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Home My WebLink About97-02055 ...0 .) . (C ~< ~ 'V) ~ ) ~ " .. ~ .~ ... ~ \I '::> v) , '. "\~. " ., i I - . . .;::) - ~ ~ <::) ~I C""- (t" , ~ MYCHAK GECKLE WELKER' THIROWAY, By: Patrick G. Geckle Attorneys at Law Identification No. 26718 11th Floor 2JO South Broad street Philadelphia, PA 19102 (215) 7J5-JJ26 p.e. Attorneys for Plaintiffs JULIE ANNE SEVERINO and TIMOTHY SEVERINO, h/w 5550 Moreland Court Mechanicsburg, PA 17055 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. OLIVIA L. STRAUB 216 South Market Street Mechanicsburg, PA 17055 ~V!,'~- ~ r;..- No. ,/'7- '"' CIVIL ACTION 1. The Plaintiffs, JULIE ANNE SEVERINO and TIMOTHY SEVERINO, are adult individuals and husband and wife residing at 5550 Moreland Court, Township of Mechanicsburg, County of Cumblerland, Commonwealth of Pennsylvania. 2. The Defendant, OLIVIA L. STRAUB, is an adult individual residing at 216 South Market street, Township of Mechanicsburg, county of Cumberland, Commonwealth of Pennsylvania. COUNT I. JULIE ANNE SEVERINO VS. OLIVIA L. STRAUB !: J. Plaintiff, JULIE ANNE SEVERINO, incorporates paragraphs 1 and 2 above as fully as though the same were hereinafter set forth at length. 4. On or about November 5, 1995, Plaintiff, JULIE ANNE SEVERINO, was a operating her motor vehicle westbound on East Simpson Street at or near the intersection with South Arch Street, Mechanicsburg, Cumberland County, Commonwealth of Pennsylvania, when suddenly and without warning the motor vehicle owned and operated by Defendant, OLIVIA L. STRAUB, attempted to turn northbound onto South Arch Street pulling out into the path of Plaintiff's motor vehicle violently striking Plaintiff's motor vehicle and causing serious injuries to Plaintiffs hereinafter referred to. 5. Solely as a result of the aforesaid accident, the wife Plaintiff suffered serious physical injuries, including without limitation, post-traumatic cervicothoracic strain and myofascial pain, somatic dysfunction, left carpal tunnel syndrome, right sacroliliac syndrome, tightness and spasms in neck, shoulder and right low back, left thumb pain, headaches, dizziness, prior to this motor vehicle accident, Plaintiff was attempting to get pregnant and due to the medication being used Plaintiff is not able to become pregnant, all of which may be permanent in nature, cause permanent disfigurement and/or loss of use of a bodily function and may have aggravated pre-existing conditions. 6. Further, Plaintiff incurred a severe shock to her nerves and nervous system, great physical pain and mental anguish and was prevented from attending to her usual 2 for an indefinite time in the near future. , ~ ' . duties, activities, and avocations all of which may continue 7. This action resulted solely from the negligence and recklessness of the Defendant herein and was due in no manner whatsoever to any act or failure to act on the part of the Plaintiffs. B. The negligence and recklessness of the Defendant consisted of the following: a. Failure to prop~rly operate and control her motor vehicle; b. Driving at an excessive rate of speed under the circumstances; c. Failure to keep a proper lookout; d. Failure to regard the point and position of Plaintiff's motor vehicle then and there being lawfully operated upon said highway; e. Failure to avoid striking Plaintiff's motor vehicle; f. Failure to keep constant vigilance of the road, traffic, weather, and road conditions; g. Violation of the statutes of the Commonwealth of Pennsylvania, as well as the Ordinances of Cumberland County 3 '>- r'. . .- c: I 'I.,i -" . ,( c.,. 1 , , . .. L j (I r:) I L' , ~. r.: -. ,- I I"J -~ :;"1- u. r- 0 . ~) C./' . ~) ~ ~~ ~,. ~ ~ - N ~ .lr, ~ j , , . ~ , I ! I fl ~ "r) ~ '- \:;- ',') i'- - ,~ C; ~~~ " " I: , i:: r-ll. ! ~ : \: '" ii "f.:!-:!;I :..1,:. . ! ~ .0...,;;1, :- n " ,,' :\ '\i! ',' iI, i . ~ I ,\ ',~' '-, :L.L~f~_.~.~ I~~~E -.;11','! 1.1., uf .' ; .'J t 111:[" !.I ;'dj!. i ';-1;," "\UII', :: ., ".1" ...... '. [I .-f.: ii-,l ,.',111 i, .11'1 .,..... .F.J. ~,'.c' r '.' '.; .~~ l,r;"i'li I iI" 1':T'--'1;,1 ;Ij: "~I,' Hi lill ',' ,1-. ., j" .r, J' \ -. I ~ .'.L'___:.~_.)_L~' ;., to. ( , , i , , I I :i , , : , , . ., , , , r, " .. ;~ : , : , , : , " I i:' .. I ; t ' ~,;! ~lL... fl'-if;:' r" I.!i I'h ,': , , I I ;'~; ~ .. : l tl. .' ,._,1 i.") '''/11.71 ~2!~.L::.!~__ ~lJ I . ; .' tt.;, ~,;j To:' ,) r " ~_';", I L.~:.; t. .--.1.:.: . !k.> ~_ 1 '" rl'- iT,' t 1 Il ., .-.. . C.:._ _If ......,. 7' /,/~~ ~ " T' l'r;,;n--::,:~~~--_._---- ;' .~l:-:d I :i':1 ....j ':lr.'I.':- t\ ~. .: .;.. ':~ 1',' l '. . ; ; . - r; ;, : oJ I~: 11.~ . ~'1 . rl " " I,"'" 'tl; "" [ ": .LEF. . ,'>'.,':\ -' I " !,J .J ., '!: ~~4.( Lf, .#~L&L.,---- /1"\:,1""1111 --- \.. )d-il-'- !C, .(1~~ I ~' ~ \ THE LAW OFFICES OF HARRINGTON, KAUFFMAN & SUlLLING ATTORNEY: Howard D. KaulTman SUPREME COURT LD. NO.: 38963 100 PINE STREET, SUITE 300 HARRISBURG, PA 17101 (717) 720-0700 ATTORNEY FOR: Olivia L. Straub JULIE ANNE SEVERINO and TIMOTIIY SEVERINO, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs VS, DOCKET NO. 97.2055.Civil OLIVIA L. STRAUB, Defendant. CERTIFICATE OF SERVICE AND NOW, this.Jl!!L day of Mav . 1997,1, Howard D. Kauffman, Esquire, attorney for Defendant, Olivia L, Straub, affirm that I served the Entry of Appearance by depositing same in the United States Mail, postage prepaid. in Harrisburg, Pennsylvania, addressed to: Patrick, G. Geckle, Esquire Mychak, Geckle, Welker & Thiroway, P.C. 11th Floor 230 South Broad Street Philadelphia, PA 19102 HowonI~ ...";~ >- '" r a.; u:' I:: ~ c:.; '.-:: lJ.I(1 ).. U. ,,;; ~ fE! a: L.- -,.-:, ~t '-'- (,., - '. I I;';: LLJI; .. ,4.j -'" :>- ll:, .", .]U.. I :l.: :;'.; II. I'- ;-~ U G1 U "- , . . mE LAW OFFICES OF HARRINGTON, KAUFFMAN & SIIILLING AITORNEY: Howard D. KaulTman SUPREME COURT LD. NO.: 38963 100 PINE STREET, SUITE 300 HARRISBURG, PA 17101 (717) 720-0700 ATIORNEY FOR: Olivia L Straub JULIE ANNE SEVERINO and TIMOTHY SEVERINO, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA Plain tilTs vs. DOCKET NO. 97-20SS-Civil OLIVIA L. STRAUB. Defendant. DEFENDANT'S PRELIMINARY oomcnoNs Motion to Strike, or in the Alternative, Motion for More Specific Plcadinl! 1. Paragraph 8 of Plain tilTs' Complaint purports to specifY the alleged negligence of Defendant in designated subparagraphs, Following the enumeration of various points of alleged negligence, Plaintiffs plead in Paragraph 8(g), (i), (k). and (I) that: l. defendant violated unnamed statutes and ordinances; 2. wantonly and recklessly disregarded the rights and safety of the Plaintiff; 3. failed to use due care under the circumstances; and 4. was negligent and reckless at law. I ~ 2. Paragraphs 8(g), (j), (k) and (I) ofthe Complaint should be stricken for lack of confonnity to Pa, R.C.P. 1019(a) or, in the alternative, PlaintilTshould be required to more lpecificaJJy allege the nature of Defendant's negligence, WHEREFORE, Defendant respectfully requests this Honorable Court to strike Paragraphs 8(g), (j), (k) and (I) of the Complaint for failure to confonn to applicable rules and law or to order PlaintilTto more specifically allege the nature of Defendant's negligence and to award costs and a reasonable attorney's fees to Defendant herein. Respectfully submitted, HARRINGTON, KAUFFMAN & SHILLING Howard . (;: I.() ,- . u'; t:?: .. , 1I ,1~. ' C"; '. , 0" :;:: If' -" n. "1""j ~~: r:" ~.' ! I ctl' ". , :.1 ., , '1.- i":" .- - .'. ~ , I', r- _+_J 0 c.." u THE LAW OFFICES OF HARRINGTON, KAUFFMAN & SHILLING ATIORNEY: Howard D. Kauffman SUPREME COURT LD. NO.: 38963 100 PINE STREET, SUITE 300 HARRISBURG, PA 17101 (717) 720-0700 ATIORNEY FOR: Olivia L. Straub JULIE ANNE SEVERINO and TIMOTHY SEVERINO, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. DOCKET NO. 97-2055-Civil OLMA L. STRAUB, Defendant. CERTIFICATE OF SERVICE AND NOW, this ] 6'11 day of May . 1997, I, Howard D. Kauffman, Esquire, attorney for Defendant, Olivia L. Straub, affinn that I served the Interrogatories Directed to Plaintiff, Set I, by depositing same in the United States Mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Patrick, G. Geckle, Esquire Mychak, Geckle, Welker & Thiroway, P.C. 11th Floor 230 South Broad Street Philadelphia, P A 19102 //'--;(0---- Howas<(D. -Kauffman, Esquire p I i I "'" '- In , -- i"-; ,,~ !::.: , ;:; Ill:' , ~f~\ h::, '- <':...1 '- ~t :'.! '" -', >- l,n 0.: ~; 0._": .:Q. ,- ;.:.: ~~ I.~ - r- e c" (..) THE LAW OFFICES OF HARRINGTON, KAUFFMAN & SHILLING ATTORNEY: Howard D. Kauffman SUPREME COURT I.D. NO.: 38963 100 PINE STREET, SUITE 300 HARRISBURG, PA 17101 (717) 720-0700 ATTORNEY FOR: Olivia L. Straub JULIE ANNE SEVERINO and TIMOTHY SEVERINO, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. DOCKET NO, 97-20SS-Civil OLIVIA L, STRAUB, Defendant. CERTIFICATE OF SERVICE AND NOW, this ] 6th day of May . 1997, I. Howard D, Kauffman, Esquire, attorney for Defendant, Olivia L. Straub, affirm that I served the Request for Production of Documents by depositing same in the United States Mail. postage prepaid. in Harrisburg, Pennsylvania, addressed to: Patrick. G. Geckle, Esquire Mychak, Geckle, Welker & Thiroway, P.C, 11th Floor 230 South Broad Street Pml~,'p~ PA/I9;?-- . /-.~ Howard D. Kauffman, Esquire r " ,. i ,. In '-1; c.: i-:~ " - ,,,f - () . i ,~ . ';'; '1._. ::... 'T': ~~ Cl U/. t'.: -. , '- ~; 'J Ci.:;! ,: '.:J4 II. r- .., w 0' :J " I . ip I. I r THE LAW OFFICES OF HARRINGTON, KAUFFMAN & SIIILLING ATTORNEY: Howard D. Kauffmnn SUPREME COURT 1.0. NO.: 38963 100 PINE STREET, SUITE 300 HARWSBURG, PA 17101 (717) 720-0700 ATTORNEY FOR: Olivia L. Straub I t JULIE ANNE SEVERINO and TIMOTHY SEVERINO, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. DOCKET NO, 97-20SS-Civil OLIVIA L. STRAUB, Defendant. ,. CERTIFICATE OF SERVICE L /G' AND NOW, this()J/lday of fAJI ~ __.1997,1, Howard 0, Kauffman, Esquire, attorney for Defendant, Olivia L. Straub, affirm that I served the Stipulation by depositing same in the United States Mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Patrick, G. Geckle, Esquire Mychak, Geckle, Welker & Thiroway, P.C. 11th Floor 230 South Broad Street Philadelphia, PA 19102 0,1 ------- / /l~ Howard D. Kauffman, Esquire ~ "S ',- C ,., \:: ".,-: Ul'~~~ (.J . t){., po' i;.. J .1. 6' " '.n .. 0'. N " u':' . . , 'i " 'W..." . . r- -' .\:- ll- r- , () 0", ;:.; THE LAW OFFICES OF HARRINGTON, KAUFFMAN & SlIILLlNG ATTORNEY: Howard D. Knuffman SUPREME COURT 1.0. NO.: 38963 100 PINE STREET, SUITE 300 HARRISBURG, PA 17101 (717) 720-0700 ATTORNEY FOR: Olivia L. Strnub i ~ JULIE ANNE SEVERINO and TIMOTHY SEVERINO, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ,I ~I Plaintiffs vs, DOCKET NO. 97-20SSoCivil OLIVIA L, STRAUB, Defendant. PRAECIPE TO THE PROTHONOTARY: Kindly mark Defendant's Preliminary Objections as withdrawn. Respectfully submitted, Harrington, Kauffman & Shilling a' ! /'~'i/Z"----' Howard ,Kauffman, Esquire Counsel For Defendant f - \: " J 'I I ,I TilE LAW OFFICES OF HARRINGTON, KAUFFMAN & SIIILLING ATTORNEY: Howard D. Kauffman SUPREME COURT 1.0. NO,: 38963 100 PINE STREET, SUITE 300 HARRISBURG, PA 17101 (717) 720-0700 ATTORNEY FOn: Olivia L. Straub JULIE ANNE SEVERINO and TIMOTHY SEVERINO, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiffs vs. DOCKET NO, 97-20SSoCivil OLIVIA L. STRAUB, Defendant. CERTIFICATE OF SERVICE AND NOW, this ~~. ~ C./' , 1997, I, Howard D, Kauffman, Esquire, attorney for Defendant, Olivia L. Straub, affirm that I scrved the Praecipe by depositing same in the Unitcd States Mail, postage prepaid, in Harrisburg, Pcnnsylvania, addressed to: Patrick, G. Gecklc, Esquire Mychak. Geckle, Welker & Thiroway, P.C, 11 th Floor 230 South Broad Street Philadelphia, PA 19102 ~;J /?J .'--- Howard'D. Kauffman, Esquire - '\ -. -... ("I C; t;:: E~ ~ luf-:; '" (.); , " r i.:~. . IL.I v... 9" c- o', ~ ..., UJ.. '" a:! . 0, j I l,_ r- :j co C;- U intersection with South Arch Street, Mcchanicsburg, Cumberland County, Pennsylvania. The collision occurred between that motor vehicle and the motor vehicle being driven by Answering Defendant u Answering Defendant was turning northbound onto South Arch Street. It is denied that the Answering Defendant acted negligently or recklessly in any manner whatsoever, On the contrary, Answering Defendant acted reasonably and prudently under the circumstances. The remaining averments ofthis paragraph contain conclusions of law to which no response is required, Further, after reasonable investigation, Answering Defendant is without sufficient information or knowledge with which to form a belief as to the truth of the remaining averments of this paragraph and they are accordingly denied, S. Denied, After reasonable investigation, Answering Defendant is without sufficient information or knowledge with which to form a belief as to the truth of the averments of this paragraph. 6. Denied. After reasonable investigation, Answering Defendant is without sufficient information or knowledge with which to form a belief as to the truth of the averments of this paragraph. 7. Denied. It is denied that Answering Defendant was negligent or reckless in any manner whatsoever. On the contrary, Answering Defendant acted reasonably and prudently under the circumstances, It is further denied that the accident did not occur in any manner whatsoever from the act or failure to act on the part of the Plaintiff. Answering Defendant incorporates its New Matter herein by reference as if more fully set forth herein at length, 2 , " .1 " 8. Denied. It is denied that the Answering Defendant was negligent or reckless in any manner whatsoever. On the contrary, Answering Defendant acted reasonably and prudently under the circumstances. (a-I), (h-i) Denied. On the contrary, Answering Defendant acted reasonably and prudently under the circumstances, (g), (i-I) Stricken by Stipulation, 9. Denied. After reasonable investigation, Answering Defendant is without sufficient information or knowledge with which to form a belief as to the truth of the averments of this paragraph, 10, Denied, After reasonable investigation, Answering Defendant is without sufficient information or knowledge with which to form a belief as to the truth of the averments of this paragraph, 11. Denied. After reasonable investigation, Answering Defendant is without sufficient information or knowledge with which to form a belief as to the truth of the averments of this paragraph, 12. Denied, After reasonable investigation, Answering Defendant is without sufficient information or knowledge with which to form a belief as to the truth of the averments of this paragraph, 13, Denied, After reasonable investigation, Answering Defendant is without sufficient information or knowledge with which to form a belief as to the truth of the averments of this paragraph. 3 WHEREFORE, Defendant denies that Plaintiff is entitled to judgment against thc Dcfcndant in the amount specified. or to any sum of money whatsoever, or to intcrcst or costs and prays that judgment bc entered in Defendant's favor and against the Plaintiff and for her costs and fecs and for such other relief as the Court deems appropriatc, DEFENDANT DEMANDS TRIAL BY JURy, COUNT n 14. Answering Defendant incorporates by reference its responses to Paragraph 1.13 as if more fully set forth herein at length. 15. Denied, After reasonable investigation, answering defendant is without sufficient information or knowledge with which to form a belief as to the truth of the averments of this paragraph. 16, Denied. It is denied that Answering Defendant was negligent in any manner whatsoever, On the contrary, Answering Defendant acted reasonably and prudently under the circumstances. Further, after reasonable investigation, Answering Defendant is without sufficient information or knowledge with which to form a belief as to the truth of the remaining averments and they are accordingly denied, 17, Denied, After reasonable investigation, Answering Defendant is without sufficient information or knowledge with which to form a belief as to the truth of the averments of this paragraph. WHEREFORE, Defendant denies that !'laintiffis entitled to judgment against the defendant in the amount specified, or to any sum of money whatsoever, or to interest or costs and 4 prays that judgment be entered in Defendant's favor and against the Plaintiff and for her costs and fees snd for such other relief as the Court deems appropriate, DEFENDANT DEMANDS TRIAL BY JURY. 18, Defendant reserves the right to challenge any award of delay damages in this case. 19. Defendant demands that appropriate hearings be conducted in this case prior to any award of delay damages, 20. Rule 238 of the Pennsylvania Rules of Civil Procedure, on its face, and as applied is violative of the Due Process and Equal Protection clauses of the Fourteenth Amendment to the Constitution of the United States, ~1983 of Title 42 of the United States Code and Article I, ~l, 6,11 and 26 and Article V, ~IO(c) of the Pennsylvania Constitution and imposes a chilling effect on the exercise by Defendant of its constitutional rights. 21, Some or all of Plaintiffs' claims may be barred or limited by Plaintiffs' election of the limited tort option of their insurance coverage pursuant to the Pennsylvania Motor Vehicle Financial Responsibility law, 75 Pa. C,S,A. ~ 1701 et. seq, 22. Answering Defendant asserts all the defenses, limitations and exclusions of the Pennsylvania Motor Vehicle Financial Responsibility law, 75 Pa. C,S.A. ~ 1701 et. seq., and avers that Plaintiff may not plead, prove, introduce into evidence or recover any benefits paid or payable by the Pennsylvania Motor Vehicle Financial Responsibility law, 23. 1fit is determined that the Defendant is liable under the Plaintiffs' cause of action, the Defendant avers that the Plaintiffs' recovery should be eliminated or reduced in accordance with the Pennsylvania Comparative Negligence Act, 42 Pa, C.S.A. ~ 1702, because Plaintiff: 5 " (8) did not keep the proper lookout; I , f .1 I ,I ,j (b) failed to properly operate and control her motor vehicle; (c) drove at an excessive rate of speed under the circumstances; (d) failed to regard the point and position of Defendant's motor vehicle then and there being lawfully operated upon said highway; (e) failed to avoid striking Defendant's motor vehicle; (f) failed to keep constant vigilance of the road, traffic, weather and road conditions; (g) failed to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; (h) failed to apply her brakes in sufficient time to avoid striking the Answering Defendant's vehicle; (i) failed to operate the steering of her vehicle in such a manner so that she could maneuver her vehicle to avoid a collision. 24, It is further averred that if the Plaintiff suffered any injuries/damages as alleged, they were caused solely and primarily by Plaintiffs own carelessness, recklessness and negligence because Plaintiff: (a) did not keep the proper lookout; (b) failed to properly operate and control her motor vehicle; (c) drove at an excessive rate of speed under the circumstances; 6 (d) failed to regard the point and position of Defendant's motor vehicle then and there being lawfully operated upon said highway; (e) failed to avoid striking Defendant's motor vehicle; (f) failed to keep constant vigilance ofthe road, traffic, weather and road conditions; (g) failed to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; (h) failed to apply her brakes in sufficient time to avoid striking the Answering Defendant's vehicle; (i) failed to operate the steering of her vehicle in such a manner so that she could maneuver her vehicle to avoid a collision, 25. It is further averred by the Answering Defendant that if the Plaintiff suffered any injuries/damages as alleged, said Plaintiffs by their conduct assumed the risk of those injuries/damages because Plaintiffs: (a) did not keep the proper lookout; (b) failed to properly operate and control her motor vehicle; (c) drove at an excessive rate of speed under the circumstances; (d) failed to regard the point and position of Defend ant's motor vehicle then and there being lawfully operated upon said highway; (e) failed to avoid striking Defendant's motor vehicle; 7 TIlE LAW OFFICES OF HARRINGTON, KAUFFMAN & SHILLING ATTORNEY: Howard D. Kauffman SUPREME COURT LD. NO.: 38963 100 PINE STREET, SUITE 300 HARWSBURG, PA 17101 (717) 720-0700 ATTORNEY FOR: Olivia L. Straub , ~ i i " JULIE ANNE SEVERINO and TIMOTIIY SEVERINO, IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. DOCKET NO. 97-20SS-Civil OLIVIA L, STRAUB, Defendant. CERTIFICATE OF SERVICE AND NOW, this.1gL day of Julv . 1997,1, Howard D, Kauffman, Esquire, attorney for Defendant, Olivia L. Straub, affirm that I served the Answer and New Matter by depositing same in the United States Mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Patrick, G. Geckle, Esquire Mychak, Geckle, Welker & Thiroway, P.C, 11th Floor 230 South Broad Street Philadelphia, P A 19102 /l- Vt""- , Kauffman, Esquire ,/ Howard .... (: i- lr. i - " I' (.~ (, ,,' L L:'" .' L I . ( r,:. r-' , l.ii I _II " L"_ I . I' r- .--.) Li G' U ,. I \ THE LAW OFFICES OF HARRINGTON, KAUFFMAN & SIIILLlNG ATTORNEY: Howard D. Kauffman SUPREME COURT 1.0. NO.: 38963 100 PINE STREET, SUITE 300 HARRISBURG, PA 17101 (717) 720-0700 ATTORNEY FOR: Olivia L. Straub JULIE ANNE SEVERINO and TIMOTHY SEVERINO, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. DOCKET NO. 97-205s-Civil OLIVIA L, STRAUB, Defendant. CERTIFICATE OF SERVICE AND NOW, th~ay of October, 1997,1, Howard D, Kauffman, Esquire, attorney for Defendant, Olivia L, Straub, affirm that I served the Praecipe by depositing same in the United States Mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Patrick, G, Geckle, Esquire Mychak, Geckle, Welker & Thiroway, P.C, 11th Floor 230 South Broad Street Philadelphia, PA 19102 / /7,/~~' Howar D. Kauffman, Esquire ,- \.to '~ IT; , ~, ...;, , , ~; ,-, c' U !~ - (')-. .-, G:~ l:.. I'.. (?: , 'J r. , . I ~ I ' ~ " __I" ,- , :.J Li..:'" C-:. I .., j':'- c.; t,_ r-- ~j U C' 0 "\ /