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Home My WebLink About12-3266 Jodi L. Guise IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Helen K. Horton No 20 12 Defendant Civil Term 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 AN ATTORNEY AND FILLING 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 JUDGEMENT 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 PEOPERTY 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 THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 S ??} 1?1fl3.75 dad a ??. ???so I-4-9 -7 SO IPS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JODI L. GUISE Plaintiff V. HELEN K. HORTON Defendant NO: CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT 1. The Plaintiff, Jodi L. Guise, is an adult individual with a current mailing address of P. O. Box 188, Gardners, Pennsylvania 17324. 2. The Defendant, Helen K. Horton, is an adult individual residing at 24C Guardhouse Lane, Carlisle, Pennsylvania 17013. 3. On July 5, 2010, Plaintiff Jodi L. Guise was the operator of a 1997 Ford F-250 bearing Pennsylvania license plate YGK4100 which was owned by and used with the permission of Robert E. Guise. 4. On July 5, 2010, the Defendant Helen K. Horton, was the operator of a 2006 Volvo XC70 bearing Pennsylvania license plate GMD3161. 5. On July 5, 2010 at approximately 1:42 p.m., Plaintiff's vehicle was southbound P, C, on SR34 approaching its intersection with Pine Grove Road in Dickinson Township, I loae. oF?'x vn sr?. •+x ?. ??a...'s Cumberland County, and was intending to proceed straight through the intersection which is not I controlled by any traffic control device for motorists proceeding on SR34. 6. At that same time and place, the Defendant was operating her vehicle eastbound on Pine Grove Road at its intersection with SR34 when she failed to stop for a lawfully posted stop sign and entered the intersection causing a collision with Plaintiff's vehicle which resulted in injuries and damages to the Plaintiff. 7. This accident occurred as a result of the negligence of the Defendant and was due !, in no manner to any act, or failure to act, on the part of the Plaintiff. 8. This matter is alleged to exceed the applicable limits of arbitration, and a jury trial is hereby demanded. 9. The negligence of the Defendant consisted of the following: a. Failing to properly operate and control her motor vehicle; b. Failing to keep alert and maintain a proper lookout for the presence of other motor vehicles on the streets and highways; C. Operating her vehicle in careless disregard for the safety of others and the Plaintiff in particular in violation of 75 Pa.C.S. §3714; d. Failing to stop for a stop sign in violation of 75 Pa.C.S.§3323 (b); e. Failing to yield the right-of-way to Plaintiff's vehicle in violation of 75 Pa. C.S. §3323(b); and f. Failing to observe the presence of Plaintiff's vehicle when the Defendant knew or should have known of the presence of Plaintiff's vehicle. 10. As a result of the negligence of the Defendant, the Plaintiff suffered serious and permanent injuries including but not limited to, bilateral knee injury, cervical injury, dislocated left little finger, headaches, and a severe shock to her nerves and nervous system. 11. As a result of the negligence of the Defendant, the Plaintiff was forced to incur medical bills and expenses for the injuries she has suffered, and she will, or may, continue to DALH E. ANSTI_ N. P. C. gJxgs T incur medical expenses in the future. 2 12. As a result of the negligence of the Defendant, the Plaintiff has suffered, or may suffer, a severe loss of her earnings and impairment of her earning capacity. This loss of income and impairment of earning capacity will, or may, continue in the future. 13. As a result of the negligence of the Defendant, the Plaintiff has undergone, and in the future may undergo, great mental and physical pain and suffering, mental anguish and humiliation, loss of life's pleasures, and a severe limitation in her pursuit of daily activities, all to her great loss and detriment. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter judgment against the Defendant in an amount in excess of the mandatory arbitration limits. RESPECTFULLY SUBMITTED: LAW OFFICES OF DALE E. ANSTINE, P.C. Gr%?dy E. Martin, Esquire A tt6mey I.D. 938894 Two West Market Street P.O. Box 952 York, Pennsylvania 17405 (717) 846 - 0606 3 VERIFICATION I HEREBY VERIFY that the information set forth in the foregoing Complaint is true and correct to the best of my knowledge, information and belief. I understand that any false statements contained herein are subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: 5-023-107 c'':. - Jody L. Guise I).1LP ?i.?c?XHTISN. Via. Q?- Y'oaa, 0 IA, t ., "' 1 'M b '4' 7 ?''EM'gSYL%?-, j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JODI L. GUISE Plaintiff V HELEN K. HORTON Defendant : NO: 12-3266 : CIVIL ACTION - LAW PRAECIPE TO REINSTATE COMPLAINT DAI.io $^A11-CES 01 H9 TIMID. P. C. Yom, P. ae mu I- To the Prothonotary: David Buell PLEASE REINSTATE THE ABOVE-CAPTIONED COMPLAINT. G Dated: June 19, 2012 iry E. Martin, Esquire (I.D. 38894) ey for the Plaintiff Q? S? a s? Ck-* w°l59 21, a?-)oa? SHERIFF'S OFFICE OF CUMBERLAND COUNTY I Ronny R Anderson " UFTIf Sheriff Jody S Smith ?{ J[?L ! ^ 01 Chief Deputy _ Richard W Stewart ;I Solicitor Jodi L. Guise Case Number vs. 2012-3266 . Helen K. Horton SHERIFF'S RETURN OF SERVICE 06/25/2012 On this date Ronny R. Anderson, Sheriff mailed the within Complaint and Notice by certified mail, returk receipt requested to Helen K. Horton. t se 07!05/2012 Ronny R. Anderson, Sheriff, named who debeing duly fendant to according KnHorton, but was unablerto Idocateih enn hisz rch and inquiry for the within bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Helen K. Horton found. Request date The Carl sle Postmaster has been unable to provide la good forwarding address not fou for the Defendant. 07/06/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he served the within i Complaint and Notice upon the within named defendant, Helen K. Horton, in the following manner: O June 26, 2012 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of he within Complaint and Notice to the defendant's last known address of 20 Brunacini Road, Sandia Park, New Mexico 87047. The certified mail return receipt card was received by the Cumberland County Sheriffs Office signed by Helen K. Horton on June 26, 2012. SHERIFF COST: $61.20 SO ANSWERS, (Z"a RON R ANDERSON, SHERIF July 11, 2012 a Agent Www d 8 dso compiete red' e ¦ Comp1 the revers MP v on item 4 R 26: ¦ so hat we can the WOW the madpiece? ¦ Attach this ?f space P' or on the iron to: t Article Add Helen K. cis ad 20 Bruna 87047 Sandia Park, NM Docket 4t 2012"3266 t4umbef ic (T 2. (-rransler from 20? Nary PS Form 3811. Feb X C. to Delive Pr ted Naq?e) (G `CZ g. Received b ?t- 17 kA- L rd? ? Nc I D. Is delNerY to dke dress below It YES. -b 3 ice Type 13 Express Mail hendise '?14. erttfled Mail Recum Receipt for M ego E] C.O.D. nsured 14111 ra Fee) stricted Delivery Q O6 a 810 102595 02 M 1540 -mastic Return Receipt Do Lbi- THE PR'0TI 0N0TAR` 20I3 111 24 PH I i 02 CI.IMBERLANID COUNTY PENNSYLVANIA Thomas,Thomas&Hafer,LLP Todd B.Narvol,Esquire (717)237-7133—direct Attorney I.D.No.42136 tnarvol @tthlaw.com Marc A.Moyer,Esquire (717)441-3960—direct Attorney I.D.No. 76434 mmoyer @tthlaw.com 305 N.Front Street (717)237-7105—fax P.O.Box 999 Attorneys for Defendant Harrisburg,PA 17108-0999 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JODI L. GUISE, Plaintiff NO. 12-3266 Civil 2012 V. JURY TRIAL DEMANDED HELEN K. HORTON, Defendant CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22,,� - - - As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve a Subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party on or about July 16, 2013 to serve a subpoena upon Paychex. 2. A true and correct file copy of the Notice of Intent, including a copy of the proposed subpoena, is attached to this Certificate. 3. The twenty (20) day notice period for filing and serving objections has been waived by counsel for Plaintiff, as evidenced by the attached correspondence. 4. The subpoena which will be served is identical to the subpoena attached to the Notice of Intent. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP by: arc A. Moyer, Esqui e Attorney I.D. No.: 76434 Todd B. Narvol, Esquire Attorney I.D. No.: 42136 305 North Front Street, 6th Floor Post Office Box 999 Harrisburg, PA 17108 717-441-3960 mmoyer @tthlaw.com Attorneys for Defendant 1 " J Thomas,Thomas&Hafer,LLP Todd B.Narvol,Esquire (717)237-7133—direct Attorney I.D.No.42136 tnarvol@tthlaw.com Marc A.Moyer,Esquire (717)441-3960—direct Attorney I.D.No.76434 mmoyer@tthlaw.com 305 N.Front Street (717)237-7105—fax P.O.Box 999 Attorneys for Defendant Harrisburg,PA 17108-0999 Helen K.Horton JODI L. GUISE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-3266 Civil 2012 HELEN K. HORTON, Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO ISSUE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Counsel Defendant intends to serve a subpoena upon Paychex, identical to the one 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 will be served. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP Date: July 16, 2013 MARC A. MOYER, 1WQUIRi JODI L. GUISE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-3266 Civil 2012 HELEN K. HORTON, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Paychex,2405 Park Dr.,#200, Harrisburg,PA 17110 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things:Any and all AgXroll information regarding Toth L. Guise(DOB &2 67, concerning Mloyment ndth AI Vending. 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 its 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg,PA 17108-0999 TELEPHONE: (717) 441-3960 ATTORNEY ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Notice of Intent to Issue Subpoenas to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 was served by depositing the same in the United States Mail, postage prepaid, at 11 Harrisburg, Pennsylvania, on the day of 'AAA , 2013, on all counsel of record as follows: Gregory E. Martin, Esquire Law Offices of Dale E. Anstine, P.C. Two West Market Street PO Box 952 York, PA 17405 Attorney for Plaintiff THOMAS,THOMAS &HAFER, LLP Renee K. Coonradt, Paralegal for Marc A. Moyer, Esquire 1245240.2 • 2 Jul. 19. 2013 11 : 15AM DALE E ANSTINE PC No- 5588 P. 2 2 L Gregory E.Martin,Esquire,counsel for PIaintiff,do hereby agree to waive the twenty(20) day notice of intent rule allowing counsel for Defendant to issue a subpoena to Paychex, x rl,l9-;LDI0� Z4 Date Gr ory E.Martin,Esquire Smart. Resourceful. CERTIFICATE OF SERVICE AND NOW, this day of , 2013, I, Renee K. Coonradt, of the law firm of Thomas Thomas J & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Gregory E. Martin, Esquire Law Offices of Dale E. Anstine, P.C. Two West Market Street PO Box 952 York, PA 17405 Attorney for Plaintiffs THOMAS, THOMAS & HAFER, LLP np�� NEE K. COO RADT, PARALEGAL 1251236.2 i r of i 10 IN 0 P11 1 41 CE. HHRLAND COUNTY PCN`ISYLVANIA Thomas,Thomas& Hafer,LLP Todd B.Narvol,Esquire (717)237-7133 direct Attorney I.D.No.42136 tnarvol @tthlaw.com Marc A. Moyer, Esquire (717)441-3960—direct Attorney I.D.No. 76434 mmoyer @tthlaw.com 305 N. Front Street (717)237-7105—fax P.O. Box 999 Attorneys for Defendant Harrisburg, PA 17108-0999 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JODI L. GUISE, Plaintiff NO. 12-3266 Civil 2012 V. JURY TRIAL DEMANDED HELEN K. HORTON, Defendant CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve a Subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party on or about October 25, 2013 to serve a subpoena upon Pennsylvania Department of Transportation/Bureau of Driver Licensing. 2. A true and correct file copy of the Notice of Intent, including a copy of the proposed subpoena, is attached to this Certificate. 3. The twenty (20) day notice period for filing and serving objections has been waived by counsel for Plaintiff, as evidenced by the attached correspondence. 4. The subpoena which will be served is identical to the subpoena attached to the Notice of Intent. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP by: Marc A. Moyer, Esq ire Attorney I.D. No.: 76434 Todd B. Narvol, Esquire Attorney I.D. No.: 42136 305 North Front Street, 6th Floor Post Office Box 999 Harrisburg, PA 17108 717-441-3960 mmoyer @tthlaw.com Attorneys for Defendant Thomas,Thomas&Hafer,LLP Todd B.Narvol,Esquire (717)237-7133—direct Attorney I.D.No.42136 tnarvol @tthlaw.com Marc A.Moyer,Esquire (717)441-3960—direct Attorney I.D.No.76434 mmoyer @tthlaw.com 305 N.Front Street (717)237-7105—fax P.O.Box 999 Attorneys for Defendant Harrisburg,PA 17108-0999 Helen K.Horton JODI L. GUISE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-3266 Civil 2012 HELEN K. HORTON, Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO ISSUE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Counsel Defendant intends to serve a subpoena upon PennDOT, identical to the one 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 will be served. Respectfully submitted, THOMAS,THOMAS &HAFER, LLP -Date: October 25, 2013 MARC A. MOYER, ESQUIRE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JODI L. GUISE, Plaintiff NO. 12-3266 Civil 2012 V. JURY TRIAL DEMANDED HELEN K. HORTON, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Pennsylvania Department of Transportation/Bureau of Driver Licensing Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: Complete copy of the entire file regardiniz JODI L. GUISE (DOB: 71911967) including but not limited to: the certified driver record including, but not limited to the complete history of the driver on file in Pennsylvania including Departmental actions, violations and restrictions etc at Thomas, Thomas& Hafer, LLP, P.O. Box 999 Harrisburg PA 17108 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 its 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: Marc A. Mover, Esquire Attorney's Name PA 70102 Identification Number P.O. Box 999, Harrisburg, PA 17108 Address (717)255-7626 Telephone Number Attorney for: Defendant BY THE COURT: DATE: BY: Seal of the Court CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Notice of Intent to Issue Subpoenas to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 was served by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, on the a, l day of � , 2013, on all counsel of record as follows: Gregory E. Martin, Esquire Law Offices of Dale E. Anstine, P.C. Two West Market Street PO Box 952 York, PA 17405 Attorney for Plaintiff THOMAS, THOMAS &HAFER, LLP n��-'2) Renee K. Coonradt, Paralegal for Marc A. Moyer, Esquire 1245240.3 2 Oct. 28. 2013 9:38AM DALE E ANSTINE PC No. 1517 P. 1 r . f.' THOMAS, Harrisburg,PA 4 101 THOMAS � HAEER.1�p 305 North blront Street,Harrisburg,PA 177p7 Attorneys At 1_aw Mailing Address: P.O.Box 999.Harrisburg,PA 17108 Phone: 711.237.7700 fax: 717.237.7105 Renee K.Coottreidt,P iral-gaj (717)442,7063 rcoonradtQtth law.00'M October 25,2013 Gregory P,.Martin, tsquire Law Offices of Dale E.Anstine,P.C. Two West Market Street PO Sox 952 2 York,PA 17405 Z Re: Jodi Guise v.Helen Horton TTH Pile No.644-21771 Dear Mr.Martin: This office wishes to issue a subpoena to PenziDOT. Pursuant to Pennsylvania Mules of Civil Procedure, Rule 4099.22 the issuance of a Notice of Intent to Serve Subpoenas may be waived if all parties agree. It world be most appreciated if you wotfia,sig''`he bottom of this letter,date it and return it to me indicating your agreement to waive the twenty day notice. I have enclosed a Notice of Intent.for your file. I will gladly provide you with copies of all documents received. If you have any questions, please do not hesitate to contact this office. Very truly yours, Tha as Th as&Hafer,LLP epee K.Coo t,Pai aiegal for Mare A.Moyer,Esquire /rkC: 1245233.3 F-Pelosures Harrisburg Bethlehem Pittsburgh Philadelphia Wilkes-Barre Baltimore, MD Clinton, NJ www.tthlaw.com Oct. 28. 2013 9:38AM DALE E ANST1_NE PC No. 1517 P. 2 2 Y,Gregory E.Martin,Esquire,counsel for plaintiff,do hereby agree to waive the twenty(20) day notice of intent rule allowing counsel for Defendant to issue a subpoena to pemt)OT. Datd Gre ry B.Martin,Esquire 7 Smart, Resourceful. CERTIFICATE OF SERVICE AND NOW, this day o , 2013, I, Renee K. Coonradt, of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Gregory E. Martin, Esquire Law Offices of Dale E. Anstine, P.C. Two West Market Street PO Box 952 York, PA 17405 Attorney for Plaintiffs THOMAS, THOMAS & HAFER, LLP RENEE K. COONRADT, PARALEGAL 1251236.3 Randall G.IGale, Esquire Thomas, Thomas & Hafer, LLP 305 North Front Street POB 999 Harrisburg, PA 17108-0999 (717)237-7100 (717) 237-7105—facsimile Attorneys for Defendant Helen K. Horton JODI L. GUISE, Plaintiff V. HELEN K. HORTON, Defendant r !LTD. C THE PROTHONOTAT 20 14 11AR PH 3: 21 CUMBERLAND COUNTY P. E NH SYLVANIA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 12-3266 Civil 2012 : JURY TRIAL DEMANDED PRAECIPE FOR WITHDRAWAL/ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Marc A. Moyer, Esquire as counsel for Defendant Helen K. Horton. Date: 3 Cp LI THOMAS, THOMAS & HAFER, LLP Marc Moyer, v squire I.D. No. 764 TO THE PROTHONOTARY: Please enter the appearance of Randall G. Gale, Esquire on behalf of Defendant Helen K. Horton. Date: THOMAS, THOMAS & HAFER, LLP R 'a 1l G. Gale, Esquire I.D. No. 26149 CERTIFICATE OF SERVICE I, April L. Casper, a secretary with the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I have, this day, served a true and correct copy of the foregoing Praecipe for Withdraw/Entry of Appearance upon the person and at the address listed below by placing a copy of same in the United States 1st Class Mail, postage prepaid, to the following: Date: - Gregory E. Martin, Esquire Law Offices of Dale E. Anstine, P.C. Two West Market Street PO Box 952 York, PA 17405 THOMAS, THOMAS & HAFER, LLP By: 02N-€.4...,t, April L. asper, ega Secre 2 P t,'GTHGNGTA�e'Y 2014 t/ [ 9 Pi-1 !: 23 ctip-InF'ftt�..r PENT{rS,YLVA �UU? TY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JODI L. GUISE Plaintiff V HELEN K. HORTON Defendant : NO: 12-3266 : CIVIL ACTION — LAW PRAECIPE OF DISCONTINUANCE To the Prothonotary: David Buell (X) Please mark the above captioned action SETTLED AND SATISFIED OR ( ) Please mark the above captioned judgment or lien settled and satisfied. Grego . Ma 'n, Esquire Attorney for the Plaintiff I.D. No: 38894 CC: Randall Gale, Esquire Dated: November 18, 2014