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HomeMy WebLinkAbout07-5180~ ~~ F: ~FII.ES~MAC9500\CmreMki36\9500.436.pra 1 /ajt Creates: 9/20/04 0:06PM Revised: BYl9/07 2:41PM 9500.436 Daniel K. Deardorff, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17837 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff WILLIAM FEIItRELL, Plaintiff v. POLCLEAN SERVICES, INC. 96 Lincoln Avenue Hawthorn, NJ 07506 and NATIONAL FLOOR CARE, INC. 781 South Midlothian Road, Suite 109 Mundelein, IL 60060, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue a Writ of Summons upon Polclean Services, Inc., and National Floor Care, Inc., at the above-listed addresses and return it to our office for service. Respectfully submitted, ON OFF B ~` Date: August 29, 2007 Daniel K. Deardorff, Esquire I.D. No. 17837 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ~ ~ Q A `_ "'U r'; ~ \ -~... - mo / f ' ` ~'ay ~^~ w ~ { J $l v t~ ' "~ iA ~ l " ~~) d ~ V ~„ r_ . ~ ~ l ~ tTt ~ p CTs 0 Commonwealth of Pennsylvania County of Cumberland WRIT OF SiIMMONS Court of Common Pleas William Feirrell Plaintiff Vs. Polclean Services, Inc. 90 Lincoln Avenue Hawthorn N J 0 7506 and National Floor Care, Inc. No 07-5180 Civil Term 781 South Midlothian Road, Suite 109 Mundelein, I160060 Defendant In CivilAction-Law To Polclean Services Inc and National Ftoor Care, Inc., You are hereby notified that William Feirrell the Plaintiffs) has /have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment maybe entered against you. (SEAL) ~~ urtis R. Long, Prothan tary Date August 30, 2007 Attorney: Name: Deaniel K. Deardorff, Esq. Address: 10 East high Street Carlisle, Pa. 17013 Attorney for: Plaintiff Telephone: (717)243-3341 Supreme Court ID No. 17837 By eputy F:IFILFS1CtianslMAC93001Cutrutt14 3 619 30 0.43ti. affofsvc I /ajt Created: 9120/04 0:06PM Revised: 9/10/07 O:I4PM 9300.436 Daniel K. Deazdorff, Esquire MARTSON DEARDORFF WTLLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17837 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff WILLIAM FEIRRELL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. POLCLEAN SERVICES, INC., and NATIONAL FLOOR CARE, INC., Defendants NO. 07-5180 CIVIL ACTION -LAW JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE I, Daniel K. Deazdorff, Esquire, attorney for the Plaintiff, William Feirrell, being duly sworn according to law, depose and state that a copy of the attached Writ of Summons was served on the following Defendants by Certified Mail on the 4~' day of September, 2007. POLCLEAN SERVICES, INC. 96 Lincoln Avenue Hawthorn, NJ 07506 Date: 9/~jd7 NATIONAL FLOOR CARE, INC. 781 South Midlothian Road, Suite 109 Mundelein, IL 60060 MART50N LAW OFFICES By (/~ Daniel K. Deardorff, Esquire Attorneys for Plaintiff Sworn to and subs 'bed before me this ib~ay of c1 Ov-7 llt. Notary Public cow +en~.n~ aF Pa~svfv riser eaaaGu~k ~ do ~lowttaNon of Notaries Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS William Feirrell Plaintiff Vs. Polclean Services, Inc. 90 Lincoln Avenue Hawthorn N J 07506 and National Floor Care, Inc. 781 Sou#h Midlothian Road, .Suite 109 Mundelein, Il 60060 Defendant Court of Common Pleas No 07-5180 Civil Term In CivilAction-Law To Polclean Services Inc and National Floor Care, Inc., You are hereby notified that William Feirrell the Plaintiff(s) has /have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) C is R. Long, Prothonot ~-' Date August 30, 2007 By ~u,,,__ Q. Deputy Attorney: Name: Daniel I{. Deardorff, Esq. Address: 10 East High Street Carlisle, Pa. 17013 Attorney for: Plaintiff Telephone: (717)243-3341 Supreme Court ID No. 17837 i ~ +1;. .: ~l~ ~I of t8id iA ~ ~. .... h~MD#'NylA~w ~' ~ • . • • ~~ ~ • ~ '~ S 14.41 1 ---...,~,., M, "r G Certllfed Fee f2. ` . X17 ~q.~ k~4y ,~ Reprm RedeptFee (EIId0leerrleld Requred) #'~ i 1J " i ~ ReslNcEed Delivery Fee (Endorsernerrt Re uired) ~ '~ • ~~` ~ ! O q ~ ~ _, ~ Total Postage 8 Fees m ~•~/ o National Floor Care, ---''.~~`~ aA0/nYrMmi, 781 S. Midlothiaira:' Rd , „S~g: 109 , 7~s ~ -------------------------------- ---------------------------------- Mundeleln, IL 60060 ._. ; __ _ - __ ,,,..e..._._._._._ •~~ki~t 1, ~. aid 6. ~No ~ ._ 4 N Rli'I19~iwM~ M dNb~J. ~ X01/' f1rM~Ml~ ~ 011 U» 1l ~~ ' "^°" '~ M1rR 1Mi C~1 lrMrll MM O^d eu yOti. ` $. w +~-~-ard+~ tlwel~k a ~. ~, iron ~h.~gnt it~pp. ~~ ~ a rem ~~s,« onsl Floarr Vie, Inc.:.. $. ~~ot~ Riil, 9tea leis, IL 6a .~~ r f ~,.,. Q No ;, .,+~` ~ ~- ~~ ~ '"x: ~'1 c~.r'r~w ~ d w Q D kli~!!-Irll .. Q QGU0. s. Rw~llobd ~~ 1e~el.A~q- t ~~~~~~" ! 7003 1010 X001 1188. 928 k-, ~ lArs u7 ~ m ti ,. . .• y o~ ~ ~ ~~~ (~ndowsrnern Requked) !2. 5 ~.:, ~ x`^''~w ~Q.~._. 0 .(~11d0180RIBIdlt6d~ ~i'" .. ,'~~. 0 _w ~ T ~e~ Fees $ $,~.21 ~:VB~~;.,,-~ ~Rw, ~ m ~Su(1 ..-~ Wtl~-(~ o ~ Pol_clean Services, Inc. ~ ro vivo ' 96 Lincoln Avenue w ,. ....__..~,..._... ..~,_.._.~,-..~-__.__.......w _..__._ _ ,. * 41t tl~ Ind 1~ "~ ~,Y, Q it yvu' n~~i'and ~ on tM arranu •Ir thMt wr a1n arluen 1M- odd b yet. d, R~wlwd by (fie Hrmy s ~dti thls a~rt1 to 1ti baoit d the nraMpNo~, eMron tha trod it ~p~o~s v~~+nhr. c. ~s aww~e~-.ea~r.r alr~.nrta~ M~ t ~» i. AIMnM M 1(L'4s, NMM dMilMy aeNl~r b~11aNt ~'~ lr~lcla des, Zac. !6 L 4reauw ~ , ~aat~o ~- 07$Q6 s. '. I~ C~M1M~d AAU1 D D d Q f1~~t Rx k1MatMrrMr ~ O MrwwO tiA~ll ~ C.O.D. 4. RrNNolyd Diwryr4' I~w l~iN O l~s ~ ~rNunt~r 7003 1010 0001 1188 9235 Alllibr aan a~rla ~4 ~o~e~oa+~-a~ ! -- __._~ CERTIFICATE OF SERVICE I, Ami J. Thumma, an authorized agent for Manson Law Offices, hereby certify that a copy of the foregoing Affidavit of Service was served this date by depositing same in the Post Office at Cazlisle, PA, first class mail, postage prepaid, addressed as follows: POLCLEAN SERVICES, INC. 96 Lincoln Avenue Hawthorn, NJ 07506 NATIONAL FLOOR CARE, INC. 781 South Midlothian Road, Suite 109 Mundelein, IL 60060 MARTSON LAW OFFICES By Ami umm Ten East High eet Cazlisle, PA 17013 (717) 243-3341 Dated: 4//D/~ 7 ~i .r+ ~,;; li ~ A :~ ' ~~~~ , p ~~ ~~ : ~ ~ ~ ~+* ..- m FaF[LES\CGents\MAC95001Current1436\9500.436.com 1 /ajt Created: 980/04 0:06PM Revised; (/28/09 4:32PM 9500,436 Daniel K. Deardorff, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17837 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff WILLIAM FEIRRELL, Plaintiff v. POLCLEAN SERVICES, INC. and NATIONAL FLOOR CARE, INC., Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5180 CIVIL ACTION -LAW 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 or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAFER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-31 b6 Daniel K. Deardorff, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17837 10 East High Street Carlisle, PA 17013 (717)243-3341 Attorneys for Plaintiff WILLIAM FEIRRELL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-5180 CIVIL ACTION -LAW POLCLEAN SERVICES, INC and NATIONAL FLOOR CARE, INC., Defendants JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, William Feirrell, by and through his attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER (Martson Law Offices), and file the within Complaint against the above-named Defendants, averring as follows: 1. The Plaintiff, William Feirrell, is an adult and competent individual presently residing at 7 West Locust Street, Enola, Cumberland County, Pennsylvania 17021-7025. 2. The Defendant, Polclean Services, Inc., is a business corporation duly organized and existing under the laws of the State of New Jersey, with its principal place of business at 96 Lincoln Avenue, Hawthorn, NJ 07506. 3. The Defendant, National Floor Care, Inc., is business corporation duly organized and existing under the laws of Illinois with its principal place of business at 781 South Midlothian Road, Suite 109, Mundelein, IL 60060. 4. Both Defendants are involved in the business of professionally cleaning floors of stores and they had contracts to clean the floor of the Giant Food Store in Enola, Cumberland County, Pennsylvania. 5. At all times material herein, all customers and employees ofthe said Giant Food Store in Enola must walk or travel through the aisles and along the said floors that were cleaned by the Defendants. 6. At all times material herein, the flooring of said Giant Food Store consisted of tiled flooring in the area where the following event occurred. 7. At all times material herein, the Defendants acted by and through their duly authorized agents, servants and/or employees, acting within the scope of their authority and employment. 8. The Defendants owed a duty of care to the customers and Giant employees such as the Plaintiff who was employed at said store as follows: (a) the duty to warn the customers and employees of known dangers, or dangers the Defendants should have known of, and unsafe conditions occumng or existing in the subject store of which they were or should have been aware as a result of their floor cleaning; and (b) the duty to prevent, correct, remedy, cure and /or eliminate such known dangers, or dangers the Defendants should have known of, and unsafe conditions occurring or existing in the subject store as a result of their floor cleaning. COUNTI William Feirrell v Polclean Services. Inc., and National Floor Care Inc. 9. Paragraphs 1 through 8 of the Plaintiff s Complaint are hereby incorporated by reference as though fully restated herein. 10. On or about September 5, 2005, at the time of the accident described herein, the floor of said floor was being cleaned by the agents, servants and/or employees of Defendant Polclean Services, Inc., and/or Defendant National Floor Care, Inc. 11. At the time of the accident described herein, there were puddles of water that were difficult to see and that were not marked by warning signs on the floor which were left by agents, servants and employees of Defendants. 12. On or about September 5, 2005, Plaintiff, who was an employee of Giant Food Stores, while in the course of his employment was working in an aisle of the store when he slipped and fell. 13. Plaintiff slipped and fell injuring his right knee as a direct result of water and/or wet and slippery surface conditions existing on the floor as stated in paragraphs 10 and 11. 14. The floor where Plaintiff fell was open to the public and it was the duty and responsibility of the Defendants to maintain the area in a reasonably safe condition for public travel thereon. 15. At all times material herein, the Defendants carelessly and negligently permitted water and/or wet and slippery floor conditions to occur and exist in the area where Plaintiff fell. 16. At all times material herein, the Defendants knew of or should have known of the dangerous, slippery and wet floor conditions which existed in the area where Plaintiff fell. 17. The water and/or wet and slippery floor conditions occurring and existing in the area where Flaintiff fell constituted a dangerous and unsafe condition for customers and employees walking thereon. 18. As a result of the aforesaid accident, the Plaintiff suffered certain injuries and damages as further described herein. 19. The aforesaid accident, and the Plaintiffs resulting injuries and damages, were wholly, directly and proximately caused by the negligent and careless acts or omissions of the Defendants, their agents, servants and/or employees, which included the following: (a) Failing to use due care and to employ reasonable skill in the performance of their duties and in their duty of care owed to the Plaintiff; (b) Failing to exercise the judgment, care and skill of reasonable persons under similar circumstances; (c) Permitting the flooring where Plaintiff fell to remain in an unsafe, unsuitable and dangerous condition, despite knowledge of this condition; (d) Failing to use reasonable prudence or care in maintaining the floor, and failing to properly and adequately maintain the flooring where Plaintiff fell; (e) Failing to use reasonable prudence or care and failing to take precautionary measures to avoid or to otherwise prevent the accumulation of water and/or the occurrence of wet and slippery floor conditions in the area where Plaintiff fell; (f) Failing to post signs or provide any verbal or written notice or warnings to the Plaintiff of the presence and existence of the unsafe conditions described herein; (g) Unreasonably exposing the Plaintiff to the dangerous conditions described herein; (h) Failing to prevent, correct, remedy, cure and/or eliminate the dangerous and unsafe conditions described herein; (i) Failing to provide and maintain an appropriate and adequate floor covering so as to furnish users, customers, invitees and employees with a reasonably safe area on which to walk; and (j) Permitting the dangerous and unsafe conditions described herein to exist for an unreasonable period of time. 20. The Defendants had or should have had by the exercise of reasonable care, knowledge and/or notice of existence of water and/or wet and slippery conditions existing on the floor where Plaintiff fell, and the Defendants were obligated to prevent, remedy, cure, correct and/or eliminate such dangerous and unsafe conditions. 21. As a result of the negligence of the Defendants, their agents, servants and/or employees, Plaintiff has suffered a certain serious physical injury to his right knee which maybe permanent and will continue to cause Plaintiff great pain and suffering. 22. As a result of the negligence of the Defendants, their agents, servants and/or employees, Plaintiff has suffered physical pain and mental anguish, and will continue to endure the same for an indefinite time in the future, to his great detriment and loss. 23. As a result of the negligence of the Defendants, their agents, servants and/or employees, Plaintiff has been unable to attend to some of his usual daily duties and activities, and he maybe unable to attend to them for an indefinite time in the future, to his great detriment and loss. 24. Solely as a result of negligent, carelessness and recklessness of the Defendants, Plaintiff has been required to seek medical attention and care, including knee surgery, and has incurred substantial medical, hospital and other health care provider's expenses for the care and treatment of the injury that he sustained, and he may be further forced to incur such additional medical and other expenses for the care and treatment of this injury for an indefinite period of time in the future. 25. As a result of his injury, Plaintiff may have sustanied a permanent diminution to his ability to enjoy life and life's pleasures, in that he is unable to engage in many of the activities that he engaged in prior to the accident. 26. As a result of the negligence of the Defendants, Plaintiffhas suffered a loss of wages and a diminution in her earning capacity, which wage loss and diminution in earning capacity he may continue to suffer for an indeterminate time into the future. 27. At alI times material herein, Plaintiff exercised a reasonable degree of caution and used ordinary care. 28. At all times material herein, the Defendants did not provide Plaintiffwith prior notice or warning of any kind about the presence of water and/or wet and slippery floor conditions existing in the area where he fell. 29. Plaintiff avers that if he had known about the presence of water and/or existence of wet and slippery floor conditions, he would have avoided walking through the area. 30. Plaintiff did not cause or contribute in any way to the happening of the aforesaid accident. WHEREFORE, Plaintiffhereby demands that judgment be entered in his favor and against the Defendants in an amount in excess of Fifty Thousand Dollars ($50,000.00}, the compulsory arbitration limits of this Honorable Court, plus interest thereon, plus costs of this action. MARTSON LAW OFFICES B ~ ~ V . (,. Y Daniel K. Deardorff, Esquire l OEast High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: a~ i ~U o~ f ' ' . 1 VERIFICATION The foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document 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 content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. (..~~~ y William Feirrell F'.\FILE S\Clients\MAC9500\Cutrent\436\9500.436.com l "'~ ~ l ~.s ~_.\ ~ f._ ) ~~ .. ~.k,.et . _'~`j ~• ~~ ~ . r', ~ f ''" F 7? -_ t &,. -' `''~ F: \F[LES\Ctients~MAC9500\Cwrent\436\9500.436. pra2/ajt Created: 9120/04 0:06PM Revised: 2117!09 4:31 PM 9500.436 Daniel K. Deardorff, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17837 10 East High Street Carlisle, PA 17013 (717)243-3341 Attorneys for Plaintiff WILLIAM FEIRRELL, Plaintiff v. POLCLEAN SERVICES, INC. and NATIONAL FLOOR CARE, INC., Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5180 CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE TO DOCUMENT SERVICE PURSUANT TO THE PENNSYLVANIA LONG ARM STATUTE I hereby certify that a copy of the Complaint was mailed to Polclean Services, Inc., on January 29, 2009, by certified mail, return receipt requested. Attached is the post office return receipt signed and dated February 7, 2009. Date: February 17, 2009 Respectfully submitted, MA SON'L/AW OFFICES By ~` Daniel K. Deardorff, Esq I.D. No. 17837 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff 1! ~ o N '• • ~ .- • . .- rte- ~ ~ ~' f `' Postage $ ;4.59 0013 ~ O Certified Fee 12.74 4 C~a ~ S d ~ Retum Receipt Fee (EndoraemerrtRequlred) :2~2Q, el Oj ~ Fleryj;~ `7~ J' Q r..q Restricted Delivery Fee (EndoraementRequired) ~~(~ ~" O ~~ Z o nTotal Posta~e & Fees ,~ _~ ~ ,~9 ~ ~ .a ,~ ~ ` A ent or POeorNo. (D V n(~ In iAi,~,o t~ , ~ ~ n. Ns ^ tlolapiete Rems 1, 2, and 3. Also complete ilea 41f Restricted Deflvery is desired. ^ PMnt your name and address on the reverse so tat we can rllturn the card to you. ^ Alwch this card to the back of the maiipiece, a on the front if space permits. A Signature D eived by (Printed Name} C. Date of ~~7 D. is delivery address differerrt from item 1? ^ Yes If YES, enter delivery address below: ^ No 1-~-t~,v~ '" 't~ r, `~I S b-ISCSIp s. s~,~+~,y~ Certified Mail ^ Express Mail Registered O Retum Receipt for Mercherrdlss ^ Insured Mali ^ C.O.D. 4. Restricted Delivery'1(F.xbe Feel ^ Yes ~' ""~` 7006 Q81Q QOt1Q 7873 975[l (lhrrsfer from servke laden P3 Form 3$11, February 2004 Domestic Return Receipt io2sss-o2-natsso i l_. 1. Ardole /dressed to: ~o tC,~~~1 S-2.vv~ tQ-~,I `, ; ~ - • - f ~.~ -~ _, . - o~; ~a:.J ~~%" } . i' A .,k -. F:\FILES\Clieats\MAC9500\Curreat\436\9500.436.pra3/ajt Croated: 9/20/04 0:06PM Revised: 2!17!09 4:47PM 9500.436 Daniel K. Deardorff, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17837 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff WILLIAM FEIRRELL, Plaintiff v. POLCLEAN SERVICES, INC. and NATIONAL FLOOR CARE, INC., Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5180 : CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE TO DOCUMENT SERVICE PURSUANT TO THE PENNSYLVANIA LONG ARM STATUTE I hereby certify that a copy of the Complaint was mailed to National Floor Care, Inc., on January 29, 2009, by certified mail, return receipt requested. Attached is the post office return receipt signed and dated February 2, 2009. Date: February 17, 2009 Respectfully submitted, MARTSON LAW OFFICES By ~ . Daniel K. Deardorff, Esquire I.D. No. 17837 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ~' "- ,~ fr m tti - ~`- Postage $ 60.59 0013 ~ ~ Certified Fee :4.70 7 S d Sn ~ ~ Retum Receipt Fee (EndoreementRequfred) ;4'~ ~ ~ re r] ~ O ~ Restricted Delivery Fee (Endorsement Required) ~.~ ! Nal' ~ ~ ~ T P e & Fees ~ #5.49. ~ ~ ~ --- orPOewrf+w. `1g I..~Q!~1. --- --- ---- --•------------•-F- .M:~~o~`o~o~ ~~--- -~--- - ----------------- cn~, seas zrP.a rn~ - n rl o ~.~ i h 'C,1__ Lo 0 0 Ltz (7 ^ (batplete Items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Pfint your name and address on the reverse so fatat we t;B11 return the card to you. ^ ~tlelctt this card to the back of the mailpiece, or on the front if space permits. 1. Mlcle Address~eJd to: ~O~i0~0,1~ 1~`Oll~,~:0.-~~,~ ~~~`~ ~~ ~o~ ~l~p~ :Q,~lUnl ~ (~O ll lD D 2. Mlcle Number (fhrtsfer firm serufae -abeq a si9 ^ ~ X ^ 114rlwene B. Received by (Printed Name) C.~tetd_~Mwty D. Is~eUvery address different iron's item 1? ^ ~ If YES, enter delivery address below: ^ t'~o t ~~ ~_~ _. i o 3. Service T i~Certtfied I Mai ^ Regist m RAceipt for MwoFw+dM+ ^ Insured Mail ~ 4. Restricted DelNery? (Extra Fee) ^ ti1N 7006 ~81~ 0~~0 7873 9781 PS Form 3811, February 2004 Domestic Retum Receipt C.1 -- r.' ~ ~ ; ~ ~ i"^ . r. ~ ~-r ~ n r} cm ~ r - - ~r ~ t ~~ ~ . ~~ ~r C" 3 2 .., +~ . .~~.- . WILLIAM FEIRRELL, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND CTY., PENNSYLVANIA v. No. 07-5180 POL CLEAN SERVICES, INC. and CIVIL ACTION -LAW NATIONAL FLOOR CARE, INC., JURY TRIAL DEMANDED Defendants. ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned as counsel on behalf of the Defendant, Pol Clean Services, Inc., with respect to the above-referenced matter. Respectfully submitted, MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN , DATE: ~ 23 li~rp BY: TIMOTH~' J. Mcl~l~~, ESQUIRE I.D. No. 52918 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3505 Attorney for Defendant Pol Clean Services, Inc. OSl479507.v1 ~ _. _., WILLIAM FEIRR.ELL, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND CTY., PENNSYLVANIA v. No. 07-5180 POL CLEAN SERVICES, INC. and CIVIL ACTION -LAW NATIONAL FLOOR CARE, INC., JURY TRIAL DEMANDED Defendants. CERTIFICATE OF SERVICE I, Cindy Sowers, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this ~ day of March, 2009, I served a copy of the foregoing Entry of Appeazance via First Class United States mail, postage prepaid, as follows: Daniel K. Deardorff, Esquire Manson, Deardorff, Williams, et al 10 E. High Street Cazlisle, PA 17013 National Floor Caze, Inc. 781 S. Midlothian Rd., Suite 109 Mundelein, IL 60060 lam' Cin y owers E G'~ a ~h C ^-^~ ,.-~ ' ~~ ~ 1 '.. ~ _ ' ~ ~, ~ ;y ': :;, :::~ s,.3 ~~. WILLIAM FEIRRELL, Plaintiff v. POL CLEAN SERVICES, INC. and NATIONAL FLOOR CARE, INC., Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND CTY., PENNSYLVANIA No. 07-5180 CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Kindly mark the above-referenced matter discontinued and ended. Respectfully submitted, DATE: BY: U' Daniel K. Deardorff, Esquire MARTSON, DEARDORFF, W LLIAMS, ET AL 10 E. High Street Carlisle, PA 17013 Attorney for Plaintiff i,_~;. , 20Q9 JC~~. ~ i i'~ri ~~: ! ~ a:~.