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HomeMy WebLinkAbout99-06574 , Z) I r P+ , f t e ? y t ?' eta n i Ir ; y a. is } 4 f l i +)1? t Yi#i lv Y ?{ xt? + "n A & ka r e J r ?M ? t? - z 'i ? J "? - ' , j Y{ f { t C R?< xt1 k} ih?{ f. ? Js, t yi R Y? i Y F `: • k l?:R t ?J^ S its A: , r r -4 ,._.. t '? } T h R v r >ws Q - "gip ivy THOMAS D. BRAITHWAITE and : IN THE COURT OF COMMON PLEAS OF CHERYL A. BRAITHWAITE, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs CIVIL ACTION?-L/AW V. NO. 97 -6-en HARBOLD'S FORD and FORD MOTOR COMPANY, Defendants : JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint of 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 TRUE COPY FROki RECORD in Tosti whs•rof, t -wa unto." my Rana and th I cf aid Ca I his THOMAS D. BRAITHWAITE and : IN THE COURT OF COMMON PLEAS OF CHERYL A. BRAITHWAITE, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs CIVIL ACTION-LAW V. n :NO. 9q. L5,7 L/ HARBOLD'S FORD and FORD MOTOR COMPANY, Defendants : JURY TRIAL DEMANDED COMPLAINT 1. The Plaintiffs, Thomas D. Braithwaite and Cheryl A. Braithwaite, are adult Individuals who currently reside at 3790 Spring Road, Shermansdale, Cumberland County, Pennsylvania. 2. The Defendant, Harbold's Ford, Inc. Is a licensed Pennsylvania Corporation located at 700 M.R. Route 15N, Dillsburg, York County, Pennsylvania, whose business is that of selling and buying automobiles. 3. Defendant Ford Motor Company is a corporation organized and existing under the laws of Delaware, with a registered office of CT Corp. Systems, 1635 Market Street, Philadelphia, Pennsylvania 19103. 4. On July 2, 1998, Plaintiffs purchased a 1998 Ford F150 Pickup Truck, VIN 1 FTZF18W3WNB95429, from the Defendant. A copy of the sales agreement and vehicle invoice are attached as "Exhibit A". 5. During the month of August 1998, Plaintiffs began to experience a problem with what appeared to be the acceleration power; the vehicle would not accelerate past 90 miles per hour. 6. Plaintiffs took their vehicle back to Defendant who assured Plaintiff it would be checked out. 7. On August 9, 1998, Plaintiff went to Defendant's to pick up the vehicle after they completed repairing it. Plaintiff was unable to get the vehicle out of the park gear. 8. August 10. 1998, Plaintiff took a vacation day from work to go to Defendant's to explain to them what happened the day before; Again they assured him that it would be checked out. 9. Defendant looked at the vehicle for an hour and a half and told Plaintiff that the interlock had been disconnected and that he had fixed it. Plaintiff was given no reason for this occurrence. 10. Plaintiff was given his vehicle back and told that to continue to drive his vehicle and see if the new engine would work itself out. 11. Plaintiff continued to experience a power loss when attempting to pass other vehicles and the vehicle would idle roughly at intermittent times. Plaintiff would notice a difference in the vehicle's performance when driving on the interstate highways and secondary roads. 12. On August 26, 1998 Plaintiff took his vehicle to Defendant to address the vehicle problems again. Defendant looked over the vehicle and told Plaintiff that no codes were found and that he could continue to drive the vehicle. 13. Due to the problems the vehicle was experiencing, Plaintiff was almost involved in an accident while trying to pass another vehicle, in a properly marked stretch of road, his vehicle would not accelerate to the point of allowing Plaintiff to pass and he was almost involved in a head on collision. 14. Plaintiff decided to allow his 24-year-old son drive the vehicle to confirm the power problems. Plaintiffs son returned the vehicle within a 48 hour time period and told Plaintiff that he thought the shift points were off. 15. December 29, 1998 Plaintiff took his vehicle for service again informing the Defendant what his son had said, to which the Defendant responded "Is he a transmission expert?" Defendant told Plaintiff that it would be checked out, and again they told him no codes found continue to drive the vehicle. 16. Oo approximately March 13, 1999 while Plaintiff was in the Williamsport Areas he attempted to ascend a steep hill on Route 15. As his vehicle accelerated it shifted into a lower gear as the RPMS rose Plaintiff realized it would not shift to a higher gear. Plaintiff removed his foot from the accelerator and heard a loud noise and the transmission shifted with an extremely violent jolt. Plaintiff proceeded to call Defendant immediately. 17. March 16, 1999, Plaintiff took an hour to an hour and a half test drive with a transmission tech during which the tech pointed out certain anomalies in the way the transmission was operating. When they returned to the dealership pressure tests were preformed on the transmission. The tests indicated problems so the transmission was rebuilt, instead of replaced. Defendant told Plaintiff that they had to rebuild instead of replacing because there were no transmissions available. 18. Rebuilding the transmission cause the Plaintiff to be without his vehicle for 21 days, a loaner was provided. 19. Plaintiff received the vehicle and noticed a gradual return of the problems within a three-day period. The problems included no power on passing, not down shifting when needed, and when the Plaintiff reached the speed of 100mph during a long run the vehicle shut down. 20. May 6, 1999 the Plaintiff took the vehicle to the Defendant and engaged In a test drive with Denny Miller during which Plaintiff stopped the vehicle and engaged the 4 wheel drive and accelerated creating a loud clunk in the rear of the vehicle. 21. May 10, 1999 Plaintiff went to the dealership to pick up his vehicle and was told that no codes were found again and nothing could be found wrong with the rear of the vehicle. Mr. Miller proceeded to tell Plaintiff that he could not make monoy doing warranty work and therefore could not spend time trying to solve problems that did not give codes In the processor. During this visit Mr. Miller also provided Plaintiff with a document from the Ford Technical people concerning the 100miles per hour shut down, which is attached as "Exhibit B". Mr. Miller also told Plaintiff that he test drove the vehicle for about 50 to 60 miles which is not indicated by the mileage in and mileage out on invoice 45324. 22. Plaintiff has made many calls to the Ford Customer Service hotline and has received erroneous information and bad service. 23. Under the Automobile Lemon Law, 73 P.S. Section 1956, the Plaintiffs have more than met the requirements, however the Defendants still refuse to repurchase the Plaintiffs vehicle. 24. The Defendants are in direct violation of the Automobile Lemon Law, 73 P.S. Section 1955, which states that the manufacturer has a duty to refund or replace the vehicle after reasonable attempts are made to repair the vehicle. WHEREFORE, for all the above reasons the Plaintiffs respectfully request this court to order the repurchase of the defective vehicle and to award attorneys fees and court costs on behalf of the Plaintiffs. /j ?2SI?S£ Date Respectfully Submitted TURO LAW OFFICES M/&- Robert ulde ig 32 South Bedford Street Caiisle, PA 17013 (717) 245-9688 Attorney for Plaintiffs -11?11?C c • ? I verify that the statements made In the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. OJ4-91 1999 Date Thomas D. Braithwaite r. n b I u: ?" MIII cy O d ? C, V 4- '?1 DOBIS & REILLY, P.A. 5494 Perkiomen Avenue #313 Reading, Pennsylvania 19606 (610) 689-8698 Attorneys for defendant, Ford Motor Company ID #68550 THOMAS D. BRAITHWAITE and CHERYL A. BRAITHWAITE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CASE NO. 99-6574 Plaintiffs, V. Civil Action HARBOLD'S FORD and FORD MOTOR COMPANY, Defendants. AND NOW, comes defendant, Ford Motor Company, by its attorneys, Dobis & Reilly, P.A., and files the within Answer and New Matter as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. S. Ford denies the existence of a non-conformity. 6. Ford denies that it made any assurances to the plaintiff. 7. Ford denies making any repairs to the plaintiffs vehicle. It admits, however, that Harbold's Ford may have made repairs to the vehicle. 8. Ford denies that it made any assurances to the plaintiff. 9. Ford denies looking at the subject vehicle. 10. Ford denies any conversations with the plaintiff. 11. Ford denies the existence of a non-conformity. 12. Ford denies that the plaintiff brought the vehicle to it. 13. Ford was not present at the time of the alleged occurrence, and therefore, it cannot respond. 14. Ford denies that the transmission shift points were off. 15. Ford was not present during this conversation, and therefore, it cannot respond. 16. Ford denies any non-conformity with the transmission. 17. Ford was not present at the time of this conversation or test drive, and therefore, it cannot respond. 18. The repair order referred to is not attached, so Ford can make no comment as to what repairs were made. 19. Ford denies the existence of a non-conformity. 20. Ford was not present at the time of this test drive, and therefore, it cannot respond. 21. Ford was not present at the time of this test drive, and therefore, it cannot respond. 22. Ford denies giving erroneous information or bad service to the plaintiff. 23. Plaintiff does not qualify for relief under the Pennsylvania Lemon Law. 24. Denied. NEW MATTER 25. The alleged non-conformity, defect or condition does not substantially impair the use, value or safety of the vehicle. 26. Plaintiffs vehicle was used for commercial purposes and therefore outside the purview of the Pennsylvania Lemon Law. 27. The non-conformity, defect or condition is the result of abuse, neglect or unauthorized modifications or alterations of the motor vehicle. 28. Any and all injuries and damages sustained were the result of a third party over whom this party had no control. 29. Plaintiff failed to comply with the statutory prerequisites for filing a Lemon Law claim. WHEREFORE, this defendant requests this Honorable Court to enter judgment in its favor. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. CERTIFICATION I hereby certify that a copy of the within document has been filed with the Prothonotary's Office in the Court of Common Pleas of Cumberland County, PA, Civil Action and that a copy of the same was served upon all interested attorneys within the period of time allowed in accordance with the Rules of the Court. DOBIS & REILLY, P.A. Attorneys for defendant, Ford Motor Company BY: RXUL K. RUSSELL I.D. #70882 5494 Perkiomen Avenue #313 Reading, Pennsylvania 19606 (610) 689.8698 DATED: November 17, 1999 CERTIFICATE OF MAILING 1, James S. Dobis, Esq., do hereby certify that service of a true and correct copy of the within defendant's, Ford Motor Company, Answer with New Matter to Plaintiffs Complaint was made on this 17th day of November, 1999, to the below listed counsel by United States mail, postage prepaid. Robert J. Mulderig, Esq. TURO LAW OFFICES 32 South Bedford Street Carlisle, PA 17013 JAMES S!OBIS, ESQ. s tl r F _s t co s ?.. N . x u.. p. 'r t? a a 4X 1 ?T Jt , SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-06574 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BRAITHWAITE THOMAS D ET AL VS. HARBOLDS FORD ET AL R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: HARBOLD'S FORD but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania. to serve the within COMPLAINT AND NOTICE On November 22nd, 1999 this office was in receipt of the attached return from YORK County, Pennsylvania. Sheriff's Costs: So answ s• 1 Docketing 18.0 , Out of County 9.00 < <-+-` Surcharge 8.00 K./ -Immcw , York County 34.88 RO ERT J. MULDERIG 1999 Sworn and subscribed to before me this ? day of k9 ,7_ 011t) A.D. ,.YaL'7f6P B?SlQt:?C SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-06574 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BRAITHWAITE THOMAS D ET AL VS. HARBOLDS FORD ET AL R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: FORD MOTOR COMPANY but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of PHILADELPHIA County, Pennsylvania. to serve the within COMPLAINT AND NOTICE On December 10th, 1999 , this office was in receipt of the attached return from PHILADELPHIA County, Pennsylvania. Sheriff's Costs: So answers: Docketing 6.00 //77 ;„?. Out of County 9.00 ?y? T?c% Surcharge 8.00 , HAY'S Philadelphia Co. 116.00 $T3,9 n RO ERT19. MULDERIG Sworn and subscribed to before me this day of?? XP-?20yt) A.D. LUALb?CILy s • • • • • • A • • • • • • COUNTY OF YORK ERCE OFFICE OF THE SHERIFF S( 117)71960 L 28 EAST MARKET ST, YORK, PA 17401 SHERIFF SERVICE INSTRUCTIONS PROCESS RECEIPT, and SERVICE AFFIDAVIT OF RETURN PLEASE TYPE ONLY LINES 1 TO 12 DO NOT DETACH ANY COPIES. Thomas D. Braithwaite 3. DEFENDANT/S/ Harbold's fiord, et. al. -6574 Civ Notice & Complaint SERVE S. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO DE LEVIED, ATTACHED, OR SOLD. W_ Ilarbol.d's Ford 8. ADDRESS (STREET WITH % NUMBER, N CITY. P., STATE AN I CODE SERVICE: 0 PERSONAL NOW I L `? y 19 _ 1, SHERIFF ORMORK COUNTY PA hereby de a sheriff of Yo COUNTY to exec rid a at according to law. This deputation being made at the request and risk of the plaintiff. = , 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Cumbt?rlarf ADVANCE FEE PD BY A'Y CUMBOU MID COUNTY SHERIFF t NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN • Any deputy then" levying upon or anachm0 any property Wider vnthm will Inay leave same w1Uqu1 a wsltlunan, In custody of whomever is found in possession, a"er notifying person of IM or attachment, w pout liability on the part of such deputy or the then" to arty pWnti f herein lot any loss, destruction. or removal of any property before shenes sale thereof. 9. TYPE NAME AND ADDRESS of ATTORNEYIORIGINATOR and SIGNATURE I I 10. TELEPHONE NUMBER It. DATE FILED Robert J. Mulderiq, Esq. 19 n_. " n,.JC--A oW---1 ...._,,..,,, ?A 17PAII 717-245-9688 10/29/99 Cumberland County Sheriff _ 1 13.1 acknowledge receipt of the wnt SIGNATURE OF AUTHORIZED CLERK 14. Date Received 15. EslaratgrvHJalagilalA orcomp41nLaslndicetedabove . B Feeser 11/4/99 11/28/99 I&HOW SERVED: PERSONAL( ) RESIDENCE ( 1 POSTED( 1 POE' SHERIFF'S OFF ( ) OTHER ( ) SEE REMARKS 17, 0l here certify and return a NOT FOUND because I am unable to locale the individual, company. corporation, etc, named some. (Soo remarks below) 15. NA 0 TITLE OF INDIVIDUAL EEVED I LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Date of Service 20. Time or Service 21. ATTEMPTS Data Tlm MilesI In4 ate ilme Mllelnt. Date Tlma Mlles nl Dab I Tlm• Mlles Int. Oati I Time' Mlle InL Data I Tlme'i M!les, Int. i I 23. Advance Costs 24. SON" Costs $100.00 18.00 25. WF 28. Mileage 14.88 27. Postage 28. Suit Total 32.88 29 Pound 30. Notary Fee 2.00 31. Surcharge 32. Total TO R ]]. Cost Due e 12_ 34. Foreign County Costs 35. Advance Costs 38. SON" Costs 37. Notary Cert. 38. MJOaga/PostagaN F. 39 Total Costs 40. Cost Due or Refund SO ANSVjER. 4I. AFFIRM o talons me INS 18th 44 gnatuie o -r- , . 47.Date I 1 TJIRIA(rL 9 45 Signature of York 1?itTt IIlC Sf a ll?ATI ?l 4B 42. day of 19 County Shen" WI 1j, I A1.1 M Iln ri it mpr YJIW?Y rk.Y k ° ?_el 11/18/99 43. _ MV COMMISSION EXPIRES ?' c 48 pnaNra o or^,gn ,- County Shen" 49 Dale 0134.3/3 50AACKNOWLEDGE RECEIPTOF THE SHERIFF'S HETUFIN uwnAIUnc OF AUTHORIZED ISSUING Al ITHORITY AND TITLE 1. WHITE • Issuing Authority 2. PINK • Attorney 3 CANARY • Shontra OeKe 4 BLUE • Sheriff $ O"Ke SNERIPP"S RE-URN _ SUMMCNSi CCMPLAINT 74? ?,?/T T/?Cc?AiTF aCMMCN PL.ZAS NO. ruNTV CCU ecuRc VERSUS TERM. 19 99 I?O/'?"o M'0 To l' 0p ra. (o S 7 `f /7 /c e,- e9?? ys??M ? Defendant SERVED AND MADE KNOWN TO Iq/,'?? = 'V/'? "' 2 © Defendant Company by handing a true and attested copy of the within Summcns/Complaint, issued in the above captioned matter on // - /U , 19 at /LUG a'c!ock, N. E.S. /D.S.T. at 3 in the County of Philadelphia, State of Pennsylvania, to 4O L ? (1) the aforesaid defendant, personally; ? (2) an adult member of the family of said defendant, with whom said defendant resides, who stated that his/her relationship to said defendant is that of ? (3) an adult person in charge of defendant's residence; the said adult person having refused, upon re- quest, to give his/her name and relationship to said defendmrt; ? (4) the manager/c!erk of the plcce of lodging in which said defendant resides; (5) agent or person for the time being in charge of defendant's office or usual place of business. ? (6) the and officer of said defendant Company; So Answers, JCNN O. GREEN. Sheriff fey. ?2-•._ ?.?. U o.PU:7 SBerill 1241 (Re.. 12,91) In The Court of Common Pleas of Cumberland County, Pennsylvania Thomas D. Braithwaite, et. al. VS. Harbold's Ford, et. al. Serve: Ford Motor Company No. 99-6574 Civil Now, 11 3 9 9 , 19_, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of _ Philadelphia County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Now, within upon at by handing to _ a and made known to So answers, the contents thereof. Sheriff of Sworn and subscribed before me this _ day of , 19 19_, at o'clock M. served the Affidavit of Service copy of the original COSTS SERVICE MILEAGE _ AFFIDAVIT County, PA S S D013IS &'REILLY, P.A. 1173 Berkshire Boulevard #330 Wyomissing, Pennsylvania 19610 (610) 689.8698 Attorneys for defendants, Harbold's Ford and Ford Motor Company ID #70882 THOMAS D. BRAITHWAITE and CHERYL A. BRAITHWAITE, Plaintiffs, V. HARBOLD'S FORD and FORD MOTOR COMPANY, Defendants. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CASE NO. 99-6574 Civil Action AND NOW, comes defendant, Harbold's Ford, by its attorneys, Dobis & Reilly, P.A., and files the within Answer and New Matter as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Defendant denies the existence of a non-conformity. 6. Defendant denies that it made any assurances to the plaintiff. 7. Admitted. i 8. Defendant denies that it made any assurances to the plaintiff. 9. Defendant admits that the appropriate repair was made and denies any further allegations. 10. Defendant denies the characterization of the conversation. 11. Defendant denies the existence of a non-conformity. 12.' Defendant denies the characterization of the conversation. 13. Defendant was not present at the time of the alleged occurrence, and therefore, it cannot respond. 14. Defendant denies that the shift points were off. 15. Defendant denies the characterization of the conversation. 16. Defendant was not present at the time of the alleged occurrence, and therefore, it cannot respond. 17. Admitted. 18. Admitted. 19. Defendant denies the existence of any non-conformities. 20. Defendant denies the existence of a non-conformity. 21. Defendant denies the characterization of the conversation but admits the authenticity of document Special Service Message 04903. 22. Defendant was not present at the time of the alleged occurrence, and therefore, it cannot respond. 23. Plaintiff does not qualify for relief under the Pennsylvania Lemon law. 24. Denied. The Pennsylvania Lemon Law does not apply to dealers. NEW MATTER 25. The alleged non-conformity, defect or condition does not substantially impair the use, value orlsafety of the vehicle. 26. The alleged non-conformity, defect or condition is the result of abuse, neglect or unauthorized modifications or alterations of the motor vehicle. 27. Any and all injuries and damages sustained were the result of a third party over whom this party had no control. 28. Plaintiff failed to comply with the statutory prerequisites for filing a Lemon Law claim. WHEREFORE, this defendant requests this Honorable Court to enter judgment in its favor. PLEASE TAKE NOTICE that PAUL K. RUSSELL, ESQ., is hereby designated as trial counsel. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. I hereby certify that a copy of the within document has been filed with the Prothonotary's Office in the Court of Common Pleas of Cumberland County, PA, Civil Action and that a copy of the same was served upon all interested attorneys within the period of time allowed in accordance with the Rules of the Court. DOBIS & REILLY, P.A. Attorneys for defendants, Harbold's Ford and Ford Motor Company BY: ' / 21 PAUL K. RUSSELL I.D. #70882 1173 Berkshire Boulevard #330 Wyomissing, Pennsylvania 19610 (610) 689-8698 DATED: May 17, 2000 CERTIFICATE OF MAILING I, Paul K. Russell, Esq., do hereby certify that service of a true and correct copy of the within defendant's, Harbold's Ford, Answer with New Matter to Plaintiffs Complaint was made on this 17th day of May, 2000, to the below listed counsel by United States mail, postage prepaid. Robert J. Mulderig, Esq. TURO LAW OFFICES 32 South Bedford Street Carlisle, PA 17013 PAUL K. RUSSELL, ESQ. <_;a k Y '? - r, , ?'. ?i: u.? , . c_ ? .. tj.,', t'... - ? t. ? ???_ c,t i ?. A.• L ? ' , ?- a _ - ._ * 1?. ?_? ? . G c: f _? i ,?: r '` <ti ??? '? {? ti THOMAS D. BRAITHWAITE and CHERYL A. BRAITHWAITE, Plaintiffs V. HARBOLD'S FORD and FORD MOTOR COMPANY, Defendants TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW : NO. 99-6574 JURY TRIAL DEMANDED PRAECIPE Please settle, withdraw and discontinue the above-captioned matter on behalf of the Plaintiff. Respectfully Submitted TURD LAW OFFICES off: 'r?l Date Carol L. Cingranelli, Esqu' _aLdZ 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiffs I hereby certify that I served a true and correct copy of the foregoing document by First Class Mail, postage prepaid, upon the following: Paul Russell, Esquire Dobis & Reilly 326 South Livingston Avenue Livingston, NJ 07039 zz LL Date TURO LAW OFFICES i y: Carol L. Cingranell"?Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff cl, .v }