HomeMy WebLinkAbout05-3850IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
BARBARA BEEMER SANCHEZ and
DANIEL SANCHEZ, Individually
and as Wife and Husband,
524 Clermont Drive
Harrisburg, PA 17112
Plaintiff(s) &
Address(es)
NO. 3PZ
CIVIL ACTION - LAW I
SEVEN HILLS, INC. Individually and t/d/b/a
SBARRO THE ITALIAN EATERY
3449 Capital Mall Drive, Capital City Mall
Camp Hill, PA 17011
Defendant(s)
Address(es)
JURY TRIAL DEMANDED
PRAECIPE FOR WRIT OF SUMMONS
TO THE PROTHONOTARY:
Kindly issue a Writ of Summons against Defendants Seven Hills, Inc., t/d/b/a Sbarro The
Italian Eatery. The Writ of Summons should be delivered to the Sheriff for service upon
Defendants at 3449 Capital Mall Drive, Capital City Mall, Camp Hill, PA 17011 to be forwarded
to the Sheriff along with the Writs.
METZGER, Wj. KhRSHy1M, KNAUSS & ERB, P.C.
By
Date: JulyaS2005
Francis J. Laflerty; IV, Esqui
I.D. No. 84009
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Plaintiffs
325404-1
? ,64 r.,
II ll ` /Q
` u
r _ 1
T
i ?r
o
METZGER, WICKERSHAM, P.C.
By: Francis J. Lafferty, IV, Esquire
Attorney I.D. No. 84009
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiffs
Barbara Beemer Sanchez and Daniel Sanchez
BARBARA BEEMER SANCHEZ and
DANIEL SANCHEZ,, Individually
and as Wife and Husband,
Plaintiffs
vs.
SEVEN HILLS, INC., Individually and
t/d/b/a SBARRO THE ITALIAN EATERY,:
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. oS- 3,pS'd dL ` 9
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
WRIT OF SUMMONS
TO: Seven Hills, Inc., Individually and t/d/b/a
Sbarro The Italian Eatery
3449 Capital Mall Drive
Capital City Mall
Camp Hill, PA 17011
You are hereby notified that Plaintiffs Barbara Beemer Sanchez and Daniel Sanchez have
commenced an action against you.
Dated: / c G6,s-
Prothonotary ?j
325404-1
SHERIFF'S RETURN - REGULAR
'CASE NO: 2005-03850 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SANCHEZ BARABARA BEEMER ET AL
VS
SEVEN HILLS INC ET AL
GERALD WORTHINGTON , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF SUMMONS was served upon
SEVEN HILLS INC
the
DEFENDANT , at 0012:50 HOURS, on the 3rd day of August , 2005
at 3449 CAPITAL MALL DRIVE CAPITAL CITY MALL
CAMP HILL, PA 17011 by handing to
RAGHU TADAVARTHY
a true and attested copy of WRIT OF SUMMONS together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
12.00
.00
10.00 R. Thomas Kline
.00
40.00 08/04/2005
METZGER WICKERSHAM
Sworn and Subscribed to before
me this _5Fday of
a? CIW 0j / A.D.
Prothonotary
By
Deputy She 'ff
SHERIFF'S RETURN - REGULAR
CASE NO: 2005-03850 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SANCHEZ BARABARA BEEMER ET AL
VS
SEVEN HILLS INC ET AL
GERALD WORTHINGTON , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF SUMMONS was served upon
SEVEN HILLS INC T
THE ITALIAN EATERY
the
DEFENDANT , at 0012:50 HOURS, on the 3rd day of August , 2005
at 3449 CAPITAL MALL DRIVE CAPITAL CITY MALL
P HILL. PA 17011
RAGHU TADAVARTHY (OWNER
by handing to
a true and attested copy of WRIT OF SUMMONS
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
.00
.00
10.00 R. Thomas Kline
.00
16.00 08/04/2005
METZGER WICKERSHAM
Sworn and Subscribed to before By:eti
me this day of Deputy Sh ff
i
A.D.
Prot !notary
r
0
Thomas E. Brenner, Esquire
Goldberg Katzman, P.C.
PO Box 1268
Harrisburg, PA 17108-1268
717-234-4161
Attorneys for Defendants
BARBARA BEEMER SANCHEZ
and DANIEL SANCHEZ,
individually and as Wife and
Husband,
Plaintiffs
V.
SEVEN HILLS, INC., individually
and t/d/b/a SBARRO THE
ITALIAN EATERY,
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
NO. 05-3850
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
ENTRY OF APPEARANCE
Please enter the appearance of Thomas E. Brenner, Esquire of Goldberg
Katzman, P.C. on behalf of the Defendants in the above matter.
GOLDBERG KATZMAN, P.C.
Thomas E. Brenner, Esquire
Attorney ID #32085
PO BOX 1268
Harrisburg, PA 17108-1268
717-234-4161
Attorney for Defendants
Date: December 13, 2005
r
1
CERTIFICATE OF SERVICE
I, hereby certify that on this date, I served the foregoing document, via U. S. Mail,
postage prepaid, on the persons set forth below, namely:
Francis J. Lafferty, Esquire
Metzger Wickersham
PO Box 5300
Harrisburg, PA 17110-0300
GOLDBERG I<,NTZMAN, P.C.
t
By: h-llY
Thomas E. Brenner, Esquire
Date: December 13, 2005
Thomas E. Brenner, Esquire
Goldberg Katzman, P.C.
PO Box 1268
Harrisburg, PA 17108-1268
717-234-4161
Attorneys for Defendants
BARBARA BEEMER SANCHEZ
and DANIEL SANCHEZ,
individually and as Wife and
Husband,
Plaintiffs
V.
SEVEN HILLS, INC., individually
and t/d/b/a SBARRO THE
ITALIAN EATERY,
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
NO. 05-3850
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PRAECIPE FOR RULE TO FILE COMPLAINT
TO THE PROTHONOTARY:
Please issue a Rule upon the Plaintiffs to file a Complaint within twenty (20) days
after service hereof, or suffer judgment of non pros.
GOLDBERG KATZMAN, P.C.
t
By:
Thomas E. Brenner, Esquire
Attorney ID #32085
PO Box 1268
Harrisburg, PA 17108-1268
717-234-4161
Attorney for Defendants
Date: February 15, 2006
CERTIFICATE OF SERVICE
I, hereby certify that on this date, I served the foregoing document, via U. S. Mail,
postage prepaid, on the persons set forth below, namely:
Francis J. Lafferty, Esquire
Metzger Wickersham
PO Box 5300
Harrisburg, PA 17110-0300
GOLDBERG KATZMAN, P.C.
By:
Thomas E. Brenner, Esquire
Date: February 15, 2006
-a
_?,?
?? ,-i
_,-
..l ?
.,. ?
C1
?'• ?
?;?
BARBARA BEEMER SANCHEZ
and DANIEL SANCHEZ,
individually and as Wife and
Husband,
Plaintiffs
V.
SEVEN HILLS, INC., individually
and t/d/b/a SBARRO THE
ITALIAN EATERY,
Defendants
TO: Barbara Beemer Sanchez and
Daniel Sanchez
c/o Francis J. Lafferty, Esquire
Metzger Wickersham
PO Box 5300
Harrisburg, PA 17110-0300
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
NO. 05-3850
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
RULE
A Rule is hereby issued upon the Plaintiffs, to file a Complaint within twenty (20)
days of service hereof, or suffer judgment of non pros.
? t
rothonotary
Date:
?? ,LUU(o
_, <-?
,,
?h.
METZGER, WICKERSHAM, P.C.
By: Francis J. Lafferty, IV, Esquire
Attorney I.D. No. 84009
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiffs
Barbara Beemer Sanchez and Daniel Sanchez
BARBARA BEEMER SANCHEZ and
DANIEL SANCHEZ, Individually
and as Wife and Husband,
Plaintiffs
vs.
SEVEN HILLS, INC., Individually and
t/d/b/a SBARRO THE ITALIAN EATERY,:
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-3850
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PRAECIPE TO SETTLE, DISCONTINUE AND END
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Kindly mark the entire above-captioned case settled, discontinued and ended.
METZGER, WICKE HAM, KNAUSS & ERB, P.C.
By
F cis J. afferty, IV, Esquire
I.D. No. 84009
Date: March_(_, 2006
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorney for Plaintiffs
325404-1
CERTIFICATE OF SERVICE
I, Francis J. Lafferty, IV, Esquire, of the law firm of Metzger, Wickersham, Knauss &
Erb, P.C., hereby certify that I served a true and correct copy of a Praecipe to Settle, Discontinue
sh
and End with reference to the foregoing action by first class mail, postage prepaid, this day
of March, 2006, on the following:
Ms. Brenda Schambach
Commercial Liability Claims Specialist
Erie Insurance Group
P. O. Box 3543
Shiremanstown, PA 17011
Thomas E. Brenner, Esquire
Goldberg Katzman, P.C.
P.O. Box 1268
Harrisburg, PA 17108-126E
G
Franis J. La rty, , Esquire
325404-1
?
,?
_?
,'-?
` ,,.
. ",
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
erica, Inann
Plaintiff
Vs File No.
IN DIVORCE
S?' E'i-sue Mo--n n .
Defendant m
o
m
zo
NOTICE TO RESUME PRIOR SURNAME
!
Notice is hereby given that the Plaintiff/ defendant in the above matter, `
aQ
[select one by marking "x"]
?.,
prior to the entry of a Final Decree in Divorce,
or after the entry of a Final Decree in Divorce dated ?Wemu--) - ( 20cO-'
hereby elects to resume the prior surname of E CI COL S, LA 'r) k , and gives this
written notice avowing his / her intention pursuant to rb 'sions of 54 P.S. 704.
Date: CZ?
Signatdre
Signature of name being resumed
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF Cu?mbef ?Ak?(?
On the day of , 204-0, before me, the Prothonotary or the
notary public, personally appeared the above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he / she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
seal,
QL
All Nom Pu&?ie