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HomeMy WebLinkAbout04-5832 CLAIRE C. ROSS, Individually and as Executrix of the Estate of GEORGE C. ROSS, Deceased, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. C~ - ~y~ c'~i.e/~ WILLIAM GRACE and ELIZABETH GRACE Defendants : CIVIL ACTION - LAW 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 claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property of other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VE 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 MA Y BE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 A VISO LE HAN DEMANDADO EN CORTE. Si usted desea defender contra las demandas dispuestas en las paginas siguientes, usted debe tomar la acci6n en el plaza de veinte (20) dias despues de esta queja y se sirve el aviso, incorporando un aspecto escrito personalmente 0 y archivando en escribir con la corte sus defensas u objeciones alas demandas dispuestas contra usted el abogado Ie advierte que que si usted no puede hacer asi que el caso puede proceder sin usted y un juicio se puede incorporar contra usted compra la corte sin aviso adicional para cualquier dinero demandado en la queja 0 para cualquier otra demanda 0 relevaci6n pedida por el demandante. Usted puede perder el dinero 0 la caracteristica de otra endereza importante a usted. USTED DEBE LLEV AR ESTE P APEL SU ABOGADO INMEDIA T AMENTE. SI USTED NO HACE QUE UN ABOGADO V A Y A A 0 LLAME POR TELEFONO La OFICINA DISPUEST A ABAJO. ESTA OFICINA PUEDE PROVEER DE USTED LA INFORMACION SOBRE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PERMITIRSE AL HIRE A UN ABOGADO, EST A OFICINA PUEDE PODER PROVEER DE USTED LA INFORMACION SOBRE LAS AGENCIAS QUE LOS SER VICIOS JURfDICOS DE LA OFER T A DE MA YO A LAS PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO 0 NINGDN HONORARIO Cumberland County Bar Association 32 S. Bedford Street Carlisle, P A 17013 (800) 990-9108 Robert F. Claraval, Esq. CLARA VAL & CLARA VAL P.O. Box 11965 Harrisburg, PA 17108-1965 (717) 233-4780 Supreme Court I.D. 19222 Attorney for Plaintiff CLAIRE C. ROSS, Individually and as Executrix of the Estate of GEORGE C. ROSS, Deceased, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04 - 5"$13.2- C!iCJ~L~€a..."'1.. WILLIAM GRACE and ELIZABETH GRACE Defendants : CIVIL ACTION - LAW COMPLAINT The Parties 1. The Plaintiff Claire C. Ross is the Executrix ofthe Estate of George Ross with Letters issued to her on March 19,2004. Claire Ross individually is also a Plaintiff with her address at 133 Yellow Breeches Drive, Camp Hill, York County, Pennsylvania, 17011. 2. The Defendants William Grace and Elizabeth Grace are individuals with an address at 1705 Edgar Lane, Camp Hill, Cumberland County, Pennsylvania, 17011. Background 3. William Grace and Elizabeth Grace are the owners of a commercial property with an address of 630 Oak. Street, Lemoyne, Cumberland County, Pennsylvania, 17043. The property has been leased to BAPS Auto Paint Supply, Inc. for the purpose ofBAPS conducting a paint supply business at the property. 4. The premises includes a parking lot for use by employees and customers ofBAPS. 5. On January 7, 2003 George Ross, an employee of BAPS, was an invitee to the premIses. 6. Mr. Ross exited the door ofBAPS Auto Paint Supply to walk to the van which he was using that day for deliveries. 7. Mr. Ross slipped on accumulated ice caused by a pipe which allowed water to accumulate on the parking lot and then freeze or in the alternative was caused by the failure of Defendants to clear the parking lot of accumulated ice. -2- 8. Mr. Ross slipped and fell on the accumulated ice, struck his head and was found laying flat on his back with his head propped up against the building near the pipe in question. 9. Mr. Ross was taken to the Holy Spirit Hospital where he died on January 11,2003. Negligence 10. The accident described above was caused by the negligence and carelessness of Defendants acting individually or by and through their agents, workmen or employees and consisted of the following: (a) Carelessly and negligently allowing the accumulation of ice on the parking lot at a location where it was known and obvious that employees ofBAPS would walk; (b) Carelessly and negligently allowing and permitting the existence of ice at the location; (c) Carelessly and negligently permitting an artificial condition, namely the pipe, to discharge water onto the parking lot which then formed ice; (d) Carelessly and negligently failing to promptly remove the ice which had formed on the parking lot; (e) Carelessly and negligently failing to supervise their employees and to instruct them to remove the accumulated ice in a timely manner; (f) Carelessly and negligently failing to regularly inspect the parking lot so as to ensure it was in a proper and safe condition; 11. At all times relevant to the cause of action the Defendants reserved control over the parking lot and its snow removal maintenance. -3- 12. At all times relevant to the Plaintiffs' cause of action the Defendants reserved control over the maintenance of the pipe. 13. The pipe is a nuisance per se in that it drained water onto the parking lot. 14. Upon information and belief the Defendants knew of the existence of the artificial condition and its ability to create a dangerous ice condition on the parking lot. COUNT I - WRONGFUL DEATH The Estate of George C. Ross by Claire C. Ross, Executrix v. William Grace and Elizabeth Grace 15. Paragraphs 1-14 are incorporated herein by reference thereto. 16. Claire Ross brings this action pursuant to the Pennsylvania Wrongful Death Act, 42 Pa.C.S.A. 98301, et. seq. and Pa.R.C.P. 92202 and on behalf of Mr. Ross' heirs. 17. The decedent was survived by Claire Ross and his children, Russel C. Ross, Cindy L. Ross, Kenneth E. Ross and Shari Ross Lahlou. Each of his children have received notice of the filing of this Complaint. -4- 18. The decedent did not bring an action for personal injuries during his lifetime and no other action for the death of the decedent has been commenced against Defendants. 19. The applicable damages under the Wrongful Death Act are as follows: (a) Funeral expenses for the decedent George Ross; (b) The expenses of administration related to George Ross' injuries. (c) The pecuniary loss to George Ross' heirs as recoverable under the statute; (d) The heirs' deprivation and injury as a result of the loss of the support, consortium, counsel, aid, association, care and service of the decedent; (e) The other damages as permitted in a wrongful death action as a matter oflaw. WHEREFORE, the Plaintiff Estate of George C. Ross by Claire C. Ross, Executrix demands judgment against the Defendants William Grace and Elizabeth Grace in an amount which exceeds the compulsory arbitration limits of Cumberland County, together with interest and costs of suit. COUNT II - SURVIVAL ACTION Claire C. Ross, Individually and as Executrix of the Estate of George C. Ross v. William Grace and Elizabeth Grace 20. Paragraphs 1-19 are incorporated herein by reference thereto. 21. Claire Ross bring this survival action under 42 Pa.C.S. 98302, et. seq. -5- 22. As a direct result of the actions of the Defendants William Grace and Elizabeth Grace described above the Defendants are liable for the following damages: (a) George Ross' pain and suffering between the time of his injuries and the time of his death; (b) George Ross' total estimated future earning power less his estimated cost of personal maintenance; (c) George Ross' loss of retirement and Social Security income; (d) George Ross' other financial losses suffered as a result of his death; (e) George Ross' loss of enjoyment of life; and (f) George Ross' loss of the pleasures oflife. WHEREFORE, the Plaintiff Claire C. Ross, Individually and as Executrix of the Estate of . George C. Ross, demands judgment against the Defendants William Grace and Elizabeth Grace in an amount which exceeds the compulsory arbitration limits of Cumberland County, together with interest and costs of suit. if 'If-;'y B ROBERT .CLARAVAL P.O. Box 11965 Harrisburg, P A 17108-1965 (717) 233-4780 Supreme Court LD. #19222 Date: Attorneys for Plaintiff -6- VERIFICATION The language of the foregoing document is that of counsel and not necessarily my own; however, I have read the foregoing document and to the extent that it is based upon information that I have given to counsel, it is true and correct to the best of my knowledge, information, and belief; to the extent that the content of the foregoing document is that of counsel, I have relied upon counsel in making this verification. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S.A. ~4904, relating to unsworn falsification to authorities. OPtlut~/ {i_.~/ CLAIRE C. ROSS, Individually and as Executrix of the Estate of GEORGE C. ROSS 1( (:) olQ. 'i 0 ~ ~ ~ tv Q ...:f ~ (" ~, ro-..,,") .: "J Cl ~ , " .> ~ .". ,I "'" ,.. .~ (- ". :1: 1,1 -~ .~ 1 $ U) :.:,'") ( , r '. . 'I() -~.., . 1"1 . " . '.1 ..."_'. .. ':) ). . < C",) , :,11 1'1 . I , .( ,-- ...~"" :;) Ci"1 -< CLAIRE C. ROSS, Individually and as Executrix of the Estate of GEORGE C. ROSS, Deceased, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-5832 WILLIAM GRACE and ELIZABETH GRACE Defendants : CIVIL ACTION - LAW ACCEPTANCE OF SERVICE. I, C. Roy Weidner, Jr. accept service of the Complaint on behalf of William Grace and Elizabeth Grace and certify that I am authorized to do so. Authorized Agent: Date: 11/ l-1(df , /Z1:~ ---I ( ~jner, Jr., Esq. 301 Market Street Lemoyne, P A 17043 ~ -- (") s; 4::",_ -U l\: ~)f.l": ~"i: C.!;!-. ::'.,:,~ ~'-,. ~~ t..~1 ~~~ Z .:< Q ~=;;:: ~ c::;:) .s:- % o < N "" -0 ....,.. -"'" ~ ~~ ~9 ('::)6 ~=R 0- .,,0 om ~ r:-:> U1 \.C J!lhnson. Duffie, Stewart & Weidner By: C. Roy Weidner, Jr. I.D. No. 19530 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 crw@jdsw.com Attorneys for Defendants Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 04-5832 CIVIL ACTION - LAW JURY TRIAL DEMANDED CLAIRE C. ROSS, Individually and as Executrix of the Estate of GEORGE C. ROSS, Deceased, v. WILLIAM GRACE and ELIZABETH GRACE, Defendants ANSWER TO COMPLAINT AND NOW, this ...ItII!eay of December, 2004, come Defendants William Grace and Elizabeth Grace, through their undersigned attorneys, and answer Plaintiffs complaint as follows: The Parties 1. - 2. Admitted. Background 3. Admitted. 4. Admitted. 5. Admitted in Part. Denied in Part. It is admitted that on or about January 7, 2003, George Ross was an employee of BAPS. The remainder of this averment is deemed denied as a conclusion of law to which no responsive pleading is required. 6. - 8. Denied. After a reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of said averments. 9. Admitted. Negligence 10. Denied. Any negligence on the part of Defendants is specifically denied. On the contrary, at all times, Defendants acted reasonably under the circumstances. 11. Denied. On the contrary, Defendants contractl~d for snow removal maintenance of the parking lot. 12. Denied. On the contrary, maintenance and repairs were the responsibility of the tenant. 13. Denied. This averment is deemed denied as, a conclusion of law to which no responsive pleading is required. 14. Denied. COUNT I - WRONGFUL DEATH The Estate of George C. Ros!>> by Claire C. Ross, Executrix v. William Grace and Elizabeth Grace 15. Admitted In Part. Denied In Part. Paragraphs 1 - 14 hereof are incorporated by reference herein. 16. -18. Denied. After a reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of said averments. 19. Denied. This averment is deemed denied as a conclusion of law to which no responsive pleading is required. By way of further denial, any negligence or other basis for liability on the part of Defendants is specifically denied. WHEREFORE, Defendants William Grace and Elizabeth Grace demand that Plaintiffs complaint against them be dismissed. COUNT II - SURVIVAL ACTION Claire C. Ross, Individually and as Executrix of the Estate of George C. Ross v. William Grace and Elizabeth Grace 20. Admitted in Part. Denied in Part. Paragraph:; 1 - 19 hereof are incorporated by reference herein. 21. -22. Denied. These averments are deemed denied as conclusions of law to which no responsive pleading is required. By way of further denial, any negligence or other basis for liability on the part of Defendants is specifically denied. WHEREFORE, Defendants William Grace and Elizabeth Grace demand that Plaintiffs complaint against them be dismissed. B(p~ner.Jr :239957 12270-3 VERIFICA TION The undersigned confirms that the facts set forth in thE~ foregoing Answer are true and correct. This verification is made subject to the penalties of 18 Pa. C.S.A. ~ 4904, relating to unsworn falsifications to authorities. Dated: ;Jj3/u1 ~/~ ~J~A,rf~ Eliza th Grace CERT/F/CA TE OF SERVICE AND NOW, this & oil? day of December, 2004" the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Robert F. Claraval, Esquin~ Claraval & Claraval P.O. Box 11965 Harrisburg, PA "17108-1965 JOHNSON, DUFFIE, STEWART & WEIDNER By: ~~ ~d/1 ) . helle Spangler - .., c) ......., l c:.--:') () ( -~...) . .C- -n , C:J --I I I 1 -1" C) fl'i~~ I i ~D I (, .. " " , c i ,', I .. .i .,' 1 <.., "1 Johnson. Duffie, Stewart & Weidner By: C. Roy Weidner, Jr. I.D. No. 19530 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 crw@jdsw.com Attorneys for Defendants CLAIRE C. ROSS, Individually and as Executrix of the Estate of GEORGE C. ROSS, Deceased, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Plaintiffs NO. 04-5832 v. CIVIL ACTION - LAW WILLIAM GRACE and ELIZABETH GRACE, JURY TRIAL DEMANDED Defendants CERTIFICATE PREREQUISITE TO ~;ERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: 1) A Notice of Intent to serve the subpoena, with a copy of the subpoena attached thereto, was mailed or delivered to each party at least 20 days prior to the date on which the subpoena were sought to be servE!d; 2) A copy of the Notices of Intent, including the proposed subpoena, is attached to this certificate; 3) No objection to the subpoena has been received; and 4) DATE: /3 /a I hLf The subpoena to be served is identical to the subpoena attached to the Notice of Intent. /~/ .' ,/ .".~~.__." By: (/' /" .../ . .. C. Roy WE~idner, Jr. Attorney I.D. No. 19530 301 Market Street P.O. Box '109 Lemoyne, PA 17043-0109 TelephonE! (717) 761-4540 Attorneys for Defendants . Johnson, Duffie, Stewart & Weidner By: C. Roy Weidner, Jr. I.D.No.19530 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 crw@jdsw.com Attorneys for Defendants Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 04-5832 CLAIRE C. ROSS, Individually and as Executrix of the Estate of GEORGE C. ROSS, Deceased, v. CIVIL ACTION - LAW JURY TRIAL DEMANDED WILLIAM GRACE and ELIZABETH GRACE, Defendants NOTICE OF INTENT TO SERVE A SUB:POENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Claire C. Ross, Individually and as Executrix of the Estate of George C. Ross, Deceased c/o Robert F. Claraval, Esquire P.O. Box 11965 Harrisburg, PA 17108-1965 PLEASE TAKE NOTICE that Defendants intend to serve a subpoena identical to the ones attached to this notice. You have 20 days from the date listed below in which to file on record and serve upon the undersigned an objection to the subpoenas. If no objection is made, the subpoena may be served. JOHNSON, DUFFIE, STEWART & WEIDNER ~~-~-'... (!~~~ - By: .~ . Roy Weidner, ..Ir. Attorney 1.0. No. '19530 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) i'61-4540 Attorneys for DefE!ndants DATE: I,"'" , .', i A;2j ~ ': - j~' :., i' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CLAIRE C. ROSS, Individually and as Executrix of the Estate of GEORGE C. ROSS, Deceased, Plaintiffs vs. File No. Q>4-5832 WILLIAM GRACE and ELIZABETH GRACE, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE '!!!!!2:n TO: Connor-Rich Associates. 207 House Avenue. CalllD Hill. FA 17011 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the cmrrt to produce the following documents or things: Copies of the entire medical records, medical reports, office notes, physical therapy records, correspondence, x- ray reports, MRI reports, hospital records, test reports and any other records pertaining to any evaluation, care or treatment rendered to George C. Ross, D.O.B: 07/27/1935; Social Security No.: 361-26-2146 at C. Roy Weidner. Jr.. Johnson. Duffie. Stewart & Weidner. 301 Market Street. Lemovne. P A 17043 ( Address) You may deliver or mail legible copies of the documents or produce things requesting 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 ad vane, 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 1twenty (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 FOUOWING ,PERSON: NAME: C. Rov Weidner. Jr.. Johnson. Duffie. Stewart & Weidner ADDRESS: 301 Market Street. Lemovne. FA 17043 TELEPHONE: (717) 761-4540 SUPREME COURT ID # 19530 ATTORNEY FOR: Defendants By the Court: DATE: Seal of the Court . Prothonotary Deputy CERT/F/CA TE OF SERVICE AND NO~ this /~1 day of J )J{t' 11'1/;' ( .,2004, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Robert F. Claraval, Esquire Claraval & Claraval P.O. Box 11965 Harrisburg, PA 17108-1965 JOHNSON, DUFFIE, STEWART & WEIDNER By: CERTIFICA TE OF SERVICE . / c,'!-' AND NO~ this B... day of [)c:;{e 1Vl.l?e r _' 2004, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Robert F. Claraval, Esquire Claraval & Claraval P.O. Box 11965 Harrisburg, PA 17108-1965 JOHNSON, DUFFIE, STEWART & WEIDNER By: Elizabeth L.. Ziegler ,- "'..~, L. - . ; ..- r--"", r.) r'" : CLAIRE C. ROSS, Individually and as Executrix of the Estate of GEORGE C. ROSS, Deceased, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-5832 WILLIAM GRACE and ELIZABETH GRACE Defendants : CIVIL ACTION - LAW CERTIFICATE OF SERVICE I hereby certifY that I have this day served Plaintiffs' Answers to Defendants' Interrogatories and Plaintiffs' Responses to Defendants' Request for Production of Documents by first class mail, postage prepaid, addressed to the following person: C. Roy Weidner, Jr., Esq. Johnson, Duffie, Stewart & Weidner 301 Market Street P.O. Box 109 Lemoyne, P A 17043 CLARA V AL & CLARA V AL Date: ;) I/~ lo.~ . , BY-l)2n~ll..Q \ndUCtV\\,L\; DENISE 1. WILLIAMS, Secretary CLAIRE C. ROSS, Individually and as Executrix of the Estate of GEORGE C. ROSS, Deceased, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-5832 WILLIAM GRACE and ELIZABETH GRACE Defendants : CIVIL ACTION - LAW CERTIFICATE OF SERVICE 1 hereby certifY that I have this day served Plaintiffs' Answers to Defendants' Interrogatories and Plaintiffs' Responses to Defendants' Request for Production of Documents by first class mail, postage prepaid, addressed to the following person: C. Roy Weidner, Jr., Esq. Johnson, Duffie, Stewart & Weidner 301 Market Street P.O. Box 109 Lemoyne, P A 17043 CLARA V AL & CLARA V AL Date: d-1,/Q}05 . , By \)Pr\\b.2 \nd UCtflA,ll; DENISE 1. WILLIAMS, Secretary ~ o c:.", -n ~ ~ .P "3 D <., o ,/' ; /( \)...:>, . 6lJ CLAIRE C. ROSS, Individually and as Executrix of the Estate of GEORGE C. ROSS, Deceased, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-5832 WILLIAM GRACE and ELIZABETH GRACE Defendants : CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please mark the above captioned action settled and discontinued. CLARA V AL & CLARA V AL Date: ROBERT F. P.O. Box 11965 Harrisburg, PA 17108-1965 (717) 233-4780 Supreme Court I.D. #19222 B Attorneys for Plaintiff i\ C., c << . . ~ LESA M. SOURBEER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-5832 CIVIL TERM x\t2 0 0 6 v. MYLES H. SHOOP, Defendant RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following fonn: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Geof f rev M. Bi ringer , counsel forthe plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of the plaintiff in the action is $ 2. 922 . 76 The counterclaim of the defendant in the action is Q TIle following attorneys are interested in the case(s) as counselor are otherwise disqualified to sit as arbitrators: Geoffrey M. Biringer WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, ~~';z,.:~ ORDER OF COURT Geoffrey M. Blrlnge P.I. AND NOW, , 19_, in consideration of the foregoing petition, Esq., and actions) as prayed for. Esq.,_ ,Esq.,are appointed arbitrators in the above captioned action (or By the Court, C) ,........, C~ (~ -;) ",-/ (:/.... ~. .~ -l'.... -,..,; ;-=;1 :lJ ~0 r- -':f CD :"1 '.,j --J ~) I , . .., ;':',:"U "-;;..(") ,.j IT ~ U1 ~t (Xl .-< ,_.._..~"......~ - ~ LESA M. SOURBEER Plaintiff Vs. : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA MYLES H. SHOOP Defendant : CIVIL TERM - 05-5832 : CIVIL ACTION - LAW To the Prothonotary: PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow the Plaintiff, Lesa M. Sourbeer to proceed in forma pauperis. I, Geoffrey M. Biringer, Esquire, attorney for the party proceeding in forma pauperis, certify that I am providing free legal services to the party. ~-r~ Geoffrey M. Biringer Attorney for the Plaintiff ./~~~ ~ r::::~ ,--...... ,;:-::) ,:.;;-' ~=' --~ r \.j 'n ..-l :J:-r ;llF: .on''-; -~';O ) ,~, ;.1 ~.~ :s (") ,_yi-n ., ~ .-< r;-? U1 C;., 'l"