HomeMy WebLinkAbout10-7425
MARY M. LYNN
267 Redwood Lane
Carlisle, PA 17015
versus
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. ~ U .. (`t ~ J
Civil Action - (x) Law
( )Equity
James D. Schaffer, Jr, and ~
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Nancy Schaffer, husband and ~ r
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5812 Marsh Road ~~ ,
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Waynesboro, PA 17268 ~~ N ~~?
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Tara L. Mattern ~a ~
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800 Wertzville Road ;~ c
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Enola, PA 17025 -
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Nicholaus E. Kettoman
c/o State Correctional Institution
Coal Township
1 Kelley Drive
Coal Township, PA 17866
Plaintiff(s) &
Address(es)
PRAECIPE FOR WRIT OF SUMMONS
TO THE PROTHONOTARY OF SAID COURT:
Please issue writ of summons in the above-captioned action.
Defendants} &
Address(es)
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X Writ of Summons shall be issued and forwarded to () Attorney ~ Sheriff
along with attached Interrogatories. See attached Instructions for Service.
Bradford Dorrance
210 Walnut Street ignature of Attorney
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8014 Supreme Court ID No. 32147
Names/Address/Telephone No.
of Attorney Date: / ~'3a ~ l b
WRIT OF SUMMONS
TO THE ABOVE NAMED DEFENDANT(S):
YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED
AN ACTION AGAINST YOU.
Pr onotary
Date: I a.- `al. /U By
Deputy
( ) Check here if reverse is issued for additional information
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No.
Civil Action - (x) Law
( )Equity
MARY M. LYNN James D. Schaffer, Jr. and
267 Redwood Lane Nancy Schaffer, husband and wife
Carlisle, PA 17015 5812 Marsh Road
Waynesboro, PA 17268
versus
Tara L. Mattern
800 Wertzville Road
Enola, PA 17025
Nicholaus E. Kettoman
c/o State Correctional Institution
Coal Township
1 Kelley Drive
Coal Township, PA 17866
Plaintiff(s) & Defendant(s) &
Address(es) Address(es)
INSTRUCTIONS FOR SERVICE
Plaintiff requests that the Cumberland County Sheriff deputize the Franklin County
Sheriff for the purpose of serving the attached writ of summons and interrogatories on
defendants, James D. Schaffer, Jr. and Nancy Schaffer, husband and wife, residing at 5812
Marsh Road, Waynesboro, PA 17268.
Plaintiff further directs the Cumberland County Sheriff to serve Tara L. Mattern at her
residence located at 800 Wertzville Road, Enola, PA 17025.
Plaintiff further directs that the Cumberland County Sheriff deputize the Northumberland
County Sheriff for the purpose of serving defendant, Nicholaus E. Kettoman, at the State
Correctional Institution -Coal Township at 1 Kelley Drive, Coal Township, PA 17866.
If possible, plaintiff requests that all service be attempted on or before December 8,
2010.
Date: ~ ~ ~ 3 ~ ~ ~ b
adford Dorrance
I.D. No. 32147
KEEPER WOOD ALLEN & RAHAL, LLP
210 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8014
(Attorneys for Plaintiff)
MARY M. LYNN,
~T .
Plaintiff
JAMES D. SCHAFFER, JR. and
NANCY SCHAFFER, .
husband and wife; .
TARA L. MATTERN; and
NICHOLAUS E. KETTOMAN,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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PLAINTIFF'S FIRST SET OF INTERROGATORIES
DIRECTED TO DEFENDANTS
T0: Defendants, James D. Schaffer, Jr. and Nancy Schaffer; Tara
L. Mattern; and Nicholaus E. Kettoman
PRELIMINARY STATEMENT OF CAUSES OF ACTION
Pursuant to Pa. R.C.P. Nos. 4003.8, 4005(a), and
related provisions, these interrogatories seek material and
necessary information which will be used in preparing a complaint
against the named defendants (and any other subsequently
identified, responsible individuals or entities). Upon
completion of pre-complaint discovery, plaintiff may allege
various causes of action including intentional torts, negligence,
and negligent entrustment claims against the named defendants and
other currently unknown parties.
PLEASE TAKE NOTICE that you are hereby required,
pursuant to Pa. R.C.P. Nos. 4005, 4006, and related provisions,
to serve upon the undersigned your answers and objections, if
any, in writing and under oath to the following interrogatories
within 30 days after service upon you or your counsel.
INTERROGATORIES
1. In December 2008, were you the owner or permitted
driver of the blue/gray Ford F-150 Truck, regular cab, long bed,
with a gray stripe down the side (the "Truck"), as depicted in
the attached Exhibit "A"?
ANSWER:
2. Identify any individual (the "Owner") who gave
Nicholaus E. Kettoman and/or Tara L. Mattern permission to drive
the Truck in December 2008?
ANSWER:
2
3. If the answer to preceding interrogatory identifies an
Owner, please provide the following: the make, model, and VIN of
the Truck; the name of the permitted driver(s); the period of
permitted use of the Truck; and any restrictions on its use.
ANSWER:
4. In December 2008, were you aware of any criminal record
of Nicholaus E. Kettoman and/or Tara L. Mattern or were you aware
of either individual's driving record or history of motor vehicle
code violations including any suspended driver's license?
ANSWER:
3
5. If your answer to the preceding interrogatory is in the
affirmative, please state the nature and extent of your knowledge
concerning Ms. Mattern's and Mr. Kettoman's criminal records (if
any), driving records, and history of motor vehicle violations.
ANSWER:
6. Were you aware of any accident involving the Truck in
December of 2008?
ANSWER:
7. If your answer to the preceding interrogatory is in the
affirmative, please state the nature and extent of your knowledge
of any such accident including the individuals and vehicles
involved in such accidents, the date of such accident; when and
4
how you became aware of the accident; and any damage to the Truck
and any other vehicle(s).
ANSWER:
Date : ~ ~, ~ ~~ lLC~
Bradford Dorrance
I.D. No. 32147
KEEFER WOOD ALLEN & RAHAL, LLP
210 Walnut Street
P.O. Box 11963
Harrisburg, PA 17108-1963
(717) 255-8014
(Attorneys for Plaintiff)
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Exhibit "A"
LAW OFFICES OF HUSSSH14AN CAREY & FLOOD
By: JAMES M. FLOOD
Attorney I.D.#70257
2200 Stafford Avenue, Suite 500
Scranton, PA 18505
Phone #570-961-7580
Attorney for Defendants, James & Nancy Schaffer
51898
MARY M. LYNN
Plaintiff
VS.
JAMES D. SCHAFFER, JR. and NANCY
SCHAFFER, husband and wife; TARA L.
MATTERN; and, NICHOLAUS E. KETTOMAN
Defendants
FILED-OFFICE
OF THE PROTHONOTARY
2011 .'15
ClJ ? 1 .`? 'QTY
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NO. 10-7425
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of Defendants, James D. Schaffer, Jr.
and Nancy Schaffer, in the above-captioned matter.
HUBSHMAN, CAREY & FLOOD
By: 1..?
Ja es M. Flood, Esquire
Attorney for Defendants,
James & Nancy Schaffer
LAW OFFICES OF HUSSHMAN CAREY & FLOOD
By: JAMES M. FLOOD
Attorney I.D.#70257
2200 Stafford Avenue, Suite 500
Scranton, PA 18505
Phone #570-961-7580
Attorney for Defendants, James & Nancy Schaffer
S1898
MARY M. LYNN
Plaintiff .
vs.
JAMES D. SCHAFFER, JR. and NANCY
SCHAFFER, husband and wife; TARA L.
MATTERN; and, NICHOLAUS E. KETTOMAN
Defendants
FILED-OFFICE
OF THE PROTHONOTARY'
2011 - 15
CU TY
_,A
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NO. 10-7425
TO THE PROTHONOTARY:
Defendants, James D. Schaffer, Jr. and Nancy Schaffer, hereby demand trial by
twelve (12) jurors.
HUBSHMAN, CAREY & FLOOD
By:
James M. Flood, Esquire
Attorney for Defendants,
James & Nancy Schaffer
LAW OFFICES OF HUBSHMM. CAREY & FLOOD
By: JAMES M. FLOOD
Attorney I.D.#70257
2200 Stafford Avenue, Suite 500
Scranton, PA 18505
Phone #570-961-7580
Attorney for Defendants, James & Nancy Schaffer
MARY M. LYNN
Plaintiff
VS.
JAMES D. SCHAFFER, JR. and NANCY
SCHAFFER, husband and wife; TARA L.
MATTERN; and, NICHOLAUS E. KETTOMAN
Defendants
,FILED-OFFICE
OF THE FROTI?ONOTARY
iy
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NO. 10-7425
I, JAMES M. FLOOD, ESQUIRE, do hereby certify that Defendants, James and
Nancy Schaffer's, Interrogatories Addressed to Plaintiff and First Request for Production
of Documents Addressed to Plaintiff were served upon all parties this date via United
States first class mail at the following addresses:
Attorney for P/aintiff Co-Defendant Co-Defendant
Bradford Dorrance, Esquire Tara L. Mattern Nicholaus E. Kettoman - #FH8385
210 Walnut Street 800 Wertzville Road c/o State Correctional Institution
PO Box 11963 Enola, PA 1702 1 Kelley Drive
Harrisburg, PA 17108-1963 Coal Township, PA 17866
HUBSHMAN, CAREY & FLOOD
Date: ' /,///f
7
By:
JAME M. FLOOD, ESQUIRE
Attorney for Defendants,
James & Nancy Schaffer
LAW OFFICES OF HUSSHMM. CAREY A FLOOD
By: JAMES M. FLOOD
Attorney I.D. #70257
2200 Stafford Avenue, Suite 500
Scranton, PA 18505
Phone #570-961-7580
Attorney for Defendants, James & Nancy Schaffer
MARY M. LYNN
Plaintiff
VS.
JAMES D. SCHAFFER, JR. and NANCY
SCHAFFER, husband and wife; TARA L.
MATTERN; and, NICHOLAUS E. KETTOMAN
Defendants
FILED-OFFICE
OF THE PROTHONOTARY
2011
°TY
C0?
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NO. 10-7425
I, JAMES M. FLOOD, ESQUIRE, do hereby certify that Defendants, James and
Nancy Schaffer's, Answers to Plaintiff's Interrogatories were served upon all parties this
date via United States first class mail at the following addresses:
Attorney for Plaintiff Co Defendant Co-D?efendant
Bradford Dorrance, Esquire Tara L. Mattern Nicholaus E. Kettoman - #FH8385
210 Walnut Street 800 Wertzville Road c/o State Correctional Institution
PO Box 11963 Enola, PA 1702 1 Kelley Drive
Harrisburg, PA 17108-1963 Coal Township, PA 17866
HUBSHMAN, CAREY & FLOOD
Date: l fi// 1
Y
JAM S M. FLOOD, ESQUIRE
Attorney for Defendants,
James & Nancy Schaffer
LAW OFFICES OF HURSHMAN, GREY & FLOOD
By: JAMES M. FLOOD
Attorney I.D.#70257
2200 Stafford Avenue, Suite 500
Scranton, PA 18505
Phone #570-961-7580
Attorney for Defendants, James & Nancy Schaffer
MARY M. LYNN
Plaintiff
VS.
JAMES D. SCHAFFER, JR. and NANCY
SCHAFFER, husband and wife; TARA L.
MATTERN; and, NICHOLAUS E. KETTOMAN
Defendants
FILED-OFFICE
OF THE PPOTNONOTARY
2011 _°. '. 17
TY
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NO. 10-7425
CERTIFICATE OF SERVICE
I, JAMES M. FLOOD, ESQUIRE, do hereby certify that a true and correct copy of
a Praecipe for Entry of Appearance, Demand for Jury Trial and Praecipe to File
Complaint were served upon all parties this date via United States first class mail at the
following address:
Attorney for Plaintiff Co ?fendant Co Orefendant
Bradford Dorrance, Esquire Tara L. Mattern Nicholaus E. Kettoman - #FH8385
210 Walnut Street 800 Wertzville Road c/o State Correctional Institution
PO Box 11963 Enola, PA 1702 1 Kelley Drive
Harrisburg, PA 17108-1963 Coal Township, PA 17866
HUBSHMAN, CAREY & FLOOD
Date: Z(A
By:
JAMES A. FLOOD, ESQUIRE
Attorney for Defendants,
James & Nancy Schaffer
LAW OFFICES OF HUBSHMMN CAREY I FLOOD
By: JAMES M. FLOOD
Attorney I.D.#70257
2200 Stafford Avenue, Suite 500
Scranton, PA 18505
Phone #570-961-7580
Attorney for Defendants, James & Nancy Schaffer
51898
MARY M. LYNN
Plaintiff
vs.
JAMES D. SCHAFFER, JR. and NANCY
SCHAFFER, husband and wife; TARA L.
MATTERN; and, NICHOLAUS E. KETTOMAN
Defendants
FILED-OFFICE
OF THE FROTHONOTAR'Y
2011 I6
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NO. 10-7425
PRAECIPE TO FILE COMPLAINT
TO THE PROTHONOTARY:
Please enter a Rule upon the Plaintiff to file a Complaint within twenty (20) days
hereof or suffer the Entry of Judgment Non Pros.
HUBSHMAN, CAREY & FLOOD
l 11 ??
Date. By•
JAM M. FLOOD, ESQUIRE
Attorney for Defendants
RULE TO FILE COMPLAINT
AND NOW, , (J . I, X11 a Rule is hereby granted upon the Plaintiff to file
a Complaint herein within twenty (20) days after service hereof or suffer the Entry of
Judgment of Non Pros.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
01001, 01 k?111r40jyl'?44
?Q ! JAN 14 AM 8: 17
"U E L-,,.a 1-1-1 .` r
CIA
Richard W Stewart
Solicitor
Mary M. Lynn
vs.
James D. Schaffer, Jr. (et al.)
Case Number
2010-7425
SHERIFF'S RETURN OF SERVICE
12/07/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search
and inquiry for the within named defendant, to wit: James D. Schaffer, Jr., but was unable to locate him in
his bailiwick. He therefore deputized the Sheriff of Franklin County, Pennsylvania to serve the within Writ
of Summons according to law.
12/07/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search
and inquiry for the within named defendant, to wit: Nancy Schaffer, but was unable to locate her in his
bailiwick. He therefore deputized the Sheriff of Franklin County, Pennsylvania to serve the within Writ of
Summons according to law.
12/07/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search
and inquiry for the within named defendant, to wit: Nicholaus E. Kettoman, but was unable to locate him in
his bailiwick. He therefore deputized the Sheriff of Northumberland County, Pennsylvania to serve the
within Writ of Summons according to law.
12/13/2010 09:47 AM - Franklin County Return: And now December 13, 2010 at 0947 hours I, Dane Anthony, Sheriff
of Franklin County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of
Summons, upon the within named defendant, to wit: Nancy Schafffer by making known unto herself .i
personally, at 5812 Marsh Road, Waynesboro, Pennnsylvania 17268 its contents and at the same time
handing to her personally the said true and correct copy of the same.
12/13/2010 09:47 AM - Franklin County Return: And now December 13, 2010 at 0947 hours I, Dane Anthony, Sheriff
of Franklin County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of
Summons, upon the within named defendant, to wit: James D. Schaffer Jr. by making known unto himself
personally, at 5812 Marsh Road, Waynesboro, Pennnsylvania 17268 its contents and at the same time
handing to him personally the said true and correct copy of the same.
12/28/2010 10:20 AM - Northumberland County Return: And now December 28, 2010 at 1020 hours I, Chad A.
Reiner, Sheriff of Northumberland County, Pennsylvania, do herby certify and return that I served a true
copy of the within Writ of Summons, upon the within named defendant, to wit: Nicholaus E. Kettoman by
making known unto himself personally, at SCI Coal Township, One Kelley Drive, Coal Township,
Pennsylvania 17866 its contents and at the same time handing to him personally the said true and correct
copy of the same.
12/28/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Tara Lynn Mattern, but was unable to locate her in his
bailiwick. He therefore returns the within Writ of Summons as not found as to the defendant Tara Lynn
Mattern. Request for service at 800 Wertzville Road, Enola, Pennsylvania 17025 the defendant was not
found. Deputies were advised, Tara Lynn Mattern has not resided at 800 Wertzville Road, Enola,
Pennsylvania 17025 in some time. However, The Enola Postmaster is delivering Tara Lynn Mattern's mail
to 800 Wertzville Road, Enola, Pennsylvania 17025.
SHERIFF COST: $112.94
January 11, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
1] Ccuit?, S.?ite S?er;rr Tee^S't. i...,.
SHERIFF'S RETURN - REGULAR
CASE NO: 2010-00299 T
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF FRANKLIN
MARY M LYNN
VS
JAMES D JR AND NANCY SCHAFFER
ANGEL L LAVIENA
, Deputy Sheriff of FRANKLIN
County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT TO QUIET TITLE was served upon
SCHAFFER JAMES D the
DEFENDANT , at 0947:00 Hour, on the 13th day of December-, 2010
at 5812 MARSH ROAD
WAYNESBORO, PA 17268
TTMLIC+ n CVTP.PVV
by handing to
a true and attested copy of COMPLAINT TO QUIET TITLE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
.00
.00 ANGEL L V N
.00
.00 By
.00 D djmy e r i f f
.00 01/06/2011
KEEFER WOOD ALLEN AND RAHAL LL
Sworn and Subscribed to before
me this day of
Q/ 0(1 A.D.
Q GVf_ A
Notary ,.
COMMONW
=Chambersbur EA OF PENNSYLVANIA SEAL
RTY, Notary Public
ro., Franklin County
xpires Jan. 29, 2011
SHERIFF'S RETURN - REGULAR
CASE NO: 2010-00299 T
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF FRANKLIN
MARY M LYNN
VS
JAMES D JR AND NANCY SCHAFFER
ANGEL L LAVIENA
Deputy Sheriff of FRANKLIN
County, Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF SUMMONS/PLAINTIFF was served upon
SCHAFFER NANCY the
DEFENDANT at 0947:00 Hour, on the 13th day of December-, 2010
at 5812 MARSH ROAD
WAYNESBORO, PA 17268
ATTTTrv COT721T;'WWD
by handing to
a true and attested copy of WRIT OF SUMMONS/PLAINTIFF together with
RST SET OF INTERROGATORIES
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
.00
.00 ANGE L
.00
.00 B
.00 41eppu&tySheriff
.00 01/06/2011
KEEFER WOOD RAHAL ALLEN AND RA
Sworn and Subscribed to before
me this day of
c210// A.D.
I
Notary
COMMONW=Chambersburg AA OF PENNSYLVANIA
KTY, Notary Public
ro., Franklin County
xpires Jan. 24, 2011
SHERIFF'S OFFICE OF NORTHUMBERLAND COUNTY
Chad A Reiner Tony Matulewicz, Esq
Sheriff '' Solicitor
.
Randy Coe .'
Chief Deputy gYA
MARY M LYNN
vs.
JAMES D SCHAFFER, JR (et al.)
Case Number
10 CV 07425
SHERIFF'S RETURN OF SERVICE
12/28/2010 10:20 AM - DEPUTY NICOLE BAKER, BEING DULY SWORN ACCORDING TO LAW, SERVED THE
REQUESTED PRAECIPE AND WRIT OF SUMMONS (WOSM) / PLAINTIFF'S FIRST SET OF
INTERROGATORIES BY "PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING
THEMSELVES TO BE THE DEFENDANT, TO WIT: NICHOLAUS E KETTOMAN INMATE# AT
SCI-COAL TOWNSHIP, ONE KELLEY DRIVE, COAL TOWNSHIP, PA 17866.
SHERIFF COST: $71.20 SO ANSWERS,
December 30, 2010 CHAD A REINER, SHERIFF
Sworn to and subscribed before
me'this 30 day-of brC
A.D. 2010
ROTHONOTARY
My Comm, Exp. 1st Mon. Jan. 2014
LAW OFFICES OF HUBSHMAN CAREY & FLOOD
By: JAMES M. FLOOD
Attorney I.D.#70257
2200 Stafford Avenue, Suite 500
Scranton, PA 18505
Phone #570-961-7580
Attorney for Defendants, James & Nancy Schaffer
S1898
MARY M. LYNN
Plaintiff
n ."
-OFF
2011 Fun PVj 1.0
CUPI6E.RL 010 CoUtil Y
PENKSYI.vpNl A
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
VS. CIVIL ACTION - LAW
JURY TRIAL DEMANDED
JAMES D. SCHAFFER, JR. and NANCY .
SCHAFFER, husband and wife; TARA L.
MATTERN; and, NICHOLAUS E. KETTOMAN
Defendants NO. 10-7425
CERTIFICATE OF SERVICE
I, JAMES M. FLOOD, ESQUIRE, do hereby certify that Defendants' Answers to
Plaintiff's Second Set of Interrogatories were served upon all parties this date via United
States first class mail at the following address:
Attorney for Plaintiff Co Defendant Co-Defendant
Bradford Dorrance, Esquire Tara L. Mattern Nicholaus E. Kettoman - #FH8385
210 Walnut Street 800 Wertzville Road c/o State Correctional Institution
PO Box 11963 Enola, PA 1702 1 Kelley Drive
Harrisburg, PA 17108-1963 Coal Township, PA 17866
HUBSHMAN, CAREY & FLOOD
Date: 212
By:
DAME M. FLOOD, ESQUIRE
Attorney for Defendants,
James & Nancy Schaffer
LAW OFFICES OF HUSSHMAN, CARAY? & FLOOD
By: JAMES M. FLOOD
Attorney I.D.#70257
2200 Stafford Avenue, Suite 500
Scranton, PA 18505
Phone #570-961-7580
Attorney for Defendants, James & Nanc{ Schaffer
MARY M. LYNN
VS.
intiff
G° ?'??.?"oar iLk-
FFi 0 IoHOTAR4
TH,
X911 MAR -9 Pr, 2: 08
, PENN YLVAN N TY
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
JAMES D. SCHAFFER, JR. and NANCY
SCHAFFER, husband and wife TARA L.
MATTERN; and, NICHOLAUS E. KETTOMAN
De endants
I, JAMES M. FLOOD,
was served upon all parties
address:
Aftorney for Plaintiff
Bradford Dorrance, Esquire
210 Walnut Street
PO Box 11963
Harrisburg, PA 17108-1963
Date:
NO. 10-7425
do hereby certify that a Notice of Oral Deposition
s date via United States first class mail at the following
Co-Defendant Co-Defendant
Tara L. Mattern Nicholaus E. Kettoman - #FH8385
800 Wertzville Road c/o State Correctional Institution
Enola, PA 1702 1 Kelley Drive
Coal Township, PA 17866
HUBSHMAN, CAREY & FLOOD
BY: ?("'/
JAMES M. FLOOD, ESQUIRE
Attorney for Defendants,
James & Nancy Schaffer
By: JAMES M. FLOOD
Attorney I.D.#70257
2200 Stafford Avenue, Suite 500
Scranton, PA 18505
Phone #570-961-7580
Attorney for Defendants, James & Nancy Schaffer
MARY M. LYNN
Plaintiff
VS.
JAMES D. SCHAFFER, JR. and NANCY
SCHAFFER, husband and wife; TARA L.
MATTERN; and, NICHOLAUS E. KETTOMAN
Defendants
OF THE PROTHONGTA
2011 MAY 26 AM 10: 4 3
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NO. 10-7425
CERTIFICATE OF SERVICE
I, JAMES M. FLOOD, ESQUIRE, do hereby certify that an Amended Notice of Oral
Deposition was served upon all parties this date via United States first class mail at the
following address:
Attorney for Plaintiff
Bradford Dorrance, Esquire
210 Walnut Street
PO Box 11963
Harrisburg, PA 17108-1963
Date: J
HUBSHMAN & FLOOD
JAMES M. FLOOD, ESQUIRE
Attorney for Defendants,
James & Nancy Schaffer
.i _. .
LAW OFFICES OF HUBSHMAN & FLOOD
BY: JAMES M FLOOD, ESQUIRE
j flood 1 @progressive.com
Attorney Identification No. 70257
2200 Stafford Avenue, Suite 500
Scranton, PA 18505-3690
570-961-7580
HC FILE 015D2-S1898
MARY M. LYNN
tiff: THE PROTHCNOTAR',
2011 JUL IS AM 10: 59
CUMBERLAND COUNTY
PENNSYLVANIA
Attorney for Defendants,
James D Schaffer, Jr. and Nancy Schaffer
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
V.
JAMES D SCHAFFER, JR., NANCY
SCHAFFER, I-ARA MATTERN and
NICHOLAS KETTOMAN
NO. 10-7425
CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA
PURSUANT TO RULE 4009.21
As a prerequisite to service of subpoena for documents and things pursuant to Rule 4009.22:
Certifies that:
1. a notice of intent to serve the subpoena with copies of the subpoena attached hereto was
mailed or delivered to each party at least twenty (20) days prior to the date on which the
subpoena is sought to be served;
2. a copy of the notice of intent, including the proposed subpoena, is attached to this
certificate;
3. the subpoena which will be served is identical to the subpoena which is attached to the
notice of intent to serve the subpoena;
4. no objection to the subpoena has been received.
LA F ICES OF HU AN & FLOOD
B,
S M FL OD, QUIRE --
Attorney for Def ants,
James D Schaf er, Jr. and Nancy Schaffer
DATE: July 13 2011
File No. 0151)2-51898
LAW OFFICES OF HUBSHMAN & FLOOD
BY: JAMES M FLOOD, ESQUIRE
jflood l @progressive.com
Attorney Identification No. 70257
2200 Stafford Avenue, Suite 500
Scranton, PA 18505-3690
570-961-7580
HC FILE 015132-S 1898
MARY M. LYNN
V.
JAMES D SCHAFFER, JR., NANCY
SCHAFFER, TARA MATTERN and
NICHOLAS KETTOMAN
Attorney for Defendants,
James D Schaffer, Jr. and Nancy Schaffer
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 10-7425
r 11,4 1 i,iv I I U NERVE SUBPOENA TO PRODUCE DOCUAl
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
MARY M. LYNN:
PMA Management Group Insurance Records
TO: Bradford Dorrance, Esquire
James M Flood, Esquire intends to serve subpoena identical to the ones that are attached
to this Notice. You have 20 days from the date listed below in which to file of record and serve
upon the undersigned an objection to the subpoena. If the 20 day Notice period is waived, or, if
no objection is made, then the subpoena may be served. Complete copies of any reproduced
records may be ordered at your expense by contacting, Rhonda J. Ferrance.
Date of Issue: June 15, 2011 James M Flood, Esquire, Attorney for Defendants
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
i,?NN
Court of Common Pleas
', ?Vll ? `?_'?;t I [At-, -.' R, JR_._et al No. 10-742
f )YlClltdG(RI ?? - -'-'
Subpoena to Produce Documcnts or Things
for Discovery Pursuant to Rule 4009.22
l { ): ('MFG Man d anent t roue
(T?`pnte of I'?rson or h:ndrttil """""°-°-°
?,<Llrir? tvvcidt ("20) days after the service of this subpoena, you are ordered by the Court to produce the following;
of thims: Copies of any testimony notes ertainin to Claim #W8807-38013 em
to Yer is Count
""''tr ?+tai'fcatcf hAvenue 4_uite 500 Scranton PA 18505-3690
`, rstr na,z? dej«Er or mail legible copies of the documents or, produce things requested bv, this subpoena together evrtil
?.?^rtitrcai of compli2ncc to the party making this request at the address Fisted above. > ou t??zt? t.(?e ra ??t to seek ??
adt ancc tlre reasonable; cost of preparing the copies or producing the things sought.
Jf you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the;
h:r0 v ser vfn1?-' th is subpoena may seek a court order compelling you to comply with it.
?, his subpoena was issued at the request of the following person:
Name: Jaynes f5v1 Floo a _
_d f;sctu.re
ilddres : pQ Jizrfl0rE3.14c trueSuite 500
Scranton 1' 1505-369t1
'T'elephone. 570-961-75$0
Supreme Court ID#: 70257
Attorncv for: I cfett(fants
13Y 'rJ1E ("01,"R T:
llaviti [). Buell, Prothonotary
PIZO ?
i t ; ?`
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA,,,,,,,,,,,,
CIVIL DIVISION 3:1,
Discover Bank, Through Its Servicing Agent, r'-=+xi CJU,
DB Servicing Corporation
Plaintiff
vs. Civil Action No. 11-7425 CIVIL TERM
JODY RHODY
TIMOTHY RHODY
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONTARY:
Kindly enter Judgment against the Defendants JODY RHODY , TIMOTHY RHODY
above named, in the default of an Answer, in the amount of $5304.77
computed as follows:
Amount claimed in Complaint
Less payments / adjustments made
Interest on the remaining principa
from July 31, 2011 to November 09,
@ the interest rate of 18.9900
Attorney's fees
TOTAL
$5893.28
$978.00
1 balance
2011
per annum $264.49
$125.00
$5304.77
I hereby certify that appropriate Notices of Default, as attached have
been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the
Notices.
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY : \ ??
James C. a rodt;42524
09329171/ C1 A Pit SJS
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400 Pittsburg A 15219
And that the last known address of the e ndants are
JODY RHODY
80 ALTERS RD
CARLISLE, PA 17015
Q%14.00 pa a' J
Ck.? a (? t s? 8 3
V? 1n ? re VVtOw
TIMOTHY RHODY
80 ALTERS RD
CARLISLE, PA 17015
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
JODY RHODY
TIMOTHY RHODY
Defendant
Case No. 11-7425 CIVIL TERM
IMPORTANT NOTICE
TO:
TIMOTHY RHODY
80 ALTERS RD
CARLISLE, PA 17015
Date of Notice: .1
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY
ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS,
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
(717) 249-3166
WELTMAN, WEINBERG & REIS CO., L.P.A
By: / _.
Matthew Urban
P.A.I.D.# 90963
WELTMAN, WEINBERG & REIS CO,, L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
Phone: (412) 434-7955
(412) 338-7130
9329171 A PIT H4td
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
Case No. 11-7425 CIVIL TERM
VS.
JODY RHODY
TIMOTHY RHODY
Defendant
IMPORTANT NOTICE
TO:
JODY RHODY
80 ALTERS RD
CARLISLE, PA 17015 11
Date of Notice: ' t
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY
ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH
AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
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
(717) 248-3166
WELTMAN, WEINBERG & REIS CO., L.P,A.
-By: .?"
Matthew Urban
P.A.I. D.# 90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
Phone: (412) 434-7955
(412) 338-7130
9329171 A PIT H4N
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Discover Bank,
Through Its Servicing Agent,
DB Servicing Corporation
Plaintiff
vs. Civil Action No. 11-7425 CIVIL TERM
NON-MILITARY AFFIDAVIT
JODY RHODY
TIMOTHY RHODY
The undersigned is the duly authorized agent and/or attorney for the
Plaintiff in the within matter and states as follows:
Affiant states that the within Affidavit is made pursuant to and in
accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App.
521.
Affiant further states that based upon investigation it is the affiant's
belief that the Defendants , JODY RHODY , TIMOTHY RHODY , are not in
military service.
Affiant further states that this belief is supported by the attached
certificate from the Defense Manpower Data Center (DMDC), which states that
the DMDC does not possess any information indicating that the below
individual is in the military service:
JODY RHODY
80 ALTERS RD
CARLISLE, PA 17015
TIMOTHY RHODY
80 ALTERS RD
CARLISLE, PA 17015
Affiant further states that the averments contained herein are true and
correct to the best of Affiant's knowledge, information and belief and that
these averments are made subject to the penalties of 18 Pa C.S.A. Section
4904 relating to unsworn falsification to authorities.
Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Nov-11-2011 04:42:48
-< Last First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
Name
Based on the information you have furnished, the DMDC does not possess
RHODY JODY any information indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
A&Y 14. &?C?
4*4 - ,
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§
501 et seq, as amended) (SCRA;) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL http:/h,,-ww.defensel.in.k.m.il/fag/pis/PC09SI..;D.R.html. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
https-://www.dmdc.osd.mil/appj/scra/popreport.do 11/11/2011
Request for Military Status Page 2 of 2
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a
period of more than 30 consecutive days. In the case of a member of the National Guard, includes
service under a call to active service authorized by the President or the Secretary of Defense for a period
of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national
emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR)
members must be assigned against an authorized mobilization position in the unit they support. This
includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a
Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health
Service or the National Oceanic and Atmospheric Administration (NOAH Commissioned Corps) for a
period of more than 30 consecutive days.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active
duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate.
Many times orders are amended to extend the period of active duty, which would extend SCRA
protections. Persons seeking to rely on this website certification should check to make sure the orders on
which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report
for active duty or to be inducted, but who have not actually begun active duty or actually reported for
induction. The Last Date on Active Duty entry is important because a number of protections of SCRA
extend beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights
guaranteed to Service members under the SCRA are protected.
WARNING: This certificate was provided based on a name and SSN provided by the requester.
Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID:DFBTILVPVF
https://www.dmdc.osd.mil/appj/'scra/popreport.do 11/11/2011
Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
low
Page 1 of 2
Nov-11-2011 04:42:56
Last First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
Name
Based on the information you have furnished, the DMDC does not possess
RHODY TIMOTHY any information indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast
Guard).
44ut 14. 4A4 A??
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§
501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL http• /tiNtivw defense]ink.m.iI/fag/pis/PC09SI..,DR.html. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
https://www.dmdc.osd.mil/appj/scra/popreport.do 11/11/2011
Request for Military Status Page 2 of 2
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a
period of more than 30 consecutive days. In the case of a member of the National Guard, includes
service under a call to active service authorized by the President or the Secretary of Defense for a period
of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national
emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR)
members must be assigned against an authorized mobilization position in the unit they support. This
includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a
Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health
Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a
period of more than 30 consecutive days.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active
duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate.
Many times orders are amended to extend the period of active duty, which would extend SCRA
protections. Persons seeking to rely on this website certification should check to make sure the orders on
which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report
for active duty or to be inducted, but who have not actually begun active duty or actually reported for
induction. The Last Date on Active Duty entry is important because a number of protections of SCRA
extend beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights
guaranteed to Service members under the SCRA are protected.
WARNING: This certificate was provided based on a name and SSN provided by the requester.
Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID:NA51 QN42TJ
https://www.dmde.osd.mil/appj,lscra/popreport.do 11/11/2011
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Discover Bank, Through Its Servicing Agent,
DB Servicing Corporation
Plaintiff
vs. Civil Action No. 11-7425 CIVIL TERM
JODY RHODY
TIMOTHY RHODY
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following order of Judgment
was entered against you on ? 113111
(xx) Assumpsit Judgment in the amount of $5304.77 plus costs.
( ) Trespass Judgment in the amount of $ plus costs.
( ) If not satisfied within sixty (60) days, your motor vehicle
operator's license and/or registration will be suspended
by the Department of Transportation, Bureau of Traffic Safety,
Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration
Prothonotary
By:
JODY RHODY
80 ALTERS RD
CARLISLE, PA 17015
TIMOTHY RHODY
80 ALTERS RD
CARLISLE, PA 17015
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.,
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955