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Home My WebLink About09-0627N Paul J. Hennessy, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 610-431-2727 Attorney I.D. 65396 Attorney for Plaintiffs Nationwide Mutual Insurance Company A/S/O Cindy K. Gadberry :In The Court of Common Pleas 1100 Locust Street Des Moines, IA 50391 :Cumberland County, Pennsylvania VS Alice R. Phillips 93 Encks Mill Road Carlisle, PA 17013 :Civil Action Law No: Oq- (o-17 0,vil lean 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 S. Bedford St. Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la torte. Si usted quiere defenderse de estas demandas expuestas en [as paginas siguientes, usted tiene veinte (20) dias de plazo ai partir de la f'echa de la demanda y la notification. Hace faita asentar una comparencia escrita o en persona o con un abogado y entregar a la torte en forma escrita sus defenses o sus objeciones a ]as demandas en contra de su persona. Sea avisado que si usted no se defiende, la cone tomara medidas y puede continuar la demanda en contra soya sin previo aviso o notification. Ademas, la torte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perdee dinero o sus propiedades u otros derechos importantes para usted. Lleva esta demanda a un abogado inmediatamente. Si no dene abogado o si no dene el dinero sufieiente de pagar tal servicio. Vaya en persona o Name par telifono a la ofieina cuya direeeion se eneuentra eneuentra escrita abojo para averiguar d6nde se puede conseguir asistencia legal. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 717-249-3166 800-990-9108 M Paul J. Hennessy, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 610-431-2727 Attorney I.D. 65396 Attorney for Plaintiffs Nationwide Mutual Insurance Company A/S/O Cindy K. Gadberry :In The Court of Common Pleas 1100 Locust Street Des Moines, IA 50391 :Cumberland County, Pennsylvania VS Alice R. Phillips :Civil Action Law 93 Encks Mill Road Carlisle, PA 17013 ; No: 0 9 - (v COMPLAINT 1) Plaintiff Nationwide Mutual Insurance Company is an insurance carrier licensed and authorized to conduct business in the Commonwealth of Pennsylvania and having as one of its principal places of business the above captioned address. 2) Cindy K. Gadberry an adult individual insured with Plaintiff Nationwide Mutual Insurance Company on 05/14/2008. 3) Defendant Alice R. Phillips is an adult individual residing at the above captioned address. 4) On or about 05/14/2008, Plaintiff Nationwide Mutual Insurance Company insured Cindy K. Gadberry with personal automobile policy, policy number 5837CO94995 said policy covering a-2008 Mazda 3 and carrying with same, collision coverages. 5) On or about 05/14/2008 at or near the intersection of York Road and Fairview Streets, South Middleton Township, Cumberland County,. PA, Defendant Alice R. Phillips while operating a 2004 Cadillac SRX bearing PA tag GJY- 0358 did negligently or recklessly strike/collide into Plaintiff s insured's Mazda causing damages to same in the amount of $8,,791.02. 6) The negligence of the Defendant consisted of a) failing to yield right of way; b) being inattentive; c) striking another motor vehicle lawfully upon the?roadway; . Ift d) failing to give due regard to the rights, safety point and position of Plaintiff's insured's vehicle; e) improper turning methods, f) failing to give proper signal g) other such negligence that may be developed through continuing discovery and trial of this matter. 7) The aforesaid collision resulted solely from the negligent acts and/or failure to act on part of Defendant named herein and was due in no manner whatsoever to any act and/or failure to act on part of Plaintiff's insured. 8) As a result of the aforesaid collision, Plaintiff Nationwide Mutual Insurance Company settled the collision claim of Cindy K. Gadberry in the amount of $8,791.02 (said figure includes the first party deductible) representing fair and reasonable reimbursement for the damages sustained. 9) Pursuant to the aforesaid policy of insurance, Nationwide Mutual Insurance Company is subrogated to Cindy K. Gadberry for this loss. WHEREFORE, Plaintiffs demand judgment against the Defendant in the amount of $8,791.02 together plus costs, interest and such other relief this Court finds equitable and just. NATI-1463 Paul J. WneA- Esquire Hennessy Walker COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CHESTER : ss The undersigned verifies that the facts contained herein are true and correct. The undersigned understands that false statements herein are made subject to the penalties of 19 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. If applicable, this affidavit is made on behalf of the Plaintiff(s); that the said Plaintiff(s) is/are unable and unavailable to make this verification on its/his/her own behalf within the time allotted for filing of this pleading, and the facts set forth in the foregoing pleading are true and correct to the best of counsel's knowledge, information and belief. This verification is made pursuant to Pa. R.C.P. 1024 and is based on interviews, conferences, reports, records and other investigative material in the file Date Paul J. nnts?, Esq. Hennessy & Walker Group, P. C O (. VA -D 4 Y 0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2009-00627 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NATIONWIDE MUTUAL INSURANCE CO VS PHILLIPS ALICE R R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT PHILLIPS ALICE R but was unable to locate Her in his bailiwick. He therefore returns the NOTICE COMPLAINT the within named DEFENDANT , PHILLIPS ALICE R NOT FOUND , as to 93 ENCKS MILL ROAD CARLISLE, PA 17013 DEFENDANT DOES NOT RESIDE AT ADDRESS STATED, PER CURRENT RESIDENT SHE IS BELIEVED TO BE IN ETTERS PA Sheriff's Costs: So answer Docketing 18.00 Service 4.50 NOT FOUND RETURN 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 37.50 HENNESSY WALKER GROUP 02/09/2009 Sworn and Subscribed to before me this day of , A.D. F Cp .cs y N e , sr t a- ? cr _j ? Q N Paul J. Hennessy, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 610-431-2727 Attorney I.D. 65396 Nationwide Mutual Insurance Company Cindy K. Gadberry 1100 Locust Street Des Moines, IA 50391 VS Alice R. Phillips 5 S. Hanover Street Carlisle, PA 17013 Attorney for Plaintiffs A/S/O :In The Court of Common Pleas :Cumberland County, Pennsylvania :Civil Action Law : No: 09-627 Civil Term Praecine to Reinstate To The Prothonotary: Please reinstate the Complaint on the above-captioned action. Please forward to the sheriff for service. cn 20Glil APR 20 F 3: 4 b ?!v; s v , Y v 4 0 0o po All'/ aagcAq Sheriffs Office of Cumberland County R Thomas Kline p of €umbrEdward L Schorpp Sheriff (.01" Solicitor Ronny R Anderson Jody S Smith Chief Deputy OMCE c `'"E s"ER'FF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/23/2009 10:23 AM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on April 23, 2009 at 1023 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Alice R. Phillips, by making known unto Paula George, daughter of defendant at 9 Tall Oak Drive Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $36.10 April 24, 2009 SO ANSWERS, - 11-80110ww- R THOMAS KLINE, SHERIFF 2009-627 Nationwide Insurance By ?' ?-a Deputy eriff VS Alice R. Phillips FILED-, i"°3vk? q? ,)F THt~.i trn tlP 2003 APR 23 i'll 9. 13 CAJAL PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in triplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: (List the within matter for the next Argument Court.) CAPTION OF CASE (entire caption must be stated in full) ?, N o rn o ?' Nationwide Mutual Insurance Company a/s/o Cindy Gadberry vs. -: Alice R. Phillips _ No. 09-627 Civil Term' ? R+ 1. State matter to be argued (i.e., plaintiffs motion for new trial, defendant's demurrer to complaint, etc.): Preliminary Obiections 2. Identify all counsel who will argue cases: (a) for plaintiffs: Paul J. Hennessy, Esquire 142 W. Market Street, Suite 2 West Chester, PA 19382 (Name and Address) (b) for defendants: Neil Warner Yahn, Esquire P.O. Box 650 Hershey, PA 17033 (Name and Address) 3. 1 will notify all parties in writing within two days that this case has been listed for argument. 4. Arourrment Court Date: Date: 8/16/2010 Attorney for INSTRUCTIONS: 1. Original and two copies of all briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) before argument. 2. The moving party shall file and serve their brief 12 days prior to argument. 3. The responding party shall file their brief 5 days prior to argument. 4. If argument Is continued now briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) after the case Is refleted. Print your name Plaintiff PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in triplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: (List the within matter for the next Argument Court.) CAPTION OF CASE ~ ~' ~ (entire caption must be stated in fulQ '~ -~ `='' Nationwide Mutual Insurance Company also Cindy Gadberry ~;~. ~~ ~ ~ r vs. ~, -~° --~ Alice R. Phillips ~~ ~' = ° =~ 627 No _ 2009 `~ ~ ~. iaem n ~ ~ ~ . , ~ s -. 1. State matter to be argued (i.e., plaintiffs motion for new trial, defendant's demurrer to complaint, etc.): PreLmin ry Obiections 2. Identify all counsel who will argue cases: (a) for plaintiffs: Paul J. Hennessy, Esquire (Name and Address) 142 West Market Street, Suite 2, West Chester, PA 19382 (b) for defendants: Neil Waraer Mahn, Esquire (Name and Address) PO Box 650, Hershey, PA 17033 3. I will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: Date: October 22, 2010 Print your name Plaintiff Attorney for INSTRUCTIONS: 1.Original and two copies of all briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) before argument. 2. The moving party shall file and serve their brief 12 days prior to argument. 3. The responding party shall file their brief 5 days prior to argument. 4. ff argument is continued new briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) after the case is relisted. Paul J. Hennessy, Esquire F11 ED-OUIC- r +F r € H RO i r f' .r L010 DEC -8 AM 11 $? Neil Warner Yahn, Esquire ?``Of1 f?E RL.AE?O G `' U Attorney I.D. No. 82278 ?+ ? ;a James Smith Dietterick & Connelly, LLP pEN?S Y 44 A P.O. Box 650 Hershey, PA 17033 Attorneys for Defendant NATIONWIDE MUTUAL : IN THE COURT OF COMMON PLEAS INSURANCE COMPANY A/S/O : CUMBERLAND COUNTY, PENNSYLVANIA CINDY K. GADBERRY, Plaintiff Docket No. 09-627 Civil Term V. ALICE R. PHILLIPS, Civil Action Law Defendant PRAECIPE TO WITHDRAW TO THE PROTHONOTARY: Kindly withdraw Defendant's Preliminary Objections to the Complaint filed in the above- captioned action. Dated: December & , 2010 By: N ' W. Y n, Esquire ttomey I. . No. 82278 1 4 Sipe A enue H mel own, PA 17036 (717) 533-3280 Attorneys for Defendant Neil Warner Yalm, Esquire Attorney I.D. No. 82278 James Smith Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Attorneys for Defendant NATIONWIDE MUTUAL : IN THE COURT OF COMMON PLEAS INSURANCE COMPANY A/S/O : CUMBERLAND COUNTY, PENNSYLVANIA CINDY K. GADBERRY, Plaintiff Docket No. 09-627 Civil Term V. ALICE R. PHILLIPS, Civil Action Law Defendant CERTIFICATE OF SERVICE The undersigned hereby certifies that I served a true and correct copy of the foregoing, Praecipe to Withdraw, upon the following below-named individual(s) by depositing same in the U.S. Mail, postage pre-paid at Hershey, Dauphin County, Pennsylvania this` day of December, 2010. SERVED UPON: Dated: 1,2- (k ( w Andrew J. Hennessy, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 Attorney for Plaintiff JAMES, SMITH, DIETTERICK & CONNELLY, LLP By: EIL W. YAVN, ESQUIRE torney ID o. 82278 Neil Warner Yalm, Esquire Attorney I.D. No. 82278 James Smith Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Attorneys for Defendant NATIONWIDE MUTUAL INSURANCE COMPANY A/S/O CINDY K. GADBERRY, Plaintiff V. ALICE R. PHILLIPS, Defendant FILED-OFFICE ? 1QCEC -8 Hit: ! f CUMBERLAND : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Docket No. 09-627 Civil Term Civil Action Law NOTICE TO PLEAD To: Nationwide Mutual Insurance Company A/S/O Cindy Gadberry You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. Respectfully submitted, Date: f ??> JAWS-) SIWITH, DIETTERICK & CONNELLY, LLP -eil W. Yahn Attorney I.D. o. 82278 134 Sipe Ay ue Humme wn, PA 17036 )533-3280 Attorney for Defendant Neil Warner Yahn, Esquire Attorney I.D. No. 82278 James Smith Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Attorneys for Defendant NATIONWIDE MUTUAL INSURANCE COMPANY A/S/O CINDY K. GADBERRY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : Docket No. 09-627 Civil Term V. ALICE R. PHILLIPS, : Civil Action Law Defendant DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT AND NEW MATTER AND NOW COMES, the defendant, Alice R. Phillips (herein "Defendant"), by and through her attorneys, JAMES SMITH DIETTERICK & CONNELLY, LLP, and hereby sets forth this Answer to the Complaint of the Plaintiff, Nationwide Mutual Insurance Company A/S/O Cindy K. Gadberry (herein "Plaintiff') and New Matter, as follows: 1. Denied. After a reasonable investigation, Defendant is without knowledge as to the truth of this averment. Strict proof is required at trial. 2. Denied. After a reasonable investigation, Defendant is without knowledge as to the truth of this averment. Strict proof is required at trial. 3. Denied. Defendant is no longer residing at the address listed in the caption. By way of further answer, Defendant currently resides at 9 Tall Oak Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 4. Denied. After a reasonable investigation, Defendant is without knowledge as to the truth of this averment. Strict proof is required at trial. 5. Denied as a conclusion of law to which no responsive pleading is required. To the extent a response is required all averments herein are specifically denied. Strict proof is required at trial. 6. Denied as a conclusion of law to which no responsive pleading is required. To the extent a response is required all averments herein are specifically denied. Strict proof is required at trial. a. Denied as a conclusion of law to which no responsive pleading is required. To the extent a response is required all averments herein are specifically denied. Strict proof is required at trial. b. Denied as a conclusion of law to which no responsive pleading is required. To the extent a response is required all averments herein are specifically denied. Strict proof is required at trial. c. Denied as a conclusion of law to which no responsive pleading is required. To the extent a response is required all averments herein are specifically denied. Strict proof is required at trial. d. Denied as a conclusion of law to which no responsive pleading is required. To the extent a response is required all averments herein are specifically denied. Strict proof is required at trial. e. Denied as a conclusion of law to which no responsive pleading is required. To the extent a response is required all averments herein are specifically denied. Strict proof is required at trial. f. Denied as a conclusion of law to which no responsive pleading is required. To the extent a response is required all averments herein are specifically denied. Strict proof is required at trial. g. Denied as a conclusion of law to which no responsive pleading is required. To the extent a response is required all averments herein are specifically denied. Strict proof is required at trial. 7. Denied as a conclusion of law to which no responsive pleading is required. To the extent a response is required all averments herein are specifically denied. Strict proof is required at trial. 8. Denied as a conclusion of law to which no responsive pleading is required. To the extent a response is required all averments herein are specifically denied. Strict proof is required at trial. 9. Denied as a conclusion of law to which no responsive pleading is required. To the extent a response is required all averments herein are specifically denied. Strict proof is required at trial. WHEREFORE, Defendant respectfully requests that this Honorable Court enter an order dismissing Plaintiffs' Complaint with prejudice. NEW MATTER 10. Paragraphs numbered 1 through 9 are incorporated herein by reference. 11. Plaintiff's Complaint fails to state a claim against Defendant upon which relief can be granted. 12. Plaintiff's Complaint is barred (or at least must be offset) by the doctrine of contributory negligence. 13. Defendant reserves the right to amend her Answer to include defenses which may become known to her during discovery. Date: a Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP Nei . Yahn A orney I.D. o. 82278 1 4 Sipe Aven Hu elstown A 17036 (7171 - 0 Attorney for Defendant Neil Warner Yahn, Esquire Attorney I.D. No. 82278 James Smith Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Attorneys for Defendant NATIONWIDE MUTUAL : IN THE COURT OF COMMON PLEAS INSURANCE COMPANY A/S/O : CUMBERLAND COUNTY, PENNSYLVANIA CINDY K. GADBERRY, Plaintiff Docket No. 09-627 Civil Term V. ALICE R. PHILLIPS, Civil Action Law Defendant CERTIFICATE OF SERVICE The undersigned hereby certifies that I served a true and correct copy of the foregoing, Defendant's Answer and New Matter, upon the following below-named individual(s) by depositing same in the U.S. Mail, postage pre-paid at Hershey, Dauphin County, Pennsylvania this d day of December, 2010. SERVED UPON: Andrew J. Hennessy, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 Attorney for Plaintiff JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: 0? u - By: W. YHN, ESQUIRE iev I No. 82278 Paul J. Hennessy, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 610-431-2727 Attorney I.D. 65396 FILED-OFFICE I-F THE PPOTI-ICtdO2010 DEC 22 AM 10: ;3 CUMBERLAND COUNT'' PENNSYLVANIA Attorney for Plaintiffs Nationwide Mutual Insurance Company A/S/O Cindy K. Gadberry 1100 Locust Street Des Moines, IA 50391 VS Alice R. Phillips 93 Encks Mill Road Carlisle, PA 17013 : In The Court of Common Pleas : Cumberland County, Pennsylvania : Civil Action Law No. 09-267 Civil Term Plaintiffs Ren1y to Defendant's New Matter 10-13. Denied as conclusion and conclusion of law to which no response is required. It is specifically denied that Plaintiffs insured was in any way negligent or in any way contributed to the happening of this accident. Strict proof is demanded at the time of trial. All other averments are specifically denied. WHEREFORE, Plaintiff demands judment against the Defendant in the amount of $8,791.02 together plus costs, interest, and such other relief this Court finds equitable and just. Paul J. He essy, Esquire Hennessy & Walker Group, C. NATI-1463 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CHESTER : ss The undersigned verifies that the facts contained herein are true and correct. The undersigned understands that false statements herein are made subject to the penalties of 19 Pa. C.S. Section 4904, relating to unworn falsification to authorities. If applicable, this affidavit is made on behalf of the Plaintiff(s); that the said Plaintiff(s) is/are unable and unavailable to make this verification on its/his/her own behalf within the time allotted for filing of this pleading, and the facts set forth in the foregoing pleading are true and correct to the best of counsel's knowledge, information and belief. This verification is made pursuant to Pa. R.C.P. 1024 and is based on interviews, conferences, reports, records and other investigative material in the file - P? 9 nn& Paul J. ennessy, Esq. U Hennessy & Walker Group, P.C. Dated: /Z l a o ho IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Nationwide Mutual Insurance Co. aso Cindy K. Gadberry Plaintiff NO. 09-627 Civil Term Feb. 2009 VS. Alice R. Phillips RULE 1312-1 Defendant r ri The Petition for Appointment of Arbitrators shall be substantially in 0* Following form: Ca :I- C-) PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: C, CD C3-r c? r.,. Paul J. Hennessy, Esquire , 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 $ 8,791.02 The counterclaim of the defendant in the action is 0 The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Neil W. Yahn, Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. arv?? a ay,oo pd aN,, Respectfully submitted, Calk 95?)3 Ad ?' OA"dl _e4A4(k1% 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. NATIONWIDE MUTUAL INSURANCE CO. aso Cindy Gadberry, Plaintiff Vs. ALICE R. PHILLIPS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-0627 CIVIL ORDER AND NOW, this Z '4' day of January, 2012, the appointment of a Board of Arbitrators in the above-captioned case is VACATED. Stephen J. Hogg, Esquire, Chairman, shall be paid the sum of $50.00. BY THE COURT, Hess, P. J. Stephen J. Hogg, Esquire ? Court Administrator i r -1: - - :p ,r v Ev Paul J. Hennessy, Esquire Hennessy & Walker Group, P.C. 142 W. Market Street West Chester, PA 19382 610-431-2727 Attorney I.D. 65396 Attorney for Plaintiffs Nationwide Mutual Insurance Company A/S/O 1 Cindy K. Gadberry :In The Court of Common Pleas 1100 Locust Street Dept 2019 r Des Moines, IA 50391 :Cumberland County, Pennsylvania VS Alice R. Phillips :Civil Action Law 93 Encks Mill Road Carlisle, PA 17013 : No:09 627 Civil Term Feb 2009 Praecipe To The Prothonotary: Please mark the above captioned case as NATI-1463 r `i c- C 3 *? rn= -n OD r r =- Dn ? O i V rTt c7 -rt M !p