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HomeMy WebLinkAbout09-61414 Donna B. Ulrich, VS. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Sudhaker Akasapu Venkata, Defendant NO. 0 9- G I I L'tut? i,? : CIVIL - JURY TRIAL DEMANDED NOTICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717)-249-3166 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. You must attend the scheduled conference or hearing. 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. Donna B. Ulrich, vs. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Sudhaker Akasapu Venkata, Defendant : NO. : CIVIL - JURY TRIAL DEMANDED AVISO USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia escrita en person o por abogado y presentar en la Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificacion por cualquier dinero reclamado en la demanda o por cualquier otra wueja o compensacion reclamados por el Demandant. USTED PUEDE PERDER DINERO, O PROPIEDADES U OTROS DERCHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENT. SI USTED NO TIENE O NO CONOCE UN ABOGADO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717)-249-3166 Donna B. Ulrich, VS. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. Sudhaker Akasapu Venkata, CIVIL - JURY TRIAL DEMANDED Defendant COMPLAINT AND NOW, comes the Plaintiff, Donna B. Ulrich, by and through her counsel, R. Mark Thomas, Esquire, and files this Complaint against Defendant, Sudhaker Akasapu Venkata, and in support thereof respectfully represents: 1. Plaintiff, Donna B. Ulrich, is an adult individual, who resides at 322 Lamp Post Lane, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant, Sudhaker Akasapu Venkata, is an adult individual, whose last known address was 109 November Drive, Apartment 6, Camp Hill, Cumberland County, Pennsylvania 17011. 3. On or about October 23, 2007, at approximately 11:50 a.m., Plaintiff was traveling eastbound on Market Street in Camp Hill, Pennsylvania, when she came to a stop for a red traffic light at the intersection of Market Street and 32nd Street in the Borough of Camp Hill, Pennsylvania. 4. Immediately in front of the Plaintiff was an individual riding a bicycle who was also stopped at the red traffic and who was also traveling eastbound on Market Street. 5. The traffic light for eastbound traffic on Market Street turned green at which time the Plaintiff waited several seconds to allow the individual on the bicycle to proceed through the intersection. 6. When Plaintiff believed it was safe to proceed through the intersection, Plaintiff still had the green light and proceeded into the intersection when suddenly and without warning the Defendant, who was traveling southbound on 32nd Street, failed to stop at the red traffic light for southbound traffic on 32nd Street, entered the intersection, and collided with the car being driven by Plaintiff. 7. As a result of the collision, the Plaintiff suffered serious injuries to her cervical and thoracic regions. 8. The aforesaid accident was caused by the negligence, carelessness and/or recklessness of Defendant. 9. The Defendant's negligence, carelessness and/or recklessness consisted of the following: a. Failure to stop at a steady red traffic signal for traffic moving in the same direction as the Defendant; b. Failing to exercise due care in the operation of his vehicle; C. Failing to yield the right-of-way to Plaintiff who was traveling in obedience to the traffic control devices at the intersection; d. Operating his vehicle in a careless and reckless manner without due regard for the rights and safety of those lawfully upon the roadway, one of whom was Plaintiff; e. Failing to bring his vehicle to a stop prior to crashing into the Plaintiff s vehicle; and f. Failing to prevent a collision with Plaintiff s vehicle when there was sufficient time and space to either stop or avoid a collision with Plaintiff s vehicle. 10. By reason of the aforesaid carelessness, recklessness, and negligence of the Defendant, Plaintiff suffered severe and permanent injuries to her spinal column, particularly the cervical and thoracic regions. 11. By reason of the aforesaid carelessness, recklessness, and negligence of the Defendant, Plaintiff has in the past, and will in the future, undergo severe pain and suffering. 12. In addition to the aforesaid physical injuries, Plaintiff, as a direct result of Defendant's carelessness, recklessness, and negligence has been caused to suffer loss in the form of anxiety, humiliation, frustration, loss of the feeling of well- being, limitation of activities, and loss of enjoyment of life. 13. As a further result of Defendant's carelessness, recklessness, and negligence, Plaintiff has been and will be obliged to undergo continuing medical care, to expend various sums of money, and to incur various expenses for the injuries which she has suffered. WHEREFORE, Plaintiff, Donna B. Ulrich, prays that this Honorable Court will enter judgment in favor of the Plaintiff and against the Defendant in an amount in exceeds the jurisdictional amount requiring compulsory arbitration pursuant to local rule. Respectfully submitted, R. Mark Thomas, Esquire Attorney No. 41301 101 South Market Street Mechanicsburg, PA 17055 Telephone: 717-796-2100 VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Date: D a DPI 4-61V? Donna B. Ulrich 0 FILED-4 ;? 'FiCE OF THE PRO ? ?OYNNOTAFY 2009 SEP 10 PV I 12.17 CCUNTY PEPSNSY"LV',t IA Pd . c `7 k 3t) C-c, .244? 02L". .13014 0 7 Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor of 4Iii114rrfxn OFFICE OF TIP -ERiFF A LEC--s(_,:::, ? OF TIC" P IC #O FAIRY Donna B. Ulrich vs. Sudhaker Akasapu Venkata 2009 SEP 15 Fri 2: ? 4 CLM u??a Case Number 2009-6141 SHERIFF'S RETURN OF SERVICE 09/14/2009 07:38 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 14, 2009 at 1938 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Sudhaker Akasapu Venkata, by making known unto Sirisha Devi Chintapatla, wife of defendant at 109 November Drive Apt. 6 Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.94 SO ANSWERS, W -)e r September 15, 2009 R THOMAS KLINE, SHERIFF By $? V?/- . Depu y Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA B. ULRICH, Plaintiff, V. CIVIL DIVISION NO. 09 - 6141 SUDHAKER AKASAPU VENKATA, Defendant. PRAECIPE FOR APPEARANCE (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #17366 11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA B. ULRICH, Plaintiff, CIVIL DIVISION V. SUDHAKER AKASAPU VENKATA, Defendant. NO. 09 - 6141 (Jury Trial Demanded) PRAECIPE FOR APPEARANCE TO: THE PROTHONOTARY Kindly enter the Appearance of the undersigned, Kevin D. Rauch, Esquire, of the law firm of Summers, McDonnell, Hudock, Guthrie & Skeel, P.C., on behalf of the Defendant, Sudhaker Akasapu Venkata, in the above case. JURY TRIAL DEMANDED Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & S,KEEL, P.C. By: eWn D. F auch, Esquire ounsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR APPEARANCE has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 18TH day of September, 2009. R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: n D. Roch, Esquire isel for Defendant 2609 SEE' 21 PG` 2: r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA B. ULRICH, Plaintiff, V. SUDHAKER AKASAPU VENKATA, Defendant. TO: Plaintiff You are hereby notified to file a written response to the enclosed Answer and New Matter within twenty (20) days from servirerefll ereof a judgment maybe ea- ist yoy?7 Sum rs,'IWcDon0bn,' Guthr o & Skeel, C. ck, CIVIL DIVISION NO. 09 - 6141 ANSWER AND NEW MATTER (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #17366 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA B. ULRICH, Plaintiff, CIVIL DIVISION V. SUDHAKER AKASAPU VENKATA, Defendant. NO. 09 - 6141 (Jury Trial Demanded) ANSWER AND NEW MATTER AND NOW, comes the Defendant, Sudhakar Akasapu Venkata, incorrectly identified as Sudhaker Akasapu Venkata, by and through his counsel, Summers, McDonnell, Hudock, Guthrie & Skeel, P.C., and Kevin D. Rauch, Esquire, and files the following Answer and New Matter and in support thereof avers as follows: 1. After reasonable investigation, the Defendant has insufficient information as to the truth or falsity of said averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 2. Denied as stated. The Defendant's name is Sudhakar Akasapu Venkata. He resides at 255 East Wendy Way, Apartment 320, King of Prussia, Montgomery County, Pennsylvania, 19406. 3. Admitted. 4. After reasonable investigation, the Defendant has insufficient information as to the truth or falsity of said averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 5. After reasonable investigation, the Defendant has insufficient information as to the truth or falsity of said averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 6. Admitted in part, denied in part. It is admitted that a collision occurred between the vehicles identified on the date, time, and place of the subject accident. The remainder of the allegations in paragraph 6 are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 7. Paragraph 7 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 8. Paragraph 8 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 9. Paragraph 9 and all of its subparts state legal conclusions to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 10. Paragraph 10 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 11. Paragraph 11 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 12. Paragraph 12 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 13. Paragraph 13 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant, Sudhakar Akasapu Venkata, respectfully requests this Honorable Court enter judgment in his favor and against the Plaintiff with costs and prejudice imposed. NEW MATTER 14. The motor vehicle accident in controversy is subject to the Pennsylvania Motor Vehicle Financial Responsibility Law and this Defendant asserts, as affirmative defenses, all rights, privileges and/or immunities accruing pursuant to said statute. 15. Some and/or all of Plaintiffs claims for damages are items of economic detriment which are or could be compensable pursuant to either the Pennsylvania Motor Vehicle Financial Responsibility Law and/or other collateral sources and same may not be duplicated in the present lawsuit. WHEREFORE, Defendant, Sudhakar Akasapu Venkata, respectfully requests this Honorable Court enter judgment in his favor and against the Plaintiff with costs and prejudice imposed. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & $KEEL, FC. By: vin-u' r-au , tsquire unsel for efendant VERIFICATION Defendant verifies that he is the Defendant in the foregoing action; that the foregoing ANSWER AND NEW MATTER is based upon information which he has furnished to his counsel and information which has been gathered by his counsel in the preparation of the lawsuit. The language of the ANSWER AND NEW MATTER is that of counsel and not of the Defendant. Defendant has read the ANSWER AND NEW MATTER and to the extent that the ANSWER AND NEW MATTER is based upon information which he has given to his counsel, it is true and correct to the best of his knowledge, information and belief. To the extent that the content of the ANSWER AND NEW MATTER is that of counsel, he has relied upon counsel in making this Affidavit. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: (t l a-4 / LCD A Sud r asapu Venkata #17366 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing ANSWER AND NEW MATTER has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 30th day of October, 2009. R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: u v vin D. Rauch, Esquire Ct- -_ 7 unsel for Defendant r4 r Y l?i'-u . OF THE 2009 NO -4 Pei 12: 55 ,n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA B. ULRICH, CIVIL DIVISION Plaintiff, NO. 09 - 6141 V. STIPULATION TO AMEND CAPTION SUDHAKER AKASAPU VENKATA, Defendant. (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #17366 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA B. ULRICH, Plaintiff, CIVIL DIVISION V. SUDHAKER AKASAPU VENKATA, Defendant. NO. 09 - 6141 (Jury Trial Demanded) STIPULATION TO AMEND CAPTION AND NOW, comes the Defendant, Sudhakar Akasapu Venkata, by and through his counsel, Summers, McDonnell, Hudock, Guthrie & Skeel, P.C., and Kevin D. Rauch, Esquire, and files the following Stipulation to Amend Caption: The undersigned parties hereby stipulate and agree that the caption in this matter is amended to Donna B. Ulrich, Plaintiff, v. Sudhakar Akasapu Venkata, Defendant. R. MARK THOMAS, ESQUIRE By:-Z? R. ark Thomas, Esquire Counsel for Plaintiff SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: in D. Rauch, EsgW nsel for Defendant 101 South Market Street Mechanicsburg, PA 17055 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 h ':'_ . CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing STIPULATION TO AMEND CAPTION has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this day of , 2009. R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: in D. Rauch, Esquire nsel for Defendant 2009 NOV 25 PH 2: .146 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA B. ULRICH, Plaintiff, V. SUDHAKER AKASAPU VENKATA, Defendant. CIVIL DIVISION NO. 09 - 6141 PRAECIPE FOR AMENDMENT OF CAPTION (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #17366 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA B. ULRICH, CIVIL DIVISION Plaintiff, V. NO. 09 - 6141 SUDHAKER AKASAPU VENKATA, (Jury Trial Demanded) Defendant. PRAECIPE FOR AMENDMENT OF THE CAPTION TO THE PROTHONOTARY, Pursuant to the enclosed Stipulation to Amend Caption, kindly amend the caption in the above-referenced lawsuit to read: Donna B. Ulrich, Plaintiff, v. Sudhakar Akasapu Venkata, Defendant. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: K vin . Rau h, Esquire Counsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR AMENDMENT OF CAPTION has been mail ad by U.S. Mail to counsel of record via first class mail, postage pre-paid, this _ day of )L'A0Q_- , 2009. R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: in D. Radch, Esquire nsel for Defendant FLEC?:)i"i ` 2009 NOY 25 Ph 2: 46) C'Lt \ L.Vr N bonny '3. Gf tr►eli vs Case No. 619 - Ix /l mgr ..5gOtilaker 4kCX•50y0 irt � cr Statement of Intention to Proceed €—�= - c S - ID To the Court: _ Dn»nu • mina, intends to proceed with the above captioned matter. Print Name Mach 'The010 Sign Name ��%1i� Date: t S. e23 .20/3 Attorney for AP-mg? B. U/ri4 Explanatory Comment The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit comment. I.Rule of civil Procedure New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2,is tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice,preempting local rules. This rule was promulgated in response to the decision of the Supreme Court in Shop v.Eagle,551 Pa.360,714 A.2d 1104 (1998) in which the court held that"prejudice to the defendant as a result of delay in prosecution is required before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901." Rule of Judicial Administration 1901(b)has been amended to accommodate the new rule of civil procedure. The? general policy of the prompt disposition of matters set forth in subdivision(a)of that rule continues to be applicable. II Inactive Cases The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the court. After giving notice of intent to terminate an action for inactivity,the course of the procedure is with the parties. If the parties do not wish to pursue the case,they will take no action and"the Prothonotary shall enter an order as of course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter,he or she will file a notice of intention to proceed and the action shall continue. a.Where the action has been terminated If the action is terminated when a party believes that it should not have been terminated,that party may proceed under Ru1e230(d)for relief from the order of termination. An example of such an occurrence might be the termination of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file the notice of intention to proceed. The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of the entry of the order of termination on the docket,subdivision(d)(2)provides that the court must grant the petition and reinstate the action. If the petition is filed later than the thirty-day period,subdivision(d)(3)requires that the plaintiff must make a showing to the court that the petition was promptly filed and that there is a reasonable explanation or legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of termination on the docket and for the failure to file the petition within the thirty-day period under subdivision(d)(2). B.Where the action has not been terminated An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a common law non pros which exits independently of termination under Rule 230.2. i { Pt, 0 0 t 1, dO7 25 P11 2: 17 cu BERL `;PBC ', PENNS YLVA IH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA B. ULRICH, CIVIL DIVISION Plaintiff, NO. 09 - 6141 v. DEFENDANT'S ADMINISTRATIVE SUDHAKAR AKASAPU VENKATA, APPLICATION FOR STATUS Defendant. CONFERENCE (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #17366 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA B. ULRICH, CIVIL DIVISION Plaintiff, v. NO. 09 - 6141 SUDHAKAR AKASAPU VENKATA, (Jury Trial Demanded) Defendant. DEFENDANT'S APPLICATION FOR STATUS CONFERENCE AND NOW, comes the Defendant, Sudhakar Akasapu Venkata, by and through their attorneys, Summers, McDonnell, Hudock & Guthrie, P.C., and Kevin D. Rauch, Esquire, and files the following Motion for Discovery Conference and in support thereof avers the following: 1. This case arises out of an automobile accident that occurred on October 23, 2007. 2. As a result of the accident, the Plaintiff filed a Complaint sounding in negligence alleging personal injury. 3. Discovery has been conducted in this case and the parties have exchanged written discovery and completed depositions. 4. At this time it is believed that all discovery is complete. In an effort to move this matter forward the Defendant respectfully requests foregoing Administrative Application for Status Conference be granted so all parties may agree to schedule dates and deadlines for any additional discovery as well as Pretrial and Trial Motions. 5. At this time all parties have agreed on this Administrative Application for Status Conference because they believe the Status Conference could resolve the outstanding issues and move forward listing this matter for trial. 6. Oral Argument is not requested and is asked this matter be scheduled for a Status Conference. WHEREFORE, Defendant, Sudhakar Akasapu Venkata, respectfully request this Honorable Court enter an Order that this matter be scheduled for a Status Conference. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK & GUTHRI , '. .4 By: evin D. Rauch, Esquire ounsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing DEFENDANT'S APPLICATION FOR STATUS CONFERENCE has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 22nd day of November, 2013. R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 (Attorney for Plaintiff) SUMMERS, McDONNELL, HUDOCK, GUTHRIE :,SKEEL, P.C. By: A( L A. ■'fin D.Y'auch, Esquire lounsel for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA B. ULRICH, CIVIL DIVISION Plaintiff, V. NO. 09 - 6141 SUDHAKAR AKASAPU VENKATA, (Jury Trial Demanded) Defendant. ORDER AND NOW, TO WIT, this • day of/141e 1'1 itiew , 2013, it is hereby ORDERED, ADJUDGED and DECREED that this Honorable Court enter an Order that this matter be scheduled for a Status Conference for I 34.171 day of 020/47 4 , 21)41 at /(:(4) BY THE COURT: Distribution List: ark Thomas, Esquire; 101 South Market Street, Mechanicsburg, PA 17055 /frevin D. Rauch, Esquire, Summers, McDonnell, Hudock, Guthrie & Skeel, P.C.; 100 Sterling Parkway, Suite 306, Mechanicsburg, PA 17050 tr&u. LL, •-•- 14017alla -4 rri CI) rz-.7 r (r)t— CD rsj —10 1›. 1 DONNA B. ULRICH, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. • SUDHAKAR AKASAPU VENKATA, DEFENDANT : 09-6141 CIVIL TERM IN RE: STATUS CONFERENCE ORDER OF COURT AND NOW, this /3 day of January, 2014, following a status conference with counsel, we ORDER AND DIRECT as follows: 1. All discovery shall be concluded by March 3, 2014. 2. The parties agree to list this matter for trial for the May term commencing on May 19, 2014. By the Court, A Bert H. Masland, J. R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 le Krombach, Esquire Kevin D. Rauch, Esquire 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 rn , •.sal c,, COp *es 01... .41,Ecb /// apt Ji IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONNA B. ULRICH, CIVIL DIVISION Plaintiff, v. NO. 09 - 6141 SUDHAKAR AKASAPU VENKATA, (Jury Trial Demanded) Defendant. PRAECIPE TO SETTLE AND DISCONTINUE TO: THE PROTHONOTARY rn cr ? Please mark the above -referenced case settled and discontinued, with prejudice. Respectfully submitted, Bv: R. Mark Thomas, Esquire Counsel for Plaintiff