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HomeMy WebLinkAbout08-6982KAROL ADAMS, : IN THE COURT OF COMMON PLEAS OF Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW NO: - 68-- O R?- w' 1 f f AMERICAN LEGION POST 421 NEWVILLE, PENNSYLVANIA, Defendant : JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS To the Prothonotary: Please issue a writ of summons in the above captioned action. Writ of Summons shall be issued and forwarded to the Sheriff of Cumberland County at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. Date: Respectfully submitted, ROMINGER & ASSOCIATES Michael O.Palermo, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 WRIT OF SUMMONS To The Above Named Defendants: American Legion Post 421 28 Shepard Road Newville, PA 17241 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. /S Prothonotary Date: By: CvG'-'? Deputy ". . 11 GREGORY E. CASSIMATIS, ESQUIRE 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 717-791-0400 Attorney I.D. # 49619 KAROL ADAMS, Plaintiff V. AMERICAN LEGION POST 421 NEWVILLE, PENNSYLVANIA Defendant ATTORNEY FOR DEFENDANT, American Legion Post 421 Newville, PA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA NO. 08-6982 CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Defendant in the above-captioned matter. Date: February 26, 2009 By: Grego assimatis, EAttorney for Defendant American Legion Post 421 Newville, Pennsylvania A ' -AV CERTIFICATE OF SERVICE AND NOW, this 26th day of February, 2009, I, Gregory E. Cassimatis, Esquire, Attorney for Defendant hereby certify that I served a copy of the within Praecipe for Entry of Appearance on this date by depositing same in the United States mail, postage prepaid, in Mechanicsburg, Pennsylvania, addressed to: Michael O. Palermo, Esquire ROMINGER & ASSOCIATES 155 South Hanover Street Carlisle, PA 17013 (Attorney for Plaintiff) By: Gregory assimatis, Esquire 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 Attorney I.D. # 49619 t 77 _ G? G (`''?? ? ? G? ? ? ? ?' .?'' v ? ? ? f ?nv?? 1J °?, e F. w '? ? °S' ro ? 1 SHERIFF'S RETURN - REGULAR CASE NO: 2008-06982 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ADAMS KAROL VS AMERICAN LEGION POST 421 MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon AMERICAN LEGION POST 421 the DEFENDANT at 0011:51 HOURS, on the 6th day of December , 2008 at 28 SHEPHARD ROAD NEWVILLE, PA 17241 by handing to MICHELLE HESS ADULT IN CHARGE a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.80 Affidavit .00 Surcharge 10.00 Postage 42 1.211Sl 3 9 . 22 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 12/08/2008 ROMINGER LAW OFFIC By: D u y Sher if of A. D. GREGORY E. CASSIMATIS, ESQUIRE 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 717-791-0400 Attorney I.D. # 49619 KAROL ADAMS ATTORNEY FOR DEFENDANT, American Legion Post 421 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Plaintiff V. No. 08-6982 CIVIL ACTION - LAW AMERICANT LEGION POST 421 Defendant : JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE A COMPLAINT TO THE PROTHONOTARY: Issue a Rule upon Plaintiff, Karol Adams, to file her complaint against Defendant, American Legion Post 421 within twenty days (20) from the date of service hereof; otherwise, judgment of non pros to be entered in accordance with Rule 1037 (a) of the Pennsylvania Rules of Civil Procedure. Date: September 21, 2009 By: Gregory assimatis, Esquire Attorney for Defendant RULE AND NOW, this 2 3,1A day of 2009, in accordance with the aforesaid Order, a Rule is issued upon Plaintiff, Karol Adams to file her complaint against Defendant, within twenty days from the date of service hereof; otherwise, judgment of non pros to be entered in accordance with Rule 1037 (a) of the Pennsylvania Rules of Civil Procedure. urtis R. Lozlg, of OF TH"(I. ni n n fiiRY 2009 SEP 23 PH 1: u 1 um. KAROL ADAMS, Plaintiffs vs. AMERICAN LEGION POST 421 NEWVILLE, PENNSYLVANIA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :NO: 08-6982 : JURY TRIAL DEMANDED 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 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 Michael O. Palermo, Jr., Esq e Attorney I.D. No. 93334 155 South Hanover Street Carlisle, Pennsylvania 17013 Tel: (717) 241-6070 Fax: (717) 241-6878 Attorney for Plaintiff KAROL ADAMS, : IN THE COURT OF COMMON PLEAS OF Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW :NO: 08-6982 AMERICAN LEGION POST 421 NEWVILLE, PENNSYLVANIA, Defendant : JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, Karol Adams, through her counsel, Michael O. Palermo, Jr., Esquire, and respectfully files the following Complaint, and in support thereof avers the following: 1. Plaintiff, Karol Adams, is an adult individual residing at 581 Youngs Church Road, Shermans Dale, Pennsylvania 17090. 2. Defendant, American Legion Post 421 Newville, Pennsylvania, (hereinafter "American Legion") is a duly licensed private club with its principal place of business being located at 28 Shepard Road, Newville, Pennsylvania 17241. 3. At all times mentioned herein, Defendant was in exclusive possession, management, and control of the private club, individually and through its employees who are acting within the course and scope of their employment by Defendant and in furtherance of Defendant's business. 4. On or about November 25, 2006, Plaintiff was a business visitor to the private club, and as Plaintiff was walking from the club to the parking lot to retrieve her camera from her vehicle she walked between two other vehicles, and as a result of the lack of lighting in the parking lot Plaintiff stumbled, and fell over an existing concrete parking block/curb/bumper, which resulted in serious injuries as set forth below. 5. The accident was caused exclusively and solely by the Defendants' negligence, carelessness, and reckless in that: A. Defendants negligence to place appropriate lighting in the parking lot for its business visitors posed an unreasonable risk of injury to plaintiff and other business visitors; B. Defendants failed to make a reasonable inspection of the parking lot which would have revealed that the lighting was not maintained in an appropriate manner. C. Defendants failed to give warning of the dangerous condition posed by the inappropriate, insufficient or non-existent lighting in the parking lot, by not making the lighting appropriate for the parking lot or taking any other safety precautions to prevent injury to the plaintiff and other business visitors. D. Defendants failed to replace and/or fix the lighting in the parking lot knowing that there were concrete parking block/curb/bumpers that could pose a dangerous situation without the appropriate lighting to Plaintiff and other business visitors. E. The lighting and parking lot layout were maintained and operated in a negligent manner. 6. Solely as a result of the defendant's negligence, carelessness and recklessness, Plaintiff sustained injuries to her right wrist, her right pinky finger, her right ring finger and damage to her teeth; all of which injuries have caused Plaintiff great pain and suffering, which may continue for an indefinite time in the future and may be permanent. 7. Solely as a result of Defendant's negligence, carelessness and recklessness, Plaintiff has and will in the future be obliged to expend monies for medicine and medical care in order to treat and help her injuries. 8. Solely as a result of Defendant's negligence, carelessness and recklessness, Plaintiff has and will in the future have difficulty attend to her usual and daily duties and employment, to her financial detriment and loss. WHEREFORE, Plaintiffs respectfully request that this Honorable Court find in favor of the Plaintiff and against the Defendants, for an amount not more than the statutory limits for compulsory arbitration, including costs of this suit and attorney's fees. Date: WO Ve' M694 3V 2u?-? Respectfully submitted, ROMINGER & ASSOCIATES nAN(2 &.47 Michael O. Palermo, Jr., q ire Attorney I.D. No. 93334 155 South Hanover Street Carlisle, Pennsylvania 17013 Tel: (717) 241-6070 Fax: (717) 241-6878 Attorney for Plaintiff KAROL ADAMS, : IN THE COURT OF COMMON PLEAS OF Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW :NO: 08-6982 AMERICAN LEGION POST 421 NEWVILLE, PENNSYLVANIA, Defendant : JURY TRIAL DEMANDED VERIFICATION I verify that the statements made in this Answer are true and correct. I understand that false statements herein are made subject to the penalties of 1818 Pa C.S. 6 4904 relating to unsworn falsification to authorities. Date: // ' .2 ?J ?Z9 ?', ro Adams, Plaintiff KAROL ADAMS, Plaintiffs vs. AMERICAN LEGION POST 421 NEWVILLE, PENNSYLVANIA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO: 08-6982 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Michael O. Palermo, Jr., Esquire, do hereby certify that I served a copy of the Complaint upon the following by FACSIMILIE and depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Gregory Cassimatis Suite 103, 499 Louise Drive Mechanicsburg, PA 17055 Fax: (717)791-0524 Respectfully submitted, ROMINGER & ASSOCIATES Michael O. Palermo, Jr., quire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff Dated: November 30, 2009 FILED---"; "`= GREGORY E. CASSIMATIS, ESQUIRE 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 717-791-0400 Attorney I.D. # 49619 ATTORNEY FOR DEFENDANT, American Legion Post 421 KAROL ADAMS Plaintiff V. AMERICAN LEGION POST 421 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 08-6982 CIVIL ACTION - LAW C- -? -r . A f"11 _ 3 C G CD PRAECIPE TO FILE STIPULATION Please file the attached Stipulation to Remove Portions of Paragraphs 5(C) and 5(E) of Plaintiff's Complaint. Date: By: Greg . Cassimatis, Esquire Attorney for Defendant r KAROL ADAMS Plaintiff V. AMERICAN LEGION POST 421 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 08-6982 CIVIL ACTION - LAW STIPULATION TO WITHDRAW PORTIONS OF PARAGRAPH 5(C) AND RE) FROM PLAINTIFF'S COMPLAINT It is hereby stipulated and agreed between Michael O. Palermo, Esquire, counsel for Plaintiff, and Gregory E. Cassimatis, Esquire, counsel for Defendant, that the language "and other safety precautions" be stricken from paragraph 5(C) of Plaintiff's Complaint and the language "and parking lot layout" be stricken from paragraph 5(E) of Plaintiff's Complaint. Date: a • 1?_2?`? By: Michael O. Palermo, quire Date: 12 _3 ?po _ By:- 2A.. - 't'regr uS$;i:uti$, E: iuirv CERTIFICATE OF SERVICE AND NOW, this 4th day of January, 2010, I, Gregory E. Cassimatis, Esquire, Attorney for Defendant hereby certify that I served a copy of the within Praecipe to File a Stipulation on this date by depositing same in the United States mail, postage prepaid, in Mechanicsburg, Pennsylvania, addressed to: Michael O. Palermo, Esquire ROMINGER & ASSOCIATES 155 South Hanover Street Carlisle, PA 17013 (Attorney for Plaintiff) By: Gregor . Cassimatis, Esquire 4999 Louise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 Attorney I.D. # 49619 ' - r C? C= LJ -n 71 c L r7l GREGORY E. CASSIMATIS, ESQUIRE ATTORNEY FOR DEFENDANT, ' 4999 Louise Drive, Suite 103 American Legion Post 421 tv Mechanicsburg, PA 17055 -r? 717-791-0400 Attorney I.D. # 49619 `-? w KAROL ADAMS IN THE COURT OF COMMON P'U, S' CUMBERLAND COUNTY, PA -_' Plaintiff c/ /? A0 et l??fARE ft-7 Eb Ft V. No. 08-6982 A WrTEV RE Pcs;aG7 © T K4 CIVIL ACTION - LAW vr_c S"r AMERICAN LEGION POST 421 7F J 4 JUCiGAJEAfP A T yc? Defendant DEFENDANT'S ANSWER WITH NEW MATTER TO PLAINTIFF'S COMPLAINT AND NOW, comes the Defendant, American Legion Post 421, by and through their counsel, Gregory E. Cassimatis, Esquire, and files the following Answer with New Matter to Plaintiff's Complaint, and in support thereof avers as follows: 1. Denied. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in paragraph 1 of Plaintiff's Complaint and the same are deemed denied and strict proof thereof demanded. 2. Admitted. 3. Admitted in part and denied in part. It is specifically denied that at the aforesaid time and place, the Defendant was in exclusive possession, management and control of the private club. On the contrary, the Defendant was not in exclusive custody and control of the private club as the Hall Room was rented to Melody Teats and Sonja Mixell. ??C ??? ?? ?? ,.??,> ?;.?`. r ??-??, y . 4. Denied. The allegation that on or about November 25, 2006, Plaintiff was a business visitor to the private club is denied as a legal conclusion to which no responsive pleading is required and the same is deemed denied. To the extent that a response is deemed required, Plaintiff was not a business visitor to the private club, but was a guest at a private party. The balance of the allegations contained in Paragraph 4 of Plaintiff's Complaint are denied pursuant to Pa.R.C.P. 1029(e). 5(A)-(E). Denied pursuant to Pa. R.C.P. 1029(e) and as a legal conclusion to which no responsive pleading is required. By way of further Answer, portions of paragraphs 5(C) and 5(E) of plaintiff's Complaint have been stricken as set forth in a Stipulation which is attached hereto, made a part hereof and marked as Exhibit "A." 6. Denied. It is specifically denied that the Defendant was negligent, careless or reckless. The balance of the allegations contained in paragraph 6 of Plaintiff's Complaint are denied pursuant to Pa.R.C.P. 1029(e) and are denied in that after reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of said averments and same are deemed denied and strict proof thereof is demanded. 7. Denied. It is specifically denied that the Defendant was negligent, careless or reckless. The balance of the allegations contained in paragraph 7 of Plaintiff's Complaint are denied pursuant to Pa.R.C.P. 1029(e) and are denied in that after reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of said averments and same are deemed denied and strict proof thereof is demanded. 8. Denied. It is specifically denied that the Defendant was negligent, careless or reckless. The balance of the allegations contained in paragraph 8 of Plaintiffs Complaint are denied pursuant to Pa.R.C.P. 1029(e) and are denied in that after reasonable investigation, the 2 Defendant is without knowledge or information sufficient to form a belief as to the truth of said averments and same are deemed denied and strict proof thereof is demanded. WHEREFORE, Defendant demands judgment in their favor and against the Plaintiff, together with costs of suit. NEW MATTER 9. Plaintiff's Complaint fails to set forth the cause of action upon which relief can be granted. 10. Plaintiff's injuries and damages, if any, were caused solely and directly as a result of the negligence, carelessness and recklessness of the Plaintiff in failing to exercise ordinary care for her own safety under the existing circumstances. 11. Plaintiff had notice and knowledge of the condition alleged to have caused the accident in question and did knowingly and willfully encounter the condition and assume the risk of any injury that could have arisen. 12. If it is determined that the Answering Defendant is liable in Plaintiff's cause of action, the Defendant avers that the Plaintiff's recovery should be eliminated or reduced in accordance with the Pennsylvania Comparative Negligence Act, 42 Pa.C.S.A. §7102. 13. Plaintiff's Complaint is barred by the applicable statute of limitations Date: By: Greg . Cassimatis, Esquire Attorney for Defendant 3 z w z 0 c? ¢ w 9 cn m c> F co no 0 O w w a 0 w U U w s cW? 4 KAROL ADAMS Plaintiff V. AMERICAN LEGION POST 421 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 08-6982 CIVIL ACTION - LAW STIPULATION TO WITHDRAW PORTIONS OF PARAGRAPH 5(C) AND 5(E) FROM PLAINTIFF'S COMPLAINT It is hereby stipulated and agreed between Michael O. Palermo, Esquire, counsel for Plaintiff, and Gregory E. Cassimatis, Esquire, counsel for Defendant, that the language "and other safety precautions" be stricken from paragraph 5(C) of Plaintiff's Complaint and the language "and parking lot layout" be stricken from paragraph 5(E) of Plaintiff's Complaint. Date: I ?• ?_2,?a? t By: Michael O. Palermo, quire Date: Foci By: Cyreg;)r . Cassimatis, Esquire 46XA,4; 4' 4bt VERIFICATION I, Bill Stouffer, a representative of the Defendant herein, verify that I am authorized to execute this Verification and verify that the facts set forth in the foregoing Answer with New Matter to Plaintiff's Complaint are true and correct to the best of my knowledge, information, and belief. To the extent that the contents of the Answer with New Matter to Plaintiff's Complaint are that of counsel, I have relied upon counsel in executing this Verification. This statement is made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: 2--1 - 091 Name: ?-4?qlgei Bill Stou r 0 . - N CERTIFICATE OF SERVICE AND NOW, this 4th day of January, 2010, I, Gregory E. Cassimatis, Esquire, Attorney for Defendant hereby certify that I served a copy of the within Answer with New matter to Plaintiffs Complaint on this date by depositing same in the United States mail, postage prepaid, in Mechanicsburg, Pennsylvania, addressed to: Michael O. Palermo, Esquire ROMINGER & ASSOCIATES 155 South Hanover Street Carlisle, PA 17013 (Attorney for Plaintiff) By: y Grego Cassimatis, Esquire 4999 Z rise Drive, Suite 103 Mechanicsburg, PA 17055 (717) 791-0400 Attorney I.D. # 49619 KAROL ADAMS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW :NO: 08-6982 • n r.,a AMERICAN LEGION POST 421 ?.. NEWVILLE, PENNSYLVANIA, ; Defendant : JURY TRIAL DEMANDED n; -T:7, C7r ; arl ANSWER TO NEW MATTER co , ; s.-.ry C,'7 'D AND NOW, comes the Plaintiff, Karol Adams, through her counsel, Michael O. ` Palermo, Jr., Esquire, and respectfully files her Answer to New Matter as follows: 9. Defendant's New Matter states a legal conclusion to which no responsive pleading is deemed required. In the event a response is required, the same is denied in accordance with Pa.R.C.P. 1029(4) and (e) and strict proof is demanded at trial. 10. Defendant's New Matter states a legal conclusion to which no responsive pleading is deemed required. In the event a response is required, the same is denied in accordance with Pa.R.C.P. 1029(d) and (e) and strict proof is demanded at trial. 11. Defendant's New Matter states a legal conclusion to which no responsive pleading is deemed required. In the event a response is required, the same is denied in accordance with Pa.R.C.P. 1029(d) and (e) and strict proof is demanded at trial. 12. Defendant's New Matter states a legal conclusion to which no responsive pleading is deemed required. In the event a response is required, the same is denied in accordance with Pa.R.C.P. 1029(d) and (e) and strict proof is demanded at trial. 13. Defendant's New Matter states a legal conclusion to which no responsive pleading is deemed required. In the event a response is required, the same is denied in accordance with Pa.R. ,.P. 1029(d) and (e) and strict proof is demanded at trial. WHEREFORE, Plaintiff respectfully request that this Honorable Court find in favor of the Plaintiff and against the Defendants, for an amount not more than the statutory limits for compulsory arbitration, including costs of this suit and attorney's fees. Respectfully submitted, ROMINGER & ASSOCIATES Date: ZOl0 1114'06 " Michael O. Palermo, , Esquire Attorney I.D. No. 93334 155 South Hanover Street Carlisle, Pennsylvania 17013 Tel: (717) 241-6070 Fax: (717) 241-6878 Attorney for Plaintiff KAROL ADAMS, Plaintiff vs. AMERICAN LEGION POST 421 NEWVILLE, PENNSYLVANIA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :NO: 08-6982 : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Michael O. Palermo, Jr., Esquire, do hereby certify that I served a copy of the Complaint upon the following by FACSIMILIE and depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Gregory Cassimatis Suite 103, 499 Louise Drive Mechanicsburg, PA 17055 Fax: (717)791-0524 Respectfully submitted, ROMINGER & ASSOCIATES IKAJ('?421& Dated: January 26, 2010 Michael O. Palermo, Jr., squire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff VERIFICATION Michael O. Palermo, Jr., Esquire states that he is the attorney for Plaintiff, Karol Adams in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: 'of U 2,blb )&- U-4 Michael O. Palermo, r., Esquire Attorney for Plaintiff • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA KAROL ADAMS •• Plaintiff CIVIL No.08-6982 v. NEWVILLE AMERICANLEGION#421 • Defendant • `t F C JURY TRIAL DEMANDED --� STATEMENT OF INTENTION TO PROCEED > N) AND NOW, comes the Plaintiff, Karol Adams, by and through her counsel and hereb;submits.. Notice of her intention to proceed with the above captioned civil matter. She respectfully requests that the Hon. David Buell remove the above captioned case from the 2013 Cumberland County Purge List forthwith. Date: Oct 20, 7-013 Michael O. Palermo,Jr., Esq. 3300 Trindle Road Camp Hill, PA 17011 (717) 635-9591 mop @palermolawoffices.com PA ID No. 93334 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA • KAROL ADAMS Plaintiff CIVIL No.08-6982 v. • NEWVILLE AMERICAN LEGION #421 • Defendant . JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 28th day of October, I hereby Certify that I served a true and correct copy of the following Notice of Intention to proceed upon Defendant in the person of their Counsel, addressed as follows: Greg Cassimatis, Esquire Counsel for Defendant 4999 Louise Drive Suite 103 Mechanicsburg, PA 17055 Date: " 4 /3 By: aft__ Michael O. Palermo,Jr., Esquire