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Home My WebLink About09-8389 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JOHN EMANUEL 313 Eutaw Avenue New Cumberland, PA 17070 Plaintiff(s)& Address(es) FRANCESCA SQUILLARIO 4830 Brian Road Mechanicsburg, PA 17050 Defendant(s) Address(es) JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Kindly issue a Writ of Summons against Defendant Francesca Squillario. The Writ of Summons should be delivered to the Sheriff of Cumberland County for service upon the Defendant at the address listed below: 4830 Brian Road Mechanicsburg, PA 17050 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Date: December fL , 2009 NO. j)q - 8389 term CIVIL ACTION - LAW Clark DeVere, Esquire I.D. No. 68768 Andrew W. Norfleet, Esquire I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff 432329-1 C!!.J 1 l' J 7 U f? ?., , 4 qS, so Pn Am/ Ccw slgg4 p?r* oZ3y533 1 METZGER, WICKERSHAM, P.C. By: Clark DeVere, Esquire I.D. No. 68768 Andrew W. Norfleet, Esquire I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff John Emanuel JOHN EMANUEL, V. Plaintiff FRANCESCA SQUILLARIO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09- 8389 0'-tyilTerm CIVIL ACTION - LAW JURY TRIAL DEMANDED WRIT OF SUMMONS TO: Francesca Squillario 4830 Brian Road Mechanicsburg, PA 17050 You are hereby notified that Plaintiff John Emanuel has commenced an action against you. 5 n " r thonotary pk8 Dated: / 432329-1 ~p-~'r~CE C?~ 'fFlc P'~~ ~! ~~^~"fAAY METZGER, WICKERSHAM, P.C. Andrew W. Norfleet, Esquire I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 2010 M~ft - I P~ 2~ 54 t ~ . i', ~iUN'sY CtJ~! , ,~ ;r;°,ii r, T~'Civ' ti Attorneys for Plaintiff John Emanuel JOHN EMANUEL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. FRANCESCA SQUILLARIO, Defendant NO. 2009-8389 CIVIL ACTION -LAW . JURY TRIAL DEMANDED NOTICE TO DEFEND TO: Defendant Francesca Squillario 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIIZING A LAWYER. IF YOU CANNOT AFFORD TO HIIZE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION 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 (800) 990-9108 433926-1 AVISO LISTED 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) digs a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia esrita en persona o po 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 dinero reclamado en la demanda o po cualquier otra queja o compensacion reclamados por el Demandante. LISTED PUEDE PERDER DINERO, O PROPIEDADES U OTROS DERECHOS IMPORTANTES PARR LISTED. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI LISTED NO TIENE O NO CONOCE UN ABODAGO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARR AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 433926-1 METZGER, WICKERSHAM, P.C. Andrew W. Norfleet, Esquire I.D. No. 83894 3211 North Front Street P.O. Box 5300 Hamsburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff John Emanuel JOHN EMANUEL, v. FRANCESCA SQUILLARIO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff N0.2009-8389 CNIL ACTION -LAW JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, John Emanuel, by and through his attorneys, Metzger, Wickersham, Knauss & Erb, and respectfully represents the following: 1. Plaintiff John Emanuel is an adult individual residing at 313 Eutaw Avenue, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. Defendant Francesca Squillario is an adult individual residing at 4830 Brian Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. The facts and circumstances hereinafter set forth occurred on January 23, 2008, at or about 7:15 a.m. at the intersection of Carlisle Pike and St. Johns Road, Hampden Township, Cumberland County, Pennsylvania. 4. At the aforesaid time and place, Plaintiff John Emanuel was the operator of a 2007 Mercedes-Benz bearing Pennsylvania License Plate J22729J which was owned by his employer. 433926-1 5. At the aforesaid time and place, Defendant Franceska Squillario was the operator of a 2001 Dodge SSE bearing Pennsylvania License Plate GVZ1257 which was owned by Michael Squillario. 6. At the aforesaid time and place, the Mercedes Benz operated by Plaintiff John Emanuel was traveling south on St. Johns Road, had a green steady signal and was attempting to travel through the intersection of St. Johns Road and the Carlisle Pike. 7. At the aforesaid time and place, the Defendant, Franceska Squillario, was traveling west on the Carlisle Pike and was subject to a steady red signal at the intersection of St. Johns Road and the Carlisle Pike, Hampden Township, Cumberland County, Pennsylvania. 8. At the aforesaid time and place, the Defendant, Franceska Squillario failed to stop at the traffic light and pulled out into the intersection directly into the path of the vehicle being operated by Plaintiff John Emanuel who had the right-of--way and without allowing the Plaintiff sufficient time or distance to avoid a collision. 9. Defendant owed a duty to Plaintiff John Emanuel and other lawful users of the roadways in the Commonwealth of Pennsylvania to operate the vehicle she was driving in such a way as not to cause harm or damage to said other persons and to the Plaintiff in particular. 10. The aforesaid collision was the direct and proximate result of the actions and/or omissions of Defendant Franceska Squillario, in operating the 2001 Dodge SSE in a careless and negligent manner as follows: a. Failing to obey traffic control devices in violation of 75 Pa. C.S.A. §3111 and applicable law; 433926-1 b. Failing to obey duties when approaching traffic control signals in violation of 75 Pa. C.S.A. 3112 and applicable law; c. Failing to stop her vehicle when facing a steady red traffic control before entering the intersection in violation of 75 Pa. C.S.A. §3323(b) and applicable law; d. Failing to stop her vehicle at the point nearest the intersecting roadway where she had a clear view of approaching traffic on that intersecting roadway before entering it in violation of 75 Pa. C.S.A. §3323(b) and applicable law; e. Otherwise failing to comply with her duties at traffic control signals in violation of 75 Pa. C.S.A. §3323 and applicable law; f. Failing to obey traffic control devices in violation of 75 Pa. C.S.A. §3111 and applicable law; g. Failing to slow or stop the vehicle she was operating so as to avoid a collision; h. Failing to yield to Plaintiff s vehicle; i. Moving her vehicle when it was not safe to do so in violation of 75 Pa. C.S.A. §3333 and applicable law; j. In operating the vehicle at an excessive rate of speed under the circumstances in violation of 75 Pa. C.S.A. §3361 and applicable law; k. In failing to yield the right-of--way to traffic already upon the roadway; 1. In driving the vehicle she was operating onto St. Johns Road directly into the path of Plaintiff's vehicle; m. Operating her vehicle in careless disregard for the safety of persons and/or property in violation of 75 Pa. C.S.A. §3714 and applicable law; n. Operating her vehicle in reckless disregard for the safety of persons and/or property in violation of 75 Pa. C.S.A. §3736 and applicable law; o. In failing to apply the brakes to the vehicle she was operating or take other evasive action to avoid a collision with the Plaintiff's vehicle; 433926-1 p. In failing to give warning to Plaintiff John Emanuel of her impending collision with Plaintiff s vehicle; q. In failing to observe Plaintiff s vehicle; r. In failing to operate her vehicle safely in accordance with existing traffic conditions and traffic controls; s. In failing to exercise the high degree of care required of a motorist entering an intersection; t. In failing to keep alert and maintain a proper lookout for the presence of other motor vehicles on the streets and highways; u. In failing to familiarize herself with the roadways and her surroundings; v. In not paying attention to her surroundings; w. In failing to keep her vehicle under proper and adequate control so as not to expose other users to an unreasonable risk of harm; x. Colliding into Plaintiff s vehicle; y. Proceeding without clearance from a traffic control signal; z. Running a red traffic signal; aa. Failing to follow duties at intersections in violation of 75 Pa. C.S.A. §3321 and applicable law. 11. As a direct and proximate result of the collision and the negligent and careless conduct of Defendant Francesca Squillario, Plaintiff, John Emanuel, sustained and in the future may sustain, serious and debilitating injuries, some of which are or may be permanent, an aggravation and/or exacerbation of pre-existing conditions, and which include, but are not limited to, the following: (a) Left leg injury; (b) Left rib injury; (c) Left hip injury; (d) Neck injury; 433926-] (e} Pain in the left chest wall; (f) Headaches; (g) Concussion; (h) Anxiety; (i) Left temporal contusion; (j) Blunt chest trauma; (k) Abdominal left upper quadrant pain; (1) Cervical muscle spasm; (m) Left arm and elbow pain; (n) Difficulty breathing; (o) Lower back pain; (p) Left leg numbness; (q) Right leg numbness; (r) Sleep disturbance; (s) Weakness in arm and leg; (t) Decreased cervical range of motion; (u) Loss of lordosis of lumbar spine; (v) Paraspinal muscle spasms; (w) Upper back pain; (x) Mid back pain; (y) Thoracic myospasms; (z) Lumbar myospasms; (aa) Right hip pain; (bb) Right groin pain; (cc) High grade chondrosis of anterior femur and patella facet; (dd) Left shoulder pain; (ee) Buttock pain; (ff) Right suprapubic ramus fracture; and (gg) Bilateral knee contusions. 12. As a direct and proximate result of the aforesaid collision, negligence, and carelessness of Defendant Francesca Squillario, Plaintiff, John Emanuel, has undergone and in the future will undergo physical pain, mental anguish, discomfort, inconvenience, distress, embarrassment and humiliation, past, present and future loss of his ability to enjoy the pleasures of life and limitations in his pursuit of daily activities all to his great loss and detriment. 13. As a direct and proximate result of the aforesaid collision, negligence, and 433926-t carelessness of Defendant Francesca Squillario, Plaintiff, John Emanuel, has and/or may in the future incur expenses for medical treatment, surgery and rehabilitation for which damages are claimed. 14. As a direct and proximate result of the aforesaid collision, negligence and carelessness of Defendant Francesca Squillario, Plaintiff, John Emanuel, has suffered and may continue to suffer a loss of earnings, a loss of earning capacity and other economic damages for which damages are claimed. 15. As a direct and proximate result of the aforesaid collision, negligence and carelessness of Defendant Francesca Squillario, Plaintiff, John Emanuel, has and/or may in the future incur a loss of wages, a loss of earning capacity, loss of household services and other economic damages for which damages are claimed. 16. As a direct and proximate result of the aforesaid collision and the negligence and carelessness of Defendant Francesca Squillario, Plaintiff John Emanuel sustained incidental costs and losses to include, but not limited to, past and future medication costs, mileage expense and medical appliances for which damages are claimed. WHEREFORE, Plaintiff John Emanuel demands judgment in his favor and against the Defendant Francesca Squillario for the aforesaid damages, which exceed the limits of compulsory arbitration in Cumberland County, and demands costs, interest and/or damages for delay against Defendant as allowed by law. 433926-1 Date: L~ , 2010 METZGER, WICKERSHAM, KNAUSS & EP By Andrew W. rfleet, Esquir I.D. No. 8389 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717)238-8187 Attorneys for Plaintiff P.C. 433926-1 VERIFICATION I, John Emanuel, hereby certify that the following is correct: The facts set forth in the foregoing Complaint are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Complaint is that of counsel and not my own. I have read the Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Complaint is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Complaint are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Dated: ~~ 6'' ~~ 433926-1 CERTIFICATE OF SERVICE I, Andrew W. Norfleet, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and correct copy of Plaintiff's Complaint with ref~nce to the foregoing action by first class mail, postage prepaid, this<~~ day of --~ , 2010, on the following: Defendan Francesca Squillario c/o Kevin D. Rauch, Esquire SUMMERS, MCDONNELL, HUDOCK, GUTHRIE AND SKEEL, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 ~-~; Andrew W. orfleet, E 433926-1 ~ ~ i ~~EU--~; )i" llf~ ZQfg ~~~~ 29 iy-i 2~ 8 METZGER, WICKERSHAM, P.C. C~1~i~3~w •L.,,..~: ~.~Jve ~ Andrew W. Norfleet, Esquire ~~~,~~, i~,~ ~~~,~,~1~~ I.D. No. 83894 3211 North Front Street P.O. Box 5300 Attorneys for Plaintiff Harrisburg, PA 17110-0300 John Emanuel (717) 238-8187 JOHN EMANUEL, 1N THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 09-8389 CNIL ACTION -LAW FRANCESCA SQUILLARIO, Defendant JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO DEFENDANT'S ANSWER AND NEW MATTER 17. The averments contained in paragraph 17 of Defendant's New Matter are denied as conclusions of law to which no reply is required. If a reply is required, the averments are specifically denied and denied pursuant to Pa.R.C.P. No. 1029(e). Byway of further reply, the Defendant has failed to identify the defenses allegedly available to her pursuant to the Pennsylvania Motor Vehicle Financial Responsibility Law and, as a result, Plaintiff cannot more specifically reply to Paragraph 17 of Defendant's New Matter. By way of further reply, Plaintiff is not barred by any provision of the Pennsylvania Motor Vehicle Financial Responsibility Law and Defendant is not provided any defenses to any of the claims raised in Plaintiff's Complaint which is incorporated herein by reference. Strict proof of the same is demanded. 18. Conclusions of law, no reply required. If a reply is required, the averments are specifically denied and denied pursuant to Pa.R.C.P. No. 1029(e}. Byway 445261-1 of further reply, Plaintiff s medical and wage loss to date have been paid by Plaintiff's Workers' Compensation carrier. Gallagher Bassett Services, Inc. has asserted a lien for payments they made on Plaintiffs behalf and same is compensable pursuant to the Pennsylvania Motor Vehicle Financial Responsibility Law. Moreover, Plaintiff is entitled to recover any and all economic damages as more fully set forth in his Complaint which is incorporated herein by reference. 19. Conclusions of law, no reply required. If reply is required, the averments are specifically denied as stated and denied pursuant to Pa. R.C.P. No. 1029(e). Furthermore, Defendant has not specified the exact provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law he is referring to and Plaintiff cannot more specifically reply. Strict proof of the same is demanded. WHEREFORE, Plaintiff John Emanuel respectfully requests that Defendant's New Matter be dismissed and that judgment be entered in his favor and against Defendant as requested in the Complaint filed in this action. Date: ~ , 2010 METZGER, WICKS AUS/S & ERB, P. ~ y By GG_ / Andrew W. rfleet, Esquire I.D. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff 445261-1 VERIFICATION I, John Emanuel, hereby certify that the following is correct: The facts set forth in the foregoing Reply to New Matter are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Reply to New Matter is that of counsel and not my own. I have read the Reply to New Matter, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Reply to New Matter is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Reply to New Matter are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to autl Dated: b- (6- ' (~ 438211-1 CERTIFICATE OF SERVICE I, Andrew W. Norfleet, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and correct copy of Plaintiff's Reply to Defendant's Answer And New Matter with reference to the foregoing action by first class mail, postage prepaid, this day of v~---~ , 2010, on the following: Defendant Francesca Squillario c/o Kevin D. Rauch, Esquire SUMMERS, MCDONNELL, HUDOCK, GUTHRIE AND SKEEL, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 445261-1 ?,. , y l 1 ?. I s e ti I l! t.3 ? 1 l+i i '? ?9313 FEB 21 PH 1: L 2' C1,J1t1DERLk,ND COWtIT't' ,PEWiSY! VAl`41A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JOHN EMANUEL, Plaintiff, NO. 2009-8389 V. AMENDED ADMINISTRATIVE APPLICATION FOR STATUS FRANCESCA SQUILLARIO, CONFERENCE Defendant. (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Parry: 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 #17565 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JOHN EMANUEL, Plaintiff, V. NO. 2009-8389 (Jury Trial Demanded) FRANCESCA SQUILLARIO, Defendant. AMENDED ADMINISTRATIVE APPLICATION FOR STATUS CONFERENCE AND NOW, comes the Defendant, Francesca Squillario, by and through her attorneys, Summers, McDonnell, Hudock, Guthrie & Skeel, P.C., and Kevin D. Rauch, Esquire, and files the following Administrative Application for Status Conference and in support thereof avers as follows: 1. This matter arises out of a motor vehicle accident which occurred on January 23, 2008. 2. As a result of the accident, the Plaintiff filed a Complaint sounding in negligence and alleging personal injury. 3. Discovery has been conducted in this case. The parties have exchanged written discovery and have completed depositions. At this time, there is some limited and outstanding discovery. 4. In an effort to move this matter forward, this Defendant respectfully requests that the 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, as 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 it is asked that this matter be scheduled for a status conference. 7. Counsel for Defendant certifies that no Judge has ruled upon any other issue in the same or related matter. 8. Opposing counsel concurs in this motion. WHEREFORE, Defendant, Francesca Squillario, respectfully requests this Honorable Court enter an Order granting this Application and schedule a Status Conference. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. r By. G- Kevin D. Rauch, Esquire Counsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing AMENDED ADMINISTRATIVE APPLICATION FOR STATUS CONFERENCE has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 20th day of February, 2013. Andrew Norfleet, Esquire Norfleet and Lafferty, LLC 1300 Market Street, Suite 202B Lemoyne, PA 17043 (Attorney for Plaintiff) SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By. Kevin D. Rauch, Esquire Counsel for Defendant JOHN EMANUEL IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. FRANCESCA SQUILLARIO DEFENDANT NO. 09-8389 CIVIL ORDER OF COURT AND NOW, this 25th day of April, 2013, after status conference in this case, IT IS HEREBY ORDERED AND DIRECTED that: 1. All discovery in this matter shall be completed on or before May 31, 2013. 2. Any dispositive motions, if applicable, shall be filed on or before July 15, 2013. These motions will be set down for argument on or before July 22, 2013. Argument on the motions will be held during the August 9, 2013, Argument Court. 3. Any Motions in Limine shall be filed on or before September 20, 2013. 4. The Plaintiff shall call this case for trial during the call of the civil trial list scheduled for September 10, 2013. 5. Pre-trial Conference for this case will be held on September 25, 2013. 6. Trial in the matter will be held beginning October 7, 2013. By the Court, M. L. Ebert, Jr., J. C= Andrew Norfleet, Esquire MCC =M Attorney for Plaintiff =;0 ;:6 C1 4 VKevin D. Rauch, Esquire <C:) Attorney for Defendant C-) bas k IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JOHN EMANUEL, Plaintiff, NO. 2009-8389 v. 7 - (Jury Trial Demanded) FRANCESCA SQUILLARIO, n -4 Defendant. - c„� (Jr) --- PRAECIPE TO SETTLE AND DISCONTINUE o - CD TO: THE PROTHONOTARY r" Please mark the above-referenced case settled and discontinued, with prejudice. Respectfully submitted, NORFLEET & LAFFERTY, LLC • Andrew leet, Esq ire Counsel for Plaintiff