Paragraph 22 of Defendant's New Matter is a conclusion of law to which no response is required. To the extent a response is required, the allegations of paragraph 22 are denied and strict proof is demanded thereof from the Defendant at trial. 23. Paragraph 23 of Defendant's New Matter is a conclusion of law to which no response is required. To the extent a response is required, the allegations of paragraph 23 are denied and strict proof is demanded thereof from the Defendant at trial. 24. Paragraph 24 of Defendant's New Matter is a conclusion of law to which no response is required. To the extent a response is required, the allegations of paragraph 24 are denied and strict proof is demanded thereof from the Defendant at trial. WHEREFORE, the Plaintiff respectfully requests that this Honorable Court strike that the Defendant's New Matter and enter judgment in her favor as requested in the Complaint. 2 Respectfully submitted, SCHMIDT, RONCA & KRAMER, P.C. Date: ` By: Scott B. Cooper I.D. No. 70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 s cooper(d,,srklaw. com Attorney for Plaintiff ATTORNEY VERIFICATION I, Scott B. Cooper, Esquire, verify that I am attorney of record for the Plaintiff, Christina Sheaffer. I verify that the facts contained in the Plaintiff's Reply to Defendant's New Matter are true and correct to the best of my knowledge, information and belief. I understand that intentional false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsifications to authorities. Date ./)J Scott B. Cooper CERTIFICATE OF SERVICE AND NOW, this 31-,) day of &? W,21. 2005, I hereby certify that I have, this day, caused a copy of the foregoing Plaintiff's Reply to Defendant's New Matter to be served by deposit in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: First Class Mail: Richard H. Druby, Esquire Nestico & Druby, LLP 840 East Chocolate Avenue Hershey, Pa 17033-1213 Schmidt, Ronca, & Kramer, P.C. By: - A C,-J Scott B. Cooper, Esquire I.D.# 70242 209 State Street Harrisburg, PA 17101 (717) 232-15300 Attorney for Plaintiff ERIE ERIE INSURANCE EXCHAN( INSURANCE PIONEER GARAGE/AUTO POLI( GROUP CONTINUATION NOTICE 100 Erie Ins. Pl. Erie, PA 16530 0 AGENT` ITEM 2. POLICY PERIOD POLICY NUMBER AA7507 SHINER INSURANCE AGY PC 04/21/03 TO 04/21/04 004 2180071 H7 ITEM 1. NAMED INSURED AND ADDRESS ITEM 3. OTHER INTEREST SHEAFFER AUTOMOTIVE GARY S SHEAFFER D/B/A 39 S 8TH ST LEMOYNE PA 17043-1508 ITEM 4. COVERAGES UNDER THIS POLICY INCLUDE: GARAGE LIABILITY PACKAGE, WHICH INCLUDES: GARAGE PREMISES- OPERATIONS/PRODUCTS-COMPLETED OPERATIONS/TENANTS LEGAL LIABILITY/TRUTH IN LENDING & LEASING/ODOMETER/AUTO DAMAGE DISCLOSURE/COMPETITIVE AUTO PARTS LAWS & FEDERAL USED CAR "BUYER'S GUIDE" REGULATION AUTOS WE INSURE: HIRED & NON-OWNED AUTOS - CUSTOMERS AUTOS - LOCATION(S) SHOWN BELOW - DESCRIBED AUTOS - VEHICLES SHOWN BELOW ITEM 5. INSURANCE IS PROVIDED WHERE A PREMIUM OR "INCL" (INCLUDED) IS SHOWN FOR THE COVERAGE. STATE RATING TERR TOTAL NUMBER OF EMPLOYEES/OWNERS PA 4D FULL-TIME 1 PART-TIME PREMIUM SERVICE OPERATIONS LIABILITY COVERAGES- PERSONAL INJURY $100M/PERSON $300M/ACC & 310 PROPERTY DAMAGE $100M/ACC PREMISES MEDICAL PAYMENTS $2M/PERSON INCL STATE: PA LOCATION: 01 RATING TERRITORY: 4D CUSTOMERS AUTOS - LEGAL, LIABILITY COMPREHENSIVE $ 100 DED/AUTO $ 500 DED/LOSS 66 LIMIT $20M COLLISION $ 100 DED/AUTO LIMIT $20M 51 ITEM 4. AUTOS WE INSURE/ALSO INSURED - GARAGE PREMISES-OPERATIONS/PRODUCTS- COMPLETED OPERATIONS/TENANTS LEGAL LIABILITY/TRUTH IN LENDING & ODOMETER LAW LIABILITY ST TER SYM RATING CLASS 10 02 R/S TAG RT20137 PA 4D CPB 11 02 R/S TAG RT34711 PA 4D CPB 12 02 R/S TAG RT34712 PA 4D CPB 13 02 R/S TAG RT34714 PA 4D CPB c{ 2v1 b 001295 .,,!g¢PR4VER$F_E!rlFl•• RETURNED CHECK FEES WILL BE ADDED TO YOUR ACCOUNT CEY 02/12/0 ERIE INSURANCE EXCHANGE ERIE PIONEER GARAGE/AUTO POLICY INSURANCE GROUP CONTINUATION NOTICE 100 Erie Im pl. r+ Erie. PA 16530 E III AGENT ITEM 2. POLICY PERIOD POLICY NUMBER AA7507 'SHINER INSURANCE AGY PC 04/21/03 TO 04/21/04 Q04 2180071 H7 SHEAFFER AUTOMOTIVE GARY S SHEAFFER D/B/A 39 S 8TH ST LEMOYNE PA 17043-1508 THE LAWS OF THE COMMONWEAL'PH OF PENNSYLVANIA, AS ENACTED BY THE GENERAL ASSEMBLY, ONLY REQUIRE THAT YOU PURCHASE LIABILITY AND FIRST-PARTY MEDICAL BENEFIT COVERAGES. ANY ADDITIONAL COVERAGES OR COVERAGES IN EXCESS OF THE LIMITS REQUIRED BY LAW ARE PROVIDED ONLY AT YOUR REQUEST AS ENHANCEMENTS TO THE BASIC COVERAGES. BODILY INJURY $15M/PERSON $30M/ACC PROPERTY DAMAGE $5M/ACC FIRST PARTY BENEFITS - MEDICAL EXPENSE $5M 10 # 11 # 12 ANNUAL PREMIUMS 88 88 88 72 72 72 13 13 13 13 88 72 13 001296 CEY 02/12/03 ... fSE' RtVERSE SIDEI • • RETURNED CHECK FEES WILL BE ADDED TO YOUR ACCOUNT SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-03183 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SHEAFFER CHRISTINA VS SAMSEL TAMMY R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: SAMSEL TAMMY but was unable to locate Her deputized the sheriff of YORK serve the within COMPLAINT & NOTICE County, Pennsylvania, to On August Sth , 2005 , this office was in receipt of the attached return from YORK Sheriff's Costs: So answers -? Docketing 18. 00 Out of County 9. 00 Surcharge 10. 00 R. Thomas Kli --"-- York County 41. 06 Sheriff of Cumberland County .00 78.06 08/08/2005 SCHMIDT RONCA & KRAMER in his bailiwick. He therefore Sworn and subscribed to before me this -/ day of 0?4? o.3 A.D. COUNTY OF YORK OFFICE OF THE SHERIFF S(R X771 96011 45 N. GEORGE ST., YORK, PA 17401 SHERIFF SERVICE NSTFMTIOM PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE OWY LM 1 TFW 12 DO NOT MACK ANY CAPES 1 PLAINTIFFISI 2. COURT N BER, Christina Sheaffer 05-31 civil 4. TYPE OF WRIT OR COMPLAINT 3. DEFENDANTIS/ Tammy Samsel Notice & Complaint CICA SERVE 5 NAME OF INDIVIDUAL, C PANY, CORPORATION. ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED. ATTACHED, OR SOLD TarLmy Samsel 6. ADDRESS (STREET OR RFO WITH BOX NUMBER. APT NO. CITY, BORO. TWP.. STATE AND ZIP CODE) AT 17 North York Road Dillsburg, PA 17019 7. INDICATE SERVICE'. U PERSONAL U PERSON IN CHARGE DEPUTIZE J ERT. IL U 1 ST CLASS MAIL U POSTED 'J OTHER NOW June 23 20 I, SHERIFF OF IMM COUNTY, PA, do hereby deputize the sheriff of York COUNTY to execute th r?iake return tFj ccording to law. This deputization being made at the request and risk of the plaintiff., -g,.'..r SHERIFF OF IOM CCOUNTY 9. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE ^^ //rr Clmtberland Please mail return of service to CLanberland County Sheriff. Thank you. AA_ "i Pll, by 4 , NOT . Y NLY APPUCAaLE ONwfNT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 9. o PPE?NA? and ADDjt? S of ATTORNEY I ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE F_ILLE?D,?- FI{?G vLk l W. SCOTT COOPER ESQ 717-232-6300 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW- (This area must be completed d notice is tope mailed). I A n ?1,,,. ,0 v \ O 00 23. Advance Costs 24 Service Costs 25 N/F 26. Miles a 27 Postage 26 Sub Tolal 29. Pound 30 Notary 31 Surchg. 32. Td Costs 33 Ca s Due a d k No 100.00 140 6- 1 woo I 140W / y l DG 8 34. Foreign County Colts 35. Advance Costs 36 Service Costs 37. Notary Cart . 36. Mileage/Postage/Not Found 39. Total Costs 40 Costs Due or Refund 41. AfFIRME@and-subfiaribed-tabefore. 1 bis Z rl T l-{ N. Signature ar 42 do k? of Dep. Sheriff tr?`f 20r? try NOTARY I6. Signatured i _ County She _ t'LET'tI rl HOSE,SHERiFr' 46. Signature of Foreign County Sherrill 47 DATE IHHHH Do 7/'25/05 49 UAlt 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 16 koala or complaint as indicated above. ¢{?_t RA ?du E eS '/24/05 16. HOW SERVED PERSONAL-W RESIDENCE ( ) POSTED( I POE( ) SHERIFF'S OFFICE (r, OTHER ( ) SEE REMARKS BELOW 17. U 1 hereby, certify and returg a NOT FOUND Dec se I am uSnable to locate the individual, company, etc. named above. (See remarks below.) _ 16. NAME TITLE OF IND (DUAL SERVED T ADDRES MERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Dale of?Service 2e Time of Service illili MASHALL DENNEHEY WARNER COLEMAN & GOGGIN BY: GEOFFREY S. McINROY I.D. No. 87876 4200 Crums Mill Road Harrisburg, PA 17112 (717) 651-3510 Attorneys for Defendant Tammy Samsel CHRISTINA SHEAFFER, Plaintiff V. TAMMY SAMSEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05-3183 JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Marshall, Dennehey, Warner, Coleman & Goggin, and Geoffrey S. McInroy, Esquire, on behalf of Defendant, Tammy Samsel, in connection with the above-captioned matter. DATE: It ( O6 Respectfully submitted, MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: eoffrey S. McInro , Es ire CHRISTINA SHEAFFER, Plaintiff V. TAMMY SAMSEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 05-3183 : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Angela Zilla, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this Aay of November, 2006, I served a copy of the foregoing via First Class United States mail, postage prepaid as follows: Scott B. Cooper, Esquire SCHMIDT RONCA & KRAMER, PC 209 State Street Harrisburg, PA 17101 Angela Zifla T -TI MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN BY: Lauren M. Burnette I.D. No. 92412 4200 Crums Mill Road Harrisburg, PA 17112 (717) 651-3703 CHRISTINA SHEAFFER, Plaintiff V. TAMMY SAMSEL, Defendant Attorneys for Defendant Tammy Samsel IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 05-3183 JURY TRIAL DEMANDED PRAECIPE TO SETTLE DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-referenced matter as SETTLED, DISCONTINUED and ENDED with Prejudice. SCHMIDT KRAMER, P.C. _ zhw- By' 9 - );o Scott Cooper, Esquire 209 State St. Harrisburg, PA 17101 Y u " ll ?y '` 53