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Home My WebLink About13-4942 Supreme Col" o ennsylvania Con Df *COIYImo leas For Prothonotary Use Only: it ver`Sh. � - u Docket No: `sl' cuntis ' u vo ' Coun � f �3... The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefilhn g and service of pleadings or other pa ers as required by law or rules of court. Commencement of Action: S El Complaint 0 Writ of Summons El Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Mary J. Williams Weis Markets, Inc. f T Dollar Amount Requested: ❑ within arbitration limits I Are money damages requested? 0 Yes ❑ No (check one) R1 outside arbitration limits O N Is this a Class Action Suit? []Yes 0 No Is this an MDJAppeal? ❑ Yes ❑ No A Name of Plaintiff/Appellant's Attorney: William P. Douglas, Esq. ❑ Check here if you have no attorney (are a Self - Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections Nuisance Dept. of Transportation Premises Liability Statutory Appeal: Other S Product Liability (does not include ❑ Employment Dispute: mass tort) E Slander/Libel/ Defamation Discrimination C ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other: I ❑ Other: O MASS TORT ❑ Asbestos N Tobacco Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration B ❑ Other: HGround Eminent Domain/Condemnation ❑ Declaratory Judgment Rent Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: i Updated 1 /1/2011 r r.a' i fEw ZU l r f.� 13 19 PH 3:31 1 1MBERL AN[) C PENNSY Qt', William P. Douglas, Esq. Supreme Court I.D. 1137926 Douglas Law Office 43 W. South St. Carlisle, PA 17013 Telephone (717) 243 -1790 Mary J. Williams In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania ds No. 13 Civil Term Weis Markets, Inc. 1000S.2 nd St. Sunbury, PA 17801 Civil action law Defendant Jury Trial Demanded Praecipe to Issue a Writ of Summons Dear Mr. Buell: Please issue a writ of summons against the defendant, Weis Markets, Inc. �J Vn William P. Doug Attorney for date: August 19, 2013 f03 . 7 5At C#/wo ' p. -ZL- � Commonwealth of Pennsylvania County of Cumberland Mary J. Williams In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs No. 13 — 7 - Civil Term Weis Markets, Inc. 1000S.2 nd St. Sunbury, PA 17801 Civil action law Defendant Jury Trial Demanded Writ of Summons To: Weis Markets, Inc. 1000S.2 nd St. Sunbury, PA 17801 You are hereby notified that Mary J. Williams has brought an action against you. g�j9 /,2o/3 �— De t Prothonotary Date: Monday, August 19, 2013 William P. Douglas, Esq. Douglas Law Office 43 W. South St. Carlisle, PA 17013 717- 243 -1790 Attorney for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson f. z E )F F f c- Sheriff= f f`��; R 019 f ��t�rtta,at�uan�ic�y�F� ;i f�1�`7lr Jody S Smith ` EP b P1� 2: 5 Q Chief Deputy � . � � Richard W Stewart CUMBERL Abp COUN f Y Solicitor 0FFiCc0F`)-E µF,F �'DMSYLVANIA Mary J Williams Case Number vs. Weis Markets, Inc. 2013-4942 SHERIFF'S RETURN OF SERVICE 08/27/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Weis Markets, Inc., but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Northumberland, Pennsylvania to serve the within Writ of Summons according to law. 09/04/2013 03:00 PM -The requested Writ of Summons served by the Sheriff of Northumberland County upon Joslyn Geyer,Administrative Assistant,who accepted for Weis Markets, Inc., at 1000 S. 2nd Street, Sunbury, PA 17801. Chad Reiner, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.46 SO ANSWERS, September 11, 2013 RbNW R ANDERSON, SHERIFF (c)County5uite Sheriff,Teleosoft,Inc. SHERIFF'S OFFICE OF NORTHUMBERLAND COUNTY Chad A Reiner Aar`.,rk, `� Tony Matulewicz, Esq Sheriff JY Solicitor Randy Coe Chief Deputy MARY J WILLIAMS Case Number vs. WEIS MARKETS, INC. 13 CV 04942 SHERIFF'S RETURN OF SERVICE 09/04/2013 03:00 PM- DEPUTY JAMES A. SOUDER II, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED WRIT OF SUMMONS (WOSM) BY HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE JOSLYN GEYER/ADMIN ASSISTANT, WHO ACCEPTED AS "ADULT PERSON IN CHARGE" FOR WEIS MARKETS, INC.AT 1000 S. SECOND ST., SUNBURY, PA 17801. SHERIFF COST: $35.96 SO ANSWERS, September 09, 2013 CHAD A REINER, SHERIFF Sworn to an��'SubSCfihed b �o me this 9— day of—��/}!: A.D. 20.13 : (,i i:JU'.il•:i:t'.y$t191�i�,Tt-!2Gt?�i.17C, /�T-� �A N �/[//�� PROT),IONOTARY My Comm. Exp. 1sf Mon..Jan. 2014 �.O THE �R-OTHONOTAI-C, CUiPENN YLVA,4i1ATY MARSHALL DENNEHEY WARNER COLEMAN& GOGGIN By: Christopher M. Reeser, Esquire ID No. 73632 4200 Crums Mill Road Harrisburg, PA 17112 717-651-3209 Our File No. 23091-00166 Attorney for Defendant MARY J. WILLIAMS COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : No. 13-4942 vs. WEIS MARKETS, INC. CIVIL ACTION—LAW Defendant JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned on behalf of Defendant, Weis Markets, Inc. in the above captioned case. MARSHALL DENNEHEY WARNER COLEMAN OGGIN By: Christo r M. Reeser, Esquire Attorney for Defendant ID# 73632 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 717-651-3509 Dated: September 17, 2013 P MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID No. 73632 4200 Crums Mill Road Harrisburg, PA 17112 717-651-3209 Our File No. 23091-00166 Attorney for Defendant MARY J. WILLIAMS COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. 13-4942 VS. WEIS MARKETS, INC. CIVIL ACTION—LAW Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE 1, Christopher M. Reeser, Esquire, of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on September 17, 2013, a copy of Defendant's Entry of Appearance via First Class United States mail, postage prepaid as follows: William P. Douglas, Esquire 43 W. South Street Carlisle, PA 17801 Attorney for Plaintiff Christopher M. Reeser f t' � 11L �t' .i 2;113 OCT 29 Ail I#: 2.5 CUMBERLAND COUNTY PENNSYLVANIA MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID No. 73632 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 717-651-3209 Our File No. 23091-00166 Attorney for Defendant MARY J. WILLIAMS • COURT OF COMMON PLEAS • CUMBERLAND COUNTY, PENNSYLVANIA • Plaintiff • No. 13-4942 • vs. WEIS MARKETS, INC. • CIVIL ACTION—LAW • Defendant • JURY TRIAL DEMANDED PRAECIPE FOR CHANGE OF ADDRESS To the Prothonotary: Kindly note the change of address of counsel for Defendant Weis Markets, Inc., from 4200 Crums Mill Road, Suite B, Harrisburg, PA 17112 to: Christopher M. Reeser, Esquire Marshall Dennehey Warner Coleman & Goggin Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 Phone: 717-651-3509 Respectfully submitted, MARSHALL DENNEHEY WARNER COLEM OGGIN By: Christopher M. Reeser, Esquire Attorney for Defendant ID# 73632 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 717-651-3509 Dated: October 28, 2013 MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID No. 73632 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 717-651-3209 Our File No. 23091-00166 Attorney for Defendant MARY J. WILLIAMS • COURT OF COMMON PLEAS • CUMBERLAND COUNTY, PENNSYLVANIA • Plaintiff • No. 13-4942 • vs. WEIS MARKETS, INC. • CIVIL ACTION—LAW • Defendant • JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Christopher M. Reeser, Esquire, of Marshall, Dennehey, Warner, Coleman& Goggin, do hereby certify that on October 28, 2013, a copy of Defendant's Praecipe for Change of Address via First Class United States mail, postage prepaid as follows: William P. Douglas, Esquire 43 W. South Street Carlisle, PA 17801 Attorney for Plaintiff Christopher M. Reeser 1 2;)13O T 31 Ail 1(: 21) CUMBERLAND COLIii";" PENNSYLVANIA MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M.Reeser, Esquire ID No. 73632 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 717-651-3509 Our File No. 23091-00166 Attorney for Defendant MARY J. WILLIAMS • COURT OF COMMON PLEAS • CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • • No. 13-4942 vs. • WEIS MARKETS, INC. • CIVIL ACTION—LAW • Defendant • JURY TRIAL DEMANDED PRAECIPE FOR A RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Kindly issue a Rule directing Plaintiff, Mary J. Williams, to file a Complaint in the above-referenced matter within twenty (20) days of service thereof or risk a judgment of non pros. MARSHALL DENNEHEY WARNER COLEMA GGIN By: Christopher M. Reeser, Esquire Attorney for Defendant ID# 73632 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 717-651-3509 Dated: October 30, 2013 MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID No. 73632 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 717-651-3509 Our File No. 23091-00166 Attorney for Defendant MARY J. WILLIAMS : COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • : No. 13-4942 vs. WEIS MARKETS, INC. • CIVIL ACTION—LAW Defendant JURY TRIAL DEMANDED RULE AND NOW, this 3/day of LOr ft-en.. , 2013, upon consideration of the foregoing Praecipe, Plaintiff, Mary J. Williams, is hereby ordered to file a Complaint within twenty (20) days hereof or suffer judgment of non pros. BY THE PROTHONOTARY: By: I MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID No. 73632 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 717-651-3509 Our File No. 23091-00166 Attorney for Defendant MARY J. WILLIAMS • COURT OF COMMON PLEAS • CUMBERLAND COUNTY, PENNSYLVANIA • Plaintiff • No. 13-4942 • vs. WEIS MARKETS, INC. • CIVIL ACTION—LAW Defendant • JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Christopher M. Reeser, Esquire, of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on October 30, 2013, a copy of Defendant's Rule to File Complaint via First Class United States mail, postage prepaid as follows: William P. Douglas, Esquire 43 W. South Street Carlisle, PA 17801 Attorney for Plaintiff Christopher M. Reeser TN: 1 i DOUGLAS LAW OFFICE a 43 WEST SOUTH STREET 4,J13 DEC `9 Pli 3: WILLIAM P.DOUGLAS,ESQ. CARLISLE PA 17013 Supreme Court I.D.#37926 TELEPHONE 717-243-1790 l r fBt NL.4 ND C JUf1 T'' PtNNSYL.v1 N Its" Mary J. Williams In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs No. 13—4942 Civil Term Weis Markets, Inc., Cumberland County, Pennsylvania. Civil Action-Law Defendant 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 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 OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S.Bedford Street Carlisle PA 17013 717-249-3166 -, _ BY i DATE: December 9, 2013 COMPLAINT 1. The plaintiff, Mary J. Williams, is an adult individual residing at 900 Barlow Greenmount Road, Gettysburg, Adams County, Pennsylvania. 2. The defendant Weis Markets, Inc. maintains business offices at 1000 South Second Street, Sunbury, Pennsylvania. 3. The defendant, Weis Markets, Inc., is a Pennsylvania Corporation doing business throughout the Commonwealth of Pennsylvania with stores in all south central county locations. 4. Weis Markets, Inc., owns and operates a store at 860 Carlisle Street, Hanover, Pennsylvania. At all times relevant hereto the aforesaid real property was under the care, custody and control of agents, representatives and employees of the defendant corporation while acting within the course and scope of their employment with said Corporation. 5. On or about August 18, 2011, at approximately 8:45 pm the plaintiff Mary J. Williams went to the premises of the defendant for the purposes of shopping and as such was a business invitee. 6. After entering the building, the plaintiff proceeded to walk down an aisle in an area of the store that was open to the public when the plaintiff slipped and fell in an area where water had accumulated on the floor of the premises and was injured. 7. Due to the negligence of the defendants, the plaintiff Mary J. Williams, slipped and fell in an area where water was permitted to accumulate on the floor. 8. The defendants were negligent in the following respects; a) in failing to inspect and maintain the real estate to make it safe for the intended use; b) in failing to repair leaks in the roof which allowed water to enter the building; c) in failing to remove water from the interior floor of which they knew or should have known was present and posed a hazard to the public; d) having knowledge of said hazardous condition, in failing to warn the plaintiff Mary J. Williams, and others who would traverse said area, of the dangerous and perilous condition; e) in failing to inspect the real property to ascertain that it was safe for public use. 9. As a direct and proximate result of the negligence of the defendant the plaintiff, Mary J. Williams, suffered harm. 10. Her injuries include but are not limited to the following: a) Injury and/or aggravation to back and her right knee; and b) sprain and strain to her back and leg. 11. As a result of his injuries the plaintiff has incurred medical expenses in the past and may continue to incur the same in the future. 12. As a result of her injuries the plaintiff has incurred pain and suffering and may continue to incur the same in the future. 13. As a result of her injuries the plaintiff has incurred aggravation and inconvenience, and a loss of life's pleasures, and may continue to incur the same in the future. 14. As a result of the injuries the plaintiff sustained on August 18, 2011, she has suffered a loss of wages and as a direct and proximate result of her injuries the plaintiff's economic horizons may be limited. WHEREFORE, it is prayed that judgment be entered in favor of the plaintiff Mary J. Williams, and against the defendant in an amount in excess of that requiring compulsory referral to arbitration. Respectfully submitte•, December 9, 2013 AFFIDAVIT I HEREBY SWEAR OR AFFIRM THAT THE INFORMATION CONTAINED IN AFORESAID COMPLAINT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE AND/OR INFORMATION AND BELIEF. THIS IS MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S.§ 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. William P. Douglas, sq. for Mary J. Williams December 9, 2013 THE- PRO T HONO TA 2013 DEC 26 PM 2: 38 . CUMBERLAND COUNTY PENNSYLVANIA MARSHALL DENNEHEY WARNER COLEMAN& GOGGIN By: Christopher M. Reeser, Esquire ID No. 73632 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 717-651-3509 Our File No. 23091-00166 Attorney for Defendant MARY J. WILLIAMS : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA • Plaintiff • No. 13-4942 vs. WEIS MARKETS, INC. : CIVIL ACTION—LAW • Defendant . : JURY TRIAL DEMANDED NOTICE TO PLEAD TO: William P. Douglas, Esquire 43 W. South Street Carlisle, PA 17801 Attorney for Plaintiff You are hereby notified to plead to the enclosed New Matter within twenty (20) days from service hereof or a default judgment may be filed against you. Respectfully submitted, MARSHALL DENNEHEY WARNER COLEMA . *I GGIN By: Christopher M. Reeser, Esquire Attorney for Defendant ID# 73632 Suite 201 • 100 Corporate Center Drive Camp Hill, PA 17011 717-651-3509 Dated: December 24, 2013 LE4 -OtF F { i3 DEC 26 PM 2: 58 O UNIBERLA O COUNTY PENNSYLVANIA MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID No. 73632 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 717-651-3509 Our File No. 23091-00166 Attorney for Defendant MARY J. WILLIAMS • COURT OF COMMON PLEAS . CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff • No. 13-4942 vs. WEIS MARKETS, INC. • CIVIL ACTION—LAW Defendant : JURY TRIAL DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER TO PLAINTIFF'S COMPLAINT 1. Denied pursuant to Pa.R.C.P. 1029(e). 2. Admitted. 3. Denied as stated. It is admitted that Weis Markets, Inc. is a Pennsylvania corporation doing business in the Commonwealth of Pennsylvania. It is also admitted that Weis Markets has stores in some South Central county locations depending upon the definition of a "South Central county location." It is denied that Weis Markets does business "throughout the Commonwealth of Pennsylvania." 4. Admitted. 1 5. Admitted in part; denied in part. It is admitted that Plaintiff Mary J. Williams was on the Weis Markets'premises located at 860 Carlisle Street in Hanover on August 18, 2011, at 8:45 p.m. The remainder of the allegation in paragraph 5 is denied as a legal conclusion to which no responsive pleading is required. 6. Admitted in part; denied in part. It is admitted that, upon information and belief, Plaintiff slipped and fell in an area of the store near where water had accumulated on the floor of the property. The remainder of the allegation in paragraph 6 is denied pursuant to Pa.R.C.P. 1029(e). 7. Denied that Plaintiff Mary J. Williams slipped and fell in an area where water was permitted to accumulate on the floor. 8. The averments of Paragraph 8 and subparagraphs 8(a)-8(e) are conclusions of law to which no responsive pleading is required. To the extent that said averments in Paragraph 8 and subparagraphs 8(a)-8(e) are deemed to be factual, those averments are denied pursuant to Pa.R.C.P. 1029(e) and strict proof thereof is demanded at time of trial. 9. The allegation in paragraph 9 is a legal conclusion to which no responsive pleading is required. 10. Denied pursuant to Pa.R.C.P. 1029(e). 11. Denied pursuant to Pa.R.C.P. 1029(e). 12. Denied pursuant to Pa.R.C.P. 1029(e). 13. Denied pursuant to Pa.R.C.P. 1029(e). 14. Denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, Defendant requests judgment be entered in its favor. 2 NEW MATTER 15. Plaintiffs' claims or any amendment to those claims may be barred by the applicable statute of limitations. 16. Plaintiffs claims are barred or limited by her own contributory negligence pursuant to 42 Pa. C.S.A. §7102. 17. To the extent that there was a dangerous or defective condition on Defendant's property, which is specifically denied, Defendant did not create and was not on notice of said dangerous condition. WHEREFORE, Defendant requests judgment be entered in its favor. Respectfully submitted, MARSHALL DENNEHEY WARNER COLEM• : ' OGGIN By: C ris opher M. Reeser, Esquire Attorney for Defendant ID# 73632 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 717-651-3509 Dated: December 24, 2013 3 r VERIFICATION I,Bart Shaffer,hereby state and aver that I have read the foregoing document which has been drafted by my counsel. The factual statements contained therein are true and correct to the best of my knowledge, information and belief although the language is that of my counsel,and, to the extent that the content of the foregoing document is that of counsel, I have relied upon counsel in making this Verification. This statement is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. BART SHAFFER, Risk Manager Weis Markets,Inc. Dated: 1a do cPO13 23091-00166/AWNM 4 HLLtJ-0Fr`i1✓=': THE PRO H 1Hc`L'i1:, 2€H3 DEC 26 P!1 2: 58 CUMBERLAND COUNTY PENNSYLVANIA MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID No. 73632 Suite 201 100 Corporate Center Drive Camp Hill, PA 17011 717-651-3509 Our File No. 23091-00166 Attorney for Defendant MARY J. WILLIAMS • COURT OF COMMON PLEAS • CUMBERLAND COUNTY, PENNSYLVANIA • Plaintiff : No. 13-4942 vs. WEIS MARKETS, INC. • CIVIL ACTION—LAW Defendant : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Christopher M. Reeser, Esquire, of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on December 24, 2013, a copy of Defendant's Answer with New Matter via First Class United States mail, postage prepaid as follows: William P. Douglas, Esquire 43 W. South Street Carlisle, PA 17801 Attorney for Plaintiff 40. Christopher M. Reeser • Commonwealth of Pennsylvania County of Cumberland Mary J. Williams VS Weis Markets, Inc. Plaintiff Defendant In the Court of Common Pleaswof Cumberland County, Pennsylival c rn No. 13 — 4942 Civil Terntfj 7: 4 Civil Action — Law Jury Trial Demanded Praecipe to Settle and Discontinue Dear Mr. Buell: Please mark the above captioned matter settled and discontinued with prejudice. date: April 10,2014 %JL ilham P. Do ; las, Esq. Douglas L : Office 43 West Sol Street Carlisle, Pennsylvan . 17013 (717) 243 —1790