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Home My WebLink About03-2410SHOLLENBERGER & JANUZZl, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff STEPHEN M. KORNBLUM, Plaintiff JULIA A. HAIR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JURY TRIAL DEMANDED 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 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 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 SHOLLENBERGER & JANUZZl, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff STEPHEN M. KORNBLUM, Plaintiffs JULIA A. HAIR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW JURY TRIAL DEMANDED LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar 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 tomaro medidas y puede entrar una orden contra usted sin previo aviso o notoficacaion y por cualquier queja o alivio que es pedido en la peticion do demanda, usted puede perder dinero o sus propiededas o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASlSTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 SHOLLENBERGER & JANUZZl, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff STEPHEN M. KORNBLUM, Plaintiff Mo JULIA A. HAIR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O3--,,,~//~ CIVIL ACTION - LAW JURY TRIAL DEMANDED AND NOW, comes the Plaintiff, Stephen M. Kornblum, by and through his attorneys, SHOLLENBERGER & JANU??I, LLP, and respectfully represents the following: 1. Plaintiff, Stephen M. Kornblum, is an adult individual who currently resides at 388 Crossroad School Road, Newville, Cumberland County, Pennsylvania. 2. Defendant, Julia A. Hair, is an adult individual whose last known address is 98 Hair Road, Newville, Cumberland County, Pennsylvania. 3. The facts and circumstances hereinafter set forth took place on May 5, 2002, at or about 3:49 PM on SR 233 at South Side Drive, Penn Township, Cumberland County, Pennsylvania. 4. At the aforesaid time and place, Plaintiff, Stephen M. Kornblum, was the operator of a 1984 Honda Nighthawk motorcycle. 5. At the aforesaid time and place, Defendant, Julia A. Hair, was the operator of a 2002 Ford Crown Victoria. 6. At the aforesaid time and place, Plaintiff, Stephen M. Kornblum, was operating the 1984 Honda motorcycle south on SR 233 approaching the intersection of SR 233 and Southside Road. 7. At the aforesaid time and place, Defendant, Julia A. Hair, was operating the 2002 Ford Crown Victoria east on Southside Road, approaching the intersection of SR 233 and Southside Road. 8. Traffic traveling east on Southside Road must stop and then yield at the intersection of Southside Road and SR 233 for a stop sign which governs traffic traveling in that direction. 9. There was no stop sign governing the traffic traveling south on SR 233. 10. Defendant, Julia A. Hair, pulled from the stop sign in an apparent attempt to turn left onto SR 233 whereupon her car and the motorcycle being operated by Plaintiff, Stephen M. Kornblum, collided. 11. As a result of the aforesaid collision, Plaintiff, Stephen M. Kornblum, has suffered serious and permanent injuries, including but not limited to the following: (a) (b) (c) (d) (e) (f) Comminuted fracture/dislocation of the left hip; Severe soft tissue injury to the left lower extremity at the knee and thigh; Multiple contusions, abrasions and lacerations; Comminuted fracture/dislocation of the left femoral head; Left foot drop; L5 nerve root impingement with sciatica; (g) (e) (f) Left peroneal nerve palsy; Depression; Scarring and disfigurement. 12. The aforesaid collision was the direct and proximate result of the negligence of the defendant, Julia A. Hair, in operating the 2002 Ford Crown Victoria in a careless, reckless, and negligent manner as follows: (a) (b) (c) (d) (e) (f) (g) (h) Failing to slowly pull forward from a stopped position to a point where she had a clear view of approaching traffic after stopping at a crosswalk or clearly marked stop line in violation of Section 3323(b) of the PA Motor Vehicle Code. Failing to yield the right-of-way to another vehicle in the intersection in violation of Section 3323(b) of the PA Motor Vehicle Code. Failing to yield the right-of-way to another vehicle in the intersection in a manner contrary to a preferential right-of-way stop sign placed at the intersection or junction of roadways during the time that she was movoing her vehicle across or within the intersection or junction of roadways in violation of Section 3323(b) of the PA Motor Vehicle Code. Failing to yield the right-of-way to another vehicle approaching an intersection on another roadway so close as to constitute a hazard during the time that she was moving her vehicle within the intersection or junction of roadways in a manner contrary to a preferential right-of-way stop sign placed at that intersection in violation of Section 3323(b) of the PA Motor Vehicle Code. Driving her vehicle in such a manner as to deprive a motorcycle of the full use of its lane of travel in violation of Section 3523(a) of the PA Motor Vehicle Code. In failing to observe Plaintiff's vehicle on the highway. In failing to exercise the high degree of care required of a motorist entering an intersection; and In attempting to enter an intersection when such movement could not be safely accomplished. 13. As a direct and proximate result of the aforesaid injuries, Plaintiff, Stephen M. Kornblum, has undergone and in the future will undergo great pain and suffering for which damages are claimed. 14. As a further result of the aforesaid injuries, Plaintiff, Stephen M. Kornblum, has suffered and may continue to suffer a loss of earnings for which damages are claimed. 15. As a further result of the aforesaid injuries, Plaintiff, Stephen M. Kornblum, has and/or may in the future incur expenses for medical treatment and rehabilitation for which damages are claimed. 16. As a further result of the aforesaid injuries, Plaintiff, Stephen M. Kornblum, has and/or may in the future incur a loss of earning capacity for which damages are claimed. 17. As a further result of the aforesaid injuries, Plaintiff, Stephen M. Kornblum, has sustained a permanent diminution in his ability to enjoy life and life's pleasures for which damages are claimed. 18. As a further result of this collision, Plaintiff, Stephen M. Kornblum, has and/or may incur reasonable and necessary medical and rehabilitative costs and expenses in excess of the amounts paid or payable pursuant to Subchapter B of the Pennsylvania Motor Vehicle Financial Responsibility Law, Workers' Compensation or any program, group contract, or other arrangement for payment of benefits as defined in 75 Pa. C.S.^. Section 1719. 19. As a further result of the aforesaid injuries, Plaintiff, Stephen M. Kornblum, has incurred or may hereinafter incur financial expenses and losses which exceed sums recoverable under the limitations and exclusions of the Pennsylvania Motor Vehicle Financial Responsibility Law for which damages are claimed. 20. Plaintiff Stephen M. Kornblum was occupying a motorcycle at the time of the collision, which is not a private passenger motor vehicle. Therefore, Plaintiff Stephen M. Kornblum remains eligible to claim compensation for non economic loss and economic loss sustained in this collision pursuant to applicable tort law. WHEREFORE, Plaintiff, Stephen M. Kornblum demands judgment against Julia A. Hair for compensatory damages in an amount in excess of the amount requiring compulsory arbitration. Dated: Respectfully submitted, SHOLLENB/,/ERGER & JANUT?I, LLP VERIFICATIC., action and that I have read the and that the facts stated herein are true and correct to the best of my knowledge, '"-" information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 490,4, relating t'o unswom falsification to authorities. 03HB-00099 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Julia A. Hair STEPHEN M. KORNBLUM, (PLAINTIFF) VS. JULIA A. HAIR, (DEFENDANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03-2410 CIVIL ACTION - LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendant, Julia A. Hair. Respectfully submitted, LAW OFFICES OF JACOBS & ASSOCIATES Date: June 19, 2003 By:~~__- JoAn~ E. Kinzel, Esquire Attoriqey for Defendant Court I.D. 55453 03HB-00099 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite $03 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Julia A. Hair STEPHEN M. KORNBLUM, (PLAINTIFF) VS. JULIA A. HAIR, (DEFENDANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2410 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE JoAnne E. Kinzel, Esquire, hereby certifies that she is the attorney for Defendant Julia A. Hair herein, and that she caused a true and correct copy of Entry of Appearance to be served by regular first class mail upon: Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, PA 17106-0545 Dated: June 19, 2003 (~) Jo~nne E. Kinzel, Esquire Attorney for Defendant SHERIFF'S RETURN - CASE NO: 2003-02410 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KORNBLUM STEPHEN M VS HAIR JULIA A REGULAR HAROLD WEARY , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE HAIR JULIA A DEFENDANT , at 1415:00 HOURS, at 98 HAIR ROAD NEWVILLE, PA 17241 JULIA A HAIR a true and attested copy of COMPLAINT & NOTICE Sheriff or Deputy Sheriff of who being duly sworn according was served upon on the 23rd day of May by handing to to law, the , 2003 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.28 Affidavit .00 Surcharge 10.00 .00 36.28 Sworn and Subscribed to before me this /~ ~ day of o2z%~3 A.D. ' Prothonotary ~ So Answers: R. Thomas Kline 05/27/2003 SHOLLENBERGER JANUZZI Deputy She~ff 03HB-00099 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Julia A. Hair STEPHEN M. KORNBLUM~ (PLAINTIFF) VS. JULIA A. HAIRs (DEFENDANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA No. 03-2410 CIVIL ACTION - LAW 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 Answer with New Matter of Defendant Julia A. Hair to Plaintiff's Complaint 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 Answer with New Matter of Defendant Julia A. Hair to Plaintiff's Complaint or for any other claim or relief requested by the Plaintiffs. 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. CUMBERLAND COUNTY Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 03HB-00099 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Julia A. Hair STEPHEN M. KORNBLUM~ (PLAINTIFF) VS. JULIA A. HAIR, (DEFENDANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2410 CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER VgITH NEW MATTER OF DEFENDANT JULIA A. HAIR TO PLAINTIFF'S COMPLAINT AND NOW, comes the Defendant, Julia A. Hair, by her attorney, JoAnne E. Kinzel, Esquire, and sets forth the following Answer with New Matter of Defendant Julia A. Hair to Plaintiff's Complaint: 1. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 1 of the Complaint. Therefore, they are denied and strict proof is demanded. 2. Paragraph 2 of the Complaint is admitted. 3. Paragraph 3 of the Complaint is admitted to the extent that an accident took place on May 5, 2002 at approximately 3:49 p.m. on SR 233 at Southside Drive, Penn Township, Cumberland County, Pennsylvania. 4. Paragraph 4 of the Complaint is admitted to the extent that Plaintiff was operating a motorcycle at the time of the accident. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the remaining allegations in paragraph 4. Therefore, they are denied and strict proof is demanded. 5. Paragraph 5 of the Complaint is admitted. 6. Paragraph 6 of the Complaint is admitted with the qualifications set forth in paragraph 4 above, which is incorporated herein by reference as though set forth at length. 7. Paragraph 7 of the Complaint is admitted. 8. Paragraph 8 of the Complaint is admitted to the extent that a stop sign on Southside Road at its intersection with SR 233 requires motorists to stop prior to entering SR 233. 9. Paragraph 9 of the Complaint is admitted. 10. Paragraph 10 of the Complaint is admitted with the correction that Defendant had all but completed her left turn onto SR 233 when Plaintiff's motorcycle struck the rear quarter panel of her vehicle. 11. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 11 of the Complaint. Therefore, they are denied and strict proof is demanded. 12. The allegations in paragraph 12 of the Complaint, including subparagraphs (a) through (h), are denied generally pursuant to Pa. R.C.P. 1029(e). 13-19. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations in paragraphs 13 through 19 of the Complaint. Therefore, they are denied and strict proof is demanded. 2 20. The allegations in paragraph 20 of the Complaint state conclusions of law to which no response is required. WHEREFORE, Plaintiff's Complaint should be dismissed with costs in this Defendant's behalf sustained. NEW MATTER 21. Any injuries or damages allegedly suffered by the Plaintiff were the result of his own recklessness and/or gross negligence in operating his motorcycle at such a dangerously high rate of speed that he was unable to stop his motorcycle within the sight distance ahead and was unable to assess and safely respond to surrounding traffic conditions. 22. Any injuries or damages allegedly suffered by the Plaintiff were the result of his assumption of a known or obvious risk of danger, the consequences of which were known or obvious to him. WHEREFORE, Plaintiff's Complaint should be dismissed with costs in this Defendant's behalf sustained. Date: August 6, 2003 Respectfully submitted, By: LAW~C JoAnne E. K 214 Senate A OF JACOBS & ASSOCIATES el, Esquire :nue, Suite 503 Camp Hill, PA 17011 Telephone No. (717) 731-0988 Identification No. 55453 (Attorney for Defendant Julia A. Hair 03HB-00099 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Julia A. Hair STEPHEN M. KORNBLUM, (PL~NT~FF) VS. JULIA A. HAIR~ (DEFENDANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA NO. 03-2410 CIVIL ACT1ON - LAW JURY TRIAL DEMANDED VERIFICATION I, Julia A. Hair, verify that the statements made in the foregoing Answer with New Matter of Defendant Julia A. Hair to Plaintiff's Complaint are true and correct to the best of our knowledge, information and belief. I understand that false statements herein are made subject to the penalties of Pa.C.S.A. §4904, relating to unsworu falsification to authorities. Date: ~.,~x . ~ & - 03 ~.~,x~ (~-. J- J Julia A. Hair (Defendant) 03HB-00099 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Julia A. Hair STEPHEN M. KORNBLUM, (PLAINTIFF) VS. JULIA A. HAIR, (HEVENOANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2410 ClVlL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE JoAnne E. Kinzel, Esquire, hereby certifies that she is the attorney for Defendant Julia A. Hair herein, and that she caused a true and correct copy of Answer with New Matter of Defendant Julia A. Hair to Plaintiff's Complaint to be served by regular first class mail upon: Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, PA 17106-0545 Dated: August 6, 2003 JoA e~E. ~inzel, Esquire" Attorney for Defendant SHOLLENBERGER & JANUZZl, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff STEPHEN M. KORNBLUM, Plaintiff Vo JULIA A. HAIR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03--2-~-4~ ,A41O CIVIL ACTION - LAW JURY TRIAL DEMANDED AND NOW, comes the Plaintiff, Stephen M. Kornblum, by and through his attorneys, SHOLLENBERGER & JANUZZI, LLP, and files the following Answer to Defendant's New Matter: 21. The above-referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required, same is denied pursuant to Pa. R.C.P. 1029(e). 22. The above-referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required, same is denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, the Plaintiff respectfully requests that the Defendant's New Matter be dismissed and judgment entered in favor of the Plaintiff as a matter of law. Respecffully submitted, Date: SHOLLENBERGER & JANUZZI, LLP By: Attorne ; A?Shollenbe~ger, ~-sq. I.D.#34343 SHOLLENBERGER & JANUZZ. I, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff STEPHEN M. KORNBLUM, Plaintiff JULIA A. HAIR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2140 CIVIL ACTION - LAW JURY TRIAL DEMANDED Timothy A. Shollenberger, Esq., being duly sworn according to law, deposes and says that he is the attorney for the within Plaintiff, that he is authorized by Stephen M. Kornblum to make this Affidavit on his behalf, and that based on information supplied by the Plaintiff, he believes that the facts set fo~h in the foregoing Reply to New Matter of Defendant are true and correct. Ti~('o~y ~./l~ho~l'c~c~, ~'sq-. Attorney I. D. No. 34343 Sworn and subscribed before me this;-~ th day of:~, 2003. SHOLLENBERGER & JANUZZl, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff STEPHEN M. KORNBLUM, Plaintiff JULIA A. HAIR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2140 CIVIL ACTION - LAW JURY TRIAL DEMANDED AND NOW this~_ day of,~L~, 2003, I hereby certify that I have served the !ollowin,g Plaint!frs Reply to Defendant's New Matter on the following by forwarding a true an(] correct copy or same in the United States mail, postage prepaid, addressed to: JoAnne E. Kinzel, Esquire LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Date: ~'/'")/~) ;~ Respecffully submitted, SHOLLENE~ERGER & JANUZZI, LLP By: 'mothy A./~h-ollenbe~ge~, Es-q. Attorney I.D. # 34343 03HB-00099 SHOLLENBERGER & JANUZZI, LLP Timothy A. Shollenberger, Esquire 1820 Linglestown Road P.O. Box 60545 Harrisburg, PA 17106-0545 Telephone No. (717) 234-3700 Attorneys for Plaintiff Stephen M. Kornblum STEPHEN M. KORNBLUM, (PLAINTIFF) VS. JULIA A. HAIR, (OEFENOANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2410 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above-captioned case settled, discontinued and ended. Date: SHOLLENBF_. By: ~ 20 Linglestc (GER & JANUZZI, LLP ~f'~, Esquire wn Road P.O. Box 60545 Harrisburg, PA 17106-0545 (Attorney for Plaintiff) Court I.D. 34343 SHOLLENBERGER & JANUZZl, LLP 1820 Linglestown Road P.O. Box 60545 Harrisburg, Pennsylvania 17106-0545 Telephone Number: (717) 234-3700 Fax Number: (717) 234-8212 Attorneys for Plaintiff STEPHEN M. KORNBLUM, Plaintiff JULIA A. HAIR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2140 CiViL ACTION - LAW JURY TRIAL DEMANDED AND NOW this 26th day of February, 2004, I hereby certify that I have served the following Praecipe for Discontinuance on the following by forwarding a true and correct copy of same in the United States mail, postage prepaid, addressed to: JoAnne E. Kinzel, Esquire LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Date: Respectfully submitted, SHOLLEblBEJ~GER & JANUZZI, LLP /_~t~y A. Sh811'enl~ger,~-~. Attorney I.D. # 34343