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HomeMy WebLinkAbout11-0666SAMIRA OSOJKIC, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA V. ab l 1- T?6IO No . KAREN M. WOLF, C_ _4 Defendant CIVIL ACTION - LAW -per ?? rv Q a " PRAECIPE FOR WRIT OF SUMMONS © a ? c. d Z ' TO THE PROTHONOTARY OF SAID COURT: p,.G •- Please issue a Writ of Summons in the above-captioned action against the following Defendant: Karen M. Wolf 1629 Airport Drive Mechanicsburg, PA 17050 Writ of Summons shall be issued and forwarded to - Attorney X Joanne Harrison Clough squire 3 820 Market Street Camp Hill, PA 17011 Telephone (717) 737-5890 Supreme Court ID. No. 36461 Date: ' 2pr ZOk I Attorney for Plaintiffs WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S) aasga.tp Zak C" silo t YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED A CIVIL ACTION AGAINST YOU. i -D(-11 By: Date Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor _+ r40 v:?1 SHERIFF'S OFFICE OF CUMBERLAND COUNT' = rte . Di ?- 00 rU C-n ,1V 0 iUt!??p C ?: .. 3 C' ?1SY ?'7a { _ Samira Osojik vs. Karen M. Wolf Case Number 2011-666 SHERIFF'S RETURN OF SERVICE 02/22/2011 12:20 PM - Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on February 22, 2011 at 1220 hours, he was unable to serve a true copy of the within Writ of Summons, upon the within named defendant, to wit: Karen M. Wolf. After several attempts the tenants of 1629 Airport Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 will not answer the door. SHERIFF COST: $55.44 February 22, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF you jt r 2011 AFR -4 AM 11: 19 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SAMIRA OSOJKIC, Plaintiff, NO. 2011-666 v. PRAECIPE FOR APPEARANCE KAREN M. WOLF, (Jury Trial Demanded) Defendant. Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #18515 k IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAMIRA OSOJKIC, CIVIL DIVISION Plaintiff, V. NO. 2011-666 KAREN M. WOLF, (Jury Trial Demanded) Defendant. PRAECIPE FOR APPEARANCE TO: THE PROTHONOTARY Kindly enter the Appearance of the undersigned, Kevin D. Rauch, Esquire, of the law firm of Summers, McDonnell, Hudock, Guthrie & Skeel, P.C., on behalf of the Defendant, Karen M. Wolf, in the above case. JURY TRIAL DEMANDED Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE &AKE R.C. By: in D. Rauch, Esquire nsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR APPEARANCE has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 1St day of April, 2011. Joanne Harrison Clough, Esquire 3820 Market Street Camp Hill, PA 17011 (Attorney for Plaintiff) SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: ' a ch, Esquire Co sel for Defendant 1011 APP,-4 041!l:{9 'UMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION SAMIRA OSOJKIC, Plaintiff, NO. 2011-666 V. PRAECIPE FOR RULE TO FILE COMPLAINT KAREN M. WOLF, Defendant. (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #18515 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAMIRA OSOJKIC, Plaintiff, V. KAREN M. WOLF, Defendant. CIVIL DIVISION NO. 2011-666 (Jury Trial Demanded) PRAECIPE FOR RULE TO FILE COMPLAINT TO: The Prothonotary Kindly rule the Plaintiff, Samira Osojkic, to file a Complaint in Civil Action within twenty (20) days. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE &,SKEEL, P.I;. By: iR D. Rbuch, Esquire nsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR RULE TO FILE COMPLAINT has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 1St day of April, 2011. Joanne Harrison Clough, Esquire 3820 Market Street Camp Hill, PA 17011 (Attorney for Plaintiff) SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKFEEL, P.C. By: ri B-Rauc'h, Esquire nsel for Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAMIRA OSOJKIC, CIVIL DIVISION Plaintiff, V. NO. 2011-666 KAREN M. WOLF, (Jury Trial Demanded) Defendant. RULE AND NOW, this -, day of aDyt ( 2011, upon consideration of Defendant's Praecipe for Rule to File a Complaint, a Rule is hereby granted upon Plaintiff to file a Complaint within twenty (20) days of service, or suffer judgment Non Pros. Rule issued this _? day of nr; , 2011. FILED-OFFI" OF THE PR0TH0S ?,) ., 2011 APP 21 PM 1: C:; CUMBERLAND C`W*17?.;_ PENNS (D/AI,g'A SAMIRA OSOJKIC, Plaintiff V. KAREN M. WOLF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2011-666 : (Jury Trial Demanded) NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following complaint, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 JOANNE HARRISON CLOUGH, PC BY: JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 3820 Market Street Camp Hill, PA 17011 Telephone: (717) 737-5890 Attorney for Plaintiff SAMIRA OSOJKIC, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2011-666 KAREN M. WOLF, Defendant (Jury Trial Demanded) COMPLAINT AND NOW, this 21St day of April, 2011, comes Plaintiff Samira Osojkic, by and through her attorney Joanne Harrison Clough, Esquire, and respectfully files this Complaint and in support thereof avers as follows: Plaintiff Samira Osojkic, is an adult individual currently residing at 12 Clover Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050. Plaintiff resided at said address at all times related herein. 2. Defendant Karen M. Wolf, is an adult individual last known to be residing at 1629 Airport Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 It is believed Defendant resided at said location at all times related herein. On January 31, 2009, at approximately 2:20 p.m. Plaintiff Samira Osojkic was a passenger in a vehicle operated by her Father, Sabrija Osojkic. At said place and time Plaintiff's Father was driving a 2007 Nissan Frontier in an easterly direction on Route 11 herein after referred to as "Carlisle Pike". 4. As Plaintiff's Father traveled in an easterly direction of the Carlisle Pike he traveled in to the right hand turn lane of the Carlisle Pike. 5. At said place and time Defendant was operating a 2003 Honda CRV in a westerly direction on the Carlisle Pike. 6. As Plaintiff s Father proceeded past the entrance way to Just Cabinets/Ollies stores, Defendant suddenly and without warning made a left hand turn across the east bound lanes of traffic, violently striking in to the driver's side of the Plaintiff's Father's vehicle. 7. The force of the impact of Defendant's vehicle smashing in to Plaintiff's Father's vehicle caused Plaintiff's body to be severely jarred and jostled and she struck her head and her knee against the inside of the passenger side of the vehicle. 8. At said place and time immediately proceeding impact, Plaintiff was properly restrained in a shoulder harness seatbelt and suffered injuries as a result of being jarred from impact and restrained by the seatbelt. 9. At all times related herein Plaintiff's Father was exercising due care, caution and diligence operating his motor vehicle in an easterly direction on the Carlisle Pike. 10. At all times related herein Plaintiff's father was maintaining a proper look out and was safely operating his automobile in accordance with the laws of the Commonwealth of Pennsylvania. 11. The January 31, 2009 accident and all of the damages resulting therefrom and set forth below were the direct and proximate result of the negligence, carelessness, and recklessness of Defendant in the manner in which she was operating her automobile as follows: a. Failing to yield to oncoming traffic; b. Improperly executing a left turn in to the direct path of oncoming traffic; c. Failing to observe the traffic laws of the Commonwealth of Pennsylvania; d. Failing to keep and maintain a proper look out or other vehicles using the roads and highways; e. Failing to safely execute a left hand turn across several lanes of oncoming traffic; f. Failing to use due care and caution; g. Failing to operate her vehicle at a safe speed while executing a turn; h. Failing to apply her brakes to avoid striking Plaintiff's father's vehicle; i. Failing to drive at a speed and in such a manner as to be able to bring her vehicle to a stop within the assured clear distance ahead; j. Negligently and carelessly relying upon another driver waving or other signaling for her to execute a left turn directly in to the side of Plaintiff's father's vehicle; and k. Otherwise failing to use appropriate due care and caution in the operation of her vehicle and in operating her vehicle in a careless, reckless and negligent manner with careless disregard to the rights and safety of others. 12. As a direct result of the negligence of Defendant as set forth here above, Plaintiff suffered significant and serious bodily injuries as follows: a. Injury to the right side of Plaintiff head; b. Concussion; c. Soft tissue injuries to her back; d. Chronic low back pain; e. Contusion to right knee and soft tissue injury to knee; f. Soft tissue injury to right shoulder area; g. Injury to lower right leg; h. Pain and suffering; i. Bouts of vomiting following head injury and concussion; j. Severe repetitive migrane headaches; k.. Contusions; and 1. Other painful injuries. 13. As a result of the injuries suffered in this accident Plaintiff was initially treated at Holy Spirit Hospital Emergency Room on February 1, 2009, and subsequently received additional medical and physical therapy treatment. 14. All of the afore listed injuries suffered by Plaintiff in the accident would not have occurred but for the negligence of Defendant causing the accident. 15. As a direct and proximate result of the negligence of Defendant and the injuries suffered by Plaintiff, Plaintiff has suffered damages as follows: a Medical expenses; b. Loss earnings; c. Intermittent loss of enjoyment of life's pleasures; d. Continued impairment from soft tissue injuries; and e. Pain and suffering; and f. Other damages. 16. As a direct result of the injuries suffered by Plaintiff as set forth above, Plaintiff is of the belief and therefore avers that she will in the future continue to incur damages as follows: a. Medical expenses; b. Continued suffering from soft tissue injuries; c. Intermittent restriction in future activities; d. Continued intermittent need for medical treatment and physical therapy; e. Continued intermittent pain and suffering. 17. As a result of the injuries Plaintiff suffered on January 31, 2009, Plaintiff is at times unable to enjoy life and its pleasures. WHEREFORE, Plaintiff Samira Osojkic respectfully requests this Honorable Court enter a Judgment after a trail by jury against the Defendant Karen M. Wolf in an amount in excess of the compulsory arbitration award limits and grant any further relief this Court deems dust. Respectfully submitted, JOANNE HARRISON CLOUGH, PC Date: 1 Joanne Harrison C gh, Esquire Attorney ID No.: 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Samira Osojkic VERIFICATION I, Samira Osojkic hereby verify and state that the facts set forth in the foregoing pleading are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn verification to authorities. DATE: `1 I 0 / 1 1Samira Osojkic CERTIFICATE OF SERVICE I, Joanne Harrison Clough, Esquire, do hereby certify that on this date l: served a copy of the foregoing document by First Class United States Mail the following individual set forth below: Defendant Karen M. Wolf C/O Kevin D. Rauch, Esquire Attorney for Defendant Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, Pa 17050 Date: 2 1 Joanne Harrison Clough, Attorney ID No. 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff FILED-OFFICE TH FliO + C.TAR` 1011`x} 26 PM 1 12:i7 CU115ERLANID COUNTV 4 SY?.4'A'N'1A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PLAINTIFF, SAMIRA OSOJKIC NO. 2011-666 12 Clover Lane Mechanicsburg, PA 17050 PRAECIPE FOR WRIT TO JOIN ADDITIONAL DEFENDANT V. (Jury Trial Demanded) DEFENDANT, KAREN M. WOLF 1629 Airport Drive Mechanicsburg, PA 17050 Filed on Behalf of the Defendant Counsel of Record for This Party: V. Kevin D. Rauch, Esquire ADDITIONAL DEFENDANT, Pa. I.D. #83058 SABRIJA OSOJKIC, 12 Clover Lane SUMMERS, McDONNELL, HUDOCK, Mechanicsburg, PA 17050 GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #18515 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, CIVIL DIVISION SAMIRA OSOJKIC 12 Clover Lane Mechanicsburg, PA 17050 NO. 2011-666 V. DEFENDANT, KAREN M. WOLF 1629 Airport Drive Mechanicsburg, PA 17050 V. ADDITIONAL DEFENDANT, SABRIJA OSOJKIC, 12 Clover Lane Mechanicsburg, PA 17050 (Jury Trial Demanded) PRAECIPE FOR WRIT TO JOIN ADDITIONAL DEFENDANT TO THE PROTHONOTARY: Kindly issue a Writ of Summons joining the following Additional Defendant: Sabirja Osojkic, 12 Clover Lane, Mechanicsburg, PA 17050. JURY TRIAL DEMANDED Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: AaevinD. u ch, Esquire Counsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Praecipe for Writ to Join Additional Defendant has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 24rd day of May, 2011. Joanne Harrison Clough, Esquire 3820 Market Street Camp Hill, PA 17011 (Attorney for Plaintiff) SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. I By: ? ga?( Kevin . Rauch, Esquire Counsel for Defendant WRIT TO JOIN ADDITIONAL DEFENDANT Cumberland County, ss: The Commonwealth of Pennsylvania to Sabirja Osojkic at 12 Clover Lane, Mechanicsburg, PA 17050 You are notified that Karen M. Wolf has joined you as an additional defendant in this action, which you are required to defend. Date: 5/26/11 6" David D. Buell, Prothonotary By: 1-61 A A r?(Jj Deputy (Seal) No. 11-666 Civil Term Samira Osojkic vs Karen M. Wolf Defendant Sabrija Osojkic Additional Defendant WRIT TO JOINED AN ADDITIONAL DEFENDANT Kevin D. Rauch, Esquire Summers, McDonnell, Hudock, Guthrie and Skeel, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 717-901-5916 Attorney for Defendant SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson - c Sheriff tF!LL0 -U l- i i CE 00, ni 4tt r?Grtl, 1 ! 3 {IwYt ??Id; Jody S Smith Chief Deputy 2Pj I I JUN 15 AM 9* Richard W Stewart Solicitor aff CUMBERLNO CGJ i , PENH§YLV NIA Samira Osojkio Case Number vs. Karen M. Wolf (et al.) 2011-666 SHERIFF'S RETURN OF SERVICE 06/10/2011 07:33 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 10, 2011 at 1933 hours, he served a true copy of the within Writ to Join Additional Defendant, upon the within named defendant, to wit: Sabirja Osojkic, by making known unto Jasmin Osojkic, Son of Defendant at 12 Clover Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at th same time handing to him personally the said true and correct copy of the same. I AEL BAR ICK, DEPUTY SHERIFF COST: $38.00 June 14, 2011 SO ANSWERS, RON ~ R ANDERSON, SHERIFF rqi CouniyS,j to Shear. le,oo-,ofl, If%;. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAMIRA OSOJKIC, Plaintiff, CIVIL DIVISION NO. 2011-666 V. KAREN M. WOLF, Defendant, V. SABRIJA OSOJKIC, Additional Defendant. TO: Plaintiff and Additional Defendant You are hereby notified to file a written response to the enclosed Complaint to Join Additional Defendant within twenty (20) days from se ice hereof or a judgment may bntpregr?nainsVkou. Sum e"cDojnell, Hudock, Guth tie & Skeel, P.C. COMPLAINT TO JOIN ADDITIOPJAL , DEFENDANT C- cza rnn C m -'..r (Jury Trial Demanded) r ?M < O CD = >c Filed on Behalf of the Defendants r Karen M. Wolf 70 Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #18515 NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim 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 LAWYER REFERRAL SERVICEDAUPHIN COUNTY 32 S. Bedford Street Carlisle, PA 17013 Telephone Number: 717-249-3166 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las pagina siguientes, usted tiene viente (20) dias do plazo al partir de la fecha de la demanda y la notification. Usted debe presenter una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defenses o sus objeciones a las demandas en contra de sus persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puded entar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero os sus propiedades o otros derechos importantes para usted. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAMIRA OSOJKIC, Plaintiff, V. KAREN M. WOLF, Defendant, V. SABRIJA OSOJKIC, Additional Defendant. CIVIL DIVISION NO. 2011-666 (Jury Trial Demanded) COMPLAINT TO JOIN ADDITIONAL DEFENDANT SABRIJA OSOJKIC AND NOW, comes the Defendant, Karen M. Wolf, by and through her counsel, Summers, McDonnell, Hudock, Guthrie & Skeel, P.C., and Kevin D. Rauch, Esquire, and files the following Complaint to Join Additional Defendant, Sabrija Osojkic, and in support thereof avers as follows: PARTIES 1. The Plaintiff, Samira Osojkic (hereinafter "Plaintiff'), is an adult individual currently residing at 12 Clover Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. The Defendant, Karen M. Wolf (hereinafter "Defendant"), is an adult individual currently residing at 1629 Airport Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050. I The Additional Defendant, Sabrija Osojkic (hereinafter "Additional Defendant"), is an adult individual currently residing at 12 Clover Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050. PROCEDURAL HISTORY 4. On April 21, 2011, the Plaintiff filed a Complaint in Cumberland County, Pennsylvania. (A true and correct copy of Plaintiff's Complaint is attached hereto as Exhibit "A",) 5. On May 12, 2011, the Defendant filed an Answer and New Matter. (A true and correct copy of Defendant's Answer and New Matter is attached hereto as Exhibit «B.'.) 6. On May 24, 2011, the Defendant filed a Writ to Join an Additional Defendant. (A true and correct copy of Defendant's Writ to Join Additional Defendant is attached hereto as Exhibit "C".) FACTS 7. On January 31, 2009, at approximately 2:20 p.m., the Defendant was operating her vehicle westbound on the Carlisle Pike, and after being waived across by vehicle operators in the two eastbound lanes of travel on the Carlisle Pike, made a left hand turn across the eastbound lanes. 8. On the above-stated date and time, the Plaintiff's vehicle, driven by Additional Defendant, Sabrija Osojkic, was traveling in the right turn lane heading east on the Carlisle Pike. 9. On the above-stated date and time, as a result of the negligent operation of the Plaintiff's vehicle, a collision occurred between the vehicle driven by the Defendant, and that driven by Additional Defendant. COUNTI NEGLIGENCE 10. The allegations set forth in paragraphs 1 through 9 are incorporated by reference as if fully set for the at length herein. 11. If the Plaintiff sustained injuries and damages, as alleged in the Plaintiff's Complaint, which is not admitted by Defendant, then it is believed and therefore averred that said injuries and damages are the direct and proximate result of the carelessness, negligence, and recklessness of Additional Defendant, generally and in the following particulars: a. In failing to keep his motor vehicle under proper control; b. In failing to keep alert and maintain a reasonable lookout; C. In operating his motor vehicle in careless disregard for the safety of others; d. Failing to exercise due care and caution; and e. In failing to operate his motor vehicle at a speed and in such a manner as to be able to bring his vehicle to a stop within the assured clear distance ahead. 12. If the Plaintiff sustained injuries and damages, as alleged in the Plaintiffs Complaint, which is not admitted by Defendant, then it is averred that Additional Defendant is solely liable to the Plaintiff, or is liable over to this Defendant for contribution and/or indemnity. WHEREFORE, Defendant, Karen M. Wolf, joins Additional Defendant, Sabrija Osojkic, as being solely liable to the Plaintiff or liable over to this Defendant, Karen M. Wolf, for full contribution and/or indemnification on any and all sums recoverable under the causes action asserted in the Plaintiff's Complaint. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: , evin . Rauch, Esquire Counsel for Defendant, Karen M. Wolf VERIFICATION Defendant verifies that she is the Defendant in the foregoing action; that the foregoing COMPLAINT TO JOIN ADDITIONAL DEFENDANT is based upon information which she has furnished to her counsel and information which has been gathered by her counsel in the preparation of the lawsuit. The language of the COMPLAINT TO JOIN ADDITIONAL DEFENDANT is that of counsel and not of the Defendant. Defendant has read the COMPLAINT TO JOIN ADDITIONAL DEFENDANT and to the extent that the COMPLAINT TO JOIN ADDITIONAL DEFENDANT is based upon information which she has given to her counsel, it is true and correct to the best of her knowledge, information and belief. To the extent that the content of the COMPLAINT TO JOIN ADDITIONAL DEFENDANT is that of counsel, she has relied upon counsel in making this Affidavit. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: 401 Karen M. Wolf #18515 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing COMPLAINT TO JOIN ADDITIONAL DEFENDANT has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 8th day of July, 2011. Joanne Harrison Clough, Esquire 3820 Market Street Camp Hill, PA 17011 (Attorney for Plaintiff) Sabrija Osojkic 12 Clover Lane Mechanicsburg, PA 17050 SUMMERS, McDONNELL, HUDOCK, GUTHRIE &,SKEEL, P.C. By: evin D. Rouch, esquire ounsel for Defendant, Karen M. Wolf OWENS BARCAVAGE & MCINROY, L.L.C. By: Bart W. Holmes, Esquire PA ID No.: 85071 2595 Interstate Drive Harrisburg, PA 17110 717-909-2500 717-909-2504(fax) SAMIRA OSOJKIC, Plaintiff V. KAREN WOLF, Defendant V. SABRIJA OSOJKIC, Additional Defendant ONOTA" 011 AUG 10 PPS 1: 16 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 2011-666 JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE Dear Prothonotary: Kindly enter the appearance of Owens Barcavage & McInroy, LLC, and Bart W. Holmes, Esquire, on behalf of additional defendant Sabrija Osojkic. Thank you. O S BARCAVAGE & MCINROY, L.L.C. Date: August 8, 2011 - k4' ? I By: Bart W. Holmes, squire PA ID No.: 85071 2595 Interstate Drive Harrisburg, PA 17110 717-909-2500 717-909-2504 (fax) CERTIFICATE OF SERVICE I, Bart W. Holmes, Esquire, certify under penalty of unsworn falsification to governing authorities that I have served a true and correct copy of the foregoing, by United States Mail, pre-paid, at: Joanne Harrison Clough, P.C. Attn: Joanne Harrison Clough, Esquire 3820 Market Street Camp Hill, PA 17011 Julia Phillips, Esquire Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. 100 Sterling Parkway, Ste. 306 Mechanicsburg, PA 17050 OW NS BARCAVAGE & MCINROY, L.L.C. Date: August 8, 2011 By: Bart W. Holmes, squire PA ID No.: 85071 2595 Interstate Drive Harrisburg, PA 17110 717-909-2500 717-909-2504 (fax) SAMIRA OSOJKIC, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, : PENNSYLVANIA V. : NO.: 2011-666 KAREN WOLF, : JURY TRIAL DEMANDED = .? Defendant r r SABRIJA OSOJKIC, Additional Defendant =-' S? PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the Answer with New Matter of Additional Defendant Sabrija Osojkic in the above referenced matter. DATE: 1 OWENS BARCAVAGE AND MCINROY, LLC. L BY: B W. Holmes, E uire I.D. No. 85071 2595 Interstate Drive Harrisburg, PA 17110 (717) 909-2500 CERTIFICATE OF SERVICE AND NOW, this a? day of October, 2011, I, Bart W. Holmes, Esquire, a member of the firm of Owens Barcavage & McInroy, LLC, hereby certify that I have this date served a copy of the foregoing document pursuant to Pa.R.C.P. 1012, by United States Mail, postage prepaid, addressed to the party or attorney of record as follows: Joanne Harrison Clough, P.C. Attn: Joanne Harrison Clough, Esquire 3820 Market Street Camp Hill, PA 17011 Julia Phillips, Esquire Summers, McDonnell, et al 100 Sterling Parkway, Ste 306 Mechanicsburg, PA 17050 J ? Bart W. Holmes, squit VERIFICATION I, Sabrija Osojkic, hereby state and aver that I have read the foregoing document which has been drafted by my counsel. The factual statements contained therein are true and correct to the best of my knowledge, information and belief although the language is that of my counsel, and, to the extent that the content of the foregoing document is that of counsel, I have relied upon counsel in making this Verification. This statement is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. rija Osojkic 02/08!2012 11:05 171792091._ >9 SUMMERSMCDONNEU_ °AGE 21lK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAMIRA OSOJKIC, Plaintiff, V. KAREN M. WOLF, Defendant, CIVIL DIVISION NO. 2011-666 (Jury Trial Demanded) c a ? CD V. SABRIJA OSOJKIC, Additional Defendant. PRAECIPE TO SETTLE DISCONTINUE AND END TO: THE PROTHONOTARY Please mark the above-referenced case settled and discontinued, with prejudice. Respectfully submitted, By: Joanne Harrison U( Counsel for Plaintiff