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Home My WebLink About05-0241ANGINO & ROVNER, P.C. Joseph M. Melillo, Esquire Attorney ID# : 26211 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: jmelillo@angino-rovner.com VIRGINIA BANGOUP and ARSENE BANGOUP, her husband Plaintiffs V. GIANT FOOD STORES, LLC Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW SLIP AND FALL ACTION" NO. 5 -,-2 IL// ei c ! JURY TRIAL DEMANDED NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 717/249 3166 291432 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se persentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a , las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier soma de dinero reclamada en la demanda o cualquier otra reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Used puede perder dinero o propiedad u otros derechos importantes para used. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 717/249 3166 291432 ANGINO & ROVNER, P.C. Joseph M. Melillo, Esquire Attorney ID# : 26211 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: jmelillo@angino-rovner.com VIRGINIA BANGOUP and ARSENE BANGOUP, her husband Plaintiffs V. GIANT FOOD STORES, LLC, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW SLIP AND FALL ACTION NO. D5 -- l.?cvc(, 1?jL JURY TRIAL DEMANDED COMPLAINT 1. Plaintiffs Virginia Bangoup and Arsene Bangoup are adult individuals who reside at 1877 Spring Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant Giant Food Stores, LLC is a Delaware Corporation which regularly conducts business at Spring Garden Road, Carlisle, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on or about May 15, 2003, near the Pharmacy section of Defendant Giant Food Stores, LLC, located at Spring Garden Road, Carlisle, Cumberland County, Pennsylvania. 4. At that time and place, Plaintiff Virginia Bangoup was about to exit the pharmacy section and was walking toward the door in the aforementioned Giant Store. 5. Virginia Bangoup's right foot slipped on a greasy substance approximately 14-16 inches, causing her left knee to twist, and causing Plaintiff Virginia Bangoup to lose her balance and fall. 6. Immediately after the fall, Plaintiff Virginia Bangoup was assisted by the 290731 Assistant Manager who identified the substance as shampoo and informed Plaintiff Virginia Bangoup that there were no warning signs posted and at that time they were in the process of cleaning the substance off of the floor, around the corner and down the aisle. Plaintiff Virginia Bangoup also observed that there were no warning signs posted in the area. 7. The aforementioned accident and resulting injuries sustained by Plaintiff Virginia Bangoup. are the direct and proximate result of the careless, reckless, and negligent conduct of the employees of Defendant Giant Food Stores, LLC as follows: (a) failed to properly inspect and maintain its premises; (b) allowed dangerous foreign substance to accumulate in an area used by business invitees; (c) failed to properly inspect the floor of the premises for the presence of foreign slippery liquids in an area used extensively by business invitees; (d) failed to remove any present or accumulated substances of which the Defendant was aware or should have been aware; (e) failed to properly warn business invitees, of the possibility of slippery conditions, and the possibility of slipping and falling on such substances; (f) failed to take proper measures to eliminate accumulation of substances on the premises; and (g) failed to exercise the high degree of care that a business or landowner owes to business invitees utilizing the premises for its intended purposes. COUNTI Virginia Baneoup v. Giant Food Stores, LLC 8. Paragraphs 1 through 7 of Plaintiffs' Complaint are incorporated herein by reference. 9. As a direct and proximate result of the aforementioned fall, Plaintiff Virginia 290731 Bangoup sustained painful and severe injuries, which include but are not limited to injury to her left knee 10. As a result of the injuries sustained, Plaintiff Virginia Bangoup was forced to incur liability for medical treatment, medications, hospitalizations, and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefore. 11. Because of the nature of her injuries, Plaintiff Virginia Bangoup has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefore. 12. As a result of the aforementioned accident and resulting injuries, Plaintiff Virginia Bangoup has undergone and in the future will undergo great physical and mental suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefore. 13. As a result of the aforementioned accident and resulting injuries, Plaintiff Virginia Bangoup has been and in the future will be subject to great humiliation and embarrassment, and claim is made therefore. 14. Plaintiff Virginia Bangoup continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefore. 15. As a result of the aforementioned injuries, Plaintiff Virginia Bangoup has sustained work loss and may sustain permanent diminution of her earning power and capacity, and claim is made therefore. 16. As a result of the aforesaid injuries, Plaintiff Virginia Bangoup has sustained uncompensated work loss, and claim is made therefore. 290731 WHEREFORE, Plaintiff Virginia Bangoup demand judgment against Defendant Giant Food Stores, LLC in an amount in excess of Twenty Five Thousand Dollars ($25,000.00), exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. COUNTI Arsene Baneoup v. Giant Food Stores, LLC 17. Paragraphs 1 through 16 of the Complaint are incorporated herein by reference. 18. As a result of the aforementioned injuries sustained by his wife, Plaintiff Virginia Bangoup , Plaintiff Arsene Bangoup has been and may in the future be deprived of the care, companionship, consortium, and society of his wife, all of which will be to her great detriment, and claim is made therefor. WHEREFORE, Plaintiffs Virginia Bangoup and Arsene Bangoup demand judgment against Defendant Giant Food Stores, LLC in an amount in excess of Twenty Five Thousand Dollars ($25,000.00) exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. Date: 0 1 ill 105 Respectfully submitted, ANGINO & ROVNER, P.C. M Y? Jos ,Melillo A rney I.D. No. 26211 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Attorney for Plaintiffs 290731 VERIFICATION 1, Virginia Bangoup, Plaintiff hereby verify that the facts set forth in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unworn falsification to authorities. WITNESS: 1 ley A?IRGINIA ?4 Date: D-ec 04? C'e ' ?2c4 290750 oow`` -- _,, C 1 rr.. ?? -C ) F\FILES\DATAPILE\MAC9500\Cw enc\340.pm I\mvn Crewed 920/04 0.06PM Revised: 2/2/05 3 14PM 9500340 George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant VIRGINIA BANGOUP and ARSENE BANGOUP, her husband, Plaintiffs, V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-241 CIVIL ACTION - LAW GIANT FOOD STORES, LLC, Defendant. JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Defendant in the above matter. Defendant hereby demands a twelve juror jury trial in the above captioned action. MARTSON DORFF WILLIAMS & OTTO By-- G e oir?g e$ ller, Jr., Esquire I.D. No. 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Dated: 91 ? ? j CERTIFICATE OF SERVICE I, Melissa A. Mowery, an authorized agent for Manson ]Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Joseph M. Melillo, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 MARTSON DEAI:DORFF WILLIAMS & OTTO By Ot Melissa A. Mowery Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: `???L? ^ r.. • ? 'ri _i -r ; ,.: _ ',:J S"?.) .. ?J -..i L" ?? r M Lti U11 v1 IUm'n..,_ .=ya ,nsrm+??„ rem J' 4'004 0OI PII R-,n d ]/II'"F I ISP.V 9IQ, id l George B. Fatter, Jr., Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant VIRGINIA BANGOUP and ARSENE BANGOUP, her husband, Plaintiffs, V. GIANT FOOD STORES, LLC, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-241 CIVIL ACTION - LAW JURY TRIAL DEMANDED DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT AND NOW, comes the Defendant, Giant Food Stores, LLC, by and through its attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and hereby responds to Plaintiff's Complaint as follows: After reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or falsity of these averments. Denied as stated. To the contrary, Defendant Giant Food Stores, LLC is a Delaware Limited Liability Company. It is admitted that Giant Food Stores, LLC regularly conducts business at Spring Garden Road, Carlisle, Cumberland County, Pennsylvania. 1-7. Denied pursuant to Pa. R.C.P. 1029(e). COUNT I Virginia Bangoup v. Giant Food Stores. LLC 8. The averments of paragraphs 1 through 7 of this Answer are hereby incorporated by reference. 9.-16. Denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, Defendant Giant Food Stores, LLC demands judgment in its favor and dismissal of Plaintiff's Complaint with prejudice. COUNT II Arsene Bangoup v. Giant Food Stores, LLC 17. The averments of paragraphs 1 through 16 of this Answer are hereby incorporated by reference. 18. Denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, Defendant Giant Food Stores, LLC demands judgment in its favor and dismissal of Plaintiff's Complaint with prejudice. MARTSON DEARDORFF WILLIAMS & OTTO By George B. Faller, Jr., Esquire I.D. No. 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Dated: ?. ?C VERIFICATION I, LIZABETH CHRISTMAN, Director, Risk Management Department of Giant Food Stores, LLC, acknowledge that I have the authority to execute this Verification on behalf of Giant Food Stores, LLC and certify that the foregoing Answer is based upon information which has been gathered by my counsel in the preparation of this lawsuit. The language of this Answer is that of counsel and not my own. I have read the document and to the extent that this Answer is based upon information which I have given to my counsel, it is true and correct and to the best of my knowledge, information and belief. To the extent that the content of this Answer is that of counsel, I have relied upon counsel in making this Verification. This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. Giant Food Stores, LLCM? !! AA '' -- C?V ? Lizabet Christman Director-Risk Management Dated: 1z AFILESVDATAEILE\MAC9500ACuventA340.ansI CERTIFICATE OF SERVICE I, Melissa A. Mowery, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Defendant's Answer to Plaintiff's Complaint was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Joseph M. Melillo, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 MARTSON DEARDORFF WILLIAMS & OTTO BY ?' 1 I 01 t }'f, Melissa A. Mowery Ten East High Street Carlisle, PA 17013 (717) 243-3341 J'J?' Dated: r.?i l .Jl -? +Y T ?. 1lt f ??.t n, tl ..,{it ?^ 1 ," a c,? CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VIRGINIA BANGOUP TERM, -VS- GIANT FOOD STORES, LLC CASE NO: 05-241 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE FALLER, JR., ESQ. 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 twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 03/02/2005 MCS on behalf of l Ei?j G ??? ? lJ GE GE F ER, JR., E Attorney for DEFENDANT DE11-546919 8 0 9 8 0- L 0 1- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VIRGINIA BANGOUP vs. GIANT FOOD STORES, LLC File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOSEPH A PION D O (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: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street. Suite 800. Philadelphia. PA 19103 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: GEORGE FALLER, JR., ESQ. ADDRESS: 10 E. HIGH STREET CARLISLE. PA 17013 TELEPHONE: _(215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant ??M.4R 0 2 2005 Date: ?5 _ 1'7f an/?S Seal of the Court BY HE COURT: Prothonotary/Clerk, Civil Divisi Deputy 80980-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOSEPH A. PION, D.O. 100 S. HIGH STREET NEWVILLE, PA 17241 RE: 80980 VIRGINIA BANGOUP Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING CHART,MRI'S Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : VIRGINIA BANGOUP 208 NORTH HANOVER STREET, CARLISLE, PA 17013 Social Security 1{: 165-56-8204 Date of Birth: 01-14-1968 SU10-547704 8 0 9 8 0-L,0 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS VIRGINIA BANGOUP TERM, -vs- GIANT FOOD STORES, LLC CASE NO: 05-241 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GEORGE FALLER, JR 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 twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/02/2005 GEORGE FALLER, JR., ES Attorney for DEFENDANT DE11-546920 80980-1,02 C O M M O N W E A L,T H OP P E N N S Y L VANS A COUNTY OP C UM B E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS VIRGINIA BANGOUP -VS- GIANT FOOD STORES, LLC INTENT TO SERVE TERM, CASE NO: 05-241 fLE 4009.21 JOSEPH A. PION, D.O. MEDICAL RECORDS & XRAYS ORTHOPEDIC INSTITUTE OF PA MEDICAL RECORDS & XRAYS TO: JOSEPH MELILLO, ESQ., PLAINTIFF COUNSEL MCS on behalf of GEORGE FALLER, JR., ESQ. 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 the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/10/2005 CC: GEORGE FALLER, JR., ESQ. - 9500.340 MCS on behalf of GEORGE FALLER, JR_, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292082 8 0 9 8 0- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VIRGINIA BANGOUP vs. GIANT FOOD STORES, LLC File No. 05-241 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ORTHOPEDIC INSTITUTE OF PA (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: **** SEE ATTACHED RIDER **** at The MCC Groun Inc 1601 Market Street. Suite 800, Philadelphia PA 19103 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: GEORGE FALLER. JR.. ESO. ADDRESS: 10 E. HIGH STREET CARLISLE. PA 17013 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR 0 2 2005 Date: . `71, ) r-)6S Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Divisi 80980-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPEDIC INSTITUTE OF PA 875 POPLAR CHURCH ROAD CAMP HILL, PA 17011 RE: 80980 VIRGINIA BANGOUP Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING CHARTS,MRI'S Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : VIRGINIA BANGOUP 208 NORTH HANOVER STREET, CARLISLE, PA 17013 Social Security #: 165-56-8204 Date of Birth: 01-14-1968 SU10-547706 8 0 9 8 0- 1, 0 2 ,; CASE NO: 2005-00241 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANGOUP VIRGINIA ET AL VS GIANT FOOD STORES KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GIANT FOOD S the DEFENDANT , at 1550:00 HOURS, on the 14th day of January , 2005 at 255 SOUTH SPRING GARDEN STREET CARLISLE, PA 17013 by handing to ANDY MOTTER, ASSISTANT MANAGER ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18. 00 3 . 70 . 00 10. 00 R. Thomas Kline . 00 31. 70 01/18/2005 ANGINO & ROVNER Sworn and Subscribed to before By: me this Pyt, day of „1dUS A.D. Prothonotary T ANGINO & ROVNER, P.C. Joseph M. Melillo, Esquire Attorney ID# : 26211 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: imeliIlo@angino-rovner.com VIRGINIA BANGOUP and ARSENE BANGOUP, her husband Plaintiffs V. GIANT FOOD STORES, LLC Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW SLIP AND FALL ACTION NO. 05-241 Civil Term JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Please mark the above-captioned action as settled, satisfied, and discontinued, with prejudice. Respectfully submitted, ANGINO & ROVNER, P.C. Date: August _', 2007 J 5§epIYM. Melillo, Esquire Attorney I.D. No. 26211 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 Attorney for Plaintiffs 361993 C ?f t""=. ?' ?s1 ?y t-tl M ?. c-n