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Home My WebLink About98-06302 ~ ~. . : ~' .. \I \t ~. CQ ~ ~ . ) . ""( ~ \ I '" ~.., .... .~- ~ I ,I ~I ~i i I .-1 .5\ uj ! I r11 <::)1 t()! ~l I .1 ~. :\0"1'1('1.\ I.c han dcmandado a lIstcd cn la cortc Si list cd qllicrc dcrcndcrsc dc cstas dCl1landas cxpllcstas cn las paginas sigllicnlcs. lIslcd licnc vicnlc (~O) dias dc plazo alpartir dc la Iccha dc 101 dcmanda y la nolilicacion. Ustcd dcbc prcscntar una aparicncia cscrita 0 cn pcrsona 0 pur abogado y .lrchivar cn la cortc cn forma cscrila SllS dcfcnsas 0 SllS objcctioncs alas dCl1landas cn contra dc SlI pcrsona. Sca adisado qllc si ustcd no sc dclicndc, la sin prcvio aviso 0 nOlilicacion y por cualquicr quja 0 pucdc pcrdcr dincro 0 sus propicdadcs 0 olros dcrcchos importantcs para lIstcd. LLEVE ESTA DEMANDA A UN ABOGADO IlvlI\IEDIATAMENTE. SI NO T1ENE ABOGADO 0 SI NO THiNE EI. DINERO SUFICIENTE DE PAGAR TAL SER VICIO, VAYA EN I'ERSONA 0 LI.AME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY B,\R ASSOCIATION 2 Libcrty Avcnuc Carli sic, I' A 17013 Tclcphonc: (717) 249-3166 ~ :i.: " John R. Nino.ky, Esquire Attorney I. D. No. 78000 GOLDBERG, KATZMAN & SIIIPMAN, P.C. 320 Market SlIcet P.O. Box 1268 I Jarri.burg, PA 17108-1268 Telephone: (717) 234-4161 AlIorney for Plaintiffs KEITH A. HANFORD and RHONDA L. HANFORD, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . .~ 1 :CIVIL ACTION - LAW v. : NO. 98-6302 MICHAEL J. BARRICK and DOYLE W. IVEY, JR., Defendants : JURY TRIAL DEMANDED COMPLAINT AND NOW, come the Plaintiffs, Keith A. Hanford and Rhonda L. Hanford, by and through their allomeys, Goldberg, Katzman and Shipman, P.C., who file this Complaint by respectfully stating the following: 1. Plaintiff, Keith A. Hanford, is an adult individual who currently resides at 430 East Main Street, Dallastown, Yark County, Pennsylvania 17313. 2. Plaintiff, Rhonda L. Hanford, is an adult individual who currently resides at 6640 Clearfield Street, Harrisburg, Dauphin County, Pennsylvania. ,. , ,~ l ,,~ Dcfcndant, Doylc W. Ivcy, Jr., is.1Il adull individual '''10 (IIltenllv ICsides at 107 ) ~:l Stoncy Run Road, Dillsburg, York County, I'cnnsylvania 170 PJ. I 4. Dcfcndant, Michael J. Barrick, is an adull individual who currcntly rcsidcs al 650 Moullluin Roud, Murysvillc, Pcrry County, Pcnnsylvaniu 17053. i ,. ~ :< . 5. The facts und occurrcnces hercinulier reluted took plucc on or ubout Novelllbcr 7, 1996al approximulcly 5:20 1'.11I. on Stutc Roule li3 South inlhc Borough ofl.cllloync, Cumberland County, Pcnnsylvaniu. 6. At that lime and place, Plainliff, Kcith A Hanford, was opcrating his 1995 Pontiac ) l .,} 'I I 1 I I I " I . , '1' 1:" Grand Am automobile which was stopped behind tramc in the southbound lane of Interstate 83. Rhonda L. Hanford was also owner of the 1995 Pontiac Grand Am. 7. At that time and place, Defendant, Michael 1. Barrick, was opemting his 1991 Ford Ranger which was traveling in the southbound lane of Interstute 83. Michael J. Ilarrick's motor vehicle was behind Plaintiffs vehicle which was stopped in tramc in the southbound lane of Interstate 83. 2 ll, At t hatlimc and placc, Dcfcndant, Doylc W Ivc)', Jr, was opcrating his 1995 GMC V,lI1dura which was traveling in thc slIuthhllUlll1 of flltcrslatc llJ. Dcfcndanl Il'cy's vchiclc was bchind I'lainlil1;;' vchiclc IIhkh was sloppcd inllal1ic in thc slIuthbolllllllanc of Il1Icrstatc ILl. COllNTI Kcith A. 1I11nford lInd Rhondn L. 1/1Inford. 1'lnintilTs ". llo,'lc \Y. h'c\', .11'" I>cfl'llllnnl 9, I'laintil1s hcrcby incorporate thc avennents contained in paragraphs I through 8 as though fully stated herein at length, 10, Defcndant Ivcy's automobile struck thc rcar portion of the vchiclc in frol1l of him which struck the rear portion of Plaintil1s' automobile. II, As a result ofthc collision, PlainlilTs have sulTered damages to their vehicle as well as were forced to rent an automobile while their vehicle was repaired, 12, The vehicle sulTered damages in the amount of$8,837,92, Further, PlaintilTs were forced to rent a vehicle while their Grand Am was rcpaired, and the rcntal fce totaled $600.00. 3 ,; . 13. The loregoing a.:cidel1l and damages as set Illlth herein sustained by the l'laintill"s arc the direct IInd proximate Cilllse oflhe negligence, carelessness and/or re.:klessncss of Defendant Doyle W. Ivey, Jr. who operated his vehicle as follows a tililure to have his vehicle under such corllrol ilS to be able to stop within the assured clear distance ahead, tranic conditions which were existing and of which he was or b. I1liled to keep alert IInd maintain a proper walcllllll' the presence of olher motor vehicles on the highway; c. failure to apply his brakes in suniciel1ltime to avoid striking the rear of Plaintills' vehicle; d failure to travel at II safe speed; e. tllilure to keep a proper wlltch for tranic on the highway; f. failure to drive his vehicle with due regard lor the highway and should have been aware; g. Illilure to ke<.:p proper and adequate control over his vehicle; and h. driving his vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard for the rights and safety of others and in violation of the Motor Vehicle Code of the Common wealth of Pennsylvania. t':. ""i " .~ 4 .~ WIIEIU:FOIU:, Plaintills demand judgment in their lilVor and againsl Dclcnd:lIlt Doyle W. Ivey, Jr. for $9,437.92 together wilh interest and delay damages which is an amount whil:h requires this matter being submitted to compulsol)' arbitration. CO\li'iT II Keith A. lIauflll'd and I{honda L. Hanford, PlaintilTs v. Michael.l. lIarrick. J)cfendant 14. Plaintin's hereby incorporate Ihe averments contained in paragraphs I through 13 as though fully stated herein at length 15. Defendant, Michael J, Barrick, failed to stop his automobile. and the tront portion I of his vehicle violently collided with the rear portion of Defendant Doyle Ivey's aulomobile. The front portion of Defendant Ivey's vehicle struck the rear portion of the vehicle in front of him 16. As a result of the collision, I'laintills have sutTered damage to their automobile as r ,. I I ~ . , i f,' I'';',..> ~'. " ~:. , (} V~~'t which struck the rear portion of PlaintilTs' automobile. well as were forced to incur rental expenses while their vehicle was being repaired. 17. The vehicle sulli~red damages in the amount of$8,837.92. Further, I'laintills were forced to rent a vehicle while their Grand Am was repaired, and the rental fee totaled $600.00. ':~~; ;f{ 5 !~ III The Illregoing accidenl and dama!!l's as ,,'I lilllh hell'in slIslainl'd hy Ihe I'lainlills arc Ihe direcI and proximale callSl' of Ihe negligenel', ':,lIc1essnl'ss and/m re.:kll'ssnl'ss of Defendant Michael J. Barrick who operall'd his vehide as lilll,,\\s a. f.lilure to have his vehicle under such control .IS 10 be able to SlOP within the assured clear dislanee ahead; b. Iililed to keep alert and mailllain a proper wal.:h Jilr the presen.:e 01' other molar vehicles on the high WilY; e. failure to apply his hrakes in sullieient time to avoid slriking Ihe rear of Plaintiffs' vehicle; d. f.lilure to travel at a safe speed; e. failure to keep a proper walch for Iranic on Ihe highway; 1'. lililure to drive his vehicle wilh due regard lor the highway and trallie conditions which were existing and 01' which he was or should have been aware; g. failure to keep proper and adequate control over his vehicle; and h. driving his vehicle lIpon Ihe highway in a manner endangering persons and property and in a reckless manner with careless disregard for the rights and safely of others and in violation 01' the Motor Vehicle Code of the COll1mon wealth of Pennsylvania. I 6 t..1 ...+ r \VII EI~E"'()IU:, Plailllill's demand judgmelll in their I;I\-of and againsl Defendalll Michael requires this llIatter bcing submilled to compulsory mbitratiun. J.l3arrick for $9,437.92 togcthcr with inlercst and delay damages whidl is an .nlloulIl whkh Respectfully submillcd, ,. ~ ,0' GOLl>IIERG, KATZi\L\'" & SIIII'i\L\i'l. P.c. By: /1 /:' ){ v1 J, .'., < Joh;;-J~ Esq~~ Attorney I. D. No. 78000 320 Market Street P.O. Box 1268 Harrisburg, I' A 17108-1268 Telephonc: (717) 234-4161 ~ .:~ DATE: <f /,;1/71 Attorneys for !,Iaintin's 15561.1 7 J I .. vt:IU FICATlJ}:'>i I, KEITII A. IIA!':FOIH), herehy acknllwledge thai I allllhe Plainlill' in this aclion; Ihal I have read the foregoing doculIlel1l. and that the Iilcls statcd therein arc Irue and correclto the best of my knowledge, informal ion and helief '. :.' fi I understand Ihat any Iitlsc statcmcnts hcrcin arc made suhjcct to pcnaltics of 18 I'a. C. S. Section 4904, relating to unsworn falsilicationto aUlhorities. /~;; .... "'/;:::'7 -~---7~ ~ L/' // /~c:# ~EITII A. IIANF~H; ,/ c:/ .. , DATE: ? /0 9'/' '\ 1 J i . .l ( .... KEITH A. HANFORD and RHONDA L. HANFORD, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-6302 CIVIL ACTION - LAW JURY TRIAL DEMANDED .,' v. MICHAEL J. BARRICK and DOYLE W. IVEY, JR., Defendants 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 Notice and New Matter are served, by entering a written appearance personally or by attorney and filing in writing with this Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and 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 Plaintiffs. You may lose money or property or other rights important to you. :J YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT ,'l.r-FORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. ;)1 Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 THOMAS, THOMAS & HAFER, LLP ,'J; ~F~ ~,~ ':\~ t"il eK L. ,:'! BY:~~- ~~ las B. arcello, Esquire 305 North Front Street Post Office Box 999 Harrisburg, PA 17108-0999 (717) 255-7238 :r, ,.>i;~. Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-6302 CIVIL ACTION - LAW JURY TRIAL DEMANDED KEITH A. HANFORD and RHONDA L. HANFORD, v. MICHAEL J. BARRICK and DOYLE W. IVEY, JR., Defendants ANSWER AND NEW MATTER OF DEFENDANT DOYLE W. IVEY. JR. 1. Denied. Answering Defendant is without information or belief as to the truth of the averments of paragraph 1, hence it is denied and proof is demanded at time of trial. 2. Denied. Answering Defendant is without information or belief as to the truth of the averments of paragraph 2, hence it is denied and proof is demanded at time oftrial. 3. Admitted. 4. Denied. Answering Defendant is without information or belief as to the truth of the averments of paragraph 4, hence it is denied and proof is demanded at time of trial. 5. Admitted. 1 7. Denied as stated. The averments of paragraph 7 are denied as slated 6. Denied. Answering Defendant is without information or belief as to the truth of the averments of paragraph 6, hence it is denied and proof is demanded at time of trial. pursuant to Pa.R.C.P. Rule 1029(e). 8. Denied in part and admitted in part. It is admitted that Doyle W. Ivey at said time and place was operating his 1995 GMC Vandura travelling southbound on Interstate 83. Any and all other averments are denied as stated pursuant to Pa.R.C.P. Rule 1029(e). COUNT I Keith A. Hanford and Rhonda L. Hanford. Plaintiffs v. Davie W. Ivav. Jr.. Defendant 9. The averments of paragraphs 1 through 8 are incorporated herein and made a part hereof as if set forth in full. 10. Denied as stated. The averments of paragraph 10 are denied as stated pursuant to Pa.R.C.P. Rule 1029(e). 11. Denied. Answering Defendant is without information or belief as to the truth of the averments of paragraph 11, hence they are denied and proof is demanded at time of trial. 12. Denied. Answering Defendant is without information or belief as to the truth of the averments of paragraph 11, hence they are denied and proof is demanded at time of trial. 2 COUNT II 13. Denied. The averments of paragraph 13 are denied pursuant to Pa.R.C.P. Rule 1029(e). WHEREFORE, Defendant request this Honorable Court to dismiss Plaintiffs' Complaint. Keith A. Hanford and Rhonda L. Hanford. Plaintiffs v. Michael J. Barrick. Defendant ^ ,'. !' 15. -18. The averments of paragraphs 15 through 18 are directed to a party 14. The averments of paragraph 1 through 13 are incorporated herein and made a part hereof as if set forth in full. other than Answering Defendant hence no responsive pleading is required. In the alternative, the averments of paragraphs 15 through 18 are denied pursuant to . Pa.R.C.P. Rule 1029(e). 1 ,\ WHEREFORE, Defendant request this Honorable Court to dismiss Plaintiffs' Complaint. NEW MATTER 19. Some or all of Plaintiffs' claims may be barred by the statute of limitations. 20. Some or all of Plaintiffs' claims may be barred by settlement and/or waiver. 21. Some or all of Plaintiffs' claims may be barred by Plaintiffs' contributory and/or comparative negligence. 22. Some or all of Plaintiffs' claims may be barred by Plaintiffs' assumption of risk. 3 VERIFICATION I. Doyle W. Ivey, Jr. verify that the foregoing action and that the attached document is based upon the information which has been gathered by me. my counsel and/or others on my behalf in preparation of this lawsuit. The language of the document is that of counsel and is not mine. I have read the document, and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge. information, and belief. To the extent that the contents of the document are that of counsel, I have relied upon counsel in making this Verification. I understand that intentional false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsifications made to authorities. Date: .5/$/ /~,.'t . ~ 'h/. . .1.7 t Doyl . Ivey, Jr. - " I John R. Nino.ky. (:.quire Attorney I. D. No. 78000 GOLDBERG. KATZMAN & SIIIPMAN. P.C. 320 Markel SUccI P.O. !lox 1268 HAITi.bur8. PA 17108.1268 Telephone: (717) 2344161 Attorney for Plaintiffs KEITH A. HANFORD and RHONDA L. HANFORD, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW v. : NO. 98-6302 MICHAEL J. BARRICK and DOYLE W. IVEY, JR.. Defendants : JURY TRIAL DEMANDED REPLY TO NEW MATTER OF DEFENDANT. DOYLE W. IVEY. JR. AND NOW, come the Plaintiffs, Keith A. Hanford and Rhonda L. Hanford, by and through their counsel, Goldberg, Katzman and Shipman, P.C., who file this Reply to New Matter by respectfully stating the following: 19. Denied. The allegations contained n this paragraph contain conclusions oflaw and fact to which no response is required by Plaintiffs. If a response is deemed to be required, the averments contained herein are denied. 20. Denied. The allegations contained n this paragraph contain conclusions of law and fact to which no response is required by Plaintiffs. If a response is deemed to be required, the averments contained herein are denied. 21. Denied. The allegations contained n this paragraph contain conclusions of law and fact to which no response is required by Plaintiffs. If a response is deemed to be required, the averments contained herein arc denied. 22. Denied. The allegations contained n this paragraph contain conclusions of law and fact to which no response is required by Plaintiffs. If a response is deemed to be required, the averments contained herein arc denied. CROSSCLAIM 23-25. The allegations in these paragraphs are directed at a party other than Plaintiffs. Therefore no responses by Plaintiffs are required. WHEREFORE, Plaintiffs demand judgment in their favor and against Defendants in the amount of$9,437.92 together with interest and delay damages which is an amount which requires this matter being submitted to compulsory arbitration. GOLDBERG, KATZMAN & SHIPMAN, P.c. DATE: 7 I;) I ['it( 23307.1 / ( By: John ~, ~u~~ Attorney I. D. No. 78000 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Plaintiffs 2 ~ ,'" V.:IUFICt\TIO:-i , I I I, J 'J' It KEITII t\. IIANFOJUl. hcrcby ucknowledge thut IUIll thc PlaintitT in this aclion; that I have read the forcgoing documcnt: und thutthc lilcts stutcd thcrcin arc true and correct 10 the a ---,>// //j/ ..--, ~ // ~' Ktfr~I'A. I;ANFORD - / / /' /-, /// --,/' ~ r ."' ) ,\ best ormy knowledge. infonl1ution m1(1 helic!: I understund that any fulsc stutcmcnts hcrein mc madc subjcct to penalties of 18 Pa. C. S. Section 4904, rellllingto unsworn Iillsilicationto uuthoritics. DATE: ',"'( " I,j ~... ~}, i ,! tl-r >1 ;, ..~", t . ~. ' c~ ) >. ,... , " , , ( '. , j c , " ~ r... ) ,. u :1 '1; j Michael J. Barrick 650 Mountain Road Marysville, Perry County, I' ^ 17053 Doyle W. Ivcy, Jr. 107 Stoney Run Road Dillsburg, York County,P^ 17019 . l 1M GOLDBERG, KATZMAN & SIfIPMAN, P.C. . f ,.1 I I ) , 320 Market Street P. O. Box 1268 Harrisburg, P A 17108-1268 Telephone: (717) 234-4161 Counsel for Plaintiffs '\ . .\ Date: !/I'I(f8 12411.1 ., Commonwealth of Pennsylvania County of Cumberland Keith A. Ililnford and Rhonda L. lIanford Court of Common Pleas Vs. Michael J. Barrick 650 Mountain Road Marysville, PA 17053 and ~". __..9.f,l-:!?)_Q~J:J.IliL:J:etlJ\..___m__... 19____ Doyle W. Ivey, Jr. 107 Stoney Run Road DI11sburg, PA 17019 III ___\;j.~U_!\!:;U9Jl_-:_!!'l_~_'_______________n_ the PlaintiH haS commenced an action in __~__Cblil.ActJ.ac_=-_-Law.n____________________..______ '" I I. i~j I.. r f" Ii {?t ~!. j?. !0; To n.r1i.chileLJJ__Bal:tick..aod.lloyle._b'._~\ley, Jr. You are hereby notified that .----~~~!9__~~_~~;9!_~_~~s!_~~9_~~~_J;~_~9_~fQ~9______________________________________________ against you which you are required to defend or a default judgment may be entered against you. <; ;,..-: '" ~\ (SEAL) Curtis R. Long .------------------p~th~~~~~------------------- Date __t!9~~g!L?________________ IL2B ~~-f?-:2?.J.cn:2a.:C:::____ Deputy Y'- ";/ , ., ,,\, :8~ ,t I , , I , , I , , . , , '" , , - , , , co , . , '" , I , N , el , ..... , ~ I = ti< , , e'!.'i '0 M .~ co , ~ U') . '0 '" Ul 0 , I .'< 0 I-< Ill"'" ~ " ~ ..... , ~ ~ '0 U'O" '">00 , ... " , '01-< -r-! m~ "'r- S . <II ..... :e I-< 0 ~g<c ..... 8 >'<11 :~ .... 0.... c .... .'<1-< ~ u: ....c &lcP< it'~ ~ ~ ~ Ul... '< N: c III OUlOO .....0 :\!!:I: ..... . :> c '" ''''0 o. . III <II H >, _ en ,...j :2!...N 01.....0 "'" .~ I-J ........ <110> <II.....~...co ",' c..... . c ~ .... .>: , r- " <C III Ul ,....j ::I.r-l 3: 0 a . J..l x.a <qo 00' :> <II :2 :> ....0 "':l!!SUlM.. "': '<::'0 III Ul <II Ul Ul .....N I ... c -Doc ..... ..... , .Eoci~'!"ci , .~ 0 >,,, ..... , el :E!~:l!! 80..... I ON. ,...f. :.:lE .....0 I J-)Mll.. f'oH Z , , '.... - 'l' ,n, '". ' " .... ; - ~ , . ' .' "_1.' ~~.~/' r,:) i s...; ;-:, '. c,,, _..'i'!::. ,'.....9i: MLlJ.....~ C+rl.L/2'i,~L,~ ';! \r - In The Court of Common Picas ofCumbcl'lalld County, Pennsylvania Keith ^. ",'nford, et. al. VS. Michael J. Barrick, et. ill. Serve I Michael J. Barrick No. 98-6302 Civil Now, 11/10/98 . 19_, I, SHERIFF OF Cl 1MBERLAND COUNTY, I' A, do hereby deputize the Sheriff of Perry County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. :?'f'....~1 ?f ):::j-~~<., ~--.! Sheriff of Cumberland County, PA Affidavit of Sen'icc Now, ."... 11 , 19.1L, at s: Jr o'clock 2- M. served the within to..:.. e\ 'qL~rM"",'I" upon M",~"c I -:r /3"",j, at '1,~,"J }\I_w 111..,.,[,,/,) , f'~. by handing to 1'1.. ~'c I T, '/S';w.'/' a ;{;"t.. /l"';'.s/Y"d copy of the original 0,:( 6F S"M~"".. and made known to /,; M the contents thereof So answers, AO- t? /t,_L )Y'~ Sheriffof/7".y County, P A Sworn and subscribed before me this ~~ay of/))o v el\1b....., 19 K COSTS SERVICE MILEAGE AFFIDA VIT $ llUU1Y PROTHONOTARY & RK OF COURTS BlOOMfIELD BORD, PERRY CO., PA MY COMYISSION miRES JAN. 3. 2000 $ - CIO LJ.J In .. !:2>-- - .......f- L'-:Z: x: Q:::l C <flC .W N '-'->-- '-'-c:: :>- cr:cr. <=> LJ.JW :z: :r:o.. co <fl Q\ .,--..-.-_ '0 . :: C. ,1(,;1', Vle1Ji: I ft I,. ';:. ljHm.~t.(;Ja ;::. '~>.: WY~b"~" "t YM .... CERTIFICATE OF SERVICE AND NOW, this Z- S- day of -\1,1 v' 'I" --... ,2000, I hereby \ certify that I have served the foregoing Praecipe to Enter Appearance on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Douglas B. Marcello, Esquire THOMAS, THOMAS & HAFER 305 North Front Street Harrisburg, PA 17108 John Ninosky, Esquire GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 ~;(>"l~ ChristopherJ. Khight, Esquire John It, Nmosk)', 1:S<<luirc ^lIomey Ill. No 7KINNI GOLDBERG, KATZMAN 8< SIIIPMAN,I'.C. 320 Markel Sired P.ll Box 12('K II11rri,hllrg, P^ 17108.12(,8 Telepholle: (717) 23-1-11(,) Attorney for Plaintiffs KEITH A. I.IANFORD and RHONDA L. HANFORD, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA :CIVIL ACTION - LAW v. : NO. 98-6302 MICHAEL J. BARRICK and DOYLE W. IVEY, JR., Defendants : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOT AR Y: PLEASE mark the above-captioned matter settled and discontinued, GOLDBERG, KATZMAN & SHIPMAN, P.c. By: tjt,,, MAh~ John . Ninosky, Esquire Attorney I.D. No. 78000 320 Market Street P.O. Box 1268 Harrisburg, P A 17108-1268 Telephone: (717) 234-4161 Counsel for Plaintiffs DATE: 7' I/q I 6SS84,1 II ( ;0 f