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HomeMy WebLinkAbout02-3111RONALD E. BETTY A. KLAIR and KLAIR, his wife, Plaintiffs VS. FARMINGTON CASUALTY COMPANY, TRAVELERS PROPERTY CASUALTY INSI/R3kNCE COMPANY, and THE TRAVELERS INDEMNITY COMPANY, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA - 3111 : CIVIL ACTION - LAW : JURY TRIAL DEMJ~I'DED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Kindly issue a Writ of Summons in the above-captioned action. Date: June ~ , 2002 Marlin R. McCaleb Attorney I.D. No. 06353 219 East Main Street P.O. Box 230 Mechanicsburg, PA 17055 (717) 691-7770 FAX: (717) 691-7772 Attorney for Plaintiffs MARLIN R, McCAL,~B According to the Pennsylvania Insurance Department, the home offices of the Defendants are as follows: Farmington Casualty Company One Tower Square Hartford, CT 06183 Travelers Property Casualty Insurance Company One Tower Square Hartford, CT 06183 The Travelers Indemnity Company One Tower Square Hartford, CT 06183 Please serve these Defendants by mail at these addresses pursuant to Pa. R.C.P. 403 and 404(2). Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS RONALD E. KLAIR AND BETTY A. KLAIR, HIS WIFE Plaintiff Vs. Court of Common Pleas No. 02-3111 CIVIL TERM In CivilAction-Law FARMINGTON CASUALTY COMPANY, TRAVELERS PROPERTY CASUALTY INSURANCE COMPANY, AND THE TRAVELERS INDEMNITY COMPANY Defendant To FARMINGTON CASUALTY COMPANY, TRAVELERS PROPERTY CASUALTY INSURANCE COMPANY, AND THE TRAVELERS INDEMNITY COMPANY You are hereby notified that RONALD E. KLAIR AND BETTY A KLAIR, HIS WIFE the Plaintiff has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Prothonotary Date JUNE 28, 2002 By Attorney: Name: MARLIN R. MCCALEB Address: 219 E MAIN ST P O BOX 230 MECHANICSBURG, PA 17055 Attorney for: Plaintiff Telephone: 717-691-7772 Supreme Court ID No. 06353 MEMO TO THE SHERIFF: According to the Pennsylvania Insurance Department, the home offices of the Defendants are as follows: Farmington Casualty Company One Tower Square Hartford, CT 06183 Travelers Property Casualty Insurance Company One Tower Square Hartford, CT 06183 The Travelers Indemnity Company One Tower Square Hartford, CT 06183 Please serve these Defendants by mail at these addresses pursuant to Pa. R.C.P. 403 and 404(2). F: ~FILESkDATAFILE\Travdoc c ur\742_pra, l/a jr Created: 02/01/02 02:08:05 PM Revised: 08/15/02 08:53:18 AM 3090.742 RONALD E. KLAIR and, BETTY A. KLAIR, his wife, Plaintiffs FARMINGTON CASUALTY COMPANY, TRAVELERS PROPERTY CASUALTY INSURANCE COMPANY, and THE TRAVELERS INDEMNITY COMPANY, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3111 CiVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO: THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance ofMARTSON DEARDORFF WILLIAMS & OTTO on behalf of the Defendants, Farmington Casualty Company, Travelers Property Casualty Insurance Company, and The Travelers Indemnity Company in the above matter. Issue a rule upon the Plaintiffs to file a Complaint within twenty (20) days from service thereof or suffer judgment of non pros. Dated: August 15, 2002 MARTSON DEARDORFF WILLIAMS & OTTO Daniel K. Deardorff, Esquire ~ I.D. No. 17837 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendants RULE AND NOW, this ~ day of~, 2002, a Rule is issued upon the Plaintiffs to file a Complaint within twenty (20) days fr~ service hereof. Prothonotary/~ CERTIFICATE OF SERVICE I, Ami J. Thumma, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Marlin R. McCaleb, Esquire 219 East Main Street P.O. Box 230 Mechanicsburg, PA 17055 Attorney for Plaintiffs MARTSON DEARDORFF W1LLIAMS & OTTO Y~)~ ~ B Ami J. Tbkanma Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: August 15, 2002 SHERIFF'S RETURN - CASE NO: 2002-03111 P COMMONWEALTH OF PENNSYLVANIA cOLrNTY OF CUMBERLAND KLAIR RONALD E ET AL VS. FARMINGTON CASUALTY CO ET AL U.S. CERTIFIED MAIL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,FARMINGTON CASUALTY COMPANY , by United States Certified Mail postage prepaid, on the 1st day of July ,2002 at 0000:00 HOURS, at ONE TOWER SQUARE HARTFORD, CT 06183 and attested copy of the attached WRIT OF SUMMONS with , a true Together The returned receipt card was signed by JEFFREY L BURRILL 07/04/2002 Additional Comments: on Sheriff's Costs: Docketing 18.00 Cert Mail 4.42 Affidavit .00 Surcharge 10.00 .00 32.42 So ans~ze~$: - :~- L~ R. Thomas Kline Sheriff of Cumberland County Paid by MARLIN MCCALEB Sworn and subscribed to before me this2~ day of ~l~ A.D. Pr6thonotary on 07/09/2002 SHERIFF'S RETURN - U.S. CASE NO: 2002-03111 p COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KLAIR RONALD E ET AL VS. FARMINGTON CASUALTY CO ET AL CERTIFIED MAIL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,TRAVELERS PROPERTY CASUALTY INSURANCE COMPANY by United States Certified Mail postage prepaid, on the 1st day of July ,2002 at 0000:00 HOURS, at ONE TOWER SQUARE HARTFORD, CT 06183 and attested copy of the attached WRIT OF SUMMONS with , a true Together receipt card was signed by JEFFREY L BURRILL 07/03/2002 The returned on Additional Comments: Sheriff,s Costs: Docketing 6.00 Cert Mail 4.42 Affidavit .00 Surcharge 10.00 .00 20.42 So answers: J~ -- ~ R. Thomas Kline Sheriff of Cumberland County Paid by MARLIN MCCALEB Sworn and subscribed to before this j~ day of L~ me ~_ A.D. P~o~honotary on 07/09/2002 SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2002-03111 p COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERL~ND KLAIR RONALD E ET AL VS. FARMINGTON CASUALTY CO ET AL R. Thomas Kline County, Pennsylvania, within named DEFENDANT , Sheriff of Cumberland who being duly sworn according to law served the ,TRAVELERS INDEMNITY COMPANY prepaid, on the 1st day of ONE TOWER SQUARE by United States Certified Mail postage July ,2002 at 0000:00 HOURS, at HARTFORD, CT 06183 and attested copy of the attached WRIT OF SUMMONS with a true Together receipt card was signed by JEFFREY L BURRILL 07/03/2002 Additional Comments: The returned on Sheriff,s Costs: Docketing 6.00 Cert Mail 4.42 Affidavit .00 Surcharge 10.00 .00 20.42 So answers: R. Thomas' Klin/~-- ~ Sheriff of Cumberland County Paid by MARLIN MCCALEB Sworn and subscribed to before me this. ~4~W day of ~2~ 2~ A.D. Pr6t~onot~ry on 07/09/2002 · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Tr~velers Property Casualty Insurance Company One Tower Square Hartford, CT 06183 3, Service Type ~ Cedified Mail [] Express Mail [] Registered [] Return Receipt for Merchandise [] Insured Mail [] C.O,D. 4. Restricted Delivery? (Extra Fee) [] Yes 7001 2510 0009 1017 8305 02-3111 civ PS Form 3811, August 2001 Domestic Return Receipt 102595-01 -M-0381 · Complete items 1, 2, and 3. Also complete item 4 if Restribted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: The Travelers Indemnity Company One Tower Square Hartford, CT 06183 A. Signature X; I-1 Agent [] Addressee B. Received by ( Printed Name) C. Date of Delivery D. Is delivery addms~Ji~r~m fm~m ~m~r~ TTYes If YES, enter delivery address below: [] No 3. Service Type X~ Certified Mail [] Express Mail [] Registered [] Return Receipt for Merchandise [] Insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) [] Yes 2. A 7001 2510 0009 1017 8299 02-3111 civ PS Form 3811, August 2001 Domestic Return Receipt 102595-01 -M-0381 · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the meilpiece, or on the front if space permits. 1. Article Addressed to; Farmington Casualty Cc~pany One Tower Square Hartford, CT 06183 7001 2510 0009 1017 8312 ,' .A. Signature Receive(J'by ( Printed Name) / C. Date of ?~livery Is delivery address diffe~o~rffite~ 1~- I~-Yes 3. Service Type X~ Certified Mail [] Express Mail [] Registered [] Return Receipt for Merchandise [] Insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) [] Yes 02-3111 civ PS Form 3811, August 2001 Domestic Return Receipt 102595-01-M-0381 RONALD E. KLAIR and BETTY A. KLAIR, his wife, Plaintiffs VS. iINGTON CASUALTY COMPANY, TRAVELERS PROPERTY CASUALTY INSURANCE COMPANY, and THE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : · NO. 02-3111 CIVIL : : : CIVIL ACTION - LAW : TRAVELERS INDEMNITY COMPANY, : Defendants : JURY TRIAL DEMANDED PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY: Please mark the within action as settled, discontinued and ended as to all Defendants. Date: September 20, 2002 Marlin R. McCaleb Attorney I.D. No. 06353 219 East Main Street P.O. Box 230 Mechanicsburg, PA 17055 (717) 691-7770 FAX: (717) 691-7772 Attorney for Plaintiffs MARLIN R. McCALEB