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Home My WebLink About12-1923 FELICIA BEAVER, Lrr2 IN THE COURT OF COMMON PLEA CUMBERLAND COUNTY, PENNSYLVANKE'Li ") +-e'z CIVIL ACTION-LAW Plaintiff NO. dD l a-) 9 a3 e(-VO VS COMPULSORY ARBITRATION CHRISTINA L. BARR, Defendant NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by 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, 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. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 C-9) avk%Io Ck-4 16n-) ao? 124 'Q -) Q'*? "';? 2 AVISO LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mds adelante en las siguientes pdginas, 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 mds aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED 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. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA FELICIA BEAVER, Plaintiff CHRISTINA L. BARR, Defendant CIVIL ACTION-LAW NO. VS COMPULSORY ARBITRATION COMPLAINT AND NOW, this „,l`?l day of -MARCH-, 2012, comes the Plaintiff, Felicia Beaver, by and through her attorney, Joseph J. Dixon, Esquire, who respectfully avers as follows: 1. The Plaintiff, Felicia Beaver, is an adult individual who resides at 215 Center Street, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant, Christina L. Barr, is an adult individual who resides at 502 Bridge Street, Apartment A, New Cumberland, Cumberland County, Pennsylvania 17070. 3. On February 17, 2010, at approximately 6:30 P.M., the Defendant, Christina L. Barr, was driving a 2007 Toyota motor vehicle, exiting a parking lot on Shady Lane in Enola, Cumberland County, Pennsylvania. 4. At said time and place, the Plaintiff, Felicia Beaver, was a passenger in a 2010 Ford motor vehicle operated by Gregg N. Gunn. 5. The motor vehicle operated by Gregg N. Gunn was traveling westbound on Shady Lane. 6. At said time and place, the motor vehicle operated by the Defendant, Christina L. Barr, pulled into Shady Lane causing a collision with the motor vehicle operated by Gregg N. Gunn. 7. Said collision was due to the negligence and carelessness of the Defendant, Christina L. Barr, which consists of the following: a. Failure to wait until traffic clears before entering a through street. b. Failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway. c. Failure to travel at a safe speed. d. Failure to apply her brakes in sufficient time to avoid striking another motor vehicle. e. Failure to keep proper watch for traffic on the highway. f. Failure to take reasonable evasive action to avoid an accident. g. Failure to drive a motor vehicle with due regard for highway and traffic conditions which were existing and of which she was or should have been aware. h. Failure to keep proper and adequate control of her vehicle. 8. As a result of the accident described herein, the Plaintiff, Felicia Beaver, suffered severe personal injuries. These injuries include, but are not limited to, laceration of the chin, internal pocket in mouth, dislocation of jaw requiring extraction of four molars to realign the jaw, 2 cm linear scar of the mid chin, I cm angular scar of the left chin, and post traumatic lipomas. 9. As a result of the injuries sustained as described herein, the Plaintiff, Felicia Beaver, has suffered in the past and will continue to suffer scarring, lumping, discoloration, internal scarring of the mouth, as well as great pain and suffering, 10. As a result of the injuries sustained as described herein, the Plaintiff, Felicia Beaver, has had to incur medical expenses, the total amount of these expenses is unascertained at this time. The Plaintiff believes, and therefore avers, that in the future she will incur additional medical expenses. 11. As a result of the scarring and injuries sustained by the Plaintiff, the Plaintiff has undergone great psychological pain because the disfigurement is permanent in nature. WHEREFORE, the Plaintiff prays this Honorable Court enter judgment against the Defendant in an amount not to exceed Fifty Thousand Dollars ($50,000.00), an amount requiring compulsory arbitration. Respectfully Submitted, By: Jos ph J. Dixon, Esquire Attorney No. 28290 126 State Street Harrisburg, PA 17101 (717) 235-8515 Date: March ??? , 2012 Attorney for the Plaintiff VERIFICATION i:L /yj rte'?'?tj,?''7` I verify that the statements made in this are true and correct. I understand that false statements herein are made subject to the penalty of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: CERTIFICATE OF SERVICE AND NOW,this -26th day of March , 2012, I, Joseph J. Dixon, Esquire, hereby certify that I have served a true and correct copy of the foregoing Complaint this day by depositing the same in the United States Mail, first class, postage prepaid, in the Post Office at Harrisburg, Pennsylvania, addressed to: Erie Insurance Group 4901 Louise Drive Rossmoyne Business Center P.O. Box 2013 Mechanicsburg, PA 17055-0710 Attention: A.J. Abramczyk Liability Adjustor The Law Office of Joseph J. Dixon, Esquire FBy: JOSEPH J. DIXON, ESQUIRE ATTORNEY ID #28290 126 STATE STREET HARRISBURG, PA 17101 (717) 233-8757 ATTORNEY FOR PLAINTIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart cc Solicitor - "' r Felicia Beaver vs. C p Number..; Christina L. Barr 2012-1923 SHERIFF'S RETURN OF SERVICE 04/09/2012 05:35 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on April 9, 2012 at 1735 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Christina L. Barr, by making known unto herself personally, at 502 Bridge Street, Apartment A, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. W SHA IT75 SHERIFF COST: $45.45 April 12, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF JOHNSON, DUFFIE, STEWART & WEIDNER By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jjs@jdsw.com FELICIA BEAVER, V. Plaintiff CHRISTINA L. BARR, Defendant rrlq t=R,j _,^ Attorneys for Defendant ...;1* 2E xLAN`.D COUP { `:` PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2012-1923 Civil CIVIL ACTION - LAW COMPULSORY ARBITRATION PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the undersigned on behalf of the Defendant in the above-captioned matter. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By: eff n J. Ship an, Esquire Attorney I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Date: June, 2012 Counsel for Defendant, Christina L. Barr 499110 Y CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Praecipe for Entry of Appearance has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on June ?- , 2012: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 JOHNSON, DUFFIE, STEWART & WEIDNER J 46J. Shipm n JOHNSON, DUFFIE, STEWART & WEIDNER By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jjs@jdsw.com Attorneys for Defendant FELICIA BEAVER, V. Plaintiff CHRISTINA L. BARR, Defendant NO. 2012-1923 Civil CIVIL ACTION - LAW COMPULSORY ARBITRATION NOTICE TO PLEAD TO: Felicia Beaver c/o Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 AND NOW, this 26 day of June, 2012, you are hereby notified to plead responsively within twenty (20) days of the date of service hereof, or judgment may be entered against you. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHNSON, DUFFIE, STEWART & WEIDNER ,4Aftorneys r n J. Ship an for Defendant JOHNSON, DUFFIE, STEWART & WEIDNER By: Jefferson J. Shipman I. D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jjs@jdsw.com FELICIA BEAVER, V. Plaintiff CHRISTINA L. BARR, Defendant Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2012-1923 Civil : CIVIL ACTION - LAW COMPULSORY ARBITRATION ANSWER AND NEW MATTER OF DEFENDANT, CHRISTINA L. BARR, TO PLAINTIFF'S COMPLAINT AND NOW, comes the Defendant, Christina L. Barr, by and through her counsel, Jefferson J. Shipman and Johnson, Duffie, Stewart & Weidner, and files the following Answer and New Matter to Plaintiff's Complaint: 1. Admitted upon information and belief. 2. Admitted. 3. Admitted. 4. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 4, and the same are therefore denied. 5. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 5, and the same are therefore denied. 6. Admitted in part, denied in part. It is admitted only that Ms. Barr pulled onto Shady Lane. The remaining averments of paragraph 6 are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained herein are specifically denied. 7. Denied. The averments contained in paragraph 7 and subparagraphs (a) through (h) are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. (a) Denied. It is specifically denied that Ms. Barr was negligent in allegedly failing to wait until traffic cleared; (b) Denied. It is specifically denied that Ms. Barr failed to keep alert and maintain a proper watch for other vehicles; (c) Denied. It is specifically denied that Ms. Barr failed to travel at a safe speed; (d) Denied. It is specifically denied that Ms. Barr failed to apply her brakes in sufficient time; (e) Denied. It is specifically denied that Ms. Barr failed to keep proper watch for traffic; (f) Denied. It is specifically denied that Ms. Barr failed to take reasonable and evasive action; (g) Denied. It is specifically denied that Ms. Barr failed to drive the motor vehicle with due regard for the highway and traffic conditions; (h) Denied. It is specifically denied that Ms. Barr failed to keep proper and adequate control of her vehicle. 8. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 8, and the same are therefore denied, and strict proof is demanded at the time of trial. 9. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 9, and the same are therefore denied, and strict proof is demanded at the time of trial. 10. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 10, and the same are therefore denied, and strict proof is demanded at the time of trial. 11. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 11, and the same are therefore denied, and strict proof is demanded at the time of trial. WHEREFORE, the Defendant, Christina Barr, respectfully requests that judgment be entered in her favor and that Plaintiffs Complaint be dismissed with prejudice. NEW MATTER 12. That Plaintiffs alleged cause of action may be barred by the Pennsylvania Financial Responsibility Law. 13. That Plaintiffs alleged cause of action may have been caused by third parties or entities not presently involved in this action. 14. That Plaintiffs alleged cause of action may have been caused by a dangerous condition of the roadway. 15. That if it should be found that there was any negligence on the part of Ms. Barr, which is denied, then in that event, any such negligence was not a factual cause of the accident nor Plaintiffs alleged injuries. 16. That Plaintiff may have failed to mitigate her alleged injuries. 17. That Plaintiff's cause of action may be barred by the Pennsylvania Comparative Negligence Act and the Plaintiffs assumption of the risk. 18. That Plaintiffs alleged cause of action may be barred by the statute of limitations. WHEREFORE, the Defendant, Christina Barr, respectfully requests that judgment be entered in her favor and that Plaintiffs Complaint be dismissed with prejudice. Date: June , 2012 499374 Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER J ffers J. 06ipma(h, Esquire Attorney I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Counsel for Defendant, Christina L. Barr VERIFICATION The undersigned verifies that the facts set forth in the foregoing document are true and correct to the best of her knowledge, information and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsifications to authorities. GbriOna L. Barr Dated: 06'l7 - i,-? :499383 CERTIFICATE OF SERVICE 1 hereby certify that a copy of the foregoing Answer and New Matter of Defendant to Plaintiff's Complaint has been duly served upon the following counsel of record, by depositing the same in the United States First Class Mail, postage prepaid, in Lemoyne, Pennsylvania, on June, 2012: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 JOHNSON, DUFFIE, STEWART & WEIDNER J rson J. Shipman cF I'Hc F,R0TH GPI(o) TA, R)' 2012 JUN 29 PM 2: G 4 A4 IN THE COURT OF COMMON PLEAS CUM &I COUNTY .'NSYLVANIA CUMBERLAND COUNTY, PENNSYLVANIA P FELICIA BEAVER, Plaintiff CHRISTINA L. BARR, Defendant CIVIL ACTION-LAW NO. 2012-1923 Civil vs COMPULSORY ARBITRATION REPLY TO NEW MATTER AND NOW, this .y day of 2012, comes the Plaintiff, Felicia Beaver, by and through her attorney, Joseph J. Dixon, Esquire, who respectfully responds to New Matter as follows: 12. Denied. Said averment is a conclusion of law which requires no response. To the extent, however, that a response is required, the Plaintiff's cause of action is not barred by the Pennsylvania Financial Responsibility Law. 13. Denied. Said averment is a conclusion of law which requires no response. To the extent, however, that a response is required, the Defendant, Christina L. Ban-, caused the motor vehicle accident. • 14. Denied. After reasonable investigation, the Plaintiff, Felicia Beaver, is unable to determine that there was any dangerous condition on the road on the roadway. 15. Denied. Said averment is a conclusion of law which requires no response. By way of further additional answer, however, the negligence of the Defendant caused the injuries to the Plaintiff. 16. Denied. Said averment is a conclusion of law which requires no response. To the extent, however, that a response is required, the Plaintiff took all possible steps to seek treatment for her injuries. 17. Denied. Said averment is a conclusion of law which requires no response. By way of further additional answer, the Plaintiff was a passenger in a motor vehicle that was struck and is not negligent in any matter, nor did she assume a risk. 18. Denied. Said averment is a conclusion of law which requires no response. To the extent, however, that a response is required, the Plaintiff's action conformed with the statute of limitations. WHEREFORE, the Plaintiff prays this Honorable Court enter judgment against the Defendant in an amount not to exceed Fifty Thousand Dollars ($50,000.00), an amount requiring compulsory arbitration. By: r° Date: 2012 Respectfully Submitted, Joseph J. Dixon, Esquire Attorney No. 28290 126 State Street Harrisburg, PA 17101 (717) 235-8515 Attorney for the Plaintiff VERIFICATION I verify that the statemenis made in this are true and correct. I understand that false statements herein are made subject to the penalty of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: CERTIFICATE OF SERVICE J ._r AND NOW, this day of 2012, I, Joseph J. Dixon, Esquire, hereby certify that I have served a true and correct copy of the foregoing Reply To New Matter, this day by depositing the same in the United States Mail, first class, postage prepaid, in the Post Office at Harrisburg, Pennsylvania, addressed to: Law Offices Johnson Duffie 301 Market Street, P.O. Box 109 Lemoyne, PA 17043-0109 Attention: Jefferson J. Shipman, Esquire The Law Office of Joseph J. Dixon, Esquire By: J EPH J. IXON, ESQUIRE ATTORNEY ID 428290 126 STATE STREET HARRISBURG, PA 17101 (717) 233-8757 ATTORNEY FOR PLAINTIFF I- t . FiCE i 2012 OCT 15 PM 3:09 JOHNSON, DUFFIE, STEWART & WEICR"BEf AND COUNTY By: Jefferson J. Shipman PENNSYLVANIA I . D. No. 51785 By: Matthew Ridley I.D. No. 204265 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 MR@jdsw.com FELICIA BEAVER, V. Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2012-1923 Civil CIVIL ACTION - LAW COMPULSORY ARBITRATION CHRISTINA L. BARR, Defendant PRAECIPE TO SUBSTITUTE APPEARANCE TO THE PROTHONOTARY: Please substitute the appearance of Matthew Ridley, Esquire of Johnson, Duffle, Stewart & Weidner for Jefferson J. Shipman, Esquire, as counsel on behalf of the Defendant in the above-captioned matter. Date: October 2012 519521 Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By: /1L /__? Matthew Ridley, Esquire Attorney I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Counsel for Defendant, Christina L. Barr ' i • CERTIFICATE OF SERVICE I hereby :certify that a copy of the foregoing Praecipe to Substitute Appearance has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on October J2 , 2012: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 JOHNSON, DUFFLE, STEWART & WEIDNER By. 1"L r1 Matthew Ridley #`cif°fi0 ; ,� 1'AUG 27 Pdi !. 54, JOHNSON, DUFFIE, STEWART&WEIDNER CUMBERLAND COUN y Attorneys for Defendant By: Matthew Ridley PENNSYLVANIA I.D. No. 204265 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 mr @jdsw.com FELICIA BEAVER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2012-1923 Civil CHRISTINA L. BARR, CIVIL ACTION — LAW Defendant COMPULSORY ARBITRATION MOTION FOR DISCOVERY CONFERENCE AND NOW, comes Defendant, Christina L. Barr, by and through her attorneys, Johnson, Duffie, Stewart & Weidner, P.C., and Matthew Ridley, Esquire, and files the following Motion for Discovery Conference and hereby avers as follows: 1. This case involves a two vehicle accident that occurred on February 17, 2010, in Enola, Cumberland County, Pennsylvania. 2. As a result of the accident, the Plaintiff filed a civil Complaint sounding in negligence and alleging physical injuries, including scarring. 3. This matter was arbitrated on December 5, 2012, and the Defendant filed a Notice of Appeal on December 14, 2012. 4. The Defendant desires a Status Conference in order to set deadlines for discovery and expert reports, etc. 5. Defense counsel sought the concurrence of Plaintiffs counsel regarding a Proposed Case Management Order, but has received no response. (See the letter of 7/10/2013 and 8/7/2013, attached as Exhibit A.) 6. No judge has ruled upon any issue in this case. WHEREFORE, the Defendant respectfully requests this Honorable Court enter an Order scheduling a status conference. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By: Matthew Ridley, Esquire Attorney I.D. No. 204265 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Date: August ZG, 2013 Counsel for Defendant, Christina L. Barr 576859 EXHIBIT A JERRY R.DUFFIE - " BARRIE B.GEHRLEIN FUCHARD W. STEWART ANTHONY T.LUCIDO EDMUND G.MYERS L A W O F F I C E S ELIZABETH D.SNOVER DAVID W.DELUGE OHNSON CAROLYN B.MCCLAIN JOHN A.STATLER JOHN A.LUCY JEFFREY B.RETTIG ULYSSES S.WILSON MARK C.DUFFIE DUFFIE JULIA A.PHILLIPS JOHN R.NINOSKY MATTHEW RIDLEY MICHAEL J.CASSIDY MELISSA P.GREEVY OF COUNSEL WADE D.MANLEY HORACE A.JOHNSON C.ROY WEIDNER;JR. At July 10, 2013 Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 Re: Felicia Beaver v. Christina L. Barr Cumberland County, C.C.P.; No. 2012-1923 Civil Dear Mr. Dixon: Enclosed please find a proposed Case Management Order, which sets forth deadlines for the completion of discovery, etc. Please notify me at your earliest convenience whether you agree with my proposed timeframe. In the event that we are unable to agree upon a schedule for disposition of this matter, I intend to file for a status conference with the Court. Please feel free to contact me should you wish to discuss this matter. Thank you. Very truly yours, JOHNSON, DUFFIE, STEWART & WEIDNER Matt Ridley M R/bam:568363 022740-2965 301 MARKET STREET P.O.BOX 109 LEMOYNE,PENNSYLVANIA 17043-0109 VMV.JDSW.COM 717.761.4540 FAX:717.761.3015 MAIL @JDSW.COM JOHNSON, DUFFIE, STEWART & WEIDNER, P.C. JERRY R.DUFFIE ! ELIZABETH D.SNOVER RICHARD W.STEWART EDMUND G.MYERS LAW OFFICES CAROLYN B.MCCLAIN DAVID W.DELUGE JOHN A.LUCY JOHN A.B.RET I ON ULYSSES S.WILSON JEFFREY B.RETTIG JULIA A.PHILLIPS MARK C.DUFFIE FFIE MATTHEW RIDLEY JOHN R.NINOSKY BARRIE B.GEHRLEIN MICHAEL J. CASSIDY OF COUNSEL MELISSA P.GREEVY HORACE A.JOHNSON WADE D.MANLEY C.ROY WEIDNER,JR. CONSTANCE P.BRUNT WaT'rTnt,'-'1',x,'.'N>>. I.it; August 7, 2013 Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 Re: Felicia Beaver v. Christina L. Barr Cumberland County, C.C.P.; No. 2012-1923 Civil Dear Mr. Dixon: have not heard from you regarding the proposed Case Management Order that I forwarded to your office with my Letter of July 10, 2013. Please contact me at your earliest convenience to discuss the same. Should I not hear from you by the close of business on August 21, 2013, 1 intend to file a Motion for Status Conference with the Court. look forward to speaking with you. Thank you. Very truly yours, JOHNSON, DUFFIE, STEWART & WEIDNER Matt Ridley MR/men:573466 022740-2965 301 MARKET STREET P.O.BOX 109 LEMOYNE,PENNSYLVANIA 17043-0109 WWW.JDSW.COM 717.761.4540 FAX:717.761.3015 MAILQJDSW.COM _ JOHNSON, DUFFIE, STEWART & WEIDNER, P.C. CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Defendant's Motion for Status Conference has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on August 16, 2013: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 JOHNSON, DUFFIE, STEWART & WEIDNER By: '/1 -"� ' Matthew Ridley F ILED-_fl{FFICi- 0,11: THE 1 R T 13ON TAR`,( 2013 AUG 29 PM 2: 34 CUMBERLAND CONA i Y FELICIA BEAVER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2012-1923 Civil CHRISTINA L. BARR, CIVIL ACTION — LAW Defendant COMPULSORY ARBITRATION ORDER AND NOW, this o19 day of ± 2013, a Status Conference is hereby scheduled to take place on the o�Z0 day of D�J 201 , at //:67) A.M.AP-W. at the Cumberland County Courthouse in j OL- BY THE COURT: Judge Distribution: Joseph J. Dixon, Esquire, 126 State Street, Harrisburg, PA 17101; Ph: 717-233-8757, fax 717-233-5860; dixonlaw @paonline.com Matthew Ridley, Esquire, Johnson, Duffie, Stewart& Weidner, P.C.; 301 Market Street, P.O. Box 109, Lemoyne, PA 17043; 717-761-4540, fax 717-761-3015; mr @jdsw.com � 3 FELICIA BEAVER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION—LAW NO. 12-1923 CIVIL CHRISTINA L. BARR, : Defendant ORDER AND NOW, this day of September, 2013, at the request of counsel for the parties, the status conference in the above matter set for September 20, 2013, is continued to Thursday, October 10, 2013, at 9:30 a.m. in Chambers of the undersigned. BY THE COURT, Kevin . Hess, P. J. -/ Joseph Dixon, Esquire For the Plaintiff Matthew Ridley, Esquire For the Defendant :rlm �S M11-71 lcc� X13 1 rQ rr-t _Ml sv , F "1'or E..P Rfl T 1O O l A 2033 OCT 22 PFi 0 19 CUMBERLAND COUNTY PENNSYLVANIA FELICIA BEAVER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA Plaintiff NO. 12-1923 CIVIL VS. CIVIL ACTION - LAW CHRISTINA L. BARR, COMPULSORY ARBITRATION Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END Please mark the above-captioned case settled, discontinued and ended. Respectfully submitted, By: Joseph J. Dixon, Esquire Attorney No. 28290 126 State Street Harrisburg, PA 17101 (717) 236-8515 Attorney for Plaintiff Date: �� CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Praecipe to Settle, Discontinue and End has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on October 21, 2013: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 JOHNSON, DUFFIE, STEWART &WEIDNER By: Mich le E. Neff, Legal S c Qt ry to Matthew Ridley, Esquire 587022