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Home My WebLink About09-2662DONNA MOWRY, Plaintiff V. MATTHEW COOVER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 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. Date: April 27, 2009 To The Above Named Defendants: Respectfully submitted, Rominger & Associates JW E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 WRIT OF SUMMONS Matthew Coover 391 North Middleton Road Carlisle, Pennsylvania 17013 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Date: -:51 d 'z' e _0 _ o` Prothonotary By:4-w2a Deputy TH' C APR P'j Qc3 t l '_? F..:'rte:°.;;,.'"• Sheriffs Office of Cumberland County R Thomas Kline ?wnt? of cumbp? Edward L Schorpp Sheri t Solicitor Ronny R Anderson ?W_ 's Jody S Smith Chief Deputy OFr-xE 4F '"E S04gR1FF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/30/2009 10:50 AM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April 30, 2009 at 1050 hours, he served a true copy of the within Writ of Summons upon the within named defendant, to wit: Matthew Coover by making known unto Matthew Coover personally, at 391 North Middleton Road, Carlisle, Cumberland County, Pennsylvania, 17013, its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $32.92 April 30, 2009 SO ANSWERS, R THO S K SHERIFF De y Shdrjfflf 2009-2662 Donna Mowery v Matthew Coover N rn _ ri - 7 , .e ?A ? .. . . C-0 "j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA MOWRY, Plaintiff No. 09-2662 V. MATTHEW COOVER, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE PURSUANT TO Pa.R.C.P. 1012 TO THE PROTHONOTARY: Kindly enter the appearance of Michael B. Scheib, Esquire of Griffith, Strickler, Lerman, Solymos & Calkins, as attorney for the Defendant in the above-captioned matter and mark the docket accordingly. Dated: March , 2012 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By: Ze MICHAEL B. SC IB, ESQUIRE v Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 (T) 717-757-7602 (F) 717-757-3783 mscheib@gslsc.com Attorneys for Defendant Matthew Coover .y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA MOWRY, No. 09-2662 Plaintiff v. CIVIL ACTION - LAW MATTHEW COOVER, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this _I „ day of March, 2012, I, Michael B. Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of Praecipe for Entry of Appearance, by United States Mail, addressed to the party or attorney of record as follows: Karl E. Rominger, Esquire Rominger & Associates 155 South Hanover Street Carlisle, PA 17013 (Attorney for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By::T/I MICHAEL B. SCHEIB, ESQUIRE " Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 (T) 717-757-7602 (F) 717-757-3783 mscheib@gslsc.com Attorneys for Defendant Matthew Coover c:a te r -' . _..y ?- ?? ? . tea IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA MOWRY, Plaintiff V. MATTHEW COOVER, Defendant TO THE PROTHONOTARY: No. 09-2662 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE Please enter a Rule upon Donna Mowry, Plaintiff, to file a Complaint within twenty (20) days from the date of the service of this Rule or suffer Judgment non-pros. Date: March G 2012 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By. MICHAEL B. SCHEIB, ESQUI Supreme Court I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402-3737 Phone (717) 757-7602 Fax (717) 757-3783 MscheibLg)gslsc.com Attorney for Defendant NOW, March Q 2012, RULE ISSUED AS ABOVE. loxid 1>7&e l l Prothonotary J BY: Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA MOWRY, No. 09-2662 Plaintiff V. CIVIL ACTION - LAW MATTHEW COOVER, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this qt? day of March, 2012, I, Michael B. Scheib, Esquire, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the Praecipe for Rule to file a Complaint by United States Mail, postage prepaid, addressed to the party or attorney of record as follows: Karl E. Rominger, Esquire Rominger & Associates 155 South Hanover Street Carlisle, PA 17013 (Attorney for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS j By: G?- MICHAEL B. SCHEIB, ESQUIRE Supreme Court I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402-3737 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA MO WRY, No. 09-2662 Plaintiff v. CIVIL ACTION - LAW? w 7 MATTHEW COOVER, `_ Defendant JURY TRIAL DEMANDED;'- rv co CERTIFICATE OF SERVICE AND NOW, this 441 day of March, 2012, I, Michael B. Scheib, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the Interrogatories/Request for Production of Documents of Defendant Matthew Coover to Plaintiff Donna Mowry; Set No. 1, by United States First-Class Mail, postage prepaid, addressed as follows: Karl E. Rominger, Esquire Rominger & Associates 155 South Hanover Street Carlisle, PA 17013 (Attorney for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS J/ ? 1 J_ YJ y / By: / ?. C?' ???f1 MICHAEL B. SC EIB, ESQ. #PA 63868 110 South Northern Way York, Pennsylvania 17402-3737 Phone (717) 757-7602 Fax (717) 757-3783 Mscheib &g),slsc.com Attorney for Defendant Matthew Coover DONNA MOWRY, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. MATTHEW COOVER, Defendant, CIVIL ACTION - LAW ' ?. NO: 2009 - 2662 - 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. DONNA MOWRY, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO: 2009 - 2662 MATTHEW COOVER, Defendant, JURY TRIAL DEMANDED COMPLAINT Plaintiff, Donna Mowry, by and through her undersigned counsel, and avers in support of her complaint as follows: Plaintiff, Donna Mowry, is an adult individual residing at 41 Mill Street, Mt. Holly Springs, Pennsylvania 17065. 2. Defendant, Matthew Coover, is an adult individual residing at 391 N. Middleton Rd., Carlisle, Pennsylvania 17013. 3. On May 27, 2007 at about 6:15 PM, Plaintiff was the driver of a vehicle traveling East on the Harrisburg Pike near the intersection of Harrisburg Pike and South Middlesex Road in Middlesex Township, Cumberland County, Pennsylvania. 4. Defendant, Matthew Coover, who was traveling North on South Middlesex Road and was stopped at the traffic light at the intersection South Middlesex Road and Harrisburg Pike; suddenly, unexpectedly, and failing to yield to oncoming traffic, proceeded into the intersection of Harrisburg Pike and South Middlesex Road disobeying the red traffic signal. 5. Due to Mr. Coover's sudden encroachment into Plaintiff's lane of travel, Plaintiff was unable to avoid striking the rear of the Mr. Coover's vehicle. 6. Plaintiff reported to her family physician complaining of neck pain and was diagnosed with a cervical sprain and tinnitus. 7. The accident and resulting injuries to the Plaintiff, were solely caused by the negligence of Defendant, Matthew Coover. Count I: Negligence 8. Previous paragraphs are incorporated herein by reference as if fully set forth herein. 9. The occurrence of the aforementioned incident and the resultant injuries to Plaintiff, Donna Mowry, are the direct and proximate result of the negligence, carelessness, and/or recklessness of Defendant, Matthew Coover, generally and more specifically as set forth below: a. In failing to be reasonably vigilant to observe the road and traffic conditions then and there existing; b. In failing to yield the right-of-way to oncoming traffic prior to entering an intersection; c. In failing to obey a red traffic signal in violation of 75 Pa. C.S.A. §3112(a)(2) d. In failing to wait until it is safe to move his vehicle from a stopped position in violation of 75 Pa. C.S.A. §3333; e. In failing to exercise reasonable care in the operation and control of his vehicle, in violation of 75 Pa. C.S.A. § 3714; f. In failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in failing to have his vehicle under such control that injury to persons or property could be avoided; g. In otherwise driving his vehicle upon the roadway in a manner endangering persons and property and in a manner with careless disregard to the rights and safety of others in violation or the Motor Vehicle Code of the Commonwealth of Pennsylvania. 10. As a direct and proximate result of the negligence of the Defendant, Plaintiff Donna Mowry suffered injuries to her cervical spine and neck, as well as ongoing issues with headaches caused by the same. 11. As a direct and proximate result of Defendant's negligence, Plaintiff Donna Mowry has suffered great physical pain, discomfort and mental anguish, and she will continue to endure the same for an indefinite period of time in the future, to her great physical, emotional, and financial detriment and loss. 12. As a direct and proximate result of the Defendant's negligence, Plaintiff Donna Mowry has suffered lost wages, and a loss of earning capacity as she has not returned to work since her accident. 13. As a direct and proximate result of the Defendant's negligence, Plaintiff Donna Mowry has been compelled, in order to affect a cure for the aforesaid injuries, to spend money for medicine and/or medical attention, and may be required to expend money for the same purposes in the future, to her detriment and loss. 14. As a direct and proximate result of the Defendant's negligence, Plaintiff Donna Mowry has been, and probably will in the future be, hindered from attending to her daily duties, to her great detriment, loss, humiliation, and embarrassment. 15. As a direct and proximate result of the Defendant's negligence, Plaintiff Donna Mowry has suffered a loss of life's pleasures, and will continue to endure the same in the future, to her great detriment and loss. 16. Plaintiff Donna Mowry believes and, therefore, avers that her injuries are permanent in nature. WHEREFORE, Plaintiff, Donna Mowry, seeks damages from Defendant, Matthew Coover, in an amount in excess of the compulsory arbitration limits of Cumberland County, exclusive of interest and costs. 3/a?/Ja Date: Respectfully submitted, ROMINGER & ASSOCIATES Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Attorney for Plaintiff VERIFICATION I, Donna Mowry, verify that the statements in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: 3 -V-?R- /(;? DONNA MOWRY, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA MATTHEW COOVER, Defendant CIVIL ACTION - LAW NO: 2009 - 2662 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Petitioner, do hereby certify that I this day served a copy of the within Complaint by USPS First Class Mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402-3737 Attorney for Defendant Matthew Coover Respectfully, Rominger & Associates Date: ID ? Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241- 6070 Supreme Court ID #: 81924 Attorney for Donna Mowry c? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA MOWRY, Plaintiff v. MATTHEW COOVER, Defendant No. 09-2662 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD To: Donna Mowry c/o Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 You are hereby notified to file a written response to the enclosed Defendant's Answer with New Matter within twenty (20) days from service hereof or a judgment may be entered against you. GRIFFITH, STRI S Dated: April 0 _, 2012 By: MICHAEL B. SCHEIB, ESQUIRE Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 (T) 717-757-7602 (F) 717-757-3783 mscheib@gslsc.com Attorneys for Defendant Matthew Coover IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA MOWRY, No. 09-2662 Plaintiff V. CIVIL ACTION - LAW MATTHEW COOVER, Defendant JURY TRIAL DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER COME NOW, Defendant, Matthew Coover, by and through his attorneys, Griffith, Stickler, Lerman, Solymos & Calkins and Michael B. Scheib, Esquire, respond to the allegations in Plaintiff's Complaint as follows: 1. Admitted upon information and belief. 2. Admitted. 3. Admitted. 4. Admitted in part, denied in part. It is admitted that Defendant, Matthew Coover, was traveling North on South Middlesex Road and was stopped at the traffic light at the intersection South Middlesex Road and Harrisburg Pike. The remaining allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 4 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. 5. Admitted in part, denied in part. It is admitted that Defendant was struck by the Plaintiff. The remaining allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 5 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. 6. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 6 of Plaintiff's complaint and the same is denied and strict proof thereof is demanded. 7. Denied. This paragraph states a conclusion of law to which no response is required. Furthermore, after reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 7 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. COUNTI NEGLIGENCE 8. Paragraphs 1 through 7 of Defendant's Answer with New Matter are incorporated herein as though fully set forth at length. 9. Denied. This paragraph states a legal conclusion to which no response is required. 10. Denied. This paragraph states a legal conclusion to which no response is required. Furthermore, after reasonable investigation answering Defendant is without knowledge or information sufficient to form a belief as to the truth or accuracy of the allegations in paragraph 10 of Plaintiff's Complaint and the same is denied and strict proof thereof is demanded. 11. Denied. This paragraph states a legal conclusion to which no response is 2 required. Furthermore, after reasonable investigation answering Defendant is without knowledge or information. sufficient to form a belief as to the truth or accuracy of the allegations in paragraph 11 of Plaintiff's Complaint and the same is denied and strict proof thereof is demanded. 12. Denied. This paragraph states a legal conclusion to which no response is required. Furthermore, after reasonable investigation answering Defendant is without knowledge or information sufficient to form a belief as to the truth or accuracy of the allegations in paragraph 12 of Plaintiff's Complaint and the same is denied and strict proof thereof is demanded. 13. Denied. This paragraph states a legal conclusion to which no response is required. Furthermore, after reasonable investigation answering Defendant is without knowledge or information sufficient to form a belief as to the truth or accuracy of the allegations in paragraph 13 of Plaintiffs Complaint and the same is denied and strict proof thereof is demanded. 14. Denied. This paragraph states a legal conclusion to which no response is required. Furthermore, after reasonable investigation answering Defendant is without knowledge or information sufficient to form a belief as to the truth or accuracy of the allegations in paragraph 14 of Plaintiff's Complaint and the same is denied and strict proof thereof is demanded. 15. Denied. This paragraph states a legal conclusion to which no response is required. Furthermore, after reasonable investigation answering Defendant is without knowledge 3 or information sufficient to form a belief as to the truth or accuracy of the allegations in paragraph 15 of Plaintiff's Complaint and the same is denied and strict proof thereof is demanded. 16. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 16 of Plaintiff's complaint and the same is denied and strict proof thereof is demanded. WHEREFORE, Defendant respectfully requests this Honorable Court to enter judgment in his favor together with the costs of this lawsuit. By way of further defense: NEW MATTER 17. Paragraph 1 through 16 of Defendant's Answer with New Matter are incorporated herein and as if fully set forth at length. 18. Plaintiff's injuries, if any, may be barred or limited by the Motor Vehicle Financial Responsibility Law. 19. Plaintiff's injuries, if any, may be barred or limited by a limited tort selection. 20. Plaintiff's injuries, if any, were caused by the acts or omissions of a third party over whom Defendant had no control. 21. Plaintiff's injuries, if any, were caused by events which either predated or postdated the motor vehicle accident which is the subject of this lawsuit. 22. Plaintiff's damages were caused by her own conduct. 4 23. Plaintiffs recovery may be barred or limited by the amount of uninsured or underinsured motorist's benefits, if any, to which Plaintiff may be entitled to recover. 24. Defendant is entitled to have the Court mold any verdict in Plaintiffs favor to reflect the amount of uninsured or underinsured motorist's benefits, if any, which Plaintiff has received. WHEREFORE, Defendant respectfully requests this Honorable Court to enter judgment in his favor together with the costs of this lawsuit. Dated: April _I ? , 2012 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS r,J f By: MIC EL B. S IB, tSQUW?E Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 (T) 717-757-7602 (F) 717-757-3783 mscheib@gslsc.com Attorneys for Defendant Matthew Coover 5 VERIFICATION I, Matthew Coover, hereby verify that the statements made in the foregoing Defendant's Answer with New Matter are true and correct to the best of my personal knowledge or information and belief, as well as reports, records, conferences and other investigatory material made available to me. To the extent that the foregoing contains averments which are inconsistent in fact, I verify that my knowledge or information is sufficient to form a belief that one or more of them is true, although I am currently unable, after reasonable investigation, to ascertain which of the inconsistent averments are true. To the extent that the foregoing contains legal conclusions or opinions, I hereby state that my Verification is made upon the advice of counsel, upon whom I have relied in filing this document. This Verification is made subject to the penalties of 18 Pa.C.S. § 4904 related to unsworn falsifications to authorities. /? Date: April ?, 2012 (?? Matthew Coover IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA MOWRY, No. 09-2662 Plaintiff : V. CIVIL ACTION - LAW MATTHEW COOVER, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this day of April, 2012, I, Michael B. Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of Defendant's Answer with New Matter, by First Class Mail, addressed to the party or attorney of record as follows: Karl E. Rominger, Esquire Rominger & Associates 155 South Hanover Street Carlisle, PA 17013 (Attorney for Plaintiff) By: GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CAL1S MICHAEL B. SCHEIB, ESQUII7 Attorney I.D. No. 63868 vv 110 South Northern Way York, Pennsylvania 17402 (T) 717-757-7602 (F) 717-757-3783 mscheib@gslsc.com Attorneys for Defendant Matthew Coover IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA MOWRY, No. 09-2662 Plaintiff V. CIVIL ACTION - LAW < MATTHEW COOVER, ?• Defendant JURY TRIAL DEMANDED -- CERTIFICATE OF SERVICE AND NOW, this I ? day of 2012, I, Michael B. Schei6,_'E,&ire a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the Interrogatories of Defendant Matthew Coover to Plaintiff Donna Mowry, Set No. 2, by United States First-Class Mail, postage prepaid, addressed as follows: Karl E. Rominger, Esquire Rominger & Associates 155 South Hanover Street Carlisle, PA 17013 (Attorney for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKIAS 11 . By: MICtIAEL B. SCHEIB, ESQUIRE Attorney I.D. # PA. 63868 110 South Northern Way York, PA 17402-3737 Phone (717) 757-7602 Fax (717) 757-3783 Mscheib(&gslsc.com. Attorney for Defendant, Matthew Coover DONNA MOWRY, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO: 2009 - 2662 MATTHEW COOVER, JURY TRIAL DEMANDED N Defendant, co :3C Fn Z -C ;T. PLAINTIFF'S REPLY TO NEW MATTER OF DEFENDANT ? c- 17. Admitted. = c 18. Denied. This paragraph states a legal conclusion to which no response is required. 19. Denied. By way of further answer, the Plaintiff was covered by the full tort election under her motor vehicle policy. 20. Denied. Plaintiff knows of no third party who was responsible for the injuries sustained. Strict proof of the same will be required at the time of trial. 21. Denied. 22. Denied. 23. Denied. This paragraph states a legal conclusion to which no response is required. 24. Denied. This paragraph states a legal conclusion to which no response is required. Respectfully submitted, ROMINGER & ASSOCIATES Dated: d- Lee Manarino, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 312895 Attorneys for Plaintiff DONNA MOWRY, Plaintiff, V. MATTHEW COOVER, Defendant, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO: 2009 - 2662 JURY TRIAL DEMANDED VERIFICATION LEE MANDARINO, ESQUIRE, states that he is the attorney for Plaintiff 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: May 7, 2012 Lee Mandarino, Esquire Attorney for Plaintiff DONNA MOWRY, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. MATTHEW COOVER, Defendant, CIVIL ACTION - LAW NO: 2009 - 2662 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Lee Mandarino, Esquire, attorney for Plaintiff, do hereby certify that I this day served a copy of the Response to New Matter upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, Pennsylvania 17402 717-757-7602 Dated: May 7, 2012 Lee Mandarino, Esquire Attorney for Plaintiff f[�t Pt G CUtle 2 NdiA 2: E p `NditdS r C Q J; y dlA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA MOWRY, Plaintiff v. MATTHEW COOVER, Defendant TO: Prothonotary Date: No. 09-2662 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE Pursuant to Rule 229, please mark this matter settled, discontinued and ended. , 2014 By: DONNA MO R 41 Mill Stre Mt. Holly Springs, PA 170:5