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HomeMy WebLinkAbout03-5463PENNY A. CRAMER, ET. AL. · IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA DONALD WISE, JR. : NO. 5463 CIVIL 2003 : CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 24th day of September, 2004, with agreement of counsel, a pretrial conference in this case listed for the civil trial term beginning on October 25, 2004 has been rescheduled from the pretrial conference date of Oclober 6, 2004 due to a scheduling conflict with counsel for the Defendant. The pretrial conference shall take place before the undersigned judge on Monday, October, 11, 2004 at 11 ::30 A.M. Edgar B. Bayley, Judge cc: //~chard A. Sadlock, Esq. ~l~onald R. Doter, Esq. F~LED~2FF~E OF THE t00~ SEP 2'1 Pi'l pF...J, INS'YLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNY A. CRAMER, and KENNETH E. CRAMER, her husband Plaintiffs DONALD WISE, JR., Defendant CIVIL ACTION - LAW NO. - .Ct/t0 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 judgrnent may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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 REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 .AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se persentan mils adelante en las siguientes piginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despu6s de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a , las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra mclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mils aviso adicional. Used puede perder dinero o propiedad u otros derechos irnportantes para used. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 266299.1~.AS\SSA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNY A. CRAMER, and KENNETH E. CRAMER, her husband Plaintiffs DONALD WISE, JR., CIVIL ACTION - LAW _ Defendant JURY TRIAL DEMANDED COMPLAINT Plaintiffs Penny A. Cramer and Kenneth E. Cramer are adult individuals and citizens of the Commonwealth of Pennsylvania, who reside at 263 Neil Road, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant Donald Wise, Jr. is an adult individual and citizen of the Commonwealth of Pennsylvania, who currently resides at 1017 Celeste Drive, Shippensburg, Franklin County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on or about July 16, 2002 at approximately 4:40 p.m., near the intersection of King Street (SR 11) and Penn Street, Shippensburg, Cumberland County, Pennsylvania. 4. At that time and place, Plaintiff Penny A. Cramer was operating a 2002 Ford Escape in a northerly direction on King Street. Her 2 year old grandson was a restrained rear seat passenger. 266299. I\RAS\SSA 5. At that time and place, Plaintiff Penny A. Cramer stopped on King Street behind three or four other vehicles that had already stopped for a red traffic signal. 6. At that time and place, Defendant Donald Wise, Jr. was operating his Ford Ranger, and was traveling in a northerly direction directly behind Plaintiff Penny A. Cramer's vehicle. 7. At that same time and place, Defendant Donald Wise, Jr., operated his vehicle at a high rate of speed without paying attention to traffic, failed to observe that Plaintiff Penny A. Cramer had stopped the vehicle she was operating behind the other stopped traffic due to the red traffic signal; failed to stop his vehicle, and suddenly and without warning, violently slammed into the right rear of Plaintiff Penny A. Cramer's vehicle. 8. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff Penny A. Cramer are a direct and proximate result of the negligent, careless, wanton and reckless manner in which Defendant Donald Wise, Jr. operated his motor vehicle as follows: (a) (b) (c) (d) (e) failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; failure to have his vehicle under such control as to be able to stop within the assured clear distance ahead; failure to follow Plaintiff's vehicle at a safe distance; failure to apply his brakes in sufficient tune to avoid striking the rear of Plaintiff's vehicle; failure to travel at a safe speed; 266353.1~Ra~S\SSA 2 (I3 (g) (i) failure to drive his vehicle with due regard for the highway and traffic conditions which were existing and of which he was or should have been aware; failure to keep proper and adequate control over his vehicle; failure to take reasonable evasive action to avoid the accident; driving iris vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. reference. 10. CLAIM I PENNY A. CRAMER v. DONALD WISE. JR. Paragraphs I through 8 of Plaintiffs' Complaim are incorporated herein by As a result of the aforesaid accident, PlaintiffPenny A. Cramer sustained painful and severe injuries which include, but are not limited to, occipital neuritis, cervical and trapezius strain and sprain. 11~ By reason of the aforesaid injuries sustained by PlaintiffPenny A. Cramer, she wa' forced to incur liability for medical treatment, medications, and similar miscellaneous expenses i an effort to restore herself to health, and claim is made therefor. 12. Because of the nature of her injuries, Plaintiff Penny A. Cramer has been adh,, and, therefore, avers that she may be forced to incur similar expenses in the future, and clair made therefor. 266353. IkRAS\SSA 3 13. As a result of the aforementioned injuries, Plaintiff Penny A. Cramer has undergone, and in the future will undergo, great physical and mental suffering, great inconvenience in carrying out her daily activities, and loss of life's pleasures and enjoyment, and claim is made therefor. 14. As a result of the aforesaid injuries, Plaintiff Penny A. Cramer has sustained uncompensated wage loss, and claim is made therefor. 15. As a result of the aforesaid injuries, Plaintiff Penny A. Cramer has sustained loss of opportunity and a permanent diminution of her earning power and capacity, and claim is made therefor. 16. As a result of the aforesaid injuries, Plaintiff Penny A. Cramer has been and in the future will be subject to great humiliation and embarrassment, and claim is made therefor. 17. As a result of the aforesaid injuries, Plaintiff Penny A. Cramer continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefor. 18. reference. CLAIM II KENNETH E. CRAMER v. DONALD WISE, JR. Paragraphs 1 through 17 of Plaintiffs' Complaint are incorporated herein by 266353.1~AS\SSA 4 19. As a result of the aforementioned injuries sustained by his wife, Plaintiff Penny A. Cramer, Plaintiff Kenneth E. Cramer has been and may in the future be deprived of the care, companionship, consortim, and society of his wife, all of which will be to his great detdmem, and claim is made therefor. WHEREFORE, Plaintiffs Penny A. Cramer and Kenneth E. Cramer demand judgment against Defendant Donald Wise, Jr. in an mount in excess of Twenty-five Thousand Dollars ($25,000.00), exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. Date: October 14, 2003 ANOn O & ROVNm P__2Y - 8aalock, Esquire I.D. No. 47281 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiffs 266353. I~>.AS\SSA 5 VERIFICATION We, Penny A. Cramer and Kenneth E. Cramer, Plaintiffs, have read the foregoing PLAINTIFFS' COMPLAINT and do hereby swear or affirm that the facts set forth in the foregoing are true and correct to the best of our know/edge, information and belief. We understand that this Verification is made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unswom falsification to authorities. Penny A.~ramer Dated: 266449. i~P, AS~viLB 03HB-00175 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Donald Wise, Jr. PENNY A. CRAMER AND KENNETH E. CRAMER, HER HUSBAND, PLAINTIFFS VS. DONALD WISE, JR., DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA No. 03-5463 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL iDEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendant, Donald Wise, Jr. Date: November 18, 2003 Respectfully submitted, LA~ ~ICES ~F~A~ & ASSOCIATES Attorney for Defendant Court I.D.39126 03HB-00175 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Donald Wise, Jr. PENNY A. CRAMER AND KENNETH E. CRAMER, HER HUSBAND, PLAINTIFFS VS. DONALD WISE, JR., DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA No. 03-5463 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Entry of Appearance to be served by regular first class mail upon: Date: November 18, 2003 Richard A. Sadlock, Esquire Angino & Rovner P.C. 4503 North Front/S Harrisburg, PP~I 7 D6 ald R. Dorer, Esquire Attorney for Defendant SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-05463 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CRAMER PENNY A ET AL VS WISE DONALD JR R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT , WISE DONALD JR but was unable to locate Her in his bailiwick. deputized the sheriff of FP~ANKLIN County, serve the within COMPLAINT & NOTICE , Sheriff or Deputy Sheriff who being says, that he made a diligent search and to wit: He therefore Pennsylvania, to On November 7th , 2003 attached return from FPJkNKLIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Franklin Co 32.00 .00 69.00 11/07/2003 ANGINO & ROVNER Sworn and subscribed to before me this /y~ day of ~w~ ~(Ut3 A.D. ! ~ Prothonotary ' this office was in receipt of the So answers ~ ....... ~? 3_~_.~r~ R% Thomas Kline // Sheriff of Cumberland County In The Court of Common Pleas of Cumberland County, Pennsylvania Penny A. Crier et al VS. Donald Wise Jr. SERVE: sa~e 03-5463 civil No. Now, October 17, 2003 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of · Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA within upon at by handing to a and made known to Affidavit of Service ,20 ,at o'clock M. served the copy of the original So answers, the contents thereof. Sworn and subscribed before me this __ day of ,20 Sheriffof COSTS SERVICE MILEAGE AFFIDAVIT County, PA SHERIFF'S RETURN CASE NO: 2003-00264 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FR3kNKLIN PENNY A CP~AMER ET AL VS DONALD WISE JR REGULAR ERIC R. HOCKENBERRY , Deputy Sheriff of FR3tNKLIN County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT was served upon WISE DONALD JR DEFENDANT at 0011:45 Hour, on the 24th day of October at FPJtNKLIN CO SHERIFF OFFICE CHAMBERSBURG, PA 17201 DONALD WISE JR 157 LINCOLN WAY EAST by handing to a true and attested copy of COMPLAINT the 2003 together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 9.00 Service 9.00 Affidavit 4.00 Surcharge 10.00 .00 32.00 Sworn and Subscribed to before me this ~-~A day of So Answers: ERIC R. HOCKENBERRY (-~Deputy She~ff 11/04/2003 CUMBERLAND CO SHERIFF 03HB-00175 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Donald Wise, Jr. PENNY A. CRAMER AND KENNETH E. CRAMER, HER HUSBAND, PLAINTIFFS VS. DONALD WISE, JR., DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA No. 03-5463 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL, DEMANDED ANSWER WITH NEW MATTER OF DEFENDANT, DONALD WISE, JR., TO PLAINTIFFS' COMPLAINT 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted in part, denied in part. The Defendant, Donald Wise, Jr., generally admits that he was solely negligent for the occurrence of the motor velficle accident described in Plaintiffs' Complaint on or about July 16, 2002. However, by way of further statement, all other allegations factual nature are generally denied pursuant to Pa.R.C.P. § 1029(e). 8. Admitted in part, denied in part. The answer to paragraph 7 is incorporated herein by reference as if more fully set forth herein. CLAIM I Penny A. Cramer v. Donald Wise, Jr. 9. Paragraphs 1 through 8 are incorporated herein by reference, and made a part hereof as if set forth in full. 10-17. Denied. Paragraphs 10 through 17 of Plaintiffs' Complaint are generally denied pursuant to Pa.R.C.P. §1029(e). CLAIM II Kenneth E. Cramer v. Donald Wise, Jr. 18. Paragraphs 1 through 17 are incorporated herein by reference, and made a part hereof as if set forth in full. 19. Denied. Paragraph 19 of Plaintiffs' Complaint is :generally denied pursuant to Pa.R.C.P. § 1029(e). WHEREFORE, the Defendant respectfully prays this Itonorable Court to dismiss Plaintiffs' Complaint, and to enter judgment against the Plaintiffs and in favor of the Defendant. NEW MATTER 20. Paragraphs 1 through 19 are incorporated herein by reference, and made a part hereof as if set forth in full. 2 21. Plaintiff's claims are barred in whole or in part by the provisions of the Pennsylvania No-Fault Motor Vehicle Insurance Act and/or the Pennsylvania Motor Vehicle Financial Responsibility Law. WHEREFORE, the Defendant respectfully prays this E[onorable Court to dismiss Plaintiffs' Complaint, and to enter judgment against the Plaintiffs and in favor of the Defendant. Date: April 12, 2004 Respectfully submitted. ~ ~~~FFIC 0 JA~ S _ By D6nald R. & ASSOCIATES Dorer, Esquire Attorney for Defendant Court I.D.39126 APR,-12'O4(MON) 09:46 DONALD R, DORER, ESQ TEL:?i? 731 0987 P, O02 O3HB-00175 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Donald Wise, Jr. PENNY A. CRAMER AND It~NNExu E. CRAMER, HER I:IU$1~_ND, PLAINTIFFS VS. DONALD WISE, JR., DEFEI~DANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5463 Civil CIVIL ACTION - LAW JURY TRIAL 'DEMANDED VERIFICATION I, Donald Wise, Jr.. verify that the statemems made in the foregoing Answer with New Matter of Defendant, Donald Wi~e, Jr. ~o Plaim~ffs' Comply!pt which are within the personal lmowledgc of thc undersigned, are ~ue and correct, and as to the facts based on the informatiOn of others, the undersigned, after diligent inquiry, believe them to be role. And further, this Verification is signed on the recommendation of my atxorncys, who advise me that the allegations and language in this document are required legally to raise issues for resolution at trial, by the Court, or by continuing investigalion and preparation for trial. I understand that some of these allegations may prove inappropriate after investigation and trial preparation are complete and I leave the determination of these ma~ters to my attorneys on their advice. I understand that all statements herein arc made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsifications to authorities. Donald Wise, Jr. 03HB-00175 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Donald Wise, ,Ir. PENNY A. CRAMER AND KENNETH E. CRAMER, HER HUSBAND, PLAINTIFFS VS. DONALD WISE, JR., DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5463 CIVIL TERM CIVIL ACTION - LAW JURY TRIAl. DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attomey for the Defendant herein, and that he caused a true and correct copy of the attached Answer with New Matter of Defendant, Donald Wise, Jr., to Plaintiffs' Complaint to be served by regular first class mail upon: Date: April 12, 2004 Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Str/q_et Harrisburg, i~/ Donald R. Dorer, Esquire Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PENNY A. CRAMER, and CIVIL ACTION - LAW KENNETH E. CRAMER, her husband Plaintiffs v. NO. 03-5463 Civil DONALD WISE, JR., Defendant JURY TR~A~, DEMANDED PLAINTIFFS' REPLY TO NEW MATTER OF DEFENDANT AND NOW come the Plaintiffs, by and through their attorneys, Angino & Rovner, P.C., and hereby enter the following Reply to the New Ma~ter of Defendan! as follows: 20. Defendant's averment does not require a responsive pleading. 21. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, all of Plaimiffs' injuries and damages are recoverable in the instant action. The Pennsylvania Motor Vehicle Financial Responsibility Law in no way limits the damages Plaintiffs may recover herein. WHEREFORE, Plaintiffs respectfully request this Honorable Court to dismiss Defendant's Answer and New Matter and enter judgment in their favor against the Defendant. Date: April 15, 2004 Sadlock, Esquire I.D. No. 47281 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiffs 26721 I,I~RAS\MLB COMMONWEALTH OF PENNSYLVANIA: : COUNTY OF DAUPHIN : SS. I, Richard A. Sadlock, Esquire, being duly swom according to law, depose, and state that I am counsel for Plaintiffs, that I am authorized to make this Affidavit on behalf of said Plaintiff and that the facts set forth in the foregoing PLAINTIFFS' REPLY TO NEW MATTER OF DEFENDANT are tree and correct to the best of m3 ~" Richard ~ock Sworn to and subscribed before me this 14th day of AI~% 2004. ic NOTARIAL SEAL · BRYDON N. LIDLE III, NOTARY PUBLIC I 011¥ OF HARRISBURG, DAUPHIN COUNTYI COMMI~ON ~XPIRI~$ MARCH 4, 20061 CERTIFICATE OF SERVICE I, Marcy L. Brymesser, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a tree and correct copy of PLAINTIFFS' REPLY TO NEW MATTER OF DEFENDANT on the following via postage prepaid, first class United States mail, addressed as follows: Donald R. Dorer, Esquire Jacobs & Associates 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Date: April 15, 2004 267211. I ~.AS~ILB File No.: 0mB-001?S PRAECIPE FOR LISTING CASE_ FOR TRIAL (Must be typewritten and submitted in duplicate.) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case (check one): ( x ) for JURY trial at the next term of civil court. ( ) for trial without a jury. CAPTION OF CASE: (Entire Caption Must Be Stated In Full) (Check One) ( ) Ass~ampsit Penny A. Cramer and Kenneth E. Cramer, Her Husband, Plaintiffs VS. ( ) Trespass ( x ) Trespass (Motor Vehicle) ( ) (Other) Donald Wise, Jr., Defendant The trial list will be called on September 28, 2004 Trials commence on October 25, 2004 Pre-trials will be held on October 6, 2004 (Briefs are due 5 days before pre-trials.) (The p*xty listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214-1.) No. 03-5463 Civil __2003 Indicate the attorney who will try case for the party who files this praecipe: Donald R. Dorer, Esquire, Attorney for Defendant; Jacobs & Associates, 214 Senate Avenue, Suite 503, Camp Hill, Pennsylvania, 17011; (717) 731- 0988. Indicate trial counsel for other Rovner, P.C., 4503¢4orth Front St~ree This case is ready:i~ /al. {/"// j Signed: , ~ Print Name~ ']5onald R. Dor~ Attorney for: Defendant r~es if known: Richard A. Sadlock, Attorney for Plaintiffs, Angino & larrisburg, Pennsylvania 17110; (717) 238-6791 Esquire Date: August 12, 2004 03HB-00175 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Itill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Donald Wise, Jr. PENNY A. CRAMER AND KENNETH E. CRAMER, HER HUSBAND, PLAINTIFFS VS. DONALD WISE, JR., DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA No. 03-5463 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is t'he attorney for the Defendant herein, and that he caused a true and correct copy of the attached Praecipe for Listing Case for Trial to be served by regular first class mail upon: Date:k August t2,2004 Richard A. Sadlock, Esquire Angino & Rovner P.C / 4503 North Front treet /' Harrisburg, e ~Pv- ~ ~nald R. Dorer, Esquire Attorney for Defendant %5 PENNY A. CRAMER and KENNETH E. CRAMER, Plaintiffs V. DONALD WISE, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVil, A I0 - LAW* 03-5463 CIVIL TE~ PRETRIAL CONFERENCE AND NOW, this llth day of October, 2004, befog. E~,~ar~<" ~ Bayley, Judge, present for the plaintiffs was Richard A. Sadlock, Esquire, and for the defendant, Donald R. Doter, Esquire. This case arises out of a motor vehicle accident on July 16, 2002, when defendant rear-ended a vehicle operated by plaintiff. Negligence is admitted by defendant. Plaintiff seeks general damages. Estimated time of trial, one ~~f days. Edgar B. ~ay~,ley, J. Richard A. Sadlock, Esquire For Plaintiffs Donald R. Dorer, Esquire For Defendant prs 03HB-00175 PENNY A. CRAMER AND KENNETH E. CRAMER, HER HUSBAND~ PLAINTIFFS VS. DONALD WISE~ JR. DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLANI) COUNTY~ PENNSYLVANIA No. 03-546.3 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END TO THEPROTHONOTARY: Please mark the above-captioned case settled, discontinued and ended. Date: A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Attorney for Plaintiffs Court I.D. t4'~al,~} 03 HB4}0175 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Donald Wise, Jr. PENNY A. CRAMER AND KENNETH E. CRAMER, HER HUSBAND~ PLAINTIFFS VS. DONALD WISE~ JR., DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03-5463 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Doter, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached ?raecipe to Settle, Discontinue and End to be served by regular first class mail upon: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Date: November 2, 2004 Donald R. Dorer, Esquire Attorney for Defendant