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Home My WebLink About12-4433Christina L. Bradley, Esquire FREEBURN & HAMILTON ID No. 89107 2040 Linglestown Road, Suite 304,,, t..{ ` Harrisburg PA 17110 ?i d (?"? PROTHWTAR (717) 671-1955 2012 JUL ] AN christinabo pa injurylawyer.com U 11 JANET RHODES, 45 Seneca Road Belleville, PA 17004 Plaintiff V. GIANT FOOD STORES, INC. 1149 Harrisburg Pike Carlisle, PA 17013 Defendant NO. 19 -(4V S:3 Na CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue Writ of Summons in the above-captioned action. Writ of Summons shall be issued and forwarded to ( ) Attorney (X) Sheriff Christina L. Bradley, Esquire 2040 Linglestown Road, Suite 300 Harrisburg, PA 17110 Signature of Attorney (717) 671-1955 Supreme Court ID No. 89107 Date: Tl,?) ?) (off ZO1Z ?J WRIT OF SUMMONS C?L N \ \.D% Iu 4'D -I t ut TO THE ABOVE-NAMED DEFENDANTS: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS/ HAVE COMMENCED AN ACTION AGAINST YOU. Prothonotary Date: ' D^ -By: _49?. Deputy ORIGINAL Attorney for Plaintiffs YLVV'THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA A F: TILES\Clients\9500 MAC\9500.Current\9500.609\9500.609.pra1 Revised-. 7/25/12 10.17AM ' '.. George B. Faller Jr., Esquire M ?' C= M MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES v cn -r-1 t Cl I.D. 49813 10 East High Street ' Carlisle, PA 17013 C, cr rv _ `:' (717) 243-3341 ` ?Jq Attorneys for Defendant ' JANET RHODES, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVAN IA V. NO. 12-4433 CIVIL ACTION - LAW GIANT FOOD STORES, INC., Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON LAW OFFICES on behalf of Defendant in the matter and issue a rule upon the Plaintiff to file a Complaint within twenty (20) days from serv thereof or suffer judgment of non pros. Defendant hereby demands a twelve juror jury trial in above captioned action. MARTSON LAW O Dated: July 25, 2012 Gedffige Buller, Jr., I.D. No. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 By Attorneys for Defendant RULE AND NOW, this ??ay of , 200 a Rule is issued upon the to file a Complaint within twenty (20) days from service hereof. Prothonotary `?? s CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent for Martson Law Offices, hereby certify that a of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, A, first class mail, postage prepaid, addressed as follows: Christina L. Bradley, Esquire FREEBURN & HAMILTON 2040 Linglestown Road Suite 300 Harrisburg, PA 17110 MARTSON LAW OFFICES By it #G, Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: July 25, 2012 SHERI'FF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ?e1wta of cumbe..44f x } -01 WPICE OF THE ViERIFF 1LE U-Ur r it.c a ,E PPOTHMO'i' RY 2012 JUL 30 AM 9? 03 ? IRLANp C OMIT) SYLVANi Janet Rhodes VS. Case Number Giant Food Stores, Inc. 2012-4433 SHERIFFS RETURN OF SERVICE 07/20/2012 10:45 AM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on July 20, 2012 at 1045 hours, he served a true copy of the within writ of Summons, upon the wi ' named defendant, to wit: Giant Food Stores, inc., by masking known unto Carolyn Heiges, P for Giant Food Stores, Inc. at 1149 Harrisburg Pike, Carlisle, Cumberland County, Pennsyhrania 1 013 its cunt nts and at the same time handing to her personally the said true and correct copy of the same. RONALD SHERIFF COST: $34.00 July 24, 2012 SO ANSWERS, / X• iar (c) CountySuite Sheriff, TdeosoR, Inc. Christina L. Bradley, Esquire FREEBURN & HAMILTON ID No. 89107 2040 Linglestown Road, Suite 300 Harrisburg PA 17110 (717) 671-1955 christinab(u pa-injurylawyer.com 1 E l,,CtOTHCNOTAV 2D,, AUG -2 Aft n: 23 ORIGINAL cuMBERLAND ®NUA TY Attorney for Plaintiff JANET RHODES, Plaintiff V. GIANT FOOD STORES, INC. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV : NO. 12-4433 : CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the clai set forth in the following pages, you must take action within twenty (20) days after t Complaint and Notice are served, by entering a written appearance personally or attorney and filing in writing with the Court your defenses or objections to the clai set forth against you. You are warned that if you fail to do so the case may proc, without you and a judgment may be entered against you by the Court without furt notice for any money claimed in the Complaint or for any other claim or re requested by the Plaintiff. You may lose money or property or other rights import to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU O NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WI H INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER I SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 Dated: J 1.1 ?' ZU) 2 Christina L. Bradley, Attorneys for Plaintiff Christina L. Bradley, Esquire FREEBURN & HAMILTON ID No. 89107 2040 Linglestown Road, Suite 300 Harrisburg PA 17110 (717) 671-1955 christinabCa,pa-iniurylawyer. com Attorney for Plaintiff JANET RHODES, Plaintiff V. GIANT FOOD STORES, INC. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-4433 : CIVIL ACTION - LAW NOTICE LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted quiere defenderse i estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias plazo al partir de la fecha de la demanda y la notification. Usted debe presentar i apariencia esrita o en persona o por abogado y archivar en la corte en forma escri sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisal, que si usted no se defiende, la corte tomara medidas y puede entrar una orden cone' usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en' peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechl importantes para. usted. LISTED DEBE LLEVAR ESTATE DOCUMENTO A SU ABOGA IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CEI DE COMO CONSEQUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, 1 POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBI AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 Dated: -w q 31 c 0 I Z A Christina L. Bradley, Attorneys for Plaintiff Christina L. Bradley, Esquire FREEBURN & HAMILTON ID No. 89107 2040 Linglestown Road, Suite 300 Harrisburg PA 17110 (717) 671-1955 christinabrd-pa-iniurvlawyer.com Attorney for Plaintiffs JANET RHODES, Plaintiff V. GIANT FOOD STORES, INC. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV. NO. 12-4433 CIVIL ACTION - LAW COMPLAINT AND NOW comes Plaintiff, Janet Rhodes, by her attorneys, Freeburn Hamilton, and files the following Complaint: 1. Plaintiff, Janet Rhodes, is an adult individual who resides at 45 Road, Belleville, Mifflin County, Pennsylvania. 2. Defendant, Giant Food Stores, Inc., is a Business Corporation in the State of Delaware, with a principle place of business or activity at 11 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on or about August 14, 2010 at approximately 2:00 p.m. inside Giant Food Stores #150, locatedlat 325 West Freedom Avenue, Burnham, Mifflin County, Pennsylvania. 4. At that time and place, Defendant was in exclusive management and control of the interior of Giant Food Stores #150 through ?ts employees who were acting within the scope and course of their employment Defendant, and in furtherance of Defendant's business. 5. At that time and place, Plaintiff was a business visitor at Giant Stores # 150. 6. At that time and place, Plaintiff was walking in the laundry aisle of Giant Food Stores # 150. 7. At that time and place, a foreign, slippery substance was located on floor in Plaintiff's path in the laundry detergent aisle. 8. This foreign, slippery substance caused Plaintiff to slip and fall. 9. The foregoing incident and all of the injuries and damages as set hereinafter are the direct and proximate result of the negligent, gross negligence, careless, wanton and reckless manner in which Defendant operated and main the Giant Food Stores # 150 as follows: a. In failing to exercise reasonable care to ensure the safety of business visitors such as Plaintiff; b. In failing to inspect the premises and discover the substance that caused the incident; C. In failing to discover and/or keep the premises and floor of Gi Food Stores # 150 free and clear of foreign substances that wo create a hazard to business visitors such as Plaintiff, d. In failing to adequately supervise and manage its employees o should have discovered and removed the foreign substance at caused the incident; C. In failing to anticipate the harm that the foreign substance cause business visitors; L In permitting a foreign substance to accumulate on the floor a a point where it posed an unreasonable risk of injury to Plain iff and other business visitors; g. In failing to give warning of the dangerous condition posed by accumulation of the foreign substance, erect barricades, or 1 any other safety precautions to prevent injury to Plaintiff other business visitors; h. In failing to removed the foreign substance from the floor keep the floor clean and free of hazardous conditions. 10. As a result of Defendant's negligence, carelessness and recklessness, Plaintiff suffered painful and severe injuries to her nerves, bones and soft which include, but are not limited to, her right leg. 11. By reason of the aforesaid injuries suffered by Plaintiff, she has a heightened possibility that she will suffer other or additional injury in the future, and claim is made therefore. 12. The aforesaid injuries suffered by Plaintiff may have aggravated or ben aggravated by an existing infirmity, condition or disease, resulting in a prolongation worsening of the injuries and an enhanced risk of future harm to Plaintiff, and claimlis made therefore. 13. By reason of the aforesaid injuries suffered by Plaintiff, she was forced incur liability for reasonable and necessary medical tests, medical examinations, medical treatment, medications, hospitalizations and similar expenses in an effort diagnose her injuries and to restore herself to health, and claim is made therefore. 14. Plaintiff has not fully recovered from her injuries and it is likely that she will incur similar expenses in the future, and claim is made therefore. 15. By reason of the aforesaid injuries suffered by Plaintiff, she has incidental costs and expenses, the exact amount of which cannot be ascertained this time, and claim is made therefore. 16. As a result of the aforesaid injuries suffered by Plaintiff, she undergone and in the future will undergo great physical and mental pain suffering, great inconvenience in carrying out her daily activities, loss of lif?'s pleasures and enjoyment, and claim is made therefore. 17. As a result of the aforesaid injuries suffered by Plaintiff, she has subjected to humiliation, embarrassment, shame, worry and anger. 18. As a result of the aforesaid injuries suffered by Plaintiff, she has subjected to severe mental anguish, emotional distress, nervous shock, fright horror. 19. As a result of the aforesaid injuries suffered by Plaintiff, she will con to endure great mental anguish, emotional distress, shame, worry and anger in future. 20. By reason of the aforesaid injuries suffered by Plaintiff, she has deprived her enjoyment of the pleasures of life. 21. Plaintiff continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing resid problems for the remainder of her lifetime, and claim is made therefore. 22. As a result of the aforesaid injuries suffered by Plaintiff, she has a disfigurement, and claim is made therefore. WHEREFORE, Plaintiff, Janet Rhodes, demands judgment in her favor against Defendant, Crown American Financing Partnership, in an amount in excess (of FIFTY THOUSAND 8v 00/ 100 ($50,000.00) DOLLARS, exclusive of interest and coots and in excess of any jurisdictional amount requiring compulsory arbitration. Respectfully Submitted, FREEBURN & HAMILTON By: LLIALa'( La11?aL Christina L. Bradley, Es ire I.D. No. 89107 2040 Linglestown Road Suite 300 Harrisburg PA 17110 (717) 671-1955 Date: J i 31 20 1 Z Counsel for Plaintiffs VERIFICATION I, Janet Rhodes, hereby verify that the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 3 I AA 0'/ eIOA'et Rhodes CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the forgoing document was d served on this 31st day of July, 2012, by placing the same in the U.S. First Class postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: George B. Faller, Jr. Martson Law Offices 10 East High Street Carlisle, PA 17013 BY: ? J1?? ?`l UJOe?f?? Jessie K. Walsh, Legal Assistant to Christina L. Bradley, Esquire Attorney I.D. #89107 FREEBURN & HAMILTON 2040 Linglestown Road, Suite 300 Harrisburg, PA 17110 (717) 671-1955 Dated: 'l 13j I (j Attorney for Plaintiff r F.\FILES\Clients\9500 MAC\95000urren[\9500.609\9500.609.ansLwpd Revised: 6/27/12 8:35AM George B. Faller, Jr., Esquire I.D. No. 49813 Seth T. Mosebey, Esquire I.D. No. 203046 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant f-J h,7 ~~ ro ca >~ a -t a ~ ~ JANET RHODES, v. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVAl GIANT FOOD STORES, INC., Defendant NO. 12-4433 CIVIL ACTION -LAW JURY TRIAL DEMANDED DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT 1. After reasonable investigation, Defendant is without knowledge or inform sufficient to form a belief as to the truth of this averment. 2 Admitted, with clarification. The appropriate Defendant is Giant Food Stores, a Delaware limited liability company with its corporate headquarters located at 27 Brook Avenue, Carlisle, Pennsylvania 17015. 3. This averment is denied pursuant to Pa. R.C.P. 1029(e). 4. Admitted. 5-7. This averment is denied pursuant to Pa. R.C.P. 1029(e). 8. Denied as a conclusion of law to which no response is required under Pennsylvania Rules of Civil Procedure. 9(a)-(h). Denied as a conclusion of law to which no response is required under Pennsylvania Rules of Civil Procedure. 10-11. Denied as a conclusion of law to which no response is required under Pennsylvania Rules of Civil Procedure. 12-22. Denied as a conclusion of law to which no response is required under Pennsylvania Rules of Civil Procedure. To the extent that a response is required, this averme~ denied pursuant to Pa. R.C.P. 1029(e). the the the the ~t is __r. _, __ _ _._ _ __. __ __ , _ _ r WHEREFORE, Defendant Giant Food Stores, LLC, incorrectly captioned as Giant F od Stores, Inc., respectfully requests that this Court grant judgment in its favor and against Plaintiff d dismiss all claims against it with prejudice. MARTSON ~„~W OFFICES By ~-~x George .Faller, Jr., Esquire I.D. No. 49813 Seth T. Mosebey, Esquire I.D. No. 203046 10 East High Street Carlisle, PA 17013 (717) 243-3341 Dated: 8/27/12 Attorneys for Defendant VERIFICATION I, BRUCE ASTRACHAN; Manager, General Liability, on behalf ofGiant Food Stores, acknowledge that I have the authority to execute this Verification on behalf of Giant Food LLC, and certify that the foregoing Answers to Interrogatories isbased upon information which been gathered by my counsel in the preparation of this lawsuit. The language of this Answer is of counsel and not my own. I have read the document curd to the extent that this Answer is ba upon information which I have given to my counsel, it is true and correct and to the best of knowledge, information and belief. To the extent that the content of this Answer is that of coon I have relied upon counsel in making this Verification. This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4! relating to unsworn falsification to authorities, which provides that if I knowingly make f: averments, I may be subject to criminal penalties. Gia o l~ res, LLC race Astrachan Manager -General Liability Dated: ~~ 0 ~~- F~~FILE:S1CIient514500 MAC~.9500.Currenfl9500.60919500 609 snsl.wpd CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent for Martson Law Offices, hereby certify that a c py of the foregoing Answer was served this date by depositing same in the Post Office at Carlisle, A, first class mail, postage prepaid, addressed as follows: Christina L. Bradley, Esquire FREEBURN & HAMILTON 2040 Linglestown Road Suite 300 Harrisburg, PA 17110 MARTSON LAW OFFICES By CC.~'I,rGr- Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717)243-3341 Dated: 8/27/ 12 Christina L. Bradley, Esquire FREEBURN & HAMILTON ID No. 89107 2040 Linglestown Road, Suite 300 Harrisburg PA 17110 (717) 671-1955 christinab(a,pa-injurylawyer. com 111�l 11F� 77 IL,..• L{�J' l� I C C.. Lf- THE- PROT HMO TAi' 2011.1 AUG 18 PH 3:. I CUMBERLAND COUNTY PENNSYLVANIA Attorney for Plaintiffs JANET RHODES, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 12-4433 GIANT FOOD STORES, INC. : CIVIL ACTION - LAW Defendant PLAINTIFF'S RESPONSE TO DEFENDANT'S REQUEST FOR ADMISSIONS By: FREEBURN & HAMILTON CLuN-Lalc1,. Christina L. Bradley, Esquire I.D. No. 89107 2040 Linglestown Road Suite 300 Harrisburg PA 17110 (717) 671-1955 Date: 115M Counsel for Plaintiffs Request for Admission No.1 The photographs attached hereto as Exhibit "A" accurately represent the color of the liquid that was on the floor at the Giant grocery store located at 325 West Freedom Avenue, Burnham, Pennsylvania, at the time of your alleged slip -and -fall on August 14, 2010. ANSWER: Denied. It is specifically denied that the photographs attached as Exhibit "A" accurately represent the color of the liquid that was on the floor at the Giant grocery store at the time of Plaintiff's slip and fall on August 14, 2010. Interrogatory No. 1 Unless your Response to Request for Admission No. 1 is an unqualified admission, state how the color of substance upon which you allegedly slipped was different than the color of the substance shown in the photographs attached hereto as Exhibit "A." ANSWER: The substance upon which Plaintiff slipped and fell on August 14, 2010, at the Giant grocery store located at 325 West Freedom Avenue, Burnham, Pennsylvania, was a lighter shade of blue than the substance shown in the photographs provided with Defendant's Request for Admissions. Request for Admission No. 2 The photographs attached hereto as Exhibit "A" accurately represent the aisle at the Giant grocery store located at 325 West Freedom Avenue, Burnham, Pennsylvania, where you allegedly slipped and fell on August 14, 2010. ANSWER: Admitted. 2 Interrogatory No. 2 Unless your Response to Request for Admission No. 2 is an unqualified admission, state how the aisle in which you allegedly slipped was different than aisle shown in the photographs attached hereto as Exhibit "A." ANSWER: N/A Request for Admission No. 3 The photographs attached hereto as Exhibit "A" accurately represent the location within the aisle of the substance upon which you allegedly slipped and fell on August 14, 2010, at the Giant grocery store located at 325 West Freedom Avenue, Burnham, Pennsylvania. ANSWER: Denied. It is specifically denied that the photographs attached as Exhibit "A" accurately represent the location within the aisle of the substance upon which Plaintiff slipped and fell on August 14, 2010. Interrogatory No. 3 Unless your Response to Request for Admission No. 3 is an unqualified admission, state how the location of the substance in which you allegedly slipped was different than the location shown in the photographs attached hereto as Exhibit "A." ANSWER: The photographs included as Exhibit "A" show the substance in the center of the aisle. At the time of her fall, Plaintiff was walking more to the side of the aisle as opposed to in the center of the aisle. When looking at the photographs in Exhibit "A" which show the window at the end of the aisle, Plaintiff was walking to the left side 3 of the aisle. In addition, Plaintiff did not see a bottle on the floor either prior to, or after her fall, and therefore, Plaintiff does not believe that there was a bottle located on the floor in the aisle where she fell. Request for Admission No. 4 The photographs attached hereto as Exhibit "A" accurately represent the quantity of the substance upon which you allegedly slipped and fell on August 14, 2010, that was on the floor of the aisle at the Giant grocery store located at 325 West Freedom Avenue, Burnham, Pennsylvania. ANSWER: Denied. It is specifically denied that the photographs attached as Exhibit "A" accurately represent the quantity of the substance upon which Plaintiff slipped and fell on August 14, 2010. Interrogatory No. 4 Unless your Response to Request for Admission No. 4 is an unqualified admission, state how the quantity of the substance in which you allegedly slipped was different than the quantity of the substance shown in the photographs attached hereto as Exhibit "A." ANSWER: While Plaintiff did not see the substance upon which she slipped and fell until she had fallen and was lying on the ground, Plaintiff believes that the quantity of the substance upon which she fell was greater than the quantity shown in the photographs attached as Exhibit "A". 4 VERIFICATION I, Janet Rhodes, hereby verify that the statements in the foregoing First Set of Request of Admissions with Interrogatories Directed to Plaintiff are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 1 / �' Christina L. Bradley, Esquire FREEBURN & HAMILTON ID No. 89107 2040 Linglestown Road, Suite 300 Harrisburg PA 17110 (717) 671-1955 christinabQba-inju rylawyer. com Attorney for Plaintiffs JANET RHODES, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 12-4433 GIANT FOOD STORES, INC. : CIVIL ACTION - LAW Defendant CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the forgoing Plaintiff's Response to Defendant's Request for Admissions was duly served on this 15th day of August, 2014, by placing the same in the U.S. First Class Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: BY: George B. Faller, Jr. Martson Law Offices 10 East High Street Carlisle, PA 17013 Jessie K. Walsh, Legal Assistant to Christina L. Bradley, Esquire Attorney I.D. #89107 FREEBURN & HAMILTON 2040 Linglestown Road, Suite 300 Harrisburg, PA 17110 (717) 671-1955 Dated: 8/15/14 Attorney for Plaintiff