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Home My WebLink About99-07689 h I `t ANiJ(? 131AN?D Plat IT X c=F laaa N -aAXZO S, t-? Ertl l'lk VS. S?I.ta ?1? MI kg S, l?FE1J DA hn S-q Awc_,,' - Diz. NE(.ti PA OC43 In the Court of Common Pleas or Cumberland County, Pennsylvania No. 99- 7/-,E7: Civil.19_ w??T G SU!4HON S T O T11? P??C?T1 E 0110 i?iF?Y ' 1?tEPcSt ISSV?z N WRIT QV- SU1-tk?ti15_ UPOQ Mz Act' oJ-- Cl?lr?ONEU DF1t1:J?iJiS Ptz?-rA:Zu \( IF;,.?,1?C1 SvSil?lUtt? _17J?'U To Prothonotary ?Gktl13k1Z ??' 19 Attorney for Plaintiff 11 i i i i Oil I r i No. Term, 19 vs. PRAECIPE pqO' SO _ s. vv - S??-- ?s- so - i?L 1-3c-Q? CtL ? 7?f ? I i . 19 Atty. 1 1 Commonwealth of Pennsylvania County of Cumberland Anna Bianco Y3. Jonathan Mays 50 Sycamore Drive Mechanicsburg, PA 17055 To __Jonathan_Mays________-_- You are hereby notified that Anna Bianco •-------------------------------- Court of Common Pleas 99-7689-Civil- Term Civil Action--- Law the Plaintiff ha scommenced an action in _____ Civil- Action--- Law - ---------------------- against you which you are required to defend or a default judgment may be entered against you. (SEAL) Lona •--------Curtis R,- ---- ---------------------- Prothonotary Date . December 28--------------- 19_ 99 "LY------? ----- - Deputy z 8 b ai m C 0 0 .i >a N C m U3 c h L a O N O u"i . ?a 8 E tT ro al 2 N C N ?4G N r-I s 4 i it' ABBA BIANCO, PLAINTIFF V. JONATHAN MAYS, DEFENDANT TO THE PROTHONOTARY: 4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7689 CIVIL ACTION - AT LAW : JURY TRIAL DEMANDED PRAECIPE Please enter the undersigned's appearance on behalf of the Defendant, Jonathan Mays, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER Date: 01/21/00 By: Matthew R. Gover, Esquire Attorney I.D. #47593 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 fI CERTIFICATE OF SERVICE AND NOW, this 215' day of January, 2000, 1 hereby certify that I have served the foregoing Praecipe on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Scott B. Cooper, Esquire SCHMIDT, RONCA & KRAMER, PC 209 State Street Harrisburg, PA 17101 attew R. Gover Esquire ABBA BIANCO, PLAINTIFF V. JONATHAN MAYS, DEFENDANT TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7689 CIVIL ACTION - AT LAW : JURY TRIAL DEMANDED PRAECIPE Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer a judgment of non pros. Respectfully submitted, NEALON & GOVER Date: 01/21/00 TO THE PLAINTIFF: By: ?Uv jc1 Matthew R. Gover, Esquire Attorney I.D. #47593 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 RULE A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros. DATED: Qill. S ;err, i5/ Cl6% ; ? kEiil U Prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 1999-07689 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BIANCO ANNA VS MAYS JONATHAN KATHY CLARKE Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon MAYS JONATHAN the DEFENDANT at 0008:56 HOURS, on the 3rd day of January , 2000 at 50 SYCAMORE DRIVE MECHANICSBURG, PA 17055 by handing to JONATHAN MAYS 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 18.00 Service 4.96 Affidavit .00 Surcharge 8.00 .00 30.96 Sworn and Subscribed to before me this -4laJ- day of A 1 Prothonotary So Ansviers: 01 R. Thomas Kline 01/04/2000 ANNA BIANCO^p By: De ty Sheriff ANNA BIANCO, Plaintiff V. JONATHAN MAYS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA 7189 NO. 99 974A CIVIL ACTION - LAW JURY TRIAL DEMANDED N O T I C E 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 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 299-3166 ANNA BIANCO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA 7la8`l NO. 99-4q*4- vi. CIVIL ACTION - LAW JONATHAN MAYS, Defendant JURY TRIAL DEMANDED N O T I C I A Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 299-3166 ANNA BIANCO, Plaintiff V. JONATHAN MAYS, Defendant IN THE COURT OF COMMON PLEAS CU14BERLAND COUNTY, PENNSYLVANIA TO 157<i NO. 99-4-?4 A- CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, Anna Bianco, by and through her attorneys, Schmidt, Ronca & Kramer, P.C., and respectfully sets forth as follows: 1. Plaintiff, Anna Bianco, is an adult individual currently residing at 1223 North Third Street, Harrisburg, Dauphin County, Pennsylvania 17102. 2. Defendant, Jonathan Mays, is an adult individual currently residing at 50 Sycamore Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The facts and occurrences hereinafter described took place on or about December 28, 1997, around dusk on the Pennsylvania Turnpike at approximately mile post 147.3 going east. 4. At the aforementioned time and place, the Plaintiff was the owner and operator of a 1989 Volvo and traveling east on the Pennsylvania Turnpike in the left lane. 5. At the aforementioned time and place, it is believed and therefore averred that the Defendant was the owner and 1 operator of 1995 Nissan traveling east in the left lane of the Pennsylvania Turnpike. 6. At the aforementioned time and place, the Plaintiff stopped for traffic that was backed up on the Pennsylvania Turnpike and she was suddenly and without warning struck in the rear by the car being operated by the Defendant. 7. The collision between the two vehicles caused the injuries to the Plaintiff set forth below. 8. The injuries set forth below were caused solely by the negligence of the Defendant and were in no way caused by or contributed to by the Plaintiff. COUNT I ANNA BIANCO V. JONATHAN MAYS NEGLIGENCE 9. Paragraphs 1 through 8 of the Plaintiff's Complaint are incorporated and herein by referenced and made a part thereof as if set forth in full. 10. The negligence and carelessness of the Defendant consisted of: A. Inattentiveness; B. Driving too fast for conditions; C. Operating his vehicle at an excessive rate of speed under the circumstances; D. Failing to have his vehicle under proper and adequate control; E. Failing to apply his brakes in time to avoid the collision with the Bianco vehicle; F. Negligently applying the brakes; G. Failing to observe the Bianco vehicle lawfully on the highway; H. Failing to operate his vehicle in accordance with existing traffic conditions and traffic controls; I. Operating his vehicle such as to create a dangerous situation for other vehicles lawfully on the roadway; 2 J. Operating a motor vehicle in violation of the Pennsylvania Motor Vehicle Code § 3714 for careless driving, which is negligence per se; and K. Operating his motor vehicle in violation of the Assured Clear Distance Ahead Rule. 11. As a direct and proximate result of the accident, the Plaintiff suffered severe, and what are believed to be permanent, injuries which include the following: A. Bruising of the chest; B. Pain in the left side of her body, including the left hip and left arm; C. Neck pain; D. Neck pain which radiates into the left shoulder down the left arm and into the left hip and left thigh; E. Trigger point in the right lumbosacral muscle; 12. As a direct and proximate result of the accident, the Plaintiff, Anna Bianco, has incurred medical expenses to-date and may continue to incur medical expenses into the future, and, thus, a claim for these expenses is made. 13. As a direct and proximate result of the injuries sustained in the accident, the Plaintiff, Anna Bianco, has sustained a wage loss and may continue to incur additional wage loss into the future and, thus, a claim for these losses is made. 14. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff, Anna Bianco, has been advised and, therefore, avers that the aforementioned injuries may be permanent in nature and effect and, thus, a claim for these injuries is made. 15. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff, Anna 3 Bianco, has undergone in the past and, will continue to undergo in the future, great pain and suffering and, thus, a claim for these losses is made. 16. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff, Anna Bianco, has been obliged to spend various sums of money and to incur various expenses for the injuries that she has suffered, and may continue to incur the same in the future and, thus, a claim for these losses is made. 17. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff, Anna Bianco, suffered a permanent diminution of her ability to enjoy life and life's pleasures and, thus, a claim for these losses is made. 18. As a direct and proximate result of the injuries sustained in the motor vehicle accident, the Plaintiff, Anna Bianco, suffered a loss of earnings and an impairment of her earning power and capacity and, thus, a claim for these losses is made. WHEREFORE, the Plaintiff, Anna Bianco, demands judgment on the Defendant, Jonathan Mays, in an amount in excess of Thirty- Five Thousand Dollars ($35,000.00) and in excess of an amount requiring compulsory arbitration. 4 Respectfully submitted, DATE: .L SCHMIDT, RONCA & KRAMER, P.C. By: Scott B. Cooper Attorney I.D. #70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff H ?: I, ANNA BIANCO, verify that I am the Plaintiff in the foregoing action and that the attached COMPLAINT is based upon the information which has been gathered by my counsel in preparation of this lawsuit. The language of the COMPLAINT is that of counsel and is not mine. I have read the COMPLAINT, and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the contents of the COMPLAINT are that of counsel, I have relied upon counsel in making this Verification. I understand that intentional false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsifications made to authorities. DATT? ANN1)( BIANCO 6 II ANNA BIANCO, Plaintiff PENNSYLVANIA V. JONATHAN MAYS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, NO. 99-44 4- CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this v/ day of February, 2000, I, Scott B. Cooper, Esquire, attorney for the Plaintiff, hereby certify that I have, this day, served the COMPLAINT, by depositing a copy of the same in the United States Mail, via Certified Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Matthew R. Gover, Esq. Nealon & Gover 301 Market Street 9th Floor Harrisburg, PA 17108 SCHMIDT, RONCA & KRAMER, P.C. By ??. Scott B. Cooper I.D. #70242 Attorneys for Plaintiffs 209 State Street Harrisburg, PA 17101 (717) 232-6300 ANNA BIANCO, : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-7689 : CIVIL ACTION - AT LAW JONATHAN MAYS, DEFENDANT JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Anna Bianco, and her attorney, Scott B. Cooper, Esquire SCHMIDT, RONCA & KRAMER, PC 209 State Street Harrisburg, PA 17101 YOU ARE HEREBY NOTIFIED, that the Answer to Complaint set forth herein contains averments against you to which you are required to respond within twenty (20) days after service thereof. Failure by you to do so may constitute an admission. Respectfully submitted, NEALON & GOVER By Date: -z/z-2-A 0 Matthew R. Gover, Esquire Attorney I.D. #47593 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 >- ,?, ;, ' . .. ,:? f.>i _. ANNA BIANCO, PLAINTIFF V. JONATHAN MAYS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7689 CIVIL ACTION -AT LAW JURY TRIAL DEMANDED ANSWER OF DEFENDANT TO PLAINTIFF'S COMPLAINT AND NOW, comes the Defendant, Jonathan Mays, by and through his attorneys, NEALON & GOVER, P.C., and files the following Answer: 1.-5. Admitted. 6.-8. Denied pursuant to Pa.R.Civ.P. 1029(e). COUNT I ANNA BIANCO V. JONATHAN MAYS 9. Paragraphs 1 through 8 of Defendant's Answer are incorporated herein by reference thereto. 10. Denied pursuant to Pa.R.Civ.P. 1029(e). 11.-18. Denied. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted and proof is demanded at trial. WHEREFORE, Jonathan Mays, respectfully request that the Complaint be dismissed with costs of this action. NEW MATTER 19, Paragraphs 1 through 18 of Defendant's Answer are incorporated herein by reference thereto. 20. Plaintiffs claims may be barred in whole or in part by application of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, Defendant, Jonathan Mays, respectfully requests that the Complaint be dismissed with costs of this action. Date: L Z?/C U Respectfully submitted, NEALON & GOVER By: Matt ew R. Gover, Esquire Attorney I.D. #47593 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 VERIFICATION I, JONATHAN MAYS, verify that the statements made in the foregoing Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. n JO ATHAN MAY CERTIFICATE OF SERVICE AND NOW, this !T? day of '7Uct- 000, served the foregoing Answer on the following by depositing a true in the United States mails, postage prepaid, addressed to: Scott B. Cooper, Esquire SCHMIDT, RONCA & KRAMER, PC 209 State Street Harrisburg, PA 17101 hereby certify that I have and correct copy of same Matth w R. Gover Esquire { 1'N.V ANNA BIANCO, Plaintiff V. JONATHAN MAYS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA NO. 99-7689 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 94 day of February, 2000, I, Scott B. Cooper, Esquire, attorney for the Plaintiff, hereby certify that I have, this day, served the REQUEST FOR PRODUCTION OF DOCUMENTS OF PLAINTIFF TO DEFENDANT (Set I), by depositing a copy of the same in the United States Mail, via Certified Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Matthew R. Gover, Esq. Nealon & Gover 301 Market Street 9th Floor Harrisburg, PA 17108 SCHMIDT, RONCA & KRAMER, P.C. By Scott B. Cooper I.D. #70292 Attorneys for Plaintiffs 209 State Street Harrisburg, PA 17101 (717) 232-6300 _ _ ??":? .-> ., ??. ? _; -- _; i ANNA BIANCO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7689 V. CIVIL ACTION - LAW JONATHAN MAYS, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this day of February, 2000, 1, Scott B. Cooper, Esquire, attorney for the Plaintiff, hereby certify that I have, this day, served the PLAINTIFF'S INTERROGATORIES ADDRESSED TO DEFENDANT (Set I), by depositing a copy of the same in the United States Mail, via Certified Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Matthew R. Gover, Esq. Nealon & Gover 301 Market Street 9th Floor Harrisburg, PA 17108 SCHMIDT, RONCA & KRAMER, P.C. BY Scott B. Cooper I.D. #70242 Attorneys for Plaintiffs 209 State Street Harrisburg, PA 17101 (717) 232-6300 I ANNA BIANCO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7689 V. CIVIL ACTION - LAW JONATHAN MAYS, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 00 day of February, 2000, I, Scott B. Cooper, Esquire, attorney for the Plaintiff, hereby certify that I have, this day, served the PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER, by depositing a copy of the same in the United States Mail, via Certified Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Matthew R. Gover, Esq. Nealon & Gover 301 Market Street Stn Floor Harrisburg, PA 17108 SCHMIDT, RONCA & KRAMER, P.C. By Scott B. Cooper I.D. #70242 Attorneys for Plaintiffs 209 State Street Harrisburg, PA 17101 (717) 232-6300 "::::? ._, ANNA BIANCO, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7689 V. CIVIL ACTION - LAW JONATHAN MAYS, Defendant JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER 19. Paragraph 19 is not directed towards answering Plaintiff and, therefore, no responsive pleading is required. 20. Paragraph 20 of Defendant's New Matter is a conclusion to law to which no responsive pleading is required. By way of further answer, if a responsive pleading is deemed required, the averment in Paragraph 20 is specifically denied and the Plaintiff demands strict proof from the Defendant prior to the time of trial as to what portions of the Pennsylvania Motor Vehicle Financial Responsibility Act may apply in this case. WHEREFORE, the Plaintiff, Anna Bianco, respectfully requests that this Honorable Court enter judgment in her favor as requested in her Complaint. Respectfully submitted, DATE: 2 0SCHMIDT, RONCA & KRAMER, P.C. By: .?? Scott B. Cooper Attorney I.D. #70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff VERIFICATION I, Scott B. Cooper, verify that I am attorney of record for the Plaintiff, and that the foregoing document contains no facts within the knowledge of the Plaintiff, but rather, is based upon the record or facts solely within the knowledge of the attorney; and, for that reason, I make this Verification on Plaintiff's behalf. I verify that the facts contained in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that intentional false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsifications to authorities. Respectfully submitted, SCHMIDT, RONCA S KRAMER, P.C. By: DATE: OD Scott B. Cooper Attorney I.D. #70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff ? .l r:_:_.:- ANNA BIANCO, Plaintiff V. JONATHAN MAYS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7689 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE ??7 AND NOW, this 16 day of May, 2000, I, Scott B. Cooper, Esquire, attorney for the Plaintiff, hereby certify that I have, this day, served the Notice of Deposition of Jonathan Mays, by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Matthew R. Gover, Esq. Nealon & Gover 301 Market Street 9th Floor Harrisburg, PA 17108 SCHMIDT, RONCA & KRAMER, P.C. By Scott B. Cooper I.D. 070292 Attorneys for Plaintiffs 209 State Street Harrisburg, PA 17101 (717) 232-6300 ? o? L ? [:- ?;c? c: c ,? =- ? - 1?S` i ; _ ? `'? w.? L . _ -. ' Z, ?' ` r) ?J ANNA BIANCO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7689 V. CIVIL ACTION - LAW JONATHAN MAYS, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE rl AND NOW, this day of June, 2000, I, Scott B. Cooper, Esquire, attorney for the Plaintiff, hereby certify that I have, this day, served the PLAINTIFF'S RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO PLAINTIFF-FIRST REQUEST, by depositing a copy of the same in the United States Mail, via Certified Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Matthew R. Gover, Esq. Nealon & Gover 301 Market Street Stn Floor Harrisburg, PA 17101 SCHMIDT, RONCA & KRAMER, P.C. By /l___' Scott B. Cooper I.D. #70242 Attorneys for Plaintiff 209 State Street Harrisburg, PA 17101 (717) 232-6300 " 'tz; Ir. ; ? -- ` (jti: ? C r 11 M1:.. '? O G U L , ANNA BIANCO, Plaintiff V. JONATHAN MAYS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0. 99-7689 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this day of June, 2000, I, Scott B. Cooper, Esquire, attorney for the Plaintiff, hereby certify that I have, this day, served the PLAINTIFF'S SUPPLEMENTAL RESPONSE TO REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO PLAINTIFF-FIRST REQUEST, by depositing a copy of the same in the United States Mail, via Certified Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Matthew R. Gover, Esq. Nealon & Gover 301 Market Street Stn Floor Harrisburg, PA 17101 SCHMIDT, RONCA & KRAMER, P.C. By S Ott B. Cooper I.D. #70242 Attorneys for Plaintiff 209 State Street Harrisburg, PA 17101 (717) 232-6300 ' - r- >- ? u; ?? :_] - - :?•t? ???_: " a " :?i .=?, to •? : - _? -- =. =O- o ' ? . ? i FMNA BIANCO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7689 V. CIVIL ACTION - LAW JONATHAN MAYS, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this l?? day of June, 2000, I, Scott B. Cooper, Esquire, attorney for the Plaintiff, hereby certify that I have, this day, served the PLAINTIFF'S SECOND SUPPLEMENTAL RESPONSE TO REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO PLAINTIFF-FIRST REQUEST, by depositing a copy of the same in the United States Mail, via Certified Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Matthew R. Gover, Esq. Nealon & Gover 301 Market Street 9th Floor Harrisburg, PA 17101 SCHMIDT, RONCA & KRAMER, P.C. By Scott B. Cooper Z.D. #70242 Attorneys for Plaintiff 209 State Street Harrisburg, P.A. 17101 (717) 232-6300 ?" .y S) _ •_ ?- F- _i r - ter. :Y . ? L.. J r .L .n - n _'? "D r o ? -. O :J ANNA BIANCO, Plaintiff V. JONATHAN MAYS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7689 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE J /g bio AND NOW, this / U day of July, 2000, I, Scott B. Cooper, Esquire, attorney for the Plaintiff, hereby certify that I have, this day, served the Revised Notice of Deposition of Jonathan Mays, by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Matthew R. Gover, Esq. Nealon & Gover 301 Market Street 9th Floor Harrisburg, PA 17108 SCHMIDT, RONCA & KRAMER, P.C. By-L- Scott B. Cooper I.D. #70242 Attorneys for Plaintiffs 209 State Street Harrisburg, PA 17101 (717) 232-6300 ?- C :, ? _ L: -- 7 , .1 _'' .. .1 ..: J ? ? !.7 - 1. l' itU y J ? v ...• ?r.... ,? ,...... ANNA BIANCO, Plaintiff V. JONATHAN MAYS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7689 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE ACTION By: TO THE PROTHONOTARY: Please discontinue the above-captioned action on behalf of the Plaintiff. Thank you. Respectfully submitted, SCHMIDT, RONCA and RRAMER, P.C. Scott B. Cooper Attorney I.D. #70292 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for the Plaintiff Dated: ???Q? 14 . w ANNA BIANCO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7689 V. CIVIL ACTION - LAW JONATHAN MAYS, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 11th day of August, 2000, I, Shawn T. Peterson, hereby certify that I have this day served a true and correct copy of PRAECIPE TO DISCONTINUE ACTION, by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Matthew R. Gover, Esq Nealon & Gover 301 Market Street 9th Floor Harrisburg, Pa 17101 Cheryl Donahue Allstate Insurance Company Market Claims office 6345 Flank Drive Suite 1000 Harrisburg, PA 17112-9916 SCHMIDT, RONCA & KRAMER, P.C. By: ky Shawn T. Peterson, Paralegal 209 State Street Harrisburg, PA 17101 (717) 232-6300 ti ? ?, F : _ , ??.,? ?, `?` ?'' (` _' i]J i? "[q _ ]L J.. ice- C^ 1'?G ?_ : ,aC . L .t 1:. 1 ? ? t, r