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Home My WebLink About07-2880IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. ? Alrb n c'C L Civil Action (X) Law () Equity LORENTZ KAFKA Red Rock Road East Chatham, NY 12060 EDWIN GEWIRZ and NATALIE GEWIRZ, husband and wife 13726 Mills Avenue Silver Spring, MD 20904 Defendant & Address Plaintiffs & Address PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Writ of Summons in the above-captioned action. X Writ of Summons shall be issued and forwarded to( ) Attorney (X) Sheriff. Todd D. Getgen, Esquire Schmidt Kramer PC ?yJ 209 State Street Harrisburg, PA 17101 (717) 232-6300 Signature of Atto ney Supreme Court I.D. No. 80719 Date: 0-/jI 1120,01 // WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANTS: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED AN ACTION AGAINST YOU. .2 k- " Prothonotary Date: fq_?x w( 1007 By: Deputy ) Check here if reverse is used for additional information. A ? ? L _ 7 +r 7'4 +.? cn .a CZ) -< C7 120296 DICKIE, MCCAMEY & CHILCOTE, P.C. BY: CHARLES E. HADDICK, JR., ESQUIRE ATTORNEY FOR: DEFENDANT ATTORNEY I.D. NO. 55666 LORENTZ KAFKA BY: J. DAVID ZIEGLER, ESQUIRE ATTORNEY I.D. NO. 92882 1200 Camp Hill Bypass, Suite 205 Camp Hill, PA 17011 (717)7314800 (Tele) (717)731-4803 ax EDWIN GEWIRZ AND NATALIE IN THE COURT OF COMMON PLEAS GEWIRZ, HUSBAND AND WIFE, OF CUMBERLAND COUNTY, PENNSYLVANIA LORENTZ KAFKA, Plaintiffs V. Defendant NO. 07-2880 CIVIL ACTION JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the undersigned as counsel for Defendant, Lorentz Kafka, in the above-captioned matter. Respectfully submitted, DICKIE, MCCAMEY & CHILCOTE, P.C. Date: June 15, 2007 B CXA ? Charles E. Haddick, Jr., Esquire ATTORNEY I.D. NO. 55666 J. David Ziegler, Esquire ATTORNEY I.D. NO. 92882 1200 Camp Hill Bypass, Suite 205 Camp Hill, PA 17011-3700 (717) 731-4800 Attorney for Defendants, Lorentz Kafka 1 f • V. CERTIFICATE OF SERVICE AND NOW, June 15, 2007, I, Charles E. Haddick, Jr., Esquire, hereby certify that I did serve a true and correct copy of the foregoing ENTRY OF APPEARANCE upon all counsel of record by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill, Pennsylvania, addressed as follows: By First-Class Mail: Todd D. Getgen SCHMIDT KRAMER, P.C. 209 State Street Harrisburg, PA 17101 (Counsel for Plaintiff) i Haddick, Jr., Esquire c_ --? ko :. 120298 DICKIE, MCCAMEY & CHILCOTE, P.C. BY: CHARLES E. HADDICK, JR., ESQUIRE ATTORNEY FOR: DEFENDANT ATTORNEY I.D. NO. 55666 LORENTZ KAFKA BY: J. DAVID ZIEGLER, ESQUIRE ATTORNEY I.D. NO. 92882 1200 Camp Hill Bypass, Suite 205 Camp Hill, PA 17011 (717)7314800 (Tele) (717)7314803 (Fax) EDWIN GEWIRZ AND NATALIE GEWIRZ, HUSBAND AND WIFE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. 07-2880 CIVIL ACTION LORENTZ KAFKA, Defendant JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue a rule on Plaintiffs to file a Complaint in the above case within twenty days after service of the rule or suffer a judgment of non pros. Respectfully submitted, E, MEY CHILCOTE, P.C. Date: June 15, 2007 By: Charles E. Haddick, Jr., Esquire ATTORNEY I.D. NO. 55666 J. David Ziegler, Esquire ATTORNEY I.D. NO. 92882 1200 Camp Hill Bypass, Suite 205 Camp Hill, PA 17011-3700 (717) 731-4800 Attorney for Defendants, Lorentz Kafka RULE NOW, June 19, 2007, RULE ISSUED AS ABOVE. Prothonot By: Deputy (NOTE: File in duplicate) CERTIFICATE OF SERVICE AND NOW, June 15, 2007, I, Charles E. Haddick, Jr., Esquire, hereby certify that I did serve a true and correct copy of the foregoing PRAECIPE FOR RULE TO FILE COMPLAINT upon all counsel of record by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill, Pennsylvania, addressed as follows: By First-Class Mail: Todd D. Getgen SCHMIDT KRAMER, P.C. 209 State Street Harrisburg, PA 17101 (Counsel for Plaintiff) C' -_?' Charles E. Haddick, Jr., Esquire Ca ^' _a Fn f ? r? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EDWIN GEWIRZ AND NATALIE GEWIRZ, Husband and wife, Plaintiffs V. LORENTZ KAFKA, Defendant No. 07-2880 Civil Action - Law Jury Trial Demanded COMPLAINT The Plaintiffs, Edwin Gewirz and Natalie Gewirz, by and through their attorneys, SCHMIDT KRAMER PC, hereby aver as follows: THE PARTIES 1. The Plaintiffs, Edwin Gewirz and Natalie Gewirz, are adult individuals currently residing at 13726 Mills Avenue, Silver Spring, Maryland. 2. Defendant, Lorentz Kafka, is an adult individual currently residing at 117 Route 24 (also known as Red Rock Road), East Chatham, New York. r FACTS 3. The facts which give rise to the cause of action occurred on or about June 24, 2005 at the Hotel Carlisle at 1700 Carlisle Pike, Carlisle, Cumberland County, Pennsylvania. 4. On June 24, 2005, at about 10:00 a.m., Edwin Gewirz was walking, pushing a hand cart, toward his car when the automobile operated by Lorentz Kafka backed up quickly and hit Edwin Gewirz, knocked him to the ground, and ran over his right foot. 5. At the time of the above-referenced accident, Edwin Gewirz had just walked past the driver's side of Lorentz Kafka's car while the car was stationary and Mr. Kafka was sitting in the car. 6. The collision and resulting injuries and damages are in no way caused or contributed to by the Plaintiffs and were solely caused by the Defendant for the reasons set forth below. COUNT I Edwin Gewirz v. Lorentz Kafka NEGLIGENCE 7. Paragraphs 1 through 6 of the Complaint are incorporated herein by reference and made a part thereof as if set forth in full. 8. The negligence and carelessness of the Defendant, Lorentz Kafka, consisted of the following: a. Failing to keep a reasonable lookout for pedestrians in the parking lot; b. Hitting Edwin Gewirz with an automobile; 2 C. Driving in reverse without looking to see that the way was clear; d. Failing to apply the brakes in time to avoid hitting Edwin Gewirz; e. Operating his vehicle at an excessive rate of speed under the circumstances in the parking lot; f. Failing to have his vehicle under proper and adequate control; g. Operating his vehicle in a manner so as to create a dangerous situation for pedestrians in the parking lot. 9. As a direct and proximate result of the collision and Defendant's negligence, Plaintiff Edwin Gewirz sustained severe and disabling injuries that may be permanent, including but are not limited to: a. transverse fractures of the right 4th and 5th metatarsals of the right foot; b. a heel fracture of the right foot; and c. ongoing left hip and left shoulder pain. 10. As a result of his right foot injuries, Edwin Gewirz currently cannot bear full weight on the right foot and typically uses the assistance of a cane to walk in order to not put full weight on the foot. 3 11. As a factual result of the accident, Plaintiff Edwin Gewirz has incurred medical expenses to date and will continue to incur medical expenses into the future, and thus, a claim for these expenses is made. 12. As a factual result of the accident, Plaintiff Edwin Gewirz has been advised and, therefore avers, that the aforementioned injuries may be permanent in nature and effect and a claim for these injuries is made. 13. As a factual result of the accident, Plaintiff Edwin Gewirz has undergone in the past, and will continue to undergo in the future, pain and suffering, and thus, a claim for these injuries is made. 14. As a factual result of the accident, Plaintiff Edwin Gewirz has been obliged to spend various sums of money and to incur various expenses due to the injuries that he has suffered and may continue to incur the same in the future, and thus, a claim for these losses is made. 15. As a factual result of the accident, Plaintiff Edwin Gewirz suffered a loss of earnings and an impairment of her earning power and capacity in the future, and thus, a claim for these losses is made. 16. As a factual result of the accident, Plaintiff Edwin Gewirz suffered a permanent diminution of his ability to enjoy life and life's pleasures, and thus, a claim for these losses is made. WHEREFORE, Plaintiff Edwin Gewirz demands judgment against the Defendant, Lorentz Kafka, for compensatory damages in an amount in excess of the amount requiring compulsory arbitration. 4 COUNT III Natalie Gewirz v. Lorentz Kafka LOSS OF CONSORTIUM 17. Paragraphs 1 through 16 of the Plaintiffs' Complaint are incorporated herein by reference and made a part thereof as if set forth in full. 18. As a direct and proximate result of the negligence and the injuries sustained in the motor vehicle collision by her husband, Edwin Gewirz, Natalie Gewirz has suffered the loss of consortium, including the diminishment of society and companionship of her husband. WHEREFORE, Plaintiff Natalie Gewirz demands judgment on the Defendant, Lorentz Kafka, in an amount in excess the amount requiring compulsory arbitration. Respectfully submitted, SCHMIDT KRAMER PC Date: TA ,-? 607 By: .---- ? Todd D. Getgen I.D. No. 80719 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs 5 VERIFICATION We, Edwin Gewirz and Natalie Gewirz, verify that the facts contained in the foregoing Complaint are true and correct to the best of our knowledge, information and belief. We 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. DATED: ,.? Ta g? a 00 Edwin Gewi Natalie Gewirz L7 {`? ' v - n rte .? cam. ? -r, -w:;:'- - ? ? ??3t?? -. ? -,}? 'a )s.? g? ?` •'^\ a ? , ?' 1 a Q 189552 DICKIE, MCCAMEY & CHILCOTE, P.C. BY: CHARLES E. HADDICK, JR., ESQUIRE ATTORNEY FOR: DEFENDANT ATTORNEY I.D. NO. 55666 LORENTZ KAFKA BY: J. DAVID ZIEGLER, ESQUIRE ATTORNEY I.D. NO. 92882 1200 Camp Hill Bypass, Suite 205 Camp Hill, PA 17011 (717)7314800 (Tele) (717)7314803 ax EDWIN GEWIRZ AND NATALIE GEWIRZ, IN THE COURT OF COMMON PLEAS OF HUSBAND AND WIFE, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. LORENTZ KAFKA, NO. 07-2880 CIVIL ACTION JURY TRIAL DEMANDED Defendant NOTICE TO PLEAD TO: Todd D. Getgen SCHMIDT KRAMER, P.C. 209 State Street Harrisburg, PA 17101 YOU ARE HEREBY NOTIFIED TO PLEAD TO THE WITHIN DEFENDANT'S ANSWER WITH NEW MATTER WI'T'HIN TWENTY (20) DAYS OF THE DATE OF SERVICE OF THIS PLEADING OR JUDGMENT MAY BE ENTERED AGAINST YOU. Respectfully submitted, DICKIE, MCCAMEY & CHILCOTE, P.C. Date: August 21, 2007 By: Charles E. Haddick, Jr., Esquire ATTORNEY I.D. NO. 55666 J. David Ziegler, Esquire ATTORNEY I.D. NO. 92882 1200 Camp Hill Bypass, Suite 205 Camp Hill, PA 17011-3700 (717) 731-4800 Attorney for Defendants, Lorentz Kaf ca 1 127916 DICKIE, MCCAMEY & CHILCOTE, P.C. BY: J. DAVID ZIEGLER, ESQUIRE ATTORNEY FOR: DEFENDANT ATTORNEY I.D. NO. 92882 LORENTZ KAFKA BY: CHARLES E. HADDICK, JR., ESQUIRE ATTORNEY I.D. NO. 55666 1200 Camp Hill Bypass, Suite 205 Camp Hill, PA 17011 (717)731-4800 (Tele) (717)731-4803 (Fax) EDWIN GEWIRZ AND NATALIE GEWIRZ, HUSBAND AND WIFE, Plaintiffs V. LORENTZ KAFKA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-2880 CIVIL ACTION JURY TRIAL DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER TO PLAINTIFFS' COMPLAINT AND NOW, comes Defendant, Lorentz Kafka, by and through his counsel, Dickie, McCamey & Chilcote, P.C. and responds to Plaintiffs' Complaint as follows: 1. Admitted. 2. Admitted. 1-6. The averments contained in these paragraphs are denied generally pursuant to Pa.R.C.P. 1029(e). By way of further response, the averments contained in these paragraphs are conclusions of law to which no response is required. In the alternative, the averments contained in these paragraphs are specifically and unequivocally denied with strict proof demanded at the time of trial. Answering Defendant hereby incorporates his New Matter as if fully set forth herein. COUNTI EDWIN GEWIRZ V. LORENTZ KAFKA NEGLIGENCE 7. Answering Defendant hereby incorporate paragraphs 1 through 6 above as if fully set forth herein. 8.46. The averments contained in these paragraphs are denied generally pursuant to Pa.R.C.P. 1029(e). By way of further response, the averments contained in these paragraphs are conclusions of law to which no response is required. In the alternative, the averments contained in these paragraphs are specifically and unequivocally denied with strict proof demanded at the time of trial. Answering Defendant acted reasonably, properly and prudently at all times material hereto. Answering Defendant hereby incorporates his new matter as if fully set forth herein. WHEREFORE, Answering Defendant, Lorentz Kafka respectfully request that Plaintiffs' Complaint be dismissed and judgment be entered in favor of Answering Defendant, together with all allowable costs and attorneys fees. COUNT III [SIC] NATALIE GEWIRZ V. LORENTZ KAFKA LOSS OF CONSORTIUM 17. Answering Defendant hereby incorporates by reference paragraphs 1 through 16 above as if fully set forth herein. 18. The averments contained in this paragraph are denied generally pursuant to Pa.R.C.P. 1029(e). By way of further response, the averments contained in this paragraph are conclusions of law to which no response is required. In the alternative, the averments contained in these paragraphs are specifically and unequivocally denied with strict proof demanded at the time of trial. Answering Defendant acted reasonably, properly and prudently at all times 2 material hereto. Answering Defendant hereby incorporates his new matter as if fully set forth herein. WHEREFORE, Answering Defendant, Lorentz Kafka respectfully request that Plaintiffs' Complaint be dismissed and judgment be entered in favor of Answering Defendant, together with all allowable costs and attorneys fees. NEW MATTER 19. All averments not specifically admitted above are specifically and unequivocally denied with strict proof demanded at the time of trial. 20. At all times material hereto, Answering Defendant acted reasonably, properly, and prudently. 21. The evidence will likely show that the Plaintiffs claims are barred and/or limited by the doctrines of comparative and/or contributory negligence. 22. The evidence will likely show that the Plaintiff's claims are barred and/or limited by the doctrine of assumption of the risk. 23. The evidence will likely show that the Plaintiff's injuries, which are specifically denied with strict proof demanded, were the result of acts or omissions of persons over whom Answering Defendant had no control or right of control. 24. The evidence will likely show that the Plaintiff s injuries, which are specifically denied with strict proof demanded, were caused in whole or in part by persons other than Answering Defendant, over whom Answering Defendant had no control or right of control. Such conduct precludes and/or limits any liability on the part of Answering Defendant, which is specifically and unequivocally denied. 3 25. The evidence will likely show that the Plaintiff's claims are barred and/or limited by the applicable statutes of limitations. 26. The evidence will likely show that the Plaintiff's claims are barred by the doctrines of arbitration and award, accord and satisfaction, estoppel, failure of consideration, illegality, release, and / or waiver. 27. All defenses are raised and preserved under the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S.A. §1701 et seq. 28. The evidence will likely show that the Plaintiff's Complaint fails to state a cause of action upon which relief can be granted. 29. The evidence will likely show that the Plaintiff has not sustained substantial impairment of bodily function and is therefore limited and/or precluded from recovering damages under the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S.A. §1701 et seq. 30. The evidence will likely show that no conduct on the part of Answering Defendant was the proximate cause of Plaintiff's injuries, if any. 31. The evidence will likely show that at no time material hereto did Answering Defendant know or believe that operation of his vehicle caused a hazard to any other motorists. WHEREFORE, Answering Defendant, Lorentz Kafka respectfully request that Plaintiffs' Complaint be dismissed and judgment be entered in favor of Answering Defendant, together with all allowable costs and attorneys fees. 4 Respectfully submitted, DICKIE, MCCAMEY & CHILCOTE, P.C. Date: August 21, 2007 B_..- Charles E. Haddick, Jr., Esquire ATTORNEY I.D. NO. 55666 J. David Ziegler, Esquire ATTORNEY I.D. NO. 92882 1200 Camp Hill Bypass, Suite 205 Camp Hill, PA 17011-3700 (717) 731-4800 Attorney for Defendants, Lorentz Kafka 5 128909 VERIFICATION I, Lorentz Kafka, hereby verify that the facts set forth in the foregoing Answer with New Matter 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 unworn falsification to autliorities. CERTIFICATE OF SERVICE AND NOW, August 21, 2007, I, Charles E. Haddick, Jr., Esquire, hereby certify that I did serve a true and correct copy of the foregoing DEFENDANT'S ANSWER WITH NEW MATTER TO PLAINTIFFS' COMPLAINT upon all counsel of record by depositing, or causing to be deposited, same in the U.S. mail, postage prepaid, at Camp Hill, Pennsylvania, addressed as follows: By First-Class Mail: Todd D. Getgen SCHMIDT KRAMER, P.C. 209 State Street Harrisburg, PA 17101 (Counsel for Plaintiff) Charles E. Haddic , Jr., Esquire ?? r? c_-- <_? ?? -,?, '"r n,? ? - ?"" ? ?? - -? ?, c_ `?" ?,.: _ ? ??::, ? ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EDWIN GEWIRZ AND NATALIE GEWIRZ, Husband and wife, Plaintiffs V. LORENTZ KAFKA, Defendant No. O?-2880 Civil Action - Law Jury Trial Demanded PLAINTIFFS' REPLY TO DEFENDANT'S NEW MATTER The Plaintiffs, Edwin Gewirz and Natalie Gewirz, by and through their attorneys, SCHMIDT KRAMER PC, hereby aver as follows: 19. Denied. Defendant's new matter does not contain any facts and is a conclusion of law which is deemed denied under Pa.R.C.P. 1029(d) and (e). 20. Denied. Defendant's new matter does not contain any facts and is a conclusion of law which is deemed denied under Pa.R.C.P. 1029(d) and (e). 21. Denied. Defendant's new matter does not contain any facts and is a conclusion of law which is deemed denied under Pa.R.C.P. 1029(d) and (e). 22. Denied. Defendant's new matter does not contain any facts and is a conclusion of law which is deemed denied under Pa.R.C.P. 1029(d) and (e). 23. Denied. Defendant's new matter does not contain any facts and is a conclusion of law which is deemed denied under Pa.R.C.P. 1029(d) and (e). 24. Denied. Defendant's new matter does not contain any facts and is a conclusion of law which is deemed denied under Pa.R.C.P. 1029(d) and (e). 25. Denied. Defendant's new matter does not contain any facts and is a conclusion of law which is deemed denied under Pa.R.C.P. 1029(d) and (e). 26. Denied. Defendant's new matter does not contain any facts and is a conclusion of law which is deemed denied under Pa. R. C. P. 1029(d) and (e). 27. Denied. Defendant's new matter does not contain any facts and is a conclusion of law which is deemed denied under Pa.R.C.P. 1029(d) and (e). 28. Denied. Defendant's new matter does not contain any facts and is a conclusion of law which is deemed denied under Pa.R.C.P. 1029(d) and (e). 29. Denied. Defendant's new matter does not contain any facts and is a conclusion of law which is deemed denied under Pa.R.C.P. 1029(d) and (e). Moreover, limited tort cannot be an issue in this case given the facts. 30. Denied. Defendant's new matter does not contain any facts and is a conclusion of law which is deemed denied under Pa.R.C.P. 1029(d) and (e). 31. Denied. Defendant's new matter does not contain any facts and is a conclusion of law which is deemed denied under Pa.R.C.P. 1029(d) and (e). 2 WHEREFORE, Plaintiffs, Edwin Gewirz and Natalie Gewirz, demand judgment of the Defendant, Lorentz Kafka, in an amount in excess the amount requiring compulsory arbitration. Respectfully submitted, SCHMIDT KRAMER PC Date: ,Z -3/g 60-7 By: l Todd D. Getgen I.D. No. 80719 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs 3 ?? ti r ? c: a <4 ..? 7 "Tt { _ _a --c: --? ?? , ?- v. -n :? -1 r, °4.? 1 . ' - G .,? ? 1* EDWIN GEWIRZ and NATALIE GEWIRZ, her husband, Plaintiffs V. LORENTZ KAFKA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-2880 CIVIL ACTION - LAW PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Todd D. Getgen, counsel for the Plaintiffs in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of plaintiff in the action is $45,000. The counterclaim of the defendant in the action is 0.00. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: Todd D. Getgen, Esquire; James DeCinti, Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, SCHMIDT KRAMER PC By: Todd D. Getgen Attorney I.D. No. 80719 209 State Street Harrisburg, PA 17101 (717) 232-6300 Date: Attorneys for Plaintiffs ? '?' -- ? ? `=,? f ?T 4?k .. ?? ?.. ?d .,.a ?* `? ?1i$:? ? ? ? .n-... ? • y ?.../ ?? n ? T`J , :.a,3 „? EDWIN GEWIRZ and NATALIE : IN THE COURT OF COMMON PLEAS GEWIRZ, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA • 67.2"" Plaintiffs NO. Q3-a" V. CIVIL ACTION - LAW LORENTZ KAFKA, Defendant JURY TRIAL DEMANDED ORDER OF COURT AND NOW, the 1& -eA day of 2009, in consideration of the foregoing //ii n petition, CA44, . d. 6-4g z -IXZ Es Esq., and Esq, are appointed arbitrators in the ove captioned action as prayed for. By the Co CM 1 F.i f`? d t? UL l V W c7N t...e rat tii. $ f 1 v so it, `t rI 2k.?Y2 Plaintiff Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. O 4 --o) "0 Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support , ob y and defend the Constitution of the United of this Co mmonw e will discharge the duties of o States and the Co7,: with fidelity. /-signature Signature gnature ? ?w?cs ,Qe?tY Na C-, 4 t. -, t q ? - - +,. , me (Chairman)) Q,p Law Firm // a S- #C Prot Lo.v- Adv e_ Address Address f J Name + l Clrb s?-?f O , ?C Law Firm p? A 9b ?u Address City, zip city, zip City, 'p O /aarra ,'6` sL 'il -.819 We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the follow//i??ng award: (Note: If dama es for de y are award they shall be separately stated.) k? ?- -ry?-? ow Q ?,. 4?? K vu? o p 1a', . f , _ C w ?? ... V z , 441 GLmo-- /- aftt !4. ?GVq?.t pI&--t4.J7 AfQ+4(-e- ?WtYZ Arbitrator, dissents. Date of Hearing: E LIf- 0 Date of Award: S&L name if (Chairinan) .r t Je'.rdu3r. t.vr'n... t;?gpn CdAC XYJ Name S/4 /* 4!r Law Firm Notice of Entry of Award Now, the day of 20LJ__, at e '.Z7 ?.M., the above award was entered upon the docket and notice there f given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $-3,4;a ar2 ( a&7k w By: Prothonotary Deputy FILF D- 2099 AI?G 10 A, '1 0: 21 1 N 6 _ OOF IES ?n.`It??p P4 . £? p A e.C 2 zb IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EDWIN GEWIRZ AND NATALIE GEWIRZ, Husband and wife, Plaintiffs V. LORENTZ KAFKA, Defendant No. 07-2880 Civil Action - Law Jury Trial Demanded PRAEICPE FOR ENTRY OF JUDGMENT TO THE PROTHONOTARY: Please enter judgment against Lorentz Kafka as follows: Arbitration award in favor of the Plaintiff in the amount of $14, in favor of Plaintiff Natalie Gewirz in the amount of $2,500. Please enter this judgment in accord with the arbitrators' award captioned case and Pa. R.C.P. 3021. Respectfully submitted, Date: ?? 260 SCHMIDT KRAMER PC C By: Todd D. Getgen I.D. # 80719 209 State Street Harrisburg, PA 17101 (717) 232-6300 tgetgen@schmidtkramer.com Attorney for Plaintiffs and the CERTIFICATE OF SERVICE AND NOW, this 11th day of September, 2009, I hereby certify that I 1?ave, this day, caused a copy of the foregoing Praecipe for Entry of Judgment to be served by deposit in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: By U.S. Mail James DeCinti, Esquire Dickie McCamey & Chilcote, P.C. 1200 Camp Hill Bypass, Ste. 205 Camp Hill, PA 17011 SCHMIDT KRAMER PC Date: By: Todd D. Getgen I.D. # 80719 209 State Street Harrisburg, PA 17101 (717) 232-6300 tgetgen@schmidtkramer.com Attorney for Plaintiffs FILED-c,' FICE OF THE R ;1.40 OTARY 2009 SEP 16 AM 9; 14 curly l y L ?AW 6 T -+ 14. oo Po A7" CK.'w I Ban K)Ae,t Ktw j-td IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA EDWIN GEWIRZ AND NATALIE GEWIRZ, Husband and wife, Plaintiffs v. LORENTZ KAFKA, Defendant : No. 07-2880 Civil Action - Law Jury Trial Demanded NOTICE OF ENTRY OF JUDGMENT PUR8UANT TO PA R.C.P. 236 TO: LORENTZ KAFKA Care of: James DeCinti, Esquire Dickie McCamey & Chilcote, P.C. 1200 Camp Hill Bypass, Ste. 205 Camp Hill, PA 17011 You are hereby notified that on September I ivy` , 2009, the judgment has been entered against you in the above captioned case: Date: