Loading...
HomeMy WebLinkAbout13-7249 Supreme Cou Pke nnsylvania �� Cour r4fo OII1ITll leas For Pr otlrorrotar1 Use Onl <; C v r Sh et S °� 7" Docket No: CU =an County The information collected on this fibrin is rased solely for court administration purposes. This form does not supplement or replace the,liling and service of pleadings or other papers as required by laiv or rules of court. Commencement of Action: S xl Complaint © Writ of Summons Petition E ® Transfer from Another Jurisdiction © Declaration of Taking C Lead Plaintiffs Name: Lead Def'endant's Namc: Donald Deaven Jessica Juran T Dollar Amount Requested: ❑ within arbitration limits I Are money damages requested? El Yes ® No (check one) iic, outside arbitration limits O N Is this a Class Action Suit? © Yes ED No Is this an MDJAppeal? Q Yes El No A Name of Plaintiff /Appellant's Attorney: CHRISTINA L. BRADLEY Check here if you have no attorney (are a Self - Represented [Pro Sel 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 Moss Tort) CONTRACT (do not inchrde.tudgments) CIVIL APPEALS J Intentional Buyer Plaintiff Administrative Agencies Q Malicious Prosecution © Debt Collection: Credit Card 0 Board of Assessment xl Motor Vehicle Debt Collection: Other [3 Board of Elections ® Nuisance Dept. of Transportation S ® Premises Liability Statutory Appeal: Other Product Liability (does not include ® Employment Dispute: E mass tort) ® Slander/Libel/ Defamation Discrimination ® C ® Other: Employment Dispute: Other Zoning Board T 8 Other: 1 Q Other: O MASS TORT 0 Asbestos N © Tobacco 0 Toxic Tort - DES 13 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS Toxic Waste Ej ® 0 Other: J ectment 13 Common Law /Statutory Arbitration B E3 Eminent Domain /Condemnation [3 Declaratory Judgment Ground Rent Mandamus Landlord /Tenant Dispute Non - Domestic Relations J Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure: Commercial Quo Warranto 11 Dental Partition Replevin Q Legal E3 Quiet Title Other: Medical Other: ® Other Professional: Updated 1/1/2011 fir THE M L ED OFF I CE QTHOnTA R Y Christina L. Bradley, Esquire `!O FREEBURN & HAMILTON fi p EC —b f ID No. 89107 UM ERLANO COUNTY 2040 Linglestown Road �+ C Suite 300 PENNSYLVANIA Harrisburg PA 17110 (717) 671 -1955 Attorney for Plaintiffs christinab &pa- iniurylawyer.com DONALD DEAVEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, ENNSYLVANIA V. NO. / 3 -�? / - 1 C!1/ CIVIL ACTION - LAW JESSICA JURAN, Defendant 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 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. 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 (800) 990 -9108 Dated: 11 1 3 `u�o. V S Christina L. Bradley, Es ire Attorneys for Plaintiff aO Christina L. Bradley, Esquire FREEBURN & HAMILTON ID No. 89107 2040 Linglestown Road Suite 300 Harrisburg PA 17110 (717) 671 -1955 Attorney for Plaintiffs christinab(a�pa- iniurylawyer. com DONALD DEAVEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CIVIL ACTION - LAW JESSICA JURAN, Defendant NOTICE LISTED HA SIDO DEMANDADO /A EN CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar ua apariencia esrita 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 tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio,que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para. usted. LISTED DEBE LLEVAR ESTATE DOCUMENTO A SU ABOGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEQUIR UN ABOGADO. SI USTED 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 S. Bedford Street Carlisle, PA 17013 (800) 990 -9108 Dated: I ? 7 Christina L. Bradley, Esq re Attorneys for Plaintiff 2 Christina L. Bradley, Esquire FREEBURN & HAMILTON ID No. 89107 2040 Linglestown Road Suite 300 Harrisburg PA 17110 (717) 671 -1955 Attorney for Plaintiffs christinab(rD,pa- iniurylawver. com DONALD DEAVEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CIVIL ACTION - LAW JESSICA JURAN, Defendant COMPLAINT AND NOW comes Plaintiff, Donald Deaven, by his attorneys, Freeburn 8a Hamilton, and files the following Complaint: 1. Plaintiff, Donald Deaven, is an adult individual who resides at 2160 Camelot Drive, Apartment A3, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, Jessica Juran, is an adult individual who resides 2015 Briggs Street, Harrisburg, Dauphin County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on or about December 30, 2011, at approximately 9:30 p.m. at the intersection of Orrs Bridge Road and Creekview Road in Hampden Township, Cumberland County, Pennsylvania. 4. At or about that time and place, Plaintiff, Donald Deaven, was operating his motor vehicle northbound on Orrs Bridge Road approaching the intersection with Creekview Road. 5. At or about that time and place, Defendant, Jessica Juran, was operating a motor vehicle eastbound on Creekview Road. i 6. At or about that time and place, the traffic signal at the intersection of Orrs Bridge Road and Creekview Road was red for the direction in which Defendant, Jessica Juran, was travelling. 7. At or about that time and place, the traffic signal at the intersection of Orrs Bridge Road and Creekview Road was green for the direction in which Plaintiff, Donad Deaven was travelling. 8. At or about that time and place, Defendant, Jessica Juran, went through the red light controlling her direction of travel without stopping, at which time she struck the driver side of the vehicle driven by Plaintiff, Donald Deaven. 9. By reason of the aforesaid collision, Plaintiff suffered painful and severe injuries to his nerves, bones and soft tissues which include, but are not limited to, head, neck, chest and back injuries. 10. By reason of the aforesaid collision and injuries, Plaintiff suffered a heightened possibility that he will suffer other or additional injury in the future, and claim is made therefore. 11. The aforesaid collision and injuries suffered by Plaintiff may have aggravated or been aggravated by an existing infirmity, condition or disease, resulting in a prolongation or worsening of the injuries and an enhanced risk of future harm to Plaintiff, and claim is made therefore. 12. By reason of the aforesaid collision and injuries, Plaintiff has been forced to incur liability for reasonable and necessary medical tests, medical examinations, medical treatment, medications, hospitalizations and similar expenses in an effort to diagnose his injuries and to restore him to health, and claim is made therefore. 2 13. Plaintiff has not fully recovered from his injuries and it is reasonably likely that he will incur similar expenses in the future, and claim is made therefore. 14. By reason of the aforesaid collision and injuries, Plaintiff has suffered a loss of earnings and earning capacity and is entitled to recover the value of the time, earnings and employment benefits he has lost and which he might reasonably have earned in the pursuit of his ordinary calling, and claim is made therefore. 15. By reason of the aforesaid collision and injuries, Plaintiff has suffered a loss or impairment of future earning capacity, and claim is made therefore. 16. By reason of the aforesaid collision and injuries, Plaintiff has incurred incidental costs and expenses the exact amount of which cannot be ascertained at this time, and claim is made therefore. 17. By reason of the aforesaid collision and injuries, Plaintiff has undergone and in the future will undergo great physical and mental pain and suffering, great inconvenience in carrying out his daily activities, loss of life's pleasures and enjoyment, and claim is made therefore. 18. By reason of the aforesaid collision and injuries, Plaintiff has been subjected to severe humiliation, embarrassment, shame, worry and anger. 19. By reason of the aforesaid collision and injuries, Plaintiff has been subjected to severe mental anguish, emotional distress, nervous shock, fright and horror. 20. By reason of the aforesaid collision and injuries, Plaintiff will continue to endure great mental anguish, emotional distress, shame, worry and anger in the future. 3 21. By reason of the aforesaid collision and injuries, Plaintiff has been deprived his enjoyment of the pleasures of life. 22. By reason of the aforesaid collision and injuries, Plaintiff continues to be plagued by persistent pain and limitation and, therefore, avers that his injuries may be of a permanent nature, causing residual problems for the remainder of his lifetime, and claim is made therefore. 28. By reason of the aforesaid collision and injuries, Plaintiff has suffered a disfigurement, and claim is made therefore. 21. Plaintiff is entitled to recover non - economic damages because at the time of this accident, he was insured under an automobile insurance policy that provided the full tort option and because Plaintiff sustained a "serious injury," as that term is defined in the Pennsylvania Motor Vehicle Financial Responsibility Law. COUNT I Donald Deaven, Plaintiff v. Jessica Juran, Defendant 22. Paragraphs 1 -21 are incorporated herein by reference thereto. 23. The foregoing accident and all of the injuries and damages set forth hereinafter suffered by Plaintiff, Donald Deaven, are the direct and proximate result of the negligent, gross negligence, careless, wanton and reckless manner in which Defendant, Jessica Juran, operated her motor vehicle as set forth above and as follows: a. In operating her vehicle at an excessive rate of speed under the circumstances; b. In failing to have her vehicle under proper and adequate control; C. In failing to apply her brakes in time to avoid the collision; d. In negligently applying her brakes; 4 e. In failing to observe Plaintiffs vehicle on the highway; f. In failing to operate her vehicle in accordance with existing traffic conditions and traffic controls; g. In failing to exercise the high degree of care required of a motorist entering an intersection; h. In failing to drive at a speed and in the manner that would allow Defendant to stop within the assured clear distance ahead; i. In failing to properly observe traffic signals controlling Defendant's direction of travel; j. In failing to keep a reasonable look -out for other vehicles lawfully on the road; k. In attempting to enter an intersection when such movement could not be safely accomplished; 1. In failing to yield the right -of -way to traffic already upon the highway; M. In operating the vehicle in a manner not consistent with the road and weather conditions prevailing at the time; n. In failing to prudently proceed through the intersection so as to avoid creating a dangerous situation for other vehicles on the highway; o. In failing to observe oncoming traffic; and p. In proceeding through an intersection when such movement could not be made in safety; 24. Defendant's conduct, as set forth above, was in violation of the Pennsylvania Motor Vehicle Code, which is intended to protect persons lawfully on the highway such as Plaintiff, Donald Deaven, from personal injury, and thus constitutes negligence per se. 5 WHEREFORE, Plaintiff, Donald Deaven, demands judgment in his favor and against Defendant, Jessica Juran, in an amount in excess of FIFTY THOUSAND & 00/ 100 ($50,000.00) DOLLARS, exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. Respectfully Submitted, FREEBURN & HAMILTON, PC By: u L Christina L. Bradley, E uire I.D. No. 89107 2040 Linglestown Road Suite 300 Harrisburg PA 17110 (717) 671 -1955 Date: I Z�I ZO 3 Counsel for Plaintiffs 6 i I j 7 { I VERIFICATION j I, Donald Deaven, hereby verify that the statements in the j foregoing Complaint are true and correct. I understand that false 1 statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. i i Dated: Donald Deaven ` r i i i I I • Joseph R. D'Annunzio I.D. No. 23384 Attorney for Defendant, 4309 Linglestown Road, Suite 211, «FirmAddr2» Jessica Juran Harrisburg, PA 17112 (717)901-5002 Fax: (717) 901-5012 r i c.. ry IN THE COURT OF COMMON PLEAS OF rn CUMBERLAND COUNTY, PENNSYLVANIA 'c, Cnr- Donald Deaven • =� Plaintiff No. �- ?d4/9 '� • v. • Civil Action — Law �. Jessica Juran, • Jury Trial Demanded • Defendant PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Defendant, Jessica Juran, in the above- captioned matter. LAW OFFICE OF JOSEPH R. D'ANNUNZIO Date: n".i, Z�/ BY: A 2 � Joseph R. D'Annunzio, Esquire Attorney for Defendant >. . CERTIFICATE OF SERVICE I HEREBY CERTIFY that I am this day served a true and correct copy of the foregoing document upon the persons and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first-class postage prepaid, addressed as follows: Christina Bradley, Esquire Freeburn & Hamilton 2040 Linglestown Road, Suite 300 Harrisburg, PA 17110 Date: ti By: „AM*' • Kim f ly Stielper BY:Joseph R.D'Annunzio Law Law Office of Joseph R. • Identification No.23384 �� 4309 Linglestown Road, Suite 211oe�for Defendant,Jessica Juran Harrisburg,PA 17112 CUMBERLAND(717)901-5002 PENNSYLVANIA (717)901-5012(Fax) jdannunzio@geico.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONALD DEAVEN, Plaintiff NO. 13-7249 V. CIVIL ACTION -LAW JESSICA JURAN, JURY TRIAL DEMANDED Defendant NOTICE TO PLEAD TO: Donald Deaven c/o Christina Bradley, Esquire Freeburn& Hamilton 2040 Linglestown Road, Suite 300 Harrisburg, PA 17110 You are hereby notified to file a written response to the enclosed Answer and New Matter of Defendant to Plaintiff's Complaint within twenty (20) days from service hereof or a default judgment may be entered against you. LAW OFFICE OF JOSEPH R. D'ANNUNZIO Date: January 7, 2014 By: ose P h R. D'Annunzio, Attorney for Defendant, Jessica Juran BY:Joseph R.D'Annunzio Law Office of Joseph R. Identification No.23384 4309 Linglestown Road, Suite 211 Attorney for Defendant,Jessica Juran Harrisburg,PA 17112 (717)901-5002 (717)901-5012(Fax) jdannunzio@geico.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DONALD DEAVEN, Plaintiff NO. 13-7249 v. CIVIL ACTION - LAW JESSICA JURAN, JURY TRIAL DEMANDED Defendant ANSWER AND NEW MATTER OF DEFENDANT,JESSICA JURAN, TO PLAINTIFF'S COMPLAINT 1. Admitted only upon information and belief. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. After reasonable investigation the answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments set forth in this paragraph. Accordingly, the averments are deemed denied and strict proof is demanded. 7. After reasonable investigation the answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments set forth in this paragraph. Accordingly, the averments are deemed denied and strict proof is demanded. 8. Admitted in part and denied in part. It is admitted only that the vehicle operated by the Defendant, Jessica Juran collided with the vehicle operated by the Plaintiff, Donald Deaven. After reasonable investigation the answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the remaining averments set forth in this paragraph. Accordingly,the averments are deemed denied and strict proof is demanded. 9. After reasonable investigation the answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments set forth in this paragraph regarding injuries and damages. Accordingly, the averments are deemed denied and strict proof is demanded. 10. After reasonable investigation the answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments set forth in this paragraph regarding injuries and damages. Accordingly, the averments are deemed denied and strict proof is demanded. 11. After reasonable investigation the answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments set forth in this paragraph regarding injuries and damages. Accordingly, the averments are deemed denied and strict proof is demanded. 12. After reasonable investigation the answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments set forth in this paragraph regarding injuries and damages. Accordingly,the averments are deemed denied and strict proof is demanded. 13. Denied as a conclusion of law to which no responsive pleading is required. 14. Denied as a conclusion of law to which no responsive pleading is required. 15. Denied as a conclusion of law to which no responsive pleading is required. 16. Denied as a conclusion of law to which no responsive pleading is required. 17. Denied as a conclusion of law to which no responsive pleading is required. 18. Denied as a conclusion of law to which no responsive pleading is required. 19. Denied as a conclusion of law to which no responsive pleading is required. 20. Denied as a conclusion of law to which no responsive pleading is required. 21. Denied as a conclusion of law to which no responsive pleading is required. 22. Denied as a conclusion of law to which no responsive pleading is required. 23. Incorrectly identified as number 28. Denied as a conclusion of law to which no responsive pleading is required. 24. Incorrectly identified as number 21. Denied as a conclusion of law to which no responsive pleading is required. COUNT I. Donald Deaven,Plaintiff v. Jessica Juran,Defendant 25. The answers to paragraphs 1-24 are incorporated by reference as if fully set forth herein. 26. Incorrectly labeled as 23. Denied as a conclusion of law to which no responsive pleading is required. 27. Incorrectly labeled as 24. Denied as a conclusion of law to which no responsive pleading is required. WHEREFORE, Defendant, Jessica Juran demands that judgment be entered in her favor. NEW MATTER 1. The answers to paragraphs 1 through 27 of Plaintiff's Complaint are incorporated by reference as if fully set forth herein. 2. The injuries and damages allegedly sustained by the Plaintiff may have been caused by occurrences that happened before the date of this motor vehicle accident and so pre- existed the date of this motor vehicle accident. 3. The injuries and damages allegedly sustained by the Plaintiff may be caused by occurrences that happened after the date of the motor vehicle accident and so were caused by events which are subsequent to the date of the motor vehicle accident. 4. The claims of the Plaintiff, Donald Deaven, are barred and or limited by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law in that the Plaintiff, Donald Deaven, is deemed to have elected the Limited Tort option of coverage and he has not sustained serious injuries. WHEREFORE, Defendant, Jessica Juran, demands that judgment be entered in her favor. Respectfully submitted, Date: January 7, 2014 By: 4- \ / Joseph R. D'Annunzio, Attorney for Defendant . VERIFICATION I, Jessica Juran, hereby state that I am the Defendant in this action, and verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: I 7 ! . . . . _: ._AA /JESSICA i•RAN -- • CERTIFICATE OF SERVICE I, Kimberly Stielper, do hereby certify that on this V ' day of J�n�U---y , 2014, I caused a true and correct copy of Defendant, Jessica Juran's, Answer and New Matter Addressed to Plaintiff,Donald Deaven ,to be served upon the following person listed below via first class United States mail,postage prepaid: Christina Bradley, Esquire Freeburn &Hamilton 2040 Linglestown Road, Suite 300 Harrisburg, PA 17110 LAW OFFICE OF JOSEPH R. D'ANNUNZIO BY: A' r.a.7"nika► Kimberly CT elper, Legal S'cretary Christina L. Bradley, Esquire JAN P FREEBURN & HAMILTON 1 �suB . • 7 ID No. 89107 p efl�( Y�r� 2040 Linglestown Road O;y S �V CQ(f � . Suite 300 A VAN Harrisburg PA 17110 (717) 671-1955 Attorney for Plaintiffs christinab(upa-iniu rylawyer.com DONALD DEAVEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 13-7249 CIVIL ACTION - LAW JESSICA JURAN, Defendant PLAINTIFFS' REPLY TO NEW MATTER 1. This is an incorporation paragraph to which no response is required. 2. This paragraph contains no averments of fact, only conclusions of law to which no reply is required. To the extent that a court determines that this paragraph contains any averments of fact, the same are specifically denied. 3. This paragraph contains no averments of fact, only conclusions of law to which no reply is required. To the extent that a court determines that this paragraph contains any averments of fact, the same are specifically denied. 4. This paragraph contains no averments of fact, only conclusions of law to which no reply is required. To the extent that a court determines that this paragraph contains any averments of fact, the same are specifically denied. WHEREFORE, Plaintiff, Donald Deaven, demands judgment in his favor and against Defendant, Jessica Juran, in an amount in excess of FIFTY THOUSAND 8s 00/100 ($50,000.00) DOLLARS, exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. Respectfully Submitted, FREEBURN & HAMILTON By: C Christina L. Bradley, Esq ire I.D. No. 89107 2040 Linglestown Road Suite 300 Harrisburg PA 17110 (717) 671-1955 Date: of - °Z ql 2,o pq Counsel for Plaintiff 2 VERIFICATION I, Donald Deaven, hereby verify that the statements in the foregoing Reply to New Matter are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 1 /` ��7.¢it�r�-ri Donald Deaven Christina L. Bradley, Esquire FREEBURN & HAMILTON ID No. 89107 2040 Linglestown Road Suite 300 Harrisburg PA 17110 (717) 671-1955 Attorney for Plaintiffs christina a,pa-iniurylawyer.com DONALD DEAVEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 13-7249 CIVIL ACTION - LAW JESSICA JURAN, Defendant CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the forgoing Reply to New Matter was duly served on this 24th day of January, 2014, by placing the same in the U.S. First Class Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Joseph R D'Annunzio, Esquire Law Offices of Joseph R. D'Annunzio 4309 Linglestown Road, Ste. 211 Harrisburg, PA 17112 Counsel for Defendant BY: 1 Jessie K. Walsh, Legal Assistant to Christina L. Bradley, Esquire Attorney I.D. #89107 FREEBURN & HAMILTON 2040 Linglestown Road, Suite 300 Harrisburg, PA 17110 (717) 671-1955 Dated: I a`f �� Attorney for Plaintiff