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HomeMy WebLinkAbout12-1366 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REGINA YENTZER 40 Bushey School Road York Springs, PA 17372, Plaintiff, Case No.: 2 - 36 6 (41y1 L v.rl^ CIVIL ACTION DIANE WATTS 159 South West Street Carlisle, PA 17013, Defendant. c PRAECIPE FOR WRIT OF SUMMONS rnco a == cow'' -r, TO THE PROTHONOTARY OF SAID COURT: -<> ! ti) r:F- Please issue a Writ of Summons in the above-referenced matter. Respectfully submitted, ?- MOONEY & ASSOCIATES ?' - Date: X)o By: Mark A. Buterbaugh, Esquire 2 South Hanover Street Carlisle, Pennsylvania 17013 Telephone: (717) 632-4656 extension 402 Attorney I.D. 4306967 ?i Attorney for Plaintiff 11rJ SUMMONS IN CIVIL ACTION DIANE WATTS AKA DIANE HILL, DIANE HILL-WATTS 159 SOUTH WEST STREET CARLISLE, PA 17013 ? a6 7y R?A 7/ 7 7 ? YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST __7? onotary Date:.?/ & Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson R1L.FD--F FICE Sheriff ELF T NOTARY Jody S Smith ?:Ilmte,"rj _ gar Ems, -, Chief Deputy tL-12I R 28 AM 83' Richard W Stewart r Solicitor r uuMBEF<i_,A;?L) (JU1,iT!, Regina Yentzer vs. Diane Watts Case Number 2012-1366 SHERIFF'S RETURN OF SERVICE 03/21/2012 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: Diane Watts, but was unable to locate her in his bailiwick. He therefore returns the within Writ of Summons as not found as to the defendant Diane Watts. Request for service at 159 S. West Street, Carlisle, Pennsylvania 17013 the Defendant was not found. The Carlisle Postmaster has confirmed, Diane Watts new address is 550 N. Railroad Street, Palmyra, Pennsylvania 17078. SHERIFF COST: $39.45 March 21, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF .,oun?yswto ieieoertt. rec. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REGINA YENTZER 40 Bushey School Road York Springs, PA 17372, Plaintiff, Case No.: 2012-1366 ; i V. ?- CIVIL ACTION DIANE WATTS :< - 159 South West Street Carlisle, PA 17013, Defendant. PRAECIPE TO REISSUE TO THE PROTHONOTARY OF SAID COURT: Please reissue the attached Praecipe for Writ of Summons. Respectfully submitted, MOONEY & ASSOCIA S Date: 15-? Z By: Mark A. Buterbaugh, Esquire Attorney for Plaintiff Attorney I.D. #306967 2 South Hanover Street Carlisle, Pennsylvania 17013 Telephone: (717) 632-4656 extension 402 -75,111 c?a q? 2-?a 73 73 -1-- "Supreme Co Y' nnsylvania Coin' pkoinI>41?0 leas For Prothonotary Use Only: C 1}Y, t Docket No: Cu rland' r4 County Z The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by lain or rules of court. S E C T O N A Commencement of Action: © Complaint 1@ Writ of Summons Petition 0 Transfer from Another Jurisdiction Declaration of Taking Lead Plaintiff's Name: Lead Defendant's Name: Regina Yentzer Diane Watts Are money damages requested? 0 Yes [l No Dollar Amount Requested: within arbitration limits (check one) ©x outside arbitration limits Is this a Class Action Suit? [:] Yes El No Is this an MDJAppeal? Yes El No Name of Plaintiff/Appellant's Attorney: Mark A. Buterbaugh, Esquire 11 Check here if you have no attorney (are a Self-Represented (Pro Sel Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. S E C T I O N B TORT (do not include Mass Tort) Intentional Malicious Prosecution Motor Vehicle Nuisance Ox Premises Liability Product Liability (does not include mass tort) El Slander/Libel/ Defamation Other: CONTRACT (do not include Judgments) Buyer Plaintiff 0 Debt Collection: Credit Card Debt Collection: Other Employment Dispute: Discrimination Employment Dispute: Other Other: REAL PROPERTY Q Ejectment Eminent Domain/Condemnation El Ground Rent Q Landlord/Tenant Dispute Q Mortgage Foreclosure: Residential Mortgage Foreclosure: Commercial Partition Quiet Title Other: CIVIL APPEALS Administrative Agencies Board of Assessment Board of Elections Dept. of Transportation Statutory Appeal: Other Q Zoning Board Q Other: MISCELLANEOUS Q Common Law/Statutory Arbitration ? Declaratory Judgment Mandamus Non-Domestic Relations Restraining Order ® Quo Warranto 0 Replevin Other: Updated 1/1/2011 L NOTICE Pennsylvania Rule of Civil Procedure 205.5. (Cover Sheet) provides, in part: Rule 205.5. Cover Sheet (a)(1) This rule shall apply to all actions governed by the rules of civil procedure except the following: (i) actions pursuant to the Protection from Abuse Act, Rules 1901 et seq. (ii) actions for support, Rules 1910.1 et seq. (iii) actions for custody, partial custody and visitation of minor children, Rules 1915.1 et seq. (iv) actions for divorce or annulment of marriage, Rules 1920.1 et seq. (v) actions in domestic relations generally, including paternity actions, Rules 1930.1 et seq. (vi) voluntary mediation in custody actions, Rules 1940.1 et seq. (2) At the commencement of any action, the party initiating the action shall complete the cover sheet set forth in subdivision (e) and file it with the prothonotary. (b) The prothonotary shall not accept a filing commencing an action without a completed cover sheet. (c) The prothonotary shall assist a party appearing pro se in the completion of the form. (d) A judicial district which has implemented an electronic filing system pursuant to Rule 205.4 and has promulgated those procedures pursuant to Rule 239.9 shall be exempt from the provisions of this rule. (e) The Court Administrator of Pennsylvania, in conjunction with the Cavil Procedural Rules Committee, shall design and publish the cover sheet. The latest version of the form shall be published on the website of the Administrative Office of Pennsylvania Courts at www.pacourts.us. L+-.?eJm1 (>,i aJ1 Fir A{F 1j rl.-,+,J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REGINA YENTZER 40 Bushey School Road York Springs, PA 17372, Plaintiff, V. DIANE WATTS 159 South West Street Carlisle, PA 17013, Defendant. Case No.: l2 - 136 CIVIL ACTION PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Writ of Summons in the above-referenced matter f'1 N O ?3 ra rn zo cn ? ? <a zQ ? x, c o Respectfully submitted, r MOONEY & ASSOCIATES A f Date: By: t Mark A. Buterbaugh, Esquire 2 South Hanover Street TRUE COPY FROM RECORD Carlisle, Pennsylvania 17013 In Testimony whereof, I here unto set my hand Telephone: (717) 632-4656 extension 402 and the $e 1 of said C at Carlisle, Pa. This 7 day of /G , 20 /Z Attorney I.D. #306967 Prothonotary Attorney for Plaintiff UMMONS IN CIVIL ACTION DIANE WATTS AKA DIANE HILL, DIANE HILL-WATTS 159 SOUTH WEST STREET CARLISLE, PA 17013 m? =C.) C) I _i. YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST Date: 3 I Z Deputy T ST ED G? PR NOTARY SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ?wir'?'•'' ?t ??wa?ir?f???b -Cir r "'?HAY -8 AM 9:,5,3 Richard W Stewart Solicitor UM8E PENNSYLVANIA Regina Yentzer vs. Diane Watts SHERIFF'S RETURN OF SERVICE Case Number 2012-1366 04/12/2012 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: Diane Watts, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Lebanon County, Pennsylvania to serve the within Writ of Summons according to law. 04/27/2012 Lebanon County Return: And now, April 27, 2012 I, Michael J. DeLeo, Sheriff of Lebanon County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Diane Watts the defendant named in the within Writ of Summons and that I am unable to find her in the County of Lebanon and therefore return same NOT FOUND. Request for service at 400 S. Eighth Street, Room 3 Municipal Building, Lebanon, Pennsylvania 17042 the Defendant was not found. SHERIFF COST: $37.00 SO ANSWERS, May 04, 2012 RON R ANDERSON, SHERIFF is Goon-YSuwt Sher:-t. Te!ec;sofl 'u," REINSTATED WRIT OF SUMMONS No. 2012-1366 Regina Yentzer Mooney & Associates Mark Buterbaugh, Esquire 2 South Hanover Street Carlisle, PA 17013 (717) 632-4656 vs. Diane Watts Return to (Cumberland County) General File No. 12-01225 STATE OF PENNSYLVANIA ; COUNTY OF LEBANON ; SS: Kirk Juliani, Deputy Sheriff, being duly sworn according to law, deposes and says that after due and diligent search by him having been made in his bailiwick, and after having exhausted all known facets to locate DEFENDANT, as stipulated under Rule of Civil Procedure, Rule 430, "good faith effort," he was unable to find Diane Watts, the within named DEFENDANT, and he therefore returns "NOT FOUND," as to the said Diane Watts. Note: The Defendant has never lived at the Given Address Sworn to and subscribed before me This 27t" day of April, 2012 d ??_ Notary Public SO ANSWERS, do DEPUTY SHERIFF By Authorization Of: (-'0MM0 i WEAL:i l OF PENNSYLVANIA F-°--N-0TA' 1AL SEAL LDesi,-,e?,- A. T `son, Notary Public y of Lebavon, Lebanon County commission expirc) December 04, 2013 SHERIFF SHERIFF'S COSTS IN ABOVE PROCEEDINGS Advanced Costs paid on 4/13/2012 Check No. 2959 Amount $ 150.00 Costs Incurred: Amount $ 86.97 Amount of Refund: Check No??b9a6?,? mount $ 63.03 All Sheriffs Costs shall be due and payable when services are performed.. and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any party liable for the costs thereof, all unpaid sheriffs fees on the same before he shall be obligated by law to make return thereof. Sec. 2, Act of June 20, 1911, P.L. 1072 ? t F.\FILES\Clients\3050 Donegal\3050.Current\3050.690\3050.690.pral Revised: 7/23/12 8.18AM yy r 1?.. ..'J J1fl Daniel K. Deardorff, Esquire HE -IRO ("???, 0 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 2012 JUL 23 AM 8: 54 I.D. 17837 10 East High Street CUMBERLNO COU.Nf T Y Carlisle, PA 17013 PENNSYLVANIA (717) 243-3341 Attorneys for Defendant REGINA YENTZER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVAN V. NO. 12-1366 CIVIL ACTION - LAW DIANE WATTS, Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON LAW OFFICES on behalf ofthe Defendant in the matter. Issue a rule upon the Plaintiff to file a Complaint within twenty (20) days from thereof or suffer judgment of non pros. MARTSON LAW OFFICES Dated: July 23, 2012 By 1,t ?L-,&?l Daniel K. Deardorff, Esqui Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant RULE AND NOW, thiso23 day of , 2012, a Rule is issued upon the Plaintiff to a Complaint within twenty (20) days flVorn rvice hereof. JOLVIA 8??11 Prothonotary lL "*t ? c7k4w CERTIFICATE OF SERVICE I, Ami J. Thumma, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Praecipe and Rule were served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Mark A. Buterbaugh, Esquire MOONEY & ASSOCIATES 2 South Hanover Street Carlisle, PA 17013 MARTSON LAW OFFICES By t i`C1 Ami J. Th a 10 East High Street Carlisle, PA 17013 (717) 243-3341 Dated: July 23, 2012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY REGINA YENTZER Vs. NO. 121366 DIANE WATTS C) CERTIFICATE --u rn PREREQUISITE TO SERVICE OF A SUBPOENA c?-s PURSUANT TO RULE 4009.22 n .?co ?• c?-*? v r3 ? ? c? As a prerequisite to service of a subpoena(s) for documents 4fi tNing pursuant to Rule 4009: 2-DANIEL-K DEARDORFF, ESQUIRE certifies1 h aco: 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: 12/10/12 r DANIEL K DEARDORFF, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 717-243-3341 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215}_:335-3336 By: Ruby Schwartzberg MLR File #: M405961 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY REGINA YENTZER Vs. DIANE WATTS No. 121366 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: 11/15/12 DANIEL K DEARDORFF, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 By: Ruby Schwartzberg Enc(s): Copy of subpoena(s) Counsel return card File #: M405961 i :?irH r)r at_d!CVT ANT?: COUNTY OF CUMBERIAND REGINA YENTZER Vs. File No. 121366 DIANE WATTS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 TO: GLESSWEIN PLASTIC SURG, 5 BROOKWOOD AVE STE 1, CARLISLE PA 17015 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documnts or th-at MEDICAL LEGAL REPRODUCTIONS (A&#%§s t940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested t? this subpoena, together with the certificate of ccmipliance, to the party making thi: request at the address listed above. You have the right to seek in advance the rea.onablE 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 f20) days after its service, the party serving thin subpoena may seek a court orde;- cxxrpe I l i ng you to camp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DANIEL K DEARDORFF, ESQ ADDRESS: _ in g HTag ST elft:RLISLE, PA 17013 TELEPHONE: 215-335-3212 SUPREME COURT ID ## ATTORNEY FOR: DEFENDANT M405961-01 DATE : ?, \ lk IcD_ Seal of the Court BY THE COURT: 1) C?_V ; d ?), l? _ Prothonotary/Clerk, Civil Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA REGINA YENTZER Vs. No. 121366 DIANE WATTS CUSTODIAN OF RECORDS FOR: GLESSWEIN PLASTIC SURG ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: REGINA YENTZER ADDRESS: 40 BUSHEY SCH RD YORK SPRINGS PA DATE OF BIRTH: 10/18/59 SSAN: XXXXX6548 TO INCLUDE ANY AND ALL :PICTURES 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 GLESSWEIN PLASTIC SURG CUMBERLAND M405961-01 * * * SIGN AND RETURN THIS PAGE * * * A F TILES\Clients\3050 Donegal\3050 Current\3050.690\3050, 690.ansl Revised. 12/14/12 933AM (-y C , r1rj Daniel K. Deardorff Esquire Cn , MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER rte- ' co CD MARTSON LAW OFFICES D I 17837 ?, . . 10 East High Street >C tra Carlisle, PA 17013 (717) 243-3341 - Attorneys for Defendant REGINA YENTZER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-1366 CIVIL ACTION - LAW DIANE WATTS, Defendant : JURY TRIAL DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER TO PLAINTIFF'S COMPLAINT TO: Regina Yentzer, Plaintiff, and her attorney, Mark A. Buterbaugh, Esquire YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. AND NOW comes Defendant, Diane Watts, by and through her attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and hereby responds to Plaintiff's Complaint as follows: Admitted based on information received. 2. Admitted. 3-10. Denied. These averments are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. Proof thereof is demanded. COUNTI REGINA LEHMAN YENTZER V. DIANE WATTS NEGLIGENCE 11. Defendant incorporates by reference herein all the answers set forth in paragraphs 1 through 10 of this answer. 12-14. Denied. These averments are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. Proof thereof is demanded. COUNT II REGINA LEHMAN YENTZER V. DIANE WATTS VIOLATION OF 3 P.S. § 459-305 NEGLIGENCE PER SE 15. Defendant incorporates by reference herein all the answers set forth in paragraphs lthrough 14 of this answer. 16-18. Denied. These averments are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. Proof thereof is demanded. COUNT II REGINA LEHMAN YENTZER V. DIANE WATTS VIOLATION OF 3 P.S. § 459-305 NEGLIGENCE PER SE 19. Defendant incorporates by reference herein all the answers set forth in paragraphs lthrough 18 of this answer. 20-22. Denied. These averments are denied pursuant to Rule 1029(e) of the Pennsylvania Rules of Civil Procedure. Proof thereof is demanded. WHEREFORE, Defendant demands judgment in her favor against the Plaintiff. NEW MATTER 23. All affirmative defenses set forth in Rule 1030 of the Pennsylvania Rules of Civil Procedure are incorporated herein by reference. 24. Defendant's dog, which was involved in the alleged incident set forth in Plaintiff's Complaint had never bitten anyone before or acted vicious toward anyone before. 25. Immediately before the alleged incident set forth in Plaintiff's Complaint, Plaintiff had called the Defendant and asked the Defendant to come over to her house to console her regarding a personal matter of Plaintiff's. 26. Defendant advised the Plaintiff that her dog had been alone in the house all day and she did not want to leave the dog alone that evening, but Plaintiff told the Defendant to bring her dog along during the visit. 27. After Defendant arrived at Plaintiff's residence, the dog went over to the Plaintiff and the Plaintiff started petting the dog. 28. The dog then put his paws on the Plaintiff's shoulder and then the dog unexpectedly and suddenly snapped at the Plaintiff and bit her. 29. At no time did the Plaintiff ever object to the dog being near her, and instead, the Plaintiff allowed the dog to be close to her. 30. By her actions as stated above, Plaintiff was comparatively negligent in causing the incident referred to in her Complaint. 31. By her actions as stated above, Plaintiff knowingly and voluntarily assumed the risk of injury. 32. Under the facts set forth above, Defendant did not violate the provisions set forth in 3 P.S. §459-305. WHEREFORE, the Defendant demands judgment in her favor against the Plaintiff. MARTSON LAW OFFICES Daniel K. Deardorff, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: 1 171 12' Attorneys for Defendant VERIFICATION The foregoing Answers with New Matter is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal CERTIFICATE OF SERVICE I, Ami J. Thumma, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Answer with New Matter was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Mark A. Buterbaugh, Esquire MOONEY & ASSOCIATES 67 North Main Street Chambersburg, PA 17201 MARTS LAW Of By J. Th a 10 East Hi tree Carlisle, PA 17013 (717) 243-3341 Dated: i ? 113 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REGINA YENTZER, NO. 2012-1366 Plaintiff, V. CIVIL ACTION - LAW DIANE WATTS, C-3 Defendant. C= a PRAECIPE TO DISCONTINUE AND END --s -r <> C.0 C TO THE PROTHONOTARY: '!" C-f CD c=; Kindly mark the above-captioned case settled, discontinued and ended. €:_ Respectfully submitted, MOON Y &R I By:llw�6 Mark A. Buterbaugh, Esquire Attorney for Plaintiff I.D. # 306967 2 South Hanover Street Carlisle, PA, 17013 (717) 243-4770 2013 NAY 13 P11 2; CUMBERLAND UjUj44Ty PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA REGINA YENTZER, NO. 2012-1366 Plaintiff, VS. CIVIL ACTION -LAW DIANE WATTS, Defendant. ACTION IN CIVIL CERTIFICATE OF SERVICE I,Mark A. Buterbaugh,Esquire, attorney for the above Plaintiff,hereby certify that on this day of ,2013,I have forwarded a copy of the Praecipe to Discontinue and End, in the above-captioned action to the following individual(s) by regular U.S. Mail as set forth below: Daniel K Deardorff, Esquire Martson Deardorff Ten East High Street Carlisle, PA 17013 Respectfully submitted, MOONEY & ASSOCIATES By: /* /;z E&� Mark A. Buterbaugh, Esquire Attorney for Plaintiff I.D. 9 306967 2 South Hanover Street Carlisle,PA, 17013 (717)243-4770