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HomeMy WebLinkAbout01-0175COM~ WEALTH OF PENNSYLVANIA -- ~ ~ COURT OF COMMON PLEAS JUDICIAL DI~RICT P.O. Box 155 27 W Rig Sp~ing Newville, PA 17Z41 NOTICE OF APPEAL PROM DISTRICT JUSTICE JUDGMENT CGMMON PLEAS No. OJ -- /7~' NOTICE OF APPEAL /- ~'~ Notice is given thor ~e appeflant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice o~ the date and in the case mentioned below. Judith S. Laws 454 Stone Church Road 12/11/00 Judith S. Laws Carlisle PA 17013 Tree-Beri Farms Kennels, etal CV 19 000015q-CH') LT 19 This block will be signed ONLY when this notation is required under Pa. R.C.P.J.P. Nc~ If a[Spellant was CLAIMANT (see Pa, R,C.P.J,P. No. 1008B. 1 O01 ( 6 ) in action before District Justice, he MUST This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEA5 to the judgment for possession in fhis case FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C,P.J.P. No, 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be sealed upon appellee). PRAECIPE: To Pmthoflotary Enter rule upon , appellee(s), to file a complaint in this appeal Name of appellee(s) (Common Pleas Nc~ ) within twenty (20) days after service of rule c~ suffer entry of judgment of non pros. RULE: To , appdlee(s). (1) You am notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by ce*tiffed o~ registered mail (2) ff you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of this rule if service was by mail is the date of mailing. Da~: , 19 . COURT FILE TO BE FILED WITH PROTHONOTARY PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FiLE COMPLAINT (Thsp~(~f fse~vceMU T~E F ED WTHN TEN 7~) DAYSAFT~-t~ ~ ~, ~x,otceo~ ~ppe~ Jn ~ ~ picabi~boxes~ ~O~ONWEALTH OF PENNSYLVANIA COUNTY OF ................... ; ~ AFFIDAVIT: hereb/~¢¢~,ear or affirm (hat I served (d~t¢ ofsevce) , ~.~ by personalservice F~ ~ . by cert ~ 8d¢ ,re~ stered) ma I, sender's !9 ...... ~ by personal service [~} by (certified) (registered) ~aiL seeder's receipt a[tached hereto ~.~ a~d furthe~ that I served the Rule to F~le a Corn ) 8[e accompar v ng the above Notice of ~ppe~ Lpo~ the appellee(s) t~ whom r,s: se de*'s receff~ 8ttaEhed heCeto SWORN (A~F ~ME{:) &had SUBSCRBEC) BE~OR ME THiS D,,, ....... · COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag D~st NO 09-3-02 DJ Name Hon Addres's: P.O* BOX 155 27 W. BIG SPRING AVENUE NEWVILLE, PA rCeoho,e /717 776'3187 17241 JUDITH S. LAWS 454 STONE CHITRCH RD CARLISLE, PA 17013 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS ~LAWS, JUDITH S 454 STONE CHURCH ED CARLISLE, PA 17013 DEFENDANT: NAME and ADDRESS ~REE-BERI FARMS KENNELS., 637 GRAHAMS WOODS RD NEWVILLE, PA 17241 ET AL. CF- 0000153- O0 Docket No.: 11/17/00 Date Filed: TIllS IS TO NOTIFY YOU THAT: uuagmenl: ] uuagmen[ was enterea for: fName []Judgment was entered against: (Name) in the:amount of $ [] Defeidant .s~; !~tl't aT~ /everal~ab, [] Damages w,i~ be'~ssess~e~d on: '- , [] This case dismi's~-d wi,~ut prejuC~e. [] Amount of JbCgment Sub/ject to Attachment/Act 5 of 1996 [] Lo¥¥ is stayo~d for__ days or [] generally stayed. [] Objection t~evy has been filed and hearing will be held: Date: ~ Place: Time: TREE'BERI FARMS KENN, ELS DISMISSRD W/O PREJUDICE (Date of Judgment) (Date & Time) DEF 001 Amount of Judgment $ .00 Judgment Costs $ . O0 Interest on Judgment $ . O0 Attorney Fees $ . O0 Total $ .00 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS 'F~E RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE'PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. t certify that this is a true and correct copy of the record of the proceedings containing the judgment. Date , District Justice My commission expires first Monday of January, AOPC 315-99 2006 SEAL -COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Mag Oisl NO: 09-3-02 DJ Name: Hon. ~'~'~: P.O. BOX 155 27 W. BIG SPRING AVENUE NEWVILLE, PA 17241 To,~v,o.o (717) 776 '3187 I AMOUNT DATE PAID F/LINGCOSTS $ ]03.00 ) t / 17/ O0 SE COSTS $ .... /._/ / $__ ~ / I CIVIL COMPLAINT PLAINTIFF: NAM~ and ADDRESS r-Udd,'./¢; 5'. - DEFENDANT: NAME ~ ADDRESS Date Filed: No~emb e ~ I 7, TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for $ -s-F~/-~. together with costs upon the following claim (iD)vii fines must inc;ude citation of the statute or ordinance violated); correct to the be~~w''y ~,m me ~acts set fOrth'i6 t~c bectl0n 4904 0f the Rrlm~e ¢~/~o n* ~ o-"~ %~%%~"~" ,H*~ ~ta[emem is made subject t0 the penalties ........ ~u= L,o r~. ~.o. 9 w~u4] related t0 uDsw0rD fRJsIflCatlOD Plaintiffs Attorney: Telephone: Address: IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVI TELEPHONE NUMBER. YOU ~USTAPPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO JUDGMENT WILL BE ENTERED AGAINST YOU BY DEFAULT, If you have a claim against the plaintiff which is within district justice jurisdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office at least five (5) days before the date set for the hearing. If you have a claim against the plainliff which is not within district justice jurisdiction, you may request information from this otfice as to the orocedures o are disabled and require assistance, [qease co,,*-,-* ,~,.-- ,,~~,.L, ........ y _u .m..ay follo..w. If you above. '- '""'~' ~''~ ,.,a~,~l~rlal UlSlrlc! olrlce at Ine address AOPC 308A-95 _ COMMONWEALTH OF PENNSYLVANIA :OUNTY OF: CUMBERLAND 09~3 -02 HELEN B. SHULENBERG~R ^~: P.O. BOX 155 27 W. BIG SPRING AVENUE NEWVILLE, PA ~,~¢o,~: (717) 776-3187 17241 HELEN B. SHULENBERGER Pin. BOX 155 DocketNo.~ CV-0000153-00 ~ 27 W. BIG SPRING AVENUE Date Filed: 11/17/00 NEWVILLE, PA 17241 · , Disposition Date: 12/11/0,0 Please De advised that an appeal has been flied in the above captioned case. Kindly use this form to indicate the results in this case, and return to the issuing authority (listed above), RESULT OF APPEAL Common Pleas Judge COMMON PLEAS NOTIFICATION REQUEST FORM PLAiNTiFF: NAME and ADDRESS CLAWS, uuuITH S 454 STONE CHURCH RD CARLISLE, PA 17013 L VS. DEFENDANT: NAME and ADDRESS ~TREE- BERI FARMS KENNELS, ET AL. 637 GRAHAMS WOODS RD NEWVILLE, PA 17241 L CIVIL-LANDLORD/TENANT APPEAL APPEAL STRICKEN - appeal has been disallowed. APPEAL DISCONTINUED - appeal has been discontinued by appellant. DISTRICT JUSTICE DECISION UPHELD - court has reached the same decision as the district justice judgment, DISTRICT JUSTICE DECISION DISMISSED - court has reached a decision that does not concur with the district justice decision. WRIT OF CERTIORARI WRIT STRICKEN - appeal has been disallowed. WRIT DISCONTINUED - writ has been discontinued by appellant. DISTRICT JUSTICE DECISION SET ASIDE - the case will be reheard due to irregularity, lack of jurisdiction, or improper venue. WRiT DISMISSED - district justice decision was not found to be flawed, lacking jurisdiction, or having improper venue, STATEMENT OF OBJECTION (Please give a general summary of the results) OBJECTION DISCONTINUED - objection has been discontinued by the appellant. OBJECTION DENIED - objection has been denied by the Court of Common Pleas. OBJECTION UPHELD - appellant's objection has been upheld by the Court of Common Pleas. tOPC7296-98 FO~/~ PRINTED: 1/12/01 11:03:51 'COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND 09-3-02 HELEN B. SHULENBERGER ^dd,~ P.O. BOX 155 27 Wo BIG SPRING AVENUE NEWVILLE, PA ~o'~l,~ ...... 1717) 776-3187 17241 HELEN B. SHULENBERGER P.O. BOX 155 27 W. BIG SPRING AVENUE NEWVILLE, PA 17241 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: aAu~ and ADDRESS ~ CLAWS, JUDITH S 454 STONE CHURCH RD CARLISLE, PA 17013 L - YS. DEFENDANT; NAME and ADDRESS ~REE-BERI FARMS KENNELS, ET AL. 637 GR/tHAMS WOODS RD NEWVILLE, PA 17241 Docket No.: CV- 0000153- O0 Date Filed: 11/17/00 :~ TIllS IS TO NOTIFY YOU THAT: Judgment: E~ Judgment was entered for: (Name) [] Judgment was entered against: (Name) in the amount of $ TREE-BERI FARMS KEN-N, ELS DISMTSSRD W/O PRR~JD!CE on: (Date of Judgment) DEF' OOJ [7 Defendants are jointly and severally liable. ] Damages will be assessed on: ~ This case dismissed without prejudice. []Amount of Judgment Subject to Attachment/Act 5 of 1996 $ [~ Levy is stayed for days or [] generally stayed· ]Objection to levy has been filed and hearing will be held: (Date & Time) Amount of Judgment $ .00 Judgment Costs $ .00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ .0 0 Post Judgment Credits Post Judgment Costs Certified Judgment Total $ $ Date; Place: Time; ANY PA~TY NAS THE ~IGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUD~MEN'r BY FILING'~ NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF T~IS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH Y~IJR NOTICE OF APPEAL. Date " , District Justice certify that this is a true and correct copy of the record of the proceedings containing the'judgmentl Date , District Justi~:e My commission expires first Monday of January, AOPC 315~99 2006 SEAL COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS JUDICIAL DISTRICT NOTICE OF APPEAL F~K~M DISTRICT JUSTICE JUDGMENT CC~4MON PLEAS NO. ~ . ~ ~ NOTICE OF APPEAL ~ - ~ · ~ Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Distrid Justice on the date and in the case mentioned belo~ (3TY Carlisle /01 3 This black will be signed ONLY when this notation is required under Po. R.C.PJ.P. ~ If ~llant was CLAIMANT (see Pa. R.C.P.J.P. No. 1008B. This Notice of Appeal, when mce/ved by the District Justice, will operate as a 1001(6) in action before District Justice, he MUST SUPERSEDEAS to the judgment for possession in this case FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of fo~m to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.R No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee). PRAECIPE: To Prothonotary Enter rule upon (Common Pleas Name of appelk)e(s) ~2 , appedlee(s), to file a complaint in this appeal ) within ~,~nty (20) days after service of rule or suffer entry of judgment of non pros. RULE: To , appdlee(s). (1) ~u are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered moil (2) If you do not file a complaint within this t/mo, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of service of this rule if se~¥ice was by moil is the date of moiling. Date: , 19 . ~c ~-~ COURT FILE PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FiLE COMPLAINT AFFiDAViT: ~,e eby swear o~ afl ~ tm~t (da~e ~ servac) ~_1 2 / 0 1 [] by ~ersonai s~rv~ce ~ by ((ertified ~ ma~, se~der's rece~p attached here), and pon the appelt('s (~a~e) . R~nnks Foland, Esquire on ~.~ ~/0.~ ...... and further that ~ erred the Ru~e to Fite a C( np~a r t accompany r g th~;, above Notice o~ Appea aport the app~ lee(s) to whom th R~ewasaddressea o !9 [~, by pe~s ~at ~ervc } b' ;.rtfed. 9sered ~ ~iENDER: extra fee): 2. [] Restricted Dellven/ ~ 3. ~jtde Addressed to: /-. 4~, Ar~ie Nungger = 6. : Ps Fo~ 3811, ~mber 1~4 Domestic Return R~ipt JUDITH S. LAWS, : Plaintiff TREE-BERI FARMS KENNELS, : JOHN TARTAMELLA and : SANDY TARTAMELLA, his wife: Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-175 Civil NOTICE TO DEFEND 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. SAIDIS IUFF, FLOWER % LINDSEY 5 W. High Street Carlisle, PA Dated: Court Administrator Floor, Cumberland County Courthouse Carlisle, PA 17013 240-6200 25, ~0o I SAIDIS, SHUFF, FLOWER & LI~SAY Joh Esq~r~ Supreme ~urt I~. #53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff SAIDIS [UFF, FLOWER LINDSEY W, High Street Carlisle, PA JUDITH S. LAWS, : Plaintiff : TREE-BERI FARMS KENNELS, : JOHN TART~24ELLA and : SANDY TARTAMELLA, his wife: Defendants : COMPLAINT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-175 Civil 2. The Defendants, John Tartamella and Sandy Tartamella, are both adult individuals residing at 637 Grahams Woods Road, Newville, PA 17241. 3. On or about October 15, 2000, the Plaintiff took her three greyhound dogs to the establishment of the Defendant for kenneling. 4. Earlier the morning of October 15, 2000, one of the greyhound dogs ~Annie", suffered what seizure. After said seizure occurred, immediately contacted her veterinarian to as to special treatment for Annie. appeared to be a the Plaintiff receive information 5. Because veterinarian, as well as greyhounds and medicine, of the information she received from the a result of her own knowledge about Plaintiff advised the Defendants that other arrangements needed to be made for Annie, because of for her own safety, she would need to be separated from the other two greyhounds in the event another seizure would occur. residing at 454 Stone Church Road, Carlisle, PA 17013. 1. The Plaintiff is Judith S. Laws, an adult individual SAIDIS HUFF, FLOWER & LINDSEY Carlisle, PA another dog was leaving the nearby kennel, kennel would be made available for Annie. The Defendants advised the Plaintiff that since then a separate the Defendant, Sandy Tartamella that her husband, to Northside Veterinary Clinic with Annie. 8. That afternoon, Annie attacked by the other two dogs. Defendants did not kennel her; October 18, 2000, as a result of dogs. 9. Because the negligence of the Defendant the dogs together, losses: 7. On or about October 16, 2000, the Plaintiff contacted establishment of the Defendants and was advised by the John, was going suffered a seizure and was The sole reason that the she subsequently died Wednesday the attack by the other two in putting the Plaintiff has suffered the following a. the cost of Annie - b. hospital bill for veterinary care - d. lost wages total $200.00 $831.04 $715.84 ($44.64 x 16 hours) $1,746.88 WHEREFORE, Plaintiff prays Your Honorable Court to enter judgment in favor of the Plaintiff and against the Defendants $1,746.88 plus interest, costs and in the amount of attorney's fees. Dated Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA 17013 Attorney for Plaintiff SAIDIS FLUFF, FLOWER LINDSEY W. High Street Carlisle, PA VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: ~Judith S. Laws hereby certify that I served a true and correct foregoing Complaint upon all parties of record States Mail, postage prepaid, addressed as follows: 200! I, copy of the via United Brooks Foland, Esquire Thomas, Thomas & Hafer 305 North Front Street Harrisburg, PA 17101 SAIDIS, SHUFF, FLOWER & LINDSAY SAIDIS ;HUFF, FLOWER & LINDSEY 26 W. High Street Carlisle, PA JUDITH S. LAWS, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. TREE-BERI FARMS KENNELS, JOHN TARTAMELLA AND SANDY TARTAMELLA, HIS WlFE~ DEFENDANTS No. 01-175 CIVIL JURY TRIALDEMANDED NOTICE TO PLEAD You are hereby notified to plead to the enclosed Answer with New Matter within twenty (20) days from service hereof or a default judgment may be entered against you. ANSWER WITH NEW MATTER AND NOW, come Defendants Tree-Beri Farms Kennels, John Tartamella and Sandy Tartamella, by and through their attorneys, Thomas, Thomas & Hafer, LLP, and files the following Answer with New Matter: 1. Denied. Defendants are without information or belief as to the truth of the averments of paragraph 1 of Plaintiff's Complaint and the same are therefore denied and proof thereof is demanded at time of trial. 2. Admitted. 3. Admitted. 4. Denied. Defendants are without information or belief as to the truth of the averments of paragraph 4 of Plaintiff's Complaint and the same are therefore denied and proof thereof is demanded at time of trial. 5. Denied. It is specifically denied that Plaintiff advised Defendants that "other arrangements needed to be made for Annie" or that "she would need to be separated from the other two Greyhounds in the event another seizure would occur." To the contrary, Plaintiff instructed Defendants to kennel Annie with the other two dogs during the day and separate Annie only at night. Any and all other allegations contained in paragraph 5 are specifically denied and strict proof thereof is demanded at time of trial. 6. Denied. It is specifically denied that Defendants advised Plaintiff that since another dog was leaving the nearby kennel, that a separate kennel would be made available for Annie. 7. Admitted. 8. Denied as stated. It is admitted only that Annie was apparently attacked by one or both of the other two dogs with which she was kenneled. Any and all other allegations contained in paragraph 8 are specifically denied and strict proof thereof is demanded at time of trial. 9. Denied. The allegations contained in paragraph 9 are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, Defendants Tree-Beri Farms Kennels, John Tartamella and Sandy Tartamella, respectfully request that judgment be entered in their favor and against Plaintiff. NEW MATTER 10. Some or all of Plaintiff's claims, if any, may be barred or reduced by Plaintiffs own contributory and/or comparative negligence. 11. Some or all of Plaintiff's claims and/or damages, if any, are barred or reduced by the Pennsylvania Dog Law. 12. Some or all of Plaintiffs damages and/or claims, if any, may be barred or reduced by Plaintiff's failure to mitigate damages. 13. Some or all of Plaintiff's damages and/or claims, if any, may be barred or reduced by the limitation of liability provision contained in the kennel agreement between Plaintiff and Defendants. WHEREFORE, Defendants Tree-Beri Farms Kennels, John Tartamella and Sandy Tartamella, respectfully request that judgment be entered in their favor and against Plaintiff. Respectfully submitted, by: B~ooks ~. Foland, Esquire ~ I.D. No. 70102 305 North Front Street, 6th Floor POB 999 Harrisburg, PA 17108-0999 (717) 255-7626 :122810.1 Attorneys for Defendants VERIFICATION I, John Tartamella, have read the foregoing Answer with New Matter and hereby affirm that it is true and correct to the best of my personal knowledge, information and belief. This Verification and statement is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities; I verify that all the statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa.C.S. § 4904. CERTIFICATE OF SERVICE day of ~c~ ,~_, 200/_, I, Coleen M. Polek, of the law firm of Thomas, Thomas & Hafer, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Johnna J. Kopecky, Esq. Saidis, Shuff, Flower & Lindsay 26 West High Street Carlisle, PA 17013 Coleen M. Polek JUDITH S. LAWS, : Plaintiff : TREE-BERI FARMS KENNELS, : JOHN TARTA/~ELLA and : SANDY TARTA/~ELLA, his wife: Defendants : IN THE COURT OF COMMON PLEAS CIIMBERLA-ND COUNTY, PENNSYLVANIA NO. 01-175 Civil PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Please mark the discontinued and ended. above-captioned matter settled, Date: ~-- 25~o ! Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff SAIDI$ SHUFF, FLOWER & LINDSAY ATFORI~YS*AT.LAW 26 W. High Street Carlisle, PA