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Home My WebLink About10-0227 OF TH PIRTHONOTARY Z019 JAN -7 AM 8: 33 CUMB' i' V-40 r0LN Y PEN?16 1'![N 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 MANDY L. GALLO 559 Jonathan St. Shippensburg, PA 17257 versus Plaintiff(s) & 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 forwarded to ( )Attorn W. Scott Henning. Esquire Handler. Henning & Rosenberg LLP 1300 Linglestown Road Harrisburg. PA 17110 Signature of Attc (717) 238-2000 Supreme Court I Name/Address/Telephone No. of Attorney Date: January 4. No. 2010 - aod7 (-.iui I Term Civil Action (XX) Law ( ) Equity JOAN E. COLLINS 1970 Saranec Ave. Lake Placid, NY 12946 Defendant(s) & Address(es) 49a.co Po ATN ???r lst 9Aa WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAIN 7MIVE COM NCED AN ACTION AGAINST YOU. -Aff Prothonotary Date: ! 7 //O by Deputy ( ) Check here if reverse is used for additional information PROTHON. - 55 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ???,,,tv of ?urNbrr??4 < 4 1 OFFICE QF'rF. $4ERIFF F FC, TP7 'n ARY Jody S Smith Chief Deputy Edward L Schorpp Solicitor 2010 FEB - I P;; 2: 29 Mandy L. Gallo Case Number vs. 2010-227 Joan E. Collins SHERIFF'S RETURN OF SERVICE 01/14/2010 On this date Ronny R. Anderson, Sheriff mailed the within Writ of Summons by certified mail, return receipt requested to Joan E. Collins. 01/2712010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he served the within Writ of Summons upon the within named defendant, Joan E. Collins, in the following manner: On January 14, 2010 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Writ of Summons to the defendant's last known address of 1970 Saranec Avenue, Lake Placid, NY 12946. The certified mail return receipt card was received by the Cumberland County Sheriffs Office signed by Joan E. Collins on January 25, 2010. SHERIFF COST: $33.98 SO ANWERS, January 28, 2010 (6 CountySuite SrerM. Teleosoft. Inc. RONW R ANDERSON, SHERIFF r m $ Aso pp5tege A Fee r cep' PtF?I oOd A? ?F t7 E<'dO?? &Fe e O t?`P?aB 0 ?O - r Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can retum the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: JOAN E. COLLINS 1970 SARANEC AVENUE LAKE PLACID, NY 12946 4 A. X c 0 Agent B. ^oelved by (Printed Name) C. of ivory 1 -S (O D. Is delivery address differerd from item i? 13 es if YES, enter delivery address below: 0 No 3. Service Type -?,O Certiffed Mail 0 EVress Mail 0 Registered 0 Return Receipt for Merchandise 0 insured man 0 C.O.D. 2010-227 4. Restricted Delivery? (r=xua Fee) 0 yes 2. ArticlleNumber 7006 0810 0000 7881 7687 PS Form 3811, Febnlary 2004 Domestic Return Receipt 102595-02-M-1540 $ FII r E ?-D LJFFiVI, THE P7,-,C ^N`0TRRY 2010 FEB -9 PM 2: 4 6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MANDY L. GALLO, CIVIL DIVISION Plaintiff, NO. 2010-227 V. PRAECIPE FOR APPEARANCE JOAN E. COLLINS, 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 #17674 t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MANDY L. GALLO, CIVIL DIVISION Plaintiff, V. NO. 2010-227 JOAN E. COLLINS, (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, Joan E. Collins, in the above case. JURY TRIAL DEMANDED Respectfully submitted, SUMMERS, MCDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: Ken D" Raucll, Esquire Co nsel 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 8'h day of February, 2010. W. Scott Henning, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 (Attorney for Plaintiff) SUMMERS, MCDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: n D. Rauch, Esquire nsel for Defendant PILED ^?`ri,,E ()r THE Pa ??,I4)? JOTARY 2010 FEB -9 PM 2.46 CUB ju'Nl iY 1 is,1L 1ANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MAN DY L. GALLO, Plaintiff, V. JOAN E. COLLINS, Defendant. Civil Division No. 2010-227 PRAECIPE FOR RULE TO FILE COMPLAINT Filed on behalf of the Defendant Counsel of Record for this Party Kevin D. Rauch, Esquire I.D. #83058 Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #17674 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MANDY L. GALLO, Plaintiff, V. JOAN E. COLLINS, Defendant. CIVIL DIVISION NO. 2010-227 (Jury Trial Demanded) PRAECIPE FOR RULE TO FILE COMPLAINT TO: The Prothonotary Kindly rule the Plaintiff, Mandy L. Gallo, to file a Complaint in Civil Action within twenty (20) days. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. j By: in D. Rau h, Esquire rney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MANDY L. GALLO, CIVIL DIVISION Plaintiff, V. NO. 2010-227 JOAN E. COLLINS, Defendant. (Jury Trial Demanded) RULE AND NOW, this , day of &--6ru lrV , 2010, 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 _ k day of FejaC W r?/ , 2010. Protho otary 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 8th day of February, 2010. W. Scott Henning, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 (Attorney for Plaintiff) SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C/^a By: /"A X 0 A) 4&%__--1 K4v'ih1D._Ra?ch, Esquire A ornev for Defendant MANDY L. GALLO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYV/A0kcD ?c C= V. NO. 2010-227-CIVIL TERM co JOAN E. COLLINS, Defendants CIVIL ACTION - LAW 4 t_ ; mac? NOTICE w 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 HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE 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 (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accibn dentro de los pr6ximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacibn o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. 7 USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOME AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 South Bedford Street, Carlisle, PA 17013 (800) 990-9108 - (717) 249-3166 Very truly yours, HANDLER, HENNING & ROSENBERG, LLP By: 8 F:\WP Directories\AMC\Complaints\MVA\Rear End\Gallo, Mandy.wpd W. Scott Henning, Esquire I . D.#32298 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road, Suite 2 Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax : (717) 233-3029 E-mail: Henning@HHRLaw.com Attorneys for Plaintiff MANDY L. GALLO, Plaintiff V. JOAN E. COLLINS, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-227-CIVIL TERM CIVIL ACTION - LAW COMPLAINT AND NOW, comes the Plaintiff, Mandy L. Gallo, by and through her attorney, HANDLER, HENNING & ROSENBERG, LLP, by W. Scott Henning, Esquire, and makes the within Complaint against the Defendant, Joan E. Collins, and avers as follows: 1. Plaintiff, Mandy L. Gallo, is an adult individual currently residing at 559 Jonathan Street, Shippensburg, Franklin County, Pennsylvania 17257. 2. Defendant, Joan E. Collins, is an adult individual currently residing at 1970 Saranec Avenue, Lake Placid, New York 12946. 3. At all times material hereto, Plaintiff, Mandy L. Gallo, was the front seat passenger of a 1994 Chrysler LHS bearing Pennsylvania registration number GMT 9024, said vehicle was owned and operated by Plaintiffs mother, Sharon H. Keefer. (Hereinafter referred to as "Plaintiffs vehicle"). 4. At all times material hereto, Defendant, Joan E. Collins, was the owner and operator of a 2005 Jeep Grand Cherokee bearing New York registration number DVF 7646. (Hereinafter referred to as "Defendant's vehicle") 5. At all times material hereto, a motor vehicle insurance policy was issued to Plaintiffs mother, Sharon H. Keefer, through Nationwide Insurance Company of America, said policy provided for limited tort status. Due to Plaintiff being listed as a named driver under the policy and her status as a resident relative, Plaintiff is decreed an insured under her mother's insurance policy, however, Plaintiff is deemed to have full Tort status by virtue of the fact that, inter alia, Defendant's vehicle was registered in the State of New York. 6. At all times material hereto, there were no adverse weather or road conditions. 7. On or about January 24, 2008, at approximately 5:24 p.m., Plaintiffs vehicle was lawfully exiting onto an off-ramp of Interstate 81, approaching the stop sign at the intersection with Walnut Bottom Road in Shippensburg Township, Cumberland County, Pennsylvania. 8. At approximately the same time and place, Defendant, Joan E. Collins, was also exiting onto the off-ramp of Interstate 81, directly behind Plaintiffs vehicle in Shippensburg Township, Cumberland County, Pennsylvania. 9. When Plaintiffs vehicle came to a stop as a result of the posted stop sign at the intersection of Walnut Bottom Road, it was, suddenly and without warning, violently struck from the rear by Defendant, who had failed to come to a stop. Plaintiff immediately 2 experienced back and neck pain and was transported via ambulance to Chambersburg Hospital. 10. As a direct and proximate result of the negligence of the Defendant, Joan E. Collins, Plaintiff, Mandy L. Gallo, sustained personal injuries, as set forth more specifically below. 11. The occurrence of the aforementioned collision and the resultant injuries to Plaintiff, Mandy L. Gallo, are the direct and proximate result of the negligence, carelessness, and/or recklessness of Defendant, Joan E. Collins, generally and more specifically as set forth below: (a) In failing to be reasonably vigilant to observe the road and traffic conditions then and there existing; (b) In failing to have due regard for the speed of the vehicles and the traffic upon the road and the condition of the highway, in violation of 75 Pa. C.S.A. § 3310(a); (c) In failing to operate her vehicle in such a manner that would allow her to apply the brakes and stop before striking the rear of the vehicle in front of her; (d) In failing to properly regulate the speed of her vehicle so as to prevent a rear-end collision; (e) In failing to operate her vehicle at a speed and under such control so as to be able to stop within the assured clear distance, in violation of 75 Pa. C.S.A. § 3361; 3 (f) In failing to operate her vehicle at a speed that was safe for existing conditions, in violation of 75 Pa. C.S.A. § 3361; (g) In following another vehicle more closely than is reasonable and prudent; (h) In failing to keep a proper lookout for vehicles lawfully stopped at the intersection of the Interstate 81 off-ramp and Walnut Bottom Road, in Shippensburg Township, Cumberland County, Pennsylvania; (i) In failing to exercise reasonable care in the operation and control of her vehicle, in violation of 75 Pa. C.S.A. § 3714; Q) In failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in failing to have her vehicle under such control that injury to persons or property could be avoided; and 12. As a direct and proximate result of the Defendant's negligence, Plaintiff, Mandy L. Gallo, sustained injuries, including but not limited to, a cervical sprain/strain, headaches and neck, upper back and middle back pain and stiffness. 13. As a direct and proximate result of the Defendant's negligence, Plaintiff, Mandy L. Gallo, has suffered physical pain, discomfort, and mental anguish, and she will continue to endure the same for an indefinite period of time into the future, to her physical, emotional, and financial detriment and loss. 14. As a direct and proximate result of the Defendant's negligence, Plaintiff, Mandy L. Gallo, has been compelled, in order to effect a cure for the aforesaid injuries, to 4 spend money for medicine and/or medical attention, and will be required to expend money for the same purposes in the future, to her financial detriment and loss. 15. As a direct and proximate result of the Defendant's negligence, the Plaintiff, Mandy L. Gallo, has suffered a loss of income and will continue to suffer a loss of earnings in the future, to her financial detriment and loss. 16. As a direct and proximate result of the Defendant's negligence, Plaintiff, Mandy L. Gallo, has been, and probably will in the future be, hindered from attending to her daily duties, to her detriment, loss, humiliation, and embarrassment. 17. As a direct and proximate result of the Defendant's negligence, Plaintiff, Mandy L. Gallo, has suffered a loss of life's pleasures, and will continue to endure the same in the future, to her detriment and loss. WHEREFORE, Plaintiff, Mandy L. Gallo, seeks damages from Defendant, Joan E. Collins, in an amount in excess of the compulsory arbitration limits of Cumberland County, exclusive of interest and costs. 3Date: - 3 6 Respectfully submitted, HANDLER, HENNING ROSENBERG, LLP By: F W. Scott Henn' g, squire I . D. #32298 1300 Ling lesto Road, uite 2 Harrisburg, PA 17110 (717) 238-2000 Attorneys for Plaintiff 5 MANDY L. GALLO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2010-227-CIVIL TERM JOAN E. COLLINS, . Defendants CIVIL ACTION - LAW CERTIFICATE OF SERVICE On the 3' day of March, 2010, 1 hereby certify that a true and correct copy of Plaintiffs Complaint was served upon the following by depositing in U.S. Mail; Kevin D. Rauch, Esq. Summers, McDonnell, Hudock, Guthrie & Skeel, LLP 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 Very truly yours, HANDLER, NNIN RI By: W. Scott He ing WSH/tgd RG, LLP 6 VERIFICATION The undersigned hereby verifies that the statements in the foregoing document are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language of the document is of counsel and not my own. I have read the document 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 contents of the document are that of counsel, I have relied upon my counsel in making this Verification. The undersigned also understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Mandy L. G 911o Date: � Y i`1 L L -Ci1O I'L jC'L i'iE Ki0TiiC'WOTA . fl,13 AU G 26 PIN I: 3 I('LJ MBEIiLA�dD COU14TY PENfgSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MANDY L. GALLO, CIVIL DIVISION Plaintiff, NO. 2010-227 V. DEFENDANT'S ADMINISTRATIVE JOAN E. COLLINS, 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 #17674 �0 TAi k i. 2013 AUG 26 PM 1- ')0 ruMiBER AQ COUI;d', p IN THE COURT OF COMMON PLEAS OF CLQ9RLAND SYLyAId1A COUNTY, PENNSYLVANIA MANDY L. GALLO, CIVIL DIVISION Plaintiff, V. NO. 2010-227 JOAN E. COLLINS, (Jury Trial Demanded)- Defendant. DEFENDANT'S ADMINISTRATIVE APPLICATION FOR STATUS CONFERENCE AND NOW, comes the Defendant, Joan E. Collins, 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 24, 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. WHEREFORE, Defendant, Joan E. Collins, respectfully requests this Honorable Court enter an Order granting this Application and scheduled a Status Conference. Respectfully submitted, SUMMERS, MCDONNELL, HUDOCK, GWRE C. B quire ant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing DEFENDANT'S ADMINISTRATIVE APPLICATION FOR STATUS CONFERENCE has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 23rd day of August, 2013. W. Scott Henning, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 (Attorney for Plaintiff) SUMMERS, MCDONNELL, HUDOCK, GUTHRIE & SKEEL, P. By: AvidD. Rauch, Esquire Counsel for Defendant mco V) rat-- Z.J '0 �f°'; (N CD I C:3 C-)M _ Z --t c' C-n "? 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: Henning @HHRLaw.com MANDY L. GALLO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2010-227-CIVIL TERM JOAN E. COLLINS, Defendants CIVIL ACTION - LAW STATEMENT OF INTENTION TO PROCEED To the Prothonotary of Cumberland County: Plaintiff hereby notifies the Court of her intention to proceed with the above captioned matter. Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP By: W. Scott H n ing, E uire Supreme o rt LD # 32298 1300 Lin sto Road Harrisburg, 17110 Henning hhrlaw.com (717) 238-2000 DATED: Attorney for Plaintiff MANDY L. GALLO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2010-227-CIVIL TERM JOAN E. COLLINS, Defendants CIVIL ACTION - LAW CERTIFICATE OF SERVICE On the 5th day of September, 2013, 1 hereby certify that a true and correct copy of Plaintiff's Intent to Proceed was served upon the following by depositing in U.S. Mail; Kevin D. Rauch, Esq. Summers, McDonnell, Hudock, Guthrie &Skeel, LLP 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 Very truly yours, HANDLER, HEN ERG, LILP By: W. Scott ennin 2 MANDY L. GALLO, • IN THE COURT OF COMMON PLEAS OF PLAINTIFF • CUMBERLAND COUNTY, PENNSYLVANIA • V. • JOAN E. COLLINS, • DEFENDANT • 10-0227 CIVIL TERM ORDER OF COURT AND NOW, this day of November, 2013, upon consideration of Defendant's Administrative Application for Status Conference, a status conference shall commence at 11:00 a.m., Monday, December 23, 2013, in chambers. By the Court, 001, 4011112(Ake. - bert H. Masl. VN. Scott Henning, Esquire 1300 Linglestown Road Harrisburg, PA 17110 For Plaintiff Xcevin D. Rauch, Esquire 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 For Defendant PI "3 rrl •sal ��' I ES t ; alr MANDY L. GALLO, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JOAN E. COLLINS, DEFENDANT 10-0227 CIVIL TERM ORDER OF COURT AND NOW, this day of November, 2013, the time set for the status conference on Monday, December 23, 2013 is moved to 9:30 a.m. By the Court, Albert H. ."I-'WScott Henning, Esquire 1300 Linglestown Road Harrisburg, PA 17110 For Plaintiff ,,,- ev in D. Rauch, Esquire 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 For Defendant :Sal co r., A4113 CD rte_ z CD , ..4 C'D -r CD -4 MANDY L. GALLO, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JOAN E. COLLINS, DEFENDANT 10-0227 CIVIL TERM IN RE: STATUS CONFERENCE ORDER OF COURT AND NOW, this a 6 day of December, 2013, following a status conference with counsel, upon representation of Plaintiff's counsel that this matter is appropriate for arbitration, if not settlement, we refrain from listing this matter for trial because Plaintiff's counsel will be filing a praecipe to schedule the matter for arbitration. In the meantime, we encourage the parties to use their best efforts to settle this case. By the Court, Albert H. Masland, J. ✓ W. Scott Henning, Esquire 1300 Linglestown Road Harrisburg, PA 17110 For Plaintiff Carrie Taylor, Esquire 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 For Defendant :sale" Y.� a LC =�k �m 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA• Mandy L. Gallo • Plaintiff • NO.2010-227 CIVIL TERM r. VS cr. • Joan E. Collins xr- -- _ Defendant '{-- ' RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in the following form: ?> THE PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE,THE JUDGES OF SAID COURT: W. Scott Henning , counsel for the plaintiff/defendant in the above action(or actions),respectfully represents that: 1. The above-captioned action(or actions)is(are)at issue. 2. The claim of plaintiff in the action is$Less than $50,000.00 The counterclaim of the defendant in the action is N/A The following attorneys are interested in the case(s)as counsel or are otherwise disqualified to sit as arbitrators: Kevin D. Rauch, Esq. and W. Scott Henning, Esq. WHEREFORE,your petitioner prays your Honorable Court to appoint three(3)arbitrators to whom the case shall be submitted. Respectfully submitted, Q A 1,8.Sopd Q41 C ex-t3/4 gooLl ORDER OF COURT AND NOW, , 20 , in consi eration of the foregoing petition, Esq.,and Esq., and Esq., are appointed arbitrators in the above captioned action(or actions)as prayed for. By the Court, KEVIN A.HESS,P.J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Mandy L. Gallo Plaintiff NO.2010-227 CIVIL TER -f VS rnOD , ,: . Joan E. Collins ' Defendant { �' p Cn RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in the following form: THE PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE,THE JUDGES OF SAID COURT: W. Scott Henning , counsel for the plaintiff/defendant in the above action(or actions),respectfully represents that: 1. The above-captioned action(or actions)is(are)at issue. 2. The claim of plaintiff in the action is$Less than $50,000.00 The counterclaim of the defendant in the action is N/A The following attorneys are interested in the case(s)as counsel or are otherwise disqualified to sit as arbitrators: Kevin D. Rauch, Esq. and W. Scott Henning, Esq. WHEREFORE,your petitioner prays your Honorable Court to appoint three(3)arbitrators to whom the case shall be submitted. Respectfully submitted, ey ORDER OF COURT AND NOW, /s , 20J�, in consi eration of the foregoing petition, Esq.,and LaA � Esq., and Esq., are appointed arbitrators in the above captioned action(or actions)as prayed for. ,n•v. ..�r By the Court, /��'�A► u }' KEVIN A.HE ,P.J. `�1S ,dos ; appies MANDY L. GALLO JOAN E. COLLINS We do solemnly and'the Constit Plaintiff Defendant In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2010 - 227 Civil Action - Law. Oath ar (or affirm) that we will support, obey and defend the Constitution of the United States of this Commonwealth and that we will d. _ -urge the duties of ur office with fidelity. S natu William C. Costopoulos Name (Chairman) Costopoulos, Foster & Fields Law Firm 831 Market Street Address Lemoyne 17043 City, Zip Sl"gnature Mark A. Mateya Name Mateya Law Firm Law Firm 55 West Church Avenue Address Carlisle 17013 City, Zip igna Garret J. Brouwer Name Salzmann Hughes PC Law Firm 354 Alexander Spring Road Address Carlisle 17015 City, Zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) At 4. 1, 02x 0, )1( Date of Award: .Arbitrator, dissents. (Insert name if applicable.) Y 14 2014 May 14, 2014 William . Costopoulos, Esquire Date of Hearing: may -"(Chairman) Notice of Entry of Award Now, the 1 / day of %4a , 20 J'/ , at /.7-79 , .M., the above award was entered upon the docket and not ce thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ '//L/ .37) Prothonotary ,FILEO-OFFICE OF -1HE PROTHONOTAFC1' 2014 HAY 114 CUMBERLAND COUNTY PENNSYLVANIA 5)944- 1-ieort i'ris , Car1» 72yioc, 6p; mallet -4 6//iy Aed-- It. PRO Ht bo TAR 2014 JUL 14 P 5I CD fBERL AND G PENNSYLVANIA"T1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MANDY L. GALLO, CIVIL DIVISION Plaintiff, v. NO. 2010-227 JOAN E. COLLINS, (Jury Trial Demanded) Defendant. PRAECIPE TO DISCONTINUE TO: Prothonotary Please mark the above -referenced case discontinued, with ; prejudice. Respectfully submitted, Handler, Henning & Rosenberg, LLP By -=e® W. Scott Course ,.Esq ntiff re