Loading...
HomeMy WebLinkAbout03-2927 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION LAW MARY ROBINSON 1329 N. Alden Street Philadelphia, PA 19131 vs. TERM, HMC HOSPITALITY MANAGEMENT CORP. d/b/a RADISSON PENN HARRIS HOTEL 1150 Camp Hill Byp. Camp Hill, PA 17011 NO. 0.3 - ~9~ 7 C,o~l'J~ 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 TWENrY (20) DAYS AFfER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITIEN APPEARANCE PERSONALLY OR BY ATIORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSE OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED 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 IMPORT ANT TO YOU. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE mE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVE., CARLISLE, PA 17013 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION LAW CHRISTOPHER L. GIDDINGS, P.C. By: Christopher 1. Giddings Attorney Identification No. 72063 3000 Market Street, Suite 201 Philadelphia, PA 19104 (215) 243-3450 MARY ROBINSON 1329 N. Alden Street Philadelphia, P A 19131 THIS IS AN ARBITRATION MATTER. AN ASSESSMENT OF DAMAGES HEARING IS REQUIRED. ATTORNEY FOR PLAINTWF vs. TERM, NO. C>3 - QompliuJ./rw., HMC HOSPITALITY MANAGEMENT : CORP. d/b/a RADISSON PENN HARRIS HOTEL 1150 Camp Hill Byp. Camp Hill, P A 17011 COMPLAINT - CIVIL ACTION NEGLIGENCE 2S - PREMISES LIABILITY - SLIP & FALL 1. Plaintiff is an adult individual who resides at the address set forth in the caption above. 2. Defendant is a corporation which at all times relevant, and especially on the date and time of the accident alleged herein, did business as Radisson Penn Harris Hotel, with its principal and regular place of business at the address set forth in the caption above. 3. At all times relevant, and especially on the date and time of the accident alleged herein, defendant owned, possessed, operated, controlled, and was responsible for the inspection and maintenance of the supermarket located at 1150 Camp Hill Byp., Camp Hill, P A 17011. 4. At all times relevant, and especially on the date and time of the accident alleged herein, defendant was acting directly or through its agents, servants and/or employees, who, in turn, were acting within the scope and course of their employment, in the furtherance of the business of the defendant. 5. At all times relevant, and especially on the date and time of the accident alleged herein, plaintiff was lawfully on the property and premises of the Radisson Penn Harris Hotel, located at 1150 Camp Hill Byp., Camp Hill, P A 17011, as a business invitee, and as such was owed the highest degree of care by defendant. 6. At all times relevant, and especially on the date and time of the accident alleged herein, and for a long time before the accident which is the subject of this suit, there existed a dangerous and defective condition upon defendant's property and premises, i.e., an accumulation of hills and ridges of snow and ice 7. On or about March 17, 2002, at the Radisson Penn Harris Hotel, 1150 Camp Hill Byp., Camp Hill, P A, plaintiff was standing on the sidewalk of defendant's property and premises cleaning off her car, when she was caused to slip and fall backwards on the aforesaid accumulation of hills and ridges of snow and ice on defendant's property and premises. 8. The fall of plaintiff was caused by the negligence of defendant that owned, possessed, operated, controlled and was responsible for the inspection and maintenance of the Radisson Penn Harris Hotel. 9. Defendant was negligent in: a) permitting the dangerous condition of hills and ridges of snow and ice to exist on the property and premises; b) permitting the property and premises to remain in a dangerous condition; c) failing to remove the hills and ridges of snow and ice from the property and premises; d) failing to make safe the dangerous condition; e) failing to inspect the property and premises; f) failing to warn the plaintiff of the dangerous condition; g) failing to properly light the property and premises; h) failing to erect and maintain a proper barrier preventing persons from encountering said dangerous condition; i) failing to provide safe and proper ingress, egress, and passage thereby causing unreasonable risk of injury to people such as plaintiff; j) failing to use reasonable prudence and care to keep the property and premises in a safe condition for people such as plaintiff; k) negligence and recklessness at law. 10. By reason of the negligence of defendant, Plaintiff sustained serious personal injury, which may include injuries to the head, neck, back, upper and lower extremities, severe shock to the nerves and nervous system, including but not limited to post- concussion syndrome, left shoulder sprain and strain, left wrist sprain and strain, lumbosacral sprain and strain, all of which may continue for an indefinite period of time into the future, 11. As a direct result of the negligence of defendant, the plaintiff was, is, and yet in the future, will be rendered sick, sore, lame and disordered and she has, yet does, and will in the future sustain pain, harm, damage and suffering. 12. As a further result of the negligence of defendant, the plaintiff has, yet does, and will in the future, sustain loss of eamings and earning power and has been, yet is, and will in the future be unable to attend to her usual duties, occupations and to the essentials of daily living. 13. As a further result of the negligence of the defendant, the plaintiff has had to spend money for medicine and medical attention in order to attempt to effect a cure, treat and alleviate the signs and symptoms of her personal injuries, and she may have to spend monies for medicine and medical attention indefinitely into the future for the same or similar purpose. 14. The plaintiff has sustained and Will in the future sustain further harm, damage and inconvenience. WHEREFORE, plaintiff does demand judgment in her favor and against defendant in an amount not in excess of $50,000.00, together with costs according to law. CHRISTOPHER L. GIDDINGS, P.C. Dated: b /17 IcY:> By:(; -AJ'~ Christopher L. Giddings VERIFICATION MAR Y A. ROBINSON hereby states she is the plaintiff in this action and veri lies the statements made in the foregoing pleading are true and correct. to the best of her knowledge. information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. DATE: ~f7/tJ!. I A' MARY~~~/~ Plaintiff /.::J ""-l. l 0 q 1l CI) () 0 0 c w ," 0 s: ~ ..... ?Jcn T-D \;:; :S fil ,-. G rX' Z flip-. 2"" N "_~,rn ~ ~ ~(~;: 0 ~i19 ~ ,. .~'-~ ~l", ~) ~~. :.:r1 G; Z" ::;: ':''1-0 i~ $ 5> " - :5i'n c " -~ ~ (1'\ ~ -< MARY ROBINSON 1329 N. Alden Street Philadelphia, P A 19131 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 03-2927 Civil Term HMC HOSPITALITY MANAGEMENT CORP. d/b/a RADISSON PENN HARRIS HOTEL 1150 Camp Hill Bypass Camp Hill, PA 17011 CIVIL ACTION - LAW JURY TRIAL DEMANDED Defendant TO: PROTHONOTARY Please enter the appearance of Jeffrey B. Rettig, Esquire, and Hartman, Osborne & Rettig, P.C., on behalf of Defendant, Radisson Penn Harris Hotel, in regard to the above- captioned action. Respectfully submitted, HARTMAN, OSBORNE & RETTIG, P.C. By Attorneys for Defendant, Radisson Penn Harris Hotel CJg'ftFlCA'f\E0FSERVI'CE ......".."....,.,,,.,,,,...."'..'.1.;..,,.,;.:.;..;;;...,";..,.,.,.........,....",..........,.. I, Jeffrey B. Rettig, Esquire, hereby certify that I am this day serving a copy ofthe foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States mail, first-class postage prepaid, as follows: Christopher L. Giddings, Esquire Christopher L. Giddings, P.C. 3000 Market Street, Suite 20 I Philadelphia, PA 19104 (Attorney for Plaintiff) HARTMAN, OSBORNE & RETTIG, P.C. By ffrey B. Rettig, Es re upreme Ct. l.D. #1 16 126-128 Walnut Street Harrisburg, PA 17101 (717) 232-3046 Date: 1 II 6/ o} Attorneys for Defendant, Radisson Penn Harris Hotel 0 0 C c.:.> ?::' -oCJ .- nlf: - Z:~; Zt: (J) .-J ~. C cJ J;;r :z:. , :1:.: ,,-C ,,) --"'c.: ., 2:: :".) ?.q =< ..... GREGORY L. SCHELL, LLC BY: GREGORY L. SCHELL, ESQUIRE Attorney J.D. No. 42969 230 S. Broad Street, Suite 1050 Philadelphia P A 19102 (215) 545-9000 THIS IS A MAJOR NON-JURY MATTER. ASSESSMENT OF DAMAGES IS REQUIRED. Attorney for Plaintiff MARY ROBINSON 1329 N. ALDEN STREET PHILADELPHIA, PA 19131 COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. HMC HOSPITALITY MANAGEMENT CORP., D/B/A RADISSON PENN HARRIS HOTEL 1150 CAMP HILL BYP. CAMP HILL, P A 17011 NO; 03-2927 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance as co-counsel for the Plaintiff, Mary Robinson in the above- captioned matter. GREGORY L. SCHELL, LLC o c s:: -00': rnr" L::r Ze (J) .'; ~<;. ;<:L. ~o >8 ~ ~JMo :':') , N 0''0 (..) -:~ ,;(oc:; ~;':';rn ,-,' -... "~-.J" 5:J -< SHERIFF'S RETURN - REGULAR CASE NO: 2003-02927 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ROBINSON MARY VS HMC HOSPITALITY MANAGEMENT COR VALERIE WAERY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HMC HOSPITALITY MANAGEMENT CORP DBA RADISSON PENN HARRIS the DEFENDANT , at 1425:00 HOURS, on the 9th day of July , 2003 at 1150 CAMP HILL BYPASS CAMP HILL, PA 17011 by handing to PAMELA ROADCAP, GUEST SERVICES ADULT IN CHARGE 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 18.00 10.35 .00 10.00 .00 38.35 So Answers: ~f?6~~~ R. Thomas Kline 07/10/2003 LEGAL-EASE ENTERPRISES Sworn and Subscribed to before By: (i1-;'sfc~ me this )1. 'e. day of O.L d.l!I)3 A.D. A J~O.~II~.,.Pflr- \.. A:rothonotary ,,1 MARY ROBINSON 1329 N. Alden Street Philadelphia, PA 19131 Plaintiff v. HMC HOSPITALITY MANAGEMENT CORP. d/b/a RADISSON PENN HARRIS HOTEL 1150 Camp Hill Bypass Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2927 Civil Term CNIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Mary Robinson, Plaintiff c/o Gregory ScheU, Esquire 230 South Broad Street Suite 1050 Philadelphia, PA 19102 (Counsel for Plaintiff) You are hereby notified to file a written response to the enclosed Defendant's Answer with New Matter within twenty (20) days from service hereof or a judgment may be entered against you. Dated: J! I :3 / f) 3 RespectfuUy submitted, HARTMAN, OSBORNE & RETTIG, P.e. effrey B. Rettig, E Supreme Ct. #1961 126-128 Walnut Street Harrisburg, PA 17101 (717) 232-3046 Attorney for Defendant MARY ROBINSON 1329 N. Alden Street Philadelphia, PA 19131 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 03-2927 Civil Term HMC HOSPITALITY MANAGEMENT CORP. d/b/a RADISSON PENN HARRIS HOTEL 1150 Camp Hill Bypass Camp Hill, PA 17011 CIVIL ACTION - LAW JURY TRIAL DEMANDED Defendant AND NOW comes the Defendant, by its attorneys, Hartman, Osborne & Rettig, P.C. and answers Plaintiffs Complaint as follows: 1. It is admitted that the Plaintiff is who she says she is. As to the balance of the allegations ofthis paragraph, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth thereof and proof is demanded. 2. Denied as stated. It is admitted that the Defendant did and does business as Radisson Penn Harris Hotel with a place of business at 1150 Camp Hill Bypass, Camp Hill, Pennsylvania. 3. Denied. This allegation represents a conclusion oflaw to which no reply is required. It is admitted that the Defendant operated and was responsible for the Radisson Penn Harris Hotel premises. It is denied that there was a supermarket located at that address or that the Defendant has any involvement with a supermarket. 4. Denied as stated. Without identifying the alleged agents, servants and employees, Defendant is unable to respond to this allegation. 5. Denied as stated. On information and belief, it is admitted that the Plaintiff was at the premises of the Radisson Penn Harris Hotel on the date of this incident. As to Plaintiffs status, Defendant is without knowledge or information sufficient to form a belief as to the truth thereof and proof is demanded. The allegation that Plaintiff was "owed the highest degree of care" represents a conclusion of law to which no reply is required. 6. Denied. It is denied that for a long time prior to this accident there existed an accumulation of hills and ridges of snow and ice on Defendant's premises. 7. Denied as stated. It is denied that there was an accumulation of hills and ridges of snow and ice on Defendant's property as alleged. As to the balance of the allegations ofthis paragraph, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth thereof and proof is demanded. 8. Denied. This allegation is denied pursuant to Pa.R.C.P. 1029. 9. Denied. These allegations are denied pursuant to Pa.R.C.P. 1029. 10-13. The allegations of negligence are denied pursuant to Pa.R.C.P. 1029. As to the balance of the allegations ofthese paragraphs, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth thereof and proof is demanded. 14. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth thereof and proof is demanded. WHEREFORE, Defendant request that Plaintiffs Complaint be dismissed without cost to it. 2 NEW MATTER 15. At the time of Plaintiffs fall there was a general snowy condition in the area of Defendant's hotel. 16. It is denied that the snow and ice that Plaintiff allegedly slipped and fell on had accumulated into the hills and ridges. 17. Plaintiff has or may have failed to mitigate her damages. WHEREFORE, Defendant request that Plaintiffs Complaint be dismissed without cost to it. Respectfully submitted, HARTMAN, OSBORNE & RETTIG, P.C. B:k Attorneys for Defendant, Radisson Penn Harris Hotel 3 VERIFICATION I, Tom Dickert ofRadisson Penn Harris Hotel and Convention Center, hereby verify and state that the facts set forth in the foregoing DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn verification to authorities. Dated: ~)> CERTIFICATE OF SERVICE I, Jeffrey B. Rettig, Esquire, hereby certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States mail, first-class postage prepaid, as follows: Gregory L. Schell, Esquire 230 South Broad Street Suite 1050 Philadelphia, PA 19102 (Counsel for Plaintiff) HARTMAN, OSBORNE & Date: g/ /3/03 Attorneys for Defendant, Radisson Penn Harris Hotel GREGORY L. SCHELL, LLC BY: GREGORY L. SCHEU., ESQUIRE Attorney LD. No. 42969 230 S. Broad Street, Suite 1050 Philadelphia PA 19102 (215) 545-9000 THIS IS A MAJOR NON-JURY MATTER. ASSESSMENT OF DAMAGES IS REQUIRED. Attorney for Plaintiff MARY ROBINSON 1329 N. ALDEN STREET PHILADELPHIA, PA 19131 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. HMC HOSPITALITY MANAGEMENT CORP., D/B/A RADISSON PENN HARRIS HOTEL 1150 CAMP HILL BYP. CAMP HILL, PA 17011 NO: 03-2927 CERTIFICATE OF SERVICE I hereby certify that Plaintiff's Reply to New Matter of Defendant, HMC Hospitality Management Corp., d/b/a Radisson Penn Harris Hotel was served upon the interested party or counsel of record set forth below, by U.S. Mail on September 2, 2003. Jeffrey B. Rettig, Esquire Hartman, Osborne & Rettig, P.C. 126-128 Walnut Street Harrisburg PA 17101 GREGORY L. SCHELL, LLC .,/' o c <" o1Jff; ntrT' ;-::::-, Zl: (J~.: : ~~:~: Z~-' -;:c... .......~ L_ =<! c:::> 0-1 t.n ." .0 I (") -n --;", " !:3 C) "- ::~ r~ f;~ ...J ::::-;! :D -< 'U :1; w ... .0 GREGORY L. SCHELL, LLC BY: GREGORY L. SCHELL, ESQUIRE Attorney J.D. No. 42969 230 S. Broad Street, Suite 1050 Philadelphia PA 19102 (215) 545-9000 THIS IS A MAJOR NON-JURY MATTER. ASSESSMENT OF DAMAGES IS REQUIRED. Attorney for Plaintiff MARY ROBINSON COURT OF COMMON PLEAS CUMBERLAND COUNlY vs. HMC HOSPITALITY MANAGEMENT CORP., DIB/A RADISSON PENN HARRIS HOTEL NO: 03-2927 PLAINTIFF'S REPLY TO NEW MATTER OF DEFENDANT, HMC HOSPITALIlY MANAGEMENT CORP., DIB/A RADISSON PENN HARRIS HOTEL 15-17. Denied. The averments contained in paragraphs 15 through 17, inclusive, of Defendant, HMC Hospitality Management Corp., d/b/a Radisson Penn Harris Hotel's New Matter to Plaintiff's Complaint constitute conclusions of law to which no response is required and so, the same are hereby denied. To the extent that either paragraph 15 or 16 can be construed to aver facts, the same are specifically denied. Strict proof thereof is demanded at the time of trial. WHEREFORE, Plaintiff requests that Defendant's New Matter be dismissed; and further that judgment be entered in favor of the Plaintiff and against the Defendant, both jointly and severally, in a sum in excess of Fifty Thousand ($50,000.00) Dollars plus damages for delay as provided by law. GREGORY L. SCHELL, LLC BY:G~4s' L-. Attorney for Plaintiff , IRE .\"1', C) c- "'" ~ CEtY; ~g ~l- e 2' $fi::' -.-;;'; ::1 -~ , ': :;-:Il~ }:,:'.,. C> t,,) (~) r-r; '.0 I (') "" I, f _. ~ Ir. e] .,;: 2:: :~ co ._l':S'1 :,.--j ::0 '" -..:.,. ~, ;:- 10 GREGORY L. SCHELL, LLC BY: GREGORY L. SCHELL, ESQUIRE Attorney I.D. No. 42969 230 S. Broad Street, Suite 1050 Philadelphia PA 19102 (215) 545-9000 THIS IS A MAJOR NON.JURY MAlTER. ASSESSMENT OF DAMAGES IS REQUIRED. Attorney for Plaintiff MARY ROBINSON vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY HMC HOSPITALITY MANAGEMENT CORP., D/B/A RADISSON PENN HARRIS HOTEL NO: 03.2927 PETITION OF GREGORY L. SCHELL, ESQUIRE TO WITHDRAW AS COUNSEL FOR PLAINTIFF 1. The undersigned entered his appearance as attorney for Plaintiff and thereafter caused a Complaint to be filed. Since then the undersigned has diligently represented Plaintiff in the above case through the pleading stage and initial discovery stage. 2. Presently, significant and irreparable differences have arisen between the undersigned counsel and the Plaintiff which require the undersigned to withdraw as counsel on behalf of the Plaintiff. 3. Presently the undersigned is unable to continue to represent this client and requests permission to withdraw. 4. Plaintiffs counsel requests that all proceedings stay for ninety (90) days until such time as Plaintiff have an opportunity to engage substitute counsel and that time limits be expanded accordingly. WHEREFORE, Plaintiffs counsel requests permission to withdraw. GREGORY L. SCHELL, LLC i;i ~ "-~ By' . ' .G .~.ESQ , VERIFICATION I, Gregory L. Schell, Esquire, hereby verify that the statements made in the foregoing Petition are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsifications to authorities. G~'~' GREGORY L. SCHELL, LLC BY: GREGORY L. SCHELL, ESQUIRE Attorney J.D. No. 42969 230 S. Broad Street, Suite 1050 Philadelphia PA 19102 (215) 545-9000 THIS IS A MAJOR NON-JURY MATTER. ASSESSMENT OF DAMAGES IS REQUIRED. Attorney for Plaintiff MARY ROBINSON vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY HMC HOSPITALITY MANAGEMENT CORP., D/B/A RADlSSON PENN HARRIS HOTEL NO: 03-2927 MEMORANDUM OF LAW IN SUPPORT OF PETITION TO WITHDRAW AS COUNSEL Pennsylvania Rules of Professional Conduct at Rule 1.16 require an attorney to withdraw from representation of a client upon the occurrence of certain conditions, one of which also includes Rule 3.1. Certain issues have arisen between attorney and client concerning this case which are irreparable. Under these circumstances, the Code of Professional Conduct requires the attorney to withdraw and that such be done in a way so as to protect the client's interest to the extent that is reasonably practicable. The undersigned is attempting to follow those procedures and requests this Court to issue a stay to enable him to comply with the Rules of Professional Conduct. GREGORY L. SCHELL, LLC ~ ~~ ,....., B~ '. 7 G Gj 1;~,E U g ....., ~ = = s:: ~- ~Ul x ~:n " (1" ,.. ~~\":_l :::0 (;j :\';; N :B~ --- -- cr> Q ~r.:) ..., g~ ZC'1 ::z: C >c: z ~ ~ c..n "Xi U1 ::< GREGORY L. SCHELL, LLC BY: GREGORY L. SCHELL, ESQUIRE Attorney J.D. No. 42969 230 S. Broad Street, Suite 1050 Philadelphia PA 19102 (215) 545-9000 THIS IS A MAJOR NON.JURY MATTER. ASSESSMENT OF DAMAGES IS REQUIRED. Attorney for Plaintiff MARY ROBINSON vs. COURT OF COMMON PLEAS CUMBERLAND COUNIY HMC HOSPITALITY MANAGEMENT CORP., D/B/A RADlSSON PENN HARRIS HOTEL NO: 03-2927 CERTIFICATE OF SERVICE I hereby certify that Petition to Withdraw as Counsel for Plaintiff was served upon the interested party or counsel of record set forth below, by U.S. Mail on March 24, 2004. Jeffrey B. Rettig, Esquire Hartman, Osborne & Rettig, P.C. 126-128 Walnut Street Harrisburg PA 17101 Mary Robinson 1329 N. Alden Street Philadelphia PA 19131 Christopher L. Giddings, Esquire Christopher L. Giddings, P.C. 3000 Market Street, Suite 201 Philadelphia PA 19104 GREGORY L. SCHELL, LLC / 0 ....., ~ = c: ~ ~ :x :I! ~ffi ,... m~ ;;:cl 2:1-- I'.) :8 ~.~ 0\ 0 ;<: .. -0 :1:!'+l ig :x g9. - --I ~ .. ~ c:.n CJ1 r lIAR f 201)4 GREGORY L. SCHELL, LLC BY: GREGORY L. SCHELL, ESQUIRE Attorney J.D. No. 42969 230 S. Broad Street, Suite 1050 Philadelphia PA 19102 (215) 545-9000 THIS IS A MAJOR NON-JURY MA'ITER. ASSESSMENT OF DAIMAGES IS REQUIRED. Attorney for Plaintiff MARY ROBINSON VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY HMC HOSPITALITY MANAGEMENT CORP., D/B/A RADlSSON PENN HARRIS HOTEL NO: 03-2927 RULE TO SHOW CAUSE AND NOW, to wit, this %+t day of .4-1' ,,/ , 2004, a Rule is granted upon the Plaintiff, Mary Robinson, to show cause why the Petition to Withdraw of Gregory L. ScheU, Esquire, should not be confirmed. ~t gay of ,2004, at .H. in , Cal;!ide, PA-:- .70 ota., ~ '11V .IVVI A . Said Rule is Returnable QR the AU proceedings to stay meanwhile. BY THE COURT: Co py {'(\t>.,ILOl ~o C,AmicJp\..er c;.,oloI,n "" (...otJ\f1:\On rf\.tl,lQol.. to /'\o,ry , . B fJ.eHiq i"\l\((Qf)t j.. ,J(J+rey () MU1lcot ~o G-r'-t"~Y L, Schtll A,d J. \//N\,,:j~1'\~-:i~"/i,\j::r_) I '~"'~'-. ", ,C ' 1\.1.1 .!t II 1" ,."" _' ,': ~I't.""l.", f.' .....,~ "">:>.'H IV 9c :e Sold s- ~dV MOl ;"Wl0NO}'i10dd ~}-U. dO 3J/JdO-Q371::1 GREGORY L. SCHELL, LLC BY: GREGORY L. SCHELL, ESQUIRE Attorney I.D. No. 42969 230 S. Broad Street, Suite 1050 Philadelphia PA 19102 (215) 545-9000 THIS IS A MAJOR NON-JURY MAITER. ASSESSMENT OF DAMAGES IS REQUIRED. Attorney for Plaintiff MARY ROBINSON VS. COURT OF COMMON PLEAS CUMBERLAND COUNlY HMC HOSPITALITY MANAGEMENT CORP., D/B/A RADlSSON PENN HARRIS HOTEL NO: 03-2927 PETITION TO MAKE RULE ABSOLUTE PURSUANT TO RULE 208-2 OF CUMBERLAND COUNlY RUILES OF PROCEDURE 1. The undersigned entered his appearance as co-counsel for Plaintiff and thereafter caused a Complaint to be filed. Since then, the undersigned has diligently represented Plaintiff in the investigation of this premises liability claim arising out of an accident which occurred on March 17, 2002. 2. Thereafter, significant and irreparable differences arose between the undersigned counsel and the Plaintiff, which required the undersigned to withdraw as counsel on behalf of the Plaintiff. 3. On March 26, 2004, the undersigned filed a Petition to Withdraw as Counsel for Plaintiff (which is a document of record and is incorporated herein by reference). 4. On AprilS, 2004, this Honorable Court entered a Rule to Show Cause granting Plaintiff/Respondent, Mary Robinson, thirty (30) days after selvice to file an answer thereto. A true and correct copy of the Court's Rule to Show Cause Order dated AprilS, 2004, is attached hereto, incorporated herein and marked Exhibit "A". 5. A copy of the Rule to Show Cause entered by the Court on AprilS, 2004, was served upon the Plaintiff and defense counsel on April 14, 2004, by U.S. Mail, Postage Pre-paid as evidenced by the attached letters marked collectively as Exhibit "B" hereto. 6. To date, Plaintiff!Respondent has failed to file an answer or other response to Plaintiff's Petition to Withdraw. 7. Pursuant to Rule 208-2 of the Cumberland County Rule of Procedure, Plaintiff hereby moves that the Rule accompanying Plaintiffs Petition to Withdraw as Counsel be made absolute, and that counsel be granted leave to file a Praecipe to Withdraw from representation of Plaintiff, 8. Plaintiff, Mary Robinson can thereafter proceed pro se or retain new counsel. 9. Plaintiffs current address for purposes of the Court record for service is 1329 North Alden Street, Philadelphia, PA 19131. WHEREFORE, it is respectfully requested that this Honorable Court enter the attached Order permitting counsel to withdraw as counsel for the Plaintiff. GREGORY L. SCHELL, LLC IVii-\R 2 9 2004 GREGORY L. SCHELL, LLC BY: GREGORY L. SCHELL, ESQUIRE Attorney !.D. No. 42969 230 S. Broad Street, Suite 1050 Philadelphia PA 19102 {215) 545-9000 THIS IS A MAJOR NON-JURY MATTER. ASSESSMENT OF DAMAGES IS REQUIRED. Attorney for Plaintiff MARY ROBINSON VS. COURT OF COMMON PLEAS CUMBERlAND COUNTY HMC HOSPITALI1Y MANAGEMENT CORP., D/B/A RADlSSON PENN HARRIS HOTEL NO: 03-2927 RULE TO SHOW CAUSE AND NOW, to wit, this 5'}~ day of ----At; I , 2004, a Rule is granted upon the Plaintiff, Mary Robinson, to show cause why the Petition to Withdraw of Gregory L. Schell, Esquire, should not be confirmed. c:.a;~ RlIlg ii Re8in.ab~ 01. tile. day of , 2QgQ, :!t 1>4 in RS8uI ell , Calrlishl, Pi\:- 30 dcrs q.f}~ S'((V;L(, All proceedings to stay meanwhile. BY THE COURT: .",., " &/~I{ ~ J. ~~.'!::;;'i ':s. GREGORY L. SCHELL, LLC 230 South Broad Street, Suite 1050, Philadelphia Pa 19102 215-545-9000 . 800-545-1981 . FAX: 215-545-9540 April 14,2004 Mary Robinson 1329 N. Alden Street Philadelphia PA 19131 Re: Mary Robinson vs. HMC Hospitality Management Corp., d/b/a Radfsson Penn Harris Hotel CCP, Cumberland County, No. 03-2927 Dear Ms. Robinson: Enclosed please find a copy of the Rule to Show Cause entered by the Court on April 5,2004. You have thirty (30) days from today's date within which to file an answer or response to my petition to withdraw as your attorney in this matter. Very truly yours, GREGORY L. SCHEll GLS/mch Enclosure r. GREGORY L. SCHELL, LLC 230 South Broad Street, Suite 1050, Philadelphia Pa 19102 215-545-9000 . 800-545-1981 . FAX: 215-545-9540 April 14, 2004 Jeffrey B. Rettig, Esquire Hartman, Osborne & Rettig, P.C. 126-128 Walnut Street Harrisburg PA 17101 Re: Mary Robinson vs. HMC Hospitality Management Corp., d/b/a Radlsson Penn Harris Hotel CCP, Cumberland County, No. 03-2927 Dear Mr. Rettig: Enclosed please find a copy of the Rule to Show Cause entered by the Court on April 5, 2004 in the above matter. The Court has granted Ms. Robinson thirty (30) days after selVice of the Rule within to file an answer or response to my Petition. To date, I have not heard from new counsel nor have I heard anything further from the Robinsons. Very truly yours, GREGORY L. SCHEll. GLS/mch Enclosure VERIFICATION I, Gregory L. Schell, Esquire, hereby verify that the statements made in the foregoing Petition are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsifications to authorities. - 4- ,'.. \.0 ~~ "'.,,) ~:?' () ..I;.:~ "Tl t~~ ::;:1 fi'l:!J , -Ol-n ~r.JO C.)(;. --1 _) ~]~~ t",,) ill !~ ":;) GREGORY L. SCHELL, LLC BY: GREGORY L. SCHElL, ESQUIRE Attorney LD. No. 42969 230 S. Broad Street, Suite 1050 Philadelphia PA 19102 (215) 545-9000 THIS IS A MAJOR NON-JURY MATTER. ASSESSMENT OF DA'~GES IS REQUIRED. Attorney for Plaintiff MARY ROBINSON COURT OF COMMON PLEAS CUMBERLAND COUNfY vs. HMC HOSPITALITY MANAGEMENT CORP., D/B/A RADlSSON PENN HARRIS HOTEL NO: 03-2927 CERTIFICATE OF SERVICE I hereby certify that Petition to Make Rule Absolulte Pursuant to Rule 208-2 of Cumberland County Rules of Procedure was served upon the interested party or counsel of record set forth below, by U.S. Mail on June 14, 2004. Jeffrey B. Rettig, Esquire Hartman, Osborne & Rettig, P.C. 126-128 Walnut Street Harrisburg PA 17101 Mary Robinson 1329 N. Alden Street Philadelphia PA 19131 Christopher L. Giddings, Esquire Christopher L. Giddings, P.C. 3000 Market Street, Suite 201 Philadelphia PA 19104 GREGORY L. SCHELL, LLC >> ........-/ By' 'G . 0 ~,~QU ~l ~-; ~? \..:;:) ....., C;::;~ C:::-l "'- t=: :;;:;:: o ~n ::;;;! f'li ::!J r-' ~,cq hi ,"u f~i~ f'o,) Q:) ':>::'." ::1: --: 5:] ~'""': GRf.GOR'i \.~ S\-C~z~~\l:~~QU\~ <p't.. G~GOR 'f{l969 p..\io'Cfle\} \.D'~;~eet suite 1050 230 S. <ptOall \02 p'ni\ade\'P'nia P p.. 19 ~215) 545-9000 }l\p..R'i RO~\NSON R NONoJOR'i 1\\\S \S p.. }l\p..;~SS}I\f.N1 Of }l\p..'ft€G1\.,;,~;s Rf.QO\Rf.D. Dp..}I\N'" p..\io'Cfle\} tot p\aintitt oR'f Of CO}l\}I\ON l'\.\:J'.S ~~}I\~f.Rv.ND COO~ : "s. ~p..Gf.to\f.N1 \\}I\C \\OSl'\1~~\SSON l'f.NN CORl'., D~/p.. \\p..RR\S \\01f.\. NO: 0302921 '. : .1 rrect coop\} ot a R\! . \1.) t'nat a tcUe anll CO , '" 0'" "",,,, "'" 0< "'~ 0' \ G"'''''' \- _, , q' d n"" ",,,,,,,d""'" ' , . S ",,' ~","'" 01'" d b ""Ib"" , Sb .. C.- da"" ,,,,,,' '\ \' ...., " ~ ' o U S ~ai\O'(\ Mlt\ ' .1 set ton'n be\oVJ, b\} .' tecotll Cf.R1\f\Cp..1f. Of Sf.R\1\Cf. 'neteto. ", tI' f-sC\uite Jettce\} <p. ~e 113, 8t Rettig, l'.C, \\attt'l\llt\. Osbot\le 126-128 \/'Ja\nut Stceet r\arr\sbutg pp.. 1"7101 ~a'C'} Robinson 1329 N. ~den Street p'ni\ade\'P'nia pp.. 19131 GRf.GOR'i \.. SC\\f.\.\.' \.\.C <P\}'. - GREGORY L. SCHELL, LLC 230 South Broad Street, Suite 1050, Philadelphia Pa 19102 215-545-9000 . 800-545-1981 . FAX: 215-545-9540 April 14, 2004 Mary Robinson 1329 N. Alden Street Philadelphia PA 19131 Re: Mary Robinson vs. HMC HosPitality Mcrnagement Corp., d/b/a Radlsson Penn Harris Hotel CCP, Cumberland County, No. 03-292:r Dear Ms. Robinson: Enclosed please find a copy of the Rule to Show Cause entered by the Court on April 5,2004. You have thirty (30) days from today's date within which to me an anSWer or response to my petition to withdraw as your attorney in this matter. Very truly yours, GLS/mch Enclosure GREGORY L. SCHELL r, GREGORY L. SCHELL, LLC 230 South Broad Street, Suite 1050, Philadelphia Pa 19102. 215-545-9000 . 800-545-1981 . FAX: 215-545-9540 April 14, 2004 Jeffrey B. Rettig, Esquire Hartman, Osborne & Rettig, P.C. 126-128 Walnut Street Harrisburg PA 17101 Re: Mary Robinson vs. HMC HosPitality Management Corp., d/b/a Radlsson Penn Harris Hotel CCP, Cumberland County, No. 03.292,r Dear Mr. Rettig: Enclosed please find a copy of the Rule to Show Cause entered by the Court on April 5, 2004 in the above matter. The Court has granted Ms. Robinson thirty (30) days after service of the Rule within to file an answer or response to m1' Petition. To date, I have not heard from new counsel nor have I heard anything further from the Robinsons. Very truly yours, GLS/mch GREGORY L. SCHEU. Enclosure ..,~ ' l~' n c r--> ..-...;.:.> <"" ~ <- C: N CD l.- l.~ ~:,: :2 ~~'~ o -n ~-n fn F'~ -Cl~ -:"C)~;-" (~~O ::i:;-\ {:,2;;'""i ;:~), {Ii ,-0 w .:,) :--..,: if GREGORY L. SCHELL, LLC BY: GREGORY L. SCHELL, ESQUIRE Attorney I.D. No. 42969 230 S. Broad Street, Suite 1050 Philadelphia PA 19102 (215) 545-9000 JUN ~04 THIS IS A MAJOR NON.JURY MATTER. ASSESSMENT OF DAMAGES IS REQUIRED. Attorney for Plaintiff MARY ROBINSON VS. COURT OF COMMON PLEAS CU]~BERLAND COUNTY HMC HOSPITALITY MANAGEMENT CORP., DIBIA RADISSON PENN HARRIS HOTEL NO: 03-2927 ORDER AND NOW, to wit, this t8 day of ~1...!.r , 2004, upon consideration of the Petition to Withdraw of Gregory L. Schell, Esquire, it is hereby ORDERED and DECREED that counsel shall be permitted to withdraw their appearance as attorney for Plaintiff by the filing of a Praecipe within thirty (30) days of the date hereof. BY THE COURT: A-d J. J11 t: fl 1. ' ~ ')-- ~ \. 'f , , ,f> \fINV^lASNN3d Ilt'nO"'1 nl ",n,j~q'i"I1" 1\J..,~ '.. \,:,',.; \'_,:,,"'>It~. IV 6 Z :21 ~ld 9- lnr ~OOZ AlN10NOf-UOod 3Hl :JO 3Dl:!~O-a311::! GREGORY L. SCHELL, LLC BY: GREGORY L. SCHELL, ESQUIRE Attorney J.D. No. 42969 230 S. Broad Street, Suite 1050 Philadelphia PA 19102 (215) 545-9000 THIS IS A MAJOR NON-JURY MATTER. ASSESSMENT OF DA!\fAGES IS REQUIRED. Attorney for Plaintiff MARY ROBINSON vs. COlURT OF COMMON PLEAS CU]~BERLAND COUNTY HMC HOSPITALITY MANAGEMENT CORP., D/B/A RADlSSON PENN HARRIS HOTEL NO: 03-2927 PRAECIPE TO WITHDRAW APPEARANCE ON BEHALF OF PLAINTIFF TO THE PROTHONOTARY: Kindly withdraw the appearance of the undersigned as attorney for plaintiff in accordance with Order of Court, dated July 6, 2004, a copy of which is attached as Exhibit "A" and incorporated herein. GREGORY L. SCHELL, LLC ~~? By: ' . ego L. S If, Es ire / / GREGORY L. SCHELL, LLC BY: GREGORY L. SCHELL, ESQUIRE Attorney !.D. No. 42969 230 S. Broad Street, Suite 1050 Philadelphia PA 19102 (215) 545-9000 JUN 3 0 2004 THIS IS A MAJOR NON-JURY MATTER. ASSESSMENT OF DAMAGES IS REQUIRED. Attorney for Plaintiff MARY ROBINSON COURT OF COMMON PLEAS CUMBERLAND COUNlY vs. HMC HOSPITALITY MANAGEMENT CORP., D/B/A RADlSSON PENN HARRIS HOTEL NO: 03-2927 ORDER AND NOW, to wit, this t.. e- day of -44 , 2004, upon consideration of the Petition to Withdraw of Gregory L. ScheU, Esquire, it is hereby ORDERED and DECREED that counsel shaD be permitted to withdraw their appearance as attorney for Plaintiff by the filing of a Praecipe within thirty (30) days of the date hereof. BY THE COURT: ~/''M_- (I /-bA-d r. J. rRUE COPY FROM RECOQu In Telitimoo)' wharllOf. I ogre urtto set ~ halld md the ~I of said ~ at CarIlsle,Pa. fhls-1L ;7 (If ~ ~ ' (k ,,,. p~. , ProthonfJ1a(~ '. 0 "" = 0 c = TJ ~:" oS:" ~,[fj c.... :;:l c:: -~'Tl Z,'::- r- n'F -7 ~- }lg] ~.~-~:: W 01 r-.-"; ,--iO -" ":t-:=r1 )":.~ c:: ." ~C) ::x ~:;?O Pc t)rn -'':.1 ...-.. 1:'.... =< c:> :n ... -< GREGORY L. SCHELL, LLC BY: GREGORY L SCHELL, ESQUIRE Attorney I.D. No. 42969 230 S. Broad Street, Suite 1050 Philadelphia PA 19102 (215) 545-9000 THIS IS A MAJOR NON-JURY ~[A1TER. ASSESSMENT OF DAMAGES IS REQUIRED. A1torney for Plaintiff MARY ROBINSON vs. COURT OF COMMON PLEAS CUMBERLAND COUNlY HMC HOSPITALllY MANAGEMENT CORP., D/B/A RADISSON PENN HARRIS HOTEL NO: 03-2927 CERTIFICATE OF SERVICE I, Gregory L Schell, Esquire hereby certify that a copy of the Court's Order of July 6, 2004 and Praecipe to Withdraw Appearance 4)n Behalf of Plaintiff were served J.pon the interested party or counsel of record set forth below, by U.S. Mail on f q , 2004. . Jeffrey B. Rettig, Esquire Hartman, Osborne & Rettig, P.C. 126-128 Walnut Street Harrisburg PA 17101 Mary Robinson 1329 N. Alden Street Philadelphia PA 19131 GREGORY L. SCHELL, LLC By: G / -2- o ,C -oS:: I1Tt~; ~f!: (J)}. -<-" .-: "''' ~C ~c: i:;:::C) ~c:: 2' .'3 -, ...., = = ..- c.... c:.:: r- o -r, :r! rnfJ -om :.09 06 ::;:f-;d. -....-r.l -00 ~5nl -j )> :J) -< W .." :x o ..,.. CHRISTOPHER L. GIDDINGS, P.C. By: Christopher L. Giddings Attorney Identification No.: 72063 3000 Market Street, Suite 201 Philadelphia, PA 19104 (215) 243-3450 Attorney for Plaintiffs MARY ROBINSON COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. HMC HOSPITALITY MANAGEMENT CORP., d/b/a RADISSON PENN HOTEL NO: 03-2927 WITHDRAWAL OF APPEARANCE To the Prothonotary: Kindly withdrawal my appearance as attorney for plaintiff for the above captioned matter. CHRlSTOPF~R L. GIDDINGS, P.C. By~~L~ Attorney for Plaintiff ....., C21 C,? ""- ~'~.~ I '.0 C! ~.. C') (~, o MARY ROBINSON 1329 N. Alden Street Philadelphia, PA 19131 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 03-2927 Civil Term v. HMC HOSPITALITY MANAGEMENT CORP. d/b/a RADlSSON PENN HARRIS HOTEL 1150 Camp Hill Bypass CampHill,PA 17011 CIVIL ACTION - LAW JURY TRIAL DEMANDED Defendant ORDER OF COURT AND NOW 4;0~ /3 ,2004, in consider~on of the foregoing Petition for Appointment of Arbitrators, ~ Jiu ~' Esquire, 11ltlAJ!- iJd~, Esquire and (~ r ' Esquire, are appointed arbitrators in the above-captioned actt2 as prayed for. BY THE COURT f,J. '\!_.~/'" 1;/1'["\ ~H ~..: .,' " ',"'_:i';:: r' f,., ~iCUZ :::Hl i'..... - , --' MARY ROBINSON 1329 N. Alden Street Philadelphia, PA 19131 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 03-2927 Civil Term HMC HOSPITALITY MANAGEMENT CORP. d/b/a RADISSON PENN HARRIS HOTEL 1150 Camp Hill Bypass Camp Hill, PA 17011 CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED PETITION FORAPPOINTMl?NT OF ARBITRATORS TO: THE HONORABLE, THE JUDGES OF SAID COURT: Hartman, Osborne & Rettig, P.C., counsel for the Defendant, HMC Hospitality Management Corp., d/b/a Radisson Penn Harris Hotel, in the above action, respectfully represents that: I. The above-captioned action is at issue. 2. The claim of the plaintiff in the action is less than $25,000. The following attorneys are interested in the case as counselor are otherwise disqualified to sit as arbitrators: Jeffrey B. Rettig, Esquire; Plaintiff is pro se. WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, I' By --a! / Jeffrey B. Rettig, Es e Supreme Ct.I.D. #19616 126-128 Walnut Street Harrisburg, PA 17101 (717) 232-3046 Attorneys for Defendant, Radisson Penn Harris Hotel ~ ~ A.f\4 ~ G- . \ ......... ""'- ~ ).i \ G )v }l .::\ -0 \ MARY ROBINSON Plaintiff v. HMC HOSPITALITY MANAGEMENT CORP. d/b/a RAmSSON PENN HARRIS HOTEL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2927 Civil Term CIVIL ACTION - LAW JURY TRL<\L DEMANDED PRAECIPE TO DISCONTINU~ TO THE PROTHONOTARY: Please discontinue the above-referenced matter with prejudice. Dated:~ 1?ljlf By:~(L~~ Mary b nson 1329 orth Alden Street Philadelphia, PA 19131 Pro Se Plaintiff () C- 1:.1 ~~~ Qlh': ~~,. CiJ r~ ~~:,: ~ """ = = ..,... 0) r"'l V N CO ~ --j m:n -olTi ~~ ?'5-d 20 r")m ~:;I ,::r.'" .:'.';1 .........,: -0 :x o 00 CHRISTOPHER L. GIDDINGS, P.C. By: Christopher L. Giddings, Esquire Attorney Identification No. 72036 3000 Market Street, Suite 201 Philadelphia, PA 19104 (215) 243-3450 ATTOKNEYFORPLArnTWF MARY ROBINSON COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. HMC HOSPITALITY MANAGEMENT CORP., D/B/A RADISSON PENN HARRIS HOTEL NO. 03..2927 ORDER TO MARK ACTION SETTLED, DISCONTINUED AND ENDED TO THE PROTHONOTARY: Please mark the above action settled, discontinued and ended as to all claims and cross claims against defendant HMC Hospitality Management Corp., d/b/a Radisson Penn Harris Hotel. ~~~ Christopher L. Giddings 3000 Market Street, Suite 201 Philadelphia, PA 19102 Attorney for Plaintiffs -'" "'" <:::::-~, <..~c;;. ...- co -r:1 C,) V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2927 CIVIL MARY ROBINSON HMC HOSPITALITY MANAGEMENT CORP. d/b/a RADISSON PENN HARRIS HOTEL IN RE: APPOINTMENT OF ARBITRATORS ORDER OF COURT AND NOW, December 9, 2004, Frederick Huganir, Esquire, having previously been appointed as chairman of the arbitration panel in the above matter and having learned that the case was withdrawn, the panel of arbitrators previously appointed is vacated, and Attorney Huganir is awarded the sum of $50.00. By the Court, Geo~ P.J. Court Administrator /Frederick Huganir, Esquire - L~ I J.. -I~" >.. - -~ ~.- cr.: C"'; "".::1: j--- C',-J t~J tf -) .' u_ , , {'-;r" , Ie C'\ - ot::_ I " LU 0_ f:i: ~,~,l c:> I.,,) F t::l 1.1-. _:f- e"" 0 c:::;. """ --- MARY ROBINSON V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2927 CIVIL HMC HOSPITALITY MANAGEMENT CORP. d/b/a RADISSON PENN HARRIS HOTEL IN RE: APPOINTMENT OF ARBITRATORS ORDER OF COURT AND NOW, December 9, 2004, Frederick Huganir, Esquire, having previously been appointed as chairman of the arbitration panel in the above matter and having learned that the case was withdrawn, the panel of arbitrators previously appointed is vacated, and Attorney Huganir is awarded the sum of $50.00. By the Court, P.J. Court Administrator ~ Frederick Huganir, Esquire