The URL can be used to link to this page

Home My WebLink About05-5930RUPP AND MEIKLE, P.C. Plaintiff/Petitioner V. LAVONE G. ROOSA, individually, TDBA THYME OF YOUR LIFE WILLIAM E. ROOSA, individually, EMRICH'S INC. A Pennsylvania Corporation Defendant/Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :No. C?37J CIVIL ACTION - LAW 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 RUPP AND MEIKLE, P.C. : IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA V. . No. LAVONE G. ROOSA, individually, : CIVIL ACTION - LAW TDBA THYME OF YOUR LIFE WILLIAM E. ROOSA, individually, EMRICH'S INC. A Pennsylvania Corporation Defendant/Respondent NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dies de plazo al partir de la fecha de la demanda y la notificacion. Listed debe presentar una apariencia escrita o en persona o par abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y par cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros detechos importantes Para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO O St NO TIENE EL DINERO SLiFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 RUPP AND MEIKLE, P.C. AN THE COURT OF COMMON PLEAS A Pennsylvania Professional Corporation, Plaintiff V. LAVONNE G. ROOSA, individually, and TDBA THYME OF YOUR LIFE, :OF CUMBERLAND COUNTY, :PENNSYLVANIA :NO: 0 s - 5 3? , .CIVIL ACTION - LAW WILLIAM E. ROOSA, individually, and EMRICH'S INC. A Pennsylvania corporation, Defendants COMPLAINT 1. The Plaintiff is RUPP & MEIKLE, P.C., a Pennsylvania professional corporation, providing legal services and having a principal place of business at 355 North 21St Street Suite 201 Camp Hill, Cumberland County Pennsylvania 17011. 2. The Defendants are William E. Roosa, an adult individual, Lavone G. Roosa an adult individual trading and doing business as Thyme of Your Life, and 1 their restaurant, Emrich's Inc., a Pennsylvania Corporation having a principal place of business at 3300 Hartzdale Drive, Camp Hill, Cumberland County Pennsylvania 17011. 3. At the end on the year 2000 and in the year 2001, the Defendants verbally contracted with the Plaintiffs law firm for legal services to represent the Defendants in connection with a lawsuit brought by a prior business partner against Defendants. 4. The Plaintiff had previously provided Defendant legal services in recent and previous other matters and then Plaintiff provided new additional legal services per the request of the Defendants including preparing and filing an answer to the complaint, reviewing the legal documents and pleadings, providing legal advice, and representing Defendants at depositions. 5. The Plaintiff billed its statement for legal services to the Defendants on or about February 2002. A copy of said Plaintiffs statement is attached hereto and incorporated herein by reference. 6. To this date, despite Plaintiffs demands to Defendants, the Defendants have failed or refused to pay to the Plaintiff the sum billed in Plaintiffs statement to Defendants. 7. As a result of the aforesaid conduct of the Defendants, the Plaintiff has been damaged to Plaintiffs detriment in the sum of $1,940.00 plus interest, plus costs plus legal fees. 8. In a telephone call between Plaintiffs office and Defendant William Roosa in 2003, Defendant William Roosa promised that the Plaintiff s statement for legal services was going to be paid by Defendants out of an estate, however, this promised payment from Defendant to Plaintiff never occurred. 9. The Defendants have never objected to this statement from Plaintiff and instead have fully indicated and promised to pay this statement for legal servics to Plaintiff. COUNTI BREACH OF CONTRACT 10. Paragraphs 1 - 9 are incorporated herein by reference as if set forth in full. 11. To this date, despite Plaintiffs demands to Defandants, the Defendants have failed or refused to pay to the Plaintiff the sum billed in Plaintiff's statement to the Defendants. 12. As a result of the aforesaid conduct of Defendants, the Defendants have breached their contract with Plaintiff for Plaintiffs legal service. 13. As a result of the breach of contract by the Defendants, the Plaintiff has been damaged to Plaintiffs detriment in the sum of $1,940.00 plus interest, plus cost, plus legal fees. WHEREFORE, PLAINTIFF DEMANDS JUDGMENT IN THE SUM OF $1,940.00 PLUS INTEREST, PLUS COSTS, PLUS LEGAL FEES AGAINST DEFENDANTS COLLECTIVELY AND EACH OF THE DEFENDANTS INDIVIDUALLY. COUNT II ESTOPPEL 14. Paragraphs 1 - 13 of Plaintiffs complaint are incorporated herein by reference as if set forth in full. 4 15. Defendants made numerous promises to Plaintiff to pay Plaintiffs statement for Plaintiffs legal services to Defendant. 16. Despite Plaintiffs demands, Defendants have failed or refused to pay Plaintiff's statement for legal services. 17. Plaintiff, in reliance on Defendant's statements to pay, did not take any collection activity against Defendants by reason Defendants' promises to pay Plaintiff's statement for legal services to Defendants. 18. Defendants are estopped from denying Defendants' liability for payment of Plaintiffs statement for legal services. 19. Plaintiff relied on Defendants promises to pay Plaintiffs statement to Plaintiff's detriment. 20. Plaintiff relied on Defendants' promises to Plaintiffs detriment. 21. By reason of the aforesaid reasons, Defendants are estopped from denying any liability for payment of Plaintiffs statement for legal services. 5 WHEREFORE, PLAINTIFF DEMANDS JUDGMENT IN THE SUM OF $1,940.00 PLUS INTEREST, PLUS COSTS, PLUS LEGAL FEES AGAINST DEFENDANTS COLLECTIVELY AND EACH OF THE DEFENDANTS INDIVIDUALLY. COUNT III IMPLIED CONTRACT 22. Paragraphs 1 - 21 are incorporated herein by reference. 23. In the alternative, Plaintiff and Defendant entered into an implied contract for legal services from Plaintiff to Defendants at Defendants' request. WHEREFORE, PLAINTIFF DEMANDS JUDGEMENT IN THE SUM OF $1,940.00 PLUS INTEREST, PLUS COSTS, PLUS LEGAL FEES AGAINST DEFENDANTS COLLECTIVELY AND EACH OF THE DEFENDANTS INDIVIDUALLY. 6 Respectfully submitted, t'/m-'r" a droi? Richard C. Rupp Esq. Supreme Court ID. No. 34832 355 North 21', Suite 201 Camp Hill, Pennsylvania 17011 ( 717) 761 - 3459 Attorneys for Plaintiff VERIFICATION I, Richard C. Rupp, Esq. Am making this verification as the President of the corporate Plaintiff and am authorized to verify the facts in this pleading. I verify that the statements in the foregoing document are true and correct to the best of my knowledge, information and belief. Said statements are based on my own knowledge, belief or information or information provided me. 1 understand that false statements herein are made subject to penalties of 18 Pa. C.S.A. * 4904 relating to unsworn falsification to authorities. Date: /A 0 r ' 1 Richard C. Rupp, Esq. HERBERT G. RUPP, JR. RICHARD C. RUPP ANN MEIRLE ERIXSSON (1954-32) LAW OFFICES RUPP AND MEIKLE A PROFESSIONAL CORPORATION 356 NORTH 21ST STREET, SUITE 205 CAMP HILL, PA 17011 (717) 7614469 E-MAIL: RUPPLAWICAOL.COM February 26, 2002 Mr. and Mrs. William E. Roosa Emrich's Restaurant 3300 Hartzdale Dr. Camp Hill, PA 17011 FOR PROFESSIONAL SERVICES RENDERED: MAILING ADDRESS P.O. BOX 396 CAMP HILL, PA 17001-0396 TELRFAX: (717) 730-0214 November 27, 2000 Telephone conference Bill Roosa, re. Behney lawsuit ............................... 0.2 hours November 28, 2000 Conference Roo sa, re. lawsuit ............. 0.5 hours Telephone conference Atty. Fenicle ......... 0.2 hours December 1, 2000 Telephone conference Atty. Fenicle, re. depositions ......................... 0.3 hours Conference HGR, re. Roosa situation ........ 0.8 hours December 5, 2000 Conference Roosas ..................... 1.8 hours December 6, 2000 Conference HGR, re. lawsuit .............. 0.3 hours Telephone conference I Cherry office ....... 0.2 hours Receipt and review letter from Atty. Fenicle ... 0.2 hours December 19, 2000 Preparation of Answer and New Matter ...... 3.9 hours Answer to Motion and instructions to Legal Assistant ......................... 2.0 hours December 21, 2000 Continued preparation of New Matter and Answer and Answer to Motion ............. 2.5 hours Conference Bill Roosa ................... 1.0 hours Package Answers for filing ................ 0.8 hours Mr. and Mrs. William E. Roosa February 26, 2002 Page 2 December 21, 2000 Travel and file Answer and New Matter and Answer to Motion ................... 1.0 hours Letter to Atty. Fenicle .................... 0.3 hours Letter to J. Cherry ...................... 0.3 hours Instructions to Legal Assistant .............. 0.4 hours January 4, 2001 Receipt and review letter, re. depositions ..... 0.2 hours January 18, 2001 Review file ............................. 0.5 hours Telephone conference Bill Roosa ........... 0.2 hours Letter and fax letter to Atty. Fenicle ......... 0.4 hours January 19, 2001 Conference Roosas ..................... 0.9 hours Prepare for deposition ................... 1.0 hours January 22, 2001 Roosa depositions ...................... 3.0 hours January 23, 2001 Receipt and review fax ................... 0.2 hours Telephone conference Bill Roosa ........... 0.2 hours January 24, 2001 Telephone conference Roosas ............. 0.2 hours February 14, 2001 Review proposal ........................ 0.4 hours Telephone conference Bill Roosa ........... 0.3 hours August 5, 2001 Conference HGR 0.2 hours August 6, 2001 Instructions to Legal Assistant .............. 0.2 hours August 16, 2001 Conference Roosas ..................... 1.0 hours Mr. and Mrs. William E. Roosa February 26, 2002 Page 3 August 17, 2001 Instructions to Legal Assistant .............. 0.2 hours Draft possible counteroffer ................ 1.5 hours August 29, 2001 Memorandum to folder .................. 0.2 hours September 4, 2001 Letter to Roosas ........................ 0.2 hours TOTAL HOURS: ........................................... 27.7 hours TOTAL FEES: 27.7 @ $135/hour ...................... $3,739.50 COSTS: Photocopies: 6 @ 25¢ per copy ............... $1.50 TOTAL FEES AND COSTS : .................................... $3,741.00 CREDIT: .................................................. $1,800-00 BALANCE DUE: ............................................$1,941.00 * Please note: No charges were made for Herbert Rupp, Esquire's time. ?AK 717 R? ^I \15y?\\V C hJ ? 1- Ul t J N :7 I SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-05930 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RUPP AND MEIKLE PC VS ROOSA LAVONE G TDBA THYME ETAL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he mad= a diligent search and inquiry for the within named DEFENDANT ROOSA LAVONNE G TDBA THYME OF YOUR LIFE but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , ROOSA LAVONNE G TDBA THYME OF LIFE _, 3300 HARTZDALE DRIVE CAMP HILL, PA 170 DEFENDANT IS BELIEVED TO BE IN HARRISBURG. Sheriff's Costs: So answers- f9 Docketing 18.00 Service 14.401 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County Postage .37 47.77 RUPP AND MEIKLE 11/30/2005 Sworn and subscribed to before me this 4 day of (55? A.D. Pro onot SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-05930 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RUPP AND MEIKLE PC VS ROOSA LAVONE G TDBA THYME ETAL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT ROOSA WILLIAM E unable to locate Him in his bailiwick COMPLAINT & NOTICE but was He therefore returns the the within named DEFENDANT , ROOSA WILLIAM E 0 HARTZDALE DRIVE CAMP HILL, PA 17011 NOT FOUND , as to DEFENDANT IS BELIEVED TO BE LIVING IN HARRISBURG. Sheriff's Costs: So answers: Docketing 6.00 Service .00 %j Not Found 5.00 R. Thoma Kline Surcharge 10.00 Sheriff of Cumberland County .00 21.00 RUPP AND MEIKLE 11/30/2005 Sworn and subscribed to before me this G day of ?uro? D. / Pro ?fionot SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-05930 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RUPP AND MEIKLE PC VS ROOSA LAVONE G TDBA THYME ETAL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he mad= a diligent search and inquiry for the within named DEFENDANT EMRICH'S INC unable to locate Them in his bailiwick COMPLAINT & NOTICE but was He therefore returns the NOT FOUND , as to the within named DEFENDANT , EMRICH'S INC 3300 HARTZDALE DRIVE CAMP HILL, PA 17011 DEFENDANT IS BELIEVED TO BE IN HARRISBURG. Sheriff's Costs: So answers:_ -.? Docketing 6.00 Service 00 <-/s Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 21.00 RUPP AND MEIKLE 11/30/2005 Sworn and subscribed to before me this 4 day of h4u4l ? ac-b? A.D. Pr honot RUPP & MEIKLE, P.C. a Pennsylvania Professional Corporation, Plaintiff V. LAVONNE G. ROOSA, individually, and TDBA THYME OF YOUR LIFE, WILLIAM E. ROOSA, individually, EMRICH'S INC. a Pennsylvania Corporation, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO: 05 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: PLEASE REINSTATE THE COMPLAINT IN THE ABOVE-CAPTIONED ACTION ON BEHALF OF PLAINTIFFS AND AGAINST EACH OF THE ABOVE- NAMED DEFENDANTS. Date: December 15, 2005 AND MEI SUP. CT. ID. NO. 34832 SUITE 201 355 NORTH 21ST STREET CAMP HILL, PA 17011 ATTORNEYS FOR PLAINTIFFS n N Q ) i n . - j 7 - T. C'. C'ry r?- ..? P ' ? J. ?qr L^} r? 4?? l Il :,. ?` , y- :?_ to !tea r x! .-G J RUPP & MEIKLE, P.C. a Pennsylvania Professional Corporation, Plaintiff V. LAVONNE G. ROOSA, individually, and TDBA THYME OF YOUR LIFE, WILLIAM E. ROOSA, individually, EMRICH'S INC. a Pennsylvania Corporation, Defendants : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA CIVIL ACTION- LAW NO: PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: PLEASE REINSTATE THE COMPLAINT IN THE ABOVE-CAPTIONED ACTION ON BEHALF OF PLAINTIFFS AND AGAINST EACH OF THE ABOVE- NAMED DEFENDANTS. Date: January 12, 2006 AND SUP. CT. ID. NO.. 34832 7 , SUITE 201 355 NORTH 21ST STREET CAMP HILL, PA 17011 ATTORNEYS FOR PLAINTIFFS fV CO RUPP & MEIKLE, P.C. a Pennsylvania Professional Corporation, Plaintiff V. LAVONNE G. ROOSA, individually, and TDBA THYME OF YOUR LIFE, WILLIAM E. ROOSA, individually, EMRICH'S INC. a Pennsylvania Corporation, Defendants : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA CIVIL ACTION- LAW NO: cD5 - 593 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: PLEASE REINSTATE THE COMPLAINT IN THE ABOVE-CAPTIONED ACTION ON BEHALF OF PLAINTIFFS AND AGAINST EACH OF THE ABOVE- NAMED DEFENDANTS. Date: February 9, 2006 SUP. CT. ID. NO. 34832 SUITE 201 355 NORTH 21ST STREET CAMP HILL, PA 17011 ATTORNEYS FOR PLAINTIFFS r-..? ?? G> : J r_? . -:-! ---5 _ a-? ? ?l,__. ? ?.CJ ;-,, ?- i d;I_ <':. C ? RUPP & MEIKLE, P.C. a Pennsylvania Professional Corporation, Plaintiff V. LAVONNE G. ROOSA, individually, and TDBA THYME OF YOUR LIFE, WILLIAM E. ROOSA, individually, EMRICH'S INC. a Pennsylvania Corporation, Defendants : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA CIVIL ACTION- LAW NO: t?s S43 D PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: PLEASE REINSTATE THE COMPLAINT IN THE ABOVE-CAPTIONED ACTION ON BEHALF OF PLAINTIFFS AND AGAINST EACH OF THE ABOVE- NAMED DEFENDANTS. Date: March 7, 2006 SUP. CT. ID. NO. 34831 SUITE 201 355 NORTH 21 ST STREET CAMP HILL, PA 17011 ATTORNEYS FOR PLAINTIFFS 4r- RUPP & MEIKLE, P.C. a Pennsylvania Professional Corporation, Plaintiff V. LAVONNE G. ROOSA, individually, and TDBA THYME OF YOUR LIFE, WILLIAM E. ROOSA, individually, EMRICH'S INC. a Pennsylvania Corporation, Defendants : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA CIVIL ACTION- LAW NO: PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: PLEASE REINSTATE THE COMPLAINT IN THE ABOVE-CAPTIONED ACTION ON BEHALF OF PLAINTIFFS AND AGAINST EACH OF THE ABOVE- NAMED DEFENDANTS. Date: April 10, 2006 MEI I SUP. CT. ID. NO. 34832 SUITE 201 355 NORTH 21ST STREET CAMP HILL, PA 17011 ATTORNEYS FOR PLAINTIFFS C: C' 'ri Gl -. (. ?4 ? } _e " r ?1 SHtRIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-05930 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RUPP AND MEIKLE PC VS ROOSA LAVONE G TDBA THYME ETAL 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: ROOSA LAVONNE G TDBA THYME OF YOUR LIFE but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN serve the within COMPLAINT & NOTICE County, Pennsylvania, to On May 9th , 2006 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin Co unty 41.25 Postage 3.95 82.20 05/09/2006 RUPP & MEIKLE Sworn and subscribed to before me So answe _/? ?--• '' -' R.' Thomas Kline Sheriff of Cumberland County this ?l day of 4ot ono ary In The Court of Common Pleas of Cumberland County, Pennsylvania Rupp and Meikle PC vs. Lavone G. Roosa et al SERVE: Lavone G. Roosa No. 05-5930 civil Now, April 28, 2006 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to _ a and made known to So answers, Sheriff of Sworn and subscribed before me this _ day of 20 copy of the original COSTS SERVICE _ MILEAGE _ AFFIDAVIT the contents thereof. County, PA 20, at o'clock M. served the (pit-.re of t4P "Si4Pxiff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph:(717)780-6590 fm:(717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania , RUPP AND MEIKLE PC vs County of Dauphin ROOSA LEVONE Sheriff's Return Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy No. 0746-T - - -2006 OTHER COUNTY NO. 05-5930 CIVIL 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 ROOSA LEVONE the DEFENDANT named in the within REINSTATED NOTICE & COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, May 4, 2006 PER NEIGHBOR DEFTS MOVED OUT IN SEPT. 2005 Sworn and subscribed to before me this 4TH day of MAY, 2006 NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept 1, 2006 So Answers, ?)o ,;? Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs:$41.25 PD 05/02/2006 RCPT NO 217292 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-05930 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RUPP AND MEIKLE PC VS ROOSA LAVONE G TDBA THYME ETAL 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: ROOSA WILLIAM E but was unable to locate Him deputized the sheriff of DAUPHIN serve the within COMPLAINT & NOTICE County, Pennsylvania, to On May 9th , 2006 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 nn 1 V V V 05/09/2006 RUPP & MEIKLE Sworn and subscribed to before me So answe T- R. Thomas Kline Sheriff of Cumberland County this +L--4 day of ,;L06 A. D. P no ary in his bailiwick. He therefore In The Court of Common Pleas of Cumberland County, Pennsylvania Rupp and Meikle PC VS. Lavone G. Roosa et al SERVE: William E. Roosa No. 05-5930 civil Now, April 28, 2006 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, 20_, at within upon at by handing to - a and made known to o'clock copy of the original M. served the the contents thereof. So answers, Sheriff of Sworn and subscribed before me this _ day of 20, COSTS SERVICE MILEAGE _ AFFIDAVIT County, PA (Off.tcie of t4.e t i4rr :ff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania RUPP AND MEIKLE PC vs County of Dauphin ROOSA LEVONE Sheriff's Return Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy No. 0746-T - - -2006 OTHER COUNTY NO. 05-5930 CIVIL 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 ROOSA WILLIAM E. the DEFENDANT named in the within NOTICE & COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, May 4, 2006 PER NEIGHBOR DEFTS MOVED OUT IN SEPT. 2005 Sworn and subscribed to before me this 4TH day of MAY, 2006 11 AA--11 SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept 1, 2006 So Answers, ,Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs:$41.25 PD 05/02/2006 RCPT NO 217292 Curtis R. Long Prothonotary office of the Vrotbonotarv Cumberianb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 68' - _5 9.36 CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573