The URL can be used to link to this page

Home My WebLink About99-00176 _......_~..._, . APADOPLO' .a4 her lu.baa4, PIT" PAPADOPL08 Pl.bUtt. I UI HI conI' O. COJQIOII P I O. cmm__LAIlD COUJl'l'Y, PIIIIIIA : 110. f4. 1'7/r? (.~/~'dJ I I I I I I I v. CIVIL ACTIOII - LAW MIllOY LII KLAUII Det.ad.at JURY TltIAL DIllUQ)ID 1I0'1'ICI YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pagGs, 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 netice 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 LOCAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 JUDITH 1. PAPADOPLOI end ber Huebland, 'RTD PlPADOPL08 >>1ainUfh Defendent I IN THR OOURT 011' OOlaCO. nllU I or OUICBRRLUD OOUll'1'Y, JPIIIIIIA I I .0. I I I OIVIL AO'1'IO. - LAW I I I I JURY TRIAL DlKlIfDRD v. ICIIIDY LII ILAUII COMPLAINT AND NOW COME the Plaintiffs, Judith Papadoplos and her husband, Peter Papadoplos, by and through their attorneys, Sohmidt and Ronoa, P.c., and respeotfully aver as follows: 1. Plaintiffs, Judith and Peter Papadoplos, are adult individuals, husband and wife, who currently reside at 109 East Woodland Drive, Mechanicsburg, CWnberland County, Pennsylvania. 2. Defendant, Mindy Lee Klaum, is an adult individual with a last known residence at 206 Lantzy Road, Meohanicsburg, CUmberland County, Pennsylvania. 3. The events which give rise to this action oocurred on or about Friday, January 24, 1997 at about 3:15 p.m. at or near the intersection of West Marble street and South Market street, Mechanicsburg, Cumberland County, Pennsylvania. The above-described date, time, and location shall hereinafter be called "the scene." 4. At the scene, Plaintiff Judith A. Papadoplos was operating 1993 Chevrolet Geo Cpa. registration plate # SUO 0419) Eastbound on West Marble street and was at a complete atop b~ind an automobile then being operated by William G. wiee. 5. At the .cene, William Wise wa. operating a 1996 OMC Sonoma pick-up truck and was at a complete .top at the eaRtbound .top sign at the inter.eotion of We.t Marble Street and Market Street in Mechanic8burg, penn.ylvania, directly in front of Judith Papadoplo.. 6. At the .cene, Def.endant, Mindy Lee Klaum, was operating a 1993 Subaru Loyale (Pa. Registration plate I ArE 3746), owned by her parents, Tom and Clare Klaum, Eastbound on West Marble Street, behind Judith Papadoplos. 7. At the 8cene, Defendant, Mindy Lee Klaum, was operating the Subaru Loyale with the knowledge and permission of the owners, Tom and Clare Klaum. 8. At the scene, Defendant, Mindy Lee Klaum, failed to bring the Sub~ru Loyale to a stop behind Judith Papadoploe and, in,stead, caused the Subaru Lcyale to collide with the rear of the Subaru, pushing the Subaru into the rear of the Sonoma pick-up truck, causing a three-car COllision. COUllT 1- NBGLIGIlfCB Juclith P.D.doDlos v. Mindv Lee 1:1.111I 1. At all relevant times, the Defendant, Mindy Lee Klaum, had a duty to drive her vehicle at a safe speed and in a safe mannsr pursuant to 75 Pa. Cons. Stat. S 3361 (driving vehicle at safe speed). 2. The Defendant, Mindy Lee Klaum, breached her duty of care by driving her vehicle at such a speed and in such a 2 manner that .he was unable to .top .in time to avoid a colli.ion, thereby cauainq a three-car re~r-end colli.ion. 3. The oolli.ion was oaused solely by the neqliqence of the Defendant and Plaintiff Judith Papadoploe in no way dau.ed or contributed to the oollision. 4. ~he Defendant's negligenoe includos, but is not limited to, the fOllowing aota or failures: a. Failing to observe other vehioles on the roadway; b. Failing to operate her vehiole in aooordanoe with the existing traffio and weather oonditions; d. Failing to keep a reasonable lookout for other vehicles on the road; d. Operating her vehicle in a manner which oreated a dangerous situation for other vehicles on the road; and e. Operating her vehicle in a manner that violated 75 Pa.C.S. S 3361 (driving vehiole at safe speed) which is negligence ~ ... 5. Plaintiff Judith Papadoplos has suffered injuries- -that have not resolved ~nd may be permanent in nature--that were caused by the trauma she received in the collision caused solely by the negligence of the Defendant. 14. plaintiff Judith Papadoplos has been obliged to expend sums and inour expenses for medioal treatment as a result of her injuries oaused solely by the negligence of the Defendant. 15. Plaintiff Judith Papadoplos 1s likely to inour expenses and to expend sums in the future for necessary 3 ..dical oare a. a re.ult of her injurie. oau.ed .olely by the nl9ligence ot the Defendant. 16. Plaintiff Judith Papadoplo. ha. mi..ed work and, a. a re.ult, incurred a lose of income due only to her injurie. caused 80lely by the neqligenoe of the Defendant; therefore, Plaintiff Judith PapadoploR make. a claim for lo.t waqe.. 17. plaintiff Judith Papadoplo. believe. and therefore aver. that .he may incur a loss of earning capacity 80lely dus to the injurie. caused by the neqligence of the Defendant. 18. Plaintiff Judith Papadoplos has experienced in the pa.t and will continue to eKpBrience in the future qreat pain and .ufferinq as a result of her injuriee cau.ed .olely by the negligence of the Defendant. 19. Plaintiff Judith Papadoplo. has suffered a permanont diminution of her ability to enjoy life and life's pleasures as a re.ult of her injurie., pain, and sufterinq caus~d solely by the neqliqence of the Defendant. WHEREFORE, Plaintift Judith Papadoplos demands judqment aqainst the Defendant, Kindy Lee Klaum, in an amount in exce.. of the amount requirinq compulsory arbitration, toqether with intere.t and cost.. 4 ). (11 tr' "" ~~ .. ~~? ('1 .-, ~;I (l~ \ , l' '.~.... -,. I rt;'I, L~; " IJ.: t., \,.. fJ, 0, 0 (jl ", ..' "'" .;#' CERTIrICATE or SERVICE - -- - AND .,,", th', _It'- d,V 0' ~' ,,99, 1, J,,"' .. .onc" .,qu"" .tto,n'V fo' ".'nt"'" h.,.bV c.,t"V th.t 1 h'" ,.".d . t'u' .nd co".ct copY of ",,'Tl"" ,......,.TOR,.. to D...."",T ,..T " upon coun," of ,.co,d bV d,pO.'t'n' ,.m. 'n th. un't.d ,t,t., N.il, 'i"t cl'" po,t.,. p"p.id, .t ."d,b"" ,en",Vl..ni., .dd"".d tOO Michael M. Badowski, Esq. ReynoldS & Havas 101 pine street P.O. BOX 932 HarrisbUrg, p~ 1710a-0932 Attorney for Defendant, 'Cm<I~ t:,,";A "c. BY / James I>/~ l\ ca, Esq. 1. 9~:':N.9' 56~ 1 At\. D etgen '7 I.D. . B0719 209 state street Harrisburg, PA 17101 (717\ 232-6300 Attorney for Plaintiffs tE c::> r:- .- c: ",' :If" ~,. .. .--)..-r ~1C1 N (~)~..'::. ~(\ :\-:: :..)~[' "L u.. r:'.'I:J ~~' lO ?: &:5 Ii .-"~1 ;;.~ ~.- -;. u'~~l t',: en i.lJ~ f!": W QJ ..... ..., IL. Cf\ => <:'1 a' U ~ t 'i, . ~ 0' ~ If; ~Q. ., ':'::J..t: - ()i... [, ;C iC'):;-e -( 0., ... :;.:.- ~L <) <-' .~ ~ lO ;':,' \13 L1 ..J,.e... o. niz f):tli "' \-~ U.J l~' W .'Ju- ..... ::3 t5 en )', (,I' (,) , JUDITH A. PAPADOPLOS and her HU.band, PETER PAPADOPLOS IN THE COURT OF Cot+fON PLEAS OF CUMBERLAND COUNTY, PENNA Plaintiff. NO. gg-176 Civil v. CIVIL ACTION - LAW MINDY LEE I<LAUM Defendant JURY TRIAL DEMANDED CERTIfICATE OF SERVICE I/Y-t) Cl!-1u.. AND NOW, this --1.__ day of JbVIA-tJV[<4", , 1999, I, I James R. Ronca, Esquire, Attorney for Plaintiffs, hereby certify that I have served a true and correct copy of PLAINTIFFS' REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT (SET I) upon counsel of record by depositing same in the United States Mail, first class postage prepaid, at Harrisburg, Pennsylvania, ,addressed to: Michael M. Badowski, Esq, Reynolds & Havas 101 Pine Street P.O, Box 932 Harrisburg, PA 17108-0932 Attorney for Defendant SCHHI~ONCA --- " P,C, By James Esq, 1. D. No Todd 0, G gen I,O, No 80719 20 S te Street H isburg, PA 17101 (717) 232-6300 ~ c> E t c:: .. ~jd' N C),.:', '''' :t (-).:";'" CJ , .?:; a.. .... -~ (,::~ ~;::! Q \0 <"(,'j R ':1 ":::~ 'l-'-. , ~' C/.) t'qH~J l.u ~;" l. U. ;; ~: l:5 CI'I '") 0' () 4"\. ..... '. .~, I ,( - ---.--- JUDITH A. PAPAOOPLOS and her KU.band, PITIR PAPADOPLOY Plaintifta Defendant IN THE COURT or Ca-tMON PLEAS I 01' OUKBIRLMD OOVll'l'Y, PIDA I I HO. 11-17. CIVIL I I I CIVIL AOTIOH - LAW I I I I JURY TRIAL DBNANDID v. IIlDY LII lIl:LAUII ORDER AND NOW this "~ day of __M--o , 1999, IT IS HEREBY ORDER~D AND DECREED, that the Plaintiff's Motion for Leave to Amend Complaint is granted. J. ~ co ~ 0 t!b .. 8~ ~p ~ :I:: 0- ~ ~~ t)~ N '~ , cD ffim II; ~i; w C\ll1. F ..... ~ ~ 0> i3 Q\ .JUDITH A. PAIADOPL08 and her Bu.baad, IITIR PAPADOIL08 Plaintiff. I II THI COURT 01' COJQCOM 'L.-. I 01' CUKlIRLAMD COUlTY, 'I~ I I 10. "-17' CIVIL I I I CIVIL ACTIO. - LAW I I I I JURY TRIlL DIKAKDID v. IIIIDY LII KLAtIII Detendant AMBNDBD COMPLAINT AND NOW COME the Plaintiffs, Judith Papadoplos and her husband, Peter Papadoplos, by and through their attorneys, Sohmidt and Ronca, P.C., and respectfully aver as follows: 1. Plaintitfs, Judith and Peter Papadop1os, are adult individuals, husband and wife, who currently reside at 109 East Woodland Drive, Meohanicsburg, CUmberland County, Pennsylvania. 2. Defendant, Mindy Lee Klaum, is an adult individual with a last known residence at 206 Lantzy Road, Meohanicsburg, CUmberland County, Pennsylvania. 3. The events which give rise to this action oocurred on or about Friday, January 24, 1997 at about 3:15 p.m. at or near the interseotion of West Marble street and South Market street, Mechaniosburg, Cumberland County, Pennsylvania. The above-described date, time, and location shall hereinafter be oalled "the soene." 4. At the scene, Plaintiff Judith A. Papadop1os was operating 1993 Chevrolet Geo (pa. registration plate # SUO 0419) Eastbound on West Marble street and was at a oomplete J', ,o' r :.\) .~J ';<l '~', . '..' "1'A. w/;,:'~". ~'\~\",~t,'I'IJ~: t~l'->'''''I ,W ;.-""'" ," stop behind an automobile then being operated by William G. wiR.. 5. At the s08ne, William Wise was operating a 1996 GMe Sonoma piok-up truok and was at a oomp1ete stop at the eastbound stop sign at the interseotion of West Marble street and Market street in Meohaniceburg, Pennsylvania, direotly in front of Judith Papadoplos. 6. At the soene, DBfendant, Mindy Lee Klaum, was operating a 1993 Subaru Loya1e (pa. Registration plate # ArE 3746), owned by her parents, Tom and Clare Klaum, Eastbound on West Marble street, behind Judith Papadoplos. 7. At the scene, Defendant, Mindy Lee Klaum, was operating the Subaru Loyale with the knowledge and permission of the owners, Tom and Clare Klaum. 8. At the soene, Defendant, Mindy Lee Klaum, failed to bring the Subaru Loyale to a stop behind Judith Papadoplos and, instead, caused the Subaru Loyale to collide with the rear of the Geo, pushing the Geo into the rear of the Sonoma pick-up truck, causing a three-car collision. OOUNT X- HlGLIGIMOB Judith PaDadoDlol v. Mindy ~.. Klaua 9. Paragraphs 1 - 8 are incorporated herein by reference. 10. At all relevant times, the Defendant, Mindy Lee Klaum, had a duty to drive her vehicle at a safe speed and in a sate manner pursuant to 75 Pa. Cons. Stat. S 3361 (driving vehicle at safe speed). 2 11. The De!endant, Mindy Le. Klaum, breached her duty of care by driving her vehicle at such a speed and in such a manner that ehe was unable to stop in time to avoid a oolli.ion, thereby causing a three-car rear-end cOlliBion, 12. The oOllision was oaused solely by the negligence of the Defendant and Plaintiff Judith Papadoplos in no way caused or contributed to the collioion. 13. The Defendant's negligenoe inoludes, but is not limited to, the following acts or failures: a. Failing to observe other vehicles on the roadway; b. Failing to operate her vehicle in accordance with the existing traffic and weather oonditions; o. Failing to keep a reasonable lookout for other vehicles on the road; d; Operating her vehicle in a manner whioh oreated a dangerous situation for other vehicles on the road; and e. operating her vehicle in a manner th~t violated 75 Pa.C.S. S 3361 (driving vehicle at safe speed) which is negligence..Rat U. 14. Plaintiff Judith Papadoplos has suffered injuries- -that have not resolved and may be permanent J.n nature--that were oaused by the trauma she receivsd in the COllision caused solely by the negligence of the Defendant. 15. Plaintiff Judith Papadoplos has been obliged to expend sums and incur expenses for medioal treatment as a result of her injuries oaused solely by the negligence of the Defendant. 3 16. Plaintiff Judith Papadoplos i. likely to incur expenses and to expend slims in the future tor necessary m.dical care as a result of her injurie. cau.ed .olely by the negligence of the Defendant, 17. Plaintiff Judith Papadoplos has missed work and, as a result, inourred a loss of income due only to her injuries caused solely by the negligence cf the Defendant; therefore, Plaintiff Judith Papadoploa makes a claim tor loat wages. 18. Plaintiff Judith Papadoplos believes and therefore avers that she may incur a loss of earning capacity solely due to the injuries caused by the negligence of the Defendant. 19. Plaintiff Judith Papadoplos has experienced in the past and will continue to experience in the future great pain and suffering as a result of her injuries caused solely by the negligence of the Defendant. 20. Plaintiff Judith Papadoplos has suffered a permanent diminution of he~ ability to enjoy life and lite's pleasures as a result of her injuries, pain, and suffering caused solely by the negligence of the Defendant. WHEREFORE, Plaintiff Judith Papadoplos demands jUdgment against the Defendant, Mindy Lee Kla"m, in an amount in excess of the amount requiring oompulsory arbitration, together with interest and costs, 4 JUDITH A, PAPADOPLOS and her Hueband, PETER PAPAOOPLOS IN THI COURT 01' CON<<)N PLEAS 01' CUMBERLAND COUNTY, PENNA P~ainti!!. NO. gg~176 Civil v, MINDY LEE KLAUM Detendant CIVIL ACTION - LAW JURY TRIAL DE~DED CERTIFICATE OF SERVIC~ AND NOW, thiS.M1'/L day of f~,(lty , 1999, I, Todd D. Getgen, Esquire, Attorney for Plaintiffs, hereby certify that I have served a true and correct copy of PLAINTIFFS' RESPONSES TO DEFENDANT'S REQUEST FOR PRODUCTION OF DOCUMENTS (FIRST SET) upon counsel of record by depositing same in the United states Mail, first class, at Harrisburg, Pennsylvania, addressed to: Michael M, Badowski, Esq. Reynolds & Havas 101 Pine street P.Q, Box 932 Harrisburg, PA 17108-0932 Attorney for Defendant Sc~~IDT AND RONCA, P.C. By -r odd llJ!il. tfL"'"'- James R, Ronca, ~q, 1. D. No, 25631 Todd D, Getgen 1.D, No, 80719 209 state street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs if f... 'h~\~ J,(jCO; '''',-, ,,j,.,. 6'~I;i' fL ~~u .....T ,r. 'i. e;;> -..... ''''"", ."" co ',. L~; .~-;? o(.}~ (.J".3 i,f'._ '. L~l ;~J ;~:S .~~! , " '.~ I,'lip. ~n w '~~ 0.. ") D N 'r-' i>:; C") N Ej l... 0, 0". '~"!"r .,...". 1', JUDITH A, PAPADOPL08 and her Hu.b*nd, PETER PAPADO~LOS IN THE COURT OF COMMON PLEAS or CUMBERlAND COUNTY, PENNA PlaintiU. NO, G5I-176 Civil v. CIVIL ACTION - LAW MINDY LEE KLAUM De!endant JURY TRIAL DEMANDED 'fodd CERTIFICATE OF SERVl]! AND NOW, this .iJ/...J.. day of ~~, 1999, I, D, Getgen, Esquire, Attorney for Plaintifts, hereby certify that I have served a true and correct copy of PLAINTIFFS' ANSwtRS TO DEFENDANT'S INTERROGATORIES (FIRST SET) upon counsel of record by depositing same in the United States Mail, first class, at Harrisburg, Pennsylvania, addressed to: Michael M, Badowski, Esq. Reynolds & Havas 101 Pine Street P,O. Box 932 Harrisburg, PA 17108-0932 Attorney for Defendant SCHMIDT AND RONCA, P. C. By '-/<fdd .~, James R, Ronca, I. D, No, 25631 Todd 0, Getgen I.D, No. 80719 209 state Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs rmn 'nr. MMIffi.ll~;'M;\lIi~~ I_'''~'~~..;'''-''.''-..O'F JUDITH A. PAPADOPL08 and her I IN THI COURT O. OONNON PLBAQ BU.band, PITI. PAPAOOPLOI I o. OUM8IR~ COUNTY, PINNA I PJ.aintif1'e I NO. "-17' OIVIL I v. I I CIVIL ACTION - LAW I MINDY LIB :<<LAUM I I Defendant I JURY TRIAL DBKANDBD NOTI,Q-I YOU HAVE BEEN SUED IN COURT. If you wish to defend against the olaims set forth in the following pages, you must take aotion within twenty (20) days after this Amended Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objeotions to the claims set forth against you. You are warned that if you fail to do so the case may prooeed without you and a jUdgment may be entered against you by the Court without furth~r notioe for any money olaimed 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 TA1<E 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 LOCAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249.'3166 JUDITH a. .a.aoo'LO. an4 hor ~.ban4, '1'1'1. .a.aoo'LO. Plaintiff, IU THI COUlT OW OOMMO. .Lal. or OUIDDLUD OOUll'l'Y, ....a MO. "-17' OIVIL v. OIVIL aCTIO. - LAW MIllOY LII ItLaUll Defen4ant JURY TRIaL DUUlDID AIlIlHOIID COII.LaIU AND NOW COME the Plaintiffs, Judith PapadoploB and her husband, Peter Papadoplos, by and through their attorneys, Sohmidt and Ronoa, P. C., and respeotfully aver as follows: 1. Plaintiffs, Judith and Peter Papadoplos, are adult individuals, husband and wife, who ourrent1y reside at 109 East Woodland Drive, Meohaniosburg, CUmberland County, Pennsylvania. 2. Defendant, Mindy Lee Klaum, is an adult individual with a last known residenoe at 206 Lantzy Road, Meohaniosburg, CUmberland County, Pennsylvania. 3. The events whioh give rise to this action ooourred on or about Friday, January 24, 1997 at about 3:15 p.m. at or near the interseotion of West Marble street and South Market street, Mechanioeburg, Cumberland County, Pennsylvania. The above-desoribed date, time, and 10oation shall hereinafter be oalled "the soene." 4. At the scene, Plaintiff Judith A. Papadoplos was operating 1993 Chevrolet Geo (pa. registration plate # suo 0419) Eastbound on West Marble street and was at a oomplete .top behind an automobile thell btIinq opeut.td by William O. wi... 5. At the .oene, William Wi.. wa. operatinq a 1996 GMC Sonoma piok-up truok and was at a oomplftte stop at the eastbound stop sign at the interseotion of West Marble street and Market Street in Mechanicsburg, Pennsylvania, direotly in front of Judith PapadoploB. 6. At the scene, Defendant, Mindy f.-e Klaum, wa. operating a 1993 Subaru Loya1e CPa. Registration plate # ArE 3746), owned by her parents, Tom And Clare K1aum, Ea.tbound on West Marble street, behind Judith Papadoplos. 7. At the scene, Defendant, Mindy Lee Klaum, was . operating the Subaru Loyale with the knowledqe and permission of the owners, Tom and Clare Klaum. 8. At the scene, Defendant, Mindy Lee Klaum, failed to bring the Subaru Loya1e to a stop behind Judith Papadoplos and, instead, cAused the Subaru Loyale to collide with the rear of the Geo, pushing the Geo into the rear of the Sonoma pick-up truck, causing a three-car colliaion. COtD/T I- IIBGLIGDCI ~ith PaDa40Dlo. v. MiDdY Lee Klaua 9. Paragraphs 1 - 8 are incorporated herein by reference. 10. At all relevant times, the Defendant, Mindy Lee Klaum, had a duty to drive her vehicle at a safe speed and in a safe manner pursuant to 75 Pa. Cons. stat. S 3361 (driving vehicle at Bate speed). 2 11. The Detendant, Mindy Lee Klaum, breaohed her duty Of care by driVing hel' vehiole at euoh a epeed and in .uoh a manner that ahe wa. unable to etop in time to avoid a oollieion, thereby oaueing a three-oar rear-end oollieion. 12. The oollieion wae oau.ad eolely by the negligenoe ot the Detendant and Plaintitt Judith Papadop1oa in no way oauaed or oontributed to the oolHoion. 13. The Defendant's negligenoe inoludes, but is not limited to, the tollowing aots or failures: a. Fa:l,1ing to observe other vehio1eR on the roadway; b. Failing to operate her vehiole in aooordanoe w.t.th the existing tratfic and weather oonditions; o. Failing to keep a reasonable lookout for other vehio1es on the road; d. Operating her vehicle in a manner wh:loh oreated a dangerous situation for other vehioles on the road; and e. operating her vehicle in a manner that violated 75 Pa.C.S. S 3361 (driving vehicle at safe speed) whioh is negligence R'~ aD. '14. Plaintiff Judith Papadoplos has suffered injuries- -that have not resolved and may be permanent in nature--that were caused by the trauma she reoeived in the collision caused solely by the negligence of the Defendant. 15. Plaintiff Judith Papadoplos has been obliged to expend sums and incur expenses tor medical treatment as a result of her injuries caused solely by the negligenoe of the Defendant. 3 16. Plaintiff Judith Papadoplo. i. likely to inour expense. and to expend .um. in the future for neo...ary .edioal oare a. a re.ult of her injurie. oau.ed .01e1y by the negligenoe of the Defendant, 17. Plaintiff Judith Papadoplos ha. mi..ed work and, .. a r..u1t, inourred a lOBS of inoome due only to her injuries caused solely by the negligence o! the Defendant; therefore, Plaintiff Judith Papadoplo. makes a claim for lost wages. 18. Plaintiff Judith Papadoplos believes and therefore avers that she may inour a loss of earning capacity solely due to the injuries caused by the negligence of the Defendant, 19. Plaintiff Judith Papadoplos has experienoed in the past and will continue to experience in the future great pain and suffering as a result of her injuries caused solely by the negligence of the Defendant. 20. Plaintiff Judith Papadoplos has suffered a permanent diminution of her ability to enjoy life and life's p1easur.es as a result of her injuries, pain, and sUf.fering caused solely by the negligence of the Defendant. WHEREFORE, Plaintiff Judith Papadoplos demands judgment against the Defendant, Mindy Lee K1aum, in an amount in excess of the amount requiring compUlsory arbitration, together with interest and costs, 4 ~ to\\e.to ~t~ "e'C r1P9 I tone v).9)J)O .. \.nato ni,Cn .. ..~ 1\\> '<I ,.., ~" vf;'t.. i,01\ \l. to i,01\ i, to. -_..~~ .1\d. &c\. to'C\\\e. \.e.'<Is.\} ~ ~noVtP9, qo",\,\q \.\\e "'1\ \:,n"'s. 0. ...s. ).9'- totC 01\ ot \. e.1\ .. )0- V \.ne 0. "'? \:,,,,0\'\ ",1\s.e e\'\\:' ...m'S.'tp ,'4"'1\ 'pe.llC ..,a'Ca t CO e'/l.\:. .J"'- .." '1 S. ,,<:k \. 0 \:.nc -.tel i,1\to... 1.l\'t' '...'(\ ? ton!> toO &e\.' ',?\.& :itJ' &e \. "'5 a'(\o. co",1\ tonC ceJ/i CO"''(\ \J'>1.~'t 1~'t. 0"''' \.\.0\'\' a'Ce _~l\f)f;f) 0"''' O'!'S ',?\J'> \.0 'C\\\a '<Ie 0. ~- 'Ceo. 'p~ 'i,,~U'&U C u,&\J Cov.. . q"'''c'(\ \.1\to \.\.acne tone ne }\\'\ p.v.."'~ n~\!e 'Il\.eo.qe, :€.~U'&U a 1\ qa t \. \:nc :r. '<Ie ~'(\o #' 'pee "e 0 c~o.' '<I\\"'c o\~" . \.\\e \. i,'(\ \\a5 ",a" 'C '(\ t o. s.C ' f.\'(\q ne."c a\.i,o :;\. () '(\\.S co\l'(\ nC ... 'lle ,,\\\ 'pC \.C '(\ 't \"So \.nc co1\ 0. "''PO C 0",,,5' "'?o'(\ \. toO \. \:onc e\.i,C ..c\.1\ a" 1\0\. sed ""ee \. \:.na "e 'C ne" i,5 'pa Q~o. CO ey.\.c1\ \Ole n& 1\\'s toO i, \. ~_. \. \.e\\\e \....'(\q to'C",e \.ne 1\5c I sto& ..e\.a i,5 'to co'" C t\ " \.\. i,ct, of. \. ta\.5 1fIt\90 'pc\. to\\a\. "'0'(\' i,o'(\e. C,S. '(\c\ i,5 ca\:. '(\':. "a- e. 1.~'t , t'" \.1\\:'c \1\ < /' ._ Co\ll.',?\J'> , !\ <,Je'C). \:.na\. 5 ot i,\.\.c5' ~ \:.n).' '(\0. \. \.i,C \:.no" (-L-- _ \<,\.'(\q o.e'Cstoa 'tle'(\& \:.0 ll-'" ~ \\\a "''(\ \.ne o.e ? & -.te toO 5 \\\& ,IJ ':"""---',?e.'tl \eC\. i,01\ n 1'-- 5\}'p') . t i,C&to 0. \. ,/ \\\&o.C tll-1.s). '" '<I0'C1\ \}1\5 fJ- \:,eo.\ Ue. ~ COtDIT I - HKaLIGID1C!lIi J1lDITH PAPAnOPLOA VS. IIIHDY LEE rr.1.11II 9, Defendant incorporates hereby by reference her answers to paragraphs 1 through 8 above as if the same were set forth in their entirety, 10, Denied. The averments of this paragraph of Plaintiffs' Complaint recite legal conclusions to which no response is required. Mindy K1aum avera, however, that at all times and for all purposes relevant to the subjp.ct of this motor vehicle accident, she operated her motor vehicle in a ca~eful and prudent fashion and did not negligently cause the accident. 11, Denied, The averments of this paragraph of Plaintiffs' Complaint recite legal conclusions to which no response is required. Mindy Klaum avers, however, that the subject accident was not the result of her negligence and that, in fact, at all times and for all purposes relevant hereto, she operated her motor vehicle in a careful and prudent fashion. By way of further answer, Mindy Klaum incorporates herein by reference her answer to paragraph 9 above as if the same were set forth in its entirety, 12. Denied. The averments of this paragraph of Plaintiffs' Complaint recite legal conclusions to which no response is required. Mindy Klaum avers, however, that the subject accident was not the result of her negli,gence and that, . 2 - , ,. in fact, at all times and for all purposes relevant hereto, she operated her motor vehicle in a careful and prudent fashion, By way of further answer, Mindy Klaum incorporates herein by reference her answer to paragraph 8 above as if the same were set forth in its entirety, 13. (a). (e) 1'he averments of this paragraph and subparagraphs of Plaintiffs' Complaint recite legal conclusions to which no response is required. Mindy Klaum avers, however, that at all times and for all purposes relevant to the subject of this motor vehicle accident, she operated her motor vehicle in a careful and prudent fashion and did not negligentlY cause the accident. Mindy Klaum incorporates herein by reference her answer to paragraph 8 of this Answer as if the same was set forth in its entirety. 14.20. Denied. The averments of these paragraphs Of Plaintiffs' Complaint recite legal and medical conclusions to which no response is required. Mindy Klaum avers, however, that at all times and for all purposes relevant to the subject of this motor vehicle accident, she operated her vehicle in a careful and prudent fashion and did not negligently cau~e the accident and did not negligently cause or contribute to cause any injury or damage to Plaintiff, Judith Papadoplos. WHEREFORE, Defendant, Mindy Lee Klaum, demands judgment in her favor and against Plaintiffs, . 3 . ... COtmT II Loas 0, CONSO.TIOM U1'BR PAPAnOP.LQS.. va. IlIHDY LRR IrT,'1UI 21, Mindy K1aum incorporates herein by reference her answers to paragraphs 1 through 20 of the Plaintiffs' Complaint as if the same were set forth in their entirety. 22, Denied. The averments of this paragraph of Plaintiffs' Complaint recit.e legal and medical conclusions to which no response is required, Mindy Klaum avers, however, t.hat at all times and for all purposes relevant to the subject of this motor vehicle accident, she operated her vehicle in a careful and prudent fashion and did not negligently cause the accident and did not negligently cause or contribute to cause any injury or damage to Plaintiff, Peter Papadoplos. WHEREFORE, Defendant, Mindy Lee Klaum, demands jUdgment in her favor and against Plaintiffs, !In MATTER 23, To the extent currently applicable, or to the extent that it may later prove to be applicable, Mindy Klaum pleads the statute of limitations applicable to personal injury actions in Pennsylvania to preserve this affirmative defense for the record. 24. The automobile collision which is the subj ect of this action was unavoidable due to the icy and slippery road 4 ' '- co "- i'j; C L: i:'::: ,-:. lJ'I:'~) ..=1 ~-')~r; (.),L". I;~( I (J,~,'r f'. ':'L.. si.'/L1 i'~) ~ ~ 1 '-...\ ,01' , U'j (X' ('I , 1;1~ "I' I.\:J ""-,. i '. ~\dJ_U "- , L.'J !,HJ.. i;' f..... ..!:,: II. t,-, :::> r.) 0', 0 ~ and her Husband, PETER PAPADOPLOS I IN THE COURT or COMMON PLEAS or cUNBERLAND COUNTY, PENNA Plaintiffs NO, 99-176 Civil v, CIVIl, ACTION - LAW MINDY LEE I<LAUM Defendant JURY TRIAL DEMANDED PLAINTIFFS' REPLY TO NEW MATTER OF DEFENDANT 23, Paragraph No. 23 is a conclusion of law which requires no answer, 24. It is denied:'hat the collision was unavoidable, On the contrary, it is averred that had the Defendant Mindy Klaum been operating her vehicle properly and carefully and with careful attention to the road, she could have come to a stop without striking Plaintiffs' vehicle, as more specifically averred in the Complaint which is incorporated herein by reference. 25, Denied as stated, Plaintiffs hereby incorporate the averments of the Complaint, Plaintiffs also state that to the extent Defendant avers a conclusion of law that this was a "sudden emergency," this is a conclusion of law which requires no answer. 26, Denied. On the contrary, it is averred that the Defendant was negligent as more specifically averred in the Complaint which is incorporated herein by reference, fr; ....!J. r; {~{ r~ f (") "1.: f""": I': ,~, ~-~ ( "-'., F,,: (l..' i (liF- if' w I]G: I () L. "'-; G:~l'! :.1,11:1.1 l;~ .. "":l i :-.;..": u C!) ; 0 c~ 0 'I i" JUDITH A, PAPADOPLOS and her Huaband, PETlR PAPAOQPLOS IN THE COURT 01' COtN)N pLZJI.S or CUHBERLANO COUNTY, PENNA, Pldnti!!. NO, gg-176 Civil v, CIVIL AC~ION - LAW MINDY L1:E KLAUH Defendant JURY TRIAL DEMANDED ss: COUNTY OF DAUPHIN I hereby certify that on February 19, 1999, I mailed a true and correct copy of Plaintiff's Amended Complaint to Michael M, Badowski, Esquire, Reynolds & Havas, P,O, Box 932, Harrisburg, PA 17108-0932, counsel for the Defendant Mindy Lee Klaum, by United States First Class, CerUfied Mail, Return Receipt Requested, as evidenced by the keceipt for Certified Mail No. P397743602 attached hereto. I hereby certify that Plaintiff's Amended Complaint was served upon Michael M. Badowski, Esquire, Reynolds & Havas, P.O, Box 932, Harrisburg, PA 17108-0932, counsel for Defendant Mindy Lee Klaum, on February 22, 1999, as evidenced by the Return Re~ipt for Merchandise card No, P397743602, attached/~ereto. I- SCHMIDT r ~~NCA' . C. By James R. Rqllca Attorney /11'1: . w I. D. N9"/2 5 "31 209 ~t:e .lItreet Harrisburg, PA 17101 (717) 232-6300 Sworn and subscribed to before me this '-IfI..- day of '11 '10 tl'L , 1999, II , . ^:-Jl1 , It, ;1/ Iv ~y Public MY COMMISSION EXPIRE NOTARIAL SEAL : SUSAN M, LaVIA, Notary Public City of Harrisburg, DauRhln County My c~nn Expires O~1. 16, 2000 f j , I J ;.1 '~-' 0, "'- i:~~ .-" L. ~',i.. , I~ 6~ , j ....-r. U.I~~,! t,.,:i c.;,; (,,j ( ~t":' :.J .'--.< -_~-l II., D.... :_J (:iF (~) (' ,ee) ,( %; ILl ~ \, I ) ~_"lll. Ce:. ;-))i\.l \ U=:L ~11 ,",I{.L I... ~C -,.. u, en t,;") '-j' 0 0.... 0 ~..~ ~ ~ ('0 ~ (,I, <i "-'-. <,:-\ .... Y" 'l'"" 1-.., .'" ,.-~ 'l'", ~ <? Ill", ...( ......~"'''''<l(< ~7: ./ ~ 'l'(< . ...~ ~~Ill ",0.;. ~ ~ \l(<. 0'6\~ (' -"1! 1 Ill~' -n ~ ,,(' <l' ~ :c '1> ~ ~ Y" . 'fa ~ 1> 1" ~ ~ ~~ ij).. t. ~ ,. ''-; III (\ <". III (' ~ '" ~ 1"" ~Q: 11ll 9t. Ill.... ~ '" 'l'? ;0 t. <l" (\; (' ~ ~ Illo- ~ "~~ ~ () 9>';" ~ 9'Q.: (>0- ~ (' ~ ~., " ..... ~ '?~ <P(' ~ "'~. 7(' ~ &.. .' VI. c;.~ ....... Of:. (\ 'Is> 'l' 0,;. v <" ~ ~ 0, 0 1-. ~ ~; ~ "'Ill ('(> ~ 'l'? 0",;L. O~,t. '\. 9'", C? ..oO.,..Ill,.... 0- <l' << 0- ?Ill 0.,.. <A '" 7" "'~ ~~Ill~ ~ ~ t :Co '6;L. ~ '1>....... ~ 7'0+ <><1' "^ " 'V ~ "'", 1; '2. ~ 9t. (' V v('..... "" - (\ III '" ....-" <". ",.S) 'r. ~ <l-. (\('..0 "", ':i-. ' 0", ~ ~ "'Ill 'l't. ~ .,.. '? ,.... ;if> '\ C. -:>..0 Ill(''l'",%- .;., '" (\ <l' ~ ~ "I 'f:"" "'(' (I),.... ?o ~ (:) ~ "'" (\> 0 ~ (''''' ~ 0", .......-;, ~ "'9?~"" 0.,.. ~ oq,., ~ v'" ~ .0 ~ Ill~ ~ <l' '6", <y~ 11\> <Pc,}., ?% ~ (' 0- ~ ~ ~ ? ?(' ~'" 'i '\ <&. ~ .0", '" O@ #~ Y" -;;.:c ... ..... ~. 0 -kO (' ''0 ~ <l' ~ Y. ..~ ~ ~ ~ ~ \} ~ ~ ~/ ~ -. ~ ..0 ~ ~<l' ~ t. <l'? .;, <l' "1! \ll ~ , ..0 '?o ~o \ ~ ~<p. ~ 9<> <l'? \" \r coo-\ .,.. <P?: -; ~ \\~ t,~ \.;. .' .' .... ....... ~... ~~ -ko ~ ~~. ~ ~'b\ ~, ~.~\ ~ '1~ '" ~ " .(:) q.., \ "';. 'b 0. ~ ~<;l ~' ~ '.~ U: Ie .. , r (q I . . c'"o r", .'j (.L )1" h' f"') (" (.-1 (',I lit, , Co ',1 ., t;,; F-- "';..' fI".. IJ.; 0" - I 0 (:n n ,......."'-""'*......~~'->"",...,-~~~---- JUDITH A. PAPADOPLOS and her Husband, PETER PAPAOOPLOS - -- "'~""-"~'-- --.....-~......_~.-- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA Plaintiffs NO, 99-176C.tvil v, MINDY LEE KLAUM Defendant CIVIL ACTION - I.AW ,11JRY TRIAL DEMANDED AND NOW, 7IFIr.ATE or S~RVICE this ~ day of _ ~l , 1999, 1, James R, Ronca, Esquire, Attorney for Plaintiffs, hereby certify that I have served a true and correct copy of P~INTIFFS' FIRST SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS OF DEFENDANT upon counsel of record by depositing same in the United States Mail, first class, at Harrisburg, Pennsylvania, addressed to: Michael M. Badowski, Esq, Reynolds & Havas 101 Pine Street P.O. Box 932 Harrisburg, PA 171 08-'0932 Attorney for Defendant SC'"70 17101 Attorney for Plaintiffs ~ ,..... ~.... lr. I' f .. - ), ?-" I (,> "I I ;L '. C") }f' ;jl ("-J "11' Ci;: iI" ;jL .. " :0.; ~ fJ\ , 0\ () - - "~-~-n_",,"'-'u~.~..___~..u,>-+--"-~_._, JUDITH A. PAPADOPLOS and her Husband, PETER PAPADOPLOS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA Plaintiffs NO, 99-176 Civil v. CIVIL ACTION - J~W MINDY LEE KLAUM Defendant JURY TRIAL OEMANDED AND NOW, this CERTIFICATE OF SERVICE 3Dc}h. day of l1i~L_, 1999, I, James R, Ronca, Esquire, Attorney for Plaintiffs, hereby certify that I have served a true and correct copy of PLAINTXFrS' INTERROGATORIES PROPOUNDED UPON DEFENDANT (SET H) upon counsel of record by depositing same in the United State8 Mail, first class, at Harrisburg, Pennsylvania, addressed to: Michnel M, Badowski, Esq. Reynolds & Havas 101 Pine Street P,O, Box 932 Harrisburg, PA 17108-0932 Attorney for Defendant / RONCA, By // Jamli1S--c~./Ron a, Esq. 1.>,' No. 631 ?Cf9 stat street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs i\: - ~ g: c;:I ~ 8~ ~~ f. i1. 9~ - I ~i rtIlfl ~ lu; "t ~ ~ 3 'oC .~.___.".~~_____~"--""'+........._"-.~..__.___~___ JUDITH A. PAPADOPLOS and her Husband, PETER PAPADOPLOS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA Plaintiffs NO. 99-176 Civil v. CIVIL ACTION .. LAW MINDY LEE KLAUM Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this \.:J:::_ day of -LLt')"'~R , 1999, I, James R. Ronca, Esquire, Attorney for Plaintiffs, hereby certifY that I have served a true and correct copy of PLAINTIFFS' SECOND SUPPLEMtNTAL RESPONSE TO REQUESTS FOR PRODUCTION OF DEFENDANT upon counsel of record by depositing same in the United states Mail, first class, at Harrisburg, Pennsylvania, addressed to: Michael M. Badowski, Esq. Reynolds & Havas 101 Pine Street P.Q, Box 932 Harrisburg, PA 17108-0932 !\ttorney for Defendant ~'RONC; SCHMIDT~A' ,C. By James ""1. D, No. 25631 / 209 st~e Street Han;i:S'burg, PA 17101 (71'7) 232-6300 Attorney for Plaintiffs ~ M ~ - ~~ .. IE Q~ ~~' In ,:,~ "( tiP. I ~m I.L a:: . ,!:, Cl.. CC ~u.. l; (J\ a ()'\ ..--- ----........--~,- . ----"~_~L.~'_~n_.'.'a..'_.__ JUDITH A. PAPADOPLOS and her Husband, PETER PAPADOPLOS -". -, ..,. "~~~~~_._<~-,~~~.~--,._-, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA Plaintiffs NO. 99-176 Civil v. MINDY LEE KLAUM Defendant CIVIL ACTION - lLAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this J~ ,day of ~, 1999, I, James R. Ronca, Esquire, Attorney for Plaintiffs, hereby certify that I have served a true and correct copy of P,LAINTIFFS' THIRD SUPPLEMEN'fAL RESPONSE TO REQUESTS FOR PRODUCTION OF DEFENDANT upon counsel of record by depositing same in the United States Mail, first class, at Harrisburg, Pennsylvania, addressed to: Michael M. Badowski, Esq, Reynolds & Havas 101 Pine Street P,O, Box 932 Harrisburg, PA 171 08-0932 Attorney for Defendant SCHMIOT ~ONCA'~'C' By --:~ / ~~m~~~ p.~,R~~~~l Esq. 209 tate Street Harr burg, PA 17101 (717) 232-6300 Attorney for Plaintiffs -"~...----,....-.-"-,+....,.-+",.~~.~~ , >ri<"'~. " JUDITH A, PAPADOPLOS and her Husband, PETER PAPADOPLOS IN TilE COURT O~' COMMON ,.PLEAS O~' CUMBERI.AND COUNTY, PI!:NNA Plaintiffs NO. 99-176 Civil v. CIVIL ACTION ,- LAW MINDY LI!:E KLAUM Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this .31tl. day of J1J~ ' 1999, I, Jarn~s R. Ronca, Esquire, Attorney for Plaintiffs, hereby certify that I have served a true and correct copy of PLAINTIFFS' REVISED NOTICE OF DEPOSITION - DEFENDANT MINDY KLAUM upon counsel of record by depositing same in the United States Mail, first class, at Harrisburg, Pennsylvania, addressed to: Michael M. Badowski, Esq. Reynolds & Havas 101 Pine street P.O, Box 932 Harrisburg, PA 17108-0932 Attorney for Defendant SCHM(~}/AND _~ON , p, C, "'-'--'/ By // Ja/!le's R, oIlca, Esq. ~:f'D. Woo 25631 ,-,/ 209Sfate Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs ~ "J ~ 'ol;:t.. 1'<, M '50<1: () r :;;;J U1" t?:)~ ( ~." ~r.: -<-e, qi2 H:,( CJ.. ()l-L, c.~(i ..:r .- i~(I.) 'I"'~ iJ./, 1. I "-'~:2 ~:~.r'; >- i'hD ...; co a... :c ~.-. l~'-, 0"\ :5 ~) 0\ <..l JUDITH A. PAPADOPLOS and her Husband, PETER PAPADOPLOS : IN THE COURT OF COMMON PLEAS OF' CUMBERLAND COUm'y, PENNA Plaintiffs NO, 99-176 Civil v, CIVIL ACTION - LAW MINDY LEE KLAUM Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this :1Jte.l, day of ~ ' 1999, I, James R. Ronca, Esquire, Attorney for Plaintiffs, hereby certifY that I have served a true and correct copy of PLAINT!FFS' FOURTH SUPPLEMENTAL RESPONSE TO DEFENDANT'S REQUEST FOR PRODUCTION OF DOCUMENTS upon counsel of record by depositing same in the United States Mail, first class, at Harrisburg, Pennsylvania, addressed to: Michael M, Badowski, Esq, Reynolds & Havas 101 Pine Street P.O. Box 932 Harrisburg, PA 17108-0932 Attorney for Defendant SCHMID'f, RONCA AND KRAMER, P. C. (/ By ~_ James R. Ro ca, Esq, 1. ,D. No, 5631 , / ;a<(9sta~e Street ,.0Harri~klurq, PA 17101 ('711) 232-6300 Attorney for Plaintiffs ",.-; >. I.t) G ~ - ~h Cr) ;3~ lLJQ r_),~i.- ()"':.' ;'1: U~( p.: rj ~ u.. ")> (~5r "-. <-' C~( .:1- :;'~I'i2; I,.L i._. I ..) :.::; Lea; Cl: ~;; >-- If! "'C 1i::1(J... r ' ::c .,':);" I", ~ f3 () --.-. ,.. CERTIrICATII: PUUQI11SlTl .TO SzaVICI or A SUIPOSHA PlIUUAHT TO IULS 4009,22 IN THE HATTER OFI PAPADOPLOS COURT OF OOHMON PLE^S TIltH, 0000 -VS. KLAIIH CASE NOI 176 CIVIL 1999 As a prerequisite to service of . subpoena for documents and things pUrsuan~ to RUle 4009,22 Mes on behalf of MICHAEL 8^DOWSKI, ESQUIRE defendant certifies that (1) A notice of intent to serve the Subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena l.s soulght to be served, (2) A copy of the notice of intent, inClUding the proposed subpoena, is attA.hed to the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena, DATE, S10611J~ '-(J'ki.../ ;;Lt~~-L' 'JxCHAEL BADOWSKI, ESQUIRE Attorney for DEFENDANT DEll-l04683 94445 - L 0 1. >-, ~.. ,>. tr; I"~ f":l -.. ::.,~ .cJ.' r-j .- ;,j ~Js~::" ~,:; (~. \:, -'1'. .' ": j L" "'.C 'Lrl " ," f.Jc Gjl:; 1'-1 ':Q r-;' (' t_~-.; O"I.L. ..,.... i,j(1J J-w'/.: .,~:: ;:Ji,{~ f. :tl~ .e. 0' ~J (,) 0\ 0 " '. >- Ul f:- l'f'; c;: .., ~.::~ ,_r1 ~J" , " .t'- J 'Ilil.' . I'. " .. i! .~-~ .! ,1'1 ('[" ..'" f'l ~'I , ), -. t'./ (1; t~_ ~-. :J UJ "," .Ii U.. [," :L " " I ,. L"11 :] 9 0' () ','1 ~ \l) ~ If:; .. UJQ N 0% <t'" '" i: ~, .... 0::,; ,I'r cZ: o~ '~' ,.... (, L. If> ,'f () Lljl1 N ~4'!:. [[I! 1-, !fi~ ' fl:. L) <1l( , c::> ::i: ~. 0"\ 3 .J ct,