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Home My WebLink About06-2861l 4 William P. Douglas, Esq. Supreme Court I.D. #37926 Douglas Law Office 27 W. High St. Carlisle, PA 17013 Telephone (717) 243-1790_ Sean P. Tighe; Kimberly A. Sellers and In the Court of Common Pleas of CSR Enterprises, a Partnership Cumberland County, Pennsylvania Plaintiff vs No. 06 - - F-6 t civil Term Arpin Group t/a/d/b/a Paul Arpin Moving Co/ Van Lines Civil action law Defendant Jury Trial Demanded Praecipe to Issue a Writ of Summons Dear Mr. Long: Please issue a writ of summons against the defendant Arpin Group t/a/d/b/a Paul Arpin Moving Co./ Van Lines. Attorney for date: May 18, 2006 `mil ? ?,, D C 'L1l n? -G 4m -cs r-- 0 0 m? -? m J ? a i Commonwealth of Pennsylvania County of Cumberland Sean P. Tighe; Kimberly A. Sellers and In the Court of Common Pleas of CSR Enterprises, a Partnership Cumberland County, Pennsylvania Plaintiff vs No. 06 I Civil Term Arpin Group t/a/d/b/a Paul Arpin Moving Co/ Van Lines Civil action law Defendant Jury Trial Demanded Writ of Summons To: Arpin Group t/ a / d / b / a Paul Arpin Moving Co/Van Lines POB 1302 East Greenwich RI 02818-0998 You are hereby notified that Sean P. Tighe; Kimberly A. Sellers and CSR Enterprises, a Partnership have brought an action against you. ?' D uty Pr onotary date: May 18, 2006 William P. Douglas, Esq. Douglas Law Office 27 W. High St. Carlisle, PA 17013-0261 717-243-1790 Attorney for Plaintiff 0 RAWLE & HENDERSON LLP By: Jon Michael Dumont Identification No.: 69083 The Widener Building One South Penn Square Philadelphia, Pennsylvania 19107 (215) 575-4200 SEAN P. TIGHE, KIMBERLY A. SELLERS and CRS ENTERPRISES, a Partnership, Plaintiffs, vs. ARPIN GROUP t/a/d/b/a PAUL ARPIN MOVING CO. / VAN LINES, Defendants. TO THE PROTHONOTARY: Attorneys for IN THE COU OF CUMBEF NO.: 06-2861 CIVIL ACTI( OF COMMON PLEAS ND COUNTY, PA - LAW In accordance with Rule 1037(a) of the Pennsylvania Rules Iof Civil Procedure, kindly enter a Rule upon Plaintiffs to file a Complaint in connection within twenty (20) days after service of the Rule. RAWLE & HENDERSON LLP By: J for Defendant Dated: May 25, 2006. the above-captioned case 1308854 v.l Y r SEAN P. TIGHE, KIMBERLY A. SELLERS and CRS ENTERPRISES, a Partnership, Plaintiffs, VS. ARPIN GROUP t/a/d/b/a PAUL ARPIN MOVING CO. / VAN LINES, Defendants. IN THE COU OF CUMBEP NO.: 06-2861 CIVIL ACTI( RULE TO FILE COMPLAINT AND NOW, this 31A* day of pq-" , 2006, a Plaintiffs to file a Complaint herein within 20 days after service h Judgment of Non Pros. 'OF COMMON PLEAS LND COUNTY, PA - LAW is hereby granted upon or suffer the entry of a 1308854 v.1 a CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct for Rule upon Plaintiff to File a Complaint was served upon the class U.S. mail, postage pre-paid. William P. Douglas, Esquire Douglas Law Office 27 West High Street Carlisle, PA 17013-0261 RAWLE & Jon Dated: May 25, 2006. 1308854 v.1 of the foregoing Praecipe listed counsel via first LLP c ?r t r' C ` fi f.St C O f . RAWLE & HENDERSON LLP By: Jon Michael Dumont Dawn L. Jennings Identification No.: 69083; 68939 The Widener Building One South Penn Square Philadelphia, Pennsylvania 19107 (215) 575-4200 ------------------------------------------------------ SEAN P. TIGHE, KIMBERLY A. SELLERS and CRS ENTERPRISES, a Partnership, Plaintiffs, V. ARPIN GROUP t/a/d/b/a PAUL ARPIN MOVING CO. / VAN LINES, Defendants. Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO.: 06-2861 CIVIL ACTION - LAW PRAECIPE TO ENTER JUDGMENT OF NON PROS TO THE PROTHONOTARY: Please enter a judgment of non pros in favor of Defendant, Arpin Gruop, and against Plaintiffs, Sean P. Tighe,. Kimberly A. Sellers and CRS Enterprises, a partnership, for failure to file a Complaint. It is hereby certified that a copy of the Ten Day Notice of Intention to Enter Judgment was timely served on plaintiffs and their counsel on July 21, 2006 and May 2, 2007, in accordance with Pa. R.C.P. 237.1. See Ten Day Notices attached as Exhibit "A." RAWLE & HENDERSON, LLP BY: J,,, L . on Michael Dumont Dawn L. Jennings Date: May 29, 2007 Attorneys for Defendant, Arpin Group 2075656-1 RAWLE & HENDERSON LLP By: Jon Michael Dumont Dawn L. Jennings Identification No.: 69083; 68939 The Widener Building One South Penn Square Philadelphia, Pennsylvania 19107 (215) 575-4200 ------------------------------------------------------ Attorneys for Defendant SEAN P. TIGHE, KIMBERLY A. IN THE COURT OF COMMON PLEAS SELLERS and CRS ENTERPRISES, OF CUMBERLAND COUNTY, PA a Partnership, Plaintiffs, NO.: 06-2861 V. CIVIL ACTION - LAW ARPIN GROUP t/a/d/b/a PAUL ARPIN MOVING CO. / VAN LINES, Defendants. CERTIFICATION OF SERVICE I hereby certify that on today's date I served a true and correct copy of the foregoing Praecipe to Enter Judgment of Non Pros upon all parties addressed via regular, first class mail: William P. Douglas, Esquire Douglas Law Office 27 West High Street Carlisle, PA 17013-0261 Attorney for Plaintiffs Sean Tighe Kimberly Sellers CSR Enterprises, a Partnership 9767 Forest Ridge Rd. Shippensburg, PA 17257 RAWLE & HENDERSON LLP By: L Dawn L. Jennings Attorney for Defendant, DATED: May 29, 2007 Arpin Group 2075656-1 1, RAWLE & HENDERSON LLP By: Jon Michael Dumont Dawn L. Jennings Identification No.: 69083; 68939 The Widener Building One South Penn Square Philadelphia, Pennsylvania 19107 (215) 575-4200 SEAN P. TIGHE, KIMBERLY A. SELLERS and CRS ENTERPRISES, a Partnership, Plaintiffs, V. ARPIN GROUP t/a/d/b/a PAUL ARPIN MOVING CO. / VAN LINES, Defendants. Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO.: 06-2861 CIVIL ACTION LAW IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 TO HIRE 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. Date: July 21, 2006 RAWLE & HENDERSON, LLP BY: " /1 '4 1 gzfD Jon Micha.1 Dumont Dawn L. Jennings The Widener Building One South Penn Square Philadelphia, PA 19107 Telephone: (215) 575-4200 Attorneys for Defendant Arpin CERTIFICATION OF SERVICE I hereby certify that on today's date I served a true and correct copy of the foregoing Notice to Take Default upon all parties addressed via regular, first class mail: William P. Douglas, Esquire Douglas Law Office 27 West High Street Carlisle, PA 17013-0261 Attorney for Plaintiff RAWLE & HENDERSON LLP By: Dawn V. Jen Attorney for DATED: July 21, 2006 1331785 v.] n RAWLE & HENDERSON LLP By: Jon Michael Dumont Dawn L. Jennings Identification No.: 69083; 68939 The Widener Building One South Penn Square Philadelphia, Pennsylvania 19107 (215) 575-4200 SEAN P. TIGHE, KIlVIBERLY A. SELLERS and CRS ENTERPRISES, a Partnership, Plaintiffs, V. ARPIN GROUP t/a/d/b/a PAUL ARPIN MOVING CO. / VAN LINES, Defendants. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 TO HIRE 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. Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO.: 06-2861 CIVIL ACTION - LAW RAWLE & HENDERSON, LLP BY: Jon Michael umont Dawn L. Je ngs The Widener Building One South Penn Square Philadelphia, PA 19107 Telephone: (215) 575-4200 Date: May 2, 2007 Attorneys for Defendant Arpin Group 1331785 v.I ^a f n CERTIFICATION OF SERVICE I hereby certify that on today's date I served a true and correct copy of the foregoing Notice to Take Default upon all parties addressed via regular, first class mail: William P. Douglas, Esquire Douglas Law Office 27 West High Street Carlisle, PA 17013-0261 Attorney for Plaintiff Sean Tighe Kimberly Sellers CSR Enterprises, a Partnership 9767 Forest Ridge Rd. Shippensburg, PA 17257 RAWLE & HENDERSON LLP By: Dawn L. ings Attorney or Defen DATED: May 2, 2007 1331785 v.1 • ?.? "? J x G v ca