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Home My WebLink About07-0615' 4k Sahbaz Becinovic and Bado Becinovic , Plaintiffs VS. Teresa Ledger-Musser Defendant PRAECIPE FOR WRIT OF SUMMONS To: Cumberland County Prothonotary: Please issue a Writ of Summons in the above captioned matter against Teresa Ledger-Musser, Defendant in the above captioned matter. Teresa Ledger-Musser 130 Walnut St. Lemoyne, PA 17043 Date: I_Z?_01 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - to 15 CIVIL - LAW Mark F. Bayley, Esquire BAYLEY & MANGAN 57 W. Pomfret St. Carlisle, PA 17013 ID # 87663 Attorney for Plaintiffs r Sahbaz Becinovic and Bar o Becinovic, Plaintiffs VS. Teresa Ledger-Musser Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 CIVIL - LAW WRIT OF SUMMONS To: Teresa Ledger-Musser 130 Walnut St. Lemoyne, PA 17043 You are hereby notified that Sahbaz Becinovic and Barjo Becinovic, by and through their attorney, Mark F. Bayley, Esquire, have commenced an action against you in connection with an automobile accident which occurred on or around February 5, 2005. Date: 131 &007 ?s 1 e• , Prothonotary By: Lebo- (Deputy) Seal of the Court r r Bayley & Mangan ATTORNEYS AT LAW 57 West Pomfret Street Carlisle, Pa 17013 Mark F. Bayley, Esquire John J. Mangan, III, Esquire Jacqueline Ege, Legal Assistant January 29, 2007 To the Sheriff of Cumberland County: Telephone: (717) 241-2446 Fax: (717) 241-2456 Please serve the enclosed Writs of Summons upon the following Defendant at the address indicated: Teresa Ledger-Musser 130 Walnut St. Lemoyne, PA 17043 Enclosed is our check in the amount of $100.00 to cover your service costs. Sincerely, Mark F. Bayley, Esquire MFB/j ge Enclosure v ? r `n _ 14 = I7? O (y 0 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAHBAZ BECINOVIO and BARJO BECINOVIO, Plaintiffs, CIVIL DIVISION NO. 07-615 V. TERESA LEDGER-MUSSER, Defendant. PRAECIPE FOR APPEARANCE (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, L.L.P. Firm #911 1017 Mumma Road, Suite 300 Lemoyne, PA 17043 (717) 901-5916 #15274 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAHBAZ BECINOVIO and CIVIL DIVISION BARJO BECINOVIO, Plaintiffs, NO. 07-615 v. TERESA LEDGER-MUSSER, Defendant. (Jury Trial Demanded) PRAECIPE FOR APPEARANCE TO: THE PROTHONOTARY Kindly enter the Appearance of the undersigned, Kevin D. Rauch, Esquire, of the law firm of Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P., on behalf of the Defendant, Teresa Ledger-Musser, in the above case. JURY TRIAL DEMANDED Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. By: vin D. Rauch, Esqui unsel for Defendant r CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR APPEARANCE has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 15TH day of February, 2007. Mark F. Bayley, Esquire Bayley & Mangan 57 W. Pomfret Street Carlisle, PA 17013 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & AKEEL, L.L.P. By: Kovin D. Rauch, Esquire Counsel for Defendant C) ? o O A r. ..._ rn ?T ? r - • rn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAHBAZ BECINOVIO and BARJO BECINOVIO, Plaintiffs, CIVIL DIVISION NO. 07-615 V. TERESA LEDGER-MUSSER, Defendant. PRAECIPE FOR RULE TO FILE COMPLAINT (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, L.L.P. Firm #911 1017 Mumma Road, Suite 300 Lemoyne, PA 17043 (717) 901-5916 #15274 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAHBAZ BECINOVIO and CIVIL DIVISION BARJO BECINOVIO, Plaintiffs, NO. 07-615 V. (Jury Trial Demanded) TERESA LEDGER-MUSSER, Defendant. PRAECIPE FOR RULE TO FILE COMPLAINT TO: The Prothonotary Kindly rule the Plaintiffs, Sahbaz Becinovio and Bado Becinovio, to file a Complaint in Civil Action within twenty (20) days. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE &,$KEEL, L.L.P. By: C.! e ' auch, Esquire ounsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR RULE TO FILE COMPLAINT has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 15th day of February, 2007. Mark F. Bayley, Esquire Bayley & Mangan 57 W. Pomfret Street Carlisle, PA 17013 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. By. jf? A n D. Rauch, Esquire nsel for Defendant Q G J , '71 s> r? cv IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAHBAZ BECINOVIO and CIVIL DIVISION BARJO BECINOVIO, Plaintiffs, NO. 07-615 V. TERESA LEDGER-MUSSER, Defendant. (Jury Trial Demanded) RULE AND NOW, this day of 2007, upon consideration of Defendant's Praecipe for Rule to File a Complaint, a Rule is hereby granted upon Plaintiffs to file a Complaint within twenty (20) days of service, or suffer judgment Non Pros. Rule issued this day of , 2007. //2" P onot Sahbaz Becinovic and Barjo Becinovic, Plaintiffs VS. Teresa Ledger-Musser Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-615 CIVIL - LAW CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 400912 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 Sahbaz Becirovic (Becinovic) certifies that: (1) Counsel for Defendant, Kevin Rauch, Esquire, has indicated that he is agreeable with the attached subpoena being served at this time, (2) a copy of the Notice of Intent, including the proposed subpoena, is attached to this certificate, (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to the Notice of Intent to serve the subpoena. Date: - -?? ? )?-A ark F. Bayley, Esquire" N_ ..,.A ?` T ---.5 ? i....? -Tj C ?S -_ N ??i57 ?? ._? t.?'S :a7 ^ aI Sahbaz Becirovic and Bajro Becirovic, Plaintiffs V. Teresa Ledger-Musser Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 615 CIVIL - LAW PRAECIPE TO AMEND CAPTION To: Cumberland County Prothonotary: The parties are in agreement to amend the caption as set forth above. Amendments include: "Becinovic" to "Becirovic" and "Barjo" to "Bajro." Date: Marx r. Bayley, Esquire BAYLEY & MANGAN 57 W. Pomfret St. Carlisle, PA 17013 ID # 87663 Attorney for Plaintiffs 0 Sahbaz Becirovic and Bajro Becirovic, Plaintiffs V. Teresa Ledger-Musser Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 615 CIVIL - LAW CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Plaintiffs do hereby certify that I this day served a copy of the within Praecipe upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Kevin D. Rauch, Esquire Summers, McDonnell, Hudock, Guthrie & Skeel, LLP 1017 Mumma Road Lemoyne, PA 17043 Dated: / v O Mark F. Bayley, Esquire Attorney for Plaintiffs ?. `"?' tx ? ? 1 ? i? '?"?? ` ? ', t _ -? -' f"-, _-J ?- ;?; . 'j ;V ?? s _? ti Sahbaz Becirovic and Bajro Becirovic, IN THE COURT OF COMMON PLEAS Plaintiffs OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07 - 615 Teresa Ledger-Musser Defendant CIVIL - LAW NOTICE TO DEFEND 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Sahbaz Becirovic and Bajro Becirovic, Plaintiffs V. Teresa Ledger-Musser Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 615 CIVIL - LAW COMPLAINT 1. Plaintiff, Sahbaz Becirovic, is an adult individual residing at 1909 Esther Drive, Carlisle, Pennsylvania. 2. Plaintiff, Bajro Becirovic, is an adult individual residing at 132 Lakeview Drive, Carlisle, Pennsylvania. 3. Defendant, Teresa Ledger-Musser, is an adult individual residing at 140 Walnut Street, Lemoyne, Pennsylvania. 4. On or about February 5, 2005, Bajro Becirovic was operating his vehicle traveling west on Ritner Highway near the intersection of Shearer Drive in Cumberland County, Pennsylvania. 5. Sahbaz Becirovic, Bajro's brother, was riding in the passenger seat. 6. At the same time, Teresa Ledger-Musser was operating her vehicle eastbound on Ritner Highway and was stopped at the traffic light at the intersection of Ritner Highway and Shearer Drive intending to turn left onto Shearer Drive. 7. Bajro continued westbound through a green signal at said intersection exercising his right-of-way. 8. As Bajro's vehicle traveled through the intersection, Ms. Ledger-Musser attempted to execute her left turn causing a collision between the two vehicles. 9. The impact occurred as a direct and proximate result of the defendant's negligence. 10. The defendant was negligent in, including but not limited to, the following respects: a) failing to maintain a proper lookout; b) failing to drive within the assured clear distance ahead; C) failing to operate her vehicle in a safe and prudent manner; d) failing to stop her vehicle before she collided with the plaintiff; and e) failing to obey traffic control devices and yield the right-of-way. COUNT 1- Sahbaz Becirovic v. Teresa Ledger-Musser 11. The previous paragraphs are incorporated herein. 12. As a direct and proximate result of the negligence of the defendant the plaintiff, Sahbaz Becirovic, was injured. His injuries, and / or aggravation of possible pre-existing conditions(s), include but are not limited to: a) injury to his sternum and chest area and supporting structures; b) injury to his right shoulder area and supporting structures; and c) injury to his neck area and supporting structures. 13. As a result of his injuries, plaintiff has incurred medical expenses in the past and may continue to incur the same in the future in amounts that may not be covered by the Pennsylvania Motor Vehicle Financial Responsibility Act. 14. As a result of his injuries, plaintiff has incurred and presently incurs pain and suffering and may incur the same in the future. 15. As a result of his injuries, plaintiff has incurred and presently incurs aggravation, inconvenience, disability, and a loss of life's pleasures, and may continue to incur the same in the future. 16. As a result of his injuries the plaintiff lost wages and plaintiffs economic horizons may be limited. WHEREFORE, it is prayed that judgment be entered in favor of the plaintiff and against the defendant in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. COUNT 2 - Bairo Becirovic v. Teresa Ledger-Musser 17. The previous paragraphs are incorporated herein. 18. As a direct and proximate result of the negligence of the defendant the plaintiff, Bajro Becirovic, was injured. His injuries, and / or aggravation of possible pre-existing conditions(s), include but are not limited to: a) injury to his left arm including his left wrist, hand, shoulder and supporting structures; b) injury to his neck area and supporting structures; C) injury to his head; d) injury to his chest area and supporting structures; and e) injury to his back. 19. As a result of his injuries, plaintiff has incurred medical expenses in the past and may continue to incur the same in the future in amounts that may not be covered by the Pennsylvania Motor Vehicle Financial Responsibility Act. 20. As a result of his injuries, plaintiff has incurred and presently incurs pain and suffering and may incur the same in the future. 21. As a result of his injuries, plaintiff has incurred and presently incurs aggravation, inconvenience, disability, and a loss of life's pleasures, and may continue to incur the same in the future. 22. As a result of his injuries the plaintiff lost wages and plaintiffs economic horizons may be limited. WHEREFORE, it is prayed that judgment be entered in favor of the plaintiff and against the defendant in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. Date: -C) I- n Respectfully submitted, Mark F. Bayley, Esquire 57 West Pomfret Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID# 87663 Attorney for Plaintiffs Sahbaz Becirovic and Bajro Becirovic, Plaintiffs V. Teresa Ledger-Musser Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 615 CIVIL - LAW VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Date S- S6> -07 Sahbaz Becirovic, Plaintiff Sahbaz Becirovic and Bajro Becirovic, Plaintiffs V. Teresa Ledger-Musser Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 615 CIVIL - LAW VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Date 3^30^6)7 AA,:: r/ O° 2e-&/Iro - Bajro Becirovic, Plaintiff Sahbaz Becirovic and Bajro Becirovic, Plaintiffs V. Teresa Ledger-Musser Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 615 CIVIL - LAW CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Plaintiffs do hereby certify that I this day served a copy of the within Complaint upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Kevin D. Rauch, Esquire Summers, McDonnell, Hudock, Guthrie & Skeel, LLP 1017 Mumma Road Lemoyne, PA 17043 Dated: Mark F. Bayley, Esquire Attorney for Plaintiffs C"? ?? <? ?y ? m _..., -, -.. ?,.?:, ?, _._ _ -n ri ? LJ -?:? s_ j ? 1 r ___+.,? - - -r; __- ? -? _ ? ;;=i c?? "< SHERIFF'S RETURN - REGULAR CASE NO: 2007-00615 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BECINOVIC SAHBAZ ET AL VS LEDGER-MUSSER TERESA VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon LEDGER-MUSSER TERESA the DEFENDANT , at 1606:00 HOURS, on the 12th day of February , 2007 at 140 WALNUT STREEET LEMOYNE, PA 17043 by handing to TERESA MUSSER a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 42.24 Affidavit .00 Surcharge 10.00 R. Thomas Kline 00 70. 02/13/2007 15•01 BAYLEY & MANGAN a Sworn and Subscibed to By: before me this day Deput Sheriff of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAHBAZ BECIROVIC and BAJRO BECIROVIC, Plaintiffs, CIVIL DIVISION NO. 07-615 V. TERESA LEDGER-MUSSER, Defendant. TO: Plaintiffs You are hereby noted to file a written response to the enclosed Answer and New Matter within twenty (20) days from service hereof or a judgment may be entered against you. Ll.e? - ID j4L Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P. ANSWER AND NEW MATTER (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, L.L.P. Firm #911 1017 Mumma Road, Suite 300 Lemoyne, PA 17043 (717) 901-5916 #15274 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAHBAZ BECIROVIC and CIVIL DIVISION BAJRO BECIROVIC, Plaintiffs, NO. 07-615 V. (Jury Trial Demanded) TERESA LEDGER-MUSSER, Defendant. ANSWER AND NEW MATTER AND NOW, comes the Defendant, Teresa Ledger-Musser, by and through her counsel, Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P., and Kevin D. Rauch, Esquire, and files the following Answer and New Matter and in support thereof avers as follows: 1. After reasonable investigation, the Defendant has insufficient information as to the truth or falsity of said averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 2. After reasonable investigation, the Defendant has insufficient information as to the truth or falsity of said averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 3. Admitted. 4. After reasonable investigation, the Defendant has insufficient information as to the truth or falsity of said averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 5. After reasonable investigation, the Defendant has insufficient information as to the truth or falsity of said averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 6. Admitted in part, denied in part. It is admitted that the Defendant's vehicle was operating eastbound on Ritner Highway and was stopped at the traffic light at the intersection of Ritner Highway and Shearer Drive intending to turn left onto Shearer Drive. The remainder of the allegations in paragraph 6 are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 7. Admitted in part, denied in part. It is admitted that the Plaintiff's vehicle was traveling westbound. The remainder of the allegations in paragraph 7 are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 8. Admitted in part, denied in part. It is admitted that a collision occurred between the vehicles identified. The remainder of the allegations in paragraph 8 are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 9. Paragraph 9 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 10. Paragraph 10 and all of its subparts state legal conclusions to which no response is required. To the extent, however, that a response is deemed necessary, said averments are `denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. COUNTI SAHBAZ BECIROVIC v. TERESA LEDGER-MUSSER 11. In response to paragraph 11, the Defendant reiterates and repeats all her responses in paragraphs 1 through 10 as if fully set forth at length herein. 12. Paragraph 12 and all of its subparts state legal conclusions to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 13. Paragraph 13 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 14. Paragraph 14 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 15. Paragraph 15 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 16. Paragraph 16 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant, Teresa Ledger-Musser, respectfully requests this Honorable Court enter judgment in her favor and against the Plaintiffs with costs and prejudice imposed. COUNT II BAJRO BECIROVIC v. TERESA LEDGER-MUSSER 17. In response to paragraph 17, the Defendant reiterates and repeats all her responses in paragraphs 1 through 16 as if fully set forth at length herein. 18. Paragraph 18 and all of its subparts state legal conclusions to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 19. Paragraph 19 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 20. Paragraph 20 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 21. Paragraph 21 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant, Teresa Ledger-Musser, respectfully requests this Honorable Court enter judgment in her favor and against the Plaintiffs with costs and prejudice imposed. NEW MATTER 22. The motor vehicle accident in controversy is subject to the Pennsylvania Motor Vehicle Financial Responsibility Law and this Defendant asserts, as affirmative defenses, all rights, privileges and/or immunities accruing pursuant to said statute. 23. Some and/or all of Plaintiffs' claims for damages are items of economic detriment which- are or could be compensable pursuant to either the Pennsylvania Motor Vehicle Financial Responsibility Law and/or other collateral sources and same may not be duplicated in the present lawsuit. 24. To the extent that the Plaintiffs have selected the limited tort option or are deemed to have selected the limited tort option then this Defendant sets forth the relevant provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law as a bar to the Plaintiffs' ability to recover non-economic damages. 25. This Defendant pleads any and all applicable statutes of limitation under Pennsylvania Law as a complete or partial bar to any recovery by Plaintiff in this action. WHEREFORE, Defendant, Teresa Ledger-Musser, respectfully requests this Honorable Court enter judgment in her favor and against the Plaintiffs with costs and prejudice imposed. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. f l By.- Kevin D. Rauch, Esquire Counsel for Defendant VERIFICATION Defendant verifies that she is the Defendant in the foregoing action; that the foregoing ANSWER AND NEW MATTER is based upon information which she has furnished to her counsel and information which has been gathered by her counsel in the preparation of the lawsuit. The language of the ANSWER AND NEW MATTER is that of counsel and not of the Defendant. Defendant has read the ANSWER AND NEW MATTER and to the extent that the ANSWER AND NEW MATTER is based upon information which she has given to her counsel, it is true and correct to the best of her knowledge, information and belief. To the extent that the content of the ANSWER AND NEW MATTER is that of counsel, she has relied upon counsel in making this Affidavit. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Date: 9 /i 3 /o '7 &?a4? -d Teresa Ledger- sser 015274 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing ANSWER AND NEW MATTER has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 18th day of September, 2007. Mark F. Bayley, Esquire Bayley & Mangan 57 W. Pomfret Street Carlisle, PA 17013 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. By: - -?M OTC, -.A-- Kevin D. Rauch, Esquire Counsel for Defendant Ca C a 0 -rt ? cn l f u F C r -- V N ?! w 6- Sahbaz Becirovic and Bajro Becirovic, IN THE COURT OF COMMON PLEAS Plaintiffs OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07 - 615 Teresa Ledger-Musser Defendant CIVIL - LAW PLAINTIFFS' ANSWER TO DEFENDANT'S NEW MATTER 22. This averment is legal conclusion and is denied. 23. This averment is legal conclusion and is denied. 24. This averment is legal conclusion and is denied. 25. Denied. By way of further answer Defendant fails to aver any applicable statute of limitations that would hinder Plaintiffs' claims. WHEREFORE, Plaintiffs respectfully regUest this Honorable Court to enter judgment in their favor. Date: 0 ?, z L ., Respectfully submitted, BA EY & GAN 're Mark F. Bayley, E:et 17 West South Str Carlisle, PA 17013 (717) 241-2446 Supreme Court ID# 87663 Attorney for Plaintiffs C= { L2 t' C=) t i f C 7 -n rr, -qFn 1 r Sahbaz Becirovic and Bajro Becirovic, Plaintiffs V. Teresa Ledger-Musser Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 615 CIVIL - LAW VERIF CATION N o 0 ?`!' C F n C tU V ?D Mark F. Bayley, Esquire, states that he is the attorney for Plaintiffs in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: ? ? U - 0- Uk--/ Mark F. Bayley, Esquire Attorney for Plaintiffs r Sahbaz Becirovic and Bajro Becirovic, Plaintiffs v. Teresa Ledger-Musser Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 615 CIVIL - LAW n ? CERTIFICATE 'OF SERVICE C i?r co O .. C m? z tv ; 4 y served I, Mark F. Bayley, Esquire, attorney for Plaintiffs do hereby certify that I thi a copy of the within Plaintiffs Answer to Defendant's New Matter upon the following. sl i dZl l P li l id C a, a res van ennsy ar s e, , at depositing same in the United States mail, postage prepa as follows: Kevin D. Rauch, Esquire Summers, McDonnell, Hudock, Guthrie, & Skeel 1017 Mumma Road Lemoyne, PA 17043 Dated: ? o,--- Z ( 61 It',- ' e Mark F. Bayley, E?q ttorney for Plais A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAHBAZ BECIROVIC and BAJRO BECIROVIC, Plaintiffs, CIVIL DIVISION NO. 07-615 V. TERESA LEDGER-MUSSER, Defendant. MOTION TO COMPEL REIMBURSMENT OF IME RESCHEDULING FEE (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, L.L.P. Firm #911 1017 Mumma Road, Suite 300 Lemoyne, PA 17043 (717) 901-5916 #15274 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAHBAZ BECIROVIC and CIVIL DIVISION BAJRO BECIROVIC, Plaintiffs, NO. 07-615 V. (Jury Trial Demanded) TERESA LEDGER-MUSSER, Defendant. MOTION TO COMPEL REIMBURSMENET OF IME RESCHEDULING FEE AND NOW, comes the Defendant, Theresa Ledger-Musser, by and through her counsel, Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P., and Kevin D. Rauch, Esquire, and files the following Motion to Compel Reimbursement of IME Rescheduling Fee and in support thereof avers the following: 1. This matter arises out of a motor vehicle accident which occurred on February 5, 2005. 2. As a result of the accident, the Plaintiffs filed a Complaint sounding in negligence asserting claims for personal injuries. 3. As the Plaintiffs have placed their physical condition in controversy, the Defendant scheduled an Independent Medical Examination of Bajro Becirovic pursuant to Pennsylvania Rule of Civil Procedure 4010. 4. On June 4, 2008, Defendant's counsel informed Plaintiffs' counsel that an examination was in the process of being scheduled with Robert J. Maurer, M.D. (A true and correct copy of correspondence between the parties dated June 4, 2008, is attached hereto as Exhibit "A".) 5. Further, on July 8, 2008, Defendant's counsel informed Plaintiffs' counsel that the examination with Dr. Maurer was scheduled for Friday, August 15, 2008. (A true and correct copy of correspondence between the parties dated July 8, 2008, is attached hereto as Exhibit "B".) 6. Also contained in the July 8, 2008, letter is Dr. Maurer's cancellation and rescheduling policy which provides that 20 days prior notice must be received should a party wish to cancel or reschedule the examination. 7. At no time did the Plaintiff or Plaintiffs' counsel object to the examination or the medical examiner's rescheduling policy even though they were both aware of the possibility of being responsible for any cancellation or rescheduling fees. 8. On August 11, 2008, Defendant's counsel forwarded a letter to Plaintiffs' counsel reminding the Plaintiff of the Independent Medical Examination. (A true and correct copy of correspondence between the parties dated August 11, 2008, is attached hereto as Exhibit "C".) 9. The following day, Defendant's counsel received a phone call from Plaintiffs' counsel indicating that the Plaintiff would be unable to attend the Independent Medical Examination three days later. 10. As such, Defendant's counsel rescheduled the examination for Friday, September 26, 2008 and incurred a fee of $1,000. (A true and correct copy of the invoice of Dr. Maurer is attached hereto as Exhibit "D".) 11. On September 2, 2008, Defendant's counsel forwarded a letter to Plaintiffs' counsel requesting reimbursement of the $1,000 rescheduling fee. (A true and correct copy of correspondence between the parties dated September 2, 2008, is attached hereto as Exhibit "E".) 12. To date, the Plaintiffs' counsel has refused to reimburse Defendant's counsel. 13. Accordingly, pursuant to the Pennsylvania Rule of Civil Procedure 4019, the Defendant respectfully request this Honorable Court to enter an Order directing Plaintiffs' counsel to reimburse Defendant's counsel $1,000 for the rescheduling fee associated with the late rescheduling of Bajro Becirovic's Independent Medical Examination. 14. Public policy dictates requiring the Plaintiff to pay the $1000 rescheduling fee. If the Plaintiff is not required to pay the fee, then a plaintiff can unfairly drive up the litigation costs. 15. Counsel for Defendant certifies that he has attempted to contact with Plaintiffs' counsel as forth above to resolve this dispute. Despite such attempts by Defendant's counsel, Plaintiffs' counsel has yet to reimburse Defendant's counsel. 16. Counsel for Defendant certifies that no judge has ruled upon any other issue in the same or related matter. 17. Opposing counsel does not concur in this motion. WHEREFORE, Defendant, Theresa Ledge-Musser, respectfully requests this Honorable Court enter an Order compelling Plaintiffs' counsel to reimburse Defendant's counsel $1,000.00. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. By: 4-, % Kevin D. Rauch, Esquire Counsel for Defendant June 4, 2008 Mark F. Bayley, Esquire Bayley & Mangan 17 West South Street Carlisle, PA 17013 RE: Becirovic v. Ledger-Musser Our File No. 15274 Dear Mr. Bayley: Please be advised that I am in the process of scheduling Barjo Becirovic for an Independent Medical Examination in the above-referenced matter. This examination will take place with Robert J. Maurer, M.D., of Orthopedic Surgeons of Central Pennsylvania. At this time, Dr. Maurer is scheduling in July. As such, kindly advise me as to whether your client has any specific dates of unavailability. I look forward to hearing from you. Thank you. Very truly yours, Seth T. Black STB:Iat July 8, 2008 Mark F. Bayley, Esquire Bayley & Mangan 17 West South Street Carlisle, PA 17013 RE: Becirovic v. Ledger-Musser Our File No. 15274 Dear Mr. Bayley: Please be advised that I have scheduled the Independent Medical Examination of Barjo Becirovic in the above-referenced matter. This examination will take place on Friday, August 15, 2008, at 12:00 p.m., with Robert J. Maurer, M.D., of Orthopedic Surgeons of Central Pennsylvania, which is located at 550 North 12th Street, Lemoyne, Pennsylvania 17043. Please be advised that Dr. Maurer requires twenty (20) business days notice of any rescheduling or cancellation. Should your client fail to provide the requisite notice, you will be responsible for the penalty fees associated with the same. Finally, please be advised that Dr. Maurer requires that your client appear at his office thirty (30) minutes prior to his scheduled appointment time of 12:00 p.m. Should you have any questions or concerns regarding the above, please feel free to contact me. Thank you. Very truly yours, Seth T. Black STB:Iat August 11, 2008 Mark F. Bayley, Esquire Bayley & Mangan 17 West South Street Carlisle, PA 17013 RE: Becirovic v. Ledger-Musser Our File No. 15274 Dear Mr. Bayley: Please allow this letter to serve as a reminder of your client, Bajro Becirovic's upcoming Independent Medical Examination. This examination will take place with Robert J. Maurer, M.D., of Orthopedic Surgeons of Central Pennsylvania on Friday, August 15, 2008, at 12:00 p.m. at Dr. Maurer's offices located at 550 North 12th Street, Lemoyne, Pennsylvania 17043. Should your client fail to attend the examination, you will be responsible for the penalty fees associated with the same. Finally, please be advised that Dr. Maurer requires that your client appear at his office thirty (30) minutes prior to his scheduled appointment time of 12:00 p.m. Should you have any questions or concerns regarding the above, please feel free to contact me. Thank you. Very truly yours, Seth T. Black STB:Iat 2. 2U: : 2 7117616860 NU. GJ76 F, 2 orthopaedic Surgeons of Central Pennsylvamia, LTD. 550 N. 12th Street, Suite 140, Lemoyne, PA 17043 (717) 901-8000 Fax (717) 761-6860 Craig W. Fultz, M.D. Robert J. Maurer, M.D. Jeffrey W. Finn, M.D. Brandy M. Komykoski, PA-C STATEMENT August 12, 2008 SETH BLACK SUMMERS, MCDONNELL, HUDOCK, GUTHRIE & SKEEL 1017 MUMMA ROAD LEMOYNE, PA 17043 RE: BECIROVIC,BARJO OSCP ACCOUNT/CHART NUMBER: 119948/021923 FOR PROFESSIONAL SERVICES Fee for late cancellation of 8/15/08 IME - $1000.00 Prepayment received -1000.00 BALANCE Robert J. Maurer, MD Tax ID: 23-2936551 -0- --- Providing Quality Orthopaedic Care to Central Pennsylvania September 2, 2008 Mark F. Bayley, Esquire Bayley & Mangan 17 West South Street Carlisle, PA 17013 RE: Becirovic v. Ledger-Musser Our File No. 15274 Dear Mr. Bayley: Enclosed please find a statement dated August 12, 2008, from Orthopedic Surgeons of Pennsylvania in the above-referenced matter. As you can see, a penalty of $1,000 was incurred as a result of your client's late cancellation of his August 15, 2008, IME. As you were made aware of Dr. Maurer's IME cancellation and rescheduling policy well in advance of the examination, I respectfully request that you forward a check in the amount of $1,000 to my office for repayment of the late cancellation fee. Should you have any questions or concerns regarding the above, please feel free to contact me. Thank you. Very truly yours, Seth T. Black STB:Iat Enclosure CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing MOTION TO COMPEL REIMBURSEMENT OF IME RESCHEDULING FEE has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 22nd day of October, 2008. Mark F. Bayley, Esquire Bayley & Mangan 57 W. Pomfret Street Carlisle, PA 17013 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. B Y• Kevin D. Rauch, Esquire Counsel for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAHBAZ BECIROVIC and CIVIL DIVISION BAJRO BECIROVIC, Plaintiffs, NO. 07-615 V. TERESA LEDGER-MUSSER, Defendant. (Jury Trial Demanded) ORDER AND NOW, TO WIT, this day of , 2008, it is hereby ORDERED, ADJUDGED and DECREED that counsel for Plaintiff, Bajro Becirovic, provide counsel for Defendant, Theresa Ledger-Musser, $1,000.00 for reimbursement of the rescheduling fee for the Independent Medical Examination of Bajro Becirovic within thirty days of this order. BY THE COURT: J. Distribution to: Kevin D. Rauch, Esquire Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P. 1017 Mumma Road, Suite 300 Lemoyne, PA 17043 Mark F. Bayley, Esquire Bayley & Mangan 17 W. South Street Carlisle, PA 17013 .. ,::??J C.? is ? _ ,.. -rl t'a _? i F._t ??7?r?. E.+.? .,..y .,... t:_ f .. ../? { ^ ?"` SAHBAZ BECIROVIC and IN THE COURT OF COMMON PLEAS OF BAJRO BECIROVIC, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFFS V. TERESA LEDGER-MUSSER, DEFENDANT NO. 07-0615 CIVIL ORDER OF COURT AND NOW, this 29`h day of October, 2008, upon consideration of the Motion to Compel Reimbursement of IME Rescheduling Fee filed by the Defendant, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Plaintiffs to show cause why the relief requested should not be granted; 2. The Plaintiffs will file an answer on or before November 18, 2008; 3. If no answer to the Rule to Show cause is filed by the required date, the relief requested by Defendant shall be granted upon the Court's receipt of a Motion requesting Rule be made Absolute. If the Plaintiffs file an answer to this Rule to Show Cause, the Court will determine if further order or hearing is necessary. 4. The Prothonotary is directed to forward said Answer to this Court. By the Court, M. L. Ebert, Jr., J. Mark Bayley, Esquire Attorney for Plaintiffs Kevin Rauch, Esquire Attorney for Defendant 0 j ?pf29?0 P' bas /+ :.+? ?1?i.:lJ ?? Sahbaz Becirovic and Bajro Becirovic, Plaintiffs V. Teresa Ledger-Musser Defendant PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, NO. 07 - 615 CIVIL - LAW PLANTIFF'S ANSWER TO DEFENDANT'S MOTION TO COMPEL REIMBURSEMENT OF IME RESCHEDULING FEE PURSUANT TO RULE TO SHOW CAUSE DATED OCTOBER 29 2008 AND COUNTER-MOTION AND NOW, come Plaintiffs, by and through their attorney, Mark F. Bayley, and Answer Defendant's Motion to Compel Reimbursement of IME Rescheduling Fee as follows: Plaintiffs counsel provided at least three full days notice to reschedule the independent medical examination that had been scheduled for August 15, 2008. 2. Plaintiffs counsel rescheduled the IME in order to have an opportunity to explain what the IME was to his client along with discussing settlement issues with his client. 3. Bajro Becirovic is Bosnian and speaks little English; it is difficult for Plaintiffs counsel to quickly arrange appointments with Mr. Becirovic along with a translator. 4. When efforts by Plaintiffs counsel to arrange an appointment with Mr. Becirovic prior to August 15, 2008 failed Plaintiffs counsel immediately gave plenty of notice of his desire to reschedule. 5. The policy of Defendant's contractor, Dr. Maurer, of requiring 20 days advance notice for rescheduling is utterly unreasonable. 6. Dr. Maurer had plenty of notice to fill the August 15, 2008 slot with productive work and likely did. 7. Dr. Maurer subsequently performed an IME on Mr. Becirovic on the rescheduled date. WHEREFORE, Plaintiffs respectfully request Defendant's motion to be dismissed. COUNTER-MOTION 8. Defendant, Teresa Ledger-Musser, without any notice whatsoever, failed to appear for two scheduled depositions (on November 12, 2007 and February 5, 2008). 9. Unlike Dr. Maurer, Plaintiffs counsel wasted time waiting in vain for Ms. Ledger-Musser on these occasions. 10. Plaintiffs counsel and his staff twice spent wasted time rescheduling Defendant's deposition and re-preparing for the deposition. 11. Plaintiffs counsel believes Defendant's previous actions (which Plaintiffs counsel made no complaints about until now) are more than enough trade-off for Defendant's current gripes; in the alternative Plaintiffs counsel asks for reasonable compensation regarding his time wasted due to Ms. Ledger-Musser's failure to appear without notice. WHEREFORE, Plaintiff respectfully requests Defendant's complaint to be dismissed or, in the alternative, to award reasonable compensation for his counsel's wasted time. Respectfully submitted BAYLEY & MANGAI Mark F. Bayley, Esquir 17 West South Stre Carlisle, PA 17013 (717) 241 2446 Supreme Court I.D.#87663 VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney for Plaintiffs in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: Mark F. Bayley squire CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Plaintiffs do hereby certify that I this day served a copy of the within Plaintiffs Answer to Defendant's New Matter upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Kevin D. Rauch, Esquire Summers, McDonnell, Hudock, Guthrie, & Skeel 1017 Mumma Road Lemoyne, PA 17043 Dated. I (? b ?" Mark F. Bayley, Esquire c'3 ov C-D co rN) s : „ I ? 1 1 Sahbaz Becirovic and Bajro Becirovic, Plaintiffs V. Teresa Ledger-Musser Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 615 CIVIL - LAW ORDER OF COURT AND NOW, this day of 1?OVtw;1p?,r , 200, a Rule is hereby issued upon Defendant to show cause why the relief requested in Plaintiffs counter-motion should not be granted. Defendant shall file an answer to said Rule within days. Should Defendant fail to file an answer within said time, Defendant's Motion to Compel Reimbursement of IME Rescheduling Fee shall be dismissed. BY THE COURT: ?-?, SA, M. L. Ebert, Jr. Mark F. Bayley, Esq. / . a o S Kevin Rauch, Esq.`` t CIE A0493az 1 C A- + 71, PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in triplicate) Signed: TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: FX- for JURY trial at the next term of civil court. [] for trial without a jury. ---------------------------------------------------------------------------------------------------------------- CAPTION OF CASE (entire caption must be stated in full) (check one) X? Civil Action - Law Sahbaz Becirovic & ? Appeal from arbitration Bajro Becirovic ? (other) (Plaintiff) vs. The trial list will be called on November 2 and Teresa Ledger - Musser Trials commence on December 6, 2010 November 10, 2010 (Defendant) Pretrials will be held on VS. (Briefs are due S days before pretrials No. 615 , 2007 Term Indicate the attorney who will try case for the party who files this praecipe: John A. Lucy, Esquire Indicate trial counsel for other parties if known: Mark F. Bayley, Esquire This case is ready for trial. Date: 10/5/10 _ C ? 1 .6 s 0 ),NiF1 !N0TA17% I' T I: 0!D ri#`0?L A rCl COtlfdT Print Name: Kevin D. Rauch, Esq. Attorney for: Defendant O .-Ly9577 f ~ FILE~-Q1-~'ICc ZQiO OCT ZO P~°~ 2: [ G-.iM3El~Lr~t~~ ~Ci~~~~'~'''' PEA"P~ ~ Y~.1~'~~ ~ ~ ,~~ IN THE C URT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAHBAZ ECINOVIO and CIVIL DIVISION BARJO B CINOVIO, Plaintiffs, NO. 07-615 v. PRAECIPE FOR APPEARANCE (Jury Trial Demanded) TERESA LEDGER-MUSSER, ~ Defendant. Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 John A. Lucy, Esquire Pa. I.D. #203948 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Lemoyne, PA 17043 (717) 901-5916 #15274 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAHBAZ ECINOVIO and CIVIL DIVISION BARJO B CINOVIO, Plaintiffs, NO. 07-615 v. TERESA L~DGER-MUSSER, Defendant. (Jury Trial Demanded) PRAECIPE FOR APPEARANCE TO: TH~ PROTHONOTARY Kindly enter the Appearance of the undersigned, John A. Lucy, Esquire, of the law firm o~ Summers, McDonnell, Hudock, Guthrie & Skeel, P.C., on behalf of the Defendant, Teresa Ledger-Musser, in the above case. JURY Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE ~~K€El~. , L.L.P. .~6hn Lucy, Esquire Co el for Defendant CERTIFICATE OF SERVICE REBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR APPEARANCE has been mailed by U.S. Mail to counsel of record via first class mail, posta~e pre-paid, this 19th day of October, 2010. Mark F. Bayley, Esquire Bayley & Mangan 57 W. Pomfret Street Carlisle, PA 17013 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: John cy, Esquire n or Defendant I r FiLED-OFFICE O THE RROTHO OTAR r 2010 NOV ! 9 Ali 1 ! ? 0, rj,#HOERLAND ? 0UHT`; IN THE COURT OF 6&"WkS OF CUMBERLAND COUNTY, PENNSYLVANIA SAHBAZ BECIROVIC and CIVIL DIVISION BAJRO BECIROVIC, Plaintiffs, NO. 07-615 c v. (Jury Trial Demanded) TERESA LEDGER-MUSSER, Defendant. i PRAECIPE TO SETTLE AND DISCONTINUE TO: THE PROTHONOTARY Kindly mark the docket in this matter settled and discontinued. Respectfully submitted, BAYLEY & MANGAN By: JI-A ark F. Bayley, Counsel for Pla' i r CIVIL DIVISION NO. 07-615 CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, do hereby certify that I this day served a copy of the IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAHBAZ BECIROVIC and BAJRO BECIROVIC, Plaintiffs, v. TERESA LEDGER-MUSSER, Defendant. foregoing document upon the following by First Class U.S. Mail: Seth Black, Esquire Summers, McDonnell, Hudock, Guthrie, & Skeel 100 Sterling Parkway Suite 306 Mechanicsburg, PA 17050 ar F. Bayley, Esquire