The URL can be used to link to this page

Home My WebLink About00-03285 ~'''-'>IiIII>"' . ~ .~ "........~ ".-.-..~' ,~~~,~~._-~~ ~ ''qj' i ..J '(a:,.;,_: MELISSA E. BRIGHTBILL McHALE vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOSEPH A. GARMAN NO. cl,tHJ-1J/3J8J ~ 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 OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 STEINER, SANDOE & COOPER By: ~ (~c:Uz enneth C. Sandoe, Esquire Attorney for Plaintiff ID #25976 36 W. Main Myerstown, Telephone: Avenue PA 17067 (717) 866-5737 - ~s&:,;K:"WI.'. MELISSA E. BRIGHTBILL McHALE vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. dffV_ 3.UO' Cv;.;f ~. JOSEPH A. GARMAN COMPLAINT AND NOW, comes the Plaintiff, Melissa E. Brightbill McHale, by her attorneys, Steiner, Sandoe & Cooper, Esquires, and files the following Complaint: 1. Plaintiff, Melissa E. Brightbill McHale, is an adult individual, sui juris, who resides at 300 Ridge Road, Trailer 104, Etters, York County, Pennsylvania. 2. Defendant, Joseph A. Garman, is an adult individual, sui juris, who resides at 659 East Walnut Street, Hanover, York County, Pennsylvania. 3. At all times material hereto, Plaintiff, Melissa E. Brightbill McHale, was the owner of a 1993 Nissan Maxima automobile. 4. At all times material hereto, the Defendant, Joseph A. Garman, was the operator of a 1995 GEO Tracker automobile owned by his father, Gary L. Garman. 5. On July 29, 1999, at approximately 7:45 a.m., the Plaintiff, Melissa E. Brightbill McHale, was operating the aforesaid Nissan Maxima automobile and was in stopped traffic on 1- - . .1' 83N, just past the Limekiln Road Exit in New Cumberland, Cumberland County, Pennsylvania. 6. At the above, date, time and place, the Defendant, Joseph A. Garman, was operating the aforesaid GEO Tracker automobile when he rear-ended the Plaintiff, who was stopped at the end of a line of stopped traffic, on I-83N just past the Limekiln Road Exit in New Cumberland, Cumberland County, Pennsylvania. 7. On or about the above date, time and place, the aforesaid accident was due solely to the negligence, carelessness, recklessness, willful andlor wanton misconduct of the Defendant as more particularly described herein. 8. As a direct and proximate result of the aforesaid collision, the Plaintiff, Melissa E. Brightbill McHale, has suffered severe personal, pecuniary and psychic injuries, which injuries are set forth below with particularity. 9. The accident was not the fault in any manner whatsoever of the plaintiff, Melissa E. Brightbill McHale. 10. As a result of the aforesaid accident, the Plaintiff, Melissa E. Brightbill McHale, has sustained serious injuries to her person, including but not limited to, cervical, back and shoulder injuries. 11. As a result of the motor vehicle accident as aforesaid, the plaintiff, Melissa E. Brightbill McHale, has incurred medical expenses which she is entitled or may be entitled to recover in 'I '., ....c, - ."'." tl,i;, accordance with the applicable Pennsylvania law. 12. As a result of the motor vehicle accident as aforesaid, the Plaintiff, Melissa E. Brightbill McHale, will or may be forced to incur additional medical and hospitalization costs and may suffer a loss of earnings for which she is entitled to remuneration in accordance with applicable Pennsylvania law. 13. As a result of the motor vehicle accident as aforesaid, the Plaintiff, Melissa E. Brightbill McHale, has suffered a severe shock and trauma to her nerves and nervous system and has endured and will continue to endure in the future great physical and mental pain and suffering. 14. As a result of the motor vehicle accident as aforementioned, the Plaintiff, Melissa E. Brightbill McHale, may for an indefinite time in the future suffer a loss of earnings and earning capacity to which the Plaintiff, Melissa E. Brightbill McHale, is entitled to remuneration. 15. As a result of the conduct of the Defendant, as more particularly described herein, the Plaintiff, Melissa E. Brightbill McHale, may suffer a permanent impairment of her future earning capacity, for which she is entitled to remuneration. 16. As a result of the conduct of the Defendant, as more particularly described herein, the Plaintiff, Melissa E. Brightbill McHale, has been and will be prevented from performing her usual duties and activities, and has suffered and will suffer for the remainder of her life, great pain, mental anguish, emotional ~ ~ - "" ~ '-~ ~ ~-. .. "~ ~, 'j\;!!JiME-" difficulties, disfigurement, embarrassment, loss of well-being, and other limitations on her abilities to engage in normal activities and enjoy the ordinary pleasures of life. 1 7. As a result of the aforesaid motor vehicle accident, Plaitiff, Melissa E. Brightbill McHale, incurred expenses for a rental car in the amount of $52.75, for which she is entitled to recovery. COUNT I MELISSA E. BRIGHTBILL McH!LE v. JOSEPH A. GARMAN 18. Paragraphs 1 through as though specifically 17 are incorporated set forth at length. herein by reference 19. Plaintiff, Melissa E. Brightbill McHale, has been informed, believes and therefore avers, that the aforesaid motor vehicle accident resulted totally from the negligence, recklessness and carelessness of the Defendant, Joseph A. Garman, which said conduct consists of the following: A. In driving the aforesaid motor vehicle without obeying traffic conditions at the place of the accident; B. In driving the aforesaid motor vehicle without keeping a proper lookout for other drivers and users of the highway at the date, time and place of the accident; C. In Plaintiff at failing to yield the right of way to the the date, time and place of the accident, in , , that the Defendant, Joseph A. Garman, failed to stop his vehicle and rear-ended the Plaintiff's vehicle, causing the violent collision as aforesaid; D. In failing to have the motor vehicle under proper and adequate control at the date, time and place of the accident; E. In failing to be able to bring the motor vehicle to a stop within the assured clear distance rule at the date, time and place of the accident; F. In driving the motor vehicle as aforementioned in an inattentive and careless manner, without due regard for the rights and safety of other users of the highway; namely, the Plaintiff, Melissa E. Brightbill McHale. G. In driving the motor vehicle as aforesaid in a careless, negligent and reckless manner in that the Defendant, Joseph A. Garman, at no time attempted to slow down or use his brakes prior to colliding with Plaintiff's vehicle, and was being inattentive to his driving; H. Such other acts or omissions constituting negligence andlor gross negligence or wanton conduct as shall become evident during pre-trial discovery andlor at the trial of this case. - "' ~-, ~~ I ". , ~~,;-.. WHEREFORE, it is respectfully requested that this matter be set for arbitration before an arbitration panel. STEINER, SANDOE & COOPER By:r~ Ken eth C. Sandoe, Esqulre Attorney for Plaintiff 1D #25976 36 W. Main Avenue Myerstown, PA 17067 Telephone: (717) 866-5737 ~ " '. . .... VERIFICATION The undersigned verifies that the facts contained herein are true and correct. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. S4904, relating to unsworn falsification to authorities. Date: ild!ImlII:Nt~ ......... -iillrtlliO'_l_ - ___11'1, -"~Ir n -, . . ~l ~ QR ~ ~ ?L ~ .... J C> 0 LJ ~ -:-S' f;; 0 '-r'! ~ ,"'" :x UJ 'OJ -' " rn :;;. 'H~,j@ ~ ' ::Ii' -< ~,~ N ..ti~ 0"> :,5: ct) ~~ [<0 l::>fL ~ )> ""0 ~-T' 20 ::g ~ ...-ri :i>g 2:0 , l;;/\ ra, 0"'" ~ '\::; , ~ ~ -I N ~ -.I , ,~'.'~ ,",'. ~ '^, """'" 'd "~,, -" ,~".",.- '''~" ",' - ,,~" . ,;~ . . - ...~ ~ '~ " '".'< .,. ,io-- ~- , ,~, ;! :,j 1~ v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 200D.3285 CIVIL ACTION. AT LAW lj r~ I': ~ ,', i~ i[: ~I :r, !,c " :1 t~ t~ ill , l! rj II I~ " Ii 11 iM ti [P f! Ii " l; it il: i ~ MELISSA E.BRIGHTBILL McHALE, PLAINTIFF JOSEPH A. GARMAN, DEFENDANT JURY TRIAL DEMANDED ANSWER 2. Admitted. ", ii I~j iJ il )~ Ii ;1 ,i :~ I~ if ~, ~1 AND NOW, comes the Defendant, Joseph A. Garman, by and through his attorneys, NEALON & GOVER, P.C., and files the following Answer: 1. Admitted, upon information and belief. " :~ ,,: 4. Admitted in part and denied in part. Joseph A. Garman co-owned the 'j ~ i~ \ ij; ] :, 3. Admitted. vehicle along with his father. 5-6. Admitted in part and denied in part. It is admitted that a collision took place between a vehicle operated by Joseph Garman and a vehicle operated by the Plaintiff. It is further admitted that in the collision, the Garman vehicle struck the rear end of the McHale vehicle and that the collision occurred at the location alleged in the Complaint. To the extent these paragraphs allege any additional facts, the same are denied pursuant to Pa. R.C.P. 1029(e). "0"-'="- 'c k-"_,",;o,,. ,-~-,- 'j "I , 10-17. Denied. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the matters asserted and proof is demanded at trial. COUNT I MELISSA E. BRIGHTBILLE McHALE V. JOSEPH A. GARMAN 18. Paragraphs 1 through 17 of Defendant's Answer are incorporated herein by reference thereto. 19. This paragraph states a conclusion of law to which no responsive pleading is required. To the extent that they are construed to allege facts, the same are denied WHEREFORE, Defendant, Joseph A. Garman, respectfully request that the pursuant to Pa. R.C.P. 1029(e). Complaint be dismissed with costs of this action. Respectfully submitted, NEALON & GOVER By: .:h....:.....~ David J. Freed, Esquire Atty.I.D.#76622 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 ~~ " ,'" ,~ < - - ""- "' VERIFICATION I, Joseph A. Garman, verify that the statements made in the foregoing Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.SA 4904 relating to unsworn falsification to authorities. A"'" _~~ c:J( r-- Dated: 8/9/00 , - -~ ~ , '--,' , ,,'-- ~ ,. 0 ^,'. " '-,'; . CERTIFICATE OF SERVICE AND NOW, this 9th day of August, 2000, I hereby certify that I have served the foregoing Answer on the following via first-class mail, postage prepaid, addressed to: Kenneth C. Sandoe, Esquire 36 West Main Avenue Myerstown, PA 17067 ~......:J~ David J. Freed, Esquire Dated: 08/09/00 .'""f "',"-"-'.' : PRAECIPE FOR ENTRY OF APPEARANCE MELISSA E. BRIGHTBILL McHALE IN THE COURT OF COMMON PLEAS OF CLlMS. COUNTY. PENNSYlVANIA CIVIL ACTION LAW NO. ~ r ~ "L~6-' ~ vs. TO PROTHONOTARY OF SAID coum; JOSEPH A. GARMAN SIR, Please enter t.'1e ap?e=2..'1ce of Steiner, Sandoe & whose address is 36 W. Cooper Individual or Law Firm Main Ave., Myerstown, PA 17067 as Attorney (s) for Melissa E. Brightbill McHale the Plaintiff Dated May 25, 2QOO XJf~X in above captioned ease. /fC1i2<-~ Signa ture Kenneth C. Sandoe, Esquire ID # 25976 ~"'1i;'~~"'''''''''''~- . ..- , ..' "' ~~'_~"."'. 1== . bl" '~' ~ --" "" 'I i I I I 0 0 0 ~ (;:) -r, ::% :..-:1 "tJ9j "'" i~',~i' pJ 91 -= N ,"Om ~~ :nO 0> ~Q -0 >=14 l@ :JI: ",0 C;il ~m :> .. ~ ?J N ~ Q) " ... SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-03285 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MCHALE MELISSA E BRIGHTBILL VS GARMAN JOSEPH A 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 GARMAN JOSEPH A but was unable to locate Him , to wit: in his bailiwick. He therefore deputized the sheriff of YORK serve the within COMPLAINT & NOTICE County, Pennsylvania, to On June 26th , 2000 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge York County 18.00 9.00 10.00 34.63 .00 71.63 06/26/2000 STEINER SANDOE Sworn and subscribed to day of ~ before me this (, It- ,.2nD A.D. ~ Q h"d/#;./ ~' Prothonotary omas Kline riff of Cumberland County & COOPER COUNTY OF YORK OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN INSTRUCTIONS PLEASE TYPE ONLY LINES 1 TO 12 DO NOT DETACH ANY COPIES. 2. GOUATNUMBEA _~~.;;L/j:J CJ.VJ..L 4. TYPE OF WAIT OR COMPLAINT Notice & Complaint ! I 1. PLAINTIFF/S! Melissa E. Brightbill McHale 3. DEFENDANTIS! Joseph A. Garman SERVE { 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTI,ON ~~ ,PROPERTY TO B.E,lSVI,ED,- ATTACHED, OR SOLD. Joseph A. Garman ,,'~ ., '-" . 6. ADDRESS (STREET OR RFD WITH BOX NUMBER. APT NO., CITY, BORD, TWP., STATE AND ZIP CODE AT 659 E. Walnut St, Hanover, PA 7. INDICATE SERVICE: a PERSONAL 0 PERSON IN CHARGE Xl OEPUTlzECumheiUU:.CM&Jd 0 1ST CLASS MAIL NOW 6/14/00 19 _I, SHERIFF OF ~COU~o hereby de u'z Vt')rk COUNTY to ex I n ret to law. This deputation being made at the request and risk of the plaintiff. . SHE IFF 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: o POSTED 0 OTHER e sheriff of of, according Cumberland OUT OF COUNTY CUMBERLAND ADVlWCE FEE PAID BY ATrY ~..# ,';'/: ~::~~,'7" ",~-- ~ ' NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff leVYing upon or attaching any property under within writ may leave same Without a watchman, in custody of whomever IS found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plalntlff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 9< TYPE NAME AND ADDRESS of ATTORNEY/ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED Kenneth C. Sandoe, Esq. 36 W. Main Ave., Mverstown, PA 17067 (717) 866-5737 5/26/00 12, SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). 14, Date Received 6/16/00 15. Expiration/Hearing Date 6/26/00 13. I acknowledge receipt of the writ or complaint as indicated above. 16. HOW SERVED: PERSONAL ( ) POEt ) SHERIFF'S OFF ( ) OTHER ( ) SEE REMARKS 22. REMARKS: m 41. AFARMED and subscri~_~ ~9 b~fore -me thiS 22nd 44. Signature of h riff 45. Signature of Yor County Sheriff 42.da for William M. Hose 46. SIgnature at Foreign Coun Sheriff RN SIGNATURE 6 22 00 49. Date 43. 51. Date Received 1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY. Sheriffs Office 4. BLUE ~ Sheriff's Office ~ ". "' "RECEiVED" OFFICE OF SHERIFF YORK, PA '00 ,!UN 16 Prl12 52 I~" 10: ~fU:~ ~ ~."'ijm4Jl!!fjJli~fIi!I~_~~~ .._~~.~""",,..I'l!~,"~~, ,~j~"ffi;film~~ii;!QII'N:i,*"F\'i'!i?',"!'T,,'~ii1i~,)\iF.~A:W~i\~~~,i\i;:lifii;;~"if"'!~*ijJ~JIllf!i", ,-~~ .,J, ~ ~ COUNTY OF YORK OFFICE OF THE S'HE'RIFF - -~ - 2tEAST MARKET ST., VORK, PA 17401 "i.. -.- ,_.. - . ~- ;;. '," SERVICE CALL (717) 771-9601 t" 'fcc,; SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN INSTRUCTIONS PLEASE TYPE ONLY LINES 1 TO 12 DO NOT DETACH ANY COPIES. 1. PLAINTIFEi'_ Melissa E. 3, DE DAN_TIS! Joseph A. Ga~~Bn SERVE 5. NAME OF INDIVIDUAL, COMPANY, Cb~I'-- . Joseph A. Carman 6. ADDRESS {STREET OR RFD WITH BOX NUMBER, APT NO., CITY, BORO. 1Wf"., STATE AND ZIP CODE AT 659 E. Walnut St, Hanover, PA 7. INDICATE SERVICE: 0 PERSONAL 0 PERSON IN CHARGE )b DEPUTlzi:'um!:o-.cERT>MAI( 0 1ST CLASS MAIL o-POSTED 0 OTHER NOW Eo! 14 lOa 1!l_I,l;lHE;BIFf ()F;YQlif(c()I,IND',J~.AJc:loherebydeputlze the sheriff of Vnrk,., _ _ ,,:, "', '-_< ~",COi.JNTYtoexecutethl~Writandmakereturnthereo1according .' . - . ' ,.' ~- - - ' ....,-. r--'. " .. to law. T~J~ deputation being made at the request and risk of the plaintiff. - SHERIFF OF ~,,~ COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMA1]ON THAT WilL ASSIST IN EXPEDITING SERVICE: Brightbill. McHale 2. COURT NUMBER :~ -< 4. TYPE OF WRIT OR COMPLAINT Noti-ceH& Complaint ~ OPER -, '7"~ Cumberlan:J OUT OF COlJNTY CtlMBERLI\ND AIJ1JmQ; FEE PJlJD BY 'KIT"i NOTE 'ONLY APPLICABLE ON WRIT OF EXECUTION: N.S. WAIVER OF WATcHMAN ~ Any deputy sheriff levyIng up0l1-6r'-attachlng any property under within w!jt may leave same without a walchman, In custody of whomever Is foundJn possessIon, after notifying person of leVy or attachment. without liability on the part 'Of such deputy or the sheriff to any plaintiff herein .for any loss. destruction. or removal of any property before sheriff's sale thereo~. - . . - 9. TYPE NAM~ AND ADDRESS of ATTORNEY/ORIGINATOR and SIGNATURE ,_ 10. TELEPHONE NUMBER 11. DATE'FILED-_ Kenneth C. Sandoe, Esq. ~___ _u-_ c- '"'-=-'- ._~--' , 36 W~' "'_~i.n Ave. erstr::lWn, PA- 17067 _n -- (717) 866-5737 5/26/00 12. SEND NOTICE OF SERVICE COPY TO 'NAME A.~.AOORESS BELOW; (This area must be comj:lleted i~ notir.;e !s lobe ma[l~d). 13. I aC,knowle.dge receipt of the writ or complaint as indicated above. , J. I.udllio;Jg RESIDENCE)~ } THIS LI E t5. Expiration/Hearing Date 5i26/00 ,:ii-,-:- 11, CUrrt>etland Counq Sheriff "~SPACE BI;LOWFQR lIS.r:, Oi=T!:!E$HEI'lIF:F: ONf,.Y - DO NOT WRITE BEL SIGNATURE Ol= AU HORIZEO CLeRK 16. HOW SERVED: PERSONAL ( ) PUSTED ( ) POE ( ) SHEAIFPS OF:F ( ) OTHER ( ) ----~ .SEE REMARKS _~ (See remarks below.) 19, Date of Service 20. Time ot SerVice / ,/. /. -, 1/ () ;, (...'., 'v:. -" "../ , Time' Miles, Int. I ' ,,;~, 22. REMARKS: ~ " .~,.- ~ ~ tR . . 1>,- -~o , , , - , .... "-~'" - ,." . 41.AFFIAMEtf~d ~~~~ibed 19 .b~!.~r~ 'm~ this } -" ,:~,," .".. 1,t . '"'~Jl'h<::" --~-,' -...... 42. day of ....,u-.:;.; _, ,,~,'_~ 0 22nd 44. Signature ?f (~J 45. Signature of Yo.rk County Sheriff , .........;-...........--.......... 47.~~~,~ v, 48. Date V" 43. . ~nr Wi 11 ~am .M , Proi~ol}O~ry1totary P 46. ignature of orelgn MY I .... _ 41' -.I--,? Coun Sheriff 50,1 ACKNOWtE "~ECGIPT FIHE SHERIFF'S REtURN S'GNATURE OF AUTHORIZED ISSOffllG AUTHORITY AND TiTlE __ 1. WHITE - ISSuing Authority 2. PINK. Attorney 3. CANARY ~ She.riff's Offlce-- 4.'8l(JE-:~Sh~r[",s_OffFce 5 "? I 49. Date 51.Date Received --. ...-~~, - - "'--~- ~ " - . -~, 'c ...w.......J "' ", 'ii[; MELISSA E. BRIGHTBILL McHALE, Plaintiff l~rf!)~~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000-3285 CIVIL xmc JOSEPH A. GARMAN, Defendant JURY TRIAL DEMANDED RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS 'I ;! 'I f! ii n il Ii TO TIffi HONORABLE, THE JUDGES OF SAID COURT: Kenneth C. Sandoe, Esquire ,counsel for the plaintiff/~n the above action (liIIl'llX:1Ii:0IIS), respectfully represents that: I. The above-captioned action((J[:aotioJl~' is (DeJat issue. 2. Theclaimoftheplaintiffintheactionis$ within arbitration limits. The counterclaim of the defendant in the action is n / a ;1 " The following attorneys are interested in the case(s) as counselor are otherwise disqualified to sit as arbitrators: David J. Fr~ed, Esquire, Attorney for Joseph A. Garman, Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, /{~ ORDER OF COURT .-t9~ in consideration of the ESq.,~~_~' , Esq., are appointed arbitrators in the above captioned action (or Esq., and actions) as prayed for. PJ. ! F1LED-QFF1CE l'" "f ". c"r"' 'n"OT''''{ w '~'O,::-: ~"'i",'" n ;h,-~\j flrl 00 DEe -6 PM 2: 20 CUMBERLAND COUNTY PENNSYLVANIA >- Q() Cr:: ~ is lC) 02,0 N >-- 0,2 0::5: n:C, ::It: o~ a :...L.._:C "- ()~'~ a:';: @~? to z~ ~~I' I ~f!? <\, \}'-.... LL. ....,,_1 (...1 w-dj ~ "- l~: r..w ~ ~ 0 can;: ~ t,!_ 0 ~ -.... 0 0 a -J <J Q C'l " 0 ~ ~ 0,- ~ - , !cll1I!W'!l"" _ ~ '?~-"'l="'~ ,"IIlI!i!l!SI'\!I"7_~"" "~~"~~~~~,~"'~o.,,..,~~~~~~III__: ~~ i!o1;'m_.- . J _, "-', , , Melissa E. Brightbill McHale, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA vs. : NO. 2000-3285 : CIVIL ACTION AT LAW Joseph A. Garman, Defendant : JURY TRIAL DEMANDED NOTICE OF HEARING TO: Kenneth C. Sandoe, Esquire 36W.MainAve. Myerstown, P A 17067 David 1. Freed, Esquire 301 Market Street - 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 Stephen Bloom, Esquire 2100 Longs Gap Road Carlisle, P A 17013 Maria P. Cognetti, Esquire 210 Grandview Ave. Suite 102 Camp Hill, PA 17011 And now this 16th day of January, 2001, you are hereby notified that the Arbitrators appointed in the above captioned matter will hold a hearing for the purpose of their appointment as follows: Date: Tuesday, March 27,2001 Time: 1:30 o'clock p.m. Place: Conference Room, Maria P. Cognetti, Esquire, 210 Grandview Ave. Suite 102, Camp Hill, P A Counsel shall immediately notify all arbitrators if settlement is reached prior to the hearing. Anyone who fmds the hearing date unsuitable is responsible for making all arrangements with counsel and the arbitrators for a suitable date, time and place. Parties wishing to argue legal points will be expected to have copies of relevant materials for each arbitrator and opposing counsel at the commencement of the hearing. COYNE & COYNE, P.e. Henry F. Co e, Esquire 3901 Marke Street Camp Hill, PA 17011-4227 (717) 737-0464 cc: Court Administrator Prothonotary's Bulletin Board ~ , '-- ~., ., '"'_~'~,,,,,~",,-_-;,,,,c:.ci:,;.'i--,,_,~'\.,"c<,...,,,~,",",,,,,",,",~~,,,,,,.,;w,"~",,i<;~"j"J.,~~,-"",--,L,~,=",,'l, .._""___,,-,,,,"__~ ~ '.!,~~"',-h""."o ',,,,,,--::,",,,',"'~' .', .i MARIA Po COGNETTI & ASSOCIATES Attorneys and Counselors at Law Practice Limited to Matrimonial Law Maria P. Cognetti · Attorney at Law ,.t': Miehaele D. Alcaro Attorney at Law *Fellow-American Academy of Matrimonial Lawyers J\<IAR ) /j Karen A. Sheriff Paralegal .,.,,~--'""'~ March 12, 200/.-"~~ ~ f-t \\~> /7 Kenneth C. Sandoe, Esquire 36 W. Main Avenue Myerstown, P A 17067 , " '.1 -~;L...:- , I ~.....f RE: l\-O'~"l' ('Iv/>- (rr 1J~ ~... -cfi. \0... ._,_.__._.r=;::: David J. Fre , Esquire ar "'et Street - 9th Floor ./J ~~8j-" P.O. Box 865 Harrisburg, PA 17108-0865 _. .~tephen Bloom, Esquire fYlAYJV'v 2100 Longs Gap Road Carlisle, P A 17013 Henry F. Coyne, Esquire ~ 3901 Market Street Camp Hill, PA 17011-4227 Melissa E. Brightbill McHale v. Joseph A. Garman Cumberland County C.C.P. Docket No. 2000-3285 Q frN- ~~.wv F~-'4x ~-~ /M..t. T~ ~ UP, -referenced arbitration has been rescheduled as Dear Parties: Due to a scheduling conflict that I have, the ab follows: ~ Date: Tuesday, May 8, 2001 II , ~ Time: 9:00 o'clock a.m. k \1"1. Place: Conference Room, Maria P. Cognetti, Esquire, 210 Grandview Avenue, Suite 102, Camp Hill, PA My office confirmed the availability of this date with each of your secretaries. Anyone who fmds the hearing date unsuitable is responsible for making all arrangements with counsel and the arbitrators for a suitable date, time and place. M truly you Maria P. C , ~t~ 'Cl -.SJ "" \ rD Thank you for your cooperation in the rescheduling of this matter. MPC/lar cc: Court Administrator Prothonotary's Bulletin Board 210 Grandview Avenue, Suite 102 . Camp Hill, P A t70 II Telephone (717) 909-4060 . Fax (717) 909-4068 E-mail CognettiLaw@aol.com d*i3tf;tJ,f~",'1jM.'ll~~r'4':W~'i.l'Itl : J'. Jimit"i-'1;';f<l/;\~'l<iilit'~1<!.-ffi1ir-;;':~~~.' -"ii<';I1ft$~"""'f.1%;mJm;$lr,.,;'\qh7,",~~i""~,'.l.""w...;"..''':;,"t~-'''''''''''''''''F..t!'":z,:"_,,,''''-''''''''''..,,,,..,,,,,'~'~ ~~~ ,,-~"~ ~ -"-~'" J', ~ 0)8ne:Jl-e' ~ Z.(,tI[f~a-H'1- ~ f~'p~-k LJ) (U) La ~ 'f-h..vu- 5)8 - q:OO Am ---- " - - , '-W.,_ '';''-~'' ' ,,,,,' '. c", , ''>, ,.0;..,;-.,,> ~ ',~,,' ,-,~~ <>,">~"j '-"f;;;;"-~'~"'';'' "'"",~~,m~"'".i'~;~,'~l,;";',,,'.~..,,~', .-,,,,,,,-,.:, -'v', ".' ';''-j '" MELISSA E.BRIGHTBILL McHALE, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-3285 CIVIL ACTION -AT LAW JOSEPH A.GARMAN, DEFENDANT JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Joseph A. Garman, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER By: .b~~ David J. Freed, Esquire Atty. 1.0.#76622 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 , .1 ,'~"::.--'--", ""'--'~~{'~'~-'-<'~::-'.- ..'". ,~' ,";-__;"'...,;,"",_~,_ ",c. ..,. . .. CERTIFICATE OF SERVICE AND NOW, this 29th day of June, 2000, I hereby certify that I have served the foregoing Praecipe entering my appearance on the following via first-class mail, postage prepaid, addressed to: Kenneth C. Sandoe, Esquire 36 West Main Avenue Myerstown, PA 17067 ~- '.~ ~. David J. Freed, Esquire Dated: 6/29/00 MELISSA E. BRIGHTBILL McHALE Plaintiff vs. JOSEPH A. GARMAN, Defendant , , " ;"'"e,_, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 2000-3285 CIVIL TERM JURY TRIAL DEMANDED PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY: Please mark discontinued. By: Dated: June 14th, 2001 the above-captioned settled and case & COOPER Ke e.h ID# 25%:16 Attorney for Plaintiff 36 W. Main Avenue Myerstown, PA 17067 _c~"~ ""'lliIlliiIliI = ~ " ~, ~~ ~1~l=~-lIIiiloiililmll~~m~tllllbl!il. r""~ -~ ."' -- - U . ~ ~ ,~ ".,.'".< " o c: :2'"" -0 tr; rnrn Z::[I ZC C!J ~7: ,<e PC--, ZCJ )>r :::::; ::::. -< ~ ~ o o -n ,- c:: ::t:: .-' (.fi '-"~:~~ fs , , "-;:,,\() --1', ,;,:"~~~ ;':-');11 ~, --, ):.>- ::JJ -< -0 ':.31 ():) r:,! ,.. . .-.. "', 'j(: Melissa E. Brightbill McHale Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 2000-3285 CIVIL TERM : Jury Trial Demanded Joseph A. Garman, Defendant ,j OATH We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the ~nits Sta~ and the Constitution of this Commonwealth and that we will discharge the duties of our ~fficC'With lJi!lelity. i~ ....s :::::><( Lt.J~: N 07 ~c~, :;:: ()<( J-t'":::.. C- ::::J~ ~~J: Cf '~~ ff:..t. >- i-dUJ i!: ~CL \.c. 5 C) ~:::::> () :&.0# . "'''''' . z...,( . AWARD We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) ~lJ,A/ & J.N1-.J ..{~';. fJ/lHW- tf ~ J,f9J.Je..;'W ,~ ~ iO.J!~ r clJJ~ --AM .AiAt ~tI ~ / J SS'z. .7 Date ofHearing: -8-.8< JI'h,,'tJ.e r Date of Award: ,f!j- K ~ I NOTICE OF ENTRY OF AWARD , Now, the ~ day of Y1f~ ,2001, at ;2:.;)/ f..m., the above award was entered upon the docket and notice thereof iven by mati to the parties or their attorneys. $ OJ9tJ . O?J /$1 &uZ' /: Prothonotary BY:Depu~/~ ~ ,c-: ;t,~, W- Arbitrators' compensation to be paid upon appeal: f"''''''''' '~'n;g~~di~loj&!;~",,"'~Ill;,'" ,,- ~,_ iofiO~..l!m!I~~li<i\!H"'~"".c""";;"--,.J"],h~i:,,.,,,",,,,- <'I '0"" _, ",_"",,_ ;,""..."Jlti.La'~!lIW'",~l.~~,*,~'\1~&'>l;\\ ;\lIff01liilioj~ ,r ~llo.,i~iililll!l:&iIi'il~'_I\Oj;j..i:m,_~:;,jlJM-.ll_"~'"'. ' '- " - """""~~~ I 41#1 tw~~~~'~ d~1~ ~ 4s~ 'ra;~ ~ ~ t,f:zo/O/ }~ JJ2. (1.,....- ~CL~, I ~ /JI~~ ~.o_ ,,~ 0' ~,,",",.,.,,"~, , ,,., ~,~I"" " ",.~~,~ ,'" ",~ ,