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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ann N. Decker,
CIVIL ACTION
No. 2000-75/t:/~
Plaintiff
vs.
William F. Washinger, Patricia A.
Washinger, and Douglas L.
Washinger,
Defendants
TO: William F. WashiGger, Patricia A. Washinger, and Douglas L.
Washinger, defendants.
NOTICE TO DEFEND
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 claims or
relief requested by the plaintiff. You may lose money or
property or other rights important to you.
YOU SHOULD TAKE THIS 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.
Pennsylvania Bar Association
Lawyer Referral Service
(800) 692-7375 (Pennsylvania only)
or (717) 238-6715
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ann N. Decker,
CIVIL ACTION
Plaintiff
No. 2000-75/Q
vs.
William F. Washinger, Patricia A.
Washinger, and Douglas L.
Washinger,
Defendants
COMPLAINT
NOW comes the plaintiff, Ann N. Decker, and for cause of
action against the defendants, William Washinger, Patricia
Washinger, and Douglas Washinger, says:
1.
Plaintiff is Ann N. Decker, a sui luris adult, who lives and
resides in the Borough of Shippensburg, Cumberland County,
Pennsylvania, her post office address being 215 E. King Street,
in said Borough.
2 .
Defendants are William F. Washinger and patricia A.
Washinger, sui luris adults, who live and reside in the Borough
of Shippensburg, Cumberland County, Pennsylvania, their post
office address being 185 Strohm Road, Shippensburg, Pennsylvania.
3 .
Defendant is Douglas L. Washinger, a sui luris adult, who
lives and resides in the Borough of Shippensburg, Cumberland
County, Pennsylvania, his post office address being 142 East King
Street, in said Borough.
4.
Defendants are the owner of an apartment building located in
the Borough of Shippensburg, Cumberland County, Pennsylvania,
having the post office address of 215 East King Street, in said
Borough.
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5 .
Plaintiff resides in the second floor apartment at the
aforementioned location where she has resided since June of 1997.
6 .
On or about February 4, 2000, one of the defendants, Douglas
Washinger, undertook to shovel accumulated snow from a concrete
walkway in the rear of the aforementioned premises, which walkway
connected wooden stairs leading from plaintiff's second floor
apartment to the ground level area adjacent to the apartment
building used for the storage of trash receptacles.
7 .
Subsequent to the removal of the aforementioned snow,
accumulated snow adjacent to the aforementioned concrete walkway
melted, causing water to drained onto said concrete walkway where
the same froze, thereby creating a glaze of transparent ice.
8 .
As plaintiff was traversing said concrete walkway, she fell
on said glaze of ice, causing the injuries referred to below.
9.
The negligence and carelessness of the defendants, which was
the proximate cause of the aforementioned accident last above
alleged, consisted in:
(a) Defendants failing, refusing, or
neglecting to take steps to prevent the
water resulting from the melting of
accumulated snow on the sides of the
aforementioned concrete walkway from
collecting on said concrete walkway where
the same was subject to refreezing.
(b) Defendants failure to inspect the
aforementioned concrete walkway to
determine whether or not ice had formed
as a result of the snow removal efforts
of Douglas L. Washinger.
(c) Defendants failure to discover that a
glaze of clear ice had developed on the
aforementioned concrete walkway as a
result of the accumulation of water from
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the melting of ice along the sides of the
aforementioned walkway.
(d)
Defendants failure to remove
aforesaid glaze of clear ice through
use of ice melting salt, chemicals
cinders.
(e) Defendants failure to warn plaintiff of
the existence of the aforesaid glaze of
clear ice when they knew or should have
known that failure to completely remove
the snow from the area adj acent to the
concrete walkway could result in the
melting of said snow, the accumulation of
melt water on the adjacent concrete
walkway, and the re-freezing of said
water into patches of clear ice.
(f) Defendants failure to make reasonable
preparations and exercise reasonable care
for the protection and safety of
plaintiff as his business invitee.
10.
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and
In consequence of the negligence and carelessness of the
defendants above alleged, plaintiff sustained divers, serious
bodily injuries, consisting of the following, viz:
(a) Comminuted fracture of the distal radius
on the left side.
(b) Fracture of the distal phalanx of the
fifth finger of the left hand.
(c) Nervous shock.
11.
As a consequence of the aforementioned injuries, plaintiff
was required to undergo the attention of physicians and surgeons
at the Chambersburg Hospital, thereby incurring medical expenses
as follows:
The Chambersburg Hospital
Chambersburg Anesthesia Associates
Chambersburg Imaging Associates
Orthopaedic Associates .
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$ 3,609.00
$ 360.00
$ 32.00
$ 945.00
Orthopaedic Associates .
Prescription Medication
$
$
79.00
25.17
Total .
$ 5,050.17
12.
As a further consequence of the aforesaid injuries,
plaintiff has been plagued by persistent pain and functional
limitations, and, therefore, avers that her injuries are of a
permanent nature causing residual problems for the remainder of
her lifetime.
13.
As a result of the aforesaid injuries, plaintiff has
experienced and will continue to experience great pain,
inconvenience, emotional distress, embarrassment, humiliation,
and loss of life's pleasures, and, in the future, she will,
throughout the remainder of her life, suffer great pain,
inconvenience, emotional distress, embarrassment, and
humiliation.
14.
As a direct and proximate result of the aforementioned
injuries, plaintiffnas suffered a permanent disability of a
presently indeterminable percentage.
15.
As a direct result of the foregoing, plaintiff has
experienced permanent disfigurement of her left wrist.
16.
The amount claimed by the plaintiff exceeds the
jurisdictional limit requiring arbitration under C.C.R.P. 1301-1.
WHEREFORE, plaintiff demands judgment against the defendants
in an amount in excess of twenty-five ($25,000.00) dollars and
costs of suit.
S lcove, Esq.
est Queen Street
. Box 513
Chambersburg, PA 17201
(717) 264-5194
I.D. *09837
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VERIFICATION
I, Ann N. Decker, have read the foregoing Complaint which
has been drafted by my counsel. The factual statements and/or
denials contained therein are true and correct to the best of my
knowledge, information and belief. I am authorized to make this
Verification.
This Verification is made only as to the factual averments
contained therein and not to legal conclusions and averments
authorized by counsel in his capacity as attorney for the party
or parties hereto.
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This Verification is made subject to the penalties of 18 Pa.
C.S., Section 4904, relating to unsworn falsification to
authorities which provides that, if I knowingly made false
averments, I may be subject to criminal penalties.
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Ann N. Decker
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SHERIFF'S RETURN - REGULAR
.
CASE NO: 2000-07519 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DECKER ANN N
VS
WASH INGER WILLIAM F ET AL
BRIAN BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
WASHINGER DOUGLAS L
the
DEFENDANT
at 0019:51 HOURS, on the 1st day of November, 2000
at 142 EAST KING ST
SHIPPENSBURG, PA 17257
by handing to
DOUGLAS WASHINGER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
13.02
.00
10.00
.00
29.02
So Answers:
~~~~~~
R. Thomas Kline
me this
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day of
11/02/2000
BLACK & DAVISON
By: {J 0. IJ.A
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Deputy Sheriff
Sworn and Subscribed to before
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rothonotary .
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-07519 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DECKER ANN N
VS
WASHINGER WILLIAM F ET AL
GERALD WORTHINGTON
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
WASHINGER WILLIAM F
the
DEFENDANT
, at 0015:00 HOURS, on the 27th day of October ,2000
at 500 EKING ST
SHIPPENSBURG, PA 17257
by handing to
WILLIAM WASHINGER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
13.02
.00
10.00
.00
41. 02
So Answers:
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R. Thomas Kline
11/02/2000
BLACK & DAVISON
Sworn and Subscribed to before
me this ~!::-
day of
By: A w~
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. Deputy Sh 'ff
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rothonotary
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-07519 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DECKER ANN N
VS
WASH INGER WILLIAM F ET AL
GERALD WORTHINGTON
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
WASHINGER PATRICIA A
the
DEFENDANT
, at 0015:00 HOURS, on the 27th day of October ,2000
at 500 E. KING ST
SHIPPENSBURG, PA 17257
by handing to
WILLIAM WASHINGER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
So Answers:
e'~~~~t
R. Thomas Kline
11/02/2000
BLACK & DAVISON
Sworn and Subscribed to before
me this f'!3.
day of
BY:A ,~~
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othonotary I
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GREGORY E. CASSIMATIS, ESQUIRE
Berlon & Timmel
4999 Louise Drive, Suite 103
Mechanicsburg, PA 17055
717-791-0400
Attorney J.D. # 49619
ATTORNEY FOR DEFENDANTS,
William F. Washinger, Patricia A.
Washinger, and Douglas L. Washinger
ANN N. DECKER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
TO , nn t1I./Jecker: y{,:IN> t 5vko~&;:i
NO. 2000-7519 YOIJAIlEHEREBYNOTIFiED'R) U
A WRIT,TEN, R R..E.ESPONSE TO TIfI! i:
ENCLOSED ~~"'_ t'k-I-Hr "
CIVIL ACTION _ LAW WITHIN ,TWENTY (20) DAYS FROM .
SERVICe HEREOF OR A JUDGMENT
MAY BE~ENTERED GAlNSTYou.
BY _~.." ~
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v.
WlLLIAMF. WASHINGER,PATRlCIAA.
W ASHINGER and DOUGLAS L. W ASHINGER,:
Defendants
JURY TRIAL DEMANDED
ANSWER WITH NEW MATTER TO PLAINTIFF'S COMPLAINT
AND NOW, come the Defendants, by and through their counsel, Gregory E. Cassimatis, Esquire,
and answer the Plaintiffs Complaint as follows:
1.
Admitted.
2.
Admitted with clarification. Defendants William F. Washinger and Patricia A.
Washinger reside in Southampton Township, Cumberland County.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Denied.
8. Denied.
9.(a)-(f)
10.(a)-(c)
11.
12.
13.
14.
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Denied. The allegations contained in Paragraph 9 of Plaintiffs Complaint
contain legal conclusions to which no responsive pleading is required and the
same are deemed denied.
Denied. After reasonable investigation, the Defendants are without knowledge or
information sufficient to form a belief or veracity of the allegations contained in
Paragraph 10 of Plaintiffs Complaint and the same are deemed denied and strict
proof thereof demanded.
Deuied. After reasonable investigation, the Defendants are without knowledge or
information sufficient to form a belief or veracity of the allegations contained in
Paragraph 11 of Plaintiff's Complaint and the same are deemed denied and strict
proof thereof demanded.
Denied. After reasonable investigation, the Defendants are without knowledge or
information sufficient to form a belief or veracity of the allegations contained in
Paragraph 12 of Plaintiffs Complaint and the same are deemed denied and strict
proof thereof demanded.
Deuied. After reasonable investigation, the Defendants are without knowledge or
information sufficient to form a belief or veracity of the allegations contained in
Paragraph 13 of Plaintiffs Complaint and the same are deemed denied and strict
proof thereof demanded.
Denied. The allegations contained in Paragraph 14 of Plaintiffs Complaint
contain legal conclusions to which no responsive pleading is required and the
same are deemed deuied.
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Denied. After reasonable investigation, the Defendants are without knowledge or
information sufficient to form a belief or veracity of the allegations contained in
Paragraph 15 of Plaintiffs Complaint and the same are deemed denied and strict
proof thereof demanded.
Denied. The allegations contained in Paragraph 16 of Plaintiff's Complaint
contain legal conclusions to which no responsive pleading is required and the
same are deemed denied.
WHEREFORE, Defendants demand judgment in their favor and against the Plaintiff, together
with costs of suit.
15.
16.
NEW MATTER
18.
The Plaintiff s Complaint fails to set forth a cause of action upon which relief can
be granted.
The Plaintiffs alleged fall occurred at approximately 12:30 p.m. on Saturday,
February 5, 2000.
If the Plaintiff fell as alleged, the Defendants aver that the Plaintiff s claims are
barred in whole or in part by the Plaintiffs contributory and/or comparative
negligence.
The Plaintiff s cause of action and/or right of recovery is barred or modified by
the Doctrine of Assumption of Risk as applied in the Commonwealth of
Pennsylvania.
Any condition claimed by the Plaintiff to be dangerous and/or hazardous was at
all times pertinent hereto open, obvious and conspicuous and Plaintiff knew or
17.
19.
20.
21.
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should have known of same.
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WHEREFORE, Defendants demand judgment in their favor and against the Plaintiff, together
with costs of suit.
Date: / / -If - (J?J
By:
Gre . assimatis, Esquire
Attorney for Defendants
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VERIFICATION
I, Douglas Washinger, a Defendant herein, verify that I am authorized to execute this Verification
and verify that the facts set forth in the foregoing Answer With New Matter is true and correct to
the best of my knowledge, information, and belief. This statement is made subject to the
penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities.
Date: /1-9--otJ
Name:
ashinger
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CERTIFICATE OF SERVICE
AND NOW, this /s1'3 day of /l!We..,h-er- , 2000, I, Gregory E. Cassimatis, Esquire,
Attorney for Defendants, William F. Washinger, Patricia A. Washinger and Douglas L.
Washinger, hereby certifY that I served a copy of the within Defendants' Answer with New
Matter to Plaintiffs Complaint on this date by depositing same in the United States mail, postage
prepaid, in Mechanicsburg, Pennsylvania, addressed to:
Jan G. Sulcove, Esquire
Black and Davison
82 West Queen Street
PO Box 513
Chambersburg, P A 17201-0513
Date: 11--15-00
By:
2Ca~
reg . Cassimatis, Esquire
Berlon & Timmel
4999 Louise Drive, Suite 103
Mechanicsburg, P A 17055
(717) 791-0400
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ann N. Decker,
CIVIL ACTION
Plaintiff
No. 2000-7519
vs.
William F. Washinger, Patricia A.
Washinger, and Douglas L.
Washinger,
Defendants
REPLY TO NEW MATTER
NOW comes the plaintiff, Ann N. Decker, by her attorney, Jan
G. Sulcove, Esq., and replies to the New Matter propounded by the
defendants as follows:
17.
The averments of paragraph 17 of the new matter are denied
as stated. On the contrary, the Complaint states a cause of
action against the defendants for the reasons set forth in
paragraph 9 of the aforesaid Complaint, the averments of which
are incorporated herein by reference as fully as those set out at
large.
18.
Proof of the averments of paragraph 18 of the New Matter is
demanded. After reasonable investigation, plaintiff is without
knowledge or information sufficient to form belief as to the
truth of the averments of paragraph 18 of the new matter and
strict proof thereof at trial is demanded.
19.
Proof of the averments of paragraph 19 of the New Matter is
demanded. After reasonable investigation, plaintiff is without
knowledge or information sufficient to form belief as to the
truth of the averments of paragraph 19 of the new matter and
strict proof thereof at trial is demanded.
20.
Proof of the averments of paragraph 20 of the New Matter is
demanded. After reasonable investigation, plaintiff is without
knowledge or information sufficient to form belief as to the
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truth of the averments of paragraph 20 of the new matter and
strict proof thereof at trial is demanded.
21.
Proof of the averments of paragraph 21 of the New Matter is
demanded. After reasonable investigation, plaintiff is without
knowledge or information sufficient to form belief as to the
truth of the averments of paragraph 21 of the new matter and
strict proof thereof at trial is demanded.
WHEREFORE, plaintiff demands judgment in her favor and
against the defendants, together with costs of suit.
Respectfully Submitted,
By
Ja
8 est Queen Street
Chambersburg, PA 17201
(717) 264-5194
1.D. #09837
Attorney for plaintiff
OF COUNSEL:
BLACK AND DAVISON
82 West Queen Street
Chambersburg, PA 17201
Date: November ~, 2000
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VERIFICATION
I, Ann N. Decker, have read the foregoing Reply to New
Matter which has been drafted by my counsel. The factual
statements and/or denials contained therein are true and correct
to the best of my knowledge, information and belief. I am
authorized to make this Verification.
This Verification is made only as to the factual averments
contained therein and not to legal conclusions and averments
authorized by counsel in his capacity as attorney for the party
or parties hereto.
This Verification is made subject to the penalties of 18 Pa.
e.s., Section 4904, relating to unsworn falsification to
authorities which provides that, if I knowingly made false
averments, I may be subject to criminal penalties.
Date:
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Ann N. Decker "
, 2000
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CERTIFICATE OF SERVICE
I, Jan G. Sulcove, Esq., do hereby certify that on the 2i3t
day of fL.../P"",I1"t<.
2000, I did serve a true copy of the
Plaintiff's Rely to New Matter, upon the following person at the
address indicated below:
Gregory E. Kassimatis, Esq.
Berlon & Timmel
Suite 103
4999 Louise Drive
Mechanicsburg, PA 17055
Service by:
Personal service.
-K- Service by First Class United States Mail, postage prepaid,
mailed at Chambersburg, PA, addressed as indicated above.
Overnight delivery (Airborne Express/Federal Express).
Service by placing a copy of the above document in counsel's
box in the Office of the Recorder of Deeds of Franklin
county.
Facsimile service.
Certified/Registered Mail.
Respectfully Submitted,
BLACK AND DAVISON
By
Jan G. Sulcove, Esquire
I.D. #09837
82 West Queen Street
Post Office Box 513
Chambersburg, PA 17201-0513
(717) 264-5194
Date:
/1/x.7
I
, 2000
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ann N. Decker,
Plaintiff
vs.
William F. Washinger, Patricia A.
Washinger, and Douglas L.
Washinger,
Defendants
PRAECIPE
CIVIL ACTION
No. 2000-7519
To the Prothonotary of Cumberland County:
Kindly mark the above-captioned matter ~settled and
discontinued by order of the plaintiff".
OF COUNSEL:
BLACK AND DAVISON
82 West Queen Street
Chambersburg, PA 17201
Date: November ~, 2001
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8 West Queen Street
P.O. Box 513
Chambersburg, PA 17201
(717) 264-5194
I.D. No. 09837
Attorney for plaintiff
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CERTIFICATE OF SERVICE
I, Jan G. Sulcove, Esq., do hereby certify that on the ~
day of November, 2001, I did serve a true copy of the Praecipe upon
the following person at the address indicated below:
Gregory E. Cassimatis, Esq.
Berlon & Timmel
Suite 103
4999 Louise Drive
Mechanicsburg, PA 17055
Service by:
Personal service.
~ Service by First Class United States Mail, postage prepaid,
mailed at Chambersburg, PA, addressed as indicated above.
Overnight delivery (Airborne Express/Federal Express) .
Service by placing a copy of the above document in counsel's
box in the Office of the Recorder of Deeds of Franklin
County.
Facsimile service.
Certified/Registered Mail.
Respectfully Submitted,
BLACK AND DAVISON
By
Ja G. Sulcove, Esquire
1. D. #09837
82 West Queen Street
Post Office Box 513
Chambersburg, PA 17201-0513
(717) 264-5194
Date: November ~, 2001
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