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HomeMy WebLinkAbout03-632308-03-538 LAW OFFICES OF STEWART C. CRAWFORD BY: Stewart C. Crawford ATTORNEY I.D.: 09827 223 North Monroe Street P.O. Box E Media, PA 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Allstate Insurance Company a/s/o Jody Wagner 309 Lakeside Drive Horsham, PA 19044 Donna Starner 3808 Glenwood Avenue Camp Hill, PA 17011 IN CIVIL ACTION NO: 03 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 an 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 ease may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaim or for any other 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 CANNOT 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 ELIGABLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File # 08-03-538 LAW OFFICE OF STEWART C. CRAWFORD & ASSOCIATES BY: Stewart C. Crawford, Esquire ATTORNEY I.D. NO. 09827 223 North Monroe Street Attorney for Plaintiff Media, PA 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW Allstate Insurance Company As Subrogee of IN CIVIL ACTION Jody Wagner 309 Lakeside Drive Horsham, PA 19044 VS. Donna Stamer 3803 Glenwood Avenue Camp Hill, PA 17011 NO. 03 - COMPLAINT 4030 Motor Vehicle Property Damage. I. Pla'mtiffis an insurance company licensed and authorized to do business in the Commonwealth of Pennsylvania with one of its principle places of business at the above-captioned address. 2. Defendant, above-named, was the owner and the operator of a motor vehicle involved in an incident on June 13, 2003 and at all times pertinent hereto resided at the above-captioned address. 3. On the aforesaid date, Plaintiff had a policy of insurance with Jody Wagner, hereinafter referred to as named insured. 4. On the aforesaid date, a motor vehicle insured by Plaintiff, hereafter the insured's vehicle, was involved in an incident with Defendant. 5. On the aforesaid date, the insured's vehicle was North on Pennsylvania Route 114 at the intersection with Sparring Green Drive in Silver Springs Township, Pennsylvania when Defendant, who was traveling South, made a sudden and illegal lef~ turn in front of the insured's vehicle striking and damaging it. 6. The Defendant was negligent and careless and the sole cause of this incident in that Defendant: (a). Operated the vehicle at an unsafe rate of speed; (b). was inattentive; (c). failed to make proper observation (d). violated local laws and the laws of the Commonwealth; 7. Pursuant to the aforesaid policy of insurance, Plaintiffbecame liable for damages that arose out of this accident. 8. Due to this incident, expenses were incurred for, damage to the insured vehicle, towing, storage and car rental. 9. Pursuant to the aforesaid policy of insurance, the Common Law and governing statutes, Plaintiff is subrogated for all money paid and seeks recovery of these sums totaling $I0, 303.49. WHEREFORE, Plaintiff demands judgment for $10, 303.49 plus interest and costs of suit. Stewart C. Crawford, Esquire Attorney for Plaintiff VERIFICATION The undersigned verifies that the statements contained in the foregoing Complaint are true and correct. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Stewart C. Crawford, Esquire for Allstate Insurance Company # 08-03-538 LAW OFFICES OF STEWART C. CRAWFORD BY: Stewart C. Crawford, Esquire ATTORNEY I.D. # 09827 223 North Monroe Street P.O. Box E Media, PA 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Allstate Insurance Company a/s/o Jody Wagner 309 Lakeside Drive Horsham, PA 19044 CIVIL ACTION NO. 03-6323 Donna Stamer 3803 Glenwood Avenue Camp Hill, PA 17011 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate this Complaint an additional thirty (30) days. Dated: 'STEWART C. CRAWFORD, ES~JI17,E Attorney for Plaintiff SHERIFF'S RETURN - CASE NO: 2003-06323 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NOT FOUND ALLSTATE INSUP~ANCE CO ET AL VS STARNER DONNA R. Thomas Kline duly sworn according inquiry for the within named DEFENDANT STARNER DONNA unable to locate Her in his bailiwick. ,Sheriff or Deputy Sheriff, who being to law, says, that he made a diligent search and but was He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT 3808 GLENWOOD AVENUE CAMP HILL, PA 17011 NO SUCH ADDRESS IN CUMBERLJ~ND COUNTY. STARNER DONNA NOT FOUND , as to Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 10.35 5.00 10.00 .00 43.35 ~. ~hS~a~k~ine Sheriff of Cumberland County STEWART C CRAWFORD 12/12/2003 Sworn and subscribed to before me SHERIFF'S RETURN cASE NO: 2003-06323 P COMMONTWEALTH OF pENNSYLVANIA COUNTY OF CUMBERLAND - NOT FOb~D ALLSTATE INSURANCE CO ET AL VS STARNER DONNA R. Thomas Kline duly sworn according to law, inquiry for the within named DEFENDANT STARNER DONNA unable to locate Her in his bailiwick. ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and but was He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , STARNER DONNA , NOT FOUND , as to 3808 GLENWOOD AVENUE CAMP HILL, PA 17011 FORWARD ADDRESS OF 240 MATTIS AVENUE MIDDLETOWN, PA 17057. Sheriff's Costs: Docketing 18,00 Service 13.80 Not Found 5.00 Surcharge 10.00 .00 46.80 So answers .... ~rr~ -~ R. Thomas Kline Sheriff of Cumberland County STEWART CRAWFORD 01/02/2004 Sworn and subscribed to before me this ~ day of ~l,~7 Pro~h6not ary SHERIFF'S RETURN CASE NO: 2003-06323 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND - NOT FOUND ALLSTATE INSURANCE CO ET AL VS STARNER DONNA R. Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named DEFENDANT STARNER DONNA unable to locate Her in his bailiwick. ,Sheriff or Deputy Sheriff, who being search and but was He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT 3808 GLENWOOD AVENUE CAMP HILL, PA 17011 ATTEMPTED SERVICE AT 3803 , STARNER DONNA NOT FOUND as to GLENWOOD AVE CAMP HILL & 205 ARCH ST CARLISLE. FORWARDING OF 240 MATTIS AVE MIDDLETOWN, PA 17057. Sheriff's Costs: Docketing 18.00 Service 13.80 Not Found 5.00 Surcharge 10.00 .00 46.80 R. -Thoma~ XPine Sheriff of Cumberland County STEWART CP~AWFORD 01/26/2004 Sworn and subscribed to before me this ~ [~ day of(' .~x~_7 / ~3y A.D. · # 08-03-538 LAW OFFICES OF STEWART C. CRAWFORD BY: Stewart C. Crawford, Esquire ATTORNEY I.D. # 09827 223 North Monroe Street P.O. Box E Media, PA 19063 Telephone: (610) 565-7050 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Allstate Insurance Company aYs/o Jody Wagner 309 Lakeside Drive Horsham, PA 19044 CIVIL ACTION NO. 03-6323 Donna Starner 3803 Glenwood Avenue Camp Hill, PA 17011 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate this Complaint an additional thirty (30) days. ~TE~'ART C. ~RAWF~RD, ESQUI~ Attorney for Plaintiff SHERIFF'S RETURN CASE NO: 2003-06323 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ALLSTATE INSUPu~NCE CO ET AL VS ST~q/qER DONNA - OUT OF COUNTY R. Thomas Kline duly sworn according to law, and inquiry for the within named DEFENDANT Sheriff or Deputy Sheriff who being says, that he made a diligent search and to wit: in his bailiwick. County, the within COMPLAINT & NOTICE STARNER DONNA but was unable to locate Her deputized the sheriff of DAUPHIN serve He therefore Pennsylvania, to On March 5th , 2004 attached return from DAUPHIN Sheriff's Costs: Docketing .00 Out of County 9.00 Surcharge .00 Dep Dauphin County 29.25 .00 38.25 03/05/2004 STEWART CRAWFORD Sworn and subscribed to before me this g~ day of )~ A.D. Prothonotary this office was in receipt of the So answers:~ .3. >~ . R./Thoma~ Kline Sheriff of Cumberland County TSe Court of Common Pleas of Cumberland County, Pennsylvania Allstate Insurance Company a/s/o Jody Wagner VS. Donna Starner SERVE: sa~e No. 03-6323 civil }~ow, February-5, 2004 hereby deputize the Sheriff of deputation being made at the request and risk of the Plaintiff. Sheriffof Cumberland County, PA , I, SHERIFF OF CUMBERLAND COUNTY, PA, do County to execute this Writ, this Now~ within upon at by handing to and made known to Affidavit of Service , 20__, at o'clock M. served the copy of the original the contents thereof, So answers, Sworn and subscribed before me this ___ day of ,20 Sheriff of County, PA COSTS SERVICE MILEAGE AFFIDAVIT Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph:(717)255-2660 fax: (717) 255~2889 Jack Lotwick Sheriff 1. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania County of Dauphin AND NOW:February 27, 2004 REINSTATED COMPLAINT STAPLER DOlqlqA to DEFENDANT of the original REINSTATED COMPLAINT to him/her the contents thereof at 240 MATTIS AVE MIDDLETOWN, PA ALLSTATE INSURANCE CO A/S/O STARNER DONNA Sheriff's Return No. 0674-T - -2004 OTHER COUNTY NO. 03-6323 at 5:23PMserved the within upon by personally handing 1 true attested copy(les) and making known 17057-0000 Sworn and subscribed to before me this 2ND day of MARCH, 2004 PROTHONOTARY Sheriff of Dauphin County, Pa. By f Sheriff's Costs: $29.25 PD 02/09/2004 RCPT NO 188054 TQ IN THE COURT OF COMMON PLEAS OF CRAWFORD COUNTY, PENNSYLVANIA ALLSTATE INSURANCE COMPANY a/s/o JODY WAGNER, CIVIL ACTION - LAW No. 03-6323 Plaintiff, DONNA STARNER, Defendant. PRAECIPE FOR APPEARANCE (Jury Trial Demanded) Filed on Behalf of Defendant, Donna Starner Counsel of Record for this Party: Jeffrey C. Catanzarite, Esquire Pa. I.D. #72765 SUMMERS, MCDONNELL, WALSH & SKEEL, L.L.P. Firm #911 2400 Gulf Tower 707 Grant Street Pittsburgh, PA 15219 (412) 261-3232 #12439 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLSTATE INSURANCE, COMPANY a/s/o JODY WAGNER, Plaintiff, CIVIL ACTION - LAW No. 03-6323 JURY TRIAL DEMANDED By: Respectfully submitted, SUMMERS, McDONNELL, WALSH & SKEEL, L.L.P. J~otr~ /~./(~atanzarite, Esquire t( f~ a~rr~eDr efendant DONNA STARNER, Defendant. PRAECIPE FOR APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned, Jeffrey C. Catanzarite, Esquire, of the law firm of Summers, McDonnell, Walsh & Skeel, L.L.P., on behalf of the Defendant, Donna Starner, in the above case. 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 17th day of March, 2004: Stewart C. Crawford, Esquire Law Offices of Stewart C. Crawford 223 North Monroe Street P.O. Box E Media, PA 19063 SUMMERS, McDONNELL, WALSH & SKEEL, L.L.P. //~e'ffr/~C.- Catanzarite, Esquire Att ey for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLSTATE INSURANCE CIVIL ACTION - LAW COMPANY a/s/o JODY WAGNER, No. 03-6323 Plaintiff, DONNA STARNER, Defendant. ANSWER AND NEW MATTER (Jury Trial Demanded) Filed on Behalf of Defendant, Donna Starner Counsel of Record for this Party: Jeffrey C. Catanzarite, Esquire Pa. I.D. #72765 SUMMERS, MCDONNELL, WALSH & SKEEL, L.L.P. Firm #911 2400 Gulf Tower 707 Grant Street Pittsburgh, PA 15219 (412) 261-3232 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 st ,tFoo,,,,.. WALSH & SKEEL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLSTATE INSURANCE, CIVIL ACTION - LAVV COMPANY a/s/o JODY WAGNER, Plaintiff, No. 03-6323 DONNA STARNER, Defendant. _ANSWER AND NEW MATT_ER Defendant, Donna Starner, by and through her attorneys, Summers, McDonnell, Walsh & Skeel, L.L.P., and Jeffrey C. Catanzarite, Esquire, files the following pleading: I. ANSWER 1. Admitted. 2. It is admitted that the Defendant was the owner and operator of a motor vehicle involved in an accident on June 13, 2003 and that she resided in Camp Hill at that time. The Defendant currently resides at 240 Mattis Avenue, Middletown, Pennsylvania 17057. 3. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 3 and therefore, said allegations are denied and strict proof: thereof is demanded at the time of trial. 4. It is admitted that the Defendant was involved in a motor vehicle accident with a vehicle operated by Jody Wagner. By way of further response, after reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the remaining allegations of Paragraph 4 and therefore, said allegations are denied and strict proof thereof is demanded at the time of trial. 5. The allegations of Paragraph 5 are conclusions of law to which no response is required. To the extent that a response is necessary, said averments are generally denied pursuant to Rule 1029(d) and (e) of 'the Pennsylvania Rules of Civil Procedure. 6. The allegations of Paragraph 6 and its subparts are conclusions of law to which no response is required. To the extent that a response is necessary, said averments are generally denied pursuant to Rule 1029(d) and (e) of the Pennsylvania Rules of Civil Procedure. 7. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of -the allegations of Paragraph 7 and therefore, said allegations are denied and strict proof thereof is demanded at the time of trial. 8. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 8 and therefore, said allegations are denied and strict proof thereof is demanded at the time of trial. 9. The allegations of Paragraph 9 are conclusions of law to which no response is required. To the extent that a response is necessary, said averments are generally denied pursuant to Rule 1029(d) and (e) of the Pennsylvania Rules of Civil Procedure. WHEREFORE, Defendant, Donna Starner, demands judgment in her favor and against Plaintiff. II. N__EW MATTER 10. Paragraphs 1 through 9 are herein incorporated by reference. 11. The Plaintiff was negligent and careless and the sole cause of this accident in that she: operated her vehicle at an unsafe rate of speed; failed to pay attention to the roadway and other vehicles on the roadway; c. failed to operate her vehicle with her headlights engaged; and, e. violated the local laws and laws of the Commonwealth. 12. Defendant claims the benefit of the applicable provisions of the Pennsylvania Comparative Negligence Act as set forth in 42 Pa.C.S.A. § 102, et seq., and pleads the same as an affirmative defense against any and all claims of the Plaintiff. WHEREFORE, Defendant, Donna Starner, demands judgment in her favor and against Plaintiff. JURY TRIAL DEMANDEr) By: Respectfully submitted, SUMMERS, McDONNELl_, WALSH & SKEEL, L.L.P. tt~¢/~ eof~a ~t~r°~efendant VERIFICATION Defendant verifies that he/she is the Defendant in the foregoing action; that the foregoing ANSWER AND NEW MATTER is based upon information which he/she has furnished to his/her counsel and information which has been gathered by his/her 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/she has given to his/her counsel, it is true and correct to the best of his/her knowledge, information and belief. To the extent that the content of the ANSWER AND NEW MATTER is that of counsel, he/she 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. onna 5tarner, Defendar~-- #12439 C_EERTIFICATE OF SERVIC~E I HEREBY CERTIFY that a true and correct copy of the foregoing Answer and New Matter has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 29th day of March, 2004: Stewart C. Crawford, Esquire Law Offices of Stewart C. Crawford 223 North Monroe Street P.O. Box E Media, PA 19063 SUMMERS, McDONNELL, WALSH & SKEEL, L.L.P. D "~/~" ~atanzarite, Esquire ~//~y for Defendant ~;~ Starner : IN THE COURT OF COMMON PLEAS OF ~r~r.qTATE INSURANCE CO, ANY a/s/o JODY : CUMBERLAND COUNTY, PENNSYLVANIA WAGNER, : Plaintiff, : NO. 6323 CIVIL [g 2003 EXDNNA STA~NER, Defendant. RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE SUDGES OF SAID COURT: Jeffrey C. Catanzarite , counsel for the l~t~,~i~f/defendant in the above action respectfully represents that: 1. The above-captioned action l~tr/'o~i,6,6~ is 641(~ at issue. 2. The claim of the plaintiff in the action is $ 10,303.49 The counterclaim of the defendant in the action is none The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. zarite, Esquire ORDER OF COURT AND NOW, (~-~4- ~ , l'SJ:~9-~, in consideration of the foregoing petition,./~ 9 '~,,~ / ~ '~ /~ Esq., ~~;~Z;~/, actions) ~ prayed for. ~ By the~ ALLSTATE INSURANCE COMPANY a/s/o JODY WAGNER DONNA STARNER : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAVV : NO. 03-6323 CIVIL TFRM IN RE: ARBITRATION PANEL ORDER OF COURT AND NOW, July 30, 2004, the Court having been informed that Susan Candiello, Esquire, is unavailable for the above-captioned arbitration hearing, James Gault, Esquire, is appointed in her stead. By the Court, James D. Bogar, Esquire One West Main Street Shiremanstown, PA 1701 Court Administrator ALLSTATE INSURANCE CfIqPANY a/s/o JODY WAGNER DONNA STARNER : NO. __ IN THB coURT OF cOMMON PLEAS OF CLrMBERLAND coUNTY, PENNSYLVANIA Civil TERM 03-6323 ~ _~ OATH We do solemnly swear (or affirm) that we will support, obey and. defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of ~~Esquire ~s G. 'Gault~ Esquire AWARD We, the undersigned arbih-ators, having been duly appointed and sworn (or affm'ned), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) _. (insert name if~cable~)/} Arbitrator, dissents. Date of Award: . O[l'Ol[~ '~.., ~us~_.___Confair,._Esquire NOTICE OF ENTRY OF AWJkRD Now, the If day of ~,~207 .~, at _~:_(~/~ , &.~aM., the above award .... ,,,a ~a/t~e thereof ~iven by mail to the parties or their attorneys. was entered upon ~e OOCKer anu nuu~ m~ ~- Artibitrators'compensation to be Paid upon appeal: $ 290.00 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLSTATE INSURANCE COMPANY a/s/o JODY WAGNER, CIVIL ACTION - LAW No. 03-6323 Plaintiff, DONNA STARNER, Defendant. PRAEClPE FOR ENTRY OF JUDGMENT (Jury Trial Demanded) Filed on Behalf of Defendant, Donna Starner Counsel of Record for this Party: Jeffrey C. Catanzarite, Esquire Pa. I.D. #72765 SUMMERS, MCDONNELL, WALSH & SKEEL, L.L.P. Firm #911 2400 Gulf Tower 707 Grant Street Pittsburgh, PA 15219 (412) 261-3232 #12439 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALLSTATE INSURANCE, COMPANY a/s/o JODY WAGNER, Plaintiff, DONNA STARNER, Defendant. CIVIL ACTION - LAW No. 03-6323 PRAECIPE FOR ENTRY OF JUDGMENT By: Respectfully submitted, SUMMERS, McDONNELL, WALSH & SKEEL, L.L.P. efendant JURY TRIAL DEMANDED TO THE PROTHONOTARY: Kindly enter judgment on behalf of Defendant, Donna Starner, and against Plaintiff, per the Award of the Arbitrators in the above-captioned matter. A copy of the Award of the Arbitrators is attached hereto. 15:19 SUMMERS MCDONNELL HUDOCK GUTHRIE a HOME OFF[CE N0.608 QO1 ALLSTATE II~SUI~ COMPANY a/s/o JCOY W~.4qER IN TH~ COURT OF COMMON PI~-~S CUM3~ COUNTY, NO 03-6323 , Civi~TERM We do solemnly swear (or affirm) that we will suppo~ obe~ ~nd defcmd the Colm~tution of the Uui2d Sts~cs and ~g Cons~Qn o£ this Commonwealth and tha~ we Mil discharge the du~ie~ of AWARD We. thc unders/gn~ arbitrators, having been duly appommd and ~wom (or afSrmcd), make following award: (Note: If damag~ for delto~ are awarde~d, they zhall bz ~partltely statzd.) Date ot'Hearing: was cntcrnd upon ~hc dooke~ and/notxce dmrcof I~ven by mail to the part/es or the/r attorneys. Ara[bit,&tots'compensation ~:o be Paid upon appeal: S 290.00 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Praecipe for Entry of Judgment has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 17~h day of December, ;2004: Stewart C. Crawford, Esquire Law Offices of Stewart C. Crawford 223 North Monroe Street P.O. Box E Media, PA 19063 SUMMERS, McDONNELL, WALSH & SKEEL, L.L.P. Catanzarite, Esquire ~/Att~rhey for Defendant · Do/~na Starner