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HomeMy WebLinkAbout09-6315If q% W. Scott Henning, Esquire I.D.#32298 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiffs Fax : (717) 233-3029 E-mail: Henning@HHRLaw.com IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA a (VI 2009 (x315 a(VI I T?. Civil Action (XX) Law ( ) Equity JURY TRIAL DEMANDED GLENN D. SHAULIS 1176 W. Trindle Rd. HAROLD P. GUY Mechanicsburg, PA 17055 1036 Petersburg Rd. Boiling Springs, PA 17007 versus Plaintiff(s) & Defendant(s) & Address(es) Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue A Writ of Summons in the above-captioned action. X Writ of Summons Shall be issued and forwaryto tor ne XX W. Scott Henning. Esquire Handler. Henning & Rosenberg. LLP 1300 Linglestown Road Harrisburg. PA 17110 Signature o o ey (717) 238-2000 Supreme C9Fu_rVD No. Name/Address/Telephone No. of Attorney 0 FiL(?t, a _r' OF THE 2009 SIET 22 P I ic< 8 L_ 411.50 po 6'R'4 C?? it?$'7to8 ?' ?308a$ oq- USIS C v;t-rewm WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTI (S) H S/HAVE MMENCED AN ACTION AGAINST YOU. rothonotary Date: 9 .109 by Deputy ( ) Check here if reverse is used for additional information PROTHON. - 55 Sheriffs Office of Cumberland County R Thomas Kline Sheriff ?nof z: 41111 r; Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant -AFF Edward L Schorpp Solicitor R-F ? IF TI , Glenn D. Shaulis vs. Harold P. Guy SHERIFF'S RETURN OF SERVICE Case Number 2009-6315 09/25/2009 03:27 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on September 25, 2009 at 1527 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Harold P. Guy, by making known unto himself personally, at 1036 Petersburg Road Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $33.84 SO ANSWE September 28, 2009 R THOMAS KLINE, SHERIFF 011 puty Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLENN D. SHAULIS, CIVIL DIVISION Plaintiff, NO. 09 - 6315 V. PRAECIPE FOR APPEARANCE HAROLD P. GUY, 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 #17468 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLENN D. SHAULIS, CIVIL DIVISION Plaintiff, V. NO. 09 - 6315 HAROLD P. GUY, (Jury Trial Demanded) Defendant. 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, Harold P. Guy, in the above case. JURY TRIAL DEMANDED Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE 8vSKEEJ.. P.C" By: D. Ruch, Esquire el 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 3RD day of November, 2009. W. Scott Henning, Esquire Handler, Henning & Rosenberg, L.L.P. 1300 Linglestown Road Harrisburg, PA 17110 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: vin D. RaVch, Est+ unsel for Defendant OF W,c F" TP-7,W)TA€?Y 2009 NOV -4 Pt912: S 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLENN D. SHAULIS, CIVIL DIVISION Plaintiff, NO. 09 - 6315 V. PRAECIPE FOR RULE HAROLD P. GUY, TO FILE COMPLAINT 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 #17468 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLENN D. SHAULIS, Plaintiff, V. HAROLD P. GUY, Defendant. CIVIL DIVISION NO. 09 - 6315 (Jury Trial Demanded) PRAECIPE FOR RULE TO FILE COMPLAINT TO: The Prothonotary Kindly rule the Plaintiff, Glenn D. Shaulis, to file a Complaint in Civil Action within twenty (20) days. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: unsel f Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR RULE TO FILE COMPLAINT has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 3RD day of November, 2009. W. Scott Henning, Esquire Handler, Henning & Rosenberg, L.L.P. 1300 Linglestown Road Harrisburg, PA 17110 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: in D-Raucl,, Esquire nsel for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLENN D. SHAULIS, Plaintiff, CIVIL DIVISION V. HAROLD P. GUY, Defendant. NO. 09 - 6315 (Jury Trial Demanded) RULE AND NOW, this , day of , 2009, upon consideration of Defendant's Praecipe for Rule to File a Complaint, a Rule is hereby granted upon Plaintiff to file a Complaint within twenty (20) days of service, or suffer judgment Non Pros Rule issued this day of 2009. Prothonotary Distribution to: Kevin D. Rauch, Esquire Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 W. Scott Henning, Esquire Handler, Henning & Rosenberg, L.L.P. 1300 Linglestown Road Harrisburg, PA 17110 Rl pL -,OFF., aE TNT ' I - ..;? ", TAPY 2009 NOV -1, Pfd 12: 54 A. ?`Y FI I Fp--= ~ I~'-=~ ZDIJ ~E~ i ~ ~~~ I ~ 39 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLENN D. SHAULIS, Plaintiff, v. HAROLD P. GUY, Defendant. TO: Plaintiff You are hereby notified to file a written Response to the enclosed Answer and New Matter within twenty (20) days From service hereof or a judgment May be entered against you. S mers, McDonnell, Hudock, Guthrie & Skeel, P.C. CIVIL DIVISION NO. 09 - 6315 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 #17468 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLENN D. SHAULIS, CIVIL DIVISION Plaintiff, v. NO. 09 - 6315 HAROLD P. GUY, (Jury Trial Demanded) Defendant. ANSWER AND NEW MATTER AND NOW, comes the Defendant, Harold P. Guy, 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. Admitted. 3. 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. 4. Admitted in part, denied in part. It is admitted that the Defendant was the operator of a 2006 Chrysler PT Cruiser bearing Pennsylvania Registration Number GSL9646. It is denied that the Defendant was the owner of the vehicle. To the contrary, his wife, S. Katherine Guy, was the registered owner. 5. Admitted. 6. Admitted. 7. Admitted in part, denied in part. It is admitted at on October 16, 2007, at approximately 6:00 p.m., Plaintiff, Glenn D. Shaulis, was traveling southbound on Petersburg Road in South Middleton Township, Cumberland County, Pennsylvania. The remainder of the allegations in paragraph 8 are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 8. Admitted. 9. Paragraph 9 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. 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 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. 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. 14. Paragraph 14 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. 15. Paragraph 15 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. 17. Paragraph 17 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, Harold P. Guy, respectfully requests this Honorable Court enter judgment in his favor and against the Plaintiff with costs and prejudice imposed. NEW MATTER 18. 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. 19. 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. 20. To the extent that the Plaintiff has selected the limited tort option or is deemed to have selected the limited tort option then this Defendant sets forth the relevant provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law as a bar to the Plaintiffs ability to recover non-economic damages. 21. This Defendant pleads any and alt applicable statutes of limitation under Pennsylvania Law as a complete or partial bar to any recovery by Plaintiff in this action. WHEREFORE, Defendant, Harold P. Guy, 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 & SKEEL, P.C. B Y Kevin D. Rauch, Esquire Counsel for Defendant 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: ~-~-. Y, 2.A! Q ~ r ~-~ HAROLD P. GUY ~ #17468 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 18th day of February, 2010. W. Scott Henning, Esquire Handler, Henning & Rosenberg, L.L.P. 1300 Linglestown Road Harrisburg, PA 17110 SUMMERS, McDONNELL, HUDOCK, GUTHRIE 8~ SKEEL, P.C. By: Kevin D. Rauch, Esquire Counsel for Defendant FILED-,~:::~,-.~ -~.~ ~ : ~. ~ , ~''.~~Y Zu~O~~k-t ~~r(f~Q9 C~E,~V _~_ - rr~ '~~7 ~',~" i;~i W. Scott Henning, Esquire I.D.#32298 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorneys for Plaintiffs Fax : (717) 233-3029 E-mail: HenningCa~HHRLaw.com GLENN D. SHAULIS, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. HAROLD P. GUY, No. 2009-6315 CIVIL ACTION -LAW Defendant PLAINTIFF'S REPLY TO NEW MATTER AND NOW, come the Plaintiff, Glenn D. Shaulis, by and through his attorney, HANDLER, HENNING & ROSENBERG, LLP by W. Scott Henning, Esq., and responds to the Defendant's allegations of New Matter as follows: 18. Denied. The allegation set forth in paragraph 18 is a conclusion of law to which no responsive pleading is required, however, to the extent that the Honorable Court deems a response necessary, the Plaintiff acknowledges that since the subject cause of action involves a motor vehicle collision that the matter is subject to the properly applicable provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. 19. Denied. The allegation set forth in paragraph 19 is a conclusion of law to which no responsive pleading is required, however, to the extent that the Honorable Court deems a response necessary, the Plaintiff acknowledges that the subject cause of action is bound by any properly applicable provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law, as well as any other properly applicable collateral source doctrines. 20. Denied. It is denied that the Plaintiff selected a Limited Tort option. At the time of the motor vehicle collision he was riding a motorcycle insured by Allstate Insurance Company and thus is deemed to have Full Tort status, however, to the extent that the Honorable Court would determine that the Plaintiff is bound by Limited Tort status, the Plaintiff asserts that he nature and extent of his injuries would meet the threshold of a serious impairment of a bodily function (serious injury) and/or serious and permanent disfigurement, as defined by the Appellate Court Decisions interpreting Section 1705, and thus would be deemed to have Full Tort status in any event, and thus, able to recover non-economic damages. The injury sustained by the Plaintiff included a fractured right shoulder, fractured left hand and severe lacerations to the groin/scrotum requiring numerous stitches, which resulted in scarring and disfigurement. 21. Denied. The allegation set forth in paragraph 21 is a conclusion of law to which no responsive pleading is required, however, to the extent that the Honorable Court deems a response necessary, the Plaintiff denies that the subject cause of action was not filed within the applicable Statute of Limitations, and proof to the contrary is demanded at the trial in this matter. 2 WHEREFORE, Plaintiff, Glenn D. Shaulis, respectfully requests the Honorable Court to enter judgment in his favor and against the Defendant, Harold P. Guy, for the relief requested in his Complaint. Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP By: dv4.5cott Wing, squire Supreme C rt . # 32298 1300 Linglest n Road Harrisburg, P 17110 (717) 238- 00 DATED: - ~~~ h Plaintiff 3 W. Scott Henning Attorney ID# 32298 HANDLER, HENNING 8~ ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiff(s) Fax : (717) 233-3029 E-mail: Henning hhrlaw.com Glenn D. Shaulis IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) . ~• NO. 2009-06315 CIVIL ACTION -LAW Harold P. Guy Defendant(s) CERTIFICATE OF SERVICE On February 24, 2010, I hereby certify that a true and correct copy of Plaintiff's Reply To New Matter was served upon the following by depositing same in the United States Mail, in Harrisburg, Pennsylvania: Kevin D. Rauch, Esq. Summers, McDonnell, Hudock, Guthrie 8~ Skeel, LLP 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 HANDLER~fHENN~I~i~ROSENjefERG, LLP Dated: 2/24/10 W. Scott Henning VERIFICATION PURSUANT TO PA R C P NO 1024 (cl W. SCOTT HENNING, ESQUIRE, states that he is the attorney for the party filing the foregoing document; that he makes this affidavit as an attorney, because the party he represents lacks sufficient knowledge or information upon which to make a verification and/or because he has greater personal knowledge of the information and belief than that of the party for whom he makes this affidavit; and that 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. §4904 relating to unsworn falsification to authorities. Date: O'~--off ~ ~ j~ W. SCOTT~EidN~VG, E~'QUIRE Ti IE PROTHONO A C 2011 t R 28 Ail 11-- 29 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLENN D. SHAULIS, CIVIL DIVISION Plaintiff, NO. 09 - 6315 V. NOTICE OF DEATH OF DEFENDANT, HAROLD P. GUY, HAROLD P. GUY 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 #17468 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLENN D. SHAULIS, CIVIL DIVISION Plaintiff, V. NO. 09 - 6315 HAROLD P. GUY, (Jury Trial Demanded) Defendant. NOTICE OF DEATH OF DEFENDANT. HAROLD P GUY Let the record reflect that the Defendant in the above course of action, Harold P. Guy, died during the pendency of the action. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: evin D. Rauch, Esquire Counsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing NOTICE OF DEATH OF DEFENDANT, HAROLD P. GUY has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 27th day of April, 2011. W. Scott Henning, Esquire Handler, Henning & Rosenberg, L.L.P. 1300 Linglestown Road Harrisburg, PA 17110 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: Kevin . Rauch, Esquire Counsel for Defendant ZQ12 MAR 20 AM II: b 7 ? PRAECEPEFORLISTIIVGCASEFORTRIAL CUMBERLAND COUNTY i (Must be typewritten and submitted In duplicate) PENNSYLVANIA TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: for JURY trial at the next term of civil court. f ? for trial without a jury. I --- _--__----------------- ---- --- I CAPTION OF CASE (entire caption must be stated in juM (check one) . Q Civil Action -Law ? Appeal from arbitration Glenn Shaulis ? I (other) (Plaintiff) VS. The trial list will be called on June 2 61 2012 and Harold P. Gu Jul 23, 2012 Guy Trials commence on y (Defendant) Pretrials will be held on July 11, z o 12 VS. (Briefs are due S days before pretrials No. no, - 01S l I Vr Term i . Indicate the attorney who will try case for the party who files this praecipe: W Scott Henning, Esq Handler, Henning & Rosenberg,LLP 1300 Linglestown Rd., Harrisburg, PA 17110 i Indicate trial counsel forotherpartiesiflmown: Julia Phillips_ Swnmbers, McDonnell, Hudock, Guthrie & Skeel, 100 Sterling Pkwy., Suite 306, Mechanicsburg, PA 17Q50 i • j This case is ready for trial. Signed: PrintNarne: W. Scott Henni Date: March 16, 2012 Attorneyfor: Plaintiff, Glenn D. Shaulis i F are} %99-7* l 1 GLENN D. SHAULIS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 2009-6315 HAROLD P. GUY, CIVIL ACTION -LAW Defendant CERTIFICATE OF SERVICE On the 16th day of March, 2012 1 hereby certify that a true and correct copy of Plaintiff's Praecipe for Listing Case for Trial was served upon the following by depositing in U.S. Mail: Julia Phillips, Esq. Summers, McDonnell, Hudock, Guthrie & Skeel 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 HANDLER, HENNING & ROSENBERG, LLP lei W. Scott Hennin t W. Scott Henning, Esquire 1. D.#32298 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorneys for Plaintiffs Fax : (717) 233-3029 E-mail: Henning@HHRLaw.commailto:Henninga-HHRLaw.com GLENN D. SHAULIS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. HAROLD P. GUY, : No. 2009-6315 : CIVIL ACTION - LAW Defendant PRAECIPE FOR LISTING CASE FOR TRIAL TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list this case for a Jury Trial at the next Term of Civil Court. Respectfully submitted, Date -0100-- HANDLER, HENNING & ROSENBERG, LLP By l/ W. Scott Hen I.D. #32298 1300 Linglesto R Harrisburg, PA 171 (717) 238-2000 1 Attorney for Plaintiff GLENN SHAULIS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW HAROLD P. GUY, Defendant 09-6315 CIVIL TERM IN RE: CIVIL TRIAL LIST ORDER OF COURT AND NOW, this 26th day of June, 2012, it being represented to the Court by defense counsel that this matter should be removed from the trial list, without objection on the part of the Plaintiff, this matter is hereby removed from the trial list. By the Court, Christylee L. Peck, J. i/ W. Scott Henning, Esquire Handler, Henning & Rosenberg, LLP C For the Plaintiff = ? ° ..? V Julia Phillips, Esquire rn -g Summers, McDonnell, Hudock, Guthrie & Skeel N c3 ' For the Defendant - Rn Pcb eD f:e5 $40 , %'W 6/.Y7/Ia- sC) 3 <`. c W „era ??? ? 70 ,?