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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. (')L, -dl{96 (]J();{~~
Civil Action
Ik:( Complaint for Money Owed
GANNETT FLEMING, INC.
)
)
)
)
MR. DANIEL MORROW
CLEAN EARTH, INC
334 SOUTH W ARMINSTER
ROAD
HATBORO, PA 19040
209 SENATE AVENUE
CAMP HILL, PA 17011
Plaintiff (s) & Address( es)
Defendant(s) & Address(es)
PRAECIPE FOR WRIT OF SUMMONS
TO THE PROTHONOTARY OF SAID COURT
Please issue writ of sununons in the above-captioned action.
Writ ,rs""""""..,..., '" '"",,!o'" f_ to DAlto"", [B/s~ 1
Dale E. Kortze, Jr. ~~~ ~
Ignature of A ey rf
209 Senate Avenue
Camp Hill, PA 17011
(717) 763-7211 Ext. 2141
Supreme Court ID No.: 45620
April 25, 2006
Name! AddressfTelephone No. of Attorney
WRIT OF SUMMONS
TO THE ABOVE NAMED DEFENDANTS(S)
YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HASIHA VE
COMMENCED AN ACTION AGAINST YOU.
Date: (YI ri....., .~ J CQ k,
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Case No. 2006-02490 P
Civil Action
D Complaint for Money Owed
GANNETT FLEMING, INC.
)
)
)
)
)
MR. DANIEL MORROW
CLEAN EARTH, INC
334 SOUTH W ARMINSTER
ROAD
HATBORO, PA 19040
209 SENATE AVENUE
CAMP HILL, PA 17011
Plaintiff
Defendant
STIPULA TlON OF DISMISSAL WITH PREJUDICE, OF ALL CLAIMS
The parties to the instant action are plaintiff Gannett Fleming, Inc. and defendant
Clean Earth Inc., also or previously known as Consolidated Technologies, Inc., ("Consolidated").
These two parties now wish to dismiss all claims and cross-claims in the instant action, with
prejudice, pursuant to a stipulated settlement agreement entered into between the parties.
These parties hereby stipulate that all claims and cross-claims that were or could have been
brought in this action should be dismissed with prejudice and without further costs with each
party bearing its own attorneys' fees, and waiving all right of appeal or other judicial review,
because this action has settled.
GANNETT FLEMING, INC., Plaintiff
By its attorneys,
~L
Dale E. Ko e, sq. - \<\ Atty. ID#45620
Michelle N. Harhai, q. - PA Atty. ID #95088
P.O. Box 67100
209 Senate Ave.
Harrisburg, PA 17106-7100
Tel. 717-763-7211
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SHERIFF'S RETURN - OUT OF COUNTY
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CASE NO: 2006-02490 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GANNETT FLEMING INC
VS
MORROW DANIEL
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:
MORROW DANIEL
but was unable to locate Him
In his bailiwick. He therefore
deputized the sheriff of MONTGOMERY
County, Pennsylvania, to
serve the within WRIT OF SUMMONS
On May
22nd , 2006 , this office was in receipt of the
attached return from MONTGOMERY
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Montgomery Co
Postage
So
County
18.00
9.00
10.00
33.00
.78
70.78'; n 1.(}7,(){,
OS/22/2006 ~
GANNETT FLEMING COMPANIES
,..
,
In The Court of Common Pleas of Cumberland County, Pennsylvania
Gennett Fleming Inc
VS.
Daniel Morrow
.
No. 06-2490 civil
Now,
May 8, 2006
, I, SHERIFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of Montganery
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
r~~
Sheriff of Cum berland County, P A
Now, /~ Milt!
(
within [LJ j2 /;
Affidavit of Service
, 20&, at //d"f"o'c1ockftM. served the
upon _
....
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at
-
by handing to
~~
copy of the original
a
and made known to
the contents thereof.
COSTS
SERVICE
MILEAGE
AFFIDAVIT
$
$
.
i
SHERIFF'S RETURN
PROTHONOTARY
C-1889
DEFENDANT: Daniel Morrow POE: Clean Earth Inc.
DOCUMENT SERVED: Civil
INDIVIDUAL SERVED: Steve Sands
RELATIONSHIP TO DEFENDANT: Person In Charge
DATE AND PREVAILING TIME: May 12, 2006 @ 11:05
LOCATION:
334 South Warminster Rd., Hatboro, P A
7" Joq.e ~ ~ uwd ~ de <<~"<<c"e u flU ~ tueut Joq.e "" de
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I PATRICIA A GIA 1& J
Notary PubliC
, ',0RRI'3TOWN BOPUU(;H.MONTGO".ERY COUNTY .,
;'1 ('" ,..,.-" 1,)nE'Vlrt.Dec13,2008
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pd. 1J. 'D<<IU&4Ite
Sheriff of Montgomery County
Deputy Sheriff
Bono