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Home My WebLink About07-6209Archer & Archer, P.C. By: Thomas A. Archer, Esquire 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110-5056 717.233.8676 LORIANN SADLER and DENIS SADLER Plaintiffs, V. MICHELLE ULRICH and AMERICAN EAGLE OUTFITTERS, INC. Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. D7- J0&09 Civi l Term CIVIL ACTION JURY TRIAL DEMANDED NOTICE TO DEFEND 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 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 OR KNOW A LAWYER, THEN YOU SHOULD GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP: Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Dated: October 18, 2007 By: Thomas A. Archer, Esquire PA Atty. ID # 73293 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110 (717) 233-8676 Attorney for Plaintiffs Archer & Archer, P.C. By: Thomas A. Archer, Esquire 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110-5056 717.233.8676 LORIANN SADLER IN THE COURT OF COMMON PLEAS and DENIS SADLER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs, V. NO. MICHELLE ULRICH CIVIL ACTION and AMERICAN EAGLE OUTFITTERS, INC. Defendants. JURY TRIAL DEMANDED NOTICE TO DEFEND 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 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 OR KNOW A LAWYER, THEN YOU SHOULD GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP: Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Dated: October 18, 2007 By: Thomas A. Archer, Esquire PA Atty. ID # 73293 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110 (717) 233-8676 Attorney for Plaintiffs Archer & Archer, P.C. By: Thomas A. Archer, Esquire 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110-5056 717.233.8676 LORIANN SADLER IN THE COURT OF COMMON PLEAS and DENIS SADLER CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs, V. NO. 0-7- MICHELLE ?'/ M. ULLRICH CIVIL ACTION and AMERICAN EAGLE OUTFITTERS, INC. Defendants. JURY TRIAL DEMANDED COMPLAINT Plaintiffs, LoriAnn Sadler and Denis Sadler, by way of Complaint against Defendants, Michelle Ulrich and American Eagle Outfitters, Inc., state: COUNTI 1. Plaintiff, LoriAnn Sadler, is an adult individual residing at 3219 Sunnyside Avenue, Harrisburg, County of Dauphin, Commonwealth of Pennsylvania. 2. Plaintiff, Denis Sadler, is an adult individual residing at 3219 Sunnyside Avenue, Harrisburg, County of Dauphin, Commonwealth of Pennsylvania. 3. Defendant, Michelle M. Ullrich, is an adult individual who, through information and belief, resides at 7314 Whipple Street, Pittsburgh, County of Alleghany, Commonwealth of Pennsylvania. 1 4. Defendant, American Eagle Outfitters, Inc. is, through information and belief, a Pennsylvania business corporation maintaining a principal place of business located at 77 Hot Metal Street, Pittsburgh, County of Alleghany, Commonwealth of Pennsylvania. 5. At all material times herein, Defendant, American Eagle Outfitters, Inc., was authorized to do business in the Commonwealth of Pennsylvania and regularly transacted business within the Commonwealth of Pennsylvania and County of Cumberland. 6. At all material times herein, Defendant, Michelle M. Ullrich, was an employee, servant and/or agent of Defendant, American Eagle Outfitters, Inc., acting within her scope of employment, servitude and/or agency on behalf of Defendant, American Eagle Outfitters, Inc. 7. At all material times herein, Defendant, American Eagle Outfitters, Inc., acted or failed to act through its agent, servant and/or employee Michelle M. Ullrich, who was acting within her scope of employment, servitude and/or agency on behalf of Defendant, American Eagle Outfitters, Inc. 8. At all material times herein, Defendant, American Eagle Outfitters, Inc., owned, controlled, maintained, leased and/or possessed a vehicle being operated by Defendant, Michelle M. Ullrich, with the consent and permission of Defendant, American Eagle Outfitters, Inc. 9. On or about April 11, 2006, Plaintiff LoriAnn Sadler was lawfully operating a motor vehicle faced in a southerly direction and stopped at a stop sign located at Central Boulevard and Trindle Road, intending to turn 2 right toward Interstate 83 in Hampden Township, County of Cumberland, Commonwealth of Pennsylvania. 10. At the aforesaid time and place, Defendant, Michelle M. Ullrich, so negligently, carelessly, and recklessly operated the vehicle owned, controlled, maintained, leased and/or possessed by Defendant, American Eagle Outfitters, Inc., by colliding into the rear of LoriAnn Sadler's vehicle, causing a collision. 11. The negligence, carelessness and recklessness of the Defendants, Michelle M. Ullrich and American Eagle Outfitters, Inc., consisted of the following: a. Operating the vehicle at an excessive rate of speed under the circumstances in violation of 75 P.S. §3361 and other applicable laws; b. Failing to have the motor vehicle under proper and adequate control; c. Failing to exercise due care and caution under the circumstances; d. Failing to keep a proper look out for other vehicles on the road; e. Failing to act with due regard to the position of the vehicle operated by the Plaintiff, f. Failing to keep an assumed clear distance between Defendant's vehicle and that of the Plaintiff. g. Failing to observe and obey traffic signs and signals in violation of 75 P. S. §3111 and other applicable laws; h. Careless and reckless operation of the motor vehicle; and i. Negligence per se. 3 12. The negligence, carelessness and recklessness of the Defendant, American Eagle Outfitters, Inc., consisted of the following: a. Failing to properly train and/or instruct Defendant, Michelle M. Ullrich, in the safe operation and usage of its motor vehicle; b. Negligently entrusting its motor vehicle to Defendant, Michelle M. Ullrich, whom it knew or should have known would operate its vehicle in an unsafe manner; and c. Failing to properly and safely maintain Defendant's vehicle. 13. Solely as a direct and proximate result of the negligence, carelessness and recklessness of the Defendants aforesaid, Plaintiff LoriAnn Sadler was caused to sustain severe injuries to her person, bones, joints, muscles, tendons, ligaments, blood vessels, nervous systems and soft tissues throughout her body; was caused to suffer neck pain, headaches, lumbar pain, pain radiating down her left leg to her knee, hip pain as well as lumbar and gluteal spasms; was caused to suffer injury to her pelvis, lumbar disc herniation at L2-L3, left tensor fascia latae syndrome, paravertebral muscle spam, lumbosacral sprain and strain as well as exacerbation of lumbar degeneration at L4-L5; all of which said injuries have in the past and will in the future cause LoriAnn Sadler great pain and suffering and are permanent in nature. 14. Solely as a direct and proximate result of the negligence, carelessness and recklessness of the Defendants aforesaid, LoriAnn Sadler has in the past and will in the future undergo medical and surgical treatment, for which 4 LoriAnn Sadler has in the past and will in the future be obligated to expend large and various sums of money in an attempt to treat and cure her injuries which have or may exceed the sum recoverable under the limits in 75 P. S. §1711. 15. Solely and as a direct and proximate result of the negligence, carelessness and recklessness of the Defendants aforesaid, LoriAnn Sadler suffered and will continue to suffer emotional distress and mental anguish, inconvenience and humiliation and loss of life's pleasures, including but not necessarily limited to the inability to fully care for her young granddaughter for whom she had previously provided significant care as well as the inability to maintain her household in a manner to which she and Plaintiff Denis Sadler had become accustomed. WHEREFORE, Plaintiff, LoriAnn Sadler, demands judgment in her favor against Defendant, Michelle M. Ullrich, jointly and/or individually for compensatory and punitive damages, together with attorney's fees, costs of suit and other relief to which she may be entitled as a matter of law. COUNT II 16. Plaintiff herein incorporates paragraphs 1 - 15 of the Complaint as set forth at length herein. 17. The negligence, carelessness and recklessness of the Defendant, American Eagle Outfitters, Inc., as stated herein has caused the Plaintiff past, current and future damages as stated herein. 5 WHEREFORE, Plaintiff, LoriAnn Sadler, demands judgment in her favor against Defendant, American Eagle Outfitters, jointly and/or individually, for compensatory and punitive damages, together with attorney's fees, costs of suit and other relief to which she may be entitled by law. COUNT III 18. Plaintiff herein incorporates paragraphs 1 - 17 of the Complaint as set forth at length herein. 19. As a result of the Defendants' actions aforesaid, Plaintiff, Denis Sadler has suffered a loss of consortium, society and comfort from his wife, LoriAnn Sadler and he will continue to suffer a similar loss in the future. 20. As a result of the Defendants' actions aforesaid, Plaintiff Denis Sadler has been compelled, in order to affect a cure for his wife's injuries, to expend money for medicine and medical attention and/or will be required to expend money for the same purposes in the future, to his great detriment and loss. 21. As a result of the Defendants actions aforesaid, Plaintiff Denis Sadler, has been required to take on many of the household and care giving duties previously maintained by his wife, LoriAnn Sadler. WHEREFORE, Plaintiff, Denis Sadler, demands judgment in his favor against Defendants, Michelle M. Ullrich and American Eagle Outfitters, Inc., jointly and/or individually, for compensatory and punitive damages, together with attorney's fees, costs of suit and other relief to which he may be entitled by law. 6 Respectfully Submitted, Archer & Archer, P.C. Dated: October 17, 2007 By: fa Thomas A. Archer, Esquire PA Atty. ID # 73293 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110 (717) 233-8676 Attorney for Plaintiffs 7 VERIFICATION I, LoriAnn Sadler, hereby verify that the statements made in the foregoing Complaint 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. 34904, relating to unworn falsification to authorities. Date: q 1Z,42,07 VERIFICATION I, Denis Sadler., hereby verify that the statements made in the foregoing Complaint 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. 34904, relating to unworn falsification to authorities. Date: ?-e;v "(97 I N, Denis adler cl.;z -n * O 4:t C --? r? 10 O THOMAS, THOMAS & HAFER, LLP 305 NORTH FRONT STREET P.O. BOX 999 HARRISBURG, PA 17108 Todd B. Narvol, Esquire Attorney ID #42136 717-237-7133 LORIANN SADLER and DENIS SADLER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs, V. NO. 07-6209 MICHELLE ULRICH and AMERICAN CIVIL ACTION - LAW EAGLE OUTFITTERS, INC., Defendants. : JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Todd B. Narvol, Esquire and Thomas, Thomas & Hafer LLP, 305 North Front Street, 6th Floor, Post Office Box 999, Harrisburg, PA 17108, on behalf of Defendants Michelle Ulrich and American Eagle Outfitters, Inc. We are authorized to accept service of all documents in this matter. Respectfully submitted, Date: 1 ZN01 Thomas, Thomas & Hafer, LLP By: ) ?-- okl: I- - ? Tddd B. Narvol Attorney ID #42136 Attorneys for Defendants CERTIFICATE OF SERVICE I, Todd B. Narvol, Esquire, do hereby certify that on this day I served a true and correct copy of the foregoing PRAECIPE FOR ENTRY OF APPEARANCE upon the following, by enclosing a true and correct copy in an envelope addressed as follows, postage prepaid: Thomas A. Archer, Esquire Archer & Archer, P.C. 2515 North Front Street P. O. Box 5056 Harrisburg, PA 17110-5056 Respectfully submitted, Thomas, Thomas & Hafer, LLP 77 P Date: By: Todd B. Narvol Attorney ID #42136 Attorneys for Defendants (-:? C_`: SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2007-06209 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SADLER LORIANN ET AL VS ULRICH MICHELLE ET AL 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: but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of ALLEGHENY serve the within COMPLAINT & NOTICE County, Pennsylvania, to On December 5th , 2007 , this office was in receipt of the attached return from ALLEGHENY Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 41 Postage 1.89 1 - .00 llp1 V/ 38.89 12/05/2007 ? ARCHER & ARCHER Sworn and subscribe to before me this day of bfnas Kline ff of Cumberland County A. D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2007-06209 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SADLER LORIANN ET AL VS ULRICH MICHELLE ET AL R. Thomas Kline duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: AMERICAN EAGLE OUTFITTERS INC Sheriff or Deputy Sheriff who being but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of ALLEGHENY County, Pennsylvania, to serve the within COMPLAINT & NOTICE On December 5th , 2007 , this office was in receipt of the attached return from ALLEGHENY 11--il"/ Sheriff's Costs: So Docketing 6.00 Out of County .00 Surcharge 10.00 i .00 S,h .00 13? 16.00 ???!!Y 12/05/2007 ARCHER & ARCHER Sworn and subscribe to before me this day of R9mas Kline ff of Cumberland County A. D. r in The Court of Common Pleas of Cumberland County, Pennsylvania Loriann Sadler et al VS. Michelle Ulrich et al SERVE: Michelle Ulrich Now, October 31, 2007 5 1, SHERIFF OF CUMBERLAND COUNTY, PA, do Sheriff of Cumberland County, PA Please mail return of service to Cumberland County Sheriff. Thank you. Affidavit of Service Now, V, 916- , 206-7, at /!y? o'clock t4 M. served the within 0 C to w- upon_ AA iG L e- )Ce (J I <` tLk at 7 31 L( Val ?, I? t° 5-- hereby deputize the Sheriff of Allegheny No. 07=6209 civil County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. by handing to a and made known to 410 1 A (,r ?c_L, copy of the original c, t? c c c uc ?; r. So answers, \ the contents thereof. V. Gq (!ei A?ritf of A1)e9lenY County, PA Sworn and subscribed before me this day of , 20 COSTS SERVICE MILEAGE _ AFFIDAVIT $ Ih The Court of Common Pleas of Cumberland County, Pennsylvania Loriann Sadler et al VS. ?. Michelle Ulrich et al SERVE: American Eagle Outfitters Inc No. 07=6209 civil Now, October 31, 2007 I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Allegheny deputation being made at the request and risk of the Plaintiff. County to execute this Writ, this .15- Q Sheriff of Cumberland County, PA Please mail return of service to Cumberland County Sheriff. Thank you. Affidavit of Service Now, 11-CI-61 , 20_ OT, at 0 o'clock _ M. served the within W upon hen f,460 E)9-64f OVT fi.&ld ? U L at -7 -7 MT Al CM ST by handing to Cr???'l-(.?1 a and made known to Sworn and subscribed before me this day of , 20 copy of the original So answers, the contents thereof. Sheriff of County, PA COSTS SERVICE _ MILEAGE AFFIDAVIT Direction sheet for Sherrif Page 1 of 1 William P ullen ALLEGHENY COUNTY SHERIFF'S DEPARTMENT / " ? -7 sep'fI A. Wzo ACti eriff 436 GRANT S lyly Acting Chief Deputy PITTSBURGH, PA 15219-2496 ' PHONE (412) 350-4700 FAX (412) 350-6388 PLAINTIFF : Loriann Sadler h DEFT Ministrict7 GARNISHEDISTRICT ADDRESS :7314 Whipple Street Pittsburgh, PA 15218 4 MUNICIPALITY/CITY WARD: Swissvale Boro / Originating County: Cumberland ATTY Name/ADDRESS : ATTY PHONE : TYPE OF SERVICE : CASE # : 07-6209 EXPIRES : 11/30/2007 11:59:59 PM E SUMMONS/PRAECIPE C SEIZURE OR POSSESSION r NOTICE AND COMPLAINT r REVIVAL OR SCI FA r" INTERROGATORIES r EXECUTION - LEVY OR GARNISHEE ( OTHER (" Personal r'' Person In charge r Deputize T Mail C' Posted (. Other r Seize & Stored T First Class Mail O' Publication Service Address Direction : Now I, the SHERIFF OF ALLEGHENY COUNTY, PA do hereby deputize the Sheriff of _ County to execute this Writ and make return thereof according to law "--Is the Sheriff instructed to take manual possession of the property? If "yes" bond in the amount of S must be posted prior to levy." Scizc? trey adverts and sell all the personal to of the defendant on the premi.es located atMAKE MODEL MOTOR NUMBER SERIAL NUMBER LICENSE NUMBER SHERIFF's OFFICE USE ONLY I hereby CERTIFY and RETURN that on the day of 20 at_ o'clock, AM/PM. Address Above/Address Below, County of Allegheny, Pennsylvania I have served in the manner Described below: [ ] Defendant(s) personally served [ ] Adult in charge of Defendant's residence who refused to give name or relationship [ ] Adult family member with whom said Defendant(s) reside(s). Name & Relationship [ ] Manager/Other person authorized to accept deliveries of U.S Mail [ ] Agent or person in charge of Defendant(s) office or usual place of business. [ ] Other [ ] Property Posted Defendant not found because:[ ] Moved[ ] Unknown [ ] No Answer[ ] Vacant [ ] Other { ] Certified Mail [ ] Receipt, [ ] Envelope Rstnrned? [ ] Ncidwr Receil.t or envelope; writ expired [ ] Regular Mail Why: You are hereby notified that on , 20_, levy was made in the case of Possession/Sale has been set for 20 at o'clock YOU MUST CALL DEPUTY ON THE MORNING OF SALE/POSSESSION BETWEEN 8:30-9:30 A.M. ATTEMPTS / ! Additional Costs Due $, This is placed On Writ when returned to Prothonotary.Please check before Satisfying Case http://prothonotary.county.allegheny.pa.us/AlleghenylsheriffcasesIDirectionSheet. asp? WritID=COMPL&... 11/5/2007 Direction sheet for Sherrif William P Mullen ALLEGHENY COUNTY SHERIFF'S DEPARTMENT Joseph A.Rizzo Acting .s, 'Sheriff 436 GRANT STREET Acting Chief Deputy y ?1, PITTSBURGH, PA 15219-2496 V ('?? l PHONE (412) 350-4700 01 FAX (412) 350-6388 PLAINTIFF : Loriann Sadler DEFT : American Eagle Outfitters, Inc. GARNISHEE : DISTRICT : District I I ADDRESS : 77 Hot Metal Street Pittsburgh, PA 15203 ?? ?l l!1 MUNICIPALITY/CITY WARD: Pittsburgh 6 Originating County : Cumberland ATTY Name/ADDRESS : ATTY PHONE : TYPE OF SERVICE : CASE # : 07-6209 EXPIRES : 11130/2007 11:59:59 PM E SUMMONS/PRAECIPE • SEIZURE OR POSSESSION r NOTICE AND COMPLAINT REVIVAL OR SCI FA r INTERROGATORIES (" EXECUTION - LEVY OR GARNISHEE r OTHER r Personal G Person In charge C Deputize ('` Mail C Posted C Other r Seize & Stored (- First Class Mail C Publication Service Address Direction : Now [,the SHERIFF OF ALLEGHENY COUNTY, PA do hereby deputize the Sheriff of _ County to execute this Writ and make return thereof according to law "-Is the Sheriff instructed to take manual possession of the property? If "yes" bond in the amount of $ must be posted prior to levy." Seize lew advertise and sell all the uersonalyrooerty of the defendant on the premises located at MAKE MODEL MOTORNUMBER SERIAL NUMBER LICENSENUMBER SHERIFF'S F ICE USE ONLY I hereby CERTIFY and RETURN that on the day of_ 20n at_ o'clock,(DWM. Address Above/Address Below, County of Allegheny, Pennsylvania ?'1 1ti t have served in the manner Described below: [ j Defendant(s) personally served [ ] Adult in charge of Defendant's residence who refused to give name or relationship [ ] Adult family member with whom said Defendant(s) reside(s). Name & Relationship [ ] Manager/Other person authorized to accept deliveries of U.S Mail rA Agent or person in charge of Defenn?d?afl n?t(ss/)yoffifce?.oI /'fer usual place of business. [ ] Other [ ] Property Posted {/1/? y ft-" Defendant not found because:[ ] Moved [ ] Unknown [ ) No Answer [ ) Vacant [ ] Other [ ] Certified Mail [ ] Receipt_ [ J Envelope Returned- [ ] Neither Receipt or envelope; writ expired [ J Regular Mail Why: You are hereby notified that on , 20_, levy was made in the case of Possession/Sale has been set for 20 at o'clock YOU MUST CALL DEPUTY ON THE MORNING OF SALE/POSSESSION BETWEEN 8:30-9:30 A.M. ATTEMPTS Additional Costs Due $, This is placed On Writ when returned to Prothonotary.Please check before Satisfying Case ?t Page 1 of I /I-7.67 http://prothonotary.county.allegheny.pa.us/AlleghenylsheriffcasesIDirectionSheet.asp?WritID=COMPL&... 11/5/2007 Archer & Archer, P.C. By: Thomas A. Archer, Esquire 2515 North Front Street P.O. Box 5056 Harrisburg, PA 17110-5056 717.233.8676 LORIANN SADLER IN THE COURT OF COMMON PLEAS and DENIS SADLER CUMBERLAND COUNTY, Plaintiffs, PENNSYLVANIA V. NO. G OU MICHELLE M. ULLRICH CIVIL ACTION and AMERICAN EAGLE OUTFITTERS, INC. JURY TRIAL DEMANDED Defendants. PRAECIPE TO SETTLE, DISCONTINUE AND END TO: PROTHONOTARY Please mark the above case as settled, discontinued and ended with prejudice. ARCHER & ARCHER, P.C. Date: May 22, 2008 BY: _ Thomas A. Archer, Esquire 2515 North Front Street, PO Box 5056 Harrisburg, PA 17110 (717) 233-8676 Attorney for Plaintiffs .? s . , CERTIFICATE OF SERVICE I, Thomas A. Archer, Esquire, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the person(s) stated below, addressed as follows via U.S. First Class Mail: Todd Narvol, Esquire Thomas, Thomas & Hafer, LLP 305 North Front Street PO Box 999 Harrisburg, PA 17101 Date: May 22, 2008 Thomas A. Archer, Esquire Attorney I.D. # 73293 Attorney for Plaintiff c_.a G.7 Y