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HomeMy WebLinkAbout02-3228IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM E. KUHNERT and THERESA M. KUHNERT, his wife, Plaintiffs vs. GLENDALE LODGING, LTD., d/b/a CLARION HOTEL, Defendant CIVIL DIVISION PP~CIPE FORWRIT OF SUMMONS IN CIVIL ACTION Filed On Behalf Of: William E. Kuhnert and Theresa M. Kuhnert, his wife Counsel Of Record For The Above Party: Allan C. Lundberg Attorney at Law Lower Burrell Professional Plaza 3058 Leechburg Road Lower Burrell, PA 15068 (724) 339-9700 Attorney's I.D. #37200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION WILLI~J~ E. THERESA M. VS. KUHNERT and KUHNERT, his wife, Plaintiffs, GLENDALE LODGING, LTD., d/b/a CLARION HOTEL, Defendant. No. ~RAECIPE FOR WRIT OF SU~,~ONS IN CIVIL ACTIO~i TO THE PROTHONOTARY: Kindly issue a Writ of Summons in Civil Action against the Defendant, Glendale Lodging, Ltd., d/b/a Clarion Hotel, 1310 Holly Pike, Carlisle, PA 17013, in the above-captioned case. Dated: July 1, 2002 Allan C. Lundberg Attorney for Plaintiffs Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS WILLIAM E. KUHNERT AND THERESA M. KUHNERT, HIS WIFE Plaintiff Vs. GLENDALE LODGING, LTD. D/B/A CLAR/ON HOTEL 1310 HOLLY PIKE CARLISLE, PA 17013 Defendant Court of Common Pleas No. 02-3228 CIVIL TERM In CivilAction-Law To GLENDALE LODGING, LTD., D/B/A CLARION HOTEL You are hereby notified that WILLIAM E. KUHNERT AND THERESA M. KUHNERT, 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) Date JULY 8, 2002 Attorney: CURTIS R. LONG Prothonotary Deputy Name: ALLAN C. LUNDBERG Address: LOWER BURRELL PROFESSIONAL PLAZA 3058 LEECHBURG ROAD LOWER BURRELL, PA 15068 Attorney for: Plaintiff Telephone: 724-339-9700 Supreme Court ID No. 37200 WILLIAM E. KUHNERT and THERESA M. KUHNERT, his wife, Plaintiffs GLENDALE LODGING, LTD., d/b/a CLARION HOTEL, Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · No. 02-3228 Civil ENTRY OF APPEARANCE Please enter the appearance of Thomas E. Brenner, Esqtfire, of Goldberg, Katzman & Shipman, P.C. on behalf of Glendale Lodging, Ltd., d/b/a Clarion Hotel. Date: GOLDBERG, KATZMAN & SHIPMAN, P.C. Thomas E Brenner, Esqun'e ID #: 32085 PO Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorney for Defendant CERTIFICATION OF SERVICE I hereby certify that I served a copy of the foregoing document upon the person(s) indicated below by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania and addressed as follows: Allan C. Lundberg, Esq. Lower, Burrell Professional Plaza 3058 Leechburg Road Lower Burrell, PA 15068 Date: Thomas E. Brenner, Esq. WILLIAM E. KUHNERT and THERESA M. KUHNERT, his wife, Plaintiffs GLENDALE LODGING, LTD., d/b/a CLARION HOTEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 02-3228 Civil PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a Rule upon Plaintiffto file a Complaint within twenty (20) days of service thereof or suffer the entry of a judgment of non pros. GOLDBERG, KATZMAN & SHIPMAN, P.C. Date: BY: T~enner, Esquire ID #: 32085 PO Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorney for Defendant RULE TO FILE COMPLAINT AND NOW, this ~s~t/%day of ~ 2002, upon Praecipe of Defendant Glendale Lodging, Ltd., d/b/a Clarion Hotel, a Rul~ is hereby entered upon the Plaintiff to file a Complaint within twenty (20) days after service of this rule or suffer the entry ora judgment of non pros. Date: Prothonotary CERTIFICATION OF SERVICE I hereby certify that I served a copy of the foregoing document upon the person(s) indicated below by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania and addressed as follows: Allan C. Lundberg, Esq. Lower, Burrell Professional Plaza 3058 Leechburg Road Lower Burrell, PA 15068 Date: i nomas r~. t~renner, Esq. SHERIFF'S RETURN - CASE NO: 2002-03228 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KUHNERT WILLIAM E ET AL VS GLENDALE LODGING LTD D/B/A REGULAR RONALD HOOVER Cumberland County, Pennsylvania, says, the within WRIT OF SUMMONS GLENDALE LODGING LTD D/B/A CLARION HOTEL DEFENDANT at 1409:00 HOURS, on the at 1310 HOLLY PIKE CARLISLE, PA 17013 MIKE REYNOLDS, PRESIDENT a Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon 10th day of July the , 2002 by handing to true and attested copy of WRIT OF SUMMONS together with and at the same time directing ~is attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this ?/~_ day of ~_,.~,-4.~ ~-~..A~ · A.D. ~r~ hon-ot ary ~ So Answers: R. Thomas Kline 07/11/2002 ALLAN C LUNDBERG By: -2 ~ Deputy Sheri[f William E. Kuhnert and Theresa M. Kuhnert, h/w In The Court of Common Pleas of Cumberland County, Pennsylvania VS Plaintiffs Glendale Lodging, Ltd. d/b/a Clarion Hotel Defendant No. 02-- 3228 Civil Action -- Law Praecipe to Settle and Discontinue Dear Mr. Long: Please mark the above captioned matter settled and discontinued with prejudice. October 28, 2002 Willia~n P. [ ~uglas, Esq. Attomey ~~ William E. Kuhnert Theresa M. Kuhnert