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Home My WebLink About11-0470FILED-OrFICE OF THE FROTHON+OTARY 2g1,1j Nlg PM 2,44 COi'tR ANGINO & ROVNER, P.C. Richard A. Sadlock Attorney ID# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: rsadlock@angino-rovner.com FAITH MILLER-BOROCZ, Plaintiff V. TAYLOR DEPUE and MARK DEPUE, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 147b Ctv<<Tt'(m 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. 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 S. Bedford St., Carlisle 17013 (717) 249-3166 454064 d ?? aat?a? Q k ? 439 D`'F g? ?53g15 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defMarshalle 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 u 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 OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 S. Bedford St., Carlisle 17013 (717) 249-3166 TELEFONO (717) 249-3166 454064 ANGINO & ROVNER, P.C. Richard A. Sadlock Attorney ID# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: rsadlock@angino-rovner.com FAITH MILLER-BOROCZ, Plaintiff V. TAYLOR DEPUE and MARK J. DEPUE, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff Faith Miller-Borocz is an adult individual, citizen of the Commonwealth of Pennsylvania, who resides at 130 Wheatland Road, Lewisberry Borough, York County, Pennsylvania. 2. Defendant Taylor Depue is an adult individual, who resides at 1502 Simpson Ferry Road, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Defendant Mark J. Depue is an adult individual, who resides at 46 Brian Drive, Carlisle, Cumberland County, Pennsylvania 17015. 4. The facts and occurrences hereinafter related took place on or about September 25, 2010, at approximately 1:02 a.m., near 433 Lewisberry Road, Fairview Township, York County, Pennsylvania. 5. At that time and place, Plaintiff Faith Miller-Borocz had previously lawfully walked across the road and was then standing in a friend's driveway. 6. At that time and place, Defendant Taylor Depue was operating a 1999 Honda Accord, owned by Mark Depue, and had pulled over to speak with Plaintiff Faith Miller-Borocz. 454064 7. Plaintiff Faith Miller-Borocz approached the Honda vehicle when it came to rest near her. 8. At that time and place, after speaking with Plaintiff Faith Miller-Borocz, Defendant Taylor Depue, reversed and accelerated the Honda vehicle, and suddenly, without warning, violently struck the Plaintiff, and ran over Plaintiff's right foot, knocking her to the ground. COUNTI FAITH MILLER-BOROCZ v. TAYLOR DEPUE 9. Paragraphs 1 through 8 of Plaintiff's Complaint are incorporated herein by reference. 10. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff Faith Miller-Borocz are the direct and proximate result of the negligent, careless, wanton, and reckless manner in which Defendant Taylor Depue operated the motor vehicle as follows: (a) failing to properly inspect the premises for situations or conditions that might pose a hazard to persons in the area; (b) failure to apply her brakes in sufficient time to avoid striking Plaintiff Faith Miller-Borocz; (c) failure to keep proper and adequate control over the vehicle; (d) failure to have the vehicle under such control as to be able to stop within the assured clear distance; (e) failure to travel at a safe speed; (f) failure to ensure the safety of pedestrians before operating her vehicle; (g) failure to know whether her vehicle was in drive or reverse prior to operating her vehicle; and 454064 (h) driving the vehicle in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of other in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. COUNT II FAITH MILLER-BOROCZ v. MARK J. DEPUE 11. Paragraphs 1 through 10 of Plaintiff's Complaint are incorporated herein by reference. 12. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff Faith Miller-Borocz are the direct and proximate result of the negligence of Defendant, Mark J. Depue, for entrusting the 1999 Honda Accord to Defendant Taylor Depue as follows: permitting Defendant Taylor Depue to operate the 1999 Honda Accord although she knew or should have known that Defendant Taylor Depue did not have adequate experience and judgment to adequately control and operate the 1999 Honda Accord; b. permitting Defendant Taylor Depue to operate the 1999 Honda Accord although she knew or should have known that Defendant Taylor Depue was careless and reckless in the operation of motor vehicles; C. failing to properly supervise the operation and use of the 1999 Honda Accord by Defendant Taylor Depue; and d. permitting Defendant Taylor Depue to operate the 1999 Honda Accord in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 13. As a result of Defendants' negligence, as herein before related, Plaintiff Faith Miller-Borocz has sustained painful and severe injuries, which include, but are not limited to the following: a. multiple fractures, in particular to her right foot and ankle, at her distal tibia, fibula, talus and 1st through 5t' metatarsals, which required open reduction internal fixation, 454064 b. diffuse upper extremity trauma and injuries resulting in left elbow pain and a right elbow contusion, c. abrasions and contusions on her lower extremities, in particular to her right knee, and d. a nail bed laceration and toenail avulsion on her great toe of her right foot. 14. By reason of the aforesaid injuries sustained by Plaintiff Faith Miller-Borocz, she was forced to incur liability for medical treatment, medications, chiropractic, and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 15. Because of the nature of her injuries, Plaintiff Faith Miller-Borocz has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 16. Plaintiff Faith Miller-Borocz has undergone and in the future may undergo physical and mental suffering, inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 17. Plaintiff Faith Miller-Borocz continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefor. 18. As a direct result of the negligence of the Defendants, Plaintiff, Faith Miller- Borocz has suffered scarring and disfigurement, and claim is made therefor. 19. As a result of the aforementioned injuries, Plaintiff Faith Miller-Borocz has sustained work loss, loss of opportunity and a permanent diminution of her earning power and capacity, and claim is made therefore. 20. As a result of the negligence of Defendants, Plaintiff, Faith Miller-Borocz may in the future suffer a loss of earnings and earning capacity, and claim is made therefor. 454064 WHEREFORE, Plaintiff Faith Miller-Borocz demands judgment against Defendants Taylor Depue and Mark J. Depue in an amount excess of Fifty Thousand Dollars ($50,000.00), exclusive of interest and costs and in excess of the jurisdictional amount requiring compulsory arbitration. ANG C. ?ww ichard A. S , Esquire PA I.D. No. 47281 Date: 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 rsadlock@angino-rovner.com Counsel for Plaintiffs 454064 VERIFICATION I, FAITH MILLER-BOROCZ., do swear and affirm 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 this verification is made subject to the penalties of the Rules of Civil Procedure relating to unworn falsification to authorities. WITN FAITH MILLER-BOROCZ Dated: // l 203648 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAITH MILLER-BOROCZ, vs. Plaintiff NO. 11-470 CIVIL ACTION C2 _n r"'° ° Comer r*, :a rr 1 uv = rr; Cnnr t C r..? - = w CD --s r" rn U1 TAYLOR DEPUE and MARK DEPUE, Defendants PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter the appearance of Buzgon Davis Law Offices whose address is 525 South Eighth Street, P.O. Box 49, Lebanon, Pennsylvania 17042-0049, as attorneys for the Defendants, Taylor Depue and Mark Depue, in the above-captioned case. This entry is made without prejudice to contest service or jurisdiction. BUZGON DAVIS LAW OFFICES DATE: a . (4 BY: SCOTT ? RENOBLE, ESQUIRE Attorn .D. #72808 .525 South Eighth Street P.O. Box 49 Lebanon, PA 17042-0049 (717) 274-1421 (717) 274-1752 - facsimile Email: sgrenoble@buzgondavis.com Attorney for Defendants, Taylor Depue and Mark Depue IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAITH MILLER-BOROCZ, Plaintiff NO. 11-470 VS. CIVIL ACTION rw. ? TAYLOR DEPUE and CO - r? s= MARK DEPUE, 'ZM r -a ? Defendants r- X <C:. c -I w1 :1-" . `^' AFFIDAVIT OF SERVICE 2 Cr! COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF LEBANON ) I, Britany Hirst, an employee of the law firm of Buzgon Davis Law Offices, 525 South Eighth Street, Lebanon, Lebanon County, Pennsylvania, Attorneys for Defendant, being duly sworn according to law, depose and say that on February 4, 2011, I mailed to the Office of the Prothonotary of Cumberland County, the original PRAECIPE FOR ENTRY OF APPEARANCE and that I mailed, by First Class mail, in a postpaid envelope, a true and correct copy to Richard A. Sadlock, Esquire, 4503 N. Front Street, Harrisburg, PA 17110, Counsel for Plaintiff. /-Z- ITANY HIRST Sworn to and subscribed before me this 4`h day of February, A.D., 2011. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Ashley M. Long, Notary Public City of Lebanon, Lebanon County L My Commission Expires June 2g, 2011 Member, Pennsylvania Association of Notaries SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Faith Miller-Borocz vs. Mark J Depue (et al.) FILED- 0 F _ - nd HI 1111 FF I7 A 11=_ EWS g'i `VAHIM Case Number 2011-470 SHERIFF'S RETURN OF SERVICE 02/15/2011 08:14 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on February 15, 2011 at 2014 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Taylor Depue, by making known unto Susan Depue, Mother of defendant at 1903 Chestnut Road, Apartment 5, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. ,>q.jk & 16g"L GERALD WORTHINGT , DEPUTY SHERIFF COST: $47.34 February 16, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C: .?" FAITH MILLER-BOROCZ, a; Plaintiff c?nyr, co vs. 'T'AYLOR DEPUE and MARK DEPUE, Defendants NO. 11-470 CIVIL ACTION AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF LEBANON ) -c ? x G CID I, Britany Hirst, an employee of the law firm of Buzgon Davis Law Offices, 525 South ---°fi CD p- rt O 371 Eighth Street, Lebanon, Lebanon County, Pennsylvania, Attorneys for Defendant, being duly sworn according to law, depose and say that on February 24, 2011, I mailed, the original ANSWERS TO PLAINTIFFS' REQUEST FOR PRODUCTION OF DOCUMENTS OF DEFENDANT, TAYLOR DEPUE, and MARK DEPUE by First Ciass mail, in a postpaid envelope, a true and correct copy to Richard A. Sadlock, Esquire, 4503 N. Front Street, Harrisburg, PA 17110, Counsel for Plaintiff. Sworn to and subscribed before me this 24`" day of February. A.D., 2011. Notary 01lic BRITANY HIRST COMMONWEALTH OF PENNSYLVANL4 Notarial Seal Amy Hartranft, Notary Public City of Lebanon, Lebanon County Commission Expires Sept, 19, 2014 Member. Pannw1vsnia .Ac ;s -:,tl;tn (Notaries FAITH MILLER-BOROCZ, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA vs. TAYLOR DEPUE and No. 11-470 MARK DEPUE, Defendants -? m ?Yw ? --a ? M-._ Y 1 EZ; NOTICE TO PLEAD =cn To Plaintiff- _ 3n You are hereby notified to file a written response to the enclosed New Matter w-ihi r"?we&61 (20) days from service hereof or a judgment may be entered against you. DEFENDANTS' ANSWER AND NEW MATTER AND NOW, comes the Defendants, 'T'aylor Depue and Mark Depue, by their attorneys, Buzgon Davis Law Offices, and tiles and files the within Answer and New Matter. averring as follows: 1 A NQWV1.) 1. Admitted upon information and belief. 2. Admitted. 3. Admitted. 4. Admitted. 5. Denied. The averments of Paragraph 5 set forth conclusions to law to which no response is required. By way of further response, said allegations are denied, strict proof being demanded at trial. 6. Admitted in part and denied in part. It is denied that "Taylor Depue pulled over to speak to Plaintiff. 7. Admitted. By way of further response, Plaintiff ran at Defendant's vehicle in a threatening manner and threatened to inflict harm upon Defendant, Taylor Depue. 8. Denied. COUNTI FAITH MILLER-BOROC7 v. TAYLOR DEPUE 9. The answers to paragraphs 1 through 8 are incorporated herein by reference as if textually set forth at length. 10. Denied. The averments of Paragraph 10 a-h set forth conclusions to law to which no response is required. By way of further response, said allegations are denied, strict proof being demanded at trial. COUNTI FAITH MILLER-BOROCL v. MARK DEPUE 11. The answers to paragraphs 1 through 10 are incorporated herein by reference as if textually set forth at length. 12. (a-d) Denied. The averments of Paragraph 12 a-d set forth conclusions to law to which no response is required. By way of further response, said allegations are denied, strict proof being demanded at trial. -2- 13. (a-d) Denied. The averments of Paragraph 13 a-d set forth conclusions to law to which no response is required. By way of further response, said allegations arc denied, strict proof being demanded at trial. 14. Denied. After reasonable investigation, Defendants arc without sufficient information to respond the averments of Paragraph 14, strict proof being demanded at trial. 15. Denied. After reasonable investigation, Defendants are without sufficient information to respond the averments of Paragraph 15, strict proof being demanded at trial. 16. Denied. After reasonable investigation, Defendants arc without sufficient information to respond the averments of Paragraph 16, strict proof being demanded at trial. 17. Denied. After reasonable investigation, Defendants arc without sufficient information to respond the averments of Paragraph 17, strict proof being demanded at trial. 18. Denied. The averments of Paragraph 18 set forth conclusions to law to which no response is required. By way of further response, said allegations are denied, strict proof being demanded at trial. 19. Denied. After reasonable investigation, Defendants are without sufficient information to respond the averments of Paragraph 19, strict proof being demanded at trial. 20. Denied. The averments of Paragraph 20 set forth conclusions to law to which no response is required. By way of further response, said allegations are denied, strict proof being demanded at trial. WHEREFORE, Defendants respectfully requests this Ilonorable Court to dismiss Plaintiffs Complaint with prejudice. IL NEW MATTER -3- 21. To the extent justified by the evidence developed in discovery or the testimony at the time of trial, Defendants were not negligent, reckless, or careless with respect to any conduct regarding the injuries and damages alleged by Plaintiff. 22. To the extent justified by the evidence developed in discovery or the testimony at the time of trial, the injuries and damages allegedly sustained by Plaintiff was not proximately caused by Defendants. 23. To the extent justified by the evidence developed in discovery or the testimony at the time of trial, Defendant's conduct was legally justified. 24. To the extent justified by the evidence developed in discovery or the testimony at the time of trial, the injuries and damages allegedly sustained by Plaintiff was caused by Plaintiffs own negligence, carelessness and recklessness. 25. To the extent justified by the evidence developed in discovery or the testimony at the time of trial, all or some of Plaintiff's claimed injuries were pre-existing and/or otherwise unrelated to the incident of September 25, 2010. 26. To the extent justified by the evidence developed in discovery or the testimony at the time of trial, Plaintiff's cause of action is barred, in whole or in part, by the principles of her own contributory negligence. 27. To the extent justified by the evidence developed in discovery or the testimony at the time of trial, Plaintiffs comparative negligence, carelessness and recklessness exceeds any negligence or carelessness of Defendants, all such negligence or carelessness of Defendants being specifically denied. 28. To the extent justified by the evidence developed in discovery or the testimony at the time of trial, Plaintiffs claims are barred by the affirmative defenses identified -4- in Pennsylvania Rule of Civil Procedure 1030, including but not limited to (a) waiver; (b) estoppel; (c) statute of limitations; (d) laches; (e) illegality; (f) release; (g) impossibility of performance; (h) fraud; (i) assumption of risk; and (j) payment. 29. To the extent justified by the evidence developed in discovery or the testimony at the time of trial, This action is barred or otherwise limited by the Motor Vehicle Financial Responsibility Law, Title 75 Pa. C. S. Section 1701 et seq ., either as originally promulgated or as amended by Act No. 1990-6. Defendants plead this law and the amendments thereto as a complete or, in the alternative, partial defense to Plaintiffs civil action. 30. To the extent justified by the evidence developed in discovery or the testimony at the time of trial, Any claim or request in this action for damages for delay pursuant to Rule 238 of the Pennsylvania Rules of Civil Procedure is in contravention to and barred by the United States and Pennsylvania Constitutions because: (a) the rule exceeds the rule-making authority granted to the judiciary by the Pennsylvania Constitution; (b) the rule violates the equal protection clauses of the United States and Pennsylvania Constitutions; (c) the rule violates the standards of due process guaranteed by the United States and Pennsylvania Constitutions; and (d) the rule violates the excessive fines clause of the United States Constitution. -5- WHEREFORE, Defendants respectfully requests your Honorable Court to dismiss Plaintiff's Complaint with prejudice. BUZGON DAVIS LAW OFFICES BY: Scott L. Greno. e, Esquire Attorney I.D. '172808 525 South FI hth Street Post Office Box 49 Lebanon, PA 17042-0049 (717) 274-1421 Attorneys for Defendants -6- VERIFICATION I, MARK DEPUE, do hereby verify that I am the Defendant in the foregoing action; that the attached Answer and New Matter is based upon information which I have furnished to my counsel and information which has been gathered by my counsel in the preparation of the lawsuit. The language of the Answer and New Matter is that of counsel and not of me. I have read the Answers and to the extent that the Answers are based upon information which I have given to my counsel, they are true and correct to the best of my knowledge, information and belief. To the extent that the content of the Answers is that of counsel, I have relied upon counsel in making this Verification. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. aL MARK DEPUE Date: 4 1-1 I 1 VERIFICATION I, TAYLOR DEPUE, do hereby verify that I am the Defendant in the foregoing action; that the attached Answer and New Matter is based upon information which I have furnished to my counsel and information which has been gathered by my counsel in the preparation of the lawsuit. The language of the Answer and New Matter is that of counsel and not of me. I have read the Answers and to the extent that the Answers are based upon information which I have given to my counsel, they are true and correct to the best of my knowledge, information and belief. To the extent that the content of the Answers is that of counsel, I have relied upon counsel in making this Verification. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: L I -I I I ( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAITH MILLER-BOROCZ, Plaintiff vs. TAYLOR DEPUE and MARK DEPUE, Defendants ?7 na NO. 11-470 • - rT7 `.; =rn CIVIL ACTION a s4,, -<> M CD = . .. =C 3 CD -TI 7- AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF LEBANON I, Natalie K. Jenkins, an employee of the law firm of Buzgon Davis Law Offices, 525 South Eighth Street, Lebanon, Lebanon County, Pennsylvania, Attorneys for Defendant, being duly sworn according to law, depose and say that on April 7, 2011, I mailed to the Office of the Prothonotary of Cumberland County, the original DEFENDANTS' ANSWER AND NEW MATTER and that I mailed, by First Class mail, in a postpaid envelope, a true and correct copy to Richard A. Sadlock, Esquire, 4503 N. Front Street, Harrisburg, PA 17110, Counsel for Plaintiff. -l l.(_WIA X NATALII K. JI 4,NS Sworn to and subscribed before me this 7th day of pril, , 2011. NOTARIAL SEAL BRITANY HIRST Notary Public Notary Public CITY OF LEBANON, LEBANON COUNTY My Commission Expires Jul 10, 2013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAITH MILLER-BOROCZ, Plaintiff NO. 11-470 vs. CIVIL ACTION TAYLOR DEPU E and c MARK DEPUE, p„ z zM =;u -a M- 'V Defendants ?y M ?° x AFFIDAVIT OF SERVICE c ' ° Z>r, ?' COMMONWEALTH OF PF ,NNSYf,VAN1A ) ss: COUNTY OF LEBANON I, Natalie Jenkins, an employee of the law firm of Buzgon Davis Law Offices, 525 South Eighth Street, Lebanon, Lebanon County, Pennsylvania, Attorneys for Defendants, being duly sworn according to law, depose and say that on April 7, 2011, I mailed, the original DEFENDANT, TAYLOR DEPUE'S ANSWERS TO PLAINTIFF'S INTERROGATORIES by First Class mail, m a postpaid envelope, a true and correct copy to Richard A. Sadlock, Esquire, 4503 N. Front Street, I larrisburg, PA 17110, Counsel for Plaintiff: NATALIE Jl;NKli S Sworn to and subscribed before me this 7"' day NOTARIAL SEAL jotary,A . 2011. BRITANY HIRS T Notary Public CITY OF LEBANON, LEBANON COUNTY ublic My Commission Expires Jul 10, 2013 OF I1.1r, FED-OFFICE 201 ?NO T? z a, 1 "PIS 15 AM 11: 5,5 C""SERLAND PENNSYLVANIA ` CO-, ANGINO & ROVNER, P.C. Richard A.Sadlock Attorney ID# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: rsadlockgangino-rovner.com FAITH MILLER-BOROCZ, Plaintiff V. TAYLOR DEPUE and MARK J. DEPUE, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 11-470 JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO DEFENDANTS' NEW MATTER AND NOW come the Plaintiff Faith Miller-Borocz by and through her attorneys, Angino & Rovner, P.C., and hereby replies to the New Matter of Defendants as follows: 21. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent that the averment may be deemed factual, it is hereby specifically denied. By way of amplification, at all times applicable hereto, Defendants were negligent, reckless, wanton, and careless and caused all of Plaintiff s injuries and damages as more specifically stated in Plaintiff s Complaint. Plaintiff incorporates her Complaint herein by reference. 22. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By 468155 way of amplification, all of Plaintiffs injuries and damages were caused solely and directly as a result of the negligence, carelessness, wantonness and recklessness of the instant Defendant. 23. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Defendants' conduct was in no way legally justified. Defendants were negligent, reckless, careless, and wanton at the time of the accident referred to in Plaintiff's Complaint. 24. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Plaintiff was in no way negligent, careless, or reckless. All of Plaintiff's injuries and damages were caused solely by the negligent, careless, reckless, and wanton conduct of the instant Defendants. 25. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, at the time of the accident, Plaintiff had no pre-existing condition. All of Plaintiff s injuries and damages are related to the instant action and were caused solely as a result of the negligence, carelessness, wantonness, and recklessness of the instant Defendant. 26. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, as previously indicated herein, Plaintiff was not contributorily negligent in any way. Further, all of Plaintiffs injuries and damages are recoverable in the instant action and are in no way reduced. 468155 27. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, as previously indicated herein, Plaintiff was not negligent, careless, or reckless in any way. Therefore, the Pennsylvania Comparative Negligence Act does not apply to the instant action. Further, all of Plaintiffs injuries and damages are recoverable in the instant action and are in no way reduced. 28. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, there are no affirmative defenses available to the Defendants in the instant action. Specifically, the defenses of waiver, estoppel, statute of limitations, latches, illegality, release, impossibility of performance, fraud, assumption of the risk and payment do not apply to the instant action. All of Plaintiff's injuries and damages were caused by the instant Defendants and are recoverable herein. 29. Defendants' averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, the Pennsylvania Motor Vehicle Financial Responsibility Law in no way bars or limits Plaintiff's claims herein. 30. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent that a further response may be deemed proper, it is specifically denied that Pennsylvania Rule of Civil Procedure 238 is unconstitutional and to the contrary, it is alleged that 468155 the constitutionality of Pennsylvania Rule 238 has already been affirmed. ANGIlN+?OVWR, P.C. Do. 47281 ? 450 Front Street Esquire HaMsburg, PA 17110 (717) 238-6791 rsadlock@angino-rovner.com Counsel for Plaintiff 468155 COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF DAUPHIN AFFIDAVIT I, RICHARD A. SADLOCK, ESQUIRE being duly sworn according to law, deposes and states that I am counsel for Plaintiff, that I am authorized to make this Affidavit on behalf of said Plaintiff, and the facts set forth in the foregoing Reply to New Matter, are true and correct to the best of my knowledge, information, and belief. Sworn to and subscribed before me this 14 day of r , 2011. Notary Public My Commission Expires: COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL ANGELA DAWN HORCHLER, Notary Public Susquehanna Twp., Dauphin County Commlasion Expires March 18, 2013 468155 CERTIFICATE OF SERVICE I, Michelle M. Milojevich, 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 PLAINTIFF'S REPLY TO DEFENDANTS' NEW MATTER upon all counsel of record via postage prepaid first class United States mail addressed as follows: Scott L. Grenoble, Esquire Buzgon Davis Law Offices 525 South Eighth Street P.O. Box 49 Lebanon, PA 17042-0049 Attorney for Defendants ID No: 72808 (717) 274-1421 Michelle M. Milojevich Dated: 4/14./11 468155 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY MILLER-BOROCZ Vs. DEPUE & DEPUE NO. 11470 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 rn ::-4y r _ T I -<> c? n x ® - off.' c° : C) vc _ , rT As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 SCOTT L GRENOBLE, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 04/20/11 SCOTT L GRENOBLE, ESQUIRE 525 S 8TH ST PO BOX 49 LEBANON, PA 17042 717-274-1421 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-4907 By: Jacqueline Senske MLR File #: M385673 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY MILLER-BOROCZ vs. DEPUE & DEPUE I No. 11470 TO: RICHARD SADLOCK, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 03/30/11 SCOTT L GRENOBLE, ESQUIRE 525 S 8TH ST PO BOX 49 LEBANON, PA 17042 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-4907 By: Jacqueline Senske Enc (s) : Copy of subpoena(s) Counsel return card File #: M385673 COMMONWEALTH OF PENNSYLVANIA CDUNrY OF CLD4BER1 ND MILLER-BORQCZ Vs. Fi le No. DEPUE & DEPUE 11470 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOO'VERY PURSUANT TO RULE 4009.22 ENCOMPASS INS CO, PO BOX 440457, KENNESAW GA 30160 TO: ATTN: CLAIMS DEPT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or Sk gA wrnr Tm - MEDICAL LEGAL REPRODUCTIONS, INCA 4J . , ----- (Address) You may deliver or mail legible copies of the documents or produce things requested h? this subpoena, together with the certificate of ca pliance, to the party making thi request at the address listed above. You have the right to seek in advance the rea,onablC- cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving thin subpoena may seek a court orde;- cxripe l l i ng you to camp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: SCOTT L GRENOBLE, ESQ ADDRESS: 525 S 8TH ST TER NON, PA 17042 TELEPHONE: SUPREME COURT ID # - - ATTORNEY FOR: M385673-01 DATE: Seal of the Court erk, Cfivi l Division Deputy DEFENDANT BY THE COURT : (Eff. 7/97) ADDENDUM TO SUBPOENA MILLER-BOROCZ Vs. . No. 11470 DEPUE & DEPUE CUSTODIAN OF RECORDS FOR: ENCOMPASS INS CO FIRST PARTY BENEFITS FILE. PERTAINING TO: NAME: FAITH MILLER-BOROCZ ADDRESS: 130 WHEATLAND RD DATE OF BIRTH: 01/07/91 SSAN: XXXXX2059 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or ENCOMPASS INS CO CUMBERLAND M385673-01 * * * SIGN AND RETURN THIS PAGE COMMONNEAM OF PENNSYLVANIA COU>NrY OF a NUAM MILLER-BOROCZ 'Vs . File No. 11470 DEPUE & DEPUE SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DIS00YERY PURSUANT TO RULE 4009.22 HERSHEY MED CTR, PO BOX 850, HERSHEY PA 17033 TO: ATTN: MEDICAL RECORDS DEPT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or.th?gs If I {, ?JlL: ice 'Dyi ?*?* Tw -rff1Q!L-A- Z-4 r 1tTL V l?l at MEDICAL LEGAL REPRODII tJ 4U DISSITUN ., (Address) this subpoena, may deliver or mail with copies of the documents or produce things requested by utogether with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the rea.onabl? cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required b this s (20) days after its service the by subpoena within twenty c= pelting you to Party serving this subpoena may seek a court order crnply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: SCOTT L GRENOBLE, ESQ ADDRESS: _ 525 S 8TH ST 7042 TELEPHONE: SUPREME OOMT ID # ATTORNEY FOR: M385673-02 DEFENDANT DATE : Seal of the Court BY THE OOURT : Prot Y/CI Civil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA MILLER-BOROCZ Vs. " DEPUE & DEPUE No. 11470 CUSTODIAN OF RECORDS FOR : HERSHEY MED CTR ANY AND ALL RECORDS FROM 9/8/10 TO PRESENT. PERTAINING TO: NAME: FAITH MILLER-BOROCZ ADDRESS: 130 WHEATLAND RD DATE OF BIRTH: 01/07/91 SSAN: XXXXX2059 ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Aut ori11 111 1 ze signature or HERSHEY MED CTR CUMBERLAND M385673-02 * * * SIGN AND RETURN THIS PAGE ANGINO & ROVNER, P.C. Richard A.Sadlock Attorney ID# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: rsadlock@angino-rovner.com FAITH MILLER-BOROCZ, - Plaintiff: V. TAYLOR DEPUE and MARK J. DEPUE, Defendants '_ ? ? C I?OI?OTA??' -l1 PEKNSY?VANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 11-470 JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff intends to serve a subpoena identical to the one are attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. ANG P.C. Sad , Esquire PA I .D' 47281 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 rsadlock@angino-rovner.com Counsel for Plaintiff 477678 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FAITH MILLER-BOROCZ, Plaintiffs versus : No. 11-470 TAYLOR DEPUE and MARK J. DEPUE Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: SPRINT Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: incoming and outgoing calls and text messages from 717-226-9460 for the month of July 1, 2010 to October 31, 2010 on September 20, 2011 at 10:00 a.m. at Angino & Rovner, 4503 N. Front Street, Harrisburg, PA 17110. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name: Address: Telephone: Supreme Court ID # Attorney for: Richard A. Sadlock, Esquire 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 47281 Plaintiffs BY THE COURT: Date: Seal of the Court Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE I, Michelle M. Milojevich, 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 NOTICES OF INTENT upon all counsel of record via postage prepaid first class United States mail addressed as follows: Scott L. Grenoble, Esquire Buzgon Davis Law Offices 525 South Eighth Street P.O. Box 49 Lebanon, PA 17042-0049 Attorney for Defendants ID No: 72808 (717) 274-1421 :g"'222adw- Michelle M. Milojevich Dated: F116 / 11 477678 IN THE COURT OF COMMON PLEAS OF CUMBERLAND q@UWY M cp ? i'1" ( s. iw 9 -- K..... g is. yro MILLER-BOROCZ --+c' Vs. NO. 11470 o DEPUE & DEPUE ?- CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 SCOTT L GRENOBLE, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 08/25/11 SCOTT L GRENOBLE, ESQUIRE 525 S 8TH ST PO BOX 49 LEBANON, PA 17042 717-274-1421 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-4907 By: Jacqueline Senske MLR File #: M390396 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY MILLER-BOROCZ Vs. DEPUE & DEPUE I No. 11470 TO: RICHARD SADLOCK, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 08/04/11 SCOTT L GRENOBLE, ESQUIRE 525 S 8TH ST PO BOX 49 LEBANON, PA 17042 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-4907 By: Jacqueline Senske Enc(s): Copy of subpoena(s) Counsel return card File #: M390396 OF PENNSYLVANIA TO: couNrY OF C[>1NID'gaAm MILLER-BOROCZ Vs. Fi le No. DEPUE & DEPUE 11470 SUBPOENA TO PRODUCE DOO ENT'S OR TH I NGS FOR DISOO'VERY PURSUANT TO RULE 4009.22 SHEPHERDSTOWN FAMILY PRAC, 2140 FISHER RD, MECHANCISBURG PA 17055 Name of Person or Entity Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents orS-Ek9 lT9P*efffif) imu m at MEDICAL LEGAL REPRODUCTIONS INC; 494U DISSTUR ST., . , - Pk--(Address) You may deliver or mail legible copies of the documents or produce things requested h? this subpoena, together with the certificate of compliance, to the party making thi_ request at the address listed above. You have the right to seek in advance the reasonablE- cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving thin, subpoena may seek a court orcie:- am palling you to ca, ly with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: SCOTT L GRENOBLE, ESQ ADDRESS : 525 S 8TH ST T FRANnI` f PA 17042 TELEPHONE: 2t5-335 32±2 SUPREME COURT 1D # ATTORNEY FOR: M390396-01 DEI-eENDANT A _ DATE: If X11 I Seal of a Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA MILLER-BOROCZ Vs. DEPUE & DEPUE No. 11470 CUSTODIAN OF RECORDS FOR: SHEPHERDSTOWN FAMILY PRAC ANY AND ALL RECORDS FROM 9/8/10 TO PRESENT PERTAINING TO: NAME: FAITH MILLER-BOROCZ ADDRESS: 130 WHEATLAND RD DATE OF BIRTH: 01/07/91 SSAN: XXXXX2059 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or SHEPHERDSTOWN FAMILY PRAC CUMBERLAND M390396-01 * * * SIGN AND RETURN THIS PAGE * * * FAITH MILLER-BOROCZ, Plaintiff V. TAYLOR DEPUE and MARK J. DEPUE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 11-470 CIVIL TERM IN RE: PLAINTIFF'S MOTION FOR A STATUS CONFERENCE ORDER OF COURT AND NOW, this 24 h day of January, 2012, upon consideration of Plaintiffs Motion for a Status Conference, the motion is granted and a status conference is scheduled for Friday, the 2°d day of March, 2012, at 9:30 a.m., in chambers of the undersigned judge, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, ? Richard A. Sadlock, Esq. 4503 North Front Street Harrisburg, PA 17110-1708 Attorney for Plaintiff Scott L. Grenoble, Esq. 525 South Eighth Street P.O. Box 49 Lebanon, PA 17042-0049 Attorney for Defendants :rc ter, °, rKli . l Pty S??/ Christylee L Peck, J. rn U7 ? N ui t ; A- ? ? '' _ _ L 1 i r t Cz t 70 ANGINO & ROVNER, P.C. Richard A.Sadlock Attorney 1D# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: rsadloc!k@angino-rovner.com FAITH MILLER-BOROCZ, Plaintiff V. TAYLOR DEPUE and MARK J. DEPUE, Defendants TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 11-470 JURY TRIAL DEMANDED PRAECIPE Please mark the above-captioned action as settled, satisfied, and discontinued. ANGINO & ichard A. Sadl gtkn'e PA I. . No. 47281 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 rsadlock@angino-rovner.com Counsel for Plaintiff 500207 4 . 1. CERTIFICATE OF SERVICE I, Michelle M. Milojevich, 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 PRAECIPE upon all counsel of record via postage prepaid first class United States mail addressed as follows: Scott L. Grenoble, Esquire Buzgon Davis Law Offices 525 South Eighth Street P.O. Box 49 Lebanon, PA 17042-0049 (717) 274-1421 ichelle M. Milojevich Dated: 31 I ?- 500207