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Home My WebLink About03-0808A. MICHAEL COLEMAN, Plaintiff, Ve RONALD A. BRICKER, II, MICHELLE BRICKER, EMPIRE FIRE & MARINE INSURANCE, CO., Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL-ACTION-LAW 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 defense or objections to the claims set forth against you. Your are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TI-IlS PAPER TO YOUR LAWYER 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE #2 Liberty Avenue Carlisle, PA 17053 (717) 249-3166 Respectfully submitted, A. MICHAEL COLEMAN, Plaintiff Pro Se Dated: 6454 Taunton Road Harrisburg, PA 17111 (717) 540-5824 Fax (717) 540-5828 PENNSUMMONSNEW NOTICIA Le han demandado a usted en la cone. Si usted quiere defenderse de e stas demandas expuestas en las paginas siguien.tes., usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presenlar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las 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 previo aviso o notificacion y por cualquier queja o alivio que es pedido en la petition de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELFFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Prothon. - 77 CUMBERLAND COUNTY LAWYER REFERRAL SERVICE #2 Liberty Avenue Carlisle, PA 17053 (717) 249-3166 A. Michael Coleman, Plaintiff Pro Se STATE OF PENNSYLVANIA 6454 Taunton Road COURT OF COMMON PLEAS, Harrisburg, PA 17111 CUMBERLAND COUNTY (717) 540-5824 Fax (717) 540-5828 A. MICHAEL COLEMAN, : Plaintiff, : COMPLAINT VS. I RONALD A. BRiCKER II, MICHELLE BRICKER, EMPIRE FIRE & MARINE INSURANCE, CO., Defendant(s). : CIVIL ACTION LAW PLAINTIFF REQUESTS JURY TRIAL Plaintiff complaining of the defendants alleges as follow: 1. Plaintiff is a resident of the County of Dauphin, State of Pennsylvania with an address of 6454 Taunton Road, Harrisburg, Pennsylvania 17111; 2. Defendants RONALD A. BRICKER II and MICHELLE BRICKER herein "Bricker" are the legal owners and insured of a property known as 512 Poplar Church Road, Camp Hill, Pennsylvania 17011 and an alternate address of Christ United Methodist Church Parsonage, 400 Lincoln Street, Northumberland, PA 17857 (570) 473-3712; 3. Defendant EMPIRE FIRE & MARINE INSURANCE CO. - herein "Empire" indemnifies defendants Bricker's relevant to a Homeowners Policy, Policy # LRE470116133. Defendant Empire's address is 13810 FNB Parkway, Omaha, NE 68154, 1-800-725-3523; 4. Defendant "Brickers" maintain two dogs, which are housed at 512 Poplar Church Road, Camp Hill, Pennsylvania; 5. Defendant Bricker's dogs routinely dig holes within the circumference of the yard area at 512 Poplar Church Road, Camp Hill, Pennsylvania, said indentations are not noticeable and are camouflaged with layers of overlapping grass; 6. The volume ofundetectable holes situated within the Bricker's property at 512 Poplar Church Road, Camp Hill, Pennsylvania are extensive posing a dangerous environment; 7. Despite the on-going danger, defendant Bricker's did not take any corrective action to cover said holes, restrain their dogs, nor insure safety. FIRST COUNT - COMPENSATORY DAMAGES Plaintiff repeats, realleges, reaffirms each and every allegation as set forth in Paragraphs "1" through "7" with the same force and effect as set forth herein at length. 8. On September 12, 2002, while invited on defendant Bricker's property, plaintiff was walking within its circumference when withom visible notice, steeped into a camouflaged hole - a deep indentation concealed with overlaying grass sustaining two fractures of the fight ankle, one of which is permanent; 9. Plaintiff received medical care including x-rays, crutches, and a cast; 10. Plaintiff's ankle injury is permanent. Plaintiff endures ongoing pain and discomfort; 11. Eventually, Dr. Thompson of Arlington Associates advised plaintiff that of the two fractures one was likely to heal, while the other was a permanent, incurable injury; 12. At~ several months plaintiff continues to suffer intermittent pain, inconvenience, and occasional collapse. Plaintiff is restrained from his livelihood, and limited with physical activities; 13. The restraints plaintiff suffers - and will continue to suffer for life - include restricted ability to partake in sports, dancing, cutting the grass, running, landscaping, skiing, and other activities, which prior to the aforesaid injury were part of plaintiff's daily lifestyle; 14. In addition to the aforesaid restraint and limitation of physical activities, plaintiff routinely endures fxequent pain, collapsing and suffering sufl[ieient to relegate plaintiff to rest and intermittent immobility; 15. The aforesaid injury together with intermittent pain and suffering was as a direct and proximate result of defendant's negligence; 16. Plaintiff sues defendants Bricker and Empire for a stun which is not known, but exceeds compulsory arbitration; 17. Plaintiffreserves the right to seek leave of court and file an amended complaint when monetary damages are ascertained. By reason of the foregoing, plaintiff sues defendants Bricker and Empire for a sum exceeding statutory arbitration limits. SECOND COUNT - LIFE TIME DEPRECIATED INCOME Plaintiff repeats, realleges, realTmns each and every allegation as set forth in Paragraphs "1" through "17" with the same force and effect as set forth herein at length. 18. Plaintiff maintains two occupations A.) A Commercial Debt Collector; and B.) Real Estate Investor. Plaintiff's primary occupation as Bill Collector is intermittently affected, while secondary income of restoring and maintaining properties is significantly curtailed; 19. Plaintiff can no longer engage in medium to heavy work including, but not limited to lifting, landscaping, and/or other strenuous activities; 20. The aforesaid restraints on plaintiff's income producing activities have been diminished approximately one third for commercial debt recovery, and two thirds for property maintenance and restoration; 21. As a result of defendant Bricker's negligence, plaintiff has and will continue to be physically impaired, said disability having a lifelong corresponding effect on plaintiff's earning capacity; 22. Plaintiff sues defendants Bricker and Empire for a sum which is not known, but exceeds arbitration limitations. By reason of the foregoing, plaintiff sues defendants Bricker and Empire for a sum exceeding statutory arbitration limits. THIRD COUNT - INTERMITTENT LOSS OF INCOME Plaintiffrepeats, realleges, reaflh-ms each and every allegation as set forth in Paragraphs "1" through "22" with the same force and effect as set forth herein at length. 23. Beginning on September 13~, 2002 through mid December, 2002 plaintiff was incapacitated relevant to the aforesaid injury, including one third loss of income per primary occupation of commercial debt recovery and two thirds disabled per plaintiff's secondary occupation of real estate maintenance and restoration; 24. Plaintiff's losses are relevant to the interruption of his daily livelihood requiring frequent rest and absence from his primary occupation. The estimated loss of earnings was $4,000 per month, or $12,000; 25. Simultaneously, during the period from September 13t~, 2002 through mid Deeemher, 2002 plaintiff had several houses under restoration. Typically, plaintiff expanded 30/40 hours per week in his second occupation - property renovation to maintenance; 26. Plaintiff was restrained from doing any maintenance or restoration during a three month period necessitating hired personnel; 27. Plaintiff expended $8,000 in labor costs, a sum directly related to maintenance and restoration which would not have ensued had the aforesaid injury not occurred; 28. Plaintiff sues defendant Bricker/Empire for $20,000 represeming loss of earnings and reimbursemem for labor costs. By reason of the foregoing plaintiffrespeetfully requests that the court emer judgment jointly and severely against Bricker/Empire for $20,000. FOURTH COUNT - PUNITIVE DAMAGES Plaintiff repeats, realleges, reaffirms each and every allegation as set forth in Paragraphs "1" through "28" with the same force and effect as set forth herein at length. 29. At all times prior to plaintiff sustaining a permanent injury, defendants RONALD and MICHELLE BRICKER knew of and aggravated the dangerous environment at their homestead; 30. Defendants Bricker knowingly and without regard to safety of their children, guests, or others to their property routinely permitted their dogs to excavate holes; 31. At alt times defendant Brickers did not take any corrective action to fill the holes scattered about its property, nor to insure safety; 32. The aforesaid acts ofintemional negligence by defendant Brickers was without regard to insuring safety, while m~intaining a "who gives a damn" attitude; Defendant Brickers willfully failed to correct the dangerous environment within their 33. property; 34. As a direct and proximate result of defendant Bricker gross negligence, plaintiff sustained the aforesaid injuries, and will be physically impaired for life; 35. Defendant Brickers should be punished in the form of punitive damages for a sum to be determined. By reason of the foregoing, plaintiffrespeetfully requests of this honorable Court to enter judgment jointly and severely against RONALD A. BRICKER and MICHELLE BRICKER for punitive damages for a sum to be determined. WHEREFORE plaintiffrequests of this honorable Court to enter judgment as follows: First Count: For judgment jointly and severely against RONALD BRICKER MICHELLE BRICKER, and EMPIRE FIRE AND MARINE INSURANCE CO., for lifetime compensatory damages for a sum which is not yet known, but will exceed arbitration limits; Second Count: For judgment jointly and severely against RONALD BRICKER and MICHELLE BRICKER, and EMPIRE FIRE and MARINE INSURANCE CO., for lifetime loss of income for a sum which is not yet known, but exceeds arbitration limits; Third Count: For judgment jointly and severely against RONALD BICKER and MICHELLE BRICKER and EMPIRE FIRE and MARINE INSURANCE CO. for intermittent loss of income in the sum of $20,000; Fourth Count: For punitive damages against RONALD BRICKER and MICHELLE BRICKER for a sum to be determined; For such other relief as deemed just, together with costs, interest and disbursemems. Dated: January 3, 2002 Yours etc. TO: A. Michael Coleman, PlaintiffPro Se 6454 Taunton Road Harrisburg, PA 17111 (717) 540-5824 Fax (717) 540-5828 DEFENDANTS RONALD & MICHELLE BRICKER c/o Christ United Methodist Church Parsonage 400 Lincoln Street Northumberland, Pa 17857 DEFENDANT EMPIRE FIRE & MARINE INSURANCE CO. 13810 FNB Parkway Omaha, Nebraska 68154 brickercomplaint A. MICHAEL COLEMAN 6454 Taunton Road Harrisburg, PA 17111 (717) 540-5824 Fax (717) 540-5828 A. MICHAEL COLEMAN, Plaintiff, : -against- RONALD A. BRICKER II, MICHELLE BRICKER, EMPIRE FIRE & MARINE INSURANCE, CO., Defendant(s). STATE OF PENNSYLVANIA DISTRICT COURT COUNTY OF CUMBERLAND VERIFICATION VERIFICATION The undersigned, A. MICHAEL COLEMAN, hereby verifies that the facts set forth in the Plaintiff's Complaint with Summons are tree and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Dated: February 10, 2003 ~,~dTC HAEL COLEMAN Index No. IN THE COURT OF C(H~ON P?.~.~S CUMBERLAND COUNTY, PENNSYLVANIA Y~ar A. MICHAEL COL~%N, Plaintiff (s) , -against- RON~?.~ A. BRICKER, II, MICHELLE BRICKER, EMPIRE FIRE & MARINE INSURANCE, CO. Defendant (s) . A. MICHAEL COLEMAN, Plaintiff Pro Se Office and Post Office Address, Telephone 6454 Taunton Road Harrisburg, PA 17111 (717)540-5824 TO: Ronald A. Bricker, II Michelle Bricker c/o Christ United Methodist Church Parsonage 400 Lincoln Street Northumberland, PA 17857 Empire Fire & Marine Insurance, Co. 13810 FNB Parkway Omaha, Nebraska 68154 RONALD A BRICKER H MICHELE R BRICKER DEFENDANTS, PRO SE 400 LINCOLN STREET NORTHUMBERLAND PA 17057 570 473 7712 A. MICHAEL COLEMAN PLANTIFF STATE OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY - NO. 03-808 CIVIL VS RONALD A BRICKER II, - DEFENDANTS' MICHELE R BRICKER, -RESPONSE EMPIRE FIRE & MAIRINE INSURANCE CO - DEFENDANTS AFFIRMATIVE DEFENSES TO PLANTIFF'S COMPLAINT 1. FIRST COUNT AFTER RESONABLE INVESTIGATION, THE DEFENDANTS ARE WITHOUT SUFFICIl~NT KNOWLEDGE OR INFORMATION TO FORM A BELIEF REGARDING THE TRUTH OR FALSITY OF SAID ALLEGATION, THEREFORE SAID ALLEGATION IS DENIED. SECOND COUNT THERE IS NO KNOWLEDGE OF ANY TRUTH TO THIS ALLEGATION, THEREFORE SAID ALLEGATION IS STRONGLY DENIED. _THIRD COUNT DEFENDANTS ARE WITHOUT INFORMATION TO THE TRUTH OR FALSITY OF THIS ALLEGATION AND THEREFORE SAID ALLEGATION IS DENIED. FOURTH COUNT ON THIS COUNT, THE DEFEDANTS DO HAVE INFORMATION AND KNOWLEDGE TO THE FALSIT~-(~F SAID ALLEGATION AND THEREFORE SAID ALLEGATION SI VEHEMENTLY DENIED. SUMMARY AS ALL FOUR COUNTS ARE UNFOUNDED AND DENIED, IT IS RESPECTFULLY REQUESTED THAT PLANTIFF'S COMPLAINT BE DISMISSED WITH PRJUDICE. ,~M~ CHELE R BRICK~.R SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-00808 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COLEMAN A MICHAEL VS BRICKER RONALD A II ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a.diligent search and and inquiry for the within named DEFENDANT , to wit: BRICKER II RONALD A but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of NORTHUMBERLAND County, Pennsylvania, to serve the within COMPLAINT & NOTICE On March 20th , 2003 , this office was in receipt of the attached return from NORTHUMBERLAND Sheriff,s Costs: Docketing Out of County Surcharge Dep Northumberland 18.00 9.00 10.00 40.76 .00 77.76 03/20/2003 A MICHAEL COLEMAN & ASSOCIATES Sworn and subscribed to before me this 9 ~ day of ~ ~o~ A.D. Prothonotary SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-00808 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COLEMAN A MICHAEL VS BRICKER RONALD A II ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BRICKER MICHELLE but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of NORTHUMBERLAND County, Pennsylvania, to serve the within COMPLAINT & NOTICE On March 20th , 2003 , this office was in receipt of the attached return from NORTHUMBERLAND Sheriff,s Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 03/20/2003 Sheriff of Cumberland County A MICHAEL COLEMAN & ASSOCIATES Sworn and subscribed to before me this ~ day of ~g~ ~2 g6-3 A.D. /~ / ' Prothonot~r~ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-00808 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COLEMAN A MICHAEL VS BRICKER RONALD A II ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BRICKER RONALD A II but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On March 20th , 2003 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co 6.00 9.00 10.00 30.50 .00 55.50 03/20/2003 A MICHAEL COLEMAN & ASSOCIATES Sworn and subscribed to before me this gU day of~ ~c~ A.D. PhAIN~IFF: COLEMAN, MICHAEL P: VS: DEFENDANT: BRICKER, II, RONALD A. & D: BRICKER, MICHELLE D: 400 LINCOLN STREET (CHRIST UNITED METHODIST) D: CHURCH PARSONAGE) D: NORTHUMBERLAI~D, PA 17857 CASE #: 03 NO 0808 CTY FILED: CUMBERLAND FILE DATE: 03/02/24 DATE RECEIVED: 03/02/27 ASSIGNED TO: 2 DEF LAW FIRM: CUMBERLAND EXPIRES: 2003/03/26 : SHERIFF'S RETURN : I HEREBY CERTIFY AND RETURN I SERVED: RONALD A. BRICKER, II BY HANDING A TRUE AND ATTESTED COPY OF THE WITHIN: NOTICE & COMPLAINT PERSON SERVED: MICHELLE BRICKER DATE SERVED: 2003/03/04 CAPACITY: WIFE TIME: 3:15 PM : : PLACE SERVED: 400 LINCOLN ST. NORTHUMBERLAND PA COUNTY OF NORTHUMBERLAND AND STATE OF PEAINA,, MAKING KNOWN UNTO : HER CONTENTS THEREOF. SO ANSWERS: CHARLES S. BERKOSKI, SHERIFF BY DEPUTY: PIDCOE, DWAYNE BY: I HEREBY CERTIFY AND RETURN THAT I SERVED: MICHELLE BRICKER THE BY HANDING A TRUE AND ATTESTED COPY OF THE WITHIN: NOTICE & COMPLAINT PERSON SERVED: MICHELLE BRICKER DATE SERVED: 2003/03/04 CAPACITY : PERSONALLY TIME: 3:15 PM : : PLACE SERVED: 400 LINCOLN ST. NORTHUMBERLAND PA COUNTY OF NORTHUMBERLAND AND STATE OF PENNA., MAKING KNOWN UNTO HER THE CONTENTS THEREOF. SO ANSWERS: CHARLES S. BERKOSKI, SHERIFF BY DEPUTY: PIDCOE, DWAYN~ SHERIFF'S COSTS: $ 40.76 REC #: 21348 NO. OF ATTEMPTS: 3 DOCKET PAGE #: 03 CV 0113 In The Court of Common Pleas of Cumberland County, Pennsylvania A. Michael Coleman VS. Ronald A. Bricker II SERVE: Michel] e Bricker No. 03-808 civil Now,_ February 26, 2003 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Northmnberlanc] ' County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service' Now, ,20~, at_ o'clock M. served the within upon at by handing to a and made known to copy of the original So anawers,. the contents thereof. Sworn and subscribed before me this ~ day of ,20 . Sheriffof COSTS SERVICE MILEAGE AFFIDAVIT County, PA In The Court of Common Pleas of cumberiand County, Pennsylvania A. Michael Coleman VS. Ronald A. Bricker II SERVE: Ronald A. Bricker II No. 03-808 civil Now,_ February 26, 2003 _, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Northumberlancl ' County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, ,20 , at o'clock M. served the within upon at by handing to a and made known to copy of the original So answers~ the contents thereof. Sworn mad subscribed before me this ~ day of ,20 - Sheriff of COSTS SERVICE MILEAGE AFFDAVIT County.,_ PA In The Court of Common P~¢as of Cumberland County, Pennsylvania A. Michael Colonan VS. Ron~ld A. Bricker II et al SERVE: Ronald A. Bricker II NO. 03-808 civil NOW, FebruarY- 26, 2003 _, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now~ , 20~, at within · o'clock M. served the upon at by handing to a and made known to copy of the original So anSWers, the contents thereof. Sworn and subscribed before me this ~ day of ,20 Sheriff of COSTS SERVICE MILEAGE AFFIDAVIT County, PA Mary Jane Snyder Real Estate Deputy William T. Tully Solic/tor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania County of Dauphin : COLEMAN A MICHAEL : BRICKER RONALD A II Sheriff,s Return No. 0433-T - - -2003 OTHER COUNTY NO. 03 808 AND NOW:February 28, 2003 COMPLAINT BRICKER RONALD A II to DEF of the original at ll:30AMserved the within upon by Personally handing 1 true attested copy(les) COMPLAINT and making known to him/her the contents thereof at POE: HARRISBURG TOYOTA (FORMELY HARTMAN) 6060 ALLENTOWN BLVD. HARRISBURG, PA 17112-0000 Sworn and subscribed to before me this 3RD uay~o~ ~MARCH, 2003 ! PROTHONOTARY So Answers, Deputy Sheriff Sheriff,s Costs: $30.50 PD 02/27/2003 RCPT NO 175812 E TORO A. MICHAEL COLEMAN Plaintiff, RONALD A BRICKER II, MICHELLE BRICKER, EMPIRE FIRE & MARINE INSURANCE, CO., Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-808-Civil CIVIL-ACTION-LAW PRAECIPE TO DISCONTINUANCE ACTION WITHOUT PREJUDICE PLEASE TAKE NOTICE, that the undersigned plaintiffherein discontinues without prejudice this action on the grounds that EMPIRE FIRE & MARINE is an improper defendant) /X.~[4~hael t~ol_e~flan, Plaintiff Pro Se ~rtf54 Taunton Rbad Harrisburg, PA 17111 (717) 540-5824 Fax (717) 540-5828 TO: James Adams, Esq. Barley Snyder 126 E. King Street Lancaster, PA 17602-2893 Ronald Bricker & Michelle Bricker Christ United Methodist Church 400 Lincoln Street Northumberland, PA 17857 A. MICHAEL COLEMAN Plaintiff, YSo RONALD A BRICKER II, MICHELLE BRICKER, EMPIRE FIRE & MARINE INSURANCE, CO., Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-808-Civil CIVIL-ACTION-LAW PRAECIPE TO DISCONTINUANCE ACTION WITHOUT PREJUDICE PLEASE TAKE NOTICE, that the undersigned plaintiffherein discontinues without ~ this action on the grounds that EMPIRE FIRE & MARINE~is an improper defendan~ ~b~ ~'~ /~..~ii~hael eol_e~4~. Plaintiff Pro k6~54 Taunton Rbad Harrisburg, PA 17111 (717) 540-5824 Fax (717) 540-5828 TO: James Adams, Esq. Barley Snyder 126 E. King Street Lancaster, PA 17602-2893 Ronald Bricker & Michelle Bricker Christ United Methodist Church 400 Lincoln Street Northumberland, PA 17857