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Home My WebLink About07-53011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Douglas L. Young Plaintiff vs. Lawrence A. Rodgers Defendant _;- TO THE PROTHONOTARY: No. d7_ 53a~ Civil Action -Law ~..-. l.. l tai(, F1L.t~ l Please issue the writ of Summons in the above captioned case. ,, The address of the Plaintiff, Douglas L. Young is 44 Sandbank Road, Shippensburg, Pennsylvania. -~- The address of the Defendant, Lawrence A. Rodgers is 217 Brown Street, t.~~~t;a,,,~~,,o,~.. Pennsylvania 17702. Respectfully, ~. Date: H. Anthony Adams, Esquire Attorney for Plaintiff 49 West Orange Street, Suite 3 Shippensburg, PA 17257 Attomey ID No. 25502 (717) 532-3270 ~ 4 i.. .. ., i.~'1. ~:~. ~'. .. ~_ ~_ .c ` ~ ~ 1~.~ ~, ~,_ , h^+ '- ~_-' ~ o -~ N -~.~ ~~ ~Y ~~ l~ V f ~}~ n~ !` 1 ~7 ~. J ~ rsa V T y /"~ `. Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS LAWRENCE A. RODGERS 217 BROWN STREET WILLIAMSPORT, PA 17702 Defendant No 07-5301 CIVIL TERM In CivilAction-Law To LAWRENCE A. RODGERS, You are hereby notified that DOUGLAS L. YOUNG, the Plaintiff(s) 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. n (SEAL) Date SEPTEMBER 5, 2007 `By ~~ ~~ Deputy DOUGLAS L. YOUNG Plaintiff Vs. Court of Common Pleas Prothonotary Attorney: Name: H. ANTHONY ADAMS, ESQUIRE Address: 49 WEST ORANGE STREET, SUITE 3 SHIPPENSBURG, PA 17257 Attorney for: Plaintiff Telephone: 717-532-3270 Supreme Court ID No. 25502 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Douglas L. Young Plaintiff vs. Lawrence A. Rodgers Defendant TO THE PROTHONOTARY: No. 07-5301 Civil Action -Law PRAECIPE Please reissue the .writ of Summons in the above captioned case. The address of the Plaintiff, Douglas L. Young is 44 Sandbank Road, Shippensburg, Pennsylvania. The address of the Defendant, Lawrence A. Rodgers is 217 Brown Street, Pennsylvania 17702. Respectfully, Date: _~~~~ H. Anthony ams, Esquire Attorney for Plaintiff 49 West Orange Street, Suite 3 Shippensburg, PA 17257 Attorney ID No. 25502 (717) 532-3270 CJ ~ C c a `~ ~ '; ~ c~ ~ ~ ~~' .,,b 1= C,.T~~' ~ Q -..1 T C y~ J3 Q ~~ "~ ^"~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOUGLAS L. YOUNG, CIVIL DIVISION Plaintiff, NO. 07-5301 v. PRAECIPE FOR APPEARANCE LAWRENCE A. RODGERS, Defendant. (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, L.L.P. Firm #911 1017 Mumma Road, Suite 300 Lemoyne, PA 17043 (717) 901-5916 #15$91 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOUGLAS L. YOUNG, CIVIL DIVISION Plaintiff, v. NO. 07-5301 LAWRENCE A. RODGERS, (Jury Trial Demanded) Defendant. PRAECIPE FOR APPEARANCE TO: THE PROTHONOTARY Kindly enter the Appearance of the undersigned, Kevin D. Rauch, Esquire, of the law firm of Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P., on behalf of the Defendant, Lawrence A. Rodgers, in the above case. JURY TRIAL DEMANDED Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE ~ KEEL, L.L By: vin D. Rauch, E3~a1' ounsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR APPEARANCE has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 6T" day of November, 2007. H. Anthony Adams, Esquire 49 West Orange Street, Suite 3 Shippensburg, PA 17257 SUMMERS, McDONNELL, HUDOCK, GUTHRIE ~ KEEL, L.I. By: Kevin D. Rauch, Esquire Counsel for Defendant 1"- _~ - --4 ` "T;. j _i ~, '~., J ~..1` ~~ t~T A. c't'f _ • • ~~_ ~~ f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOUGLAS L. YOUNG, CIVIL DIVISION Plaintiff, NO. 07-5301 v. PRAECIPE FOR RULE LAWRENCE A. RODGERS, TO FILE COMPLAINT Defendant. (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, L.L.P. Firm #911 1017 Mumma Road, Suite 300 Lemoyne, PA 17043 (717) 901-5916 #15891 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOUGLAS L. YOUNG, Plaintiff, v. LAWRENCE A. RODGERS, Defendant. CIVIL DIVISION NO. 07-5301 (Jury Trial Demanded) PRAECIPE FOR RULE TO FILE COMPLAINT TO: The Prothonotary Kindly rule the Plaintiff, Douglas L. Young, to file a Complaint in Civil Action within twenty (20) days. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE ~ 9KEEL. L.I,~. By: vin D. Mauch, Esquire unsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR RULE TO FILE COMPLAINT has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this day of November 2007. H. Anthony Adams, Esquire 49 West Orange Street, Suite 3 Shippensburg, PA 17257 SUMMERS, McDONNELL, HUDOCK, GUTHRIE ~ SKEE„L,, L.Q.P. BY~ ~'l~'r'U in `B' IRauch,~squire nsel for Defendant r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOUGLAS L. YOUNG, CIVIL DIVISION Plaintiff, v. NO. 07-5301 LAWRENCE A. RODGERS, (Jury Trial Demanded) Defendant. RULE AND NOW, this __~' ~ day of IVpV~mbf~ 2007, upon consideration of Defendant's Praecipe for Rule to File a Complaint, a Rule is hereby granted upon Plaintiff to file a Complaint within twenty (20) days of service, or suffer judgment Non Pros. Rule issued this ~s~~ day of ~~p~,~~? 2007. Distribution to: Prothonotary Kevin D. Rauch, Esquire Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P. 1017 Mumma Road, Suite 300 Lemoyne, PA 17043 H. Anthony Adams, Esquire 49 West Orange Street, Suite 3 Shippensburg, PA 17257 ~ ' x -~., ~ ~i ; i ; ~ = ~ TTi ~ ~ ~lt".' ~~ ~ ~rt9 ~w~ ~ ~ =: .. {~ ~ r~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOUGLAS L. YOUNG, Plaintiff, v. LAWRENCE A. RODGERS, Defendant. CIVIL DIVISION NO. 07-5301 (Jury Trial Demanded) RULE AND NOW, this ~, day of ~~Ut~Pynb~l~_ 2007, upon consideration of Defendant's Praecipe for Rule to File a Complaint, a Rule is hereby granted upon Plaintiff to file a Complaint within twenty (20) days of service, or suffer judgment Non Pros. Rule issued this __ ~ day of ~~~~~_, 2007. Distribution to: Prothonotary Kevin D. Rauch, Esquire Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P. 1017 Mumma Road, Suite 300 Lemoyne, PA 17043 H. Anthony Adams, Esquire 49 West Orange Street, Suite 3 Shippensburg, PA 17257 ~~'~~ COI~'~ r~~~i~ ~:`CORV ~r~ Testimony whereof, ~h~e~anto set mY ~~ 8nd til® .Se~ Of said ~l ~~r ~ ry ~~~. ~ 1 Ot8ry IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Douglas L. Young, : No. 07-5301 Plaintiff . vs. :Civil Action Lawrence A. Rodgers Defendant COMPLAINT Now comes the Plaintiff, Douglas L. Young, by and through his attorney, H. Anthony Adams and sets forth the following: 1. Plaintiff is Douglas L. Young, an adult individual who resides at 44 Sandbank Road, Cumberland County, Shippensburg, Pennsylvania, 17257. 2. Defendant is Lawrence A. Rodgers, an adult individual, who resides at 217 Brown Street, Williamsport, Pennsylvania, 17702. 3. On or about September 9, 2005, the Plaintiff involved in an automobile accident. 4. The accident took place at the intersection of Pennsylvania Route 174 and the entrance ramp to Interstate 81 in Southampton Township, Cumberland County, Pennsylvania. 5. At that time, Plaintiff was traveling in a westerly direction on Pennsylvania Route 174 when a vehicle owned by Lawrence Rodgers failed to yield the right of way. While making a left turn onto the access ramp of Interstate 81. 6. It is believed that the vehicle owned by Lawrence Rodgers was being driven by his son, Joseph A. Rodgers. 7. It is believed and therefore averred that the automobile of Lawrence Rodgers was being driven by his son based upon a statement made by Joseph A. Rodger on September 11, 2005. It is not known, without the aid of discovery, if this fact is correct since the driver of the Rodgers' car fled from the area in the car after the collision. 8. If the car owned by Lawrence Rodgers was in fact being driven by him, he was negligent in failing to operate his car in a reasonable manner with due regard for the safety and welfare of other motorist including, of the Pennsylvania Vehicle Code Section 3322. 9. The act of the Defendant in failing to yield the right of way to the Plaintiff was the direct and proximate case of injury to Plaintiff. Count II 10. It is believed and therefore averred that in exchange for the entry of Joseph A. Rodgers into the Cumberland County ARD program, an agreement was made that all restitution would be paid for the incident related herein. 11. Plaintiff asserts that he is the sole beneficiary of that agreement and that the agreement was made to obtain Plaintiff's acquiescence in the entry of Joseph A. Rodgers into the program. Count III 12. Defendant, Lawrence A. Rodgers was negligent in lending his car to Joseph A. Rodgers. 13. Defendant, Lawrence A. Rodgers, in entrusting his vehicle to his son, Joseph A. Rodgers; to the ability of Joseph A. Rodgers to operate the vehicle and to obey the laws of the Commonwealth, did so without due regard to the manner in which the vehicle would be used. 14. If he was the driver, Joseph A. Rodgers drove the vehicle in a manner that was negligent and the proximate cause of the injuries of Plaintiff. Damages 15. As a direct and proximate result of the actions of the Defendant, the Plaintiff suffered an injury to his legs, contusion to his knee and thigh, and has an area on his right knee which is numb and has altered sensation. 16. As a result of the actions of the Defendant the Plaintiff has incurred medical expenses, lost wages, property damage, pain and suffering. WHEREFORE, Plaintiff prays your Honorable Court enter judgment in his favor and against Defendant in an amount n excess of $25,000.00. Respectfully submitted, H. Anthony Adams, Esquire Attorney for Plaintiff SUPREME COURT ID NO. 25502 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717}-532-3270 VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities. D te: 1a. 3-c~ 7 ~ ~. a Douglas .Young n.a (~) c'::-s ~i --j (~1 ~~ ~ -°•,~r ~ ~t.) `°7 :: .~.~ ~, =t _, b.L,~ .. SHERIFF'S .RETURN - OUT OF COUNTY a~'"+ CASE N0: 2007-05301 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND YOUNG DOUGLAS L VS RODGERS LAWRENCE A R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: RODGERS LAWRENCE A but was unable to locate Him deputized the sheriff of LYCOMING serve the within WRIT OF SUMMONS County, Pennsylvania, to On November 19th 2007 this office was in receipt of the attached return from LYCOMING ~~~ Sheriff's Costs: Docketing Out of County Surcharge Dep Lycoming Co Postage So atx~iers ; 18.00 ~~ 9.00 10.00 '~ R. 25.00 f°~ e 1.16 63.16 / ~ 2~/ l~~ 11/19/2007 H ANTHONY ADAMS Sworn and subscribe to before me this day of in his bailiwick. He therefore omas mine ff of Cumberland County A.D. ,,r-, In The Court of Common Pleas of Cumberland County, Pennsylvania Douglas L. Young VS. Lawr~cA A. Rodgers No. 07-5301 civil Now, sQpt~nbAr 25, 2007 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Lycaning deputation being made at the request and risk of the Plaintiff. County to execute this Writ, this Sheriff of Cumberland County, PA Please mail return of service to Cumberland County Sheriff. Thank you. Affidavit of Service NOW, NOVEMBER 1, , 2~ 07 , at 3:45 O'C10Ck A. M. served the Wlthln WRIT OF SUMMONS upon THE WITHIN NAMED DEFENDANT, LAWRENCE A. RODGERS, at 2040 WEST MOUNTAIN AVENUE, SOUTH WILLIAMSPORT, PA., by handing to ANN RODGERS, WIFE, a TRUE AND ATTESTED Copy Of the Original WRIT OF SUMMONS and made known to HER the contents thereof. So answers, Sworn and subscribed before me this 13 day Of November , 20 07 3" "'yf ('L~i {'1'~ wlii't .. _.:11# ~ raw u... ~^ - ~C:µ~, R`^~`'`"`~Charles T. Brewer ~, Sheriff of LYCOMING Coun A BY: COS'j'S Timothy B. Ne son,Deputy SERVICE $ 1 s . 00 MILEAGE ~ 4.50 AFFIDAVIT 2.50 $ 25.00 PAID 11/2/07 .,... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOUGLAS L. YOUNG, CIVIL DIVISION Plaintiff, NO. 07-5301 v. STIPULATION LAWRENCE A. RODGERS, Defendant. (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, L.L.P. Firm #911 1017 Mumma Road, Suite 300 Lemoyne, PA 17043 (717) 901-5916 #15891 r ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOUGLAS L. YOUNG, Plaintiff, CIVIL DIVISION v. LAWRENCE A. RODGERS, Defendant. NO. 07-5301 (Jury Trial Demanded) STIPULATION AND NOW, comes the Defendant, Lawrence Rodgers, by and through his attorneys, Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P., and Kevin D. Rauch, Esquire, and files the following Stipulation: The undersigned parties hereby stipulate and agree that Count II of the Plaintiffs Complaint is dismissed from the above-captioned matter with prejudice. By: ` _ H. An am , Counsel for Plaintiff 49 West Orange Street, Suite 3 Shippensburg, PA 17257 SUMMERS, McDONNELL, HUDOCK, GUTHRIE 8~ SKEEL, L.L.P. By: Kevin D. Rauch, Esquire Counsel for Defendant 1017 Mumma Road, Suite 300 Lemoyne, PA 17043 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing STIPULATION has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this,3c~-R~. day of , 2008. H. Anthony Adams, Esquire 49 West Orange Street, Suite 3 Shippensburg, PA 17257 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. By: \ Kevin D. Rauch, Esquire Counsel for Defendant m `n -x.~ L.. fTIFFi A 1 's •~` ~ :~ ` ~ . ~~ i ~~ { rt " ~C ..v ° 1~ ~ ~ . - 1 S II IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOUGLAS L. YOUNG, Plaintiff, v. NO. 07-5301 CIVIL DIVISION ANSWER AND NEW MATTER LAWRENCE A. RODGERS, Defendant. TO: Plaintiff You are hereby notified to file a written response to the enclosed Answer and New Matter within twenty (20) days from service hereof or a judgment may be entered against you. Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P. (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, L.L.P. Firm #911 1017 Mumma Road, Suite 300 Lemoyne, PA 17043 (717) 901-5916 #15891 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOUGLAS L. YOUNG, CIVIL DIVISION Plaintiff, v. NO. 07-5301 LAWRENCE A. RODGERS, (Jury Trial Demanded) Defendant. ANSWER AND NEW MATTER AND NOW, comes the Defendant, Lawrence A. Rodgers, by and through his counsel, Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P., and Kevin D. Rauch, Esquire, and files the following Answer and New Matter and in support thereof avers as follows: 1. After reasonable investigation, the Defendant has insufficient information as to the truth or falsity of said averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 2. Denied. To the contrary, the Defendant resides at 2040 West Mountain Avenue, South Williamsport, Pennsylvania 17702. 3. After reasonable investigation, the Defendant has insufficient information as to the truth or falsity of said averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 4. After reasonable investigation, the Defendant has insufficient information as to the truth or falsity of said averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 5. After reasonable investigation, the Defendant has insufficient information as to the truth or falsity of said averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 6. Admitted. 7. Admitted in part, denied in part. It is admitted that the Defendant's vehicle was being driven by the Defendant's son, Joseph A. Rodgers. After reasonable investigation, the Defendant has insufficient information as to the truth or falsity of the remaining averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 8. Denied. It is specifically denied that Lawrence Rodgers was operating his motor vehicle when the instant accident occurred. The remainder of paragraph 8 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to PA Rule of Civil Procedure 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 9. Paragraph 9 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. COUNT II 10. Count II of the Plaintiffs Complaint has been dismissed with prejudice by Stipulation filed on January 31, 2008. 11. Count II of the Plaintiffs Complaint has been dismissed with prejudice by Stipulation filed on January 31, 2008. COUNT III 12. Paragraph 12 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 13. Denied. It is specifically denied that Defendant, Lawrence A. Rodgers, entrusted his vehicle to his son without due regard to the manner in which the vehicle would be used. The remainder of Paragraph 13 states legal conclusions to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 14. Paragraph 14 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 15. Paragraph 15 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 16. Paragraph 16 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant, Lawrence A. Rodgers, respectfully requests this Honorable Court enter judgment in his favor and against the Plaintiff with costs and prejudice imposed. NEW MATTER 17. The motor vehicle accident in controversy is subject to the Pennsylvania Motor Vehicle Financial Responsibility Law and this Defendant asserts, as affirmative defenses, all rights, privileges and/or immunities accruing pursuant to said statute. 18. Some and/or all of Plaintiffs claims for damages are items of economic detriment which are or could be compensable pursuant to either the Pennsylvania Motor Vehicle Financial Responsibility Law and/or other collateral sources and same may not be duplicated in the present lawsuit. 19. To the extent that the Plaintiff has selected the limited tort option or is deemed to have selected the limited tort option then this Defendant sets forth the relevant provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law as a bar to the Plaintiffs ability to recover non-economic damages. 20. This Defendant pleads any and all applicable statutes of limitation under Pennsylvania Law as a complete or partial bar to any recovery by Plaintiff in this action. WHEREFORE, Defendant, Lawrence A. Rodgers, respectfully requests this Honorable Court enter judgment in his favor and against the Plaintiff with costs and prejudice imposed. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. Kevin D. Rauch, Esquire Counsel for Defendant VERIFICATION Defendant verifies that he is the Defendant in the foregoing action; that the foregoing ANSWER AND NEW MATTER is based upon information which he has furnished to his counsel and information which has been gathered by his counsel in the preparation of the lawsuit. The language of the ANSWER AND NEW MATTER is that of counsel and not of the Defendant. Defendant has read the ANSWER AND NEW MATTER and to the extent that the ANSWER AND NEW MATTER is based upon information which he has given to his counsel, it is true and correct to the best of his knowledge, information and belief. To the extent that the content of the ANSWER AND NEW MATTER is that of counsel, he has relied upon counsel in making this Affidavit. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: !:Z-2y-OT ~,r-2~~- ~. ~'~c~l- Lawrence A. Rodgers #15891 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing ANSWER AND NEW MATTER has been ImGailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this "~ `~" day of , 2008. H. Anthony Adams, Esquire 49 West Orange Street, Suite 3 Shippensburg, PA 17257 SUMMERS, McDONNELL, HUDOCK, GUTHRIE ~ SKEEL, L.L.P. Kevin D. Rauch, Esquire Counsel for Defendant c7 rv c~ ~ ~ "r ~. A .,~ ~ ~ ~ ~ ~~ F ~ .,, cst °~ r._ N ,~ rC .~ ~ tea? C.,:; :~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Douglas L. Young Plaintiff vs. Lawrence A. Rodgers Defendant TO THE PROTHONOTARY: No. 07-5301 Civil Action -Law PRAECIPE Please mark the above captioned matter settled and the action discontinued. Respectfully, Date: ~ ~~ ~ --- ~ H. Anthony Adams, Esquire Attorney for Plaintiff 49 West Orange Street, Suite 3 Shippensburg, PA 17257 Attorney ID No. 25502 (717) 532-3270 ( - CJ "i1 _ ~^ y ~:.. l(j ++- r~ of 'ii ~.~-. ~.~ _~> ~-i~1