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Home My WebLink About97-05775 ~. ~ - ~ It ~ ~ ~ ~ ~ ~ ~ " -4.. 'l; ~ ~ ~ ~ / e'l I, , I . i /.. POST & SCIIELL, P.C, BY: LA WRENCE F. BARONE, ESQUIRE \.D. # 68921 101 NORTH FRONT STREET HARRISBURG, PA 17101 (717) 232-5931 FAX: (717) 232-9274 TILDEN BRANDT and JA Y BRANDT, her husband ATTORNEYS FOR DEfHNDANTS JERRY LAUGIIMAN and COREY CIIESTNUT COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO, 97-5775 JERRY LAUGHMAN and COREY CHESTNUT CIVIL ACTION. LAW Defendant. JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance for Defendants, Jerry Laughman and Corey Chestnut, in the above-captioned case, Respectfully fiubmincd. P T & S HI;1l,P:~ r ) d'~ A RENCE F. BARONE, ESQUIRE Co un el for Defendants Date: It \21.; /1\'1 10117/HH2H llrundl CERTIFICATE OF SERVICE I, Denise M, Valente, an employee for the law firm Post & Schell, p,c., hereby state that a true and correct copy of the foregoing Entry of Appearance was served upon all counsel of rucord by first class United States mail, postage prepaid, addressed as follows, on the date set forth below: Bv First Class u.S. Mail: David Lutz, Esquire ANGINO & ROVNER, P,C, 4503 North Front Street Harrisburg, PA 17110 ./ POST & SCHELL, P,C. ~y(~,Jy, Denise M. Valente ("> Iql Dated: 1/ (. (;I . " q .f) q f;J .., (:'1 , "'-I" 1"1 I :') If, (4) , :f,'j .., . I ,I"~ Ii ,I' ."[' ., ... 1'1 . lIlt I .. I .. I , '.' " I 'II , 0' ...." i i , SHERIFF'S RETURN - REGULAR CASE NO. 1997-05775 P COKKONWEALTH OF PENNSYLVANIA. COUNTY OF CUKBERLAND BRANDT TILDEN ET AL VS, LAUGHKAN JERRY ET AL KENNETH E. GOSSERT . Sheriff or Deputy Sheriff of CUKBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COKPLAINT upon LAUGHKAN JERRY defendant, at 1850.00 HOURS, on the ~ day of November 192Z at SPRING GARDEN ESTATE LOT 8 CARLISLE. PA 17013 County, Pennsylvania, by handing to KYRTLE OF DEFT & PERSON IN CHARGE a true and atteRted copy of the COKPLAINT together with NOTICE and at the same time direoting ~ attention to the contents thereof, was served the .CUKBERLAND LAUGHKAN. GRANDKOTHER . Sheriff's Costs I Docketing Servioe Affidavit Surcharge 18,00 3.10 .00 2.00 So anll~r"., ,/. ~ '/ ,,~. :r ......;;.....".,.'-;..<.c/~ H. ". hamas K~1n., ~n.r1%% 823.1~ ANGINO AND 11/10/1997 by ROVNER c~ fu .J. .......... U ljOL {J'!,'; ueputy l>her1ff Sworn and 8ubsoribed to before me th1s 10 ~ day of "1U.".".J~ 19 fl, A.D. ~ 9ro/t;r;~~'(.~. ~ 1~~6ft&WOYNii:;:c:t~11~. t;',,"....:.; .!: ..... ;UOHIORTH 'RClN" ITIlII'" '.. .::.'. .....':.1 ;~\"\~'LL:~'_""}-"}:"";~~~{':~'~/;<':'''''~::;: ''':' , ,':i;;:J;fl!~ ;""~;"_ri"Y';.T__.,__1;if"""~..~~;..,.~!+'5'Mjo;-,-::';"';'"".l"",,,,\>c:,;;r'~~.f;;"1_tc,,.-r:0!:.,,~\,~- '~_~;;}:0~;~;:,t.,; ,". -, - ",,' ;<-:;;::.,~^""'_.,.,,...,'.... ....<;;Wf~=,"'_'li"<-._~-'=~..""2'_~" --" -~" - ;'~X::::::~~-'t,,;~;., " ... . . ., , , , :...... ~ --t.-~._ _ .- ;'.,~.. VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. l TILDEN BRANDT and JAY BRANDT, her husband Plaintiffs JERRY LAUGHMAN and COREY CHESTNUT, Defendants JURY TRIAL DEMANDED NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas sugnuientes, usted tiene viente (20) dias de plaza al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 par abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previa aviso 0 notificacion y par cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Court Administrator 4th Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 (717) 240-6200 TILDEN BRANDT and JAY BRANDT, her husband Plaintiffs IN THE COURT OP COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. (1'7 - .'5"'J 7 y' 0.,;.,( ~.- vs. JERRY LAUGHMAN and COREY CHESTNUT, Defendants JURY TRIAL DEMANDED COMPLAINT 1. Plaintiffs Tilden and Jay Brandt are adult individuals who reside at 44 Brandt Lane, Newville, Cumberland County, Pennsylvania. 2. Defendant Jerry Laughman is an adult individual who resides at Spring Garden Estate Lot 8, Carlisle, Cumberland County, Pennsylvania. 3. Defendant Corey Chestnut is an adult individual who resides at 99 Doubling Gap Road, Newville, Cumberland County, Pennsylvania. 4. The facts and occurrences hereinafter related took place on or about July 28, 1996, at approximately 8:25 p.m. on South High Street, Newville, Cumberland County, Pennsylvania. 5. At that time and place, Mrs. Brandt was operating her 1990 Cadillac, in a northbound direction on South High Street and was stopped in a line of traffic at the intersection of South High Street and Main Street. 1 6. At the same time, Defendant Laughman was operating a 1987 Ford XLT pick-up truck in a northbound direction on South High Street and was stopped in front of Mrs. Brandt's vehicle. 7. Defendant Chestnut owned the 1987 Ford XLT pick-up truck. 8. Defendant Chestnut provided Defendant Laughman permission to drive his pick-up truck when he knew or should have known that Defendant Laughman's operating privileges were suspended and that Defendant Laughman was intoxicated and unable to safely operate the vehicle. 9. Defendant Laughman reversed his vehicle and caused the rear of the pick-up truck to collide with the front portion of Mrs. Brandt's stationa~y vehicle. 10. Defendant Laughman was intoxicated when he reversed his vehicle on South High Street that resulted in the collision with Mrs. Brandt's vehicle. 11. Defendant Laughman knew or should have known that operating a motor vehicle while intoxicated would endanger persons operating and occupying motor vehicles on South High Street. COUNT I - NEGLIGENCE Tilden and Jav Brandt v. Jerrv Lauqhman 12. Paragraphs 1 through 11 of the Complaint are incorporated herein by reference. 13. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiffs Tilden and 2 Jay Brandt are the direct and proximate result of the negligent, careless, wanton and reckless manner in which Defendant Laughman operated his motor vehicle as follows: a. failure to keep alert and maintain a proper watch for the presence of other motor vehicles behind him; b. failure to apply his brakes in sufficient time to avoid striking the front of Plaintiffs' vehicle; c. failure to keep a proper watch for vehicles behind him when he reversed his vehicle; d. failure to keep proper and adequate control over his vehicle; and e. driving his vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others b}' driving a vehicle while extremely intoxicated and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. COUNT II - PUNITIVE DAMAGES Tilden and Jav Brandt v. Jerrv Lauqhman 14. Paragraphs 1 through 13 of the Complaint are incorporated herein by reference. 15. Before the subject motor vehicle accident, Defendant Laughman was consuming alcoholic beverages. 16. Defendant Laughman knew or should have known that he was intoxicated and unable to safely operate a motor vehicle. 17. Defendant Laughman knew or should have known that his conduct of operating a motor vehicle while intoxicated constituted outrageous conduct and a reckless indifference to the rights of others on the highway. 3 lB. Defendant Lau3hman knew or should have known that operating a motor vehicle while intoxicated created a high degree of risk of injury to other persons on the highway and in fact, he did cause a collision resulting in serious personal injury. COUNT III - NEGLIGENCE Tilden and Jav Brandt v. Corev Chestnut 19. Paragraphs 1 through lB of the Complaint are incorporated herein by reference. 20. Defendant Corey Chestnut provided permission to Defendant Laughman to operate his 19B7 Ford XLT pick-up truck when Defendant Chestnut knew and/or should have known that Defendant Laughman's operating privileges were suspended and that Defendant Laughman was intoxicated and unable to safely operate the vehicle. 21. Notwithstanding the fact that Defendant Chestnut knew and/or should have known that Defendant Laughman did not possess a valid driver's license and was intoxicated, Defendant Chestnut provided Defendant Laughman permission to drive his vehicle and negligently entrusted his vehicle to Defendant Laughman. 22. Defendant Chestnut knew or should have known that it was foreseeable that Defendant Laughman would cause a motor vehicle accident inasmuch as Defendant Laughman was intoxicated and that prior to the aforesaid July 2B, 1996, motor vehicle accident, Defendant Laughman'S operating privileges had been suspended. 4 COUNT IV - PUNITIVE DAMAGES Tilden and Jav Brandt v. Corev Chestnut 23. Paragraphs 1 through 22 of the Complaint are t"';' incorporated herein by reference. 24. Before the subject motor vehicle accident, Defendant Chestnut knew and/or should have known that Defendant Laughman was , ~ , , - consuming alcoholic beverages. 25. Defendant Chestnut knew and/or should have known , I' I J i i I , I I I , ! I I i ( , I ! that Defendant Laughman, because of his intoxicated state, was unablp. to safely operate Defendant Chestnut's motor vehicle. 26. Defendant Chestnut knew or should have known that Defendant Laughman was intoxicated when granted permission to operate his motor vehicie and such conduct constituted outrageous conduct and a reckless indifference to the rights of others on the highway. 27. Defendant Chestnut knew or should have known that Defendant Laughman, operating his motor vehicle while intoxicated, created a high degree of risk of injury to other persons on the highway and in fact, he did cause a collision resulting in serious personal injury. CLAIM I Tilden Brandt v. Jerrv Lauahman and Corev Chestnut 28. Paragraphs 1 through 27 of the Complaint are incorporated herein by reference. .... 5 29. Plaintiff Tilden Brandt sustained painful and severe injuries which include but are not limited to C6-C7 radiculopathy, cervical spine/strain, right shoulder pain, low back pain, upper back muscle contusion, cervical muscle contusion, and possible reflex sympathetic dystrophy, as well as carpel tunnel syndrome. 30. By reason of the aforesaid injuries sustained by Mrs. Brandt, she was forced to incur liability for medical treatment, medications, hospital treatment, physical therapy, and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 31. Because of the nature of her injuries, Mrs. Brandt has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 32. As a result of the aforementioned injuries, Mrs. Brandt has undergone and in the future will undergo physical and mental suffering, inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 33. As a result of the aforesaid injuries, Mrs. Brandt has been and in the future will be subject to humiliation and embarrassment, and claim is made therefor. 34. Mrs. Brandt continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefor. 6 CLAIM II Jav Brandt v. Jerrv Lauahman and Corev Chestnut 35. Paragraphs 1 through 34 of the Complaint are incorporated herein by reference. 36. As a result of the aforementioned injuries sustained by his wife, Tilden Brandt, Plaintiff Jay Brandt has been and may in the future be deprived of the care, companionship, consortium, and society of his wife, all of which will be to his great detriment, and claim is made therefor. WHEREFORE, Plaintiffs Tilden and Jay Brandt demand judgment against Defendants Jerry Laughman and Corey Chestnut in an amount in excess of Twenty-five Thousand ($25,000.00) Dollars for compensatory and punitive damages exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. ANGINO & ROVNER, P.C. Date: ID \J6lll (~' ,Il (!t" W'\ '\ '(" avid L. utz I.D. #35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiffs 7 VERIFICATION We, Tilden and Jay Brandt, Plaintiffs, have read the foregoing COMPLAINT and do hereby swear or affirm that the facts set forth in the foregoing are true and correct co the best of our knowledge, information and belief. We understand that this Verification is made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. WITNESS: . . <~~_;:. ._.IJT-) ~. ,~..Jj - ~tMrc) ~ &-~ Tilden Bran t . ;/4 -!~t rl rd ~,_-I~ ~andt Dated: tJc1;'. 7, /9'17 ~ (~ r-:> . ~ c--:-. }t , - I .... .;:;:; ~ i"> \.....0 -..l,J4::) \N~ '-\.. ~ ~ ~ c:J CJ C' :.~ ;') , ;-"j . , - . . . -~'l i -. l.... " .~'\ - ; , :._1 ,Ill . ; ~:. .:1 f .' ~..", [ ~\ ~ '-.i', ~~ ~ \' \,,'\ r:' vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97-05775 Civil TILDEN BRANDT and JAY BRANnT, her husband Plaintiffs JERRY LAUGHMAN and COREY CHESTNUT, Defendants JURY TRIAL DEMANDED i I . t PLAINTIFFS' REOUEST FOR ADMISSIONS TO DEFENDANT CHESTNUT To: Corey Chestnut, by and through his attorney Lawrence F. Barone, Esquire Post & Schell, P.C. 101 N. Front Street Harrisburg, PA 17101 Please take notice that you are hereby required, pursuant to Rule 4014 of the Pennsylvania Rules of Civil Procedure (Federal Rules of Civil Procedure 36), to serve upon the undersigned within thirty (30) days from service, your response to the admission(s} requested herein: 1. Do you admit that on July 28, 1996, you owned a 1987 Ford XLT pick-up truck? Admit Deny 2. Do you admit that you provided Jerry Laughman permission to operate your 1987 Ford XLT pick-up truck? Admit Deny ____ 124160/MTG CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of PLAINTIFFS' REQUEST FOR ADMISSIONS TO DEFENDANT CHESTNuT upon all counsel of record via postage prepaid first class United States mail addressed as follows: Lawrence F. Barone, Esquire Post & Schell, P.C. 101 N. Front Street Harrisburg, PA 17101 Attorney for Defendants I~ '0/.~.1 G" , I 4- lfl/ll/ L' peraets ( " , Mary T. Dated: )).~r- en n .0 0 ~.;:; ...J -:1 .:.... .~ J .. ,1' .. 'n [ . 'J I I~ I " C; ! ;) ~ .. .~ .';",:! , -n , I ~ i f"j , n .. " ..- .": ~1 :..: I ..., =< ~ :-;. (717) ltIN781 ~;,~,jJ::'\ " ,!ft~;' , "~:~:~t~;)i)'._:~,;'7"-:;~f':';:':_-- .",- .' "~,,:--,_,:;:,,,'-<-.:_Y ','. .. . NGINO ':ROVMJR.P.C~.b{2i" ,:~!" ;'i" tlOllT" '''OIfT ITRUT: ',:':\,), '. '.'. "A"Rl"URG, PA 17110:'.": '" 1-,', ','--' --:;: - 1;;. ....-,;..:.,""i-i,"'rFvi~i..-,.,~.:i"",..," ".,~-~-," -..,. "-,:,"- , ... . ~ , f ....- --~:.--- . \ ;.. ~ TILDEN BRANDT and JAY B~~DT, her husband Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 97-05775 Civil JERRY LAUGHMAN and COREY CHESTNUT, Defendants JURY TRIAL DEMANDED PLAINTIFFS' REOUEST FOR ADMISSIONS TO DEFENDANT LAUGHMAN To: Jerry Laughman, by and through his attorney Lawrence F. Barone, Esquire Post & Schell, P.C. 101 N. Front Street Harrisburg, PA 17101 please take notice that you are hereby required, pursuant to Rule 4014 of the Pennsylvania Rules of Civil Procedure (Federal Rules of civil Procedure 36), to serve upon the undersigned within thirty (30) days from service, your response to the admission(s) requested herein: 1. Do you admit that on July 28, 1996, you were operating Corey Chestnut's 1987 Ford XLT pick-up truck? Admit Deny _ 2. Do you admit that on July 28, 1996, you were operating Corey Chestnut's 1987 Ford XLT pick-up truck on South High Street, Newville, Cumberland County, Pennsylvania? Admit Deny _ 12H62/MTG 3. Do you admit that on July 28, 1996, at approximately 8:25 p.m., you were involved in a motor vehicle accident with Mrs. Tilden Brandt? Admi t Deny 4. Do you admit that at the time of the subject motor vehicle accident you were intoxicated? Admit Deny Date: p ,q.Q7 ANGINO & ROVNER, P.C. ~LU" 1.0. 1135956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for plaintiff (', '" 0 c: -I on "., "'I . , 1 ., -! , " .') I -n :) (...: , , .-., .-. " , - 'J .' " f'., 'J' " " .' r- ::. ~ :) I" '-, ~ ..:: >. -^.ti#~;,/~j;cr.,,;~;, ,:~~/:-.::~-- ,<: { f)it. ;' y~,-;': .,-~:>S~~;-;>: -:"; ,bi' r. j_'c~', ""'"!KGINOAROVNEI 'p C'~ ;.;!,.;" ..': >.,?,'" ~,::;:r;f'450' NO~~ 'RONT aT~II; ,.....<':c. .:",,~':.:~.',:.'. .. ". HARRISaURG, ",\ 17110 ~}~:xt:~~:.,,~,~,,-<,<., pm.... ....,;i'~1~~t "': ,. ... . ~ , " 1 ! , .. I j...... ,,;..:;;..--:..,....- \ -+--'" ..,.- -,J-C-_".:C'-... .. - TILDEN BRANDT and JAY BRANDT, her husband Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97.05775 Civil vs. JERRY LAUGHMAN and COREY CHESTNUT, Defendants JURY TRIAL DEMANDED PLAINTIFF'S REQUEST FOR ADMISSIONS DIRECTED TO DEFENDANT COREY CHESTNUT - SET 2 Plaintiffs request that Defendant Corey Chestnut admit, pursuant to the provisions of Pennsylvania Rules of Civil Procedure, the matters set forth below. The facts set forth below shall be deemed admitted unless Defendant Corey Chestnut serves upon Plaintiffs' attorney, a sworn answer or objection within thirty (30) deys after Defendant Corey Chestnut is served with this Request for Admissions. If an objection is made to any fact whose admission is requested, the reason for that objection shall be stated. Each answer shall admit or deny the matter or set forth in detail the reason(s) why an admission or denial cannot truthfully be made. A denial 01 any matter shall fairly meet the substance of the requested admission. When good faith requires Defendant to qualify his answer. or deny only a part of the matter of which an admission is requested, the Defendant shall specify so much of the requested admission as is truth and qualify or deny the remainder. Defendant may not give lack of knowledge or information as e reason for failure to admit or deny unless he states that he has made reasonable inquiry and that the information , . . ' . _._~.. . , , . CERTIFICATE OF SERVICE I, Candice M. Baker, an employee of the lew firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of PLAINTIFF'S REQUEST FOR ADMISSIONS DIRECTED TO DEFENDANT COREY CHESTNUT - SET 2, upon all counsel of record via postage prepaid first class United States mail addressed as follows: Lawrence F. Barone, Esquire Post & Schell, P.C. 101 N. Front Street Harrisburg, PA 17101 Attorney for Defendants ..." Dated: rLL{:2n.~ \...0"" Candice M. Baker n In 0 (~.. r.1:l ~O'I , .., '"1:"1_1: 1-. 'I'~ [');, ",,:) ';;, .nl .. :}'? ,.> <.-',.., r-.:; -'J '::iJ ., -. ::1.: !;:"1 , , , ljl 11 " ~,.. :...l .. ,; t:" ~~ =< 'Jl 'n ,;t'~.4~:.j:.:~t~t:L<>,;,~ '~':fi&\.~~~;;',';"';z.~,><. ,.\, ~~~~;~:~> ':~_;_c"" ~ ~, , '"" _, _. "'. i~' ,,)~:!dJ~' ~~,. ;j,}; T . . ~,;V' i,\ '>' j' .t.'~ - r ~,' :~~w ., ~ ~ "N~Jta .....J'_~ -J'J, <4h-' : . . ~t.- ,~:d .. j:,c<' . f ~,.,,", ,",'{~~.:d,~",:;- ("\-Pi: \i'ANGINO'(, ROVNlI, P.Ct~..:::,~,:~:. 4.01 IoI0ATII'..OrtrITII.lr.. _ :, ,;: ' 'HA....I..U..II, I'A I7t to ,.......; , 1717)""" , ~; ~:::,~t~"",,:: , :' \~~:~~ ..~ "-H:\IH~ii, >:::'_I"i;/v~,;;~'~',€~:;:v1~~Iii~~V' -ff.... t .". . . , " ! i I I " \ \ ! ,..-. ~ ,.-- ~ .--.- - /-."--:"'. "-'.:":'. ,. -'-,' .- \ ./.-: TILDEN BRANDT and JAY BRANDT, her husband Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANI.l\. CIVIL ACTION - LAW NO. S7-05775 civil vs. JERRY LAUGHMAN and COREY CHESTNUT, JURY TRIAL DEMANDED Defendants PLAINTIFF'S REPLY TO DEFENDANTS' NEW MATTER 5. through 15. Denied. The Defendants have failed to set forth factual allegations that require the plaintiff to admit and/or deny said allegations. The factual allegations contained in the Plaintiff's Complaint are herein incorporated by reference. All of the allegations contained in the Defendants' New Matter are all conclusions of law to which no response is necessary. WHEREFORE, the plaintiff pray that the Defendants' New Matter be dismissed. Date: ,~ d.l.e-~~ ANGINO & ROVNER, P.C. Qtrtu'" I. D. 1135956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff 126B62/MTG -....' . , ~ q ,.t" n ;.:> " ,- ::;1 " . - ~\., ,If;;' r....') ',rl1 C) ._J , '() " , '-1' :rJ :CJ i} :".Id "', I'~ ~.> ~I. ", " , , i I ! I I I I I I - TILDEN BRANDT and JAY BRANDT, her husband Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 97-05775 civil JERRY LAUGHMAN and COREY CHESTNUT, Defendants ,JURY TRIAL DEMANDED PRAECIPE To the Prothonotary of Cumberland County: please mark the above-captioned action settled, satisfied, and discontinued. ANGINO & ROVNER, P.C. Date: C;, l~ Ji'i cc Lawrence Barone, Esquire ~ Lutz I.D. #35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiffs ,/ 121919/MTG OR\G\NAL '-. " L ~ '\ I r,! , ,- L; ./ " ". ,-; :-J J u ! I I ~ , 00 ".i'Oall