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Home My WebLink About03-3516 II ALBERT H. "BUCK" SHULLER, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :NO. Dd ~J,S;II.:. CIVIL TERM VICKI PIONTEK, Defendant PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Writ of Summons on the above named Defendant at the following address: Vicki Piontek 116 West Green P.O. Box 173 Mechanicsburg, PA 17055 Respectfully Submitted TUR LAW OFFICES 7~3 Date R n Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff ~ ~ .~ vt - ~ D ~~~ ~ ~ "-L. (, .. '.' .- (~ ALBERT H. "BUCK" SHULLER, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA vi. :NO.D3 -3~/fo. CIVIL TERM VICKI PIONTEK, Defendant WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. p{l~~~);> .~ ~ L),/ .i~, ,:)661 Date / '--- Lh..(h()~ 2~ 011~.F' Deputy / 'l CASE NO: 2003-03516 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SHULLER ALBERT H "BUCK" VS PIONTEK VICKI BRIAN BARRICK , Sheriff or Deputy Sheriff of says, the within WRIT OF SUMMONS Cumberland County,pennsylvania, who being duly sworn according to law, PIONTEK VICKI DEFENDANT was served upon the at 116 WEST GREEN , at 1614:00 HOURS, on the 30th day of July , 2003 MECHANICSBURG, PA 17055 CORY PIONTEK, HUSBAND by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.90 .00 10.00 .00 34.90 Sworn and Subscribed to before me this (, ~ day of ()~~ A.D. U. ~ P othonotary ~ So Answers: r~~~.c~~ R. Thomas Kline 07/31/2003 TURO LAW OPFFI1l.S 0.. /AI!. By: r!7~V'/fl\ Deputy Sheriff In the Court of Common Pleas of Cumberland County, Pennsylvania ALBERT H. "BUCK" SHULLER, CIVIL ACTION - LAW Plaintiff / Respondent : vs. 03-3516 VICKI PIONTEK., Defendant / Movant Motion to Stay Deposition Proceedings, and for Protective Order AND NOW, comes the Defendant, Vicki Piontek, pro se, and raises the fol1owiDg Motion to Stay Deposition Proceedings and for Protective Order 1. On or about July 23'd, 2003, Plaintiff, Albert H. "Buck ShuIIer," through his COUIllId Ron Tum, filed. writ of summons against Defendant, Vicki Piontek. 2. To -. Plaintiff has not filed a complaint stating the cause of action. 3. Plaiatift"bu scheduled a deposition on April 19,2004. J. Plaintiffs Non-Compliance with Pennsylvania Rule of Civil Procedure 1042.1. 4. Although no formal complaint was filed, Defendant avers and believes that the cause of action relates to Defendant's alleged professional misconduct as an attorney. This assumption is based on correspondence received by Defendant from Plaintiffs attorney. 5. It is believed and averred that the basis of Plaintiffs complaint is that Defendant, Attorney Vicki Piontek, deviated from the acceptable standards of practice for an attorney. Thus the claim is one of professional liability governed by Pennsylvania Rule of Civil Procedure 1042. I, et. seq. 6. Civil actions based on allegations of professional misconduct committed by attorneys are governed by Pennsylvania Rule of Civil Procedure 1042.1, et. seq. See PA RCP I042.l (b) (2). 7. According to Pennsylvania Rule of Civil Procedure 1042.5, discovery, except for the production of documents and things or the entry upon property for inspection and other purposes, a plaintiff who has asserted a professional liability claim may not, without leave of court, seek any discovery with respect to that claim prior to the filing of a certificate of merit. 8. To date, Plaintiff has not filed a certificate of merit. 9. It is the Defendant's position that pursuant to P A RCP 1042.5, Plaintiff should not be allowed to proeeed with the deposition until a certificate of merit has been filed, since the instant action is most probably one relating to alleged professional misconduct by Defendant, Attorney Vicki Piontek. II. Attorney Client Privilege and Attorney Client Confidentiality 10. It is believed and averred that the subject matter of the deposition scheduled for April 19, 2004 will contain sensitive information concerning the attorney client relationship between Defendant Attorney Vicki Piontek, and her client, Paul Brougher. This would include the attorney client privilege as well as attorney client confidentiality. 11. Without a waiver from her client, Paul Brougher, Attorney Vicki Piontek will not be able to testify to any matters which are covered by the attorney client privilege. Wherefore, Defendant requests a stay of any discovery action, until Plaintiff complies with Pennsylvania Rules of Civil Procedure 1042. I, et., seq., and until this Court rules on issues COIlCCI'nina the attorney client privilege and attorney client confidentiality. \j'~?i~ 4 -'-0'1 Date Vicki Piontek, Esquire P.O. Box 173 Mechanicsburg, PAl 7055 717-571-4394 In the Court of Common Pleas of Cumberland County, Pennsylvania ALBERT H. "BUCK" SHULLER, CIVIL ACTION - LAW Plaintiff / Respondent: VS. 03-35 I 6 VICKI PIONTEK, Defendant / Movant Certificate of Service Vicki Piontek affirms that she is at least 18 years of age, and that on the 9th day of April she sent a true and correct copy of the attached Motion to Stay Deposition Proceedings and for Protective Order upon Plaintiff's Counsel at the following address: Turo Law Offices Attention: Ron Turo, Esquire 28 South Pitt Street Carlisle, P A 170 I3 The same was also sent by fax to: 717-245-2165, and by email to ronturo@turolaw.com. ~'...L~~~~~ Vicki Piontek, Esquire P.O. Box 173 Mechanicsburg, PAl 7055 717-571-4394 '-t - /If-CT'-I Date (') ~; (~ - .'-. -2 '" <---:~:l = ~ ~h 'u ;;v o ,', :.:;.1 6,':" -n F;; i(1CJ ._:~ (1., -'''':f .:-5-'-; ,.C") i.'c;;rn 5;' ~~ N ,"'1 --" -":- w w ALBERT H. "BUCK" SHULLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW VICKI PIONTEK, Defendant NO. 03-3516 CIVIL TERM ORDER OF COURT AND NOW, this 27th day of April, 2004, upon consideration of Defendant's Motion To Stay Deposition Proceedings, and for Protective Order, and upon relation of counsel for Plaintiff, Ron Turo, Esq., that the deposition which was the subject of the motion was conducted on April 19, 2004, the motion is del~med moot. BY THE COURT, h.on Turo, Esq. 28 South Pitt Street Carlisle, PA 17013 Attorney for Plaintiff ;Vicki Piontek, Esq. P.O. Box 173 Mechanicsburg, PAl 7055 Defendant, pro se J ) :rc ViNV^lJ.8NN:Jd "N'"'~') r', "'lu=":'^'n'" I\.L ,1U,., '.)' '-, ',' ,-'~,~tjn v SZ :z I~d BZ ~dV ~OgZ AW10NOHlOOd 3111 :10 30H:!O-CJ3ll:l 1/ Albert H. "Buck" Shuller, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-3516 CIVIL TERM Vicki Piontek, Defendant NOTICE TO DEFEND AND I~LAIM RIGHTS 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 /I Albert H. "Buck" Shuller Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-3516 CIVIL TERM Vicki Piontek, Defendant COMPLAIN"[ 1. Plaintiff is Albert H. "Buck" Shuller, an adult individual, currently residing at 120 Leeds Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Vicki Piontek, a licensed current business address of 116 W. Green Street, 17055. Pennsylvania attorney with a Mechanicsburg, Pennsylvania 3. Plaintiff Shuller owns and operates Shuller Security Motivation Group. 4. On or about April 26, 2001, Paul Brougher, an adult individual now deceased, drew on his account at Orrstown Bank by writing checks. 5. The drafts were paid by the bank, but Orrstown Bank assessed certain fees because Mr. Brougher's account did not contain adequate available funds to pay the checks from his own money. behalf. 6. Mr. Brougher never repaid Orrstown Bank for the drafts it paid on his 7. On January 30, 2002, at the request of his customer, Orrstown Bank, Mr. Shuller's company, Shuller Security Motivation Group, sent Mr. Brougher a letter requesting repayment of the amount resulting from Mr. Brougher's overdrafts. /I II 8. On February 19, 2002, after no reply to the previous letter, Mr. Shuller's company sent Mr. Brougher a letter similar to the one sent in January 2002. 9. After notice that Mr. Brougher had filed a Chapter 7 Bankruptcy case in the U.S. Bankruptcy Court for the Middle District of Pennsylvania, Mr. Shuller's company halted all contact with Mr. Brougher. 10. Mr. Brougher's bankruptcy filing was made Pro Se, with help from Maura Jenkins of Camp Hill, Pennsylvania. 11. On May 28, 2002, Vicki Piontek, Esq., filed suit in Bankruptcy Court in the name of Paul Brougher against Mr. Shuller and Shuller Security Motivation Group ("Shuller"), alleging two violations of the Federal Fair Debt Collection Practices Act ("FDCPA"). 12. The suit was filed on behalf of Mr. Brougher, but he had not authorized it, nor did any relationship exist between Ms. Piontek and Mr. Brougher. 13. On that same date, May 28, 2002, Ms. Piontek sent a letter to Mr. Brougher explaining the basis of the suit and summarizing her fee proposal with a copy of the lawsuit against Shuller, which had already been filed, and a Contingency Fee Agreement form signed by Ms. Piontek and dated May 28, 2002. 14. Mr. Brougher signed the Contingency Fee Agreement form and dated his signature June 6, 2002. 15. Another Contingency Fee Agreement form was signed by Mr. Brougher and his wife, Norma, with both signatures dated ,June 2, 2002 and signed by Ms. Piontek with a date of June 6, 2002. II 16. On receipt of the complaint, Shulller, compelled by court procedure and relying on the validity of Piontek's suit, as intended by Ms. Piontek, prepared and filed an answer. 17. On February 7, 2003, Shuller moved for Judgment on the Pleadings. 18. On March 6, 2003, Piontek withdrew the suit against Shuller. 19. On March 17,2003, the Bankruptcy Court entered jUdgment for Shuller. 20. At that point, Shuller had expended $2228.55 in legal fees to mount a defense to this frivolous suit. COUNT I WRONGFUL USE OF PROCESS 21. Paragraphs 1 through 20 are incorporated as if fully stated herein. 22. 42 Pa. C.S.A. 98351, et seq., defines liability for the Wrongful Use of Process: (1) He acts in a grossly negligent manner or without probable cause and primarily for a purpose other than that of securing the proper discovery, joinder of parties or adjudication of the claim in which the proceedings are based; and (2) The proceedings have terminated in favor of the person against whom they are brought. II 23. Defendant, by her actions, violatEid Pennsylvania statute 42 Pa. C.S.A. ~8351, in that she acted in a grossly negligent manner and without probable cause and primarily for a purpose other than that of securing the proper discovery, joinder of parties or adjudication of the claim in which the proceedings were based. 24. The proceedings were terminated in favor of Shuller. Wherefore, Plaintiff Albert H. "Buck" Shuller demands jUdgment against Defendant, Vicki Piontek, for harm to reputation damages in an amount of at least $25,000; expense damages of $2228.55; emotional distress damages of at least $25,000; and punitive damages of at least $25,000; all in excess of the arbitration limit and thus a jury trial is demanded. COUNT" FRAUD 25. Paragraphs 1 through 24 are incorporated as if fully stated herein. 26. Defendant misrepresented herself ciS the legal representative of Paul Brougher, uttered that misrepresentation to Plaintiff Shuller, intended Plaintiff Shuller to act on her misrepresentation, Plaintiff Shuller justifiably relied on Defendant's misrepresentation, and Plaintiff Shuller suffered damage as a direct result of Defendant's misrepresentation. II Wherefore, Plaintiff Albert H. "Buck" Shuller demands judgment against Defendant, Vicki Piontek, for damages in an amount in excess of $25,000. yAr joy Date Respectfully Submitted TURD AW OFFICES 1/ VERIFICAnQN I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. ~4904 relating to unsworn falsification to authoritil3s. og J?( /0-'/ Date ( /~0iU ~"BUCk" ShuIJer /I CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the foregoing document upon Vicki Piontek, Esquire, by depositing same in the United States Mail, first class, postage pre-paid on the 5"/ day of August, 2004, from Carlisle, Pennsylvania, addressed as follows: Vicki Piontek, Esquilre 116 West Green StrElet Mechanicsburg, PA 1 ?055 T~ Ron Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff n r" ,. "r;' ~:::~ ::1)" .2.' I () ~;: J-- . q; {~~ :z: ~.p, -< '" = = .c" 0> M -0 I ~ :i! nl:I! ~~r- D '"~t -iJ".,. ?5-,j :>0 '"'jm ~;! ~ :i...... ::z:: cD w "',. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYV ANIA Albert H. Shuiler, Plaintiff v. No. 03-3516 Vicki Piontek, CIVIL ACTION - LAW Defendant ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the Defendant in the above-captioned matter. c: /4' Cory D. Piontek J.D. 83299 PIONTEK LAW OFFICE 24 W. GovemorRd. Hershey,PA 17033 7/7_.5 33' 1'/71.:.... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYV ANIA Albert H. ShuIler, Plaintiff v. No. 03-3516 Vicki Piontek, CIVIL ACTION - LAW Defendant CERTIFICATE OF SERVICE I certify that I served a true and correct copy of the foregoing document upon Defendant by his attorney, Ron Turo, Esquire, by first-class U.S. mail, postage pre-paid upon the date indicated below, addressed as follows: Ron Turo, Esq. 28 S. Pitt St. Carlise, PAl 7013 '1- UJ. dIf Date of Service c05a~q. 24 W. Governor Rd. lIershey,PA. 17033 (717) 533-7472 ~ , CJ r--' 0 C.:.'l C::. =' -\1 ~'" (/) .-1 t", :!: " ,,~'U fl"l f'" l'l -[) 12: ~n \....1 0 (':;, , C) ~:-;> , -'I' (';) (5 ) rn l::'::' -- Z ~...' t....) " ," -, ...;.;J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYV ANIA Albert H. Shuller, Plaintiff v. No. 03-3516 Vicki Piontek, CIVIL ACTION - LAW Defendant ANSWER 1. Admitted. 2. Admitted. 3. After reasonable investigation, Defendant is without sufficient knowledge to admit or deny. 4. After reasonable investigation, Defendant is without sufficient knowledge to admit or deny. 5. After reasonable investigation, Defendant is without sufficient knowledge to admit or deny. 6. After reasonable investigation, Defendant is without sufficient knowledge to admit or deny. 7. Admitted. 8. Admitted. 9. After reasonable investigation, Defendant is without sufficient knowledge to admit or deny. 10. Admitted. 11. Admitted. 12. Denied. It is specifically denied that there was no attorney-client relationship between Decedent Brougher and Defendant Piontek and/or that the filing of said suit was not authorized by Decedent Brougher. While Defendant cannot recall the specifics surrounding her conversations with Decedent Brougher, she is not in the practice of filing lawsuits without first consulting with a client and believes it would be morally and ethically wrong to do so, and her n:view of the Brougher file leads her to conclude that it is highly likely that there was a telephone consultation with the client describing the substance of a letter being sent to him along with instructions regarding the completion of a fee agreement also being sent. 13. Admitted in part and denied in part, it is admitted that May 28, 2002 is the file date for the suit being referenced, it is denied that the suit was actually instituted prior to the fee agreement/cover letter being mailed. 14. Admitted. 15. Admitted. 16. Admitted. 17. Admitted. 18. Admitted. 19. Admitted. 20. After reasonable investigation, Defendant is without sufficient knowledge to admit or deny. COUNT I WRONGFUL USE OF PROCESS 21. No response required. 22. No response required. 23. To the extent the averment alleges fact, said averment is denied. Defendant's action were not violative of 42 Pa C.S.A. ~835I. To the e~:tent the averment is a conclusion oflaw, no response is required. 24. Admitted. Wherefore, Defendant prays for judgment in her favor and relief with prejudice from the PlaintifPs claims against her. COUNTH FRAUD 25. No response required. 26. Denied. Defendant's representation as attorney for Decedent Brougher was with the agreement and consent of Decedent Brougher and actions filed on his behalf were authorized by the client. Wherefore, Defendant prays for judgment in her favor and relief with prejudice from the PlaintifP s claims against her. Respectfully Submitted, PIONTEK LAW OFFICE c;w Cory D. Piontek, Esq. 24 W. GovemorRd. Hershey, PA 17033 (717) 533-7472 RULE I024 Verification I verify that the statements made in the foregoing Pleading are true and Correct to the best of my knowledge, understanding and belief and acknowledge that false statements made herein may be subject to the penalties of 18 Pa.C.S. ~4904. 9-2.0-2.00.., Date Vi.k.P~:Jc- Vicki A. Piontek IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYV ANIA Albert H. Shuller, Plaintiff v. No. 03-3516 Vicki Piontek, Defendant CIVIL ACTION - LAW CERTIFICATE OF SERVICE I certify that I served a true and correct copy of the foregoing document upon Defendant by his attorney, Ron Turo, Esquire, by fIrSt-class U.S. mail, postage pre-paid upon the date indicated below, addressed as follows: Ron Turo, Esq. 28 S. Pitt St. CarIise, PAl 7013 9-1..o~ CJtf Date of Service q4 Cory D. Piontek, Esq. 24 W. Governor Rd. Hershey, PA 17033 (717) 533-7472 :4; ~:.3 <:""), OJ . ,,-, C:.::::> C:.) ~- (,") (~ -'r; :..-/ ,.. r"i''j i~~ ~BE:Y '__.'_l I!. ) ,_.'r, (-).::; ! ;';'" i';.;:~ ~,' " r\) c, .~ ;. J ,I::: :~( Albert H. Shuller Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-35113 CIVIL 2004 Vicki Piontek Defendant PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE. THE JUDGES OF SAID COURT: Ron Turo, Esquire, counsel for the Plaintiff in the above action, respectfully represents that: 1, The above-captioned action is at issue. 2. The claim of the Plaintiff in the action is $25,000.00. The counterclaim of the Defendant in the action is $0.00. The following attorneys are interested in the case as counselor are otherwise disqualified to sit as arbitrators: Cory D. Piontek; Vicki Piontek WHEREFORE, YOUR Petitioner pra~~ Honorable Court to appoint three (3) arbitrators to whom the case shall be sUbmitti I . / ~l pectfu <" Ro Turo, Esquire ~ (') ...., = ~ c:: = ...... -rJ ~; "'" f ~ ~'-:> <- :i! tnr' c ~.> r- ~~ 1\ 21:' (.r)..-' I t156 <:-- -< U1 ...... N !;' " j; r_ = :::;1,.. 0\ l.> .. ztJ ::z i5~ $'0 '" ~ c: '::? 8m lU \f\ ~ ;~ ", is N ~1:J -.J .< ~ 1- J ~0 -\ t, cSJ! Albert H. Shuller Plaintiff RECEIVED JUL 0 B 10ffi{''J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3516 CIVIL 2004 " v. Vicki piontek Defendant AND NOW, this f]~ day of ' 2005, in consideration of the fo,.,~p""o~ ., ~'" ." '71t,ijI~~if;J E'q ,," ':;1 7tf(' iff".' ". ,ppo""'" ,"''''''''~" h. 'b~~"ptioo'" actio as pra ed for. , PJ. . ~. , ~1 ~ " , -f (;: ,I () "', \!~!\~\/ r~\)\S,\;I'\)?td ,\lNr'\C(1 ' r",':,:::',~w\\nJ S \ :0\ iW g- -$\r SUUl ^\:N10HOHl.o\:id 3Kl ::\0 3QL.J:\O-G311:J (\\\..-o~ \\. ~v\\-Q..< Plaintiff $ \C' '< \ ~\~\"H>~ Defendant In The Court of COl!l1l1on Pleas of Cumberland County, Pennsylvania No. 0 J -_ 35/ C, Oath We do solemnly SWear (or afiinn) that we will support, obey and defend the Constitution of the United ' States and the Constitution of this COl!l1l1onwealth and that we will discharge the duties of our 0 with fidelity. "'->\Ll..l'Aw\ f. ,..,....\~As Name (Chainnan) Law Finn 011 w. "'('~S\- . Address ~~l...\SU::: City, \/0 I ~ Zip Civil Action - Law. ~\111? IgIla e J(~l\it.- ~. \..j.~~~ Name Jc.VIA,O\>. ~_ ....'" ,... Law Finn 1 M.o.-k. {/, hul.f:e..... Name J;j,"'Jd'u 11+1.'1/: LawF' , -f!!'lulI}!1015-18023"o 3t1f Markt+SI.' Address tw, ~:!!:L~ Address ~i'C'( 1M......*'-- \ -=l 0 \ I . City, Zip j;:'fYl"7l-J~ PA Zi; 701f.3 Award We, the undersigned arbitrators, having been duly appointed BJ1d SWom (or afiinned), make the following aWard: (Note: If damag for delay are awarded, the shall be separately stated.) ""- \ ~. . . . ... ~;:).~';l...~. ~ . ~ Date ofHearing:-8_.Q.~ _ ~ 5 Date of AWard: a - a~ _ 0;:' . Arbitrator, dissenta. (Insert name if applicable.) - (ChairrnaJ:l ) ~,':'"~-' ~ ~,~ ~ --;,<ZO';........,.l'"'~.. Now, the 4- day of ~~, 20 OS"--, at.>>( ~ 37 ,../!....M., the above award was entered upon the docket and notice there given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ &9 D. Prothonotary tJ& By: Deputy I () r-..) C-,~ g~ 0 ;;J't -n ~-= :I! -n G) rnp G) ~B2 C;, . -.~, c~ -c,; ",-- ~'i", C J :=.: '~'-~_)' ~~ ~_ 1'.) ~r;; ::2 (..0..") '-1:) ....J '< ~ ~ tt ~ ,~~ ~ ~f ....... J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYV ANIA Albert H. ShuIIer, Plaintiff v. No. {B-1Sl6 Vicki Piontek, CIVIL ACTION - LAW I)i>:feruhnt NOTICE OF APPEAL FROM AWARD Of BOARDOf ARBlTRATORS TO THE PROTHONOTARY: Notice is given that VICKI PIONTEK appeals from the award of the board of arbitrators wta:rod in ~= on At1gust 26, 2005. A jury trial is demanded~. (Check box ifajury trial is demanded. Otherwise jury trial is waived.) I hereby certify that (I) the compensation of the arbitrators has been paid, or (2) aJllllieatieR has beeR made ter flemlissieR tEl prseeeB iR fel'ffia papeRs. A ITORNEY FOR APPELLANT {!/J Cory D. Piontek 24 W. (k)veroor Rd. Hershey, PA 17033 (717) 533-7472 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYV ANIA Albert H. Shuller, Plaintiff v_ No. iJ3-3516 Vicki Piontek, CIVIL ACTION - LAW I)Pfppd"nt CERTIFICATE OF SERVICE I rertHy that I served a true and COffect copy of the ~ NOTICE OF APPEAL upon Defendant by his attorney, Ron Turo, Esquire, by first-class U.S. mail, postage pre-paid upon the date indicated below, addressed as follows: Reft T_, Esq.. 28 S. Pitt St. CarIise, PAl 70 I3 cr- 21-0S ~IJ Cory D. Piontek, Esq. 24 W. Governor Rd. Hershey, PA 17m3 (717) 533-7472 Date of Service (') c - ~ ....1.. < r r'- .. (.1 - "" "" ... !...l '. -'> oJ;>. <> "> (" -<!. 6 ~ "- ~ ~ i. " .--- ....., = L? <.n (/) f'rl -0 N W -0 ::Jl.: r;~ ,e- N o -'1 -l :x:~ r'n-'-' -oFn :uO ,r., .L ~Q ~.:'. -H ;'(') afl) '" .p- :'J.J -< -