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Home My WebLink About97-00136 \ ! I ~ "'t ~ ~ \J .;:s ~ N ~ ~ , .;) ... ~I I t'-.. ' C-- . ' ~ IN ThE COURT OF COMMlN PLEAS OF CUMrJl:RLAfo.lD CIVIL DIVISION COUNTY, PENNSYLVANIA Plaintiff(s) & Address(es): Christina Velazquez and Dean Velazquez, h/w both of 733 Public Road Bethlehem, PA 18015 vs. File No. 11}q7 - /3/'; Civil Action. Law (';"il 1'J10Y'Tn Defendant(s) & Address(es): Robert G. Hack Old Route 22 Mexico, PA 17056 Bradley W. Hack Old Route 22 Mexico, PA t7056 AND PRAECIP~ FOR SU~~ONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue sUll1l1Ons in in the above case. ,..; ui 1 ~,..t-; nn ~ x Writ of SUll1I1Ons shall Jav A. Scherline, ESQuire Schprlinp ~ A~~n(""i~~pq tll? W.11nl1t- ~t-,...PiP" nllont-n1.rn or. lAln1 Ihln) A~7_11no Name/Address/Telephone Number of Attorney Date: Supreme Court 10 Number 24673 1 /7/q7 . . . '* . SUMMONS IN CIVIL ACTION TO: Robert G. Hack and Bradley W. Hack YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTlFF(S) -/fAS1HAVE COMMENCED AN ACTION AGAINST YOU. /s/ Ih,wrenCf> E. W~lJS.!::L_, _ Prot onotary/Clerk, CiVl1 Division Date: January 9. 1997 /1 ' 'rJ/l"'f . -' i-~ r '/J'1(f.:' f - , Deputy by E-4F-l >- -. ) c; ~i ~~ .:J . UJC' C': '....( <..) ~. I; ; f(' .: ; 0"_4 <- L.b 0, u... ,. , , < ~ , ., \. c...~ ' en . ,:J ~ ~t I , I' ~ u...l i ~,j \ '" . I _. :. I;...... ~ ~ l ~_ r- ~~ (,) :..J v U ~ .~ t i ~~ ~ ~ . Christina Velazquez and Dean Velazquez, h/w, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND CO" PENNSYLVANIA v. : NO: 1997-136 Civil Term Robert G, Hack and Bradley W, Hack, : Civil Action - Law Defendants ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Defendants in the above-referenced action, Respectfully submitted, LAVERY & KAIN DATE: 112ql~1 By: Frank j, Lav P.O, Box 1245 Harrisburg, PA 17108-1245 (717) 233-6633 Atty 1.0, 42370 Attorneys for Defendants ~ CERTIFICATE OF SERVICE I, Angela Kelly, an employee of the law firm of Lavery & Kain, do hereby certify that on this Qt.tWJday of January, 1997,1 served a true and correct copy of the foregoing Entry of Appearance via U ,5. First Claes mail, postage prepaid, addressed as follows: Jay A. Scherline, Esquire Scherline & Associates 512 Walnut Street Allentown, PA 18101-2393 - -- ," ,-~ : i' ,.' "I: , " 1-: , , .J () , " l c', " I l. i....: I ,j ,.I~ , C' .. ) i ("J , I' " , " I':' I' y, ..J r , ;-. ! It (' , ll: , ,j '- 1 , , ) I " " ! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHRISTINA VELAZQUEZ and DEAN VELAZQUEZ, h/w, Plaintiffs, : No.: 1997-136 vs. : Civil Action - Law BRADLEY W. HACK and ROBERT G. HACK, Defendants. : Jury Trial Demanded 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 judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or 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 LA WYER 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, Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 ;' I )' / , /.. v-- Jay A. ,rUne, ESquire Attorn y for Plaintiffs 512 Walnut Street Allentown, PA 18101 (610) 437-1100 Attorney I.D. No.: 24673 LAW OF"fICES SCHERlINE,. ASSOC. '">- _'J' (- f',._ U-;. " r~ ~o'l .< Ul~: < t)(', :.[.: :"J :"~1 -,' \1>' 0- .-~~1 'I.'" Oi~' - : Ii) l,}! (" ~1 <; _\., 'Hi1 li'" ",:... :,lD,. C' -."# B I' f"" .. () C1' ~) "'~ o ~3 O~ Uz ~O Z~ -u .,i I' -'" , " '. - ,>", a I ::; ~ - ... ~ ~ C; .J <8- < t.::r;; olS~~~~~ ~~gs~ i$ffi;e.~ ~ ~~ ~ .;, '.'. .i'" .'."... SCHERLlNE & ASSOCIATES ATTORNEYS AT LAW 112 W^\.NUT STllEET M,\.EN'IOWN,'p^ 18101 (610) 43'1-1 UK). I",\X: (1\10) "".I~72 ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHRISTINA VELAZQUEZ and DEAN VELAZQUEZ, h/w Plaintiffs, No: 1997-136 BRADLEY W. HACK and ROBERT G, HACK, Defendants. Jury Trial Demanded vs. Civil Action - Law COMPLAINT 1. Plaintiff, Christina Velazquez, is an individual citizen of the Commonwealth of Pennsylvania currently residing at 733 Public Road, Bethlehem, Lehigh County, Pennsylvania, 2, Plaintiff, Dean Velazquez, is an individual citizen of the Commonwealth of Pennsylvania, presently residing at 733 Public Road, Bethlehem, Lehigh County, Pennsylvania. 3, At all times material hereto, Plaintiffs, Christina Velazquez and Dean Velazquez, were legally married and husband and wife. 4. Defendant, Bradley W. Hack, is an individual citizen of the Commonwealth of Pennsylvania currently residing at RD #3, Box 464, MiffIintown, Juniata County, Pennsylvania. 5. Defendant, Robert G. Hack, is an individual citizen of the Commonwealth of LAWOnlCE:!i Pennsylvania currently residing at RD #3, Box 464, Mifflintown, Juniata County, SCHER LINE & ASSOC, Pennsylvania. sprain, bilateral TMJ disorder, shock and emotional distress as well as post-traumatic stress syndrome, the full extent of which injuries is not yet known, and some or all of which may be permanent in nature, illl to her great financial detriment and loss, 12, As a further direct ilnd proximate result of the carelessness, recklessness and negligence of the Defendants as described in the foregoing paragraphs of this Complaint, Plaintiff has been or will be obligated to receive and undergo medical care and to expend various sums of money and incur expenses for the medical treatment she receives, and may continue to be obligated to continue to expend such sums and incur monetary obligations for an indefinite period of time into the future. 13. As a further direct and proximate result of the carelessness, recklessness and negligence of the Defendants as described in the foregoing paragraphs of this Complaint, Plaintiff has been prevented from performing all or substantially all of her usual and customary duties, all to her great financial detriment and loss. 14. As a further direct and proximate result of the carelessness, recklessness and negligence of the Defendants as described in the foregoing paragraphs of this Complaint, Plaintiff has sustained loss of eilrnings, earning power and earning potential and may continue in the future to suffer such losses to her detriment. WHEREFORE, Plaintiff, Christina Velazquez, demands that judgment be entered into the Defendants, and each of them, in an amount in excess of $50,000.00 plus delay damages, interest and costs of suit. ~ VS. ~ I I ' r i I I I I SHERI~~'S NfTURN - OUT nr COUNTY GM;~: NI), I'J9'1-l.?l/I\:lh P GIlMMIJNW~:AI.TH IW PENNSYI.V AN I A, CIlIINTY IJF 1:IJMIlI':RI.AND VEI.AZI.lIH:Z DEAN '.:T AI. HACK ROBERT G ET AL R. Thomas Kline . Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: HACK BRADI.EY W but was unabl~ to locate d~puttzed th~ shertff of Him tn his bai I twick. He t.herefore JIJN lATA CI)IJNTY County, Pennsylv~nia. tlJ serve t.he wi,thtn WIHT l)F" SIJMMONS On J~nu~ry :Hst, th~ attached return from 199'7 . t.his office w~s in JIJN lATA CIJIJNTY County, recei,pt of Pennsylvania. Sh~rtff'B Cost.s, Docket.ing Out of County Surcharge So ~nClWers: h.00 .00 2.00 ~-~- ~ ~ I . " /.(' H. '[ homas KIJ.ne, SherJ.f1 68.00 SCHERLINE ASSOCA1TES 01/31/1997 Sworn and subscribed to before me this ~'~, d~y of 1~1 lY C,l A.D. (-h" , c ~ - ,t ,Jf1Ei- Prot ana at~ I;": 1:18 1...=:ur1' CT \....::r;l;-;.~li r:=_";"";l ,-_",_,":':~"_'J_'-_t....'"'/I ... r=.l~;~VlV~~I= , . . CIII'iRtina Velazqupz and Dpiln V('ldZqlll.'Z h/w -:,-5. [lober-t (;. Hack 97-136 Civil Term , ~ ------r _..-- ~c. ~ow, Jan. 10, 1997 :9_ !. S:~...:.:: 0:' C~GZ:=~)_'D CO:'''')i':'Y, ?~ c:J ==-_: C:::"~= ~ ~=.::.-.:: cr Juniata C~u::.=1 :~ :.::::-.::.: -:.:.:.s ',V:::., ='; ...:_.._.;- '-.:_- -...;- ... .~- -.- -~...._-~ ..~ - .. - '''~-'' ~.:k ci ?!~=, --- -- 4/t .,:' ,. .. -,.,.,- ,'.~ '/ ,,.-:. ,v <,..',_ ~. //. ., ,/~':';">>1-.,J"-<, _ ~~ ~C"~ :::t C==::c-..::.::d C.;u::y, ?:. _~d2.-nt or S~:"1i~ ~ow, January 15, 1997 3:00 I'M ,-- ..-'-- '.[, 0..1.....:.- --- ~~ ~: wi.:..:., SUMMONS '~?=a ROBERT G. II/ICK Mexico, Walker Township, Juniata County. Pennsylvania .. =:' ;::.:,...-! ::J BRADLEY W. IIACK, son and co-defendant 3. true and attested l.-:-t ci =~ ::~.;-=--r SUMMONS ,- l::C -,,;. cow:: :::J 111M "--'"-- ....-.--.... ':..~::=:t. So :J:-'"'W:::-..... ::~.....:.::" or Juniata II. Thomas Lyter C~u::r, ::.. 5wc::. .::c =:=-r-::e: :.de:-: __ ~ ,;;I'IL "-.,.: ,-;~,""~, " -- -.... .,' / CC:H~ S2.,...j',C!. ~ (!!.:,:.AG E .. * SEE OTIIER RETURN FOR COSTS 3 ! 9;l.Z.. .J...,: : ill ..1, ''1--.:7 {IJA :/ ...1/1 , , I"ru J.( ~ j- - C'l. , - I, ' .1 .- '-' '. ---------- s , I L. J.. t ). _-J ~ , ~~f I ~ i ~ ..~ ~L ~ 0\ (I~ -- , , 'J -' ~ \ r ,..) W' , rJ.J > ~ l" CIl .~ Cl 4_ iU (d Ii.i ~'.; ~ t", "". ~J ii: .~ ~.. '..d ...J -.c ...' ~ 'C .': IlJ !J.. Z j:.: ..... f': 1.1- ~ ....( G C""a C- Orf\O w > Ii iii fa !;t ~ ~L: 0 I- . ~ =f-~ --,. I~F'~-' 8'1'I111NI 3'.J~ II 301^lJ3S 03.1.dV>l3.llV g . {; ~ ~ . . i , I I I ! I , ,J........,.,_.' ,-.;.-....,-.... _..._-,--- '. ;,"~.r~?-.';,-j-" -', '.~....' :.~;~-. . lAvery and Kain A'ITOWm AT ~w "l'.Q.B9% ,1245 1IR~PtmtsY'lvImiaI7l~~~,". .~t~~~?m~~' FaX(711)~:7.tlO3i ' "-'~,::c:.V<" ,".<_.c..,':.".:_,-- "",'" -,- ,- ..c._,..-......,...,..,' . ...-. , ' ....;._".c'_., "i,.,.-;;'" '-';cO- '-'-"""- - -- ,,-~:;;.. ; diX~~fit~I(~:j:i,:;!:;j:.~,:,::/: . I , , " >-: C) ,- 'I; CO \.; <1. ,-- g .J~ ~p .J..:... fE~ :::: j;t; <:: ');:.J ~~., . -- ~ ,f') .:,~ ';:II> l'-Z t" C,'",J ,',a 0:-' wJ ::.:(l.. r-:' u.. ~;J L' r- <5 0'\ U CERTIFICATE OF SERVICE I, Angela Kelly, an employee of the law firm of Lavery & Kain, do hereby certify that on this 'l.d'l day of Febriuary, 1997, I served a true and correct copy of the foregoing Stipulation of Counsel via D,S. First Class mail, postage prepaid, addressed as follows: Jay A. Scherline, Esquire 512 Walnut Street Allentown, PA 18101 I ~~ I :;.. ..... I N '1 i .,.. In -- (.1: If; (-- .' ~ 0-1 .....: P: -<: UJ';'-;' ,;.~ U" ;c: ('j I:E~ .:..... '\~ 0(', ". ,:i4 ~r. .1._ r:. :ii5 -- l'- ('C, 0:;'1' W ;11Q. F- u- '- t.'_ r- ::5 0 C\ U .1k \J.l1Sw('r\S26.nrw ~ , , " Christina Velazquez and Dean Velazquez, h/w, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND CO., PENNSYLVANIA v, : NO: 1997.136 Civil Term Robert G. Hack and Bradley W. Hack, : Civil Action - Law Defendants DEFENDANTS' ANSWER WITH NEW MAlTER TO PLAINTIFFS' COMPLAINT AND NOW, come Defendants, Robert G. Hack and Bradley W. Hack, by and through their attorneys, Lavery & Kain, and file this Answer with New Matter to Plaintiffs' Complaint and aver as follows: 1. Denied. After reasonable investigation, Answering Defendants are without knowledge or information sufficient to form a belief as to the truth of the averments of paragraph 1 of Plaintiffs' Complaint and the same are therefore denied with strict proof demanded, if relevant. 2, Denied, After reasonable investigation, Answering Defendants are without knowledge or information sufficient to form a belief as to the truth of the averments of paragraph 2 of Plaintiffs' Complaint and the same are therefore denied with strict proof demanded, if relevant, I, Answering Defendant Bradley W. Hack and a vehicle driven Plaintiff Christina Velazquez. It is denied that at the time of the accident Plaintiff Christina Velazquez' vehicle was stopped as alleged in this paragraph. To the extent that further answer may be deemed appropriate, the sole, direct and proximate cause of this accident was the sudden emergency created by Plaintiff Christina Velazquez' own careless, negligent and/or reckless conduct. COUNT I 9. Answering Defendants incorporate by reference the averments of paragraphs 1 through 8 of their Answer with New Matter to Plaintiffs' Complaint as if fully set forth at length herein, 10, Denied. It is specifically denied that Answering Defendants were in any way careless, reckless and/or negligent as alleged or caused any injuries or damages to Plaintiffs as alleged in paragraph 10 of Plaintiffs' Complaint. By way of further answer, Answering Defendants are advised by counsel and therefore aver that the allegations of paragraphs 10(01) through 10(g) of Plaintiffs' Complaint constitute conclusions of law to which no response is required pursuant to the Pennsylvania Rules of Civil Procedure and the same are therefore deemed to be denied. To the extent that further answer may be deemed appropriate, at all times material hereto, Answering Defendants acted 3 reasonably and appropriately and caused no injuries and/or damages to the Plaintiffs as alleged. By way of additional funher answer, pursuant to a Stipulation of Counsel, paragraph IO(g) has been stricken from Plaintiffs' Complaint. II. Denied. It is specifically denied that Answering Defendants were in any way careless, reckless and/or negligent as alleged and it is funher denied that Answering Defendants caused any injuries or damages to Plaintiffs as alleged. By way of funher answer, after reasonable investigation, Answering Defendants are without knowledge or information sufficient to form a belief as to the truth of the remaining averments of paragraph II of Plaintiffs' Complaint and the same are therefore denied with strict proof demanded, if relevant. 12. Denied. It is specifically denied that Answering Defendants were in any way careless, reckless and/or negligent as alleged and it is funher denied that Answering Defendants caused any injuries or damages to Plaintiffs as alleged. By way of funher answer, after reasonable investigation, Answering Defendants are without knowledge or information sufficient to form a belief as to the truth of the remaining averments of paragraph 12 of Plaintiffs' Complaint and the same are therefore denied with strict proof demanded, if relevant. 4 13. Denied. It is specifically denied that Answering Defendants were in any way careless, reckless and/or negligent as alleged and it is funher denied that Answering Defendants caused any injuries or damages to Plaintiffs as alleged. By way of funher answer, after reasonable investigation, Answering Defendants are without knowledge or information sufficient to form a belief as to the truth of the remaining averments of paragraph 13 of Plaintiffs' Complaint and the same are therefore denied with strict proof demanded, if relevant. 14. Denied. It is specifically denied that Answering Defendants were in any way careless, reckless and/or negligent as alleged and it is funher denied that Answering Defendants caused any injuries or damages to Plaintiffs as alleged. By way of funher answer, after reasonable investigation, Answering Defendants are without knowledge or information sufficient to form a belief as to the tnllh of the remaining averments of paragraph 14 of Plaintiffs' Complaint and the same ate therefore denied with strict proof demanded, if relevant. WHEREFORE, Defendants Roben G. Hack and Bradley W. Hack respectfully request that this Honorable Coun dismiss Plaintiffs' Complaint with prejudice and enter judgment in their favor along with the allowable costs of this action. 5 COUNT II 15. Answering Defendants incorporate by reference the averments of paragraphs I through 14 of their Answer with New Matter to Plaintiffs' Complaint as if fully set fonh at length herein. 16. Denied. It is specifically denied that Answering Defendants were in any way careless, reckless and/or negligent as alleged and it is funher denied that Answering Defendants caused any injuries or damages to Plaintiffs as alleged. By way of funher answer, after reasonable investigation, Answering Defendants are without knowledge or information sufficient to form a belief as to the truth of the remaining averments of paragraph 16 of Plaintiffs' Complaint and the same are therefore denied with strict proof demanded, if relevant. 17. Denied. It is specifically denied that Answering Defendants were in any way careless, reckless and/or negligent as alleged and it is funher denied that Answering Defendants caused any injuries or damages to Plaintiffs as alleged. By way of fun her answer, after reasonable investigation, Answering Defendants are without knowledge or information sufficient to form a belief as to the truth of the remaining averments of paragraph 17 of Plaintiffs' Complaint and the same are therefore denied with strict proof demanded, if relevant. 6 18. Denied. It is specifically denied that Answering Defendants were in any way negligent or caused any injuries or damages to Plaintiffs as alleged. By way of funher answer, after reasonable investigation, Answering Defendants are without knowledge or information sufficient to form a belief as to the truth of the remaining averments of paragraph 18 of Plaintiffs' Complaint and the same are therefore denied with strict proof demanded, if relevant. WHEREFORE, Defendants Roben G. Hack and Bradley W. Hack respectfully request that this Honorable Coun dismiss Plaintiffs' Complaint with prejudice and enter judgment in their favor along with the allowable costs of this action. NEW MATTER 1. Plaintiffs' Complaint, and each of its counts, fails to state claims or causes of action against Answering Defendants upon which relief can be granted. 2. Plaintiffs' Complaint fails to state claims or causes of action for negligent entrustment against Roben G. Hack upon which relief can be granted. 3. Plaintiffs' claims against Answering Defendants are barred against and/or limited by application of the sudden emergency doctrine. 7 I r 4. At all times material hereto, Answering Defendants acted reasonably and appropriately and caused no injuries and/or damages to the Plaintiffs. 5. Any injuries or damages sustained by the Plaintiffs, if proven, were caused by persons Complaint. and/or entities other than Answering Defendants, and beyond the control of Answering Defendants. 6. Plaintiff Christina Velazquez' negligence, careless and/or recklessness was the sole, direct and proximate cause of the motor vehicle accident described in Plaintiffs' 7. Plaintiffs' negligence was comparatively higher than Defendants' negligence, if any such negligence is found to exist, which is denied. 8. Plaintiffs' claims are barred and/or reduced proponionately by application of the Comparative Negligence Act of the Commonwealth of Pennsylvania. 9. Investigation and discovery may reveal that Plaintiffs' claims are barred and/or limited by application of the limited ton option of the Pennsylvania Motor Vehicle Financial Responsibility Act, as amended. 8 Y.ERlEICATI.QN The undersigned hereby verifies that the facts set forth in the foregoing Answer with New Mattcr are based upon information which has becn furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language of the Answer with New Matter is that of counsel and not my own. I have read the Answer with New Matter and to the extent that the Answer with New Matter is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the Answer with New Matter is that of counsel, I have relied upon my counsel in making this verification. The undersigned also understands that the state- ments therein are made subject to the penalties of 18 Pol. C.S. Section 4904, relating to unsworn falsification to authorities. Date: ~ -8 - /7 By: 13~1Ju. 'Jr4d- Bradley . Hack ..... (") , 0; Lr: ~ c~ j ~:r' C ..)I~ ~-. (~ -. ).,~ - :"."; p,: " fJ.. i.:.:::.J I _.- z.~: .:>- C"":l 'I;') L. !.;-.: ,L:. .--,. -J c.: "i~ ccH IW -.1...).. r" -. l.L. ~ l'. /- 0 C"1 .J ~ i): -. ... c l- .' , t~,: .. "'l w" - ;)~ h~f', :'I: .!~'; ~:'; -'.,:1. j-.. . n. "-1'1 ~r; 0 :~2 {, ~:~:, N l~~ ffi . f:: n 1.0- ~ ~ ,... ::J C1\ U ""II< 00 ~3 O~ Uz ~5l :7~ -=-8 e i ~c ~ .. ~ :5 <8- ~ ~=7S ..~ ~~;~ ~~ ~~OSl!!. j~ iJ ~~ < ~ II.t on . . . V B RIP I CAT ION I verify that the statements made in the foregoing is true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are made subject to the penalties of 18 Pa. C.D. 4904, relating to unsworn falsifications to authorities. ~L\~ I D,t,d, .:<k); I f i !>- . V B RIP I CAT ION I verify that the statements made in the foregoing is true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are made subject to the penalties of 18 Pa. C.D. 4904, relating to unsworn &~~ y~ I t .r I , , f falsifications to authorities. Dated: 2~/g-q 7 f I I ~, I ~ ~ ..,.. c l- z. t; N ~:)~. i)...; u.l -- ..~. ..-, ( )'6." ~ --- ..... \f.l' 0.- l'~ . _. ~r.: ..._. ,.... ,.,..[f' 0'" I '1:;': U.\" ..-" ~, ~1 {Cl 5:: I ~ . oCl ,.,'0- r -j ::5 " co i 0 0' 0 I I I CERTIFICATE OF SERVICE I, Kelly Ann Guyer, an employee of the law firm of Lavery & KOlin, do hereby certify that on this ~,.Ii'- day of January, 1998, I served a true and correct copy of the foregoing PRAECIPE TO DISCONTINUE via U.S. First Class mail, postage prepaid, addressed as follows: John W. Hallowell, Esquire Scherline & Associates 512 Walnut Street Allentown, PA 18101-2393 I. . . '" 1 - Lj; / I, -: ,!.tiLe 1M.{\" . t'''''l Kelly Ann Guyef . >- ..3' ~ rr: c "'- ..... ..... N ::)< UJQ c.., :...~ ( ) .~ -' (~...J~~ ct'.c_~ ~ " 1,1. r ~. ;: ::""J ~C t- o ~ (,; r. (\ I -;~ ~' .. ~ :,.;...: u:1.; "IJ ."1. :':/il. f.' -l .....~ l[ CO ::> Q C1\ U