HomeMy WebLinkAbout98-03393
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JOSEPH RUDA
plaintiff .
.
,
.
v.
.
.
STEPHEN SJOBERG .
.
.
.
Defendant .
.
IN THE COURT OF COKMON PLEAS
OF CUMBERLAND COUNTY, PENNA
NO. 98-3393 civil
CIVIL ACTION - LAW
COM P L A I N T
AND NOW COMES the Plaintiff, JOSEPH RUDA, PRO SE, and
respectfully avers as follows:
THE PARTIES
1. Plaintiff Joseph Ruda is an adult individual who
currently resides at 65 Derbyshire Drive, Carlisle, Cumberland
county, Pennsylvania,
2, Defendant Stephen Sjoberg is an adult individual
believed and therefore averred to currently reside at 46-48 East
Pomfret Street, Carlisle, cumberland county, Pennsylvania,
3, ' The facts hereinafter described took place on June 19,
1996 at approximately 12:45 p,m, at the intersection of Route 34
and G Street in carlisle, Cumberland County, Pennsylvania, This
stated date, time, and location shall be referred to as "the
scene" throughout this complaint,
4, At the scene, Plaintiff Joseph Ruda was operating a
1983 Jaguar XJ 6, Pennsylvania Registration Plate COOL CAT, which
he owned,
5, At the scene, Joseph Ruda was travelling southbound on
Route 34 (Spring Road) and had entered the intersection of Route
34 and G Street,
6, At the scene, the Defendant, stephen sjoberg, was
operating a 1979 Chrysler CP-300, pennsylvania registration plate
number AYA 0723, which he owned.
7, At the scene, stephen sjoberg was driving Eastbound on
G street and entered the intersection of Route 34 and G street
against a stop sign and oncoming traffic,
8, As both vehicles entered the intersection, stephen
sjoberg attempted to cross the oncoming southbound lane of Route
34 and caused a collision between the Chrysler and the Jaguar,
9, At all relevant times, the Defendant, stephen Sjoberg,
had a duty to come to a complete stop at the stop sign and a duty
to yield the right-Of-way to on-coming traffic pursuant to 75 Pa,
Cons, Stat. S 3323 (stop and yield signs) ,
10, The Defendant, stephen Sjoberg, breached his duty of
care by failing to yield the right-of-way to Joseph Ruda who was
already in the intersection, thereby causing a collision,
11, The collision was caused solely by the negligence of
the Defendant and plaintiff, Joseph Ruda, in no way caused or
contributed to the collision,
12, The Defendant's negligence includes, but is not limited
to, the following acts or failures:
a, Failing to observe other vehicles on the roadway;
b, Failing to operate his vehicle in accordance with
the existing traffic conditions;
2
c, Failing to keep a reasonable lookout for other
vehicles on the road;
d. Operating his vehicle in a manner which created a
dangerous situation for other vehicles on the
road; and
e, Operating his vehicle in a manner that violated 75
Pa,C,S, S 3323 which is negligence per ag,
13, Plaintiff Joseph Ruda has suffered injuries to his
knees, left wrist, and spine that were caused by the trauma he
received in the collision caused solely by the negligence of the
Defendant, Stephen Sjoberg,
14, Plaintiff Joseph Ruda has been obliged to expend sums
and incur expenses for medical treatment as a result of his
injuries caused solely by the negligence of the Defendant,
Stephen Sjoberg,
15, Plaintiff Joseph Ruda is likely to incur expenses and
to expend sums in the future for necessary medical care as a
result of his injuries caused solely by the negligence of the
Defendant, Stephen Sjoberg.
16, Plaintiff Joseph Ruda has missed work and, as a result,
incurred a loss of income due only to his injuries caused solely
by the negligence of the Defendant, Stephen Sjoberg; therefore,
Plaintiff Joseph Ruda makes a claim for lost wages,
3
99HB-00020
LAW OFFICES OF JACOBS & SABA
214 Senate Avenue, Suite 503
Camp Hill, PA 17011
Telephone Number: (717) 731-0988
Attorne s for Defendant Ste hen S'ober
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY , PENNSYLVANIA
JOSEPH RUDA,
PLAINTIFF
VS.
No, 98-3393-CIVIL
STEPHEN SJOBERG,
DEFENDANT
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
ANSWER WITH NEW MATTER OF DEFENDANT STEPHEN SJOBERG
TO PLAINTIFF'S COMPLAINT
AND NOW, comes the Defendant, Stephen Sjobefg, by and through his attorney,
Girard E. Rickards, Esquire, in support of Answef with New Matter of Defendant Stephen
Sjoberg to Plaintiffs Complaint hereby avers as follows:
1. Admitted.
2, Admitted in part, denied in part. It is admitted that Defendant Stephen Sjoberg is
an adult individual. The remaining averments in paragraph 2 are specifically denied and strict
proof thefeof is demanded at the time of trial.
3, Admitted.
4. Admitted.
5. Admitted.
6. Admitted,
7, Admitted.
8. Admitted.
9. The avennents in paragraph 9 constitute a conclusion of law to which no response is
required.
10. The avennents in paragraph 10 constitute a conclusion of law to which no
response is required.
11. The avennents in paragraph 11 constitute a conclusion of law to which no
response is required.
12. The avennents in paragraph 12 constitute a conclusion of law to which no
response is required.
13. After reasonable investigation, the Defendant is without sufficient knowledge to
fonn a belief as to the truth of the avennents of paragraph 13. Therefore, each and every
avennent of paragraph 13 is specifically denied and strict proof thefeof is demanded at the
time of trial.
14. After reasonable investigation, the Defendant is without sufficient knowledge to
fonn a belief as to the truth of the avennents of paragraph 14. Thefefore, each and every
avennent of paragraph 14 is specifically denied and strict pfoof thefeof is demanded at the
time of trial.
15, After reasonable investigation, the Defendant is without sufficient knowledge to
fonn a belief as to the truth of the avefments of paragraph 15. Therefore, each and every
avennent of paragraph 15 is specifically denied and strict proof thefeof is demanded at the
time of trial.
16. After reasonable investigation, the Defendant is without sufficient knowledge to
fonn a belief as to the truth of the avennents of paragraph 16. Therefore, each and every
avennent of paragraph 16 is specifically denied and strict proof thereof is demanded at the
time of trial,
17. After reasonable investigation, the Defendant is without sufficient know ledge to
fonn a belief as to the truth of the avennents of paragraph 17. Therefore, each and every
avennent of paragraph 17 is specifically denied and strict proof thereof is demanded at the
time of trial.
WHEREFORE, Defendant Stephen Sjobefg respectfully requests your Honorable Court
to dismiss the Plaintiff's Complaint with prejudice.
NEW MATIER
18. Paragraph one (1) through seventeen (17) are incorporated herein by reference,
and made a part hereof as if set forth in full.
19. Defendant Stephen Sjobefg believes and therefore avefS that at all times relevant
hereto, Plaintiff Joseph Ruda was an insured or named insured under a policy of motor vehicle
insurance issued pursuant to the Pennsylvania MotOf Vehicle Financial Responsibility Act with
the limited tort option.
99HS.o0020
LAW OFFICES OF JACOBS & SABA
214 Senate Avenue, Suite 503
Camp HilI, PA 17011
Telephone Number: (717) 731-0988
Attorne s for Defendant Ste hen S'ober
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, I'ENNSYLVANIA
JOSEPH RUDA,
PLAINTIFF
VS,
No, 98-3393-CIVIL
STEPHEN SJOBERG,
DEFENDANT
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
Girard E, Rickards, Esquire, hereby certifies that he is the attorney for Defendant
Stephen Sjoberg herein, and that he caused a true and correct copy of Answer with New
Matter of Defendant Steuhen Sioberl! to Plaintiff's Complaint to be served by certified
mail, return receipt requested and regular fust class mail upon:
Joseph Ruda
65 Derbyshife Drive
Carlisle, PA 17013
Dated:
~-
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June 9. 2000
.-"
Girard E. Rickards, Esquire
Attorney for Defendant
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MYCHAK GECI<LE [, WI,:J.I<ER, I'. C'.
By: Richanl B. Bdtt'lIIdn, .Jr'
Identification No.: 'iI1,1
230 South Broad SLrt't't
Eleventh Float'
i Philadclphi~, PA 191{)2
(215) 735-3326
Attorney [or Plaintiffs
JOHN P. MARSHALL dnd 'I'HEANA
MARSHALL, :\el: husband
COURT OF' COMMON PLEAS
CUMBERLAND COUNTY
v.
RALPH JOHN REHM, JR.
and
MILLER & SONS, INC.
and
PAUL P. MOURATEDES
NO.: 98-3993
,I
II TO
i
PRAECIPE TO REINSTATE
THE PROTHONOTARY:
Kindly reinstate the attached Civil Action Complaint.
MYCHAK GECKLE & WELKER, P.C.
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DATED:
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JOSEPH RUDA,
Plaintiff
IN THE COURT OF COMMON PLEAS
C~mERLAND COUNTY, PENNA,
CIVIL ACTION - LAW
v,
NO, 98-3393 Civil
STEPHEN SJOBERG,
Defendant
JURY TRIAL DEMANDED
PRAECIPE
TO THE PROTHONOTARY:
Please re-issue the Writ of Summons for service upon the
Defendant in the above-captioned case.
Respectfully submitted,
SCHMIDT & RONCA, P.C.
Dated: s;"f\;,", \, \qq~
~ ~
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By /H ~ J2<--
Todd D. Getgen
Attorney for Plaintiff
ID # 80719
209 State Street
Harrisburg, PA 17101
(717) 232-6300
JOSEPH RUDA . IN THE COURT OF COMMON PLEAS
.
: OF CUMBERLAND COUNTY, PENNA
plaintiff ,
,
:
v. , NO. 98-3393 civil
.
,
.
STEPHEN SJOBERG
:
Defendant , CIVIL ACTION - LAW
,
RULE TO SHOW CAUSE
AND NOW, this
P'day of ~
, 1998, upon motion of
plaintiff's counsel, leave to withdraw, a Rule is hereby issued
cw-tl ~
upon Joseph Ruda" to show cause why leave to withdraw as counsel
should not be granted, allowing thirty (30) days for plaintiff,
Joseph Ruda, to obtain new counsel.
RULE RETURNABLE db
days after serVice~
~r
J,
JOSEPH RUDA
Plaintiff
v.
STEPHEN SJOBERG
Defendant
AND NOW, this
,:::,~,f;""..:,.~':..,__. ._....::::"'_~
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNA
NO. 98-3393 civil
CIVIL ACTION - LAW
ORDER
upon consideration of the Praecipe to withdraw as Counsel
day of
, 1998,
filed by Attorney Todd D. Getgen, attorney of record for the
Plaintiff, Joseph Ruda, it is hereby ordered and decreed
that Plaintiff's counsel, Todd D, Getgen, is granted leave
to withdraw as counsel for the Plaintiff, Joseph Ruda, upon
the expiration of thirty (30) days after the date of this
order, and the Plaintiff is directed to find new counsel
within thirty (30) days.
J.
5, plaintiff'S counsel has repeatedly requested in person,
in writing, and orally in telephone conversations that the
plaintiff provide the proper documentation regarding the
plaintiff'S alleged wage-loss claim, including the applicable tax
returns,
6, plaintiff's counsel requested the applicable wage-loss
records in writing on June 17, 1998, July 6, 1998, July 20, 1998
(mistakenly dated July 6, 1998), August 3, 1998, and August 27,
1998. (See correspondence attached as Exhibit A),
7, The plaintiff has repeatedly failed or refused to
cooperate and to provide the requested documents,
8, plaintiff'S only attempt to communicate with his counsel
of record concerning the tax records has been via a single
telephone call--made after plaintiff'S counsel threatened to file
a Praecipe to withdraw as counsel in the August 3, 1998 letteri
during which call plaintiff agreed to send the tax documents
immediately,
9, The documents have never been sent,
10, pursuant to the pennsylvania Rules of professional
conduct, Rule l,16(b) (4) which states in pertinent part:
(b) [A] lawyer may withdraw from representing a client
if withdrawal can be accomplished without material
adverse effect on the interests of the client, or
if:
. . .
(4) the client fails SUbstantially to fulfill an
obligation to the lawyer regarding the
lawyer's services and has been given
reasonable warning that the lawyer will
withdraw unless the obligation is fulfilled.
2
10. Under the contingency fee agreement between Schmidt and
Ronca, P.C" and the Plaintiff, the Plaintiff/client is required
to:
Promptly supply accurate information, as requested by
SCHMIDT AND RONCA, P,C" and cooperate fully, including
making myself available for meetings with my attorney
and for legal proceedings. Client promises all
information supplied will be truthful and accurate.
11, Plaintiff's counsel believes and avers that the
Plaintiff/client has failed to cooperate fully in the
investigation of the above claim by repeatedly failing to supply
the necessary tax documents to substantiate the wage-loss claim,
12, Plaintiff's counsel believes and avers that the
Plaintiff has failed substantially to fulfill an obligation to
supply his counsel with the necessary documentation required to
prove Plaintiff's loss of wages.
13, Plaintiff's counsel cannot properly pursue Plaintiff's
claims absent the cooperation of the client.
14, Plaintiff's counsel has given Plaintiff sufficient
notice that Attorney Todd D. Getgen would seek to withdraw if the
request for information was not fulfilled as required under Rule
of Professional Conduct 1,16.
15, Plaintiff's counsel has acted to protect the client's
interest by filing a praecipe to issue a writ of summons which has
been reissued twice due to difficulties which the Cumberland
County Sheriff has had with service, The reissued writ was served
on the Defendant on September 21, 1998,
3
EXHIBIT A
Schrnjdtand Ronca PC
2'09 Stare Sb'ed
Harrisburg, l'ennsylvanla ~710J
717 I 232-6300 Fa,,,, 117 I 232-6467
At~omeys and 'Couns.elors ,at law
June 17, 1998
Mr, Joseph Ruda
65 Derbyshire Drive
Carlisle, PA 17013
Dear Joe:
Enclosed are the documents you brought along with you to the
meeting, I have made copies for the file,
I will also need some additional information from you in order to
substantiate your wage-loss claim, First, I will need a copy of
every document you have that shows the days you missed from work
such as the calendar you mentioned at our meeting. Second, I
will need some proof that the missed time from work translated
into lost wages. Because you are the plaintiff, you have the
burden of proving that the missed work made you lose money that
you would have made absent the injuries. This means that we will
need to prove that by missing the days of work your business
suffered a loss of profits or that you missed opportunities for
work. An example would be if a potential client hired a
different contractor because you could not make it to a meeting
because of your injuries.
Nationwide requested your profit/loss statement as proof that you
actually lost money due to the work loss. Essentially, I will
need similar documentation in the form of some written record
that will show that you made less money than you normally would
have due to your accident-related injuries, Absent some sort of
records such as tax returns or profit/lOSS statements that show a
difference in earnings before and after the accident, I do not
believe that we will be able to prove that you actually lost any
~ages. If the missed work did not actually result in lost wages,
then you have no legitimate claim for lost wages.
If we cannot prove an actual wage loss from your business and
personal wage records, Nationwide does not have any obligation to
pay you and will not do so. If we go to arbitration without
proof that your profits or opportunity to work suffered due to
your injuries from the car accident, we will lose,
~
Joe Ruda
Letter
Page 2
"
I cannot just assume that we can prove the wage loss, I need
actual records that you kept from your business from the years
1996 to the present that show that you lost money and records
that can link the lost money to the days of missed work,
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I cannot ethically file a complaint on your behalf that alleges
any wage loss until I have proof that you actually lost money as
a result of the missed' work. Keep in mind that this is a claim
for lost waqes and not just a claim that you missed time from
work.
You really need to search your files at home and dig up
everything you have that will show that the days that you missed
from work resulted in lost money, If we have no proof, we have
no legitimate claim for lost wages. without a wage loss claim,
the only thing we could recover would be the medical expenses
which apparently have been paid by Blue Cross/Blue Shield.
Please compile the
soon as possible.
the meantime.
requested documents and send them to me as
I will be sending for your medical records in
Very truly yours,
SCHMIDT AND RONCA, P.C.
~I .v4tfJ-'--
Todd D, Getgen
Attorney at Law
TDG
2
Schmidt and Ronca PC
209 State Street
Harrisburg, Pennsylvania 17101
717 / 232~6300 Fax 717 /232-6461
Attorneys ,l.!ld Counselors at L,lW
July 6, 1998
Mr, Joseph Ruda
65 Derbyshire Drive
Carlisle, PA 17013
Dear Joe:
Under our written 'agreement, you are required promptly to supply
accurate information and to cooperate fully with me in my attempt
to pursue your claims, Unfortunately, I believe that this has
not occurred,
I have requested that you provide me with documentary proof of
your wage-losses caused by your 1996 automobile accident on three
occasions: (1) by telephone prior to our original attorney-client
meeting, (2) in a letter dated June 17, 1998, and (3) in a letter
dated July 6, 1998, To date, I have received no response from
you, The only wage-loss documents you have provided are the
doctor's excuse from Dr, Hoban and your letter to Penny Greene
indicating the dates you missed work; both of which were supplied
at the abova-mentioned meeting,
If you do not supply the requested tax returns and other wage-
loss documents within ten (10) days, I shall take the necessary
steps to terminate my representation of you for your claims
related to your automobile accident of June 19, 1996,
Very truly yours,
SCHMIDT AND RONCA, P,C,
-z:dd P ~o/<i0--
Todd D, Getgen I
Attorney at Law
TDG
Schmldt and Ronca PC
109 Stolte Street
H.urlsburg, l'eno5}llvanl<ll 11H)j
1~7 /232-6300 Fa-x 7i1/ 232-6467
AltOf:rl~Y5 aHld Co_ms,elors a:t Law
August 3, 1998
Mr, Joseph Ruda
65 Derbyshire Drive
Carlisle, PA 17013
Dear Joe:
As I have explained before, under our written agreement, you are
required promptly to supply accurate information and to cooperate
fully with me in my attempt to pursue your claims, The agreement
states as follows:
In return, the Client will:
1, promptly supply accurate information, as requested by
SCHMIDT AND RONCA, P,C" and cooperate fully, including
making myself available for meetings with my attorney
and for legal proceedings, Client promises all
information supplied will be truthful and accurate,
I have repeatedly asked you to assist my investigation of your
claim by providing tax and other wage documents, Unfortunately,
you have not responded to my repeated requests for any documents
which would support or substantiate your wage-loss claim, I can
never prove your claim for lost wages without some proof that
your injuries from the automobile accident caused you to earn
less money than you would have absent the injuries,
To date, you supplied only a letter you sent to Nationwide
Insurance on August 6, 1997 which identifies the dates of missed
work, As I have explained, I do not believe that this letter
alone is sufficient proof of lost wages. As you recall, you
supplied this letter at our initial meeting,
At this point, you have repeatedly failed to make any contact
with me whatsoever concerning the requested proof although I have
requested that you provide me with documentary proof of your
wage-losses caused by your 1996 automobile accident on four
occasions: (1) by telephone prior to our original attorney-client
meeting, (2) in a letter dated June 17, 1998, (3) in a letter
sent on July 6, 1998, and in a letter--mistakenly dated July 6,
1998--sent on or about July 20, 1998,
"
, ,
Joseph Ruda
Letter
Page ~
If you do not consent, I will file a Motion to withdraw as
counsel with the Cumberland county Court on or immediately after
August 24, 1998, You may then be required to appear in court at
some time in the future to explain why you believe that I should
continue as your counsel, This twenty-day period should allow
you sufficient time to find other counsel,
Very truly yours,
SCHMIDT AND RONCA, P,C.
,.,...-:- ...
Icrkf :D/iti1t0
Todd D, Getgen
Attorney at Law
TDG
3
"
Schmidt and Ronca PC
209 State Street
Harrisburg, Pennsylvania 17101'
717 / 232-6300 fax 717/232-6467
Attorneys and CounselorS at Law
August 27, 1998
Mr, Joseph Ruda
65 Derbyshire Drive
Carlisle, PA 17013
Dear Joe:
As you know, I sent' you a letter on approximately July 20, 1998
where I requested that you supply this office with your pertinent
tax returns in this case. As you know, this was the last of a
series of letters which I have sent to you requesting these same
records, My records indicate that I have sent a letter on June 17,
1998, a second letter on July 6, 1998, and a third letter on
approximately July 20, 1998 requesting these same documents.
The accident in question took place on June 19, 1996,
Consequently, please supply me with your tax returns from 1993 to
the present so that I may compare the earlier returns with your
income that you generated after the 1996 accident.
This letter is a reminder that you promised to send me these tax
documents when we spoke on the telephone approximately two weeks
ago. I realize that you are a busy man, but I cannot'process your
work loss claim until I have these records. Even with the records,
there is no guarantee that we will be able to prove that your lost
wages absolutely result from the June 19, 1996 car accident.
To date, I have filed a writ on your behalf to toll the statute of
limitations. I have been in repeated contact with the Cumberland
County Sheriff's Department, which is the entity who attempts to
effect service of process for all writs and comPlaints, To date,
the Cumberland County Sheriff's Department has attempted to serve
Steven Sjoberg on multiple occasions both at his home of record,
and at a half-way house where Steven currently resides. However,
the sheriff has been unable to serve the writ on Mr. Sjoberg.
Currently, I am having the Prothonotary reinstate the writ and will
continue to have the sheriff attempt to serve Steven Sjoberg at the
half-way house,
Additionally, I have sent for your medical records from both the
emergency room visit and from Dr. Hoban's office. I expect to
JOSEPH RUDA IN THE COURT OF COMMON PLEAS
, OF CUMBERLAND COUNTY, PEtlNA
.
Plaintiff .
.
v, , NO, 98-3393 civil
,
,
.
STEPHEN SJOBERG
,
.
Defendant , CIVIL ACTION - LAW
,
CERTIFICATE OF SERVICE
AND NOW this3)fLday of September, 1998, I, Todd D.
Getgen, Esquire, hereby certify that I have this day served
a true and correct copy of Plaintiff's counsel's PRAECIPE TO
WITHDRAW AS COUNSEL by depositing same in the United states
Mail, certified letter, return receipt requested, first
class postage prepaid, at Harrisburg, Pennsylvania,
addressed to:
Plaintiff:
Joseph Ruda
65 Derbyshire Drive
Carlisle, PA 17013
Defendant:
Stephen Sjoberg
46-48 East Pomfret Street
Carlisle, PA 17013
Respectfully submitted,
Dated: ...?u ~O Nf.?
I
SCHMIDT & RONCA, P.C.
By ~;;;y ~~4~
Todd D. Getgen
Attorney for Pla1ntiff
ID # 80719
209 State Street
Harrisburg, PA 17101
(717) 232-6300
".'., .,_._,..~...,..,~..,
99HB-00020
LA W OFFICES OF JACOBS & SABA
W, Darren Powell, Esquire
214 Senate Avenue, Suite 503
Camp Hill, PA 17011
Telephone Number: (717) 731-0988
Attorne for Defendant Ste hen S'ober
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JOSEPH RUDA,
PLAINTIFF
VS.
No. 98-3393-CIVIL
STEPHEN SJOBERG,
DEFENDANT
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
ENTRY OF ApPEARANCE
TO TIlE PROTIlONOTARY:
Kindly enter my appearance in the above-captioned matter on behalf of the Defendant,
Stephen Sjoberg.
Respectfully submitted,
Date: February 25. 1999
LAW OFFICES OF JACOBS & SABA
'~~ \) ~~\
W. Da en Powell, Esquire '
Attorney for Defendant Stephen Sjoberg
214 Senate Avenue, Suite 503
Camp Hill, PA 17011
Telephone Numbef (717) 731-0988
Identification No. 68953
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JOSEPH RUDA, IN THE COURT OF COMMON PLEAS
plaintiff . CUMBERLAND COUNTY, PENNA.
.
CIVIL ACTION - LAW
v. .
.
NO. 98-3393 civil
STEPHEN SJOBERG, ,
,
Defendant : JURY TRIAL DEMANDED
PRAECIPE
TO THE PROTHONOTARY:
Please re-issue the Writ of Summons for service upon the
Defendant in the above-captioned case.
Respectfully submitted,
SCHMIDT & RONCA, P,C.
Dated: Ju ILl "z3. /Pf Y
/ '
By ~t /)~~.u....
Todd D. Getgen
Attorney for Plaintiff
ID # 80719
209 State Street
Harrisburg, PA 17101
(717) 232-6300
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JOSEPH RUDA ,
,
65 Derbyshire Drive
carlisle, PA 17013 ,
.
plaintiff ,
.
,
,
v. :
,
.
STEPHEN SJOBERG ,
,
105 Charles street ,
,
Carlisle, PA 17013 :
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNA
fJt- 331'3 C~;fjL
,
NO.
CIVIL ACTION - LAW
PRAECIPE TO ISSUE WRIT OF SUMMONS
TO THE PROTHONOTARY:
Please issue a Writ of Summons for service upon the
Defendant in the above-captioned case.
Respectfully submitted,
Dated: & lit;. /,q?
/
SCHMIDT & RONCA, P,C,
By -;;;0( D)l&>j{~,_
Todd D. Getgen /
Attorney for plaintiff
ID # 80719
209 State Street
Harrisburg, PA 17101
(717) 232-6300
.
Commonwealth of Pennsylvania
County of Cumberland
Joseph Ruda
Court of Common Pleas
va.
Stephen Sjoberg
105 Charles St.
Carlisle PA 17013
No.
98-3393 Civil Term
-----------------------------~-------
19____
III - __ ___~_~ y_~~__ ~ ~~_~~!l__::___~_~~__m________
To ___ ___~ t_'illh\:!IU;.i9J:2S!J::9_:________ _________
Y Oil are hereby notified ilia t
.---------__________________________~9_~~_e~__~_~~~______________________________________________
the Plaintiff h:ll commenced an action in ______~_1,1_IT2~_C!.I}_s__.:___~_~y_:!:~__~_~~i.~!1__::___~~~__________
against you which you are required to defend or a default judgment may be entered against you,
(SEAL)
CURTIS R, LONG
Date
June 18.
98
19____
.------------------------------------------------
pro.thrOj,ry
",---, ~-Ii"'it1-~-------
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JOSEPH RUDA ,
.
.
.
Plaintiff :
,
.
v. .
.
:
STEPHEN SJOBERG .
.
,
.
Defendant .
.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNA
NO. 98-3393 civil
CIVIL ACTION - LAW
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
55:
COUNTY OF DAUPHIN
I hereby certify that on October 16, 1998, I mailed a true
and correct copy of Plaintiff's Rule to Show Cause to the
Defendant, Stephen Sjoberg, at 46-48 East Pomfret Street,
Carlisle, PA 17013, by United States First Class Mail,
Certified, Return Receipt Requested, as evidenced by the Receipt
for Certified Mail No, P170661330 attached hereto.
I hereby certify that Plaintiff's Rule to Show Cause was
served upon Defendant Stephen Sjoberg on October 26, 1998, at
46-48 East Pomfret Street, Carlisle, PA 17527, as evidenced by
the Return Receipt for Merchandise card No. P170661330, attached
hereto,
SCHMIDT AND RONCA, P. C.
By ~crddD+~
Todd D, Getgen -
Attorney at Law
I.D. No. 25631
209 State Street
Harrisburg, PA 17101
(717) 232-6300
Sworn and subscribed to
before me this 11ft day
Of,.ar(h<<d~ ' 1999,
~~ 'il1 ,bJ1l~
Ncl:ary Public
My Commission Expires:
NOillRIIIL SEfaL public
S1I5/\N M, LaVIII, ~lo i~n county
City 01 Hn!liSbUhg~~~~~ct. 16, 2000
My Comrl1lsslon "^,
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5c.hmkit and Ronca. PC
November 16, 1998
209 Stat!: Street
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717 /232-6300 r,l;( 7J7/ 232-6461
.\aOf il/~Y5 ,m<l Counselors at L1W
------------
Mr. Joseph Ruda
65 Derbyshire Drive
Carlisle, PA 17013
RE: Rule to Show Cause
Dear Joe:
Enclosed is a letter which I forwarded to you by certified mail and
which you did not pick up from the post office. My original letter
of October 14, 1998 and the original RUle to Show Cause is
enclosed. Please acknowledge receipt of the letter and the RUle by
signing this letter where indicated and returning it to me in the
envelope provided.
If there is anything you do not understand, please contact me.
Very truly yours,
SCHMIDT AND RONCA, P.C.
-- --:'\ ,f/,
I c--de"( V ~1J.t;Yl''--
Todd D. Getgen
Attorney at Law
TDG/caw
Enclosures
ACKNOWLEDGEMENT OF RECEIPT
I hereby acknowledge receipt of an October 14, 1998 letter
from my attorney, Todd D. Getgen, Esquire, enclosing a Rule to Show
Cause which was originally sent to me by certified mail, return
receipt requested. '
DATE: i /-;)1.../ -f) k'
fv~~
Je;ieph Ru a \
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99HB.{)0020
LA W OFFICES OF .JACOBS & SABA
W. Darren Powell, Esquire
214 Senate Avenue, Suite 503
Camp lIi11, PA 17011
Telephone Number: (717) 731-0988
Attorne for Defendant Ste hen S'oher
IN TilE COURT OF COMMON PLEAS
CUM8ERLAND COUNTY, PENNSYLVANIA
JOSEPH RUDA,
PLAINTIFF
VS.
No. 98-3393-CIVIL
STEPHEN SJOBERG,
DEFENDANT
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PRAECIPE FOR RULE TO FILE COMPLAINT
TO THE PROTIIONOTARY:
Please enter a RULE upon Plaintiff to file a Complaint within twenty (20) days hereof
or suffer the entry of a Judgment of Non Pros.
Date:
Febmary 25. 1999
j)~\? -- ~t
W. Darren Powell, Esquire
Attorney for Defendant
RULE TO FILE COMPLAINT
AND NOW, this-iL day of C) f. 6 ru-.trV , 1999 a RULE is hereby
entered upon the Plaintiff to file a Comp~int herein witJ/in twenty (20) days after service
hereof or suffer the entry of a Judgment of Non Pros,
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99HB.00020
LAW OFFICES OF JACOBS & SABA
W. Darren Powell, Esquire
214 Senate Avenue, Suite 503
Camp Hill, PA 17011
Telephone Number: (717) 731-0988
Attorne for Defendant Ste hen S'ober
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JOSEPH RUDA,
PLAINTIFF
No. 98-3393-C1VIL
VS.
STEPHEN SJOBERG,
DEFENDANT
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
DEFENDANT'S ANSWER WITH NEW MATTER TO
PETITION FOR LEAVE TO WITHDRAW AS COUNSEL
AND NOW, comes Defendant Stephen Sjoberg, by and through his attorney, W,
Darren Powell, Esquire, of the Law Offices of Jacobs & Saba, and files this Answer with New
Matter to the Petition for Leave to Withdraw as Counsel, states as follows:
1-3. Admitted.
4-15. After reasonable investigation, Defendant is without infonnation or knowledge
sufficient to fonn a belief as to these avennents,
NEW MATIER
1. The undersigned has recently been retained to represent Defendant Stephen Sjoberg
in connection with this case,
2, The undersigned has, on this date, entered his appearance on behalf of Defendant
Stephen Sjoberg and filed a Praecipe directing that Plaintiff be ruled to file a Complaint.
JOSEPH RUDA :
:
plaintiff .
.
.
.
v. :
.
.
STEPHEN SJOBERG :
0
.
Defendant .
.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNA
NO. 98-3393 civil
CIVIL ACTION - LAW
ORDER
AND NOW, this
LIlA
day of
t/I~
, 1999,
upon consideration of the Petition to Make Rule Absolute
filed by Attorney Todd D. Getgen, attorney of record for the
Plaintiff, Joseph Ruda, it is hereby ordered and decreed
that the Rule to Show Cause issued by this Court on October
7, 1998 is made absolute and Plaintiff's counsel, Todd D.
Getgen, is granted leave
Plaintiff, Joseph Ruda, effective immedia
J.
,WICL lJ7~i{l.(C ~p-1Yf
-'=1777
JOSEPH RUDA
.
.
plaintiff .
.
v. .
.
.
.
STEPHEN SJOBERG :
:
Defendant :
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNA
NO. 98-3393 civil
CIVIL ACTION - LAW
PETITION TO MAKE RULE ABSOLUTE
AND NOW COMES Plaintiff's counsel, Todd D. Getgen,
Esquire, of Schmidt and Ronca, P.C., and respectfully asks
the Court to allow the above-stated attorney to withdraw as
counsel for the Plaintiff by signing an Order making this
Court's Rule to Show Cause absolute, and respectfully avers
as follows:
1. On october 5, 1998 Plaintiff's counsel, Todd D.
Getgen, filed a motion for leave to withdraw as counsel of
Plaintiff, Joseph Ruda.
2. On October 7, 1998 this Honorable Court issued a
rule, signed by the Honorable Judge Edward E. Guido, to show
cause why Plaintiff's counsel should not be granted leave to
withdraw within 30 days. (See a copy of the Rule to Show
Cause attached as Exhibit A) .
3. The Rule had a returnable date of twenty (20) days.
4. In excess of four months have elapsed and the
plaintiff has made no response to the Motion for Leave to
withdraw or to the Rule.
5. The only response to the Rule was made by counsel
for the Defendant on February 25, 1999, long after the
twenty-day period prescribed in the Rule to Show Cause, in
the form of an Answer with New Matter to the Motion for Leave
to withdraw as Counsel. (See a copy of the Defendant's
response attached as Exhibit B) .
6. At argument, the Defendant's only request was that
the case proceed without delay. The Defendant has no
objection to the withdrawal of Plaintiff's counsel.
7. It is the Defendant's plan to issue a twenty-day
rule on Plaintiff and Plaintiff's counsel to file a
complaint.
8. Plaintiff's current counsel therefore respectfully
requests that the Rule to Show Cause be made absolute
immediately so that withdrawal as counsel is complete before
said counsel, Todd D. Getgen, is required to file suit on
behalf of Plaintiff, Joseph Ruda.
Respectfully submitted,
SCHMIDT & RONCA, P.C.
Dated:
3/3/ C;c;
/ I
By
Todd D. Getgen
Attorney for Plai tiff
ID # 80719
209 State street
Harrisburg, PA 17101
(717) 232-6300
/Odd /
2
JOSEPH RUDA IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNA
plaintiff .
.
.
.
v. . NO. 98-3393 civil
.
.
.
STEPHEN SJOBERG .
.
:
Defendant . CIVIL ACTION - LAW
.
RULE TO SHOW CAUSE
AND NOW, this
7CAd ft'"
ay 0 ~(' Cc-t.r.!,-,
, 1998, upon motion of
Plaintiff's counsel, .leave to withdraw, a Rule is hereby issued
0..,( L.if.,.k.i
upon Joseph Rudall to show cause why leave to withdraw as counsel
should not be granted, allowing thirty (30) days for Plaintiff,
Joseph Ruda, to obtain new counsel.
RULE RETURNABLE
~~ 0
days after serviceAf'<r-- aLe :~;:t;..;J .
BY THE COURT:
,LI) <lI I
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T!nJ:~ rr;DY f""'~j ~-:r~"'D
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ii~~;~i%~~,t~i~~~;lt.;~;~t;:W~!'
JOSEPH RUDA . IN THE COURT OF COKMON PLEAS
.
. OF CUMBERLAND COUNTY, PENNA
.
Plaintiff .
.
.
.
v. . NO. 98-3393 civil
.
.
.
STEPHEN SJOBERG .
.
.
.
Defendant . CIVIL ACTION - LAW
.
CERTIFICATE OF SERVICE
AND NOW this 3 K,Pday of March, 1999, I, Todd D.
Getgen, Esquire, hereby certify that I have this day served
a true and correct copy of Plaintiff's counsel's PETITION TO
MAKE RULE ABSOLUTE by depositing same in the United states
Mail, certified letter, return receipt requested, first
class postage prepaid, at Harrisburg, Pennsylvania,
addressed to:
Plaintiff:
Joseph RUda
65 Derbyshire Drive
Carlisle, PA 17013
Counsel for Defendant, Stephen Sjoberg:
W. Darren Powell
JACOBS & SABA
214 Senate Avenue
Suite 503
Camp Hill, PA 17011
Respectfully SUbmitted,
Dated, JV'~~
SCHMIDT & RONCA, P.C.
~
By c:J?k/:I:2d ' ;q
Todd D. Getgen
Attorney for PI intiff
ID # 80719
209 State street
Harrisburg, PA 17101
(717) 232-6300
JOSEPH RUDA
65 Derbyshire Drive
Carlisle, PA 17013
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNA
v.
NO. 98-3393 Civil
STEPHEN SJOBERG
105 Charles Street
Carlisle, PA 17013
CIVIL ACTION - LAW
PRAECIPE
TO TnE PROTHONOTARY:
Please withdraw my appearance as counsel of record for the
Plaintiff, Joseph Ruda.
Respectfnlly submitted,
SCHMIDT & RONCA, P.C.
Da tee: .3 . d..;) -'1'1
,tiiICJ /
Todd D. Getgen
Attorney for Plain
ID # 80719
209 State Street
Harrisburg, PA 17101
(717) 232-6300
By
JOSEPH RUDA IN THE COURT OF COMMON PLEAS
. OF CUMBERLAND COUNTY, PENNA
.
plaintiff
:
v. . NO. 98-3393 civil
.
STEPHEN SJOBERG .
.
Defendant . CIVIL ACTION - LAW
.
CERTIFICATE OF SERVICE
AND NOW this d(~!~day of March, 1999, I, Todd D.
Getgen, Esquire, hereby certify that I have this day served
a true and correct copy of Plaintiff's counsel's PRAECIPE
WITHDRAWING APPEARANCE by depositing same in the united
states Mail, first class postage prepaid, at Harrisburg,
Pennsylvania, addressed to:
Plaintiff:
Joseph Ruda
65 Derbyshire Drive
Carlisle, PA 17013
Counsel for Defendant, stephen Sjoberg:
W. Darren powell
JACOBS & SABA
214 Senate Avenue
suite 503
camp Hill, PA 17011
Respectfully submitted,
SCHMIDT & RONCA, P.C.
Dated: ~ /~j 161
BYTo~l:~4ff~
Attorney for Plaintiff
ID # 80719
209 State Street
Harrisburg, PA 17101
(717) 232-6300
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2, At the time of the accident, Plaintiff was insured with an automobile insurance policy
issued by Penn National Insurance, Policy No. 12 00 134 606 (hereinafter the "Policy").
ANSWER:
Stephanie E. Chertol" R.N., Esq.
ArJOI<NJ,Y AT I.,\\\,
61 Wesl Loather Street
Carlisle. PA 17013-2936
(717) 24<)-1177
FAX (7 J7) 24').4514
October 23. 2000
'.Ion. George E. Horter, 1'..1,
1 Courthouse Square
Carlisle, I'A 17013
RE: Ruda v. Sjoberg, No, 98-3393
Dear Judge HolTer:
Please be advised that the above captioned case has now been settled and therefore thc
arbitration that was schedulcd for November 8, 2000, will now be canceled. The filc has been
returned to thc Prothonotary.
A copy of the lettcr of notilication of settlcmcnt dated Octobcr 17,2000. li'om Attorncy
Rickards is enclosed. Thank you for entrusting this assignmcnt to me.
Vcry truly yours,
S~Mvv- 2. C>~/~
Stcphanie E. Chertok
Enclosure
SEC/jsa
.
.JACOBS & SABA
(NOT A PAann:K.SIIIP)
214 SENATE AVENUE
SUITE 503
CAMP HILL, PA 17011
(717) 731.o9fll1
FAX: (717) 731-09117
TDD (800) 611.1411
DoNWl R. Do.ER
GIRARD F_ RICKARDS-
AnORNEYS
DEN151 E. KAUffMAN,
LmCATlOI'f PAJtAUGAl.
"CnnnlD CML TRlALADVOCATY.
NATIONAL BoARD or TRIAL ADVOCACY
RInK To: 99HB-00020
October 17, 2000
Stephanie E. Chertok, Esquire
(Arbitration Chairman)
61 West Louther Street
Carlisle, P A 17013
Re: Joseph Ruda vs. Stephen Sjoberg
Cumberland County: No. 98-3393-Civil
Arbitration - November 8, 2000
Dear Ms. Chertok,
I represent Stephen Sjoberg in a lawsuit filed by Joseph Ruda, You scheduled an
arbitration hearing for November 8, 2000 at 9:00 a.m. in the Fifth Floor Hearing Room of the
Cumberland County Courthouse. Please be advised that the parties have reached a settlement and
the arbitration hearing will be unnecessary. Please let me know if you require anything further
from me.
Thank you for the professional courtesies you have extended in this matter.
GER:lsw
Enclosures
c: Dirk Berry, Esquire
Nora Gibson, Esquire
James J. Kayer, Esquire
Employees ofN.tionwide@ Mutual Insurance Company
Bethlehem' Camp Hill' C.anonsburg' Doylestolm' Otecnsburg' Mcdi.. NorriItown. ~hiladelphi.. Wurend&l.' Wilkes BlrtO
99HB-00020
LAW OFFICES OF JACOBS & SABA
214 Senate Avenue, Suite 503
Camp Hill, PA 17011
Telephone Number: (717) 731-0988
Attorne s for Defendant Ste hen S'ober
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JOSEPH RUDA,
PLAINTIFF
VS.
No. 98-3393-ClVIL
STEPHEN SJOBERG,
DEFENDANT
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PETITION FOR APPOINTMENT OF ARBITRATORS
TO TIIE HONORABLE, THE runGES OF TIIE SAID COURT:
Girard E. Rickards. Esquire
respectfully represents that:
, counsel for the Defendant in the above action,
I. The above-captioned action \s at issue.
2. The claim of the Plaintiff in the action is $ unliauidated oersonal injury
damages,
The counterclaim of the Defendant in this action is $
The following attorneys are interested in the case as counselor are otherwise disqualified to sit
as arbitrators: Girard E, Rickards. Esquire. Attorney for Defendant
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to
whom the case shall be submitted.
Respectfully submitted,
Date: June 29. 2000
LAW OFFICES OF JACOBS & SABA
~'
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By: ./ L.' C_;;::c, . ~ ._
'Girard E. Rickards, Esquire
Attorney for Defendant.
Identification No. 58867
99HB-00020
LAW OFFICES OF JACOBS & SABA
214 Senate Avenue, Suite 503
Camp Hill, PA 17011
Telephone Number: (717) 731-0988
Attorneys for Defendant Ste hen S'ober
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
JOSEPH RUDA,
PLAINTIFF
VS.
No. 98-3393-CIvIL
STEPHEN SJOBERG,
DEFENDANT
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
Girard E. Rickards, Esquire, hereby certifies that he is the attorney for Defendant
Stephen Sjoberg herein, and that he caused a true and correct copy of Petition for
Appointment of Arbitrators to be served by regular first class mail upon:
Joseph Ruda
65 Derbyshire Drive
Carlisle, PA 17013
Dated: June 29, 2000
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Girard E. Rickards, Esquire
Attorney for Defendant
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