HomeMy WebLinkAbout00-07416
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MARY E. RHOADS,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00- 7J.i/b CIVIL TERM
ANTHONY L. WISER,
Defendant
JURY TRIAL DEMANDED
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 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 plaintiff. You may lose money or property or
other rights important to you.
YOU SlIOULD TAKE THIS PAPER TO A 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 OUR WHERE YOU CAN GET
LEGAL HELP.
Legal Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
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MARY E, RHOADS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00- 7W, CNIL TERM
ANTHONY L. WISER,
Defendant
: JURY TRIAL DEMANDED
COMPLAINT
AND NOW, comes the Plaintiff, Mary E, Rhoads, by her attorney, Dale F, Shughart, Ir"
and makes the following complaint:
1. The Plaintiff is Mary E. Rhoads, an adult individual residing at 1182 Centerville
Road, Newville, Cumberland County, Pennsylvania,
2, The Defendant is Anthony L. Wiser, residing at 1100 Greenspring Road, Newville,
PA 17241.
3, On May 26, 1999 at about 4:30 o'clQck p. m, the Plaintiff was a rear seat passenger in
an automobile operated by Luann Brutko traveling east on Pine Road in Penn Township,
Cumberland County, Pennsylvania.
4. At said time and place, the Defendant was operating a vehicle traveling west on Pine
Road when he negligently and carelessly attempted to pass another vehicle while traveling at a
high rate of speed in a no passing zone.
5, The Defendant collided with the vehicle in which the Plaintiff was riding and forced it
off the road resulting in the injuries and damages hereinafter set forth,
6, The Defendant was negligent and careless in:
A. Speeding.
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B, Traveling too fast for conditions.
C. Attempting to pass without visibility of oncoming traffic in a no passing zone.
D, Failing to observe the other vehicle in time to avoid a collision.
7. As a result of the negligence and carelessness of the Defendant, the Plaintiff sustained
a closed head injury with loss of consciousness, cerebral concussion, laceration of the scalp and
ecchymosis around her left eye.
8. The Plaintiff was transported by ambulance to the Carlisle Hospital, treated in the
emergency room, admitted and discharged on May 28, 1999.
9, After discharge from the hospital, the Plaintiff was unable to care for herself for about
a month, which required her to live with family members.
10, As a result of her injuries, the Plaintiff sustained great mental and physical pain and
suffering, and loss of life's pleasures.
WHEREFORE, the Plaintiff demands damages against the Defendant for an amount in
excess of $25,000 plus interest and costs of suit.
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Supreme CourtLD. No. 19373
35 East High Street
Carlisle, P A 17013
(717) 241-4311
Attorney for Plaintiff
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VERIFICATION
I, the undersigned Plaintiff, hereby verify that the facts set
forth in the foregoing Complaint are true and correct to the best
of her knowledge, information and belief, and understands that
false statements herein are made subject to the penalties of 18 Pa.
C.S. ~4904 relating to unsworn falsificatio s.
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By: Evelyn M. Fahnestock,
Attorney-in-Fact
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DATE:
October / S , 2000
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VERIFICATION
I I the undersigned Plaintiff, hereby verify that the facts set
forth in the foregoing Complaint are true and correct to the best
of her knowledge, information and belief, and understands that
false statements herein are made subject to the penalties of 18 Pa.
C.S. ~4904 relating to unsworn falsifications.
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Mary E. Rhoads
By: Mary L. Lappano,
Attorney-in-Fact
DATE:
October 11 I 2000
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-07416 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
RHOADS MARY E
VS
WISER ANTHONY L
KENNETH GOSSERT
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
WISER ANTHONY L
the
DEFENDANT
, at 0015:50 HOURS, on the 7th day of November, 2000
at 1100 GREENSPRING RD
NEWVILLE, PA 17241
by handing to
TERRIE WISER (MOTHER)
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
lS.00
9.92
.00
10,00
.00
37,92
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R. Thomas Kline
11/0S/2000
DALE F. SHUGHART, .JR.
me this /'lIE-
day of
Sworn and Subscribed to before By:
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EVELYN M. FAHNESTOCK,
Executor of the Estate of
Mary E. Rhoads, deceased,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-7416 CIVIL TERM
ANTHONY L. WISER,
Defendant
JURY TRIAL DEMANDED
ORDER OF COURT
AND NOW, this JO~ day of
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, 2001, upon
consideration of the foregoing Petition, it is ordered that
settlement in compromise of this action for the sum of Seven
Thousand Five Hundred Dollars ($7,500.00) and docket costs of
Eighty-three Dollars and forty-two cents ($83.42) is approved.
Evelyn M. Fahnestock is authorized to execute the Release
prepared by Erie Insurance, and counsel fees and expenses are
approved as set forth below. The distribution is directed as
follows:
(a) Dale F. Shughart, Jr., Esquire, for reasonable costs
and expenses, in the amount of One Hundred Sixty Dollars and
forty-seven cents ($160.47);
(b) Dale F. Shughart, Jr., Esquire, for reasonable counsel
fees in the amount of One Thousand Eight Hundred Fifty-five
Dollars and fifty cents ($1,855.50); and
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(e) Evelyn M. Fahnestock, Executor of the Estate of Mary E.
Rhoads, in the amount of Five Thousand Five Hundred Sixty-seven
Dollars and three cents ($5,567.03).
By the
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EVELYN M. FAHNESTOCK,
Executor of the Estate of
Mary E. Rhoads, deceased,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-7416 CIVIL TERM
ANTHONY L. WISER,
Defendant
JURY TRIAL DEMANDED
PETITION FOR COURT APPROVAL OF
SETTLEMENT OF SURVIVAL ACTION
AND NOW, comes the Plaintiff, Evelyn M. Fahnestock, Executor
of the Estate of Mary E. Rhoads, deceased, by and through her
attorney, Dale F. Shughart, Jr., Esquire and petitions Your
Honorable Court to enter an Order permitting settlement of the
above captioned action, and in support thereof, states the
following:
1. Plaintiff in the above captioned action was Mary E.
Rhoads, an adult individual residing at 1182 Centerville Road,
Newville, Cumberland County, Pennsylvania, at the time of the
filing of the Complaint on October 20, 2000.
2. The said Mary E. Rhoads died on November 6, 2000 and,
pursuant to the provisions of her Last will and Testament dated
April 4, 1980, her daughter, Evelyn M. Fahnestock, was appointed
as her Executor, with Letters Testamentary being issued on
December 11, 2000 to Cumberland County Estate Number 21-00-1945,
which proceedings appear of record in the Office of the Register
of wills in and for Cumberland County, Pennsylvania.
3. On May 26, 1999, at about 4:30 o'clock p.m. the
Plaintiff, decedent, Mary E. Rhoads, was a rear seat passenger in
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an automobile operated by Luann Brutko traveling east on Pine
Road in Penn Township, Cumberland County, Pennsylvania.
4. At said time and place, the Defendant, Anthony L. Wiser,
was operating a vehicle traveling west on Pine Road when he
negligently and carelessly attempted to pass another vehicle
while traveling at a high rate of speed in a no passing zone.
5. The Defendant collided with the vehicle in which the
Plaintiff was riding and forced it off the road resulting in
injuries to the Plaintiff as hereinafter set forth.
6. As a result of the negligence and carelessness of the
Defendant, Plaintiff sustained a closed head injury, cerebral
concussion, laceration of the scalp and ecchymosis around her
left eye. Plaintiff was treated in the Emergency Room, admitted
and discharged on May 28, 1999.
7. Plaintiff's death was caused by a heart attack and was
not related to the automobile accident on May 28, 1999.
8. The Plaintiff has been offered a settlement of Seven
Thousand Five Hundred ($7,500.00) Dollars together with the
docket costs of Eighty-three Dollars and forty-two cents ($83.42)
by Defendant's automobile insurance carrier, Erie Insurance a
copy of which offer is attached hereto, made a part hereof and
marked Exhibit "A".
9. Defendant has submitted a proposed settlement release, a
copy of which is attached hereto, made a part hereof and marked
Exhibit "B".
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10. Counsel has previously been retained by the Plaintiff
to represent her. Attached hereto, made a part hereof, and
marked Exhibit "C", is a copy of the Contingent Fee Agreement.
11. Dale F. Shughart, Jr., Esquire, counsel for Plaintiff,
and the Petitioner Evelyn M. Fahnestock, believe that said
settlement is fair and equitable under the circumstances of this
case.
12. Dale F. Shughart, Jr., Esquire, pursuant to the
Contingent Fee Agreement, requests reimbursement of expenses in
the amount of One Hundred Sixty Dollars and eighty-nine cents
($160.89). Attached hereto, made a part hereof and marked
Exhibit "D" is a copy of the billing summary.
13. Pursuant to the Contingent Fee Agreement, Dale F.
Shughart, Jr., Esquire, also requests attorney fees in the amount
of twenty-five (25%) percent of the net amount received, which
calculates to One Thousand Eight Hundred Fifty-five Dollars and
fifty cents ($1,855.50).
WHEREFORE, Petitioner requests Your Honorable Court to:
a. Approve the settlement stated above;
b. Approve payment of counsel fees and expenses stated
above from tne funds received; and
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c. Direct distribution of the net funds recovered to
Evelyn M. Fahnestock, Executor of the Estate of Mary E. Rhoads,
as above stated.
Respectfully submitted,
By'JJ~lg~
Supreme Court I.D. 19373
35 East High Street, Suite 203
Carlisle, PA 17013
(717) 241-4311
Date: January 2, 2001
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VERIFICATION
Evelyn M. Fahnestock, Executor of the Estate of Mary E.
Rhoads, hereby verifies that the facts set forth in the foregoing
Petition For Court Approval of Settlement of Survival Action are
true and correct to the best of her knowledge, information and
belief, and understands that false statements herein are made
subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn
falsifications.
k!Jr/)n,
DATE: /.... J.... CJ/
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OF COUNSEL
F. LEE SHIPMAN
JOSHUA D. LOCK
ARTHUR L. GOLDBERG
(1951-2000)
HARRY B. GOLDBERG
(1961-1998)
RONALD M. KATZMAN
PAUL J. ESPOSITO
NEIL HENDERSHOT
J. JAY COOPER
THOMAS E. BRENNER
JOHN A. STATLER
APRIL L. STRANG-KUTAY
GUY H. BROOKS
JEFFERSON J. SHIPMAN
JERRY J. Russo
MICHAEL J. CaOCENZI
THOMAS J. WEBER
ARNOLD B. KOGAN
ROYCE L. MORRIS
EVAN J. KLINE, III
JOHN DELoRENZO
STEVEN E. GRUBB
JOHN R. NINOSKY
DAVID M. STECKEL
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JZO MARKET STREET. STRAWBERRY SQUARE
r.o. Box 1268 . HARR'SBURG, PENNSYLVANIA 17108-1268
717.234.4161.717,234,6808 (FAX)
jaS@gkslaw.com (E-mail)
GOLDBERG, KATZMAN 6> SHIPMAN, p.e,
November 21, 2000
Dale F. Shughart, Jr., Esquire
35 East High Street
Carlisle, PA 17013
Re:
Mary E. Rhoads v. Anthony L. Wiser
Cumberland County No. 00-7416 Civil Term
Dear Dale:
This letter will confirm our telephone conference of Monday, November
20, 2000 concerning this case, You have asked me to inquire of Erie whether they
are interested in increasing their prior offer to settle this case for $7,500,00, You
indicated that Mary Rhoads had recently passed away.
I will discuss this development with Erie and let you know their thoughts.
In the meantime, thank you for agreeing to an open-ended extension of time for me
to respond to your Complaint.
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CARLISLE OFFICE: 717.245.0597 . YORK OFFICE: 717.843.7912
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GENERAL RELEASE OF ALL CLAIMS
KNOW ALL PERSONS BY THESE PRESENTS, that I, Evelyn M. Fahnestock,
individually and as Executor of the Estate of Mary E. Rhoads, intending to be legally bound
hereby, and in consideration of the payment of Seven Thousand Five Hundr!ld ($7,500.00)
Dollars, receipt whereof is hereby acknowledged, have remised, released and forever discharg!ld,
and by these presents do for myself, my successors, agents, assigns, heirs and insurers hereby
remise, release and forever discharge Anthony L. Wiser, his SUCC!lssors, agents, assigns, offic!lrs,
directors, workmen, employees, and insurers, and all other persons, firms, corporations,
associations or partnerships, of and from all actions, causes of action, claims, suits, controversies,
trespasses, damages, judgments, and demands in any form whatsoever, at law or in equity, arising
from or by reason of any and all known or unknown, foreseen or unforeseen bodily or personal
injuries, or property damage sustained by Mary E. Rhoads, resulting from an automobile accident
which occurr!ld on May 26, 1999, on Pine Road, Penn Township, Cumberland County,
Pennsylvania, Said incident and claim is the subject of a civil action currently pending in the
Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No. 00-7416 Civil
Term, in which it is claimed that Anthony L. Wiser is legally liable for said accident and injuries,
which liability was and is expressly denied. The aforesaid civil action will be discontinued of
record contemporaneously with th!l execution of this Release.
It is understood and agreed that this is the compromise of a doubtful and disputed claim,
and that this Release and paym!lnt is not to be constru!ld as an admission of liability on th!l part of
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the parties released, and that the releasees deny liability therefor and intend merely to avoid
further litigation and buy their pe~ce.
The undersigned declares and represents that no promise, inducement or agreement not
stated herein has been made to the undersigned and that this Release contains the entire
agreement between the parties hereto, and that the terms of this Release are contractual and not a
mere recital.
THE UNDERSIGNED HAS READ THE FOREGOING RELEASE AND FULLY
UNDERSTANDS IT.
IN WITNESS WHEREOF, and intending to be legally bound, I have hereunto set my
hand and seal this
day of
, 2001.
WITNESS:
EVELYN M. FAHNESTOCK,
Individually and as Executor of
the Estate of Mary E. Rhoads
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
SS.
On the day of ,2001, before me, the subscriber, a Notary
Public in and for said Commonwealth and County, personally came the above named herein, and
who executed the foregoing Release and has acknowledged to me that he voluntari1y executed the
same.
In Testimony Whereof, I have hereunto set my hand and my seal.
Notary Public
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EMPLOYMENT AGREEMENT
THIS AGREEMENT, made this
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E. RHOADS, of 1182 Centerville Road,
d-{(!ct:y of
, 2000, by
and between MARY
Newville,
PA 17241, herein called "Client" and DALE F. SHUGHART, JR.,
ESQUIRE, of 35 East High Street, Suite 203, Carlisle, PA 17013,
herein called the "Attorney",
WITNESSETH:
WHEREAS, the Client, Mary E. Rhoads, was injured as a result
of a motor vehicle accident on May 26, 1999 on pine Road, near
Walnut Botom Road, Cumberland County, Pennsylvania; and
WHEREAS, Client hereby appoints the Attorney as her attorney
to prosecute a claim for damages arising out of this accident.
NOW, THEREFORE, the Client employs the Attorney and the
Attorney accepts employment, the parties hereto agree that the
fee of the Attorney shall be contingent upon a recovery being
made, which shall be twenty-five (25%) percent of whatever amount
which is recovered after payment of all unreimbursed costs and
expenses prior to the filing of a Complaint or Thirty-three and
one-third (33 1/3%) percent of the amount which is recovered
after the filing of a Complaint. The Attorney agrees to advance
reasonable costs and expenses, not to ex~eed One Thousand Five
Hundred ($1,500.00) Dollars. Such advances of costs and expenses
shall be reimbursed from a recovery. If no recovery is received,
the Client shall not be responsible to reimburse the Attorney.
If any costs or expenses are required in excess of One Thousand
Five Hundred ($1,500.00) Dollars, the Client agrees to advance
such costs and expenses as requested by the Attorney.
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It is the intention of the parties to this Agreement that
the Attorney's fees herein provided shall cover all services
required in the Court of Common Pleas prior to, during and
following a trial and/or judgment. If services of the Attorney
are required for an appeal to an Appellate Court, the parties
shall agree upon a reasonable additional fee and provisions for
costs and expenses.
Therefore, the parties hereto have set their hands and seals
the day and year first above written.
Witness:
'0/11~
ary E. Rhoads
[SEAL]
Dale F.
[SEAL]
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DALE F. SHUGHART, JR.
ATTORNEY AT LAW
35 EAST HIGH STREET
SU ITE 203
CARLISLE, PENNSYLVANIA 17013
Telephone (717) 241-4311
Facsimile (717) 241-4021
,
OF COUNSEL
HAMILTON C. DAVIS
ASSOCIA TE
JOHN J. BARANSKI, J R,
January 2, 2001
Evelyn M. Fahnestock, Executor
Estate of Mary E. Rhoads
TO: Dale F_ Shughart, Jr., Esquire
ErN 25-1802515
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LEGAL ASSISTANT
BONNIE L, COYLE
Professional services rendered as follows:
STATEMENT OF CASH ADVANCES
Mary E. Rhoads vs. Anthony L. Wiser
04/05/00 - Smart Corp, medical records
10/20/00 - Prothonotary, filing fee
10/20/00 - Sheriff, deposit on service
Total cash advances -
Receipts:
11/14/00 - Sheriff, refund
Total cash advances due -
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77 .47
45.50
100.00
$222.97
62.0S
$160.S9
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EVELYN M. FAHNESTOCK,
Executor of the Estate of
Mary E. Rhoads, deceased,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-7416 CIVIL TERM
ANTHONY L. WISER,
Defendant
JURY TRIAL DEMANDED
PRAECIPE TO DISCONTINUE
Dear Sir:
Please mark the above captioned action settled and
discontinued.
To: Curtis R. Long, Prothonotary
January 11, 2001
By.
hughar , Jr.
Court I D. 193 3
35 East High S eet, Suite 203
Carlisle, PA 17013
(717) 241-4311
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