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HomeMy WebLinkAbout10-3089F" 2DID MAY i 1 PM t:19 ova ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attorney ID# : 35956 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: dlutz@angino-rovner.com PAUL MARTZ, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 10 -3089 CIVI l Term PENNEY NOSS, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED 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 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. p,L o j? Qa.oo P o A77Y c1?'* gao?o e aq 187T 436530 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. Pennsylvania Lawyer Referral Service Pennsylvania Bar Association, P.O. Box 186, Harrisburg, PA 17108 TELEPHONE 1-800-692-7375 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se persentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n 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 acci6n 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 reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Used puede perder dinero o propiedad a otros derechos importantes para used. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZ,CAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Pennsylvania Lawyer Referral Service Pennsylvania Bar Association, P.O. Box 186, Harrisburg, PA 17108 TELEFONO 1-800-692-7375 436530 ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attorney ID# : 35956 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: dlutz@angino-rovner.com PAUL MARTZ, Plaintiff V. PENNEY NOSS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff Paul Martz is an adult individual and citizen of the Commonwealth of Pennsylvania and resides in Lemoyne, Cumberland County, Pennsylvania. 2. Defendant Penney Noss is an adult individual and citizen of the Commonwealth of Pennsylvania that resides at 317(B) South Enola Drive, Enola, Cumberland County, Pennsylvania, 17025. 3. The facts and occurrences hereinafter related took place on or about June 22, 2008, around 12:26 p.m. on Bridge Street, New Cumberland, Cumberland County, Pennsylvania. 4. At that time and place, Plaintiff Paul Martz was operating his bicycle traveling south on Bridge Street, on the west side of Bridge Street. 5. At the same time and place, Defendant Penney Noss was operating a 2001 Buick Regal, planning to turn left from a private parking lot on the west side of Bridge Street, and travel north on Bridge Street. 436530 6. Defendant Penney Noss pulled her vehicle from the private parking lot onto the southbound lane of Bridge Street, but did not look to her left to see Mr. Martz traveling south on Bridge Street on his bicycle. 7. When Defendant Penney Noss pulled her vehicle directly in front of Mr. Martz's bicycle, he was forced to veer to his left to avoid a collision, causing his bicycle to collide into the curb on the east side of Bridge Street. As a result of Mr. Martz's bicycle colliding into the curb, he was catapulted over his handlebars and sustained bodily injury when his body struck the ground. 8. The foregoing incident and all of the injuries and damages set forth herein sustained by Plaintiff Paul Martz is the direct and proximate result of the negligent, careless, wanton, and reckless manner in which Defendant Penney Noss operated her motor vehicle as follows: a. failure to keep alert and maintain a proper watch for the presence of bicycles traveling on Bridge Street; b. failure to yield the right-of-way to Mr. Martz's bicycle traveling south on Bridge Street; C. failure to see Mr. Martz and Mr. Martz's bicycle proceeding south on Bridge Street; and d. driving her vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 436530 2 9. Plaintiff Paul Martz sustained painful and severe injuries, which include but are not limited to left chest pain, trouble breathing, groin pain, traumatic pneumothorax necessitating a thoracostomy, multiple abrasions, superior and inferior pubic ramus fracture, and neck and back pain. 10. By reason of the aforesaid injuries sustained by Paul Martz, he was forced to incur liability for hospitalization, medical treatment, medications, and similar miscellaneous expenses in an effort to restore himself to health, and claim is made therefor. 11. Because of the nature of his injuries, Paul Martz has been advised and, therefore, avers that he may be forced to incur similar expenses in the future, and claim is made therefor. 12. Paul Martz has undergone and in the future may undergo physical and mental suffering, inconvenience in carrying out his daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 13. Paul Martz continues to be plagued by persistent pain and limitation and, therefore, avers that his injuries may be of a permanent nature, causing residual problems for the remainder of his lifetime, and claim is made therefor. 436530 3 WHEREFORE, Plaintiff Paul Martz demands judgment against Defendant Penney Noss in an amount in excess of Fifty Thousand Dollars ($50,000.00), exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. Date: ANGINO & ROVNER, P.C. David L. Lutz PA I.D. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 - phone (717) 238-5610 - fax dlutz@angino-rovner.com Attorney for Plaintiff 436530 4 VERIFICATION I, Paul Martz, Plaintiff, hereby verify that the facts set forth in the foregoing COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. WITNESS: Date 1%t?iL i( 2©11) Paul Martz 436530 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor Paul Martz vs. Penney Noss ~o~titi~tr of t:~rtn~,~,~,~T~~ }4. y ~ ..~: ct~-~eF °-F ° r~ba.~,~~ !r T~-f ~ , °,~.~Y 20101-~Y 2~ ~~° ;~: 5~ C~r~V~, : "~ i~` ~- ~, ..! ~• ~~ `+~i'1'vr ~J~t Case Number 2010-3089 SHERIFF'S RETURN OF SERVICE 05/17/2010 04:44 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on May 17, 2010 at 1640 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Penney Noss, by making known unto herself personally, at 2176 South Enola Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.94 May 18, 2010 ~~ ~ RYAN BURGE TY SO ANSWERS, RON ~ R ANDERSON, SHERIFF (ci Count,Suite Sheriff, TPlecsoft, Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAUL MARTZ, NO. 10-3089 CIVIL TERM ~ ~ Plaintiff ..r F ~, r" C... v. CIVIL ACTION -LAW f~;'~ ~ PENNEY NOSS, ~t : ~ ` , ~~ Defendant JURY TRIAL DEMANDE~r--'` , ~~+ -- ~, ~ ~. .~ ~~ PRAECIPE FOR ENTRY OF APPEARANCE PURSUANT TO PA.R.C.P.1012 TO THE PROTHONOTARY: Kindly enter the appearance of Michael B. Scheib, Esquire, of Griffith, Strickler, Lerman, Solymos & Calkins, as attorney for the Defendant, Penney Noss, in the above-captioned matter and mark the docket accordingly. Date: June "~ , 2010 GRIFFITH, STRICKLER, LERMAN, SOLYMO5 & CALKINS By: l MIC EL B. HEIB, ESQU PA 63868 110 South Northern Way York, PA 17402-3737 Phone (717) 757-7602 Fax (717} 757-3783 Mscheibna,sslsc.com Attorney for Defendant, Penney Noss 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAUL MARTZ, NO. 10-3089 CIVIL TERM Plaintiff v. CIVIL ACTION -LAW PENNEY NOSS, . Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this __-~_~ day of June, 2010, I, Michael B. Scheib, Esquire, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the Praecipe for Entry of Appearance Pursuant to Pa. R.C.P. 1012, by United States Mail, postage prepaid, addressed to the party or attorney of record as follows: David L. Lutz, Esquire Angino & Rovner P.C. 4503 North Front Street Harrisburg, PA 17110-1708 (Attorney for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By: C AEL B. S HEIB, ESQUIRE PA b3868 110 South Northern Way York, PA 17402-3737 Phone (717) 757-7602 Fax (717) 757-3783 Mscheibna,sslsc.com Attorney for Defendant, Penney Noss IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAUL MARTZ, NO. 10-3089 CIVIL TERM Plaintiff v CIVIL ACTION -LAW PENNEY NOSS, Defendant JURY TRIAL DEMANDED TO: Paul Martz, Plaintiff c/o David L. Lutz, Esquire Angino & Rovner P.C. 4503 North Front Street Harrisburg, PA 17110-1708 NOTICE TO PLEAD 4 4 i You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS ,Q Date: June ~" , 2010 B Y MIC AEL . SCHEIB, ESQUIRE PA 63868 110 South Northern Way York, PA 17402-3737 Phone (717) 757-7602 Fax (717) 757-3783 Mscheibna,~slsc.com Attorney for Defendant, Penney Noss IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAUL MARTZ, NO. 10-3089 CIVIL TERM • Plaintiff _ v CIVIL ACTION -LAW PENNEY NOSS, . Defendant JURY TRIAL DEMANDED ANSWER WITH NEW MATTER COME NOW, Defendant, Penney Noss, by and through her attorney, Michael B. Scheib, Esquire, of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, and responds to the allegations in Plaintiff s Complaint as follows: 1. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 1 of Plaintiff s Complaint, and the same are denied and strict proof thereof demanded. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted in part, denied in part. It is admitted that Defendant pulled her vehicle from the private parking lot onto the southbound lane of Bridge Street. The remaining allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 6 of Plaintiff s Complaint, and the same are denied and strict proof thereof demanded. 7. Admitted in part and denied in part. It is admitted that Plaintiff fell off his bicycle and struck the ground. The remaining allegations aze denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 7 of Plaintiffs Complaint, and the same are denied and strict proof thereof demanded. 8. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations are denied and strict proof thereof demanded. 9. Denied. This pazagraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations aze denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 9 of Plaintiffs Complaint, and the same are denied and strict proof thereof demanded. 10. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations aze denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 10 of Plaintiff s Complaint, and the same are denied and strict proof thereof demanded. 11. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations aze denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 11 of Plaintiff s Complaint, and the same are denied and strict proof thereof demanded. 12. Denied. This pazagraph states a legal conclusion to which no response is required. 2 To the extent a response is required, the allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 12 of Plaintiff s Complaint, and the same are denied and strict proof thereof demanded. 13. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the allegations aze denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Pazagraph 13 of Plaintiff s Complaint, and the same aze denied and strict proof thereof demanded. WHEREFORE, Answering Defendant, Penney Noss, respectfully requests this Honorable Court to enter judgment in her favor with costs of this lawsuit. By way of further defense: NEW MATTER 14. Pazagraphs 1 through 13 of Defendant's Answer with New Matter aze incorporated herein as though fully set forth at length. 15. Plaintiffs injuries, if any, may be barred or limited by the Motor Vehicle Financial Responsibility Law. 16. Plaintiffs injuries, if any, may be barred or limited by a limited tort selection. 17. Plaintiffs injuries, if any, were caused by the acts or omissions of a third party over whom Defendant had no control. 18. Plaintiffs injuries, if any, were caused by events which either predated or postdated the motor vehicle accident which is the subject of this lawsuit. 3 19. Plaintiff s damages were caused by his own conduct. WHEREFORE, Defendant, Penney Noss, demands judgment in her favor and against the Plaintiff, Paul Martz, together with costs of suit. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CAL S Date: June ~g , 2010 By: / M C AEL B. CHEIB, ESQ RE PA 63868 110 South Northern Way York, PA 17402-3737 Phone (717) 757-7602 Fax (717) 757-3783 Mscheibngslsc.com Attorney for Defendant, Penney Noss 4 VERIFICATION I, Penney Noss, hereby verify that the statements made in the foregoing Answer and New Matter to Plaintiff s Complaint are true and correct to the best of my personal knowledge or information and belief, as well as reports, records, conferences and other investigatory material made available to me. To the extent that the foregoing contains averments which are inconsistent in fact, I verify that my knowledge or information is sufficient to form a belief that one or more of them is true, although I am currently unable, after reasonable investigation, to ascertain which of the inconsistent averments are true. To the extent that the foregoing contains legal conclusions or opinions, I hereby state that my Verification is made upon the advice of counsel, upon whom I have relied in the filing this document. This Verification is made subject to the penalties of 18 Pa. C.S. § 4904 related to unsworn falsifications to authorities. Date: 2010 By: %~ ~~ PENNEY S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAUL MARTZ, Plaintiff v. PENNEY NOSS, Defendant NO. 10-3089 CIVIL TERM CIVIL ACTION -LAW JURY TRIAL DEMANDED J CERTIFICATE OF SERVICE AND NOW, this / day of June, 2010, I, Michael B. Scheib, Esquire, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of Defendant, Penney Noss' Answer With New Matter to Plaintiff's Complaint, by United States Mail, postage prepaid, addressed to the party or attorney of record as follows: David L. Lutz, Esquire Angino & Rovner P.C. 4503 North Front Street Harrisburg, PA 17110-1708 (Attorney for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CAL S By: MI L B. S EIB, ESQU PA 63868 110 South Northern Way York, PA 17402-3737 Phone (717) 757-7602 Fax (717) 757-3783 Mscheibna,eslsc.com Attorney for Defendant, Penney Noss FlC..ED-l:P~~C~ 2a1o ~~;m 24 PF1 2= 42 cJ~~~::-:.~~ t~ ~~o~~mr r1 ~~;~~.~~ r,~,~ ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attorney ID# : 35956 4503 North Front Street Harrisburg, PA 17110-1708 (717)238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: dlutz@angino-rovner.com PAUL MARTZ, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA v. I NO. 10-3089 CIVIL TERM PENNEY NOSS, CIVIL ACTION -LAW Defendant JURY TRIAL DEMANDED PLAINTIFF' S REPLY TO DEFENDANT' S NEW MATTER 15. through 19. The Defendant's New Matter, paragraphs 15 through 19, fails to set forth factual allegations that require the Plaintiff to admit and/or deny said allegations. The factual allegations contained in the Plaintiff's Complaint are incorporated herein by reference. 443022 WHEREFORE, the Plaintiff respectfully requests that the Defendant's New Matter be dismissed. Date: ~ ' ~}"'1 •- ~~ ANGINO & ROVNER, P.C. David L. Lutz PA I.D. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 -phone dlutz@angino-rovner. com Attorney for Plaintiff 443022 CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of the PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER upon all counsel of record via postage prepaid first class United States mail addressed as follows: "..li:ae: E. =eheb, Hqu,•e Griffith Strickler, et al. 110 S Northern Way York, PA 17402-3737 Attorney for Defendant ary Gerae s Dated: ~ ^ ~ a ~ ~`~ 443022 IL -'j, rlur L 1 FE- 24 Ft1 y .'° ; ? ."OERL ND is i ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attorney ID# : 35956 4503 North Front Street Harrisburg, PA 17110-1708 PHONE: (717) 238-6791 FAX: (717) 238-5610 Attorney for Plaintiff: E-mail: dlutzAangino-rovner.com Paul Martz PAUL MARTZ, V. PENNEY NOSS, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 10-3089 CIVIL TERM JURY TRIAL DEMANDED PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: David L. Lutz, Esquire, counsel for the Plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiff in the action is $50,000. The counterclaim of the Defendant in the action is $0. The following attorneys are interested in the case(s) as counsel or otherwise disqualified to sit as arbitrators: Erick Violago, Esquire, and Michael B. Scheib, Esquire. fh #;q d& d#9 /j//Z 462770 WHEREFORE, your Petitioners pray Your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. ??1 \ Date: ANG O & ROVNER, P.C. Davi utz PA I.D. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717) 23 8-6791 -phone (717) 238-5610 - fax dlutz@angino-rovner.com Attorney for Plaintiff 462770 CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of the PETITION FOR APPOINTMENT OF ARBITRATORS upon all counsel of record via postage prepaid first class United States mail addressed as follows: Erick Violago, Esquire Michael B. Scheib, Esquire Griffith Strickler, et al. 110 S Northern Way York, PA 17402-3737 Attorney for Defendant Dated: a, ) ? A 462770 PAUL MARTZ, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. PENNEY NOSS, Defendant CIVIL ACTION - LAW NO. 10-3089 CIVIL TERM JURY TRIAL DEMANDED ORDER OF COURT AND NOW, this; day of , 2011, in consideration of the foregoing Esq. petition,/ zet , Esq. Alp AA A V and Esq. are appointed arbitrators in the above- captioned action as prayed for. ba V.d l-"2, &-5f fir, r le 01"o /0J40, t'Copies `na. fed .3////l t2p L u .,3 CO :71P T7. 7, 462770 BY THE COURT: Plaintiff _? ?v ? /CJa S?_ Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No.-/o- d 6' Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office gnature - %? Name °? ??, Signature C? Name Law Firm Law Firm Law Firm Address Address Address t trwrok no y3 (70l 3 City, Zip City, Zip ? , City, Zip . Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: MiE Date of Award Notice of Entry of Award Now, the ?& glday of , 20 // , at //'31+ + A M.> the above award was entered upon the docket and notice ereo given by mail to the parties or their attorneys. Arbitrators' comp sation to be pain appeal ?--- _.1'.SO By: Deputy Name ?'n) 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.) ,LJMBE L r%Li wJUI1 PENNSYLVANIA s ??? tom; ? ? ,?? acl j,G, ?-? r?/l Ls i,..t0 .J - IJ B i • i,0 c>> i. I i;{y' x y 1;t 1 C$ t 1 El U1iI OCT -S AID II: 4 U MBE_RLANO l.t0U T Y PENNSYLVANIA ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attorney ID# : 35956 4503 North Front Street Harrisbure. PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: dlutz(aDangino-rovner.com PAUL MARTZ, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. I NO. 10-3089 CIVIL TERM PENNEY NOSS, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED PRAECIPE To the Prothonotary of Cumberland County: Please mark the above-captioned action settled, satisfied, and discontinued. ANGINO & ROVNER, P.C. avid L. Lutz PA I.D. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 - phone (717) 238-5610 - fax dlutz@ang ino-rovner. com Date: Attorney for Plaintiff 439804 ORIGINAL CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of the PRAECIPE upon all counsel of record via postage prepaid first class United States mail addressed as follows: Michael B. Scheib, Esquire Griffith Strickler, et al. 110 S Northern Way York, PA 17402-3737 Attorney for Defendant C110 , M T. raets Dated: l b,; P` 439804