Loading...
HomeMy WebLinkAbout10-3444Law Offices of Jeffrey S. Nowak r ' 95 Almshouse Road, Ste. 305 ry? 0? 24 Richboro, Pa. 18954 L (215) 364-3700 Fax: (215) 364-3701 (',{ p 1 '\+rl. IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA - LAW DIVISION MARIA and CELE-TINO v``-.... JACOBO (h/w) No. ?0 - 344 Co- IR 511 South 14`n Street Harrisburg, Pa. 17104, Plaintiffs, Civil Action V. CLEM A. CICCARELLI 12 Pine Street New Cumberland, Pa. 17070, Defendant. 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 an attorney or 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. CUMBERLAND COUNTY BAR ASSOCIATION (Lawyer Referral Service) 32 South Bedford Street Carlisle, Pa. 17013 (717) 249-3166 (800) 990-9108 ? 9a.oo P? urn/ ?? %'710 ?. ay ash IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA - LAW DIVISION MARIA and CELE-TINO JACOBO (h/w) No. 511 South 14th Street Harrisburg, Pa. 17104, Plaintiffs, Civil Action V. CLEM A. CICCARELLI 12 Pine Street New Cumberland, Pa. 17070, Defendant. PLAINTIFFS' COMPLAINT AND VERIFICATION AND NOW COMES the Plaintiffs, MARIA and CELE-TINO JACOBO, by and through their attorney, Jeffrey S. Nowak, Esq., and sets forth the following as to the above-captioned Defendant: 1. Plaintiff, MARIA JACOBO, is an adult individual who at all relevant times herein resided at 511 South 14th Street, City of Harrisburg, County of Dauphin and Commonwealth of Pennsylvania. 2. Plaintiff, CELE-TINO JACOBO, is an adult individual who at all relevant times herein resided at 511 South 14th Street, City of Harrisburg, County of Dauphin and Commonwealth of Pennsylvania. 1 Defendant, CLEM A. CICCARELLI upon information and belief, is an adult individual, who at all times relevant herein, resided at 12 Pine Tree Drive, New Cumberland, County of Cumberland, and Commonwealth of Pennsylvania. 4. On or about December 11, 2008, Plaintiff, MARIA JACOBO was lawfully operating her motor vehicle on State Highway 581 in an easterly direction and about one mile from the Camp Hill Exit in the County of Cumberland when a motor vehicle being operated by the Defendant, CLEM A. CICCARELLI, was caused to violently collide into the rear-end of the Plaintiff's motor vehicle. 5. Plaintiff avers that as a direct and proximate result of the conduct of the Defendant she has sustained various severe, multiple and permanent damages in the nature of orthopedic injuries to the neck, mid and low back. 6. Plaintiff avers further that as a direct and proximate result of the conduct of the defendant she has sustained severe upper and lower extremity nerve damage; loss of sleep; loss of appetite; loss of the enjoyment of life; migraine headaches; severe pain and anxiety. 2 7. Plaintiff avers further that as a direct and proximate result of the conduct of the defendant she has incurred and will incur into the future medical bills for treatment of her multiple injuries; prescription medication costs; loss of earning potential; lost present and future wages. COUNTI Maria Jacobo v. Clem A. Ciccarelli (Negligence) 8. Plaintiff incorporates by reference all of her allegations set forth in paragraph nos. one (1) through seven (7) as if set forth fully herein. 9. Plaintiff avers that the Defendant owed her the following duties: (a) The duty to operate his motor vehicle in a safe manner; (b) The duty to obey the traffic laws; (c) The duty not to speed or operate her motor vehicle at a high rate of speed; (d) The duty to obey all traffic signals and roadway signs; (e) The duty to anticipate oncoming traffic; (f) The duty to maintain a vigilant look out for oncoming vehicles; (g) The duty to properly control his vehicle in traffic; (h) The duty to operate his vehicle in a properly designated lane(s); (i) The duty to appreciate on-coming traffic; 0) The duty to properly repair and/or maintain his vehicle to facilitate safe operation on the roadways and highways; and, 3 (k) The duty to yield the right of way to on-coming traffic. 10. Plaintiff avers that the Defendant breach some or all of the foregoing duties and as a proximate result thereof the Plaintiff sustained severe, multiple and permanent injuries and economic losses as set forth herein. WHEREFORE, Plaintiff demands judgment in her favor for pain and suffering; economic losses; reasonable counsel fees; interest and costs and in excess of $50,000.00, and any other and further relief that this Honorable Court deems appropriate. COUNT II Maria Jacobo v. Clem A. Ciccarelli (Res Ispa Loquitor) 11. Plaintiff incorporates by reference all of her allegations set forth in paragraph nos. one (1) through ten (10) as if set forth fully herein. 12. Plaintiff avers that the conduct of the Defendant set forth herein could not have occurred in the absence of negligence. 13. Plaintiff avers further that as a direct and proximate result of the Defendant's action and/or inaction she was caused to sustain permanent personal injury damages and economic damages and will continue to do so into the future. 4 WHEREFORE, Plaintiff demands judgment in her favor for pain and suffering; economic losses; reasonable counsel fees; interest and costs and in excess of $50,000.00, and any other and further relief that this Honorable Court deems appropriate. COUNT III Cele-Tino Jacobo v. Clem A. Ciccarelli (Loss of Consortium) 14. Plaintiffs incorporate by reference all of the allegations set forth in paragraph nos. one (1) through thirteen (13) as if set forth fully herein. 15. Plaintiff, CELE-TINO JACOBO, avers that on the date of the accident, December 11, 2008, he was legally married by ceremony to the Plaintiff, MARIA JACOBO, and together they were husband and wife. 16. Plaintiff, CELE-TINO JACOBO, avers further that as a direct and proximate result of the actions, conduct, and/or inaction of the Defendant that he was caused to suffer the loss of love, affection, society and support of his wife, MARIA JACOBO, and will continue to sustain such loss into the future. WHEREFORE, Plaintiff, CELE-TINO JACOBO, demands judgment in his favor for loss of consortium damages; reasonable counsel fees; interest and, costs and in excess of $50,000.00, and any other and further relief that this Honorable Court deems appropriate. Law Office"f Jeffrev,S. By: `-- fre owak, Esq. P . No. 55124 5 Almshouse Road, Ste. 305 Richboro, Pa. 18954 (215) 364-3700 Fax: (215) 364-3701 Email: jefnwkg ,comcast.net Attorneys for Plaintiffs, Maria and Cele-Tino Jacobo Dated: May 6, 2010 DEMAND FOR TRIAL BY JURY The Plaintiffs hereby demand trial by jury on all issues so triable. Law By: e ey owak, Esq. P . No. 55124 Al s use Road, Ste. 305 Richboro, Pa. 18954 (215) 364-3700 Fax: (215) 364-3701 Email: jefnwk a,comcast.net Attorneys for Plaintiffs, Maria and Cele-Tino Jacobo Dated: May 6, 2010 6 VERIFICATION THE UNDERSIGNED does hereby verify that the statements set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. The undersigned further understands that this statement is made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Dated: 7 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson c FiLEC?- f " ` I~'~ t- ~/ Sheriff t ~_I ~o~~>,~r qt ~u~6rpr~~r ChtlefDepruty ~, :~. ,,~; ~ ZQIQ ~U~~ -$ Pri 2~ ~`I Richard W Stewart ~~~~~'°~ CUPt~, ~:, ~ :~~~~,~~ Solicitor ~F~~CEC=_.:FS..e~iFF p~; ~~vS`i`L'J~"'~1,~. Maria Jacobo Case Number vs. 2010-3444 Clem A. Ciccarelli SHERIFF'S RETURN OF SERVICE 06/07/2010 02:00 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on June 7, 2010 at 1355 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Clem A. Ciccarelli, by making known unto Kristina Allshouse, Medical Secretary for Green Hill Professional Center at 503 Bridge Street, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and c rrect c y of same. MARK CONKLIN, DEPUTY SHERIFF COST: $43.74 June 08, 2010 SO ANSWERS, ~~s%~""- ---~-...~ RON R ANDERSON, SHERIFF ~ci CountySuile Sheriff. T'eleosoft. Inc. R~ L7 r .'F~,'~~5'..~°.. ~ r i ;f: 2010 JU~~ -9 P~1 2~ u ! ~r-p" ~. _r i~ M ~.. t~ , .;~.:.~.; 1vTY Counsel for Defendant IN THE COURT OF COMMAh1 PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-3444Civil Term CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the undersigned on behalf of Defendant, Clem A. Ciccarelli, in the above-captioned matter. Respectfully submitted, JOHNSON UFFIE, STEWART &WEIDNER By: Jo R. Ninosky, Esquire Attorney I.D. No. 78000 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant JOHNSON, DUFFIE, STEWART S~ WEIDNER By: John R. Ninosky, Esquire I.D. No. 78000 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Phone: (717) 761-4540 E-mail: jrn@jdsw.com MARIA AND GELE-TINO JACOBO (h/w), Plaintiffs v. CLEM A. CICCARELLI, Defendant Date: June 8, 2010 i CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Entry of Appearance has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on June 8, 2010: Jeffrey S. hlo~rack, Esquire 95 Almshouse Road, Suite 305 Richboro, PA 18954 JOHNSON, DUFFIE, STEWART & WEIDNER By hn R. Ninosky • 4 T JOHNSON, DUFFIE, STEWART 8i WEIDNER By: John R. Ninosky, Esquire I.D. No. 78000 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Phone: (717) 761-4540 E-mail: jrnt~jdsw.com T 1 Ir T' ~~Er~`;~;Y~'U,i'•l~s Counsel for Defendant MARIA AND CELE-TINO IN THE COURT OF COMMON PLEAS OF JACOBO (h/w), CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 10-3444Civil Term v. CIVIL ACTION -LAW CLEM A. CICCARELLI, Defendant JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Maria and Cele-Tino Jacobo c/o Jeffrey S. Nowack, Esquire YOU ARE REQUIRED to plead to the within Answer with New Matter within 20 days of service hereof or a default judgment may be entered against you. JOHNSON, DUFFIE, STEWART &WEIDNER By: J hn R. Ninosky, Esquire ttorney I.D. No. 78000 Date: July 2, 2010 Attorney for Defendant JOHNSON, DUFFIE, STEWART & WEIDNER By: John R. Ninosky, Esquire I.D. No. 78000 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Phone: (717) 761-4540 E-mail: jrn~jdsw.com MARIA AND CELE-TINO JACOBO (h/w), Plaintiffs v. CLEM A. CICCARELLI, Defendant NO. 10-3444Civil Term CIVIL ACTION -LAW JURY TRIAL DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER TO PLAINTIFFS' COMPLAINT AND NOW, comes Dr. Clem A. Ciccarelli, by and through his counsel, Johnson, Duffle, Stewart & Weidner, P.C., and files this Answer with New Matter by respectfully stating the following: 1. Denied. After reasonable investigation, Dr. Ciccarelli is without sufficient knowledge or information to form a belief as to the truth of this averment. The same are therefore denied, and strict proof demanded at the time of trial. 2. Denied. After reasonable investigation, Dr. Ciccarelli is without sufficient knowledge or information to form a belief as to the truth of this averment. The same are therefore denied, and strict proof demanded at the time of trial. Counsel for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 3. Admitted. 4. Denied. The averments contained in this paragraph contain conclusions of law and fact to which no response is required. If a response is deemed required, the averments contained herein are denied. 5. Denied. The averments contained in this paragraph are denied pursuant to Pa.R.C.P. 1029(e). 6. Denied. The averments contained in this paragraph are denied pursuant to Pa.R.C.P. 1029(e). 7. Denied. The averments contained in this paragraph are denied pursuant to Pa. R.C. P. 1029(e). COUNT I -Negligence Maria Jacobo v. Dr. Clem A. Ciccarelli 8. Dr. Ciccarelli incorporates herein by reference his answers to paragraphs 1 through 7 above as if fully set forth at length. 9. Denied. The averments contained in this paragraph including subparagraphs (a) through (k) contain conclusions of law and fact to which no response is required. If a response is deemed required, the averments contained herein are denied. 10. Denied. The averments contained in this paragraph are denied pursuant to Pa. R.C. P. 1029(e). WHEREFORE, Defendant Dr. Clem A. Ciccarelli respectfully requests that Plaintiffs' Complaint be dismissed with prejudice and that judgment be entered in his favor. COUNT II -Res Ispa Loquitor Maria Jacobo v. Dr. Clem A. Ciccarelli 11. Dr. Ciccarelli incorporates herein by reference his answers to paragraphs 1 through 10 above as if fully set forth at length. 12. Denied. The averments contained in this paragraph are denied pursuant to Pa. R. C. P. 1029(e). 13. Denied. The averments contained in this paragraph are denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, Defendant Dr. Clem A. Ciccarelli respectfully requests that Plaintiffs' Complaint be dismissed with prejudice and that judgment be entered in his favor. COUNT III -Loss of Consortium Cele-Tino Jacobo v. Dr. Clem A. Ciccarelli 14. Dr. Ciccarelli incorporates herein by reference his answers to paragraphs 1 through 13 above as if fully set forth at length. 15. Denied. After reasonable investigation, Dr. Ciccarelli is without sufficient knowledge or information to form a belief as to the truth of this averment. The same are therefore denied, and strict proof demanded at the time of trial. 16. Denied. The averments contained in this paragraph are denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, Defendant Dr. Clem A. Ciccarelli respectfully requests that Plaintiffs' Complaint be dismissed with prejudice and that judgment be entered in his favor. NEW MATTER 17. Plaintiffs' Complaint fails to state a claim upon which relief may be granted. 18. Plaintiffs' claims and/or alleged losses may be limited in whole or in part by the Limited Tort Option pursuant to 75 Pa.C.S.A. § 1705, et seq. 19. Plaintiffs' claims and/or alleged losses were not caused by any negligence on the part of Mr. Ciccarelli. 20. The alleged negligence of Dr. Clem A. Ciccarelli, which negligence is expressly denied, was not the proximate cause of any injury suffered by the Plaintiffs. 21. Plaintiffs may have failed to mitigate their damages, if any, with any liability or responsibility on the part of Dr. Ciccarelli being expressly denied. 22. The alleged accident was not the factual cause of Plaintiffs' alleged injuries and losses. 23. Plaintiffs' claims and/or alleged losses may be barred or diminished by their own comparative negligence. WHEREFORE, Defendant Dr. Clem A. Ciccarelli respectfully requests that Plaintiffs' Complaint be dismissed with prejudice and that judgment be entered in his favor. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By: John R. Ninosky, Esquire Attorney I.D. No. 78000 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant Date: July 2, 2010 403596 VERIFICATION PURSUANT TO PA. R.C.P. NO. 1024(c) John R. Ninosky, Esquire, states that he is the attorney for the parties filing the foregoing Defendant's Answer with New Matter to Plaintiffs' Complaint and that he makes this affidavit as an attorney, because the party he represents lacks sufficient knowledge or information upon which to make a verification and/or because he has greater personal knowledge of the information and belief than that of the party for whom he makes this affidavit; and that he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. John .Ninosky, Esquire Attorney for Defendant Date: July 2, 2010 345785 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Answer with New Matter has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on July 2, 2010: Jeffrey S. Nowack, Esquire 95 Almshouse Road, Suite 305 Richboro, PA 18954 JOHNSON, DUFFIE, STEWART & WEIDNER By J n R. Ninosky I r ~ IN THE MARIA and CELE-TII~ JACOBO (h/w} 511 South 14th Street Harrisburg, Pa. 17104, Plaintiffs, V. CLEM A. CICCARELI 12 Pine Street New Cumberland, Pa. 1 Defendant. THE BELOW ; June, 2010, via Sheriff to the address below ate [ON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA -LAW DIVISION f0 No. 10-3444 Civil Action Atty ID# 55124 G~ N ~ -. ~~ ~-'" ~ --i ~~ ~'. ~'N _r -~ ! .. _... f - ~ ,l It ,, ~> > --~ _ :~ ~~: , ~ - ~a; ~~ rs, CERTIFICATE OF SERVICE med hereby certifies that he did cause to be delivered on this 7th day of ervice, one copy of Plaintiff's, Complaint, in the above captioned matter ched as exhibit "A" Clem A. Ciccarelli 503 Bridge Street New Cumberland, PA 17070 LAW OFFICES O~.~F,FFREY S. NOWAK By: Je •e S. Now quire Attorneys r Plaintiff, Maria Jacobo Dated: 30% PCW T f Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ~~~ of ~eurbr~,~fi~ CJ~AICf: CIF T#7£ &MERlFF Maria Jacobo vs. Clem A. Ciccarelli Case Number 2010-3444 SHERIFF'S RETURN OF SERVICE 06/07/2010 02:00 PM -Mark Co 2010 at 1355 hours, defendant, to wit: CIS Green Hill Professio 17070 its contents a same. in, Deputy Sheriff, who being duly sworn according to law, states that on June 7, served a true copy of the within Complaint and Notice, upon the within named A. Ciccarelli, by making known unto Kristina Allshouse, Medical Secretary for Center at 503 Bridge Street, New Cumberland, Cumberland County, Pennsylvania at the same time handing to her personally the said true and c9rrect c9py of ~ MARK CONKLIN, DEPUTY SHERIFF COST: $43.74 June 08, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF f, c Gou^?,Suits Sherdt. T2ieosal, I:,c. C Law Office of Jeffrey S. Nowak By: Jeffrey S. Nowak, Esq. Pa. ID No. 55124 95 Almshouse Rd., Ste. 305 Richboro, Pa. 18954 (215) 364-3700 Fax: (215) 364-3701 Email: Jefnwk ,comcast.net Attorneys for Plaintiff, Maria and Cele-tino Jacobo IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA -LAW DIVISION MARIA and CELE-TINO JACOBO (h/w) 511 South 14`~ Street Harrisburg, Pa. 17104, Plaintiffs, V. CLEM A. CICCARELLI 12 Pine Street New Cumberland, Pa. 17070, Defendant. No. 10-3444 t~ ~ ~' © i C1vi1 Action ~ ~ ~ -r ~ T, -v .. _ _ ~ ~~ ~ ~-, PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER Plaintiff s, by and through their Counsel, Jeffrey S. Nowak, Esq., hereby reply as follows to the Defendant's new matter: 17.) Denied. It is denied that Plaintiff's Complaint fails to state a claim upon which relief maybe granted. 18.) Denied. It is denied that Plaintiff s claims and or alleged losses maybe limited in whole or in part by the limited tort option of Pennsylvania. 19.) Denied. It is denied that Plaintiff's claims and or alleged losses were caused by their own negligence and were otherwise completely caused by the negligence of the Defendant. 20.) Denied. It is denied that the negligence of the Defendant was not the proximate cause of the injuries sustained by the Plaintiffs. 21.) Denied. It is denied that Plaintiffs have failed to mitigate their damages. 22.) Denied. It is denied that the accident was not the factual cause of Plaintiff s alleged injuries and losses. 23.) Denied. It is denied that Plaintiff's claims and or alleged losses may be barred or diminished by their own comparative negligence. WHEREFORE, Plaintiffs, respectfully request that the Defendant's new matter be dismissed with prejudice and that judgment be entered in their favor on the Complaint. Law Officgts o~Jeffrey S. Nowak By: Jeffrey o ak, Esq. Pa. ID 124 95 Al house Road, Ste. 305 Richb o, Pa. 18954 (215) 64-3700 Fax: 215) 364-3701 Email: 'et fnwk(a,comcast.net Attorneys for Plaintiffs, Maria and Cele-tino Jacobo Date: July 22, 2010 VERIFICATION PURSUANT TO PA. R.C.P. NO. 1024(c) Jeffrey S. Nowak, Esquire, states that he is the attorney for the parties filing the foregoing Plaintiff's Reply to Defendant's New Matter and that he makes this affidavit as an attorney, because the party he represents lacks sufficient knowledge or information upon which to make a verification and/or because he has greater personal knowledge of the information and belief than that of the party for whom he makes this affidavit; and that he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document and that this statement is made subject to the penalties of 18 Pa. C.S §4904, relating to unsw~rn falsification to authorities. By: Jeffrey S.~ak, Esquire Attorneys or Plaints, Maria and Dated: July 22, 2010 ~~ ,' Law Office of Jeffrey S. Nowak By: Jeffrey S. Nowak, Esq. Pa. ID No. 55124 95 Almshouse Rd., Ste. 305 Richboro, Pa. 18954 (215) 364-3700 Fax: (215) 364-3701 Email: Jefnwk(a),comcast.net Attorneys for Plaintiffs, Maria and Cele-tino Jacobo MARIA and CELE-TINO JACOBO (h/w) 511 South 14~' Street Harrisburg, Pa. 17104, Plaintiffs, V. CLEM A. CICCARELLI 12 Pine Street : New Cumberland, Pa. 17070, Civil Action Defendant. ; CERTIFICATE OF SERVICE The below signed hereby certifies that he did cause to be delivered on this 14`~ day of July, 2010, via First Class U.S. Mail, one true and correct copy of Plaintiff s Reply to Defendant's New Matter to the following: John R. Ninosky, Esquire 301 Market Street P.O. Box 109 Lemoyne, PA 1,7043-0109 Law Offices of IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA - LAW DIVISION No. 10-3444 By: Jeffrey S Attorneys for Plaintff~ S. Nowak ik, Esq. and Cele-tino Jacobo Dated: July 22, 2010