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12-4830
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ?V ' ,l?TlltaOjA No. I ot- `rB36 t az 43 Civil Action - Law X012 Atli t;13 aNTH V?MgERI. JURY TRIAL DEMANDED NSYNla ALAN ROMANKO, ROSA LIN Plaintiff Versus and DAN LODGE INC. t/d/b/a COMFORT INN WEST, Defendants PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue writ of summons in the above-captioned action. X Writ of Summons shall be issued and forwarded to ) eriff TIMOTHY A. SHOLLENBERGER, ESQUIRE Shollenberger & Januzzi, LLP Si natu orney 2225 Millennium Way Supreme Court I.D. No. 34343 Enola, Pennsylvania 17025 (717) 728-3200 Date:Ah&j 30,2_0 U. I V_ WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANTS: ROSA LIN, 2 Dovecote Lane, Malvern, PA 19355 and DANLODGE, INC. t/d/b/a COMFORT INN WEST, 6325 Carlisle Pike, Mechanicsburg, PA 17050. YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION k' $7?SFS AGAINST YOU. Date: 1b 11A Prothonotary/Clerk of Courts - Civil Division b Deputy ( ) Check here if reverse is issued for additional information f Of:' Ti l jG nr 0 rl�hl, SHOLLENBERGER & JANUZZI, LLP 1Qj�� 2 2225 Millennium Way ' PM �Ui�*" Enola, Pennsylvania 17025 SERLA�jp Telephone Number: (717) 728-3200 PE"SYLVAlaA Y Fax Number: (717) 728-3400 Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED NOTICE, 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 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 REDUCE FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA. 17013 (717) 249-3166 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por,abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomaro medidas y puede entrar una orden contra usted sin previo aviso o notoficacaion y por cualquier queja o alivio que es pedido en la peticion do demanda. usted puede perder dinero o sus propiededas o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAIL SERVICIO,VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE P,UEDA PROVEER INFORMACION SOBRE LAS AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CORGO O BAJO COSTO A PERSONAS QUE CUALIFICAN.Lawyer Referral and Information Service CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA. 17013 (717) 249-3166 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, ALAN ROMANKO, by and through his attorneys, SHOLLENBERGER & JANUZZI, LLP, and respectfully represents the following: 1. Plaintiff, ALAN ROMANKO, is an adult individual who currently resides at 2212 S. 3rd Street, Steelton, Dauphin County, Pennsylvania. 2. Defendant, ROSA LIN, is an adult individual whose last known address is 2 Dovecote Lane, Malvern, Chester County, Pennsylvania. 3. Defendant, DANLODGE, INC. t/d/b/a COMFORT INN WEST (hereinafter referred to as "COMFORT INN WEST") is a Pennsylvania corporation with corporate offices located at 6325 Carlisle Pike, Mechanicsburg, Cumberland County, Pennsylvania. 4. The facts and circumstances hereinafter set forth took place on October 25, 2010 at or about 10:00 a.m. at the intersection of Route 11/Carlisle Pike and Lexus Lane in Silver Spring Township, Cumberland County, Pennsylvania. 5. At the aforesaid time and place, Plaintiff, ALAN ROMANKO, was the owner and operator of a 1993 Harley Davidson motorcycle, bearing Pennsylvania registration GBH 15. 6. At the aforesaid time and place, Defendant, ROSA LIN, was the operator of a 2008 Lexus ES-350 owned by DANLODGE, INC. t/d/b/a/ COMFORT INN WEST, bearing Pennsylvania registration DRX9489. 7. At the aforesaid time and place, Defendant, ROSA LIN was acting as the agent and/or employee of Defendant, COMFORT INN WEST and was operating the aforesaid 2008 Lexus ES-350 within the course and scope of the agency and/or employment relationship with Defendant, COMFORT INN WEST. 8. At the aforesaid time and place, Plaintiff, ALAN ROMANKO was operating the aforesaid 1993 Harley Davidson motorcycle northbound on Route 11/Carlisle Pike in Silver Spring Township, Cumberland County, Pennsylvania. 9. At the aforesaid time and place, Defendant, ROSA LIN, was operating the aforesaid 2008 Lexus ES-350 southbound on Route 11/Carlisle Pike in Silver Spring Township, Cumberland County, Pennsylvania and attempted to turn the vehicle left onto Lexus Lane, directly into the path of the oncoming motorcycle operated by the Plaintiff, ALAN ROMANKO, whereupon the vehicles collided. 10. As a result of the aforesaid collision, Plaintiff, ALAN ROMANKO, has suffered serious and permanent injuries, including but not limited to the following: a. APC three ring pelvic disruption with APC two injury on the right, APC three injury on the left; b. Injury to the urethra; C. .Fracture of the transverse processes of the 4th and 5th lumbar vertebrae; d. Soft tissue injury to the right thumb; and e. Multiple hand lacerations. 11. The aforesaid collision was the direct and proximate result of the negligence of the Defendant, DANLODGE, INC. t/d/b/a COMFORT INN WEST, acting through its agent and employee, ROSA LIN and of the negligence of the Defendant, ROSA LIN, Individually, in operating the 2008 Lexus ES-350 in a careless manner as follows: a. Turning her vehicle left within an intersection without yielding the right of way to a vehicle approaching in the opposite direction which was so close as to constitute a hazard in violation of Section 3322 of The PA Motor Vehicle Code; b. Driving her motor vehicle in such a manner as to deprive a motorcycle of the full use of its lane of travel in violation of Section 3523 (a) of The PA. Motor Vehicle Code; C. Turning her vehicle before the movement could be made with reasonable safety and without giving an appropriate signal in violation of Section 3334 (a) of The PA Motor Vehicle Code; d. In failing to have her vehicle under proper and adequate control; e. In failing to apply the brakes in time to avoid the collision; f. In failing to observe Plaintiff's vehicle on the highway; g. In failing to exercise the high degree of care required of a motorist entering an intersection; h. In failing to keep a reasonable look-out for other vehicles lawfully on the. road; i. In attempting to enter an intersection when such movement could not be safely accomplished; j. In turning in such a manner as to endanger other vehicles on the highway; k. In failing to observe oncoming traffic; I. In proceeding through an intersection when such movement could not be made in safety; M. In failing to keep a proper look-out for approaching vehicles; n. In failing to yield the right-of-way to on-coming traffic; and o. In failing to yield half of the highway to on-coming traffic. 12. As a direct and proximate result of the aforesaid injuries, Plaintiff, ALAN ROMANKO, has undergone and in the future will undergo great pain and suffering for which damages are claimed. 13. As a further result of the aforesaid injuries, Plaintiff, ALAN ROMANKO, has suffered and may continue to suffer a loss of earnings for which damages are claimed. 14. As a further result of the aforesaid injuries, Plaintiff, ALAN ROMANKO, has and/or may in the future incur a loss of earning capacity for which damages are claimed. 15. As 'a further result of the aforesaid injuries, Plaintiff, ALAN ROMANKO, has sustained scarring and disfigurement for which damages are claimed. 16. As a further result of the aforesaid injuries, Plaintiff, ALAN ROMANKO, has sustained a permanent diminution in his ability to enjoy.life and life's pleasures for which damages are claimed. 17. As a further result of this collision, Plaintiff, ALAN ROMANKO, has and/or may incur reasonable and necessary medical and rehabilitative costs and expenses in excess of the amounts paid or payable pursuant to Subchapter B of the Pennsylvania Motor Vehicle Financial Responsibility Law, Workers' Compensation or any program, group contract, or other arrangement for payment of benefits as defined in 75 Pa. C.S.A. Section 1719. 18. As a further result of the aforesaid injuries, Plaintiff, ALAN ROMANKO, has incurred or may hereinafter incur financial expenses and losses which exceed sums recoverable under the limitations and exclusions of the Pennsylvania Motor Vehicle Financial Responsibility Law for which damages are claimed. 19. Plaintiff, ALAN ROMANKO, was occupying a motorcycle at the time of the collision, which is not a private passenger motor vehicle. Therefore, Plaintiff, ALAN ROMANKO, remains eligible to claim compensation for non-economic loss and economic loss sustained in this collision pursuant to applicable tort law. WHEREFORE, Plaintiff, ALAN ROMANKO, demands judgment against Defendants, ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST for compensatory damages in an amount in excess of the amount requiring compulsory arbitration. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP Attorneys for Plaintiff By: Timothy A. Shollenberger, Esquire Attorney I.D. #34343 Dated: 7uHe 13 Zo i3 VERIFICATION I, Alan Romanko, hereby acknowledge that I am a Plaintiff in this action and that I have read the Complaint and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. —6"e_ AI Romanko Date: tall 3 112 SHOLLENBERGER&JANUZZI,LLP 2225 Millennium Way,Enola,PA 17025 (717)728-3200!FAX(717)728-3200 SHOLLENBERGER & JANUZZI, LLPFE° 'UF��� . 2225 Millennium.Way � { Jul 0�, 0ly Enola, Pennsylvania 17025 gr, Telephone Number: "(717)'-728-3200- ptl P 0 Fax Number: 717 728-3400 P� 14S.. No Attorneys for Plaintff: ' SY vX ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED PRAECIPE TO REINSTATE COMPLAINT To the Dauphin County Prothonotary: Please reinstate the Complaint against Defendants, Rosa Lin and DanLodge, Inc. t/d/b/a Comfort Inn West. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP Attorney for Plaintiff t By: Timothy A. ShOflengerger7Esq uire Attorney I.D. #34343 i Dated: o7boit, to 90� F i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson r;Lt€�-�J► ; !( 4„ Sheriff Pii � � d+ Jody S Smith ;. U Chief Deputy JUL APi 9: Richard W Stewart " '" "- ' WMBERLAHO COON' Y Solicitor OFF IGEOFTYF VEER IFir pENNCSYi {toMA Alan Romanko Case Number vs. Rosa Lin (et al.) 2012-4830 SHERIFF'S RETURN OF SERVICE 06/21/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Rosa Lin, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Chester, Pennsylvania to serve the within Complaint&Notice according to law. 06/21/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: DanLodge, Inc.t/d/b/Comfort Inn West, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Complaint& Notice as "Not Found"at 6325 Carlisle Pike, Hampden Township, Mechanicsburg, PA 17050. Business is under new management now run by Neema Hospitality, general manager is James Gordon. 07/01/2013 The requested Complaint& Notice served by the Sheriff of Chester County upon Rosa Lin, personally, at 2 Dovecote Lane, Malvern, PA 19355. Carolyn B. Welsh, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $69.76 SO ANSWERS, July 11, 2013 RON RANDERSON, SHERIFF (c)CcuntySuite Sheriff,Teleosoft,Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson �«'8t E-11416'. Sheriff Jody S Smith Richard W Stewart Chief Deputy OFFICE OF TPE&NERIFF Solicitor Alan Romanko Case Number vs Rosa.Lin (et al.) 2012-4830 0 SERVICE COVER SHEET N Service Details: o Category: ICivil Action -Complaint& Notice Zone: C _J X Manner: Deputize Expires: 07/19/2013 Warrant: w Notes: M M r a Serve To Final Service: 2F Name: lRosa Lin Served. ersonally dult In Charge Posted Other > Primary 2 Dovecote Lane Adult In T n Q Address: Malvern, PA 19355 Charge: zPhone: DOB: Relation: �-� Q INLI-1 Alternate Date: Time: Address: v Phone: Deputy: Y l ' e Y Mileage: O Attorney/Originator: Name: Timothy A. Shollenberger Phone: 717-728-3200 Service Attempts: _ Date: M Time: 00 N Mileage: N Deputy: Notes/Special Instructions: -- Now, June 21, 2013 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Chester County to execute service of the documents herewith and mAW-eturnthereof i w. co 0 .Return To: z Cumberland County Sheriffs ::i One Courthouse Square Carlisle, PA 17013' Ronny R Anderson, Sheriff ;i Fr1 E�-Or`FlC�. 01F THE ARCTHOq TAR'r �1 l7 JELL 22 PM 2. 1 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE Kindly enter the appearance of Robert A. Lerman, Esquire and Thomas B. Sponaugle, Esquire of Griffith, Strickler,Lerman, Solymos & Calkins, as attorneys for Defendants, Rosa Lin and Dan Lodge, Inc. t/d/b/a Comfort Inn West the above-captioned matter and mark the docket accordingly. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS BY: � Robert A. Le an, Esquire P 7490 BY: Thomas B. SpWggle,E ire PA#64584 Attorney for Defendants 110 South Northern Way York, PA 17402 717-757-7602/717-757-3783 fax rierman@gslsc.com/tsponaugle@gslsc.com Dated: July 19, 2013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 19th day of July, 2013, 1, Robert A. Lerman, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of the Praecipe for Entry of Appearance by United States Mail, addressed to the party or attorney of record as follows: Timothy A. Shollenberger, Esquire Shollenberger& Januzzi, LLP 2225 Millennium Way Enola, PA 17025 (Counsel for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS Robert A. Lerman, Esquire PA#07490 Attorney for Defendants 110 South Northern Way York, PA 17402 717-757-7602/717-757-3783 fax rlerman@gslsc.com jml/danlodge-prp E1 LED-0,'FICE OF THE PROTHONOTARY SHOLLENBERGER & JANUZZI, LLP JUL O �� � , 2225 Millennium Way Enola, Pennsylvania 17025 CUMBERLAND COUNTY Telephone Number: (717) 728-3200 PENNSYLVANIA Fax Number: (717) 728-3400 Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE, And now,.this CJ day f 2013 1 hereby certify that a co of the Y � Y fY copy foregoing Interrogatories have b n se d upon the following, U.S. First Class Mail: Rosa Lin c/o Robert A. Lerman, Esquire Law Offices Griffith, Strickler, Lerman, Solymos &Calkins 110 S. Northern Way York, PA 17402-3737 SHOLLE BERGER & JANUZZI, LLP By: o y holl nberger, Esq. jF-Attorney I D#34343 31 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY! ENOLA,PA 17025 (717)728-3200!FAX(717)728-3400 SHOLLENBERGER & JANUZZI, LLP OF THE PR©T/{p CE- 203 JUL R r 2225 Millennium Way J�l �p ���` �� Enola, Pennsylvania 17025 �UP�B�RL ANt? Telephone Number: (717) 728-3200 PE1VjjS yt V ��U �.,�, Fax Number: (717) 728-3400 ANIA Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, thislW day f 2013 �1 hereby certify that a co of the Y � Y Y copy foregoing Request for Prod uctio of Do uments Set No. 1 have been served upon the following, U.S. First Class Mail: Dan Lodge, Inc. t/d/b/a Comfort Inn West c/o Robert A. Lerman, ;Esquire Law Offices Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402-3737 SHOLLENBERGER & JANUZZI, LLP BY *mo A. Shollenberger, Esq. Attorney I D#34343 THE FILED OF+`IC- SHOLLENBERGER & JANUZZI, LLP TNT I'ROTNO ?07/AR 2225 Millennium Way 7013 JUL 30 fN 11: 13 Enola, Pennsylvania 17025 1111" ;RLAND COUNTY Telephone Number: (717) 728-3200 P✓~NNs Fax Number: (717) 728-3400 I LAMA Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, ti-iiscl, day o , 2013, 1 hereby certif.Y that a copy of the foregoing Request for Productio of Documents Set No. 1 have been served upon the following, U.S. First Class Mail. Rosa Lin c/o Robert A. Lerman, Esquire Law Offices Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402-3737 SHOLLENBERGER & JANUZZI, LLP P. Z*1002 . '/'A A air- AR Af AV jAo0Ty A. enb rger, Esq. Attorney ID#34343 01 -r > ` t o a or oi�1 ,. SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way 2313 JUL 30 AM 11: 13 Enola, Pennsylvania 17025 CUMBERLAND COUNTY Telephone Number: (717) 728-3200 PENNSYLVANIA LAND CO Fax Number: (717) 728-3400 Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, thisZ day;of , 20.13, I hereby certify that a copy of the foregoing Interrogatories have be serfed upon the following, U.S. First Class Mail: Dan :Lodge, Inc. t/d/b/a Comfort Inn West c/o Robert A. Lerman, Esquire. Law Offices Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402-3737 SHOLLENBERGER & JANUZZI, LLP By: Tim by ollenberger, Esq. Attorney ID#34343 22 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY! ENOLA,PA 17025 (717)728-3200!FAX(717)728-3400 ,U�JBE RL AWD C" �OUNTY IN THE COURT OF COMM O AA1 OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE Kindly enter the appearance of Ann Margaret Grab, Esquire of Griffith, Strickler, Lerman, Solymos & Calkins, as attorneys for Defendants, Rosa Lin and Dan Lodge, Inc. t/d/b/a Comfort Inn West the above-captioned matter and mark the docket accordingly. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS i BY: i AAA ANN MARGARET GRAB, ESQUIRE PA#55986 Attorney for Defendants 110 South Northern Way York, PA 17402 717-757-7602/717-75773783 fax amgrab @gslsc.com Dated: July 30, 2013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 30'h day of July, 2013, I, Ann Margaret Grab, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of the Praecipe for Entry of Appearance by United States Mail, addressed to the party or attorney of record as follows: Timothy A. Shollenberger, Esquire Shollenberger& Januzzi, LLP 2225 Millennium Way Enola, PA 17025 (Counsel for Plaintiff) 1 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS BY: All Ann Margaret Gr , Esquire PA#55986 Attorney for Defendants 110 South Northern Way York, PA 17402 717-757-7602/717-757-3783 fax amgrrabgp,slsc.com jml/danlodge-prp ����U��«� ����U��� ��� CUMBERLAND ��d����� SHERIFF'S" ~° ~=" " "~=^~ ��" ~°~°"°"��~~"�^�"�"�~° COUNTY " Ronny RAnderson F!L E D-40 FFITc TH IF PR.O T A O'NUO'I"' IR'' Sheriff of Jody GSmith 01 w 701'3 AUG 8�� (0� °� Chief Deputy ^°'^ "«° ° ",. .° u', Richard VVStewart CUMBERLAND COUNfY Solicitor OPno emmewwER11PP PENNSYLVANIA A|anRomanko Case Number vs. Rosa Lin (et ai) | 2012-4830 SHERIFF'S RETURN OF SERVICE 07/10/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: DanLodge, Inc. t/d/b/Comfort Inn West, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Chester, Pennsylvania to serve the within Complaint& Notice according bolaw. 07/15/2013 04:10 PM -The requested Complaint &Notice served by the Sheriff of Chester County upon Rosa Lin, who accepted for DanLodgo. Inc. t/d/b/Comfort Inn West, at2 Dovecote Lane, Malvern, PA1Q355. Carolyn VVe|ah, Sheriff, Return of Service attached to and made part cf the within record. SHERIFF COST: $37.46 SO ANSWERS, July 2Q. 2U13 RONWR ANDERSON, SHERIFF (C)CounlySuito Sheriff,Teleosoft,Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 0%v 0t'C-Inn'br�r��b Sheriff Jody S Smith Richard W Stewart Chief Deputy OFFICE OF TWE S!GRIFF Solicitor Alan Romanko - 2-0-13 2P vs. Case Number Rosa Lin (et al.) 2012-4830 0 SERVICE COVER SHEET 7 � N c Service Details: to Category: ICivil Action -Complaint& Notice �l'"24 Zone: x Manner: IDeputize I Expires: 1 08/08/2013 Warrant: w Notes: M r ¢ Serve To: Fina!Service: a -- - - - 2FName: DanLodge, Inc.t/d/b/Comfort Inn West Served: Personally dult In Char Posted Other > Primary 2 Dovecote Lane Adult In f7 Q Address: Malvern, PA 19355 Charge: Li• Phone: DOB: Relation: C6-g)CC- Z wAlternate Date: 7 5 l 3 Time: `�-� Address: m] O Phone: Deputy: Uj Mileage: O Attorney/Originator. N Name: ITimothy A. Shollenberger Phone: 717-728-3200 Service Attempts: Date: M . Time: 00 N Mileage: N Deputy: 3 5 Notes/Special Instructions: v U D .. H V•................................................... ------------------------------------------------------ ...................... 3z' Now, July 10, 2013 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Chester County to LU execute service of the documents herewith and make returngtherreof`a466rdi6ft tai P, 0 aReturn To: ff't) n,g f• ' /11/7 _--��. Cumberland County Sheriffs Office �;ti'}�;��,� ;IL�� �('` C c One Courthouse Square •;r fl AcC. Carlisle, PA 17013 Ronny R Anderson, Sheriff ici CountySufle Sheriff,Teleosok Inc _ _ (\[j.M{_�{{ .{(ECE4VE/F07/�j( SHERIFF'S COSTS �1lY SHERIFF'S OI 1 !CE CHESTER COUNTY. PA. Date A13 A 2113 JUL 12' kM 1.P 2t $ �s� Paid _ A 11: 2-3 Receipt No. .5—,o z XE Expiration date: " ON. -` S e I I d , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED CERTILFICATE OF SERVICE AND NOW, this day of , 2013, I, Robert A. Lerman, a member of the firm of GRIFFITH, ST CKLER, LE RM N, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of the Interrogatories of Defendants, Rosa Lin and Dan Lodge, Inc. t/d/b/a Comfort Inn West, to Plaintiff, Set No. 2 by United States Mail, addressed to the party or attorney of record as follows: Timothy A.8hollenberger, Esquire Shollenberger&Januzzi, LLP 2225 Millennium Way Enola,,PA 17025 (Plaintiff's Counsel) GRIFFITH,'S CKLER, LERMAN, SOLYMOS & CAL S BY: ROf3ERT A. LERMAN, ESQUIRE#PA07490 Attorney for Defendants 110 South Northern Way York, PA 17402 717-757-7602/717-757-3.783 Fax a rlemian@gslsc.com rn , :Z:;o jml/danlodge-int2 Cn c` ;Z C) N) CD1 ` I I IN THE COURT OF CQMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this x day of , 2013, I, Robert A. Lerman, a member of the firm of GRIFFITH, STRICKLER, LERMANOSOLYMOS &CALKINS,hereby certify that I have this date served a copy of the Interrogatories of Defendants, Rosa Lin and Dan Lodge, Inc. t/d/b/a Comfort Inn West,to Plaintiff,Set No. 1 by United States Mail,addressed to the party or attorney of record as follows: Timothy A. Shollenberger, Esquire Shollenberger&Januzzi, LLP 2225 Millennium Way Enola, PA 17025 (Plaintiff s Counsel) GRIFFIRERT ER, LERMAN, SOLYMOS & BY: A. LERMAN, ESQUIRE #PA07490 Attorney for Defendants 110 South Northern Way York, PA 17402 717-757-7602/717-757-3783 Fax rlerman@gslsc.com jml/danlodge-int - �: ter c:: --DZK to Co r*rn rte-"W: <G ::f C A n CJ CD N ©C- {-.,. 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this day of 2013, I, Robert A. Lerman, a member of the firm of GRIFFITH,- STRICKLER; LERM , SOLYMOS. & CALKINS, hereby certify that..I .: have this date served a copy of the Request for Production of Documents of Defendants,Rosa Lin and Dan Lodge, Inc. t/d/b/a Comfort Inn West, to Plaintiff, Set No. 1 by United States Mail, addressed to the party or attorney of record as follows: Timothy A.-Shollenb.erger, Esquire Shollenberger& Januzzi, LLP 2225 Millennium Way Enola, PA 17025 (Plaintiff's Co sel) GRIFFITH, RICKLER, LERMAN, SOLYMOS & CAL INS BY: ROBERT A. L-ERMAN, ESQUIRE#PA07490 Attorney for Defendants 110 South Northern Way York,- PA 17402 , 717-757-7602/717-757-3783 Fax rlerman@gslsc.com' jm1/dan1odge-rfpd c �{] ' CA.) C rTr ,1 cn►— r © -� c� J�Cz � c �� �r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. : No. 12-4830 ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED TO: Alan Romanko, Plaintiff c/o Timothy A. Shollenberger, Esquire r Shollenberger&Januzzi, LLP -uy 2225 Millennium Way Enola, PA 17025 < NOTICE TO PLEAD ' You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. GRIFFITH, RICKLER, LERMA , SOLYMM & C S By: OBERT A. LERMA ,ESQUIRE PA#07490 ANN MARGARET GRAB, ESQUIRE PA#55986 Attorney for Defendants 110 South Northern Way York, PA 17402 717-757-7602/717-757-3783 fax rlermana,2slsc.com/ajzrabggslsc.com Dated: U 3 , 2013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANTS,ROSA LIN AND DANLODGE, INC. t/d/b/a COMFORT INN WEST TO PLAINTIFF'S COMPLAINT AND NOW, come Defendants, Rosa Lin and Danlodge, Inc. t/d/b/a Comfort Inn West, by their counsel, Robert A. Lerman and Ann Margaret Grab, Esquire, Griffith, Strickler, Lerman, Solymos & Calkins, and files the following Answer and New Matter to Plaintiff's Complaint as follows: 1. Admitted upon information and belief. 2. Admitted. 3. Denied as stated. On the contrary,it is averred that Danlodge,Inc. is a Pennsylvania domestic business corporation,no longer active and no longer with corporate offices located at 6325 Carlisle Pike, Mechanicsburg, Cumberland County, Pennsylvania. 4. Denied. On the contrary, it is averred that on October 25, 2010 at approximately 10:00 a.m. at the intersection of Route 11/Carlisle Pike and Lexus Lane in Silver Spring Township, Cumberland County, Pennsylvania, an accident occurred. 5. Admitted upon information and belief. v 6. Admitted in part, denied in part. It is admitted that on October 25, 2010 at approximately 10:00 a.m.,Defendant,Rosa Lin was the operator of a 2008 Lexus ES-350 owned by Danlodge, Inc., bearing Pennsylvania registration DRX-9489. 7. Denied as stated. On the contrary, it is averred that at all times relevant,Defendant, Rosa Lin was an owner of Defendant,Danlodge,Inc.t/d/b/a Comfort Inn West and further averred that she was operating the 2008 Lexus ES-350 owned by Danlodge,Inc.as one of the owners of the corporation. By way of further response, it is averred that at the time of the collision between the Plaintiff s motorcycle and the 2008 Lexus, Ms. Lin was driving the vehicle from her office to the Lexus dealership for a service appointment. 8. Admitted upon information and belief. 9. Denied as stated.On the contrary,it is averred that Defendant Lin at all times relevant operated her vehicle in a careful, lawful, reasonable and prudent manner, with due care under all circumstances existing. 10. Denied. After reasonable investigation,answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 10 of Plaintiff's Complaint and same are denied and strict proof thereof demanded. 11. Denied. To the extent the allegations set forth in paragraph 11 of Plaintiff's Complaint constitute a conclusion of law, no response is required. To the extent a response is required,it is specifically denied that the collision described in Plaintiff's Complaint was the direct and proximate result of the negligence of the Defendant,Danlodge, Inc.t/d/b/a Comfort Inn West, acting through its agent and employee, Rosa Lin and it is denied that the collision described in Plaintiff's Complaint was the direct and proximate result of the negligence of the Defendant,Rosa 2 Lin, individually, in operating the 2008 Lexus ES-350. It is further denied that Ms. Lin acted in a negligent or careless manner and strict proof thereof is hereby demanded. By way of further response, it is specifically denied that Rosa Lin was negligent in: a. Turning her vehicle left within an intersection without yielding the right of way to a vehicle approaching in the opposite direction which was so close as to constitute a hazard in violation of Section 3322 of The PA Motor Vehicle Code; b. Driving her motor vehicle in such a manner as to deprive a motorcycle of the full use of its lane of travel in violation of Section 3523(a)of The PA Motor Vehicle Code; C. Turning her vehicle before the movement could be made with reasonable safety and without giving an appropriate signal in violation of Section 3334(a) of The PA Motor Vehicle Code; d. In failing to have her vehicle under proper and adequate control; e. In failing to apply the brakes in time to avoid the collision; f. In failing to observe Plaintiff's vehicle on the highway; g. In failing to exercise the high degree of care required of a motorist entering an intersection; h. In failing to keep a reasonable look-out for other vehicles lawfully on the road; i. In attempting to enter an intersection when such movement could not be safely accomplished; 3 j. In turning in such a manner as to endanger other vehicles on the highway; k. In failing to observe oncoming traffic; 1. In proceeding through an intersection when such movement could not be made in safety; M. In failing to keep a proper look-out for approaching vehicles; n. In failing to yield the right-of-way to on-coming traffic; and o. In failing to yield half of the highway to on-coming traffic. On the contrary,it is averred that Rosa Lin,at all times relevant,operated the Lexus motor vehicle in a careful, lawful,reasonable and prudent manner,with due care under the circumstances,fulfilling all duties required of her by law in the operation of said motor vehicle and strict proof to the contrary is hereby demanded. By way of further response, it is averred that the collision described in Plaintiff's Complaint may have been due solely or partially to the negligence and carelessness of the Plaintiff, Alan Romanko, as more specifically set forth hereinafter. 12. Denied. After reasonable investigation,answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 12 of Plaintiff's Complaint and same are denied and strict proof thereof demanded. 13. Denied. After reasonable investigation,answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 13 of Plaintiff's Complaint and same are denied and strict proof thereof demanded. 14. Denied. After reasonable investigation,answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 14 of Plaintiff's Complaint and same are denied and strict proof thereof demanded. 4 15. Denied. After reasonable investigation,answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 15 of Plaintiff's Complaint and same are denied and strict proof thereof demanded. 16. Denied. After reasonable investigation,Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 16 of Plaintiff's Complaint and same are denied and strict proof thereof demanded. 17. Denied. To the extent the allegations set forth in paragraph 17 constitute a conclusion of law, no response is required. To the extent a response is required;Answering Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 17 of Plaintiff's Complaint and same are denied and strict proof thereof demanded. 18. Denied. To the extent the allegations set forth in paragraph 18 constitute a conclusion of law, no response is required. To the extent a response is required, Answering Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 18 of Plaintiff's Complaint and same are denied and strict proof thereof demanded. 19. Denied. To the extent the allegations set forth in paragraph 19 constitute a conclusion of law, no response is required. To the extent a response is required, Answering Defendants are without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 19 of Plaintiff's Complaint and same are denied and strict proof thereof demanded. 5 WHEREFORE,Defendants,Rosa Lin and Danlodge,Inc.t/d/b/a Comfort Inn West,demands judgment in their favor and against the Plaintiff, Alan Romanko, together with costs of suit. By way of further answer, Defendants, Rosa Lin and Danlodge, Inc. t/d/b/a Comfort Inn West, assert the following: NEW MATTER 20. Answering Defendants responses to paragraphs 1 through 19 hereinabove are incorporated herein by reference as if fully set forth at length. 21. Plaintiff's Complaint fails to state a cause of action against Defendant, Rosa Lin, upon which relief can be granted. 22. Plaintiff's Complaint fails to state a cause of action against Defendant, Danlodge, Inc. t/d/b/a Comfort Inn West, upon which relief can be granted. 23. Plaintiff's Complaint may be barred by an applicable statute of limitation. 24. At all times relevant, Defendant, Rosa Lin, acted carefully, lawfully, reasonably, properly and prudently with due care under the circumstances existing. 25. At all times relevant, Defendant, Danlodge, Inc. t/d/b/a Comfort Inn West, acted carefully, lawfully, reasonably, properly and prudently with due care under the circumstances existing. 26. At all times relevant,the incident which gives rise to the injuries and damage claims asserted by Plaintiff were the result of Plaintiff's loss of control of his motorcycle and were caused by no act or failure to act on the part of the Defendants. 6 27. The Plaintiff's claimed injuries and damages are the direct factual sole and proximate result of the negligence and carelessness of the Plaintiff, Alan Romanko, generally and more specifically as set forth below: a. In failing to be reasonably vigilant to observe the road and traffic conditions then and there existing; b. By operating his motorcycle at an unsafe speed for the geography of the intersection in question, thereby creating a hazard to himself and others lawfully on the roadway; C. In failing to operate his motorcycle in a safe,prudent and careful manner in view of the geography of the intersection and traffic conditions existing; d. In failing to operate his motorcycle at a speed that was safe for existing conditions in violation of 75 Pa. C.S.A. §3361; e. In failing to operate his motorcycle at a speed that was safe for the geography of the intersection and traffic conditions existing, in violation of 75 Pa. C.S.A. §3361; f. In failing to operate his motorcycle at a speed that was safe for actual or potential hazards then existing in violation of in violation of 75 Pa. C.S.A. §3361; g. In failing to keep a proper lookout for other vehicles lawfully and legally in the vicinity of the roadway upon which he was traveling; h. In failing to exercise reasonable care in the operation and control of his motorcycle in violation of 75 Pa. C.S.A. §3314; 7 i. In failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in failing to have his motorcycle under such control that injury to himself or his property could be avoided; j. In failing to take appropriate and careful evasive action, in view of the geography of the intersection and the highway traffic conditions existing; k. In otherwise driving his motorcycle upon\the roadway in a manner endangering himself and in a manner with careless disregard to his safety in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania; . 1. In carelessly operating his motorcycle in violation of 75 Pa C.S.A. §3714; m. In failing to keep alert and maintain a proper lookout; n. In failing to maintain proper control in the operation of his motorcycle; and negligently, carelessly and recklessly operating his motorcycle at a speed in excess of the posted speed limit or at an unsafe speed in violation of 75 Pa. C.S.A. §3362; o. In failing to wear appropriate and proper protective clothing including but not limited to a safety helmet in violation of 75 Pa. C.S.A. §3525; P. In failing to display an operable headlamp on his motorcycle and/or failing to have his headlamp activated in violation of 75 Pa. C.S.A. §3526; q. In utilizing headphones or earphones in violation of 75 Pa. C.S.A. §3314; r. In failing to obey all traffic laws as required by 75 Pa. C.S.A. §3521; S. In operating a motorcycle without being properly trained; 8 t. In breaching his required duty of care as to a motorist with only a qualified right-of-way at the intersection in question; U. In failing to take appropriate and prudent evasive action to avoid the collision when he had the last chance and/or last opportunity to do so. 28. As a result of the negligence, carelessness and recklessness of the Plaintiff, Alan Romanko,as set forth in the immediately preceding paragraphs,the claims of Plaintiff are barred or diminished in accordance with the application of the Pennsylvania Comparative Negligence Act,42 Pa C.S.A. §7102. 29. Plaintiff may not have sustained a serious injury as defined in the Pennsylvania Motor Vehicle Financial Responsibility Law(75 Pa. C.S.A. §1702 etseq.). 30. Plaintiff's claims for non-economic damages may have barred because Plaintiff has elected a limited tort option as set forth in the Pennsylvania Motor Vehicle Financial Responsibility Law. 31. Plaintiff may have failed to mitigate his damages. 32. Plaintiff has received or is entitled to receive various benefits from insurance arrangements,programs and group contracts of insurance including but not limited to benefits under the Pennsylvania Motor Vehicle Financial Responsibility Law,for medical bills and/or income loss, and he may not recover for the same benefits in this proceeding. 33. Plaintiff has recovered from some or all of the injuries he allegedly sustained as a result of the alleged incident. 34. Some or all of Plaintiffs alleged injuries and damages may have preexisted or preceded the date of the alleged incident and were not caused or aggravated by the alleged incident. 9 1 35. Some of Plaintiff's alleged injuries and damages may have been sustained or have occurred subsequent to the alleged incident and were not caused by the alleged incident. 36. Some or all of the damages requested in Plaintiff's Complaint may not be recoverable in this action against Answering Defendants. 37. Plaintiff assumed the risk of the injuries and damages he allegedly sustained. 38. Answering Defendants aver that if any liability is found for conduct on the part of either Defendant, such conduct was not the proximate or factual cause of the incident and/or Plaintiff's injuries and damages. WHEREFORE,Defendants,Rosa Lin and Danlodge,Inc.t/d/b/a Comfort Inn West,demands judgment in their favor and against the Plaintiff,together with costs of suit. GRIFFIT , TRICKLER,LERMAN, S YMOS & CALKIN By: ROBERT A. LERMAN, ESQUIRE PA# 07490 ANN MARGARET GRAB, ESQUIRE PA#55986 Attorney for Defendants 110 South Northern Way York,PA 17402 717-757-7602/717-757-3783 fax Dated. i , 2013 rlerman gaslsc.com/amgrabggslsc.com 10 VERIFICATION 1, Huei Mini Lin ,hereby verify that the statements made in the foregoing Answer and New Matter to Plaintiff s Complaint are true and correct to the best of my personal knowledge or information and belief,as well as reports,records,conferences and other investigatory material made available to me. To the extent that the foregoing contains averments which are inconsistent in fact,I verify that my knowledge or information is sufficient to form a belief that one or more of them is true, although I am currently unable, after reasonable investigation, to ascertain which of the inconsistent averments are true. To the extent that the foregoing contains legal conclusions or opinions,I hereby state that my Verification is made upon the advice of counsel, upon whom I have relied in the filing this document. This Verification is made subject to the penalties of 18 Pa. C.S. § 4904 related to unsworn falsifications to authorities. Danlodge., Inc. t/d/b/a Comfort Inn West Dated: By: VERIFICATION I,Rosa Lin,hereby verify that the statements made in the foregoing Answer and New Matter to Plaintiff s Complaint are true and correct to the best of my personal knowledge or information and belief,as well as reports,records,conferences and other investigatory material made available to me. To the extent that the foregoing contains averments which are inconsistent in fact,I verify that my knowledge or information is sufficient to form a belief that one or more of them is true,although I am currently unable,after reasonable investigation,to ascertain which of the inconsistent averments are true. To the extent that the foregoing contains legal conclusions or opinions,I hereby state that my Verification -is made upon the advice of counsel, upon whom I have relied in the filing this document. This Verification is made subject to the penalties of 18 Pa. C.S. § 4904 related to unsworn falsifications to authorities. Dated: 7 �_ By: o ROSA LIN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DANLODGE,INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW,this 13 day of S 2013,1,Robert A.Lerman,Esquire,a member of the firm of GRIFFITH,STRICKLE*R,X-MA ,SOLYMOS&CALKINS,hereby certify that I have this date served a copy of the Answer and New Matter of Defendants, Rosa Lin and Danlodge, Inc. t/d1b/a Comfort Inn West to Plaintiffs Complaint, by United States Mail, addressed to the party or attorney of record as follows: Timothy A. Shollenberger,Esquire Shollenberger&Januzzi,LLP 2225 Millennium Way Enola, PA 17025 (Counsel for Plaintiff) GRIFFITH, STRIPkLER,LERMAN, SOL S &CALKINS BY: BERT A. LERMAN,ESQUIRE PA#07490 Attorney for Defendants 110 South Northern Way York,PA 17402 717-757-7602/717-757-3783 fax rlemian@p,slsc.com r r HE PRO TA R Y SHOLLENBERGER & JANUZZI, LLP1 ( �r27 F' 2225 Millennium Way 2; 08 Enola, Pennsylvania 17025 eUMB�R��N!) ` Telephone N mber: (717) 728-3200 p£ SYCVAN1�HrY ` Fax Number: (717) 728-3400 Attorneys for Plaintiff ! ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. i NO. 12-4830 ROSA LIN.and:DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED i . PLAINTIFF'S REPLY TO DEFENDANT'S. NEW MATTER r AND NOW comes the Plaintiff, ALAN ROMANKO, by and through his attorneys SHOLLENBERGER & JANUZZI, and file this Reply to New Matter of Defendants, respectfully representing the following: 20. Paragraphs 1 through 19 of the Plaintiffs Complaint are incorporated herein by reference as if set forth in full. i 21. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). 22. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). r 23. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). ` 24. Said averment is denied pursuant to Pa. R.C.P. 1029(e). By way of further response, Plaintiff, Alan Romanko, hereby specifically incorporates paragraphs 9 and 11 of his Complaint. i 25. Said averment is denied pursuant to Pa. R.C.P. 1029(e). By way of i r E s further response, Plaintiff, Alan Romanko, hereby specifically incorporates paragraphs 9 and 11 of the Complaint. 26. Said averment is denied pursuant to Pa. R.C.P. 1029(e). Byway of further response, Plaintiff, Alan Romanko, hereby specifically incorporates paragraph 9 and 11 of his Complaint. 27. Denied. To the extent the allegations set forth in paragraph 27 of Defendants' New Matter constitute a conclusion of law, no response is required. To the extent a response is required it is specifically denied that the Plaintiff's claimed injuries and damages are the direct factual sole and proximate result of the negligence and carelessness of the Plaintiff, Alan Romanko. EL It is specifically denied that Plaintiff failed to be reasonably vigilant to observe the road and traffic conditions then and there existing; b. It is specifically denied that Plaintiff operated his motorcycle at an unsafe speed for the geography of the intersection in question, thereby creating a hazard to himself and others lawfully on the road; C. It is specifically denied that Plaintiff failed to operate his motorcycle in a safe, prudent and careful manner in view of the geography of the intersection and traffic conditions existing; d. It is specifically denied that Plaintiff failed to operate his motorcycle at a speed that was safe for existing conditions in violation of 75 Pa.C.S.A. § 3361; e. It is specifically denied that Plaintiff failed to operate his motorcycle at a speed that was safe for the geography of the intersection and traffic conditions existing, in violation of 75 Pa.C.S.A. § 3361; f. It is specifically denied that Plaintiff failed to operate his motorcycle at a speed that was safe for actual or potential hazards then existing in violation of 75 Pa.C.S.A. § 3361; g. It is specifically denied that Plaintiff failed to keep a proper lookout for other vehicles lawfully and legally in the vicinity of the roadway upon which he was traveling; h. It is specifically denied that Plaintiff failed to exercise reasonable care in the operation and control of his motorcycle in violation of 75 Pa.C.S.A. § 3314; L It is specifically denied that Plaintiff failed to be continuously alert, failed to perceive any warning of danger that was reasonably likely to exist, and failed to have his motorcycle under such control that injury to himself or his property could be avoided; j. It is specifically denied that Plaintiff failed to take appropriate and careful evasive action, in view of the geography of the intersection and the highway traffic conditions existing; k. It is specifically denied that Plaintiff otherwise drove his motorcycle upon the roadway in a manner endangering himself and in a manner with careless disregard to safety in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania; I. It is specifically denied that Plaintiff carelessly operated his motorcycle in violation of 75 Pa. C.S.A. § 3714; M. It is specifically denied that Plaintiff failed to keep alert and maintain a proper lookout; n. It is specifically denied that Plaintiff failed to maintain proper control in the operation of his motorcycle; and negligently, carelessly and recklessly operated his motorcycle at a speed in excess of the posted speed limit or at an unsafe speed in violation of 75 Pa.C.S.A. §3362; o. It is specifically denied that Plaintiff failed to wear appropriate and proper protective clothing including but not limited to a safety helmet in violation of 75 Pa.C.S.A. §3525; p. It is specifically denied that Plaintiff failed to display an operable headlamp on his motorcycle and/or failed to have his headlamp activated . in violation of 75 Pa.C.S.A. §3526; q. It is specifically denied that Plaintiff utilized headphones or earphones in violation of 75 Pa.C.S.A. §3314; r. It is specifically denied that Plaintiff failed to obey all traffic laws as required by 75 Pa. C.S.A. §3521; S. It is specifically denied that Plaintiff operated a motorcycle without being properly trained; t. It is specifically denied that Plaintiff breached his required duty of care as to a motorist with only a qualified right-of-way at the intersection in question; U. It is specifically denied that Plaintiff failed to take appropriate and prudent evasive action to avoid the collision when he had the last chance and/or last opportunity to do so. 28. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). 29. Said averment is denied pursuant to Pa. R.C.P. 1029(e). By way of further response, Plaintiff, Alan Romanko, hereby specifically incorporates paragraph 19 of the Complaint. 30. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). By way of further response, Plaintiff, Alan Romanko, hereby specifically incorporates paragraph 19 of the Complaint. 31. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). 32. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). 33. Said averment is denied pursuant to Pa. R.C.P. 1029(e). 34. Said averment is denied pursuant to Pa. R.C.P. 1029(e). 35. Said averment is denied pursuant to Pa. R.C.P. 1029(e). 36. The above referenced averment is a conclusion of law to which no answer, is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). 37. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). 38. The above referenced averment is a conclusion of.law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, the Plaintiff respectfully request that the Defendants' New Matter be dismissed and judgment entered in favor of the Plaintiffs as a matter of law. Respectfully Submitted, SHOLLE RGER & JANUZZI, LLP Attorney f r the Plaintiff By: Ajam—F- Wo othy A. Shollenberger Attorney I.D. 34343 Date: Z 13 ' SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-4830 ROSA LIN and DAN .LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, this day of August,'2013, I hereby certify that a copy of the foregoing Plaintiff's Reply to New Matter of Defendants, has been served upon the following, via U.S. Mail: Ann Margaret Grab, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402 SHOLLEN RGER & JANUZZI, LLP By: Ti othy A. Shollenberger, Esquire Attorney ID# 34343 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA ALAN ROMANKO,. CIVIL DIVISION r> 2 Plaintiff (= ' , V. M M rn 1- No. 12-4830 =::0 -0 -0 ROSA LIN and DAN LODGE,INC.t/d/b/a COMFORT INN WEST, Defendants *C-) JURY TRIAL DEI @4IDIM .°.+r CERTIFICATE PREREQUISITE TO SERVICE Cn OF SUBPOENAS PURSUANT TO RULE 4009.22 , As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendants,Rosa Lin and Danlodge, Inc. t/d/b/a Comfort Inn West, certifies that: (1) A Notice of Intent to Serve Subpoena with a copy of the Subpoenas attached thereto was mailed or delivered to each party at least twenty(20)days prior to the date on which the Subpoenas are sought to be served; (2) A copy of the Notice of Intent, including the proposed Subpoenas, is attached to this. Certificate; (3) Plaintiff's counsel has waived 20 days notice per the attached letter; and (4) The Subpoenas which will be served are identical to the Subpoenas which are attached to the Notice of Intent to Serve the Subpoenas. GRIFFITH, ST ER,LERMAN, SOLYMOS& CAL BY: Robert A. Lerman, Esquire PA#07490 Ann Margaret Grab,Esquire PA#55986 Attorney for the Defendants 110 South Northern Way York,PA 17402 Dated: August 30,2013 717-757-7602/717-757-3783 fax rlerinangaslsc.col-n/amjzrabp,gslsc.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Robert A. Lerman, Esquire, counsel for Defendants, Rosa Lin and Danlodge, Inc. t/d/b/a Comfort Inn West, intends to serve Subpoenas identical to the ones that are 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 Subpoenas. If no objection is made,the Subpoenas may be served. GRIFFITH, CKLER, LERMAN, SOLY S & CALKINS ROBERT A. LERMAN, ESQUIRE PA#07490 ANN MARGARET GRAB,ESQUIRE PA#55986 Attorney for Defendants 110 South Northern Way York, PA 17402 Date: ( (717) 757-7602/(717) 757-3783 fax rlerman@gslsc.com/amgrab @gslsc.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Dr. Carol E. Copeland/Dr. James Flynn/Penn State Hershey Medical Center, 30 Hope Drive, Building B, Suite 2400, Hershey, PA 17033 (Name of Person or Entity) 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 office notes, reports, records, memoranda, correspondence, diagnostic tests and/or reports, consultation reports, x-rays, progress notes, hospital records, nurses notes, admission and discharge summaries and records and reports of examinations, and any other medical records of any kind pertaining to Alan Romanko, date of birth: 12/6/64 from.January 1, 2013 to the present. at Griffith, Strickler, Lerman, Solymos&Calkins, 110 S. Northern Way, York, PA 17402-3737 (Address) 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;th-e-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: ROBERT A. LERMAN, ESQ. ADDRESS: GRIFFITH, STRICKLER, LERMAN, SOLYMOS&CALKINS 110 South Northern Way, York, PA 17402 TELEPHONE: (717)757-7602 SUPREME COURT 10: 07490 ATTORNEY FOR: Defendants BY THE COURT: DATE: Seal of Court Prothonotary Clerk, Civil Division IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Dr, Carl Reese, Penn State Hershey Medical Center Urology, 500 University Drive, Suite 3100, Hershey, PA 17033 (Name of Person or Entity) 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 office notes, reports, records, memoranda, correspondence, diagnostic tests and/or reports, consultation reports, x-rays, progress notes, hospital records, nurses notes, admission and discharge summaries and records and reports of examinations, and any other medical records of any kind pertaining to Alan Romanko, date of birth: 12/6154 from January 1, 2013 to the present. at Griffith, Strickler, Lerman, Solymos&Calkins, 110 S. Northern Way, York, PA 17402-3737 (Address) 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. -Ybu-havetye-right la-seek-inadvance,-he-reaso nabl�cost-of pnela i ng-the copies or producing t 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: ROBERT A. LERMAN, ESQ. ADDRESS: GRIFFITH, STRICKLER, LERMAN, SOLYMOS &CALKINS 110 South Northern Way, York, PA 17402 TELEPHONE: (717) 757-7602 SUPREME COURT ID: 07490 ATTORNEY FOR: Defendants BY THE COURT: DATE: Seal of Court Prothonotary Clerk, Civil Division IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Dr. Robert Matsko, Jr., DO, 211 Broad Street, Marysville, PA 17853 (Name of Person or Entity) 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 office notes, reports, records, memoranda, correspondence, diagnostic tests and/or reports, consultation reports, x-rays, progress notes, hospital records, nurses notes, admission and discharge summaries and records and reports of examinations, and any other medical records of any kind pertaining to Alan Romanko, date of birth: 12/6/54 from October 1, 2010 to the present. at Griffith, Strickler, Lerman, Solymos &Calkins, 110 S. Northern Way, York, PA 17402-3737 (Address) 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: ROBERT A. LERMAN, ESQ. ADDRESS: GRIFFITH, STRICKLER, LERMAN. SOLYMOS & CALKINS 110 South Northern Way, York, PA 17402 TELEPHONE: (717) 757-7602 SUPREME COURT ID: 07490 ATTORNEY FOR: Defendants BY THE COURT: DATE: Seal of Court Prothonotary/Clerk, Civil Division IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: State Farm Insurance Companies, P. O. Box 41, Concordville, PA 19331 Within twenty(20)days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: Complete first-party benefits file pertaining to Alan Romanko, date of birth: 12/6/54, date of accident 10/25/10, believed to be insured under Policy No. 1321187AO338 including but not limited to application for benefits, medical records, any payout sheet for medical and wage loss benefits paid, medical bills, medical reports, peer review reports, photographs, statements, claim notes, declaration page and/or coverage information reflecting first-party benefits coverage and tort election, documents submitted in support of or in payment of property damage claims, and any other documentation in your files. at Griffith. Strickler, Lerman, Solymos &Calkins, 110 S. Northern Way, York, PA 17402-3737 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: ROBERT A. LERMAN, ESQ. ADDRESS: GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS 110 South Northern Way, York, PA 17402 TELEPHONE: (717) 757-7602 SUPREME COURT ID: 07490 ATTORNEY FOR: Defendants BY THE COURT: DATE: Seal of Court Prothonotary/Clerk, Civil Division IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW,this k, day of �Zq 5� ,2013,I,Robert A.Lerman,Esquire,a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, Esquires, hereby certify that I have,this date,served a copy of Notice of Intent to Serve Subpoenas by United States Mail, addressed to the party or attorney of record as follows: Timothy A. Shollenberger, Esquire Shollenberger&Januzzi, LLP 2225 Millennium Way Enola, PA 17025 (Counsel for Plaintiff) - - -- - - - - -- - - -- - - - - - -- - -G-RIFFITH-ST- - KLER;L-ERMAN,- - - - SOL S & CALKINS BY: Robert A. Lerman, Esquire AX# 07490 Attorney for Defendants 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602/(717) 757-3783 fax rlermangfzslsc.com jml/danlodge-noi SHOLLENBERGERTmoTHY A. SHOLLENBERGER,EsQ. NUZZI, LLP KARL J.JANuzzi,ESQ. Attomeys At Law ADAM T.WoLFE,EsQ. Writer's Direct Email: jerb(&-sholljanlaw.com August 23, 2013 RECEIV''`.�g Ann Margaret Grab, Esquire AUG 2 6 2013 Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402 RE: Alan Romanko v. Rosa Lin and Danlodge, Inc. t/d/b/a Comfort Inn West Dear Attorney Grab: This office is in receipt of your Notice of Intent to Serve Subpoenas to Produce Documents for the following entities: 1) Dr. Carol E. Copeland/Dr. James Flynn/Penn State Hershey Medical .Center; 2) Dr. Carl Reese- Penn State Hershey Medical Center Urology; 3) Dr. Robert Matsko, Jr.; and 4) State Farm Insurance Companies. We have no objection to the service of the Subpoenas as long as we are provided with copies of all documents obtained within twenty (20) days of your receipt of them without charge. I would remind you of the content of the following Request for Production of Documents that was served upon your client: "17. Any and all documents or things that are obtained through the use of a subpoena to produce documents and things pursuant to Pa.R.C.P. 4009.22." If you are unwilling to agree to these terms, then please notify me in writing within ten business days of the date of this letter. If I do not hear from you in writing to the contrary, I will assume that you have no objection to the above referenced conditions. ly yours, a.C.P. /jme Para gal to Timothy A. Shollenberger MAIN OFFICE-@E9A nnium Way Enola,PA 17025 Phone 717-728-3200 1 Fax 717-728-3400 1 Toll Free 800-813-1368 HARRISBURG OFFICE:4811 Jonestown Road,Suite 221 1 Harrisburg,PA 17109 1 Phone 717-671-6400 (Please do not send mail to the Harrisburg address) Please visit www.shoillanlaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA ALAN ROMANKO,, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW,this 3O'h day of August,2013,I,Robert A.Lerman,a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of Certificate Prerequisite to Service of Subpoenas Pursuant to Rule 4009.22 by United States Mail, addressed to the party;or attorney of record as follows: Timothy A. Shollenberger,Esquire Shollenberger&Januzzi,LLP 2225 Millennium Way Enola,PA 17025 (Counsel for Plaintiff) GRIFFITH, STRICKLER,LERMAN, SOLYMOS& CALKINS i BY: Robert A. Lerman, Esquire PA#07490 Attorney for the Defendants 110 South Northern Way York,PA 17402 (717)757-7602/(717) 757-3783 fax rlerman@jzslsc.com i i i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW,this Y day of ,2013,I,Robert A.Lerman,Esquire,a member of the firm of GRIFFITH,STRICKLER,tERMAN,SOLYMOS&CALKINS,hereby certify that I have this date served a copy of the Objections and Responses of Defendant, Danlodge, Inc. t/d/b/a Comfort Inn West to Plaintiffs Request for Production of Documents, Set No. 1, by United States Mail, addressed to the party or attorney of record as follows: Timothy A. Shollenberger, Esquire Shollenberger& Januzzi, LLP 2225 Millennium Way rrJ W Enola, PA 17025 - M z r° (Counsel for Plaintiff) -<D >o GRIFFITH, ST CKLER, LERMAN, M I>0 SOL OS & CALKINS ' BY: ROBERT A. LERMAN, ESQUIRE PA# 07490 Attorney for Defendants 110 South Northern Way York, PA 17402 717-757-7602/717-757-3783 fax rlermankgslsc.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW,this -day of _,2013,I,Robert A. Lerman,Esquire,a member of the firm of GRIFFITH,ST RICKLER, ERMAN,SOLYMOS&CALKINS,hereby certify that I have this date. served a copy of the Objections and Responses of Defendant, Rosa Lin to Plaintiffs Request for Production of Documents,Set No. 1,by United States Mail,addressed to the party or attorney of record as follows: Timothy.A. Shollenberger, Esquire c Shollenberger& Januzzi, LLP can � . 2225 Millennium Way Enola,PA 17025 r :z (Counsel for Plaintiff) <C.-J r--rca >.c GRIFFIT4STLER, LERMAN,SALKINS BY: R BERT A. LERMAN, ESQUIRE PA# 07490 Attorney for Defendants 110 South Northern Way York,PA 174.02 . 717-757-7602/717-757-3783 fax rlerman gslsc.com i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff . V. No. 12-4830 ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW,this Aay of A u 5 r-,2013,I,Robert A.Lerman,Esquire,a member of the firm of GRIF; ITH, STRICKLER,MERMAN,SOLYMOS&CALKINS,hereby certify that I have this date served a copy of the Objections and Answers of Defendant,Danlodge,Inc.t/d/b/4:; Comfort Inn West to Plaintiffs First Set of Interrogatories,by United States Mail,aoress'd to�, the party or attorney of record as follows: t/) m r� Timothy A. Shollenberger;Esquire Shollenberger&Januzzi, LLP 4� - '2225 Millennium Way �n- _ -; Enola, PA 17025 D� '-: ° (Counsel for Plaintiff) GRIFFITH, STRIC ER, LERMAN, SOLYMO R & CALKINS BY : BERT A. LERMAN, ESQUIRE PA# 07490 Attorney for Defendants 110 South Northern Way York, PA 1740.2 717-757-7602/717-757-3783 fax rlerman(i4gslsc.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW,this day of h'►�- 1 ,2013,I,Robert A. Lerman,Esquire,a member of the firm of GRIFFITH,STRICKLER,LER. AN,SOLYMOS&CALKINS,hereby certify that I have this date served'a copy of the Objections and Answers of Defendant,Rosa Lin to Plaintiff's First Set of Interrogatories,by United States Mail, addressed to the party or attorney of record as follows: C-) c c d Timothy A. Shollenberger,,Esquire w + Shollenberger&Januzzi, LLP .:�'`� .+� w z,;o 2225 Millennium Way cnr- i Enola, PA 17025 (Counsel for Plaintiff) D:� 6-1 1 GRIFFITH, ST ER, LERMAN, SOL S & CALKINS BY: ROBERT A. LERMAN,ESQUIRE PA# 07490 Attorney for Defendants 110 South Northern Way York;PA 17402 717-757-7602/717-757-3783 fax rlerman •,gslsc.com TH Of4Q T. SHOLLENBERGER & JANUZZI, LLP AftY 2225 Millennium Way —a01-3 SE 14 AM j:j;; 1.1 Enola, Pennsylvania 17025 CUMBERLA�JpCpUtdTY Telephone Number: (717) 728-3200 PENNSYLVANIA COU Fax Number: (717) 728-3400 Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, this 11ky of September, 2013, 1 hereby certify that a copy of the foregoing Notice of Deposition of Defendant, Rosa Lin, has been served upon the following, via U.S. Mail: Ann Margaret Grab, Esquire Law Offices of Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402 SH ;ONBERGER & JANUZZI, LL By: enberger, Es q. Attorney ID# 34343 _ ILED-Uk F i:...f<. I HE i'ROTHONOTA SHOLLENBERGER & JANUZZI, LLP I3OCT 1 l PM 12: 08 2225 Millennium Way Enola, Pennsylvania 17025 CUMBERLAND COUNTY Telephone Number: (717) 728-3200 PENNSYLVANIA Fax Number: (717) 728-3400 Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, this JD day of_�(.a _�, 2013, I hereby certify that a copy of the foregoing Plaintiff's Answers to Defendant's Interrogatories- Set II have been served upon the following, U.S. First Class Mail: Ann Margaret Grab, Esquire Law Offices Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402-3737 SHOLLENBERGER & JANUZZI, LLP By: Ji/ ?'-othyA. Shollenberger, Esq. Attorney ID#34343 6 SHOLLENBERGER&JANUZZ1,LLP 2225 MILLENNIUM WAY! ENOLA,PA 17025 (717)728-3200!FAX(717)728-3400 fir F r 'r, vlw S HOLLENBERGER & JANUZZI, LLP n �� 12: GB 2225 Millennium Way Enola, Pennsylvania 17025 c'UtABE YLVANI � Telephone Number: (717) 728-3200 J BEN Fax Number: (717) 728-3400 Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, this 1044'day of 04072013, I hereby certify that a copy of the foregoing Plaintiff's Response to Defendant's Request for Production of Documents have been served upon the following, U.S. First Class Mail: Ann Margaret Grab, Esquire Law Offices Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402-3737 SHOLLENBERGER & JANUZZI, LLP By: Timothy A. Shollenberger, Esq. Attorney ID#34343 8 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY I ENOLA,PA 17025 (717)728-3200 I FAX(717)728-3400 ` `Ui ir�IL�^��. SHOLLENBERGER & JANUZZI, LLP 203 oCI 11 ?"12: 08 2225 Millennium Way Enola, Pennsylvania 17025 I�iB HD T� Telephone Number: (717) pEOSYLV Fax Number: (717) 728-3400 Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, this IV day of OCk2o13, I hereby certify that a copy of the foregoing Plaintiff's Answers to Defendant's Interrogatories have been served upon the following, U.S. First Class Mail: Ann Margaret Grab, Esquire Law Offices Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402-3737 SHOLLENBERGER & JANUZZI, LLP Adi&e, By: // 1 /7mothy A. Shollenberger, sq. Attorney ID#34343 9 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY! ENOLA,PA 17025 (717)728-3200!FAX(717)728-3400 }l,'a SHOLLENBERGER & JANUZZI, LLP 3 Q _ , 2225 Millennium Way ra°if, f111' � 46 Enola, Pennsylvania 17025 PENN$YEY COL/1'T', T'° Telephone Number: (717) 728-3200 4NI, Fax Number: (717) 728-3400 Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Lift ar And now, this . day of n011644, 2013, I hereby certify that a copy of the foregoing Plaintiff's Supplemental Answers to Defendant's Interrogatories have been served upon the following, U.S. First Class Mail: Ann Margaret Grab, Esquire Law Offices Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402-3737 SHOLLENBERGER & JANUZZI, LLP B : 4,414.1 1.111111111111:11111100..- T' o y A. ollen. ' Esq. Attorney ID#34343 4 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY! ENOLA,PA 17025 (717)728-3200!FAX(717)728-3400 f SHOLLENBERGER & JANUZZI, LLP `` j C - P[ j. 2225 Millennium Way r:,� r:�� k, t Enola, Pennsylvania 17025 f' Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED STIPULATION SETTING DISCOVERY AND OTHER PRETRIAL pEADLINES Noverrbu- And now, this Z IAf day of Qete r, 2013, the Plaintiff and Defendants, by and through their respective counsel of record do hereby Stipulate and agree as follows: a. All fact discovery is to be completed by March 18, 2014; b. Plaintiffs shall provide all expert reports to Defendants by April 18, 2014; C. Defendants shall provide all expert reports to the Plaintiffs by May 19, 2014; d. All dispositive Motions shall be filed no later than May 30, 2014; and e. If no dispositive Motions are filed, either party may list the case for trial at the next available Civil Trial term. -- The Parties further agree that this Stipulation shall be filed with the Prothonotary and have the same force and effect as if approved by a Judge of the Court of Common Pleas of Cumberland County. Date: /04 /go /3 mo by olle rge , Esq. Date: `� � 3 �✓ Ann Margaret Grab, ES . SHOLLENBERGER & JANUZZI, LLP -"IN -8 a 2225 Millennium Way CUk18 �M/j; i Enola, Number: 17025 728-3200 PENS AND LV e4UN Fax Number: (717) 728-3400 LVAN/A Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, this61widay of January, 2014, I hereby certify that a copy of the foregoing Notice of Deposition of Officer Tracy Miller, has been served upon the following, via U.S. Mail: Officer Tracy Miller Silver Spring Township Police Department 5 Willow Mill Park Road, Suite 1 Mechanicsburg, PA 17050 Ann Margaret Grab, Esquire Law Offices of Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402 SHOLLENBERGER & JANUZZI, LLP By: 0////144° Timothy A. Shollenberger, Esq. Attorney ID# 34343 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoena for documents and things pursuant to Rule 4009.22, Defendants, Rosa Lin and Danlodge, Inc. t/d/b/a Comfort Inn West, certifies that: (1) A Notice of Intent to Serve Subpoena with a copy of the Subpoena attached thereto was mailed or delivered to each party at least twenty (20) days prior to the date on which the Subpoenas are sought to be served; (2) A copy of the Notice of Intent, including the proposed Subpoena, is attached to this Certificate; (3) Plaintiff s counsel has waived 20 days notice per the attached letter; and (4) The Subpoena which will be served are identical to the Subpoena which is attached to the Notice of Intent to Serve the Subpoena. r Cl) _� O GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS i �,, J BY: - � yi 1 Robert A. Lerman, Esquire PA#07490 Ann Margaret Grab, Esquire PA#55986 Attorney for the Defendants 110 South Northern Way York, PA 17402 Dated: January 27, 2014 717-757-7602/717-757-3783 fax rlennanggslsc.com/amgrabggslsc.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Robert A. Lerman, Esquire, counsel for Defendants, Rosa Lin and Danlodge, Inc. t/d/b/a Comfort Inn West, intends to serve a Subpoena identical to the one that is attached to this Notice. You have twenty(20)days from the date listed below in which to file of record and serve upon the undersigned an objection to the Subpoena. If no objection is made,the Subpoena may be served. GRIFFITH, STRICKLER, LERMAN, SOLYMOS &CAL BY: R RT A. LERM QUIRE PA#07490 ANN MARGARET GRAB,ESQUIRE PA#55986 Attorney for Defendants 110 South Northern Way York, PA 17402 Date: (717) 757-7602/(717) 757-3783 fax rlerman @gslsc.com/amgrab @gslsc.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Fluor Industrial Services Inc. 2020 Technology Parkway, Mechanicsburg, PA 17050 Within twenty(20)days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: Complete personnel file pertaining to Alan Romanko, date of birth: 12/6/54 including but not limited to all performance evaluations, employment applications, resumes, wage and earnings documentation, employee evaluations, attendance records, and medical records. at Griffith Strickler Lerman Solymos &Calkins, 110 S. Northern Way, York, PA 17402-3737 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: ROBERT A. LERMAN, ESQ./ANN MARGARET GRAB, ESQ. ADDRESS: GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS 110 South Northern Way, York, PA 17402 TELEPHONE: (717)757-7602 SUPREME COURT ID: 07490. 55986 ATTORNEY FOR: Defendants BY THE COURT: DATE: Seal of Court Prothonotary/Clerk, Civil Division IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DANLODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW,this '�day of 'Ll L ,2014,1,Robert A.Lerman,Esquire,a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, Esquires, hereby certify that I have,this date,served a copy of Notice of Intent to Serve Subpoena by United States Mail, addressed to the parry or attorney of record as follows: Timothy A. Shollenberger, Esquire Shollenberger&Januzzi, LLP 2225 Millennium Way Enola, PA 17025 (Counsel for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOLYMOS & S r Robert A. Lerman, Esau re PA# 07490 Attorney for Defendants 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602/(717) 757-3783 fax rlerman ,gslsc.com jml/danlodge-noi v k ` aw fs r Writer's Direct Email: jerb _shol janlaw.com January 23, 2014 Ann Margaret Grab, Esquire Griffith, Strickler, Lerman, Solymos & Calkins JAN 2 4 2014 110 South Northern Way York, PA 17402 RE: Alan Romanko v. Rosa Lin and Danlodge, Inc. t/d/b/a Comfort Inn West Dear Attorney Grab: This office is in receipt of your Notice of Intentto Serve Subpoenas to Produce Documents for the following entities: 1) Fluor Industrial Services. We have no objection to the service of the Subpoena as long as we are provided with copies of all documents obtained within twenty(20) days of your receipt of them without charge. I would remind you of the content of the following Request for Production of Documents that was served upon your*client: "17. Any and all documents or things that are obtained through the use of a subpoena to produce documents and things pursuant to Pa.R.C.P. 4009.22." If you are unwilling to agree to these terms, then please notify me in writing within ten business days of the date of this letter. If I do not hear from you in writing to the contrary, I will assume that you have no objection to the above referenced conditions. Very truly yours, J c . r , a. .P. /jme Paralegal to Timothy A. Shollenberger MAIN OFFICE:2225 Millennium Way ( Enola,PA 17025 Phone 717-728-3200 1 Fax 717-728-3400 1 Toll Free 800-813-1368 HARRISBURG OFFICE:4811 Jonestown Road,Suite 221 1 Harrisburg,PA 17109 1 Phone 717-671-6400 (Please do not send mail to the Harrisburg address) Please visit www.shollianlaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALAN ROMANKO, CIVIL DIVISION Plaintiff V. No. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 27th day of January, 2014, 1,Ann Margaret Grab, a member of the firm of GRIFFITH, STRICKLER,LERMAN, SOLYMOS&CALKINS,hereby certify that I have this date served a copy of Certificate Prerequisite to Service of Subpoena Pursuant to Rule 4009.22 by United States Mail, addressed to the party or attorney of record as follows: Timothy A. Shollenberger, Esquire Shollenberger&Januzzi, LLP 2225 Millennium Way Enola, PA 17025 (Counsel for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS BY: Ann Margaret Grab, Esquire PA#55986 Attorney for the Defendants 110 South Northern Way York, PA 17402 (717) 757-7602/(717) 757-3783 fax amgrab(a,gslsc.com OF =.fC r;t I1 f'fC1Tf I`t ' 'U'/if 't SHOLLENBERGER & JANUZZI, LLP 2014 FES 26 Pr 2. , 2225 Millennium Way 8 Enola, Pennsylvania 17025 CU11BERLA,ND COUNTY Telephone Number: (717) 728-3200 PENNSYLVANIA Fax Number: (717) 728-3400 Attorneys for Plaintiff ALAN ROMANKO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-4830 ROSA LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, CIVIL ACTION - LAW Defendants JURY TRIAL DEMANDED . CERTIFICATE OF SERVICE �h ��rvar y And now, this 2fday of - , 20?4, I hereb certi that a co of the Y certify copy foregoing Notice of Deposition of Stephen Truesdell, has been served upon the following, via U.S. Mail: Stephen Truesdell 4 Watson Drive Carlisle, PA 17015 Ann Margaret Grab, Esquire Law Offices of Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402 SHOLLENBERGER & JANUZZI, LLP By: �ID S len r , E 064rney; 343?3 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728 -3200 Fax Number: (717) 728 -3400 Attorneys for Plaintiff ALAN ROMANKO, Plaintiff v. ROSA LIN and DAN LODGE, INC. t/d /b /a COMFORT INN WEST, Defendants ;LED-OFF ICE 3 OF THE PROTHONOTARY 2014 MAR -3 P11 2: °23 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12 -4830 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, thi2 day of W. , 2014, I hereby certify that a copy of the foregoing Plaintiffs Supplemental Answers to Defendant's Interrogatories have been served upon the following, U.S. First Class Mail: Ann Margaret Grab, Esquire Law Offices Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402 -3737 SHOLLENBERGER & JANUZZI, LLP By: y A. Shollenberger, Esq. Attorney ID #34343 3 SHOLLENBERGER & JANUZZI, LLP 2225 MILLENNIUM WAY ! ENOLA, PA 17025 (717) 7283200 ! FAX (717) 728-3400 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ALAN ROMANKO, Plaintiff v. ROSA=LIN and DAN LODGE, INC. t/d/b/a COMFORT INN WEST, Defendants I. 6 UP PRO I�h'� O 1Y J C*& HONO 204 4116 C'Up��RC 4 11 6 ,0 COUNTY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-4830 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above -captioned matter settled, discontinued and ended. oate:bg22.. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP y - . Sholl=nberger, Esquire Counsel for Plaintiff Attorney I.D. #34343