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HomeMy WebLinkAbout08-2387I. JAMES W. GIBBS and LINDA M. GIBBS Plaintiffs V. BRANDON I. MORRIS and HARRY MORRIS Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No: 6 a- A 3 k 7 C 1 L)r 1 `fe r'k NOTICE 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717-249-3166) NOTICIA Les han demandado a usted en la corte. Se usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dins de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archhivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en conra de su persona. Sea avisado qui si usted no soe defiende, la corte tomara mmedidas y puede entrar una order contra usted sin previo aviso o notoficacion y pro cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes pars usted. LLEVE ESTA DEMANDO A US ABODAGO IMMEDIATEMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME FOR TELEFONO A LA OFICIAN CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSGUIR YASISTENCIA LEGAL. JAMES W. GIBBS and LINDA M. GIBBS Plaintiffs V. BRANDON I. MORRIS and HARRY MORRIS Defendants: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: Q - 3 FS7 COMPLAINT COUNT I - JAMES W. GIBES v. BRANDON I. MORRIS AND HARRY MORRIS 1. Plaintiffs James W. Gibbs and Linda M. Gibbs are adult individuals residing at 50 W. Keller Street, Mechanicsburg, Pennsylvania and at all times relevant aretwere husband and wife. 2. Defendants Brandon I. Morris and Harry Morris reside at 590 Lucinda Lane, Mechanicsburg, Cumberland County, Pennsylvania. 3. On July 30, 2007, Defendant Brandon I. Morris as operating a motor vehicle, owned by Defendant Harry Morris, south on Locust Point Road at which time Brandon I. Morris, acting individually and/or as agent for Defendant harry Morris, failed to obey a properly posted stop sign at the intersection of Locust Point Road and SR 174, causing an accident with a vehicle driven by Plaintiff James W. Gibbs which was traveling lawfully westbound on Route 174, causing injuries to Plaintiff James W. Gibbs and Plaintiff Linda M. Gibbs who was a passenger in the Gibbs vehicle. 4. The aforesaid accident was the direct result of the negligence of Defendant Brandon I. Moms, individually and/or as agent, servant and/or employee of the aforesaid Defendant Harry Morris, as follows: a. in failing to yield the right of way to Plaintiffs vehicle; b. in failing to observe and obey duties at a property posted stop sign; c. in failing to observe the Plaintiffs vehicle lawfully on the roadway; d. in operating his vehicle in violation of 75 Pa.C.S.A. §3323; e. in operating his vehicle too fast for the conditions of the traffic and traffic control; f. in failing to be highly vigilant at an intersection; g. in failing to apply brakes and/or negligently applying his brakes. 5. The Defendant Harry Morris was additionally negligent in: a. negligently entrusting his vehicle to Defendant Brandon I Morris; b. in failing to properly train, educate and/or supervise Defendant Brandon 1. Morris on compliance with the Pennsylvania Motor Vehicle Code; c. in failing to properly ensure compliance of Brandon I. Morris with the Pennsylvania Motor Vehicle Code; d. in failing to make certain that Brandon I. Morris knew and was familiar with the vehicle he was operating and to make certain he was familiar with the roads and restrictions of his route of travel. 6. As a result of the aforesaid accident, the Plaintiff Jams W. Gibbs suffered severe and permanent injuries which include, but are not limited to, the following: Acute cervical strain Right shoulder traumaicontusion Bilateral forearm trauma Chest traumalecchymosis Trauma to right hand and fingers Severe shock to nerves and nervous system 7. As a result of the aforesaid accident, the Plaintiff James W. Gibbs suffered, and in the future will suffer, pain, suffering, loss of life's pleasures, consortium (for injuries to Plaintiff Linda M. Gibbs), inconvenience, miscellaneous expenses (rental expense - $224.58). 8. Plaintiff James W. Gibbs's medical expenses (reimbursed) include: Reimbursed Expenses Holy Spirit Hospital ................................... $1,308.00 Yellow Breeches EMS ................................... 435.27 Christopher Bero, MD .................................... 351.00 Orthopedic & Spine Physical Therapy ..................... 2,159.00 Walnut Bottom Radiology .................................. 60.00 Quantum Imaging .................................. 31.87 Total Medical Expenses ............................ $4,345.14 2 9. As a result of the aforesaid accident, Plaintiff Linda M. Gibbs suffered severe and permanent injuries which include, but are not limited to, the following: Left hand traumalcontusion and fingers Acute cervical strain Lumbar strain Chest trauma Musculoskeletal contusions Severe shock to nerves and nervous system Abrasion of chin 10. As a result of the aforesaid accident, Plaintiff Linda M. Gibbs suffered, and in the future will suffer, pain, suffering, loss of life's pleasures, consortium (for the injuries to Plaintiff James W. Gibbs), inconvenience and miscellaneous expenses. 11. Plaintiff Linda M. Gibbs medical expenses (reimbursed) include: Holy Spirit Hospital ................................... $5,652.05 West Shore EMS ....................................... 956.25 Quantum Imaging ....................................... 485.00 Christopher Bero, MD .................................... 210.00 Walnut Bottom Radiology ............................... 1,763.00 Moffitt Heart & Vascular Group ............................. 800.00 Orthopedic & Spine Physical Therapy ..................... 2,235.00 Pharmacy ....................................... 78.64 Total Medical Bills ............................... $12,179.94 WHEREFORE, Plaintiff Jams W. Gibbs demands judgement against the Defendants individually, severally and/or jointly in an amount in requiring arbitration plus costs, interest and delay damages. 3 COUNT 11- LINDA M. GIBBS v. BRANDON I. MORRIS AND HARRY MORRIS 12. Paragraphs 1-11 are incorporated herein by reference and made a part hereof. WHEREFORE, Plaintiff Linda M. Gibbs demands judgment against the Defendants individually, severally and/or jointly in an amount requiring arbitration limit costs, interest and delay damages. Dated: 101 John B. Iancke, Esq., ID No. 07212 Mancke, , agner, Spreha & McQuillan 2233 N. Front Street, Harrisburg, PA 17110 717-234-7051, Attorney for Plaintiffs 4 VERIFICATION We hereby verify that the statements made in this document are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities. %v Date mes W. Gibbs Date Linda M. Gibbs 5 Cil W N C, IN THE COURT O? COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES W. GIBBS nd LINDA M. GIBBS, CIVIL DIVISION Plain ills, NO.: G.D -o8-002387 VS. BRANDON I. MO MORRIS PRAECIPE FOR APPEARANCE and HARRY (JURY TRIAL DEMANDED) Filed on Behalf of Defendants, Brandon I. Morris and Harry Morris. Counsel of Record for this Parry: Stephen J. Summers, Esquire PA I.D. #40213 SUMMERS, MCDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. Firm #911 707 Grant Street Suite 240o, Gulf Tower Pittsburgh, PA 15219 (412) 261-3232 16241 IN THE COURT OP COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES W. GIBBS Plain vs. BRANDON I. MO MORRIS LINDA M. GIBBS, S and HARRY ts. CIVIL DIVISION NO.: G.D -08-002387 PRAECIPE FOR APPEARANCE TO: THE PRO' Kindly enter law firm of S Defendants, Br, NOTARY Appearance of the undersigned, Stephen J. Summers, Esquire, of the McDonnell, Hudock, Guthrie & Skeel, L.L.P., on behalf of I. Morris and Harry Morris, in the above case. Respectfully submitted, Summers, McDonnell, Hudock, Gut ie & S , LLP s/s: Stephen J. Summers, Esquire Counsel for Defendant CERTIFICATE OF SERVICE I hereby c?rtify that a true and correct copy of the foregoing Praecipe for Appearance has been served via first-class U.S. mail, postage prepaid, this 21st day of April, 2008, addressed as follows: John B. Mancke, Esquire Mancke, Wagner, Spreha & McQuillan 2233 N. Front Street Harrisburg, PA 17110 Respectfully submitted, ll, Hudock, Summers, Y_""P'T7 Gut rie & S s/s: S ephen J. Summers, Esquire Counsel for Defendant 'a l r?= IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES W. GIBBS and CIVIL DIVISION LINDA M. GIBBS, Plaintiff, No. 08-2387 V. PRAECIPE FOR SUBSTITUTION OF ATTORNEY BRANDON I. MORRIS and HARRY MORRIS, (Jury Trial Demanded) Defendants. Filed on Behalf of Defendants Counsel of Record for This Party: Jeffrey C. Catanzarite, Esquire PA I.D.#: 72765 Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P. Firm No.: 911 Gulf Tower, Suite 2400 707 Grant Street Pittsburgh, PA 15219 (412) 261-3232 #16241 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES W. GIBBS and CIVIL DIVISION LINDA M. GIBBS, Plaintiff, No. 08-2387 V. BRANDON I. MORRIS and HARRY MORRIS, Defendants. PRAECIPE FOR SUBSTITUTION OF APPEARANCE TO THE PROTHONOTARY: Kindly substitute the appearance of Jeffrey C. Catanzarite, Esquire, in place of the appearance previously entered by Stephen J. Summers, Esquire, on behalf of the Defendants, Brandon I. Morris and Harry Morris, in the above case. JURY TRIAL DEMANDED Respectfully submitted, By: Summers, McDonnell, Hudock, Ggthrie & Skeel, L.L.P. Jeff,hy C. Catanzarte, Esquire Co nsel for Defendants CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within Praecipe for Substitution of Appearance was served upon the following counsel of record on the 2nd day of May, 2008, by U.S. First Class Mail, postage prepaid: John B. Mancke, Esquire Mancke, Wagner, Spreha & McQuillan 2233 N. Front Street Harrisburg, PA 17110 Summers, McDonnell, Hudock, R6athxie & Skeel, L.L.P. By: Yfrey C. Catanzarite, Esquire ounsel for Defendants c n r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES W. GIBBS and LINDA M. GIBBS, CIVIL DIVISION Plaintiffs, V. BRANDON I. MORRIS and HARRY MORRIS, Defendants. TO: PLAINTIFFS You are hereby notified to file a written response to the closed Answer and New Matter within twenty (20) d s f m service hereof or a judgment may be entered SUM RS, MWeNNELLAWDOCK, GUTHRIE & EEL c• No. 08-2387 ANSWER AND NEW MATTER (Jury Trial Demanded) Filed on Behalf of Defendants Counsel of Record for This Party: Jeffrey C. Catanzarite, Esquire PA I.D.#: 72765 Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P. Firm No.: 911 Gulf Tower, Suite 2400 707 Grant Street Pittsburgh, PA 15219 (412) 261-3232 6241 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES W. GIBBS and CIVIL DIVISION LINDA M. GIBBS, Plaintiffs, No. 08-2387 v. BRANDON I. MORRIS and HARRY MORRIS, Defendants. ANSWER AND NEW MATTER Defendants, Brandon I. Morris and Harry Morris, by and through their attorneys, Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P., and Jeffrey C. Catanzarite, Esquire, file the following Answer and New Matter: 1. ANSWER COUNT I - JAMES W. GIBBS v. BRANDON I. MORRIS AND HARRY MORRIS 1 . After reasonable investigation, the Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 1 and therefore, said allegations are denied and strict proof thereof is demanded at the time of trial. 2. Admitted. 3. It is admitted that Defendant, Brandon I. Morris, was operating a vehicle owned by Defendant, Harry Morris, and was involved in a motor vehicle accident with a vehicle driven by Plaintiff, James W. Gibbs, on the date, time and place in question. The remaining allegations of Paragraph 3 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. 4. Defendant, Brandon I. Morris, admits that he negligently operated a motor vehicle on the date, time and place in question. The remaining allegations of Paragraph 4 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. 5. The allegations of Paragraph 5 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. 6. The allegations of Paragraph 6 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. The allegations of Paragraph 7 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. 8. After reasonable investigation, the Defendants are 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. 10. The allegations of Paragraph 10 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. 1 1 . After reasonable investigation, the Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 11 and therefore, said allegations are denied and strict proof thereof is demanded at the time of trial. COUNT II - LINDA M. GIBBS v. BRANDON I. MORRIS AND HARRY MORRIS 12. The allegations of Paragraphs 1 through 11 are herein incorporated by reference and made a part hereof. WHEREFORE, Defendants, Brandon I. Morris and Harry Morris, demand judgment in their favor and against Plaintiffs. II. NEW MATTER 13. Paragraphs 1 through 12 are herein incorporated by reference. 14. The Plaintiffs' claims are subject to the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law and the Defendants assert as an affirmative defense all rights, privileges and/or immunities accruing pursuant to said statute. 15. The Plaintiffs' claims are barred by the applicable statute of limitations. WHEREFORE, Defendants, Brandon I. Morris and Harry Morris, demand judgment in their favor and against Plaintiffs. JURY TRIAL DEMANDED Respectfully submitted, Summers, McDonnell, Hudock, Iawthrie & Skeel, L.L.P. By: :frey C: Catanzarite, Esquire unsel for Defendants 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. Date: S / Q o randon I. Morris, Defendant #16241 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. Date: Y G b Harry Morris, Defendant ` #16241 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within Answer and New Matter was served upon the following counsel of record on the ,N day of 1 / i , 2008, by U.S. First Class Mail, postage prepaid: John B. Mancke, Esquire Mancke, Wagner, Spreha & McQuillan 2233 N. Front Street Harrisburg, PA 17110 Summers, McDonnell, Hudock, OTi'thrie & Skeel, L.L.P. By: c_ J ey C. Catanzarite, Esquire ounsel for Defendants SHERIFF'S RETURN - REGULAR CASE NO: 2008-02387 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GIBBS JAMES W ET AL VS MORRIS BRANDON I ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon AM1-1n T-) -r C, nn T NTT %n NT T the DEFENDANT , at 2049:00 HOURS, on the 14th day of May , 2008 at 590 LUCINDA LANE MECHANICSBURG, PA 17055 by handing to HARRY MORRIS, FATHER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge So Answers: 18.00 33.00 .59 10.00 R. Thomas Kline .00 11.59 05/15/2008 MANCKE WAGNER SPREHA Sworn and Subscibed to before me this of By. day A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-02387 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GIBBS JAMES W ET AL VS MORRIS BRANDON I ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MnT?PTR LTAPPV the DEFENDANT , at 2049:00 HOURS, on the 14th day of May 2008 at 590 LUCINDA LANE MECHANICSBURG, PA 17055 by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 00 10.00 R. Thomas Kline .00 ? 16.00 05/15/2008 MANCKE WAGNER SPREHA Sworn and Subscibed to By: before me this day of A.D. JAMES W. GIBBS and : IN THE COURT OF COMMON PLEAS LINDA M. GIBBS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : NO: 08-2387 CIVIL DIVISION BRANDON I. MORRIS and HARRY MORRIS Defendants PLAINTIFFS' ANSWER TO NEW MATTER Paragraphs 1-12 of the Plaintiffs' Complaint are incorporated herein by reference. 14. Paragraph 14 is denied. The Plaintiffs' claims are not subject to any limitations under the Financial Responsibility Law as the Plaintiffs had full tort coverage at the time of the accident. 15. Paragraph 15 is denied as Plaintiffs' claims are not barred by the applicable statute of limitations. WHEREFORE, Plaintiffs demand judgment inVar favor against the defendants. John B. Mdpcke, Esq., ID No. 07212 Mancke, Wagner, Spreha & McQuillan 2233 N. Front Street, Harrisburg, PA 17110 717-234-7051, Attorney for Plaintiffs Dated: 5-Aq,pg VERIFICATION I hereby verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities. L? ''; 2- Date VERIFICATION I hereby verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities. Date CERTIFICATE OF SERVICE 1, John B. Manske, a partner of the law firm of MANCKE, WAGNER, SPREHA & McQUILLAN do hereby certify that I am this day serving a copy of the foregoing document to the following person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by U.S. First Class Mail, postage prepaid and addressed as follows: Jeffrey C. Catanzarite, Esq. Summers McDonnell Hudock Guthrie & Skeel Gulf Tower, Suite 2400 707 Grant Strut Pittsburgh, PA 1519 DATE: 5-Aa-06 John B. M , Esc/ MANCKE, WA NER, SPREHA & McQUILLAN 2233 N. Front t Harrisburg, PA 1 110 t" 7-r JAMES W. GIBBS and LINDA M. GIBBS Plaintiffs V. BRANDON I. MORRIS and HARRY MORRIS Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2387 Civil 2008 RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in the Fallowing form: PETITION POR APPOINTMENT OF ARBITRATORS TO THE HONORARLE, THE JUDGES OF SAID COURT: John B. Mancke , counsel for the plaintiff/dW m the above action WJWVM& respcctfully represents that 1. The above-captioned action (A?(:rdflro A) is (&) at issue. 2. The claim of plaintiff in the action is S unliquidated but $50,000 or less The camtaclairm of the defendant in the action is NIA The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitratm: Summers McDonnell Hudock Guthrie & Skeei Law Firm WHEREFORE, your petitioner prays your whom the case shall be submitted. ORDER OF Court to appoint three (3) arbitrators to B. h1Wcke, Esq., ID No. 07212 ke Wagner Spreha & McQuillan N. Front St., Harrisburg, PA 17110 AND NOW, , 200 , in consideration of the foregoing petition, Esq., and Esq., and Esq., are appointed arbitrators in the above captioned action (or actions) as prayed for. By the Court, EDOAR B. BAYLEY a 0 PZ v.p F? 71 ?p?.JP ww..w JAMES W. GIBBS and LINDA M. GIBBS Plaintiffs V. BRANDON I. MORRIS and HARRY MORRIS Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2387 Civil 2008 RULE 1312-1 The Petition for Appointment of Arbitrators sbaU be substantially in the Following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE BUDGES OF SAID COURT: John B. Mancke counsel for the plaintiffldOW01M m the above action 44Klfi NII& res m"y repmmo that: 1. The above-cafiorad action (&GYd") is (") at issm. 2. The claim of plaintiff in the action is $ unliquidated but $50,000 or less 1be eamta?elaim of the defendant in the action is N/A , The following attarneYs ano interested in the case(s) as counsel or are ofberwise disqualified to sit as arbitrators: Summers McDonnell Hudock Guthrie & Skeel Law Firm WHEREFORE, your petitiow prays your whom the cane shall be mA minted. ORDER OF AND NOW, petition, Esq., and captioned a6Eion (or actions) as praayed for. Court to appoint twee (3) ar69itratoars to B. k cke, Esq., ID No. 07212 ke Wagner Spreha & McQuillan N. Front St., Harrisburg, PA 17110 200 8 , in consideration of the foregoing Esq., and OV4*w. -Esq., are appointed 'trators in the ove By the EDOAR B. BAYLEY / J ?Aj CL. n CO L.1. , T ry??y A.r , IS. y? 00 O CD r.` v 314 JAMES W. GIBBS AND LINDA M. GIBBS, PLAINTIFF V. BRANDON I. MORRIS AND HARRY MORRIS, DEFENDANTS AND NOW, this COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 08-2387 CIVIL TERM ORDER OF COURT ?i0 day of November, 2008, the appointment of Maria P. Cognetti, Esquire, as the chairman on the Board of Arbitrators in the above- captioned cases, IS VACATED. James D. Hughes, Esquire, is appointed in her place. By James D. Hughes, Esquire Edgar B. Bayley, J. Court Administrator - :sal 0oe7 mz.i LL ?.. ?::.? _? ? ? ,,,_ -- __? ? ? ???? e•? ..? `'- ? C.- ?..) ?; j ,`? JAMES W. GIBBS, ET AL., COURT OF COMMON PLEAS OF PLAINTIFFS CUMBERLAND COUNTY, PENNSYLVANIA V. BRANDON MORRIS, ET AL., DEFENDANTS 08-2387 CIVIL TERM ORDER OF COURT AND NOW, this L%J?'" day of December, 2008, the appointment of James Hughes, Esquire, as the chairman on the Board of Arbitrators in the above- captioned cases, IS VACATED. Taylor P. Andrews, Esquire, is apppjnted in his place. By the Edgar B. Bayley, J. Xylor P. Andrews, Esquire Court Administrator S :sal - U ) t.u 5 LL- r3 a G, L ?. - ..ate t. y . FM ? N ? JAMES W. GIBBS and LINDA M. GIBBS Plaintiffs V, BRANDON I. MORRIS and HARRY MORRIS Defendants To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO: 08-2387 CIVIL DIVISION PRAECIPE TO DISCONTINUE Please mark the above-captioned case settled, discontinued and ended. submitted, John BV?ul?ke, Esq., ID No. 07212 h a .%,lWagner, Spreha & McQuillan 2233 N. Front Street, Harrisburg, PA 17110 717-234-7051, Attorney for Plaintiffs Dated: February 2, 2009 c? >^„ -_ ? ::: _; : ? ._., :: -;..? ;.>: r;., : . JAMES W. GIBBS AND IN THE COURT OF COMMON PLEAS OF LINDA M. GIBBS, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFFS V. BRANDON I. MORRIS AND HARRY MORRIS, DEFENDANTS 08-2387 CIVIL TERM ORDER OF COURT AND NOW, this V-kk- day of February, 2009, the appointment of a Board of Arbitrators in the above-captioned case, IS VACATED. Taylor P. Andrews, Esquire, Chairman, shall be paid the sum of $50.00. By the C Edgar B. Bayley, J. Taylor P. Andrews, Esquire - ?p matLL 7 Court Administrator _ eCy ? L7CECL ;-) V1, LC . sal 02` 5?Og L"I " n >- [V cr CA- [L Co = tw G? cr% C= j {