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Home My WebLink About03-6098LAURA KENNEFICK, Plaintiff PEARL JULIAN& Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-/a,Oqo~ CWIL CIVIL ACTION - LAW PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a Writ of Summons in the above-captioned action to be served by the Sheriff on the Defendant at the following address: Pearl Juliana 77 2nd Street West Fairview, PA 17025 The address of the Plaintiffs is 1311 Scenery Drive, Mechanicsburg, Pennsylvania, 17050 CLARAVAL & CLARAVAL Date: /t/Iq~OS MA~Y ANN KENNEDY CLARAVAL P.O. Box 11965 Harrisburg, PA 17108-1965 (717) 233-4763 Supreme Court I.D. #87347 Attorneys for Plaintiff Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS LAURA KENNEFICK Plaintiff Vs. PEARL JULIANA 77 2ND STREET WEST FAIRVIEW, PA 17025 Defendant Court of Common Pleas No. 03-6098 CIVIL TERM In CivilAction-Law To PEARL JULIANA, You are hereby notified that LAURA KENNEFICK, the Plaintiff has / have conunenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date NOVEMBER 20, 2003 CURTIS R. LONG Prothonotary Deputy Attorney: Name: MARY ANN KENNEDY CLARAVAL, ESQUIRE Address: PO BOX 11965 HARRISBURG, PA 17108-1965 Attorney for: Plaintiff Telephone: 717-233-4763 Supreme Court ID No. 87347 SHERIFF'S CASE NO: 2003-06098 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KENNEEICK LAURA VS JULIANA PEARL GERALD WORTHINGTON Cumberland County,Pennsylvania, says, the within WRIT OF SUMMONS JULIANA PEARL DEFENDANT at 1758:00 HOURS, at 77 2ND STREET WEST FAIRVIEW, PA 17025 PEARL JULIANA a true and attested copy of WRIT OF RETURN - REGULAR Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 26th day of November , 2003 by handing to SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this /~3-' day of ~c~ (L ~ -2 ~2~A~ A.D. P~0thonotary So Answers: --~F''~ .~::~!.::t .. ,: R. Thomas Kline 12/01/2003 MARY ANN CLARAVAL Deputy SKe4~fff f 04HB-00036 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Pearl Juliana LAURA KENNEFICK, PLAINTIFF VS. PEARL JULIANA, DEFENDANT IN THE COURT OF COMMON FLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6098 CIVIL ACTION - LAW JURY TmAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly emer my appearance in the above-captioned matter on behalf of the Defendant, Pearl Juliana. Date: March 10, 2004 Respectfully submitted, Dona'~T~R. Dorer, Esquir~ Attorney for Defendant Court I.D.39126 IATES 04HB-00036 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Pearl Juliana LAURA KENNEFICK~ PLAINTIFF VS. PEARL JULIANA, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA NO. 03-6098 CIVIL ACTION - LAW JURY TmAL 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: March 10, 2004 Mary Ann Kennedy Claraval, Esquire Claraval & Claraval P.O. Box 11965 Harrisburg, PA 17108-1965 Attorney for Defendant 04HB-00036 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Pearl Juliana LAURA KENNEFICK, PLAINTIFF VS. PEARL JULIANA, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6098 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please enter a RULE upon Plaintiff to file a C~'~t v~ithi~a or suffer the entry of a Judgment of Non Pros. L/~"-Donald R. Dor~ Date: ty 0) Esquire March 10, 2004 Attorney for Defendant Court I.D. 39126. days hereof RULE TO FILE COMPLAINT AND NOW, this (4 day of //~O~[cc~(~, , 2004 a RULE is hereby entered upon the Plaintiff to file a Complaint herein within twenty (20) days after service hereof or suffer the entry of a Judgment of Non Pros. PROTHONOTARY 04HB-00036 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Pearl Juliana LAURA KENNEFICK, PLAINTIFF VS. PEARL JULIANA~ DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA NO. 03-6098 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 Praecipe - Rule to File Complaint to be served by regular first class mail upon: Date: March 10, 2004 Mary Ann Kennedy Claraval, Esquire Claraval & Claraval P.O. Box 11965 Harrisburg, PA 17108-1965 Donald R. Dore[ Esquire Attorney for Defendant LAURA KENNEFICK, Plaintiff PEARL JULIANA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003- 6098 CIVIL : CIVIL ACTION - LAW NOTICE - COMPLAINT 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 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 800-990-9108 AVISO LE HAN DEMANDADO EN CORTE. Si usted desea defender contra las demandas dispuestas en las p~ginas siguientes, usted debe tomar la acci6n en el plazo de veinte (20) dias despu6s de esta queja y se sirve el aviso, incorporando un aspecto escrito personalmente o y archivando en escribir con la corte sus defensas u objeciones a las demandas dispuestas contra usted .el.ab. ogado le advierte que que si usted no puede hacer asi que el caso puede proceder sin usted y tm jmcm se puede incorporar contra usted compra la corte sin aviso adicional para cualquier dinero demandado en la queja o para cualquier otra demanda o relevaci6n pedida por el demandante. Usted puede perder el dinero o la caracteristica de otra endereza importante a usted. USTED DEBE LLEVAR ESTE PAPEL SU ABOGADO INMEDIATAMENTE. SI USTED NO HACE QUE UN ABOGADO VAYA A O LLAME POR TELI~FONO La OFICINA DISPUESTA ABA JO. ESTA OFICINA PUEDE PROVEER DE USTED LA INFORMACI(~N SOBRE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PERMITIRSE AL HIRE A UN ABOGADO, ESTA OFICINA PUEDE PODER PROVEER DE USTED LA INFORMACI(~N SOBRE LAS AGENCIAS QUE LOS SERVICIOS JUR[DICOS DE LA OFERTA DE MAYO A LAS PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO O NINGI~N HONORARIO Cumberland Cotmty Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 800-990-9108 LAURA KENNEFICK, Plaintiff PEARL JULIANA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2003- 6098 CIVIL : CIVIL ACTION - LAW COMPLAINT 1. The PlaintiffLaura Kennefick is an adult individual residing at 1311 Scenery Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant Pearl Juliana is an adult individual residing at 77 2nd Street, West Fairview, Cumberland County, Pennsylvania. 3. On November 30, 2001 the Plaintiff Laura Keunefick was driving her 1999 Saturn. 4. On that same date Defendant Pearl Juliana was operating a 1997 Mazda. Township. The Plaintiff Laura Kennefick was traveling south on Salt Road in East Pennsboro 6. The Defendant Pearl Juliana was traveling north on Salt Road when she turned left without stopping at the driveway to 225 Salt Road. 7. Without regard for the approaching car of Plaintiff Laura Kennefick, the Defendant Pearl Juliana negligently and carelessly made a left hand turn to turn lef~ onto the driveway to 225 Salt Road causing a collision between the two vehicles. 8. The force of the impact shoved the engine of Laura's Saturn into the dashboard and caused her airbags to deploy. The sunroof of the Saturn was popped out of its container. 9. The chemicals from the airbag caused Plaintiff Laura Kennefick to have an asthmatic reaction, foming her to exit the car under emergency cimumstances. 10. The force of the impact also caused instant pain in Laura's right wrist, thumb and elbow. 11. The collision and all of the hereinafter mentioned injuries and damages sustained by Laura Kennefick are the direct result of the negligence, recklessness and carelessness of Defendant Pearl Juliana as more particularly described below: A. In failing to yield the right-of-way; B. Turning left in the face of oncoming traffic; C. In failing to observe the Plaintiff's vehicle in time to avoid a collision; D. In failing to keep adequate and proper control over her vehicle to avoid contact with the automobile that Plaintiff Laura Kennefick was driving; In failing to keep alert and to maintain the proper lookout for the presence of other motor vehicles, more specifically the Plaintiff Laura Kermefick's vehicle; In operating her vehicle in a reckless manner and with careless disregard for the right or safety of persons or property in the violation of Motor Vehicle Code of the Commonwealth of Pennsylvania specifically 75 Pa.C.S.§3714, by turning her car left and proceeding into the path of Plaintiff Laura Kennefick thereby causing a collision; and In operating her vehicle in a manner endangering person and property in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania specifically 75 Pa.C.S. §3322, by turning lelt within an intersection without yielding to the right-of-way to any vehicle approaching from the opposite direction which is so close to constitute a hazard. 12. The force and impact of the collision as caused by the negligence and carelessness of the Defendant Pearl Juliana caused serious injury to PlaintiffLaura Kennefick for which she has received medical care. 13. The Plaintiff Laura Kennefick suffered the following injuries as a result of the negligence and carelessness of Defendant Pearl Juliana: A. Right wrist instability; B. Right wrist hamate fracture non-union; C. Triangular fibrocartilage tear in the right wrist; Post operative formation of cyst in right wrist; and Injury to her right elbow. 14. Plaintiff Laura Kennefick underwent a surgical iprocedure performed by Dr. Robert J. Mauer on October 27, 2003 to repair tom ligaments and the hamate fracture in her fight wrist. 15. As a result of the tom ligaments a cyst has formed in Laura's right wrist. The surgical procedure to remove the cyst is scheduled for April 8, 2004 to be performed by Dr. Mauer. 16. As a result of the negligence and carelessness of the Defendant Pearl Juliana as described herein the Plaintiff Laura Kennefick has suffered and will continue to suffer mental and physical pain, great difficulty in carrying out and engaging in life's activities, a loss of life's pleasures and enjoyment, humiliation and embarrassment. 17. All ofPlaintiffLaura Kennefick's injuries as herein described are continuing and will continue into the foreseeable future, as will the treatment costs thereof. 18. Plaintiff Laura Kennefick may in the future have medical expenses that will be either subject to subrogation or will be out of pocket expenses. 19. The negligence and carelessness of the Defendant Pearl Juliana bas resulted in the general detefioration of Plaintiff Laura Kennefick's well being. 20. The negligence, recklessness and carelessness of Pearl Juliana has resulted in the total loss of Plaintiff Laura Kennefick's 1999 Saturn. 21. The negligence, recklessness and carelessness of Pearl Juliana has resulted in the loss of income for Plaintiff Laura Kennefick. WHEREFORE, the Plaintiff Laura Kennefick demands judgment against Defendant Pearl Juliana in an amount which exceeds the compulsory arbitration limits of Cumberland County together with interest, delay damages if applicable and costs of suit. CLARAVAL & CLARAVAL IVlP{~ ANN KENNEDY CEARAVAL P.O. Box 11965 Harrisburg, PA 17108-1965 (717) 233-4763 Supreme Court I.D. #87347 Attorneys for Plaintiff 3~ERIFICATION I, Mary Ann Kennedy Claraval, being duly sworn according to law, depose and state that I am the attorney for the Plaintiff Laura Kennefick, and that I make this affidavit on Laura KeImefick's behalf and that the said Plaintiff is unavailable and unable to make this Verification on her behalf at this time and the facts set forth in the foregoing document are true and correct to the best of my knowledge, information and belief. This Verification is made pursuant to Pa.R.C.P. 1024 and is based on reports, records and other investigatory material in this file. MARY(~NN I~NNEDY CLAR~VAL, ESQUIRE LAURA KENNEFICK, Plaintiff PEARL JULIANA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003- 6098 CIViL CIViL ACTION - LAW CERTIFICATE OF SERVICE I hereby certify that I have this day served the Complaint by facsimile and certified mail, postage prepaid and addressed to the following person: Donald Dorer, Esquire 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Date: By -~)O~._LyO~ ~ BARBARA ~. KOCHER SecretaW for MaW Ann Clamval 04HB-00036 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Pearl Juliana LAURA KENNEFICK, PLAINTIFF VS. PEARL JULIANA, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03-6098 CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANT, PEARL JULIANA, TO PLAINTIFF'S COMPLAINT 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. - 21. Denied. These paragraphs are generally denied pursuant to Pa.R.C.P. §~029(e). WHEREFORE, the Defendant respectfully prays this Honorable Court to dismiss Plaintiff's Complaint, and to enter judgment against the Plaintiff and in favor of the Defendant. NEW MATTER 22. Paragraphs 1 through 21 are incorporated herein by reference, and made a part hereof as if set forth in full. 23. 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 Honorable Court to dismiss Plaintiff's Complaint, and to enter judgment against the Plaintiff and in favor of the Defendant. Respectfully submitted, L ~ AW O~ES OF/J/CO]~ Donald R. Doter, Esq~ril~ Attorney for Defendant: Identification No. 39126 &ASSOCIATES Date: March 26 2004 04HB-00036 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Pearl Juliana LAURA KENNEFICK, PLAINTIFF VS. PEARL JULIANA, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6098 CIVIL ACTION - LAW JURY TRIAL, DEMANDED VERIFICATION DONALD R. DORER, ESQUIRE, hereby states that he is the attorney for the Defendant in this action, and is authorized to verify that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities, o~R~, ~ DOlX~D R. RE Attorney for Defendant Dated: March 26, 2004 04HB-00036 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Pearl Juliana LAURA KENNEFICK, PLAINTIFF VS. PEARL JULIANA, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6098 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 hue and correct copy of the attached[ Answer with New Matter of Defendant, Pearl Juliana, to Plaintiff's Complaint to be served hy regular first class mail upon: Date: March 26, 2004 Mary Ann Kennedy Claraval, Esquire Claraval & Claraval P.O. Box 11965 Harrisburg, PA 17108-1965 nald R. Dorer, Esquire Attorney for Defendant 04HB-00036 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Pearl Juliana LAURA KENNEFICK, PLAINTIFF VS. PEARL JULIANA, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03-6098 CIVIL ACTION - LAW JURY TRIAl_, DEMANDED ANSWER WITH NEW MATTER OF DEFENDANT, PEARL JULIANA, TO PLAINTIFF'S COMPLAINT 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. - 21. Denied. These paragraphs are generally denied pursuant to Pa.R.C.P. §1029(e). WHEREFORE, the Defendant respectfully prays this Honorable Court to dismiss Plaintiff's Complaint, and to enter judgment against the Plaintiff and in favor of the Defendant. NEW MATTER 22. Paragraphs 1 through 21 are incorporated herein by reference, and made a part hereof as if set forth in full. 23. 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 ]Honorable Court to dismiss Plaintiff's Complaint, and to enter judgment against the Plaintiff and in favor of the Defendant. Respectfully submitted, LAW O ~ S OF J~ CID ByC Donald R. Dorer, Esq~ Attorney for Defendartt Identification No. 391:26 ~& ASSOCIATES Date: March 26, 2004 04HB-00036 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Pearl Juliana LAURA KENNEFICK, PLAINTIFF VS. PEARL JULIANA, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03-6098 CIVIL ACTION - LAW JURY TRIAL DEMANDED VERIFICATION DONALD R. DORER, ESQUIRE, hereby states that he is the attorney for the Defendant in this action, and is authorized to verify that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to auth~oriti:~es. / , DOI,~7~D, R. DORER, E~ Attorney for Defendant Dated: March 26, 2004 04HB-00036 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Pearl Juliana LAURA KENNEFICK, PLAINTIFF VS. PEARL JULIANA, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA NO. 03-6098 CIVIL ACTION - LAW JURY Tm~L DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the.. attorney for the Defendant herein, and that he caused a tree and correct copy of the attached Answer with New Matter of Defendant, Pearl Juliana, to Plaintiff's Complaint to be served by regular first class mail upon: Date: March 26, 2004 Mary Ann Kennedy Claraval, Esquire Claraval & Claraval P.O. Box 11965 Harrisburg, PA 17108-1965: /~~~/ l!~o~ld R. Dorer, Esquire Attorney for Defendant LAURA KENNEFICK, Plaintiff PEARL JULIANA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003- 6098 CIVIL CIVIL ACTION - LAW PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER 22. Denied. No response is required. 23. Denied. It is specifically denied that Plaintiff's claims are barred in whole or in part by the provisions o fthe Pennsylvania No Fault Motor Vehicle Insurance Act and or the Pennsylvania Motor Vehicle Responsibility Law. Therefore, the Plaintiff Laura Kennefick demands judgment against Defendant Pearl Juliana in an amount which exceeds the compulsory arbitration limits of Cumberland County together with interest, delayed damages if applicable and costs of suit. Respectfully submitted, CLARAVAL & CI_,ARAVAL MA~ A/~.~ KENNEDY CLAR~V~AL P.O. l~/ox 11965 Harrisburg, PA 17108-1965 (717)233-4763 Supreme Court I.D.#87347 Attorneys for Plaintiff LAURA KENNEFICK, Plaintiff PEARL JULIANA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003- 6098 CIVIL CIVIL ACTION - LAW CERTIFICATE OF SERVICE I hereby certify that I have this day served Plaintiff's Reply to Defendant's New Matter by first class mail, postage prepaid and addressed to the following person: Donald Dorer, Esquire 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Date: BAJ~ARAJ. KOCHER Secretary ~r Mary Ann Cl~aval LAURA KENNEFICK, Plaintiff PEARL JULIANA, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003- 6098 C, IVIL : CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please mark the above captioned action settled mad discontinued. Date: (Ida 200 CLARAVAL & CLARAVAL MAt~ ANN KENNEDY CLARAVAL P.O. Box 11965 Harrisburg, PA 17108-1965 (717) 233-.4763 Supreme Court I.D. #87347 Attorneys for Plaintiff