HomeMy WebLinkAbout14-0853 Supreme Court of Pennsylvania
Court of Commo'nTleas For Prothonotary Use Only:
Civil Cover Sheet ,
Docket No:
CUMBERLAND 2 '
J
-.� County
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court.
Commencement of Action:
S 0 Complaint n Writ of Summons ❑ Petition
Transfer from Another Jurisdiction Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
T Dean U. Chapman Sheldon S. Davis & Real Stars Trucking, LLC
Dollar Amount Requested: Owithin arbitration limits
I Are money damages requested? Yes No (check one) [H ]outside arbitration limits
O
N Is this a Class Action Suit? F1 Yes ED No Is this an MDJAppeal? 0 Yes Ix No
A Name of Plaintiff /Appellant's Attorney: Michael J. Cooper, Esq. /Cellino & Barnes, P.C.
El Check here if you have no attorney (are a Self- Represented [Pro Set 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
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TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
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:] Premises Liability 0 Statutory Appeal: Other
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Q
C El Other: Employment Dispute: Other El Zoning Board
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O MASS TORT
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N p Tobacco
E] Toxic Tort -DES
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B El Eminent Domain /Condemnation 0 Declaratory Judgment
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Updated 1/1/2011
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DEAN U. CHAPMAN f ,
Plaintiffs = t
lab
vs.
Civil No.
REAL STARS TRUCKING, LLC c -;
SHELDON S. DAVIS
Defendants �.
COMPLAINT IN CIVIL ACTION
AND NOW comes the Plaintiff DEAN U. CHAPMAN, by her counsel, MICHAEL
J. COOPER, of counsel to Cellino & Barnes, P.C., 451 Grider Street, Buffalo, New York,
14215, and files this Complaint against defendants, REAL STARS TRUCKING, LLC
and SHELDON S. DAVIS, upon information and belief alleges as follows:
1. That Plaintiff DEAN U. CHAPMAN is an adult individual residing at 169 N.
Main Street, Warsaw, New York 14569.
2. At all times herein relevant defendant REAL STARS TRUCKING, LLC has been
a Limited Liability Company duly authorized to conduct business in the State of
Pennsylvania.
3. At all times herein relevant defendant REAL STARS TRUCKING, LLC has
conducted business in Pennsylvania and has maintained a place of business at 9611 N.
US. Highway 1, #257, Sebastian, Florida 32958. 1 o ? , � S �'
� � 3ai 133
4. That Defendant Sheldon S. Davis is an adult individual residing at 921
Shadowmoss Drive, Winter Garden, Florida 34787.
5. On or about February 7, 2013, Northeast Transport, Inc. was the owner of
a 2002 Freightliner bearing New York State License Plate Number 21800PB.
6. On or about February 7, 2013, plaintiff DEAN U. CHAPMAN operated the
aforementioned 2002 Freightliner with the full knowledge, consent and permission of the
owner, Northeast Transport, Inc.
7. On or about February 7, 2013, defendant REAL STARS TRUCKING, LLC
was the owner of a 2001 Kenworth bearing Florida State License Place No. Z4723V.
8. On or about February 7, 2013, defendant SHELDON S. DAVIS operated
the aforementioned vehicle with the full knowledge, consent and permission of the
owner, defendant REAL STARS TRUCKING, LLC.
9. On or about February 7, 2013, at approximately 5:03 a.m., plaintiff, DEAN
U. CHAPMAN operated the 2002 Freightliner in a northbound direction on Interstate 81
in South Middleton Township, County of Cumberland and State of Pennsylvania.
10. On or about February 7, 2013, at approximately 5:03 a.m., defendant
SHELDON S. DAVIS operated the 2001 Kenworth in a northbound direction on
Interstate 81 in South Middleton Township, County of Cumberland and State of
Pennsylvania.
11. On or about February 7, 2013, at approximately 5:03 a.m., the 2001
Kenworth being operated by defendant, SHELDON S. DAVIS struck the back of the
2002 Freightliner being operated by plaintiff, DEAN U. CHAPMAN on the northbound
2
Interstate 81 in South Middleton Township, County of Cumberland and State of
Pennsylvania, thereby injuring plaintiff.
12. That as result of the collision of the parties hereto plaintiff has suffered
serious bodily injury including, but not limited to:
a. L4 -5 bilateral pars fracture, L4 -5 and L5 -S1 disc herniations with
stenosis and lumbar radiculitis requiring surgery to repair in the nature
of a lumbar fusion on December 13, 2013;
b. Limited range of motion in the lumbar spine;
c. Low back pain;
d. Radiating pain into bilateral legs and feet;
e. Numbness and tingling in bilateral feet;
f. Loss of sensation in bilateral feet;
g. Neck pain;
h. Limited range of motion in cervical spine;
i. Mid back pain; '
j. Limited range of motion in mid back;
k. Incontinence; and
I. Sleeplessness due to pain.
13. That Plaintiff suffered bodily injuries, severe pain and suffering, work loss
and the loss of life's pleasures in the past, present and into the future.
14. That the injuries to Plaintiff directly resulted from the negligence of the
Defendant, REAL STARS TRUCKING LLC:
a. Failed to properly supervise the driver of the vehicle.
3
r '
b. Failed to perform a sufficient background investigation
of Sheldon S. Davis' driving skills before letting him
use the vehicle.
C. Failed to properly instruct Sheldon S. Davis as to
proper safe driving techniques.
e. Failed to maintain the vehicle in proper working
condition.
f. Failed to inquire of Sheldon S. Davis if he knew the
applicable rules and regulations of the road at the
time and place of the occurrence.
15. That the injuries to Plaintiff directly resulted from the negligence of the
Defendant, SHELDON S. DAVIS:
a. Failed to yield the right of way.
b. Failed to maintain a proper lookout for other vehicles
on the highway.
C. Failed to divert his vehicle into an alternate path of
travel in order to avoid the accident.
d. Failed and omitted to be reasonably alert.
e. Failed and omitted to use proper and adequate care
when approaching an intersection.
f. Failed and omitted to warn of his approach.
g. Used the brakes of her vehicle in such a careless and
negligent manner as to fail to slow down and /or stop
his vehicle.
h. Failed and omitted to make proper use of his vehicle's
brakes, lights, steering, horn and other safety devices.
4
a
i. In operating said vehicle at an unreasonable rate of
speed under the circumstances and condition then
and there prevailing.
WHEREFORE, Plaintiff claims damages against the Defendants REAL STARS
TRUCKING, LLC and SHELDON S. DAVIS for an unliquidated sum of damages in
excess of the jurisdictional amount requiring arbitration in Cumberland County, plus
interest, costs of suit and delay damages as may be recoverable under the
Pennsylvania Rules of Civil Procedure.
MICHAEL OPER .
CELLINO & rreet RNES C.
451 Grider
Buffalo, New York 14215
(716) 888 -8888
Pennsylvania I.D. No. 86799
Dated: February 3, 2014
5
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
i f 3 -
Ronny R Anderson E �;
Sheriff
.�t5 a4 xtuither
Jody S Smith (i ' �i \ 0
Chief Deputy
Richard W Stewart
Solicitor PENNSYLVANIA
-Ox,.
Dean U Chapman
Case Number
vs.
Real Stars Trucking, LLC (et al.) 2014-853
SHERIFF'S RETURN OF SERVICE
02/18/2014 Ronny R Anderson, Sheriff, who being duly sworn according to law, states that he served the within
Complaint& Notice upon the within named defendant, Real Stars Trucking, LLC, in the following manner:
On February 18, 2014 the Sheriff mailed by certified mail, return receipt requested a true and correct copy
of the within Complaint& Notice to the defendant's last known address of 9611 N. US Highway 1, #257,
Sebastian, FL 32958. The certified mail return receipt card was received by the Cumberland County
Sheriffs Office signed by Brandi McCain adult in charge for Real Stars Trucking, LLC on February 21,
2014.
02/18/2014 Ronny R Anderson, Sheriff, who being duly sworn according to law, states that he served the within
Complaint&Notice upon the within named defendant, Sheldon S Davis, in the following manner: On
February 18, 2014 the Sheriff mailed by certified mail, return receipt requested a true and correct copy of
the within Complaint& Notice to the defendant's last known address of 921 Shadowmoss Drive, Winter
Garden, FL 34787. The certified mail return receipt card was received by the Cumberland County Sheriff'
s Office signed by Sheryl Davis adult in charge for Sheldon S Davis on February 28, 2014.
SHERIFF COST: $57.87 SO ANSWERS,
,
f�
March 07, 2014 RON0 R ANDERSON, SHERIFF
h ate , ,.
SENDER. CO^lf t.L 't tH'. stC:HON
• Complete items 1,2,and 3.Also complete A• -1111111111.11111
item 4 if Restricted Delivery is desired. 0 Agent
❑Addressee
• Print your name and address on the reverse C.Date of Delivery
so that we can return the card to you. B. I eoeived y(Prin Name)
• Attach this card to the back of the mailpiece, / VI . -2e^%t.
or on the fce permits. �hc�
D. Is del ery address different from item 1? ❑Yes
'
1. Article Add =< If YES,enter delivery address below: ❑No
' to:
Sheldon S Davis 2 0/` -
921 S iadowmoss Drive o 1 —
Winter Garden, FL 34787 3 Service Type
❑Certified Mail® ❑Priority Mail Express"
❑Registered ❑Return Receipt for Merchandise
❑Insured Mail ❑Collect on Delivery
4. Restricted Delivery?(Extra Fee) ❑Yes
2. Article Number /y��r 7007 0710 0003 2210 3979
I s i is 1 Ti 1 t ! t _ 1
PS Form 3811,July 2013 Domestic Return Receipt
•
SENDEI S ,.,,,,, t't r r ,,, 7,f,.,, 1 ). , i , r..,,r.Di-LiVERY
• Complete items 1,2,and 3.Also complete 4"` A - I� ie`1
item 4 if Restricted Delivery is desired. - �_ ent
• Print your name and address on the reverse ` .� ❑Addressee
so that we can return the card to you. B. -eceived by(Printed Name) C. Date of Delivery
• Attach this card to the back of the mailpiece, �"� n �.D/�' (1-�
or on the front if space permits.
D. Is delivery address different from item 1? ❑Yes
1. Article Addressed to: If YES,enter delivery address below: O
Real Stars Trucking, LLC
9611 N. US Highway 1 01 f ' [ FM
#257 • `ir
Sebastian, FL 32958 3. Service'Type
❑Certified Mall® ❑Priority Mail Express'
❑Registered ❑Return Receipt for Merchandise
❑Insured Mall ❑Collect on Delivery
4. Restricted Delivery?(Extra Fee) ❑Yes
2, Article{'Jupger i i 7 0 710 0003 2 210 3986
malt ogro
Ili 1
! i I li i
PS Form 8811',tza0 I 07)
0 3' ' . { Domeistic Return Receipt
SALMON, RICCHEZZA, SINGER & TURCHI LLP
By: Zachary J. Ballard, Esquire
Attorney I.D. No.: 206177
1600 Market Street, Ste. 2500
Philadelphia, PA 19103
(215) 606-6600
Attorney for Defendants,
Real Stars Trucking, LLC and
Sheldon S. Davis
DEAN U CHAPMAN,
PLAINTIFF,
v.
REAL STARS TRUCKING, LLC and
SHELDON S. DAVIS,
DEFENDANTS.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Civil No.: 14-853
JURY OF 12 DEMAND g
x
r-
> v
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
rzi -
r
Please enter the appearance of Zachary J. Ballard, Esquire, on behalf of Defendants, Real
Stars Trucking, LLC and Sheldon S. Davis.
Respectfully submitted,
SALMON, RICCHEZZA, SINGER & TURCHI, LLP
By:
Dated: May 2, 2014
Z J. Ballard, Esquire
A . - for Defendants,
Real Stars Trucking, LLC and Sheldon S. Davis
{J0145891.DOC}1
SALMON, RICCHEZZA, SINGER & TURCHI LLP
By: Zachary J. Ballard, Esquire
Attorney I.D. No.: 206177
1600 Market Street, Ste. 2500
Philadelphia, PA 19103
(215) 606-6600
Attorney for Defendants,
Real Stars Trucking, LLC and
Sheldon S. Davis
DEAN U CHAPMAN,
PLAINTIFF,
v.
REAL STARS TRUCKING, LLC and
SHELDON S. DAVIS,
DEFENDANTS.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Civil No.: 14-853
JURY OF 12 DEMANDED
DEMAND FOR JURY TRIAL
TO THE PROTHONOTARY:
Defendants, Real Stars Trucking, LLC and Sheldon S. Davis, hereby demand a jury trial
in the above matter.
Respectfully submitted,
SALMON, RICCHEZZA, SINGER & TURCHI, LLP
By:
Dated: May 2, 2014
J. allard, Esquire
y for Defendants,
Real Stars Trucking, LLC and Sheldon S. Davis
{J0145891.DOC}2
CERTIFICATE OF SERVICE
I, Zachary J. Ballard, Esquire, hereby certify that the foregoing Entry of Appearance and
Demand for Jury Trial of Defendants was served this date upon all counsel and parties listed
below, by electronic filing and United States regular mail, postage prepaid.
Michael K. Cooper, Esquire
Cellino & Barnes, P.C.
451 Grider Street
Buffalo, NY 14215
Attorney for Plaintiff,
Dean U. Chapman
SALMON, RICCHEZZA, SINGER & TURCHI, LLP
By:
Dated: May 2, 2014
. Ballard, Esquire
ey for Defendants,
Real Stars Trucking, LLC and Sheldon S. Davis
{J0145891.DOC}3
2014 JUN 30 P1i 2: f*4
CUMBERLAND COUNTY
PENNSYLVANIA
To Plaintiff:
You are hereby notified to plead to the enclosed New
Matter and New Matter Cross-claim within twenty (20)
days from the service hereof or a default judgment may
be entered against you.
Real Stars
SALMON, RICCHEZZA, SINGER & TURCHI LLP
By: Zachary J. Ballard, Esquire
Attorney I.D. No.: 206177
1600 Market Street, Ste. 2500
Philadelphia, PA 19103
(215) 606-6600
ruc _ LC and Sheldon S. Davis
Attorney for Defendants,
Real Stars Trucking, LLC and
Sheldon S. Davis
DEAN U CHAPMAN,
PLAINTIFF,
v.
REAL STARS TRUCKING, LLC and
SHELDON S. DAVIS,
DEFENDANTS.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Civil No.: 14-853
JURY OF 12 DEMANDED
ANSWER WITH NEW MATTER OF DEFENDANTS, REAL STARS TRUCKING,
LLC AND SHELDON S. DAVIS TO PLAINTIFF'S COMPLAINT
Defendants, Real Stars Trucking, LLC and Sheldon S. Davis (hereafter "Answering
Defendants"), by and through its attorneys, Salmon, Ricchezza, Singer & Turchi, LLP, as
and for its Answer to Plaintiff's Complaint (the "Complaint") with New Matter, states as
follows:
1.
Denied. After reasonable investigation Answering Defendants are without
sufficient knowledge or information to form a belief as to the truth of the averments set forth
in this paragraph; as such, same are denied and strict proof thereof is demanded at time of
trial.
2. Admitted.
{J0146649.DOC} 1
3. Admitted in part; denied in part. It is only admitted that Answering Defendant,
Real Stars Trucking maintains a place of business at 9611 N. U.S. Highway 1, #257,
Sebastian, Florida 32958. The remainder of the allegations contained in this paragraph are
conclusions of law to which no responsive pleading is necessary. To the extent these
remaining allegations of this paragraph are deemed factual, same are denied in accordance
with Pa.R.C.P. 1029(e) and strict proof thereof is demanded at time of trial.
4. Admitted.
5. Denied. After reasonable investigation Answering Defendants are without
sufficient knowledge or information to form a belief as to the truth of the averments set forth
in this paragraph; as such, same are denied and strict proof thereof is demanded at time of
trial.
6. Denied. After reasonable investigation Answering Defendants are without
sufficient knowledge or information to form a belief as to the truth of the averments set forth
in this paragraph; as such, same are denied and strict proof thereof is demanded at time of
trial.
7. Denied. After reasonable investigation Answering Defendants are without
sufficient knowledge or information to form a belief as to the truth of the averments set forth
in this paragraph; as such, same are denied and strict proof thereof is demanded at time of
trial.
8. Admitted.
9. Denied. After reasonable investigation Answering Defendants are without
sufficient knowledge or information to form a belief as to the truth of the averments set forth
{J0146649.DOC} 2
in this paragraph; as such, same are denied and strict proof thereof is demanded at time of
trial.
10. Admitted.
11. Denied. The allegations of this paragraph contain conclusions of law to which
no responsive pleading is required. To the extent the allegations of this paragraph are factual
same are denied in accordance with Pa.R.C.P. 1029(e) and strict proof thereof is demanded at
time of trial.
12. Denied. The allegations of this paragraph and its subparts contain conclusions
of law to which no responsive pleading is required. To the extent the allegations of this
paragraph and/or its subparts are factual same are denied in accordance with Pa.R.C.P.
1029(e) and strict proof thereof is demanded at time of trial.
13. Denied. The allegations of this paragraph contain conclusions of law to which
no responsive pleading is required. To the extent the allegations of this paragraph are factual
same are denied in accordance with Pa.R.C.P. 1029(e) and strict proof thereof is demanded at
time of trial.
14. Denied. The allegations of this paragraph and its subparts contain conclusions
of law to which no responsive pleading is required. To the extent the allegations of this
paragraph and/or its subparts are factual same are denied in accordance with Pa.R.C.P.
1029(e) and strict proof thereof is demanded at time of trial.
15. Denied. The allegations of this paragraph and its subparts contain conclusions
of law to which no responsive pleading is required. To the extent the allegations of this
paragraph and/or its subparts are factual same are denied in accordance with Pa.R.C.P.
1029(e) and strict proof thereof is demanded at time of trial.
{J0146649.DOC} 3
WHEREFORE, Answering Defendants demand judgment in its favor and against all
parties with costs, interest and any other fees the Court deems appropriate.
NEW MATTER — AFFIRMATIVE DEFENSES
16. Plaintiffs claims are barred because any alleged damages were proximately
caused by negligent acts or omissions of third parties over whom Answering Defendants
exercised no control and for whose conduct Answering Defendants bear no responsibility.
Said acts or omissions intervened between the alleged acts and omissions of Answering
Defendants, if any, and the accident alleged by Plaintiff and was the sole, direct, and
proximate cause of Plaintiff s damages, if any.
17. Plaintiff's alleged damages, if any, were caused and brought about by
intervening and superseding causes not caused by Answering Defendants.
18. Answering Defendants' conduct was not a substantial factor in contributing to
Plaintiff's alleged damages.
19. Plaintiff's recovery of damages, if any, must be reduced as a result of
Plaintiffs failure to mitigate his damages.
20. The accident, which is the subject of this lawsuit, was not the result of any
negligence or carelessness on the part of Answering Defendants.
21. Plaintiff's claims are barred by the doctrines of Collateral Estoppel and Res
Judicata.
22. Plaintiffs claims are barred by the doctrines of Estoppel and Waiver.
23. Plaintiffs claims are barred by such other facts, circumstances and/or
principles of law as may be shown through investigation, discovery or trial of this matter.
{J0146649.DOC} 4
24. Answering Defendants preserve all affirmative defenses that may apply
against Plaintiff under the Pennsylvania Comparative Negligence Act. Further, Plaintiff's
damages, if any, were caused or contributed to by Plaintiff's own negligence or fault, and
Plaintiff's recovery, if any, should therefore be barred or diminished in accordance with
applicable law.
25. Answering Defendants incorporate herein by reference and plead as
affirmative defenses all of those defenses specified in Pennsylvania Rule of Civil Procedure
1030.
WHEREFORE, Answering Defendants demand judgment in its favor and against all
parties with costs, interest and any other fees the Court deems appropriate.
Respectfully submitted,
SALMON, RICCHEZZA, SINGER & TURCHI, LLP
y .: allard, Esquire
Attorney for Defendants,
Real Stars Trucking, LLC and Sheldon S. Davis
By:
Dated: June 27, 2014
{J0146649.DOC} 5
.7 14 07:49a Realstars Trucking
JUN. 27 2014 9:38AM SALMON RICCHEZZA
8602420457 p.1
NO. 937 P. 2
VERIFICATION
1, Sheldon. S_ Davis, hereby state that I am the owner of Real Stars Trucking, LLC and
that 1 am authorized to make this Verification on its behalf; that 1 am familiar with the facts set
forth in the foregoing Answer with New Matter to Plaintiffs Complaint that the same are true
and correct to the best of my knowledge, information and belief; and that this statement is made
subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities_
Sheldon S. Davis
Dated: June 2014
(.10150992.DOC)
CERTIFICATE OF SERVICE
I, Zachary J. Ballard, Esquire, hereby certify that the foregoing Answer with New
Matter of Defendants, Real Stars Trucking, LLC and Sheldon S. Davis to Plaintiff's
Complaint was served this date upon all counsel and parties listed below by United States
regular mail, postage prepaid.
Michael K. Cooper, Esquire
Cellino & Barnes, P.C.
451 Grider Street
Buffalo, NY 14215
Attorney for Plaintiff,
Dean U. Chapman
SALMON, RICCHEZZA, SINGER & TURCHI, LLP
Bv:
Dated: June 27, 2014
Zachar : allard, Esquire
Attorney for Defendants,
Real Stars Trucking, LLC and Sheldon S. Davis
{J0146649.DOC} - 7 -
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA CIVIL ACTION — LAW
DEAN U. CHAPMAN
Plaintiff
VS.
Civil No. 14-853
REAL STARS TRUCKING, LLC
SHELDON S. DAVIS
Defendants
PRAECIPE
TO THE PROTHONOTARY, CUMBERLAND COUNTY, PENNSYLVANIA:
Please mark the above captioned case "discontinued, settled and ended."
Dated: October 21, 2014
Michael J.
Esq.
Michael J. Coer, Esq.
Cellino & Barnes, P.C.
451 Grider Street
Buffalo, New York 14202
I.D. No.: 86799
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA CIVIL ACTION — LAW
DEAN U. CHAPMAN
Plaintiff
vs.
Civil No. 14-853
REAL STARS TRUCKING, LLC
SHELDON S. DAVIS
Defendants
PRAECIPE
Filed on behalf of Plaintiff
Counsel of Record for this Party:
Michael J. Cooper, Esq.
Cellino & Barnes, P.C.
451 Grider Street
Buffalo, New York 14215
I.D. No.: 86799
Representative for Adverse Parties:
Zachary Ballard, Esq.
Salmon, Ricchezza, Singer
& Turchi
1601 Market Street, Suite 2500
Philadelphia, PA 19103
Dated: October 21, 2014
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the within Praecipe was sent via
United States Postal Service, first class mail, postage prepaid, on the 21st day of
October 2014 to:
Zachary Ballard, Esq.
Salmon, Ricchezza, Singer
& Turchi
1601 Market Street, Suite 2500
Philadelphia, PA 19103