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HomeMy WebLinkAbout09-0105IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA RAPHAEL K. CHIEKE 4146 Beaufort Hunt Drive Harrisburg, PA 17110, Plaintiff V. LADE THRUSH 482 Beech Tree Street Shippensburg, PA 17257, Defendant CIVIL ACTION AT LAW . Case No. ~q ~ ~/l~ ~ C' ~ ~~ / ~IYWI CIVIL ACTION - PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Kindly issue summons in the above case. Writ of Summons shall be issued and Date: 1 !$ IZ©Oq SUMMONS IN CIVIL ACTION to the Sheriff for service. ~~~ Print ame: ~~C Attorn r: ~p,~ Address: Telephone: Supreme Court ID NO: To: Lane Thrush, 482 Beech Tree Street, Shippensburg, PA 17257 You are hereby notified that RAPHAEL K. CHIEKE has commenced an action against you. DATE: ~~~~ Curtis R. Long Prothonotary or Clerk BY: ,~S/ ~/.~Y~/.f ~ ~~1~ Deputy ~ ~~ /~~~~ ~~~~ ~ ~ ~ ~ , ,. ~ ~ ` ~ ~, ~ ~4 ~'' ~ ~~~, ~ t~~i ~ ~ ~ ~ ~ ~ ~- ~~ Johnson, Duffie, Stewart 8~ Weidner By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com RAPHAEL K. CHIEKE, Plaintiff v. LANE THRUSH, Defendant NOTICE TO PLEAD TO: Raphael K. Chieke c/o Sheri D. Coover, Esquire 44 South Hanover Street Carlisle, PA 17013 NO. 09-0105 CIVIL TERM CIVIL ACTION -LAW JURY TRIAL DEMANDED AND NOW, this ~~day of May, 2010, you are hereby notified to plead responsively within twenty (20) days of the date of service hereof, or judgment may be entered against you. JOHNSON, DUFFIE, STEWART & WEIDNER :400224 ZQIO lif't` 13 i''~°~ 3~ U6 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA B' Jeff rson J. Shi man Johnson, Duffle, Stewart 8~ Weidner By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com RAPHAEL K. CHIEKE, Plaintiff Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-0105 CIVIL TERM v. LANE THRUSH, Defendant CIVIL ACTION -LAW JURY TRIAL DEMANDED DEFENDANT'S ANSWER AND NEW MATTER TO PLAINTIFF'S COMPLAINT AND NOW, comes the Defendant, Lane Thrush, by and through his counsel, Jefferson J. Shipman, Esquire and Johnson, Duffle, Stewart & Weidner, and files the following Answer and New Matter to Plaintiff's Complaint: 1. Admitted upon information and belief. 2. Admitted. 3. Admitted in Part. Denied in Part. It is admitted that on or about January 10, 2007, the Plaintiff was driving his vehicle at some location behind Defendant's vehicle on Cedar Cliff Road in Camp Hill. After a reasonable investigation, Mr. Thrush is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of paragraph 3 and the same are therefore denied. 1 Y 4. Denied. It is specifically denied that Mr. Thrush moved to the extreme left side of the road and signaled that he was going to turn left. 5. Admitted in Part. Denied in Part. It is admitted that the Plaintiff made an attempt to pass the Thrush vehicle. After a reasonable investigation, Mr. Thrush is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of paragraph 5 and the same are therefore denied. 6. Admitted in Part. Denied in Part. It is admitted only that there was contact made between the vehicles. The remaining averments of paragraph 6 are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. 7. Admitted. 8. Denied. The averments contained in paragraph 8 are in part conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. The remaining averments of paragraph 8 are denied as stated. 9. Denied. After a reasonable investigation, Mr. Thrush is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 9 and the same are therefore denied and strict proof is demanded at the time of trial. 10. Denied. After a reasonable investigation, Mr. Thrush is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 10 and the same are therefore denied and strict proof is demanded at the time of trial. e 11. Denied. After a reasonable investigation, Mr. Thrush is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 11 and the same are therefore denied and strict proof is demanded at the time of trial. 12. Denied. After a reasonable investigation, Mr. Thrush is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 12 and the same are therefore denied and strict proof is demanded at the time of trial. 13. Denied. After a reasonable investigation, Mr. Thrush is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 13 and the same are therefore denied and strict proof is demanded at the time of trial. 14. Denied. After a reasonable investigation, Mr. Thrush is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 14 and the same are therefore denied and strict proof is demanded at the time of trial. 15. Denied. After a reasonable investigation, Mr. Thrush is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 15 and the same are therefore denied and strict proof is demanded at the time of trial. 16. Denied. After a reasonable investigation, Mr. Thrush is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 16 and the same are therefore denied and strict proof is demanded at the time of trial. 17. Denied. After a reasonable investigation, Mr. Thrush is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 17 and the same are therefore denied and strict proof is demanded at the time of trial. 18. Denied. After a reasonable investigation, Mr. Thrush is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 18 and the same are therefore denied and strict proof is demanded at the time of trial. 19. Denied. After a reasonable investigation, Mr. Thrush is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 19 and the same are therefore denied and strict proof is demanded at the time of trial. 20. Denied. After a reasonable investigation, Mr. Thrush is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 20 and the same are therefore denied and strict proof is demanded at the time of trial. 21. Denied. The averments contained in paragraph 21 are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. 22. Denied. The averments contained in paragraph 22 are in part conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. After a reasonable investigation, Mr. Thrush is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of paragraph 22 and the same are therefore denied and strict proof is demanded at the time of trial. WHEREFORE, Defendant Lane Thrush respectfully requests that judgment be entered in his favor and that Plaintiffs Complaint be dismissed with prejudice. NEW MATTER 23. That the Plaintiffs alleged cause of action may be barred in whole or in part by the provisions of the Motor Vehicle Financial Responsibility Law. 24. That if Mr. Thrush is found to be negligent, which is denied, then in that event, any such negligence was not a factual cause of any injury to the Plaintiff. 25. That the Plaintiffs alleged injuries may have been preexisting. 26. That the Plaintiffs alleged injuries may have been caused by third parties or entities not presently involved in this action. 27. That the Plaintiff himself was comparatively negligent. 28. That the Plaintiffs own negligence included, without limitation, the following: a. Attempting to pass the Defendant on the right.; b. Driving too fast for conditions; c. Failing to be attentive to the Defendant's vehicle; and d. Driving in a careless and reckless manner. 29. That the Plaintiffs own comparative negligence was a factual cause of the accident and Plaintiffs alleged injuries. 30. That the Plaintiff failed to state a cause of action for punitive damages. WHEREFORE, Defendant Lane Thrush respectfully requests that judgment be entered in his favor and that Plaintiff's Complaint be dismissed with prejudice. JOHNSON, DUFFIE, STEWART & WEIDNER Jeffer n J. Ship an Attorney I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Date: / 2 ~ d Attorneys for Defendant VERIFICATION The undersigned says that the facts set forth in the foregoing document are true and correct. This verification is made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsifications to authorities. _. /" Lane Thrush Dated: S 6 :400224 CERTIFICATE OF SERVICE AND NOW, this ~~~day of May, 2010, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Sheri D. Coover, Esquire 44 South Hanover Street Carlisle, PA 17013 JOHNSON, DUFFIE, STEWART & WEIDNER By: 2` ~ ~ n i~~' Mi helle H. Spangler :400224 " s Johnson, Duffie, Stewart ~ Weidner By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761 X540 jjs c~Di jdsw.com RAPHAEL K. CHIEKE, Plaintiff v. LANE THRUSH, Defendant TO: Sheri D. Coover, Esquire 44 South Hanover Street Carlisle, PA 17013 (~ Attorneys for Defendant -~:,;, ~ ~ N i .: ? - _ c:~ -~~ <a~ r C ; ~- --- n t'Z ~ .' ~..~ 4.1~ .:. q..' L ~ pay R '^S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-0105 CIVIL TERM CIVIL ACTION -LAW JURY TRIAL DEMANDED As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: (1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoenas attached thereto, was mailed, via Certified Mail, or delivered to each party at least twenty days prior to the date on which the subpoenas were sought to be served; (2) A copy of the Notice of Intent including the proposed subpoenas, is attached to this Certificate; (3) No objection to the subpoenas has been received, the waiting period for objections was waived; and (4) The subpoenas to be served are identical to the subpoenas attached to the Notice Of Intent. JOHNSON, DU FIE, STEWART & WEIDNER By: Je erson J. Ship an, Esquire A orney I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Date: ~/~ ~ `~~ Attorneys for Defendant CERTIFICATE OF SERVICE ~- AND NOW, this l~¢ day 2010, the undersigned does hereby certify that he did this date serve a opy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Sheri D. Coover, Esquire 44 South Hanover Street Carlisle, PA 17013 JOHNSON, DUFFIE, STEWART & WEIDNER Je erson J. S pman, Esquire Johnson, Duffle, Stewart 8~ Weidner By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs cLDjdsw.com RAPHAEL K. CHIEKE, Plaintiff v. LANE THRUSH, Defendant Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-0105 CIVIL TERM CIVIL ACTION -LAW JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Sheri D. Coover, Esquire 44 South Hanover Street Carlisle, PA 17013 PLEASE TAKE NOTICE that Defendant intends to serve three (3) subpoenas identical to the ones that are attached to this notice. You have twenty (20) days from the date listed below in which to file of records and serve upon the undersigned objections to the subpoenas. If no objections are made, the subpoenas may be served. JOHNSO. , DUFFIE, STEWART & WEIDNER By: J erson J. Shipman, Esquire A orney I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Date: (~ I t~ jj ~ Attorneys for Defendant CERTIFICATE OF SERVICE AND NOW, this y~ day of ~Lc..V1 ~ 2010, the undersigned does hereby certify that he did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, certified, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Sheri D. Coover, Esquire 44 South Hanover Street Carlisle, PA 17013 JOHNSON, DUFFIE, STEWART & WEIDNER fferson J. Shipman, Esquire COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Raphae! K: Chieke; Plaintiff vs. Lane Thrush, Defendant File No. 09-0105 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Family Medical Care (Name of Person or Entity) Within hwenty (ZO) days afier service of this'subpoena, you are ordered by the court to produce the fallowing docun'rents or things: Any and all medical records. reports, dia~tnostic test results, correspondence office notes reaardina Raphael Chieke DOB: 9/13151 SSN: XXX-XX-5376 at Johnson. Duffle Stewart ~ V4'eidner. 301 Market Street. P.O. Box 109. Lemovne. PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail tc produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THiS SUBPOENA~WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: Jefferson J. Shipman. Esquire 301 Market Street Lemovne. PA 17043 717-761-4540 51785 Defendants ' ~ ~ THE COURT: onotary/Cle k, Civil Division Deputy DATE: ~- S~ 02~/~ Seat of a Court (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Raphael K. Chieke, Plaintiff vs. Lane Thrush, Defendant File No. 09-0105 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Property &. Casual InsuFance Comaany`of,liartford (Name of Person or Entity) Wit.'~iri.t_~rer~ty (20) days after service of`this subpoena, you are ordered by the court to produce the following cJc~cuMents• or things: Any and all claims records; vehicle repair estimates. vehicle photograahs, nnedocal records aertainin4 to Claim #.YHTAF02756 Policy # 55 PHF932953-361302. accident date 1110107 re~ardina Raphael Chieke DOB: 9113151 SSN: XXX-XX-5376 at Johnson, Duffle: Stewart & Weidner, 301 Market Street, P.O. Box 109, Lemovne, PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena., together with the certificate of compliance, to the party making this request at the address listed above: You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS~SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Jefferson J. Shipman, EsQUire ADDRESS: 301 Market Street ' ~ ~ Lemovne. PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendants ~iY T. ` CCURT: ' ~ Pr onotary/Clerk, lull Division Deputy DATE: ~ ' 6 °~ ~'~~ Seal of th Court (Elf. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Raphael K. Ghieke, Plaintiff vs. Lane Thrush, Defendant File No. 09-0105 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Mladden Phvsicl Thera (dame of Person or Entity) Witli~rl~tvrent (20) days after service of this subpoena, you are ordered by the court to produce the fat{owing documents ~nr things: Any and all medical records: reports, diagnostic test results. correspondence, physical therapy records, office notes regarding Raphael Chieke DOB: 9/13/51 SSN: XXX-XX-5376 at Johnso~i. Duffle. Stewart 8~ Weidner. 301 Market Street. P.O. Box 109, Lemoyne, PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the' party making this request at the address listed above. You. have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Jefferson J. Shipman. Esquire ADDRESS: 301 Market Street Lemovne. PA 17043 TELEPFfONE: ~ 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendants DATE: at-~, p~-~~d Seal of th Court BY T OURT: Pro notary/Clerk, vil Division Deputy (Eff. 7/97) RAPHAEL K. CHIEKE Plaintiff IN THE COURT OF COMMON PLEA I-OF- CUMBERLAND COUNTY, PENN SYL ji 6YIA-n ? NO. 09-0105 CIVIL TERM 2 CGQ Z VS. LANE THRUSH 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 JUDGES OF SAID COURT: Jefferson J. Shipman , counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $ 50,000 or less The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Sheri D. Coover, Esquire, 44 South Hanover Street, Carlisle, PA 17013 Jefferson J. Shipman, Esquire, 301 Market Street, Lemoyne, PA 17043 WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. ?® nu nn Pd af4v spectfully submitted, &# 35€O 8 1??' LPYL yt_et - a Ass b 7- e son J. Shipman ORDER OF COURT AND NOW, petition, Esq., and captioned action (or actions) as prayed for. 200 , in consideration of the foregoing Esq., and Esq., are appointed arbitrators in the above By the Court, Kevin A. Hess, P.J. RAPHAEL K. CHIEKE Plaintiff IN THE COURT OF COMMON PLEA2-_OF!r I- = r. , CUMBERLAND COUNTY, PENN SYLjj IA-+1 tR n -i NO. 09-0105 CIVIL TERM 4 ?c C) vs. LANE THRUSH 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 JUDGES OF SAID COURT: Jefferson J. Shipman , counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $ 50,000 or less The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Sheri D. Coover, Esquire, 44 South Hanover Street, Carlisle, PA 17013 Jefferson J. Shipman, Esquire, 301 Market Street, Lemoyne, PA 17043 WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. w?t?a?,oo 14 a14Y . -`Wespectfully submitted, j58 O 8 ? ASS l??I e son J. Shipman ORDER OF COURT AND NOW, , 200 , in consideration of the fo petition, , Esq., and F. A 64 Esq., and Esq., are appointed arbitrators in the above captioned action (or actions) as prayed for. By the C / ilk -NNd `"? ?"' '?! r?? ? •? ?)"Y ? f U? ? J?`-t-FerSOh ? J?•pMQp evin A. Hess, P.J. i? ? !, 8 ? zlps )09-i- Plaintiff S? Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No:-??5 Civil Action - Law. 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 ommonwealth and that we will discharge the duties of our office with fidelity. A V Signature Signature Signature ??w Ate, Name (Chairman) -DOVC?1?5 1 ?J -1CE Law Firm LA 2 Address c USA qf\ `7013 City, Zip ICI tht L- S6Mfjcr Name Law Firm 2ygew is 4 Address ,CA I two City, Zip Name Law Firm Address City, Zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the ? following award: , (Note: If damages for del] are awarded, they hall be eparat?ely?state . Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: (Chairman) Date of Award: Notice of Entry of Award Now, the ! 7 day of 320 at /.?% VI , .M., the above award was entered upon the docket and notice th of given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ .fin - 6'? 1?j Prothono Deputy _ i. Pf •: •1 P i f i ;.J ?? i AU'r 1 7 PM 12' MBEkLA-u " its-r-?'?,' -`? ? i _J Jbl •/-?Nll?l p r ?''S? d 1 f'i 1 U (. l ro E`'r Op II e's <iV,. jell 5/? //,/ )?k/l Johnson, Duff ie, Stewart & Weidner By: Sarah E. Hoffman I.D. No. 307612 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com RAPHAEL K. CHIEKE, Plaintiff v. LANE THRUSH, Defendant Z'41lZ JA 24 APB II: I;UM8r-_RL",hD G 11 Attorneys for Defendant PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-0105 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO ENTER JUDGMENT AND NOW, this rd day of January, 2012, no appeal having been taken from the Arbitrators' Award, attached hereto as Exhibit A, in the above captioned matter, please enter judgment on the award in favor of Defendant Lane Thrush and against Plaintiff Raphael K. Chieke. JOHNSON, DUFFIE, STEWART & WEIDNER By: Awt? Sarah E. H an JUDGMENT AND NOW, this day of 2012, judgment is entered as above requested in favor of Defendant Lane Thrush and against Plaintiff Raphael K. Chieke. r David D. Bell, PROTHONOTARY . 5d UGC A4 f By: UE COPY FROM RD nd pta- as -a le ? a In lUbMilul. --9 - U T ' 0 C??tom( Q ???S and the seal MdLrrp? isie, Pa. :474082 rotho tary FF) Plaintiff Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No.Z?n- Civil Action - Law. Oath We do solenmly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this ommonwealth and that we will discharge the duties of our office with fidelity 2 ----- Signature Signature Signature Name (Chairman) Name Name S- L W-WA Law Firm Law Firm Law Firm Address Address Address City, Zip City, Zip City, Zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for del are awarded, the hall be gep:rately state I'A L J S? Arbitrator, dissents. (Insert name if applicable.) Date of Hearing:] Rl- ??) (Chairman) Date of A xard: ) - Notice of Entry of Award Now, the / 7 day of , 20 at /"o ,M., the above award was entered upon the docket and notice thetqof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ - - ZSD - L Prot ono E COPY FROM E RD Deputy In Testimony whereof, I here unto set my hand f` y r ; and the seal of said Court at Carlisle, Pa. ° a j . , This. /Z _ day of .20 Prothonotary 4 Ji Exhibit A CERTIFICATE OF SERVICE ANL> NOW, this o??f day of January, 2012, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, First Class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Sheri D. Coover, Esquire 44 South Hanover Street Carlisle, PA 17013 JOHNSON, DUFFIE, STEWART & WEIDNER By: A wt F Sarah E. Hoffman :474082