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Home My WebLink About12-4659t f` L ty r RO f i' ONOTAR 1 7012 JUL 2S PSI I: 5S CUMBERLAND COUNTY PENNSYLVANIA ANGINO & ROVNER, P.C. Richard A.Sadlock Attorney ID# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) f?-mail:rsadlock@angino-rovner.com DIANE L. SAKSON and ROBERT J. SAKSON, Her Husband, Plaintiffs V. MATTHEW D. LENHARDT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LA NO. )a-C4 fC S iU1 JURY TRIAL DEMANDED 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 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. Cumberland County Bar Association 32 S. Bedford St., Carlisle 17013 (717) 249-3166 502613 Dd apt Ckµ 'i 24- a-7 S ti AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defMarshalle de las demandas que se persentan mas adelante en las siguientes pdginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despuds 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 mas aviso adicional. Used puede perder dinero o propiedad u otros derechos importantes para used. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USED 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 0 BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 S. Bedford St., Carlisle 17013 (717) 249-3166 TELEFONO (717) 249-3166 502613 ANGINO & ROVNER, P.C. Richard A. Sadlock Attorney [D# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) F-mai1:rsadlock@angino-rovner.com DIANE L. SAKSON and ROBERT J. SAKSON, Her Husband, Plaintiffs V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. MATTHEW D. LENHARDT, Defendant JURY TRIAL DEMANDED COMPLAINT 1. Plaintiffs Diane L. Sakson and Robert J. Sakson are husband and wife, adult individuals and citizens of the Commonwealth of Pennsylvania who reside at 133 Forest Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant Matthew D. Lenhardt is an adult individual and citizen of the Commonwealth of Pennsylvania who resides at 1039 Walnut Street, Lemoyne, Cumberland County, Pennsylvania 17043. 3. The facts and occurrences hereinafter related took place on or about September 27, 2010, on North 12th Street in Lemoyne, Cumberland County, Pennsylvania. 4. At that time and place, Plaintiff Diane Sakson was operating a 2005 Ford Explorer traveling south on North 12th Street. 502613 5. At that time and place, Defendant Matthew D. Lenhardt was operating a 2006 Ford traveling north on North 12`h Street. 6. At that time and place, Defendant Matthew D. Lenhardt was traveling too fast for road conditions, began to fishtail, crossed the double yellow lines into the southbound lane of North 12`h Street, and violently collided with Plaintiff Diane L. Sakson's vehicle. 7. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff Diane L. Sakson and Robert J. Sakson are the direct and proximate result of the negligent, careless, wanton, and reckless manner in which Defendant Matthew D. Lenhardt operated his vehicle as follows: (a) failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; (b) failure to stay within a single lane of travel in violation of §3309 of the Pennsylvania Motor Vehicle Code; (c) failure to travel at a safe speed; (d) failure to apply his brakes in sufficient time to avoid colliding with the Plaintiff s vehicle; (e) failure to have proper and adequate control over his vehicle; (f) failure to take reasonable evasive action to avoid the accident; and (g) driving his vehicle upon the highway in a manner endangering persons and property, and in a reckless manner with careless disregard to the rights and safety of others, and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. CLAIM I DIANE L. SAKSON V. MATTHEW D. LENHARDT 8. Paragraphs 1 through 7 of Plaintiffs' Complaint are incorporated herein by reference. 502613 9. Plaintiff Diane L. Sakson sustained painful and severe injuries which include, but are not limited to left lower rib fracture, bilateral knee pain, and multiple contusions/abrasions, a fractured left radial head and torn rotator cuff. 10. By reason of the aforesaid injuries sustained by Plaintiff Diane L. Sakson, she was forced to incur liability for medical treatment, medications, hospitalizations, and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 11. Because of the nature of her injuries, Plaintiff Diane L. Sakson has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 12. As a result of the aforementioned injuries, Plaintiff Diane L. Sakson has undergone, and in the future will undergo, great physical and mental suffering, great inconvenience in carrying out her daily activities, and loss of life's pleasures and enjoyment, and claim is made therefor. 13. Plaintiff Diane L. Sakson continues to be plagued by persistent pain and limitations and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefor. 14. As a result of the aforementioned collision and resulting injuries, Plaintiff Diane L. Sakson has been, and in the future will be, subject to great humiliation and embarrassment, and claim is made therefor. 15. As a result of the aforementioned injuries, Plaintiff Diane L. Sakson may sustain work loss, loss of opportunity and a permanent diminution of her earning power and capacity, and claim is made therefor. 16. As a result of the aforesaid injuries, Plaintiff Diane L. Sakson has sustained 502613 uncompensated work loss, and claim is made therefor. CLAIM II ROBERT J. SAKSON V. MATTHEW D. LENHARDT 17. Paragraphs 1 through 16 of Plaintiffs' Complaint are incorporated herein by reference. 18. As a result of the aforementioned injuries sustained by his wife, Plaintiff Diane L. Sakson, Plaintiff Robert J. Sakson has been and may in the future be deprived of the care, companionship, consortium, and society of his wife, all of which is be to his great detriment, and claim is made therefor. WHEREFORE, Plaintiffs Diane L. Sakson and Robert J. Sakson demand judgment against Defendant Matthew D. Lenhardt in an amount in excess of Fifty Thousand ($50,000.00) Dollars exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. ANGINO & RO T-.D. No. 47281 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff(s) 502613 VERIFICATION I, DIANE L. SAKSON, do swear and affirm that the facts set forth in the foregoing COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that this verification is made subject to the penalties of the Rules of Civil Procedure relating to unswom falsification to authorities. WITNESS: DIANE L. SAKSON Dated: 7// W?0 I ;-- 203648 VERIFICATION I, ROBERT J. SAKSON, do swear and affirm that the facts set forth in the foregoing COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that this verification is made subject to the penalties of the Rules of Civil Procedure relating to unsworn falsification to authorities. WITNESS: Dated:-Z? RO R J.SAKSON 203648 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~,~~-titr at ~:~uaGe~r/~~~~~ ~ ;: ,.T ,, -c ~`~~` ,,° ~F ~ G -, ..~as€ i ,iE_ E ~~;? AUG ~ 5 A+~9 ~~ 2 ~'1J~'1Ci~ ~ i~~?~l~ 1~~u~~T,~, Diane L. Sakson vs. Matthew D. Lenhardt Gase Numb 2012-4659 SHERIFF'S RETURN OF SERVICE 08/08/2012 12:10 PM -Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on Aug 8, 2012 at 1210 hours, she served a true copy of the within Complaint and Notice, upon the within nan defendant, to wit: Matthew D. Lenhardt, by making known unto Phyllis George, Grandmother to Matthi D. Lenhardt at 1039 Walnut Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents a at the same time handing to her personally the said true and correct copy of the same. VALERIE WEARY, D SHERIFF COST: $44.00 August 09, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF c? Cau~tySuite Si~eritf, Tr>lae~nft, Inr. q"-a f~.T.,. I . ~~ N 2 C fTt _- r fJ? T' ...~ ~ -'- ~ ~ f: ~. a ~ .... _ ~. '~"' "I' A ~ c~a _,- ~~~ ~~ na ~' ~~ ,; ~- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV DIANE L. SAKSON and ROBERT J. SAKSON, Plaintiffs, CIVIL DIVISION NO. 12-4659 v. MATTHEW D. LENHARDT, Defendant. PRAECIPE FOR APPEARANICE (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Pairty: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #19430 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PE~'NSYLV DIANE L. SAKSON and ROBERT J. CIVIL DIVISION SAKSON, Plaintiffs, NO. 12-4659 v. MATTHEW D. LENHARDT, (Jury Trial Demanded) Defendant. PRAECIPE FOR APPEARANCE TO: THE PROTHONOTARY Kindly enter the Appearance of the undersigned, Kevin D. Rauch, Esquire, of law firm of Summers, McDonnell, Hudock, Guthrie & Skeel, P.C., on behalf of Defendant, Matthew D. Lenhardt, in the above case. JURY TRIAL DEMANDED Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE ~ SKEEL, P.C. By: i~D`'Ra~dcfi, Esquire nsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAEC FOR APPEARANCE has been mailed by U.S. Mail to counsel of record Wia first mail, postage pre-paid, this 14th day of August, 2012. Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 (Attorney for Plaintiffs) SUMMERS, McDONNELL, HUDOCK, GUTHRI~ ~ SKEEL, P.~. By: Ruch, Esquire I for Defendant ~;` s #~~ f'~Q THONO T~f~ ~~i1 BUG 29 PPS I~ i i r11~ERLANO COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAP DIANE L. SAKSON and ROBERT J. SAKSON, Plaintiffs, CIVIL DIVISION NO. 12-4659 v. MATTHEW D. LENHARDT, Defendant. TO: Plaintiffs You are hereby notified to file a written Response to the enclosed Answer and New Matter within twenty (20) days From service hereof or a judgment May be entered against you. ~~ ~ ~ a Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. ANSWER AND NEW MATTER (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 ~IA #19430 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANE L. SAKSON and ROBERT J. SAKSON, Plaintiffs, CIVIL DIVISION NO. 12-4659 v. MATTHEW D. LENHARDT, Defendant. (Jury Trial Demanded) ANSWER_AND NEW MATTER AND NOW, comes the Defendant, Matthew D. Lenhardt, by and through is counsel, Summers, McDonnell, Hudock, Guthrie & Skeel, P.C., and Kevin D. Rau h, Esquire, and files the following Answer and New Matter and in support thereof avers as follows: 1. After reasonable investigation, the Defendant has insufficient informati as to the truth or falsity of said averments, therefore said averments are denied a strict proof thereof is demanded at the time of trial. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted in part, denied in part. It is admitted that the Defendant's vehic began to fishtail and cross the double yellow lines into the southbound lane of North T Street. The remainder of the allegations in paragraph 6 are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 7. Admitted in part and denied in part. It is admitted that the Defendant negligent in the operation of his motor vehicle at the averred date, time and place. remainder of paragraph 7 and all of its subparts state legal conclusions to which response is required. To the extent, however, that a response is deemed necess~ry, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict pry thereof is demanded at the time of trial. CLAIM I 8. In response to paragraph 8, the Defendant reiterates and repeats all ~is responses in paragraphs 1 through 7 as if fully set forth at length herein. 9. Paragraph 9 states a legal conclusion to which no response is requir~d. To the extent, however, that a response is deemed necessary, said averments ~re denied generally pursuant to Pa. R.C.P. 1029(d) and (e). Strict proof thereof demanded at the time of trial. 10 is Paragraph 10 states a legal conclusion to which no response is requir~d. To the extent, however, that a response is deemed necessary, said averments ; denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof demanded at the time of trial. 11. Paragraph 11 states a legal conclusion to which no response is requ is To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proaf thereof is demanded at the time of trial. 12. Paragraph 12 states a legal conclusion to which no response is requi To the extent, however, that a response is deemed necessary, said averments < denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof demanded at the time of trial. 13. Paragraph 13 states a legal conclusion to which no response is require To the extent, however, that a response is deemed necessary, said averments denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof demanded at the time of trial. 14. Paragraph 14 states a legal conclusion to which no response is require To the extent, however, that a response is deemed necessary, said averments denied generally pursuant to Pa. R.C.P. 1029(d) and (e). Strict proof thereof demanded at the time of trial. is is is 15. Paragraph 15 states a legal conclusion to which no response is requir d. To the extent, however, that a response is deemed necessary, said averments re denied generally pursuant to Pa. R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 16. Paragraph 16 states a legal conclusion to which no response is require To the extent, however, that a response is deemed necessary, said averments denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proaf thereof demanded at the time of trial. CLAIM II 17. In response to paragraph 17, the Defendant reiterates and repeats all I responses in paragraphs 1 through 16 as if fully set forth at length herein. is its ~_ T 18. Paragraph 18 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments re denied generally pursuant to Pa. R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant, Matthew D. Lenhardt, respectfully requests Honorable Court enter judgment in his favor and against the Plaintiffs with costs prejudice imposed. NEW MATTER 19. The motor vehicle accident in controversy is subject to the Pennsylva Motor Vehicle Financial Responsibility Law and this Defendant asserts, as affirmai is defenses, all rights, privileges and/or immunities accruing pursuant to said statute. 20. Some and/or all of Plaintiffs' claims for damages are items of econo is detriment which are or could be compensable pursuant to either the Pennsylvania Mo or Vehicle Financial Responsibility Law and/or other collateral sources and same may of be duplicated in the present lawsuit. 21. To the extent that the Plaintiffs have selected the limited tort option or deemed to have selected the limited tort option then this Defendant sets forth relevant provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law a~ a bar to the Plaintiffs' ability to recover non-economic damages. 22. This Defendant pleads any and all applicable statutes of limitation Pennsylvania Law as a complete or partial bar to any recovery by Plaintiffs in action. WHEREFORE, Defendant, Matthew D. Lenhardt, respectfully requests t is Honorable Court enter judgment in his favor and against the Plaintiffs with costs nd prejudice imposed. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. ~~ By: Kevin D. Rauch, Esquire Counsel for Defendant T VERIFICATION Defendant verifies that he is the Defendant in the foregoing acition; that foregoing ANSWER AND NEW MATTER is based upon information which he as furnished to his counsel and information which has been gathered by his counsel in he preparation of the lawsuit. The language of the ANSWER AND NEW MATTER is tha of counsel and not of the Defendant. Defendant has read the ANSWER AND N W MATTER and to the extent that the ANSWER AND NEW MATTER is based u information which he has given to his counsel, it is true and correct to the best of his knowledge, information and belief. To the extent that the content of the AIWSWER NEW MATTER is that of counsel, he has relied upon counsel in making this Affid Defendant understands that false statements herein are made subject to the penalties 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: e` Matthew D. Lenhardt of #19430 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing ANSW~R AND NEW MATTER has been mailed by U.S. Mail to counsel of record via first mail, postage pre-paid, this 28th day of August, 2012. Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 (Attorney for Plaintiffs) SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. B : ~~ Y Kevin D. Rauch, Esquire Counsel for Defendant ANGINO & ROVNER, P.C. Richard A. Sadlock Attorney [D# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 (7]7)238-6791 F.AX (717) 238-5610 Attorneys for Plaintiff(s) E-mail:rsadlock@angino-rovner.com C ~" 1 ~ ~~ ~ ~ t^ ~ ~ N.2 - -~I:twJ C~ Z -~ ~ "~ ~~ w ~~ y ~~' ~ W ;> ^' -C CA " DIANE L. SAKSON and ROBERT J. SAKSON, Her Husband, Plaintiffs v. MATTHEW D. LENHARDT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 12-4659 JURY TRIAL DEMANDED PLAINTIFFS' REPLY TO DEFENDANT'S NEW MATTER AND NOW, comes Plaintiffs Diane L. Sakson and Robert J. Sakson, Her Husband and replies to Defendant's New Matter as follows: 19. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, all of Plaintiffs injuries and damages are recoverable in the instant action. The Pennsylvania Motor Vehicle Financial Responsibility Law in no way limits the damages Plaintiff may recover herein. 20. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By 507159 way of amplification, all of Plaintiffs injuries and damages are recoverable in the- instant action. The Pennsylvania Motor Vehicle Financial Responsibility Law in no way limits .the damages Plaintiff may recover herein. 21. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, all of Plaintiffs' injuries and damages are recoverable in the instant action. The Pennsylvania Motor Vehicle Financial Responsibility Law in no way limits the damages Plaintiff may recover herein. By way of further amplification, the Pennsylvania Motor Vehicle Financial Responsibility Law in no way bars or limits Plaintiffs' claims herein. Further, all of Plaintiffs' injuries are serious injuries, and therefore, she is deemed full tort. 22. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent that the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Plaintiff s claim and the instant action were filed within the applicable statute of limitations. WHEREFORE, Plaintiff respectfully requests this Honorable Court to dismiss Defendant's Answer and New Matter and enter judgment in his/her favor against the Defendant. Street A 17110 507169 Harrisburg, P (717) 238-6791 rsadl ock@angino-rovner. com Counsel for Plaintiff COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DAUPHIN SS. AFFIDAVIT I, RICHARD A. SADLOCK, ESQUIRE, being duly sworn according to law, deposes and states that I am counsel for Plaintiff, that I am authorized to make this Affidavit on behalf of said Plaintiffs, and the facts set forth in the foregoing Repl; best of my knowledge, information, and belief. Sworn to and subscribed before me this day of , 2012. Notary Public My Commission Expires: 507169 CERTIFICATE OF SERVICE I, Michelle M. Milojevich, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of PLAINTIFFS' REPLY TO DEFENDANT'S NEW MATTER upon all counsel of record via postage prepaid first class United States mail addressed as follows: Kevin D. Rauch, Esquire Summers, McDonnel, Hudock, Guthrie & Skeel, PC 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 h 4 ; 1 Michelle M. Milojevich Dated: 8!31/12 507169 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DIANE L. SAKSON and ROBERT J. CIVIL DIVISION C-) SAKSON, C= Plaintiffs, -O:r � rnco ; �erq NO. 12-4659 V. =-n <C) -0 c5tn MATTHEW D. LENHARDT, (Jury Trial Demanded) 3:-n z " Defendant. Zn PRAECIPE TO DISCONTINUE TO: Prothonotary Please mark the above-referenced case discontinued, with prejudice. Respectfully submitted, ANGINO & ROVNE By: Richard,Ak q , Esquire Counsel for Plaintiff