HomeMy WebLinkAbout14-1453 Supreme Cou � o- UPennsylvania
COUCH Of -Co_m M Pleas For Prothonotary Use Only:
Civil } Cov r Sheet j �l
Docket No:
Curnbe and County - - y -/V s S
The information collected on this farm is used solely 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 X Complaint J Writ of Summons J Petition
E Transfer from Another Jurisdiction J Declaration of Taking
C Lead Plaintiffs Name: Lead Defendant's Name:
T Mark D. Meyerhoff DVM Thomas W. Munkittrick, DVM
I Are money damages requested? iE Yes IJ No Dollar Amount Requested: Dwithin arbitration limits
(check one) fx outside arbitration limits
N Is this a Class Action Suit? J Yes El No Is this an MDJAppeal? J Yes [R No
A Name of Plaintiff /Appellant's Attorney: Peter M. Good, Esquire & Jessica E. Mercy, Esquire
0 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 Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
!J Intentional El Buyer Plaintiff Administrative Agencies
El Malicious Prosecution J Debt Collection: Credit Card f-=1 Board of Assessment
0 Motor Vehicle ❑ Debt Collection: Other 1-I Board of Elections
Nuisance J Dept. of Transportation
Premises Liability Statutory Appeal: Other
S E] Product Liability (does not include
E mass tort) IJ Employment Dispute:
Slander/Libel/ Defamation Discrimination
C El Other: F-1 Employment Dispute: Other J Zoning Board
T Conversion, Misappropriatica 0 Other:
of Trade Secrets & Civil Coca
I 0 Other:
O MASS TORT
1 Asbestos
N 0 Tobacco
IJ Toxic Tort - DES
J Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
1 -i Toxic Waste
Other: J Ejectment 0 Common Law /Statutory Arbitration
B 0 Eminent Domain /Condemnation I. J Declaratory Judgment
Ground Rent 0 Mandamus
Landlord /Tenant Dispute L Non- Domestic Relations
Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY J Mortgage Foreclosure: Commercial 0 Quo Warranto
❑� Dental 0 Partition 0 Replevin
0 Legal J Quiet Title - 1 Other:
Medical J Other:
i Other Professidnal:
Updated 1/1/2011
MARK D. MEYERHOFF, DVM, IN THE COURT OF COMMONS PLEAS
and ANIMAL EMERGENCY CUMBERLAND COUNTY, PENNSYLVANIA
MEDICAL CENTER, LLC,
Plaintiffs,
l 2
V. NO.
THOMAS W. MUNKITTRICK, DVM,, '
RENEE D. RICHARDS, VMD, SHAKA
MONROE, DVM and MONROE CIVIL ACTION — LAW
VETERINARY EMERGENCY
GROUP OF MECHANICSBURG, INC. u)`— �f -
{
D /B /A THE ANIMAL EMERGENCY
CENTER OF MECHANICSBURG, JURY TRIAL DEMANDED v c - � c
Defendants.''`'
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, 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 LAWYER REFERRAL SERVICE
32 S. BEDFORD STREET
CARLISLE, PA 17013
(800) 990 -9108
OA"
�� yss
MARK D. MEYERHOFF, DVM, IN THE COURT OF COMMONS PLEAS
and ANIMAL EMERGENCY CUMBERLAND COUNTY, PENNSYLVANIA
MEDICAL CENTER, LLC,
Plaintiffs,
V. NO.
THOMAS W. MUNKITTRICK, DVM,
RENEE D. RICHARDS, VMD, SHAKA
MONROE, DVM and MONROE CIVIL ACTION — LAW
VETERINARY EMERGENCY
GROUP OF MECHANICSBURG, INC.
D /B /A THE ANIMAL EMERGENCY
CENTER OF MECHANICSBURG, JURY TRIAL DEMANDED
Defendants.
AVISO
USTED HA SIDO DEMANDADO /A EN CORTE. Si usted desea defenderse de las
demandas que se presentan mis adelante en las siguientes piginas, debe tomar accion dentro de los
proximos veinte (20) dias despues de la nodficacion de esta Demanda y Aviso radicando
personalmente o pot medio de un abogado una comparecencia escrita y radicando en la Corte pot
escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte
de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin
usted y un fallo pot cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion
o remedio solicitado pot el demandante puede set dictado en contra suya pot la Corte sin mis aviso
adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI
USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA
OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR 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 LAWYER REFERRAL SERVICE
32 S. BEDFORD STREET
CARLISLE, PA 17013
(800) 990 -9108
Caldwell & Kearns, P.C. Peter M. Good, Esq.
3631 North Front Street I.D. No. 64316
Harrisburg, PA 17110 Jessica E. Mercy, Esq.
(717) 232 -7661 (phone) I.D. No. 206405
(717) 232 -2766 (fax)
pgood @cklegal.net
jmercy @cklegal.net
Attorneys for Plaintiffs
MARK D. MEYERHOFF, DVM, IN THE COURT OF COMMONS PLEAS
and ANIMAL EMERGENCY CUMBERLAND COUNTY, PENNSYLVANIA
MEDICAL CENTER, LLC,
Plaintiffs,
V. NO.
THOMAS W. MUNKITTRICK, DVM,
RENEE D. RICHARDS, VMD, SHAKA
MONROE, DVM and MONROE CIVIL ACTION — LAW
VETERINARY EMERGENCY
GROUP OF MECHANICSBURG, INC.
D /B /A THE ANIMAL EMERGENCY
CENTER OF MECHANICSBURG, JURY TRIAL DEMANDED
Defendants.
COMPLAINT
AND NOW COMES, Plaintiffs Mark D. Meyerhoff, DVM and Animal Emergency Medical
Center, LLC, by and through their attorneys, Caldwell & Kearns, P.C., to file the within Complaint
against Defendants Thomas W. Munkittrick, DVM, Renee D. Richards, VMD, Shaka Monroe,
DVM and Monroe Veterinary Emergency Group of Mechanicsburg, Inc. d /b /a The Animal
Emergency Center of Mechanicsburg, by averring as follows:
Parties
1. Plaintiff Mark D. Meyerhoff, DVM (hereinafter "Dr. Meyerhoff") is an adult
individual with a principal place of business located at 4930 Ritter Road, Suite 101, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
2. Plaintiff Animal Emergency Medical Center, LLC (hereinafter "Animal Emergency
Medical Center ") is a Pennsylvania limited liability company with a principal place of business
located at 4930 Ritter Road, Suite 101, Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. Dr. Meyerhoff and Animal Emergency Medical Center are hereinafter collectively
referred to as "Plaintiffs."
4. Defendant Thomas W. Munkittrick, DVM (hereinafter "Dr. Munkittrick ") is an adult
individual with a principal place of business located at 11 Willow Mill Park Road, Mechanicsburg,
Cumberland County, Pennsylvania 17050.
5. Defendant Renee D. Richards (hereinafter "Dr. Richards ") is an adult individual with
a principal place of business located at 11 Willow Mill Park Road, Mechanicsburg, Cumberland
County, Pennsylvania 17050.
6. Defendant Shaka Monroe, DVM (hereinafter "Dr. Monroe ") is an adult individual
with a principal place of business located at 11 Willow Mill Park Road, Mechanicsburg, Cumberland
County, Pennsylvania 17050.
7. Defendant Monroe Veterinary Emergency Group of Mechanicsburg, Inc. d /b /a The
Animal Emergency Center of Mechanicsburg (hereinafter "AECM ") is a Pennsylvania corporation
with a principal place of business located at 11 Willow Mill Park Road, Mechanicsburg, Cumberland
County, Pennsylvania 17050.
8. Dr. Munkittrick, Dr. Richards, Dr. Monroe and AECM are hereinafter collectively
referred to as "Defendants."
Jurisdiction and Venue
9. This Court has jurisdiction over the parties and the subject matter of the instant
dispute.
10. Venue is appropriate in Cumberland County, Pennsylvania under Pennsylvania Rule
of Civil Procedure 1006, as the cause of action arose in Cumberland County.
2
Facts
11. Plaintiffs own and operate an animal emergency medical center in Mechanicsburg,
Pennsylvania and are in the business of providing emergency medical care to small animals.
12. Plaintiffs work closely with primary care veterinarians to provide outpatient care for
minor ailments and inpatient care for small animals that require critical care and /or surgical services.
13. The success of Plaintiffs' operations is, in large part, based on the continued
confidentiality of its trade secrets and other confidential information, including but not limited to, its
valuable and proprietary customer lists.
14. Plaintiffs have invested substantial amounts of money and resources to create,
develop, and compile confidential and proprietary information relating to, among other things,
customer information, employee information and other confidential information (hereinafter
collectively referred to as "Plaintiffs' Protected Information ").
15. Pursuant to an Agreement of Lease (hereinafter the "Lease ") dated October 27, 2009
between Plaintiffs and Dr. Munkittrick and Dr. Richards, Plaintiffs leased a portion of the real
property located 11 Willow Mill Park Road, Mechanicsburg, Cumberland County, Pennsylvania
(hereinafter the "Leased Premises ") from Dr. Munkittrick and Dr. Richards for the operation of
their animal emergency medical center.
16. Plaintiffs' Protected Information was stored in electronic and paper format at the
Leased Premises until October 31, 2012, when the Lease expired at the end of its stated term and
Plaintiffs vacated the Leased Premises.
17. In or about July 2012, Dr. Munkittrick and Dr. Richards, without Plaintiffs'
knowledge or consent, entered the Leased Premises and unlawfully obtained copies of Plaintiffs'
Protected Information.
18. Dr. Munkittrick and Dr. Richards provided Plaintiffs' Protected Information to Dr.
3
Monroe and AECM, the new tenants for the Leased Premises beginning on November 1, 2012, for
the purpose of directly competing with Plaintiffs.
19. It is believed and therefore averred that Dr. Munkittrick and Dr. Richards will
directly benefit from the success of Dr. Monroe and AECM at the Leased Premises because the
monthly rent for the Leased Premises is based on Dr. Monroe and AECM's gross receipts at the
Leased Premises.
20. Upon information and belief, Dr. Monroe and AECM have utilized Plaintiffs'
Protected Information to solicit customers of Plaintiffs to end their ongoing business relationships
with Plaintiffs and, rather, to engage in business relationships with Dr. Monroe and AECM.
21. In particular, Dr. Monroe and AECM utilized Plaintiffs' Protected Information to
send communications to most, if not all, of Plaintiffs' customers in an effort to induce them to
terminate their relationships as customers of Plaintiffs.
22. Upon information and belief, Dr. Monroe and AECM have utilized Plaintiffs'
Protected Information to attempt to solicit and induce Plaintiffs' employees to terminate their
employment with Plaintiffs.
23. In particular, Dr. Monroe and AECM utilized Plaintiffs' Protected Information to
attempt to contact Plaintiffs' office manager for the purpose of soliciting Plaintiffs' office manager
to leave Plaintiffs' employment to become employed by Dr. Monroe and AECM.
24. Dr. Munkittrick and Dr. Richards obtained access to Plaintiffs' Protected
Information solely through their relationship with Plaintiffs as landlord under the Lease.
25. In addition, Dr. Monroe and AECM caused and permitted its credit card company
to utilize Dr. Meyerhoff's home address in its records, which resulted in Dr. Meyerhoffs home
address being printed on credit card receipts received by customers of Dr. Monroe and AECM and
4
mail from the credit card company to Dr. Monroe and AECM to be sent to Dr. Meyerhoff's home
address.
26. Dr. Monroe and AECM have also caused and permitted and continue to cause and
permit their mail to be sent to Dr. Meyerhoff's home address.
COUNTI
Conversion
Mark D. Meyerhoff, DVM and Animal Emergency Medical Center, LLC P. Thomas W/.
Munkittrick, DVM, Renee D. Richards, VMD, Shaka Monroe, DVM and Monroe Veterinary
Emergency Group of Mechanicsburg, Inc. dl bl a The Animal Emergency Center of Mechanicsburg
27. Plaintiffs hereby incorporate by reference paragraphs 1 through 26 of the within
Complaint as if fully set forth herein.
28. In or about July 2012, Dr. Munkittrick and Dr. Richards, without Plaintiffs'
knowledge or consent, used their position as landlord to enter the Leased Premises in order to
intentionally and fraudulently obtain copies of Plaintiffs' Protected Information.
29. Dr. Munkittrick and Dr. Richards provided Plaintiffs' Protected Information to Dr.
Monroe and AECM so that Dr. Monroe and AECM could directly compete with Plaintiffs' bus iness
by soliciting customers of Plaintiffs to end their ongoing business relationships with Plaintiffs and,
rather, to engage in business relationships with Dr. Monroe and AECM and by attempting to solicit
and induce Plaintiffs' employees to terminate their employment with Plaintiffs.
30. Dr. Monroe and AECM will directly benefit from their use of Plaintiffs' Protected
Information.
31. Dr. Munkittrick and Dr. Richards will also directly benefit from Dr. Monroe and
AECM's use of Plaintiffs' Protected Information because it is believed and therefore averred that
the monthly rent for the Leased Premises is based on Dr. Monroe and AECM's gross receipts at the
Leased Premises.
32. Defendants have converted Plaintiffs' Protected Information for their own personal
5
use without Plaintiffs consent and without lawful justification.
33. By converting Plaintiffs' Protected Information for their own personal use,
Defendants have denied and interfered with Plaintiffs' lawful right to exclusively possess and control
Plaintiffs' Protected Information.
34. As a direct and proximate cause of Defendants' conversion of Plaintiffs' Protected
Information, Plaintiffs have suffered damages in the form of loss of competitive advantage over
Plaintiffs' competitors, loss of reputation and goodwill, loss of certain customers, lost profits and
permanent loss of business altogether.
WHEREFORE, Plaintiffs Mark D. Meyerhoff, DVM and Animal Emergency Medical
Center, LLC respectfully request that this Honorable Court enter judgment in their favor and against
Defendants Thomas W. Munkittrick, DVM, Renee D. Richards, VMD, Shaka Monroe, DVM and
Monroe Veterinary Emergency Group of Mechanicsburg, Inc. d /b /a The Animal Emergency
Center of Mechanicsburg in an amount in excess of $50,000.00 together with costs of this suit and
any other relief that this Honorable Court deems reasonable and just.
COUNT II
Misappropriation of Trade Secrets in Violation of the
Pennsylvania Uniform Trade Secrets Act
Mark D. Meyerhoff, DVM and Animal Emergency Medical Center, LLC v. Thomas W.
Munkittrick, DVM, Renee D. Richards, VMD, Shaka Monroe, DVM and Monroe Veterinary
Emergency Group of Mecbanicsburg, Inc. d/ bl a The Animal Emergency Center of Mechanicsbur
35. Plaintiffs hereby incorporate by reference paragraphs 1 through 34 of the within
Complaint as if fully set forth herein.
36. Plaintiffs' Protected Information constitutes trade secrets as defined under
Pennsylvania law.
37. Plaintiffs' Protected Information derives independent economic value from not
being generally known or readily ascertainable by proper means by persons who could obtain value
6
from their disclosure or use.
38. Plaintiffs have used reasonable means at all times to protect the secret, confidential
and proprietary nature of Plaintiffs' Protected Information.
39. Plaintiffs' Protected Information is highly valuable to Plaintiffs and constitutes a
significant source of Plaintiffs' income and significant competitive advantage over its competition.
40. Plaintiffs have devoted substantial sums of money researching, developing and
creating Plaintiffs' Protected Information; others could not duplicate Plaintiffs' Protected
Information without undertaking the same lengthy and expensive process as Plaintiffs.
41. Despite Plaintiffs' reasonable efforts to maintain its secrecy, Defendants accessed
and misappropriated Plaintiffs' Protected Information.
42. Defendants' unlawful misappropriation of Plaintiffs' Protected Information has
enabled and will continue to enable Dr. Monroe and AECM to unfairly compete with Plaintiffs by,
among other things, utilizing Plaintiffs' Protected Information to target Plaintiffs' customers to
divert business and income from Plaintiffs, which will enable Dr. Monroe and AECM to earn more
revenue and Dr. Munkittrick and Dr. Richards to make more money in monthly rental payments for
the Leased Premises.
43. In addition, the use of Plaintiffs' Protected Information by Defendants has caused,
and /or threatens to cause, irreparable harm, including, but not limited to, loss of competitive
advantage over Plaintiffs' competitors, loss of reputation and goodwill, loss of certain customers,
lost profits and permanent loss of business altogether.
WHEREFORE, Plaintiffs Mark D. Meyerhoff, DVM and Animal Emergency Medical
Center, LLC respectfully request that this Honorable Court enter judgment in their favor and against
Defendants Thomas W. Munkittrick, DVM, Renee D. Richards, VMD, Shaka Monroe, DVM and
Monroe Veterinary Emergency Group of Mechanicsburg, Inc. d /b /a The Animal Emergency
7
Center of Mechanicsburg and to enter an order as follows: (a) compelling Defendants to return to
Plaintiffs all of Plaintiffs' Protected Information in their possession, including, but not limited to,
information relating to Plaintiffs' customer and employee lists and any other of Plaintiffs' Protected
Information that Defendants copied, retained and /or took from the Leased Premises; (b)
compelling Defendants to forfeit any and all profits or other monetary benefits derived from the use
of Plaintiffs' Protected Information; (c) compelling Defendants to pay Plaintiffs compensatory
damages, as well as exemplary damages pursuant to 12 Pa. C.S.A. § 5304, in an amount to be proven
at trial, for the harm that Plaintiffs have suffered as a result of Defendants' willful and malicious
misappropriation of Plaintiffs' Protected Information; (d) enjoining Defendants from using and /or
disclosing Plaintiffs' Protected Information; (e) compelling Defendants to pay Plaintiffs' reasonable
attorneys' fees, expenses and costs of this action pursuant to 12 Pa. C.S.A. § 5305; and (f) any such
other relief as this Honorable Court deems reasonable or just.
COUNT III
Civil ConspiracX
Mark D. Meyerhoff, D and Animal Emergency Medical Center, LLC P. Thoma W/
Munkittrick, DVM, Renee D. Richards, VMD, Shaka Monroe, DVM and Monroe Veterinary
Emergency Group of Mechanicrbur� Inc. d/ bl a The Animal Emergency Center of Mechanicsburg
44. Plaintiffs hereby incorporate by reference paragraphs 1 through 43 of the within
Complaint as if fully set forth herein.
45. Upon information and belief, Defendants conspired with each other and acted with
the common purpose to unlawfully convert and misappropriate Plaintiffs' Protected Information so
that Dr. Monroe and AECM could directly compete with Plaintiffs' business by soliciting customers
of Plaintiffs to end their ongoing business relationships with Plaintiffs and, rather, to engage in
business relationships with Dr. Monroe and AECM and by attempting to solicit and induce
Plaintiffs' employees to terminate their employment with Plaintiffs.
46. Defendants unlawfully converted and misappropriated Plaintiffs' Protected
8
Information in pursuance of their common purpose.
47. Defendants' actions in converting and misappropriating Plaintiffs' Protected
Information were malicious and willful.
48. By conspiring with each other, for the express purpose of unlawfully converting and
misappropriating Plaintiffs' Protected Information, Defendants are liable to Plaintiffs for civil
conspiracy.
49. As a direct and proximate cause of Defendants' actions in furtherance of the
conspiracy, Plaintiffs have suffered actual legal damages in the form of loss of competitive advantage
over Plaintiffs' competitors, loss of reputation and goodwill, loss of certain customers, lost profits
and permanent loss of business altogether.
WHEREFORE, Plaintiffs Mark D. Meyerhoff, DVM and Animal Emergency Medical
Center, LLC respectfully request that this Honorable Court enter judgment in their favor and against
Defendants Thomas W. Munkittrick, DVM, Renee D. Richards, VMD, Shaka Monroe, DVM and
Monroe Veterinary Emergency Group of Mechanicsburg, Inc. d /b /a The Animal Emergency
Center of Mechanicsburg in an amount in excess of $50,000.00 together with costs of this suit and
any other relief that this Honorable Court deems reasonable and just.
Respectfully Submitted,
CALDWELL & KEARNS, P.C.
Dated: March, 2014 By. r V��
Vd , er M. Go squire — I.D. No. 64316
Jessica E. Mercy, Esquire — I.D. No. 206405
3631 North Front Street
Harrisburg, PA 17110
(717) 232 -7661
(717) 232 -2766
pgood @cklegal.net
jmercy @cklegal.net
Attorneys for Plain tos
9
VERIFICATIO
Z, Mark D. Meyerhoff, DVM, individually, and as the Ma nagin g Member of Animal
Emergency Medical Centex, LLC, verify that the statements contained in the foregoing docutaciat
axe true and coxtect to the best of my knowledge, infomnation and belief. I undetstaud that false
statements therein are made subject to the penalties of I$ Pa.C.S.A. § 4904, relatLng to unswofn
£alsi£ cation to authorities.
h
Date.
Mar 4D. ,indiv idually, and as
Managing Member of A ninial Emergency Medical
Centex, LLC
MARK D. MEYERHOFF, DVM,
and ANIMAL EMERGENCY
MEDICAL CENTER, LLC,
Plaintiffs,
: IN THE COURT OF COMMONS PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. 14-1453 Civil
THOMAS W. MUNKITTRICK, DVM,
RENEE D. RICHARDS, VMD,
SHAKA MONROE, DVM and CIVIL ACTION — LAW
MONROE VETERINARY
EMERGENCY GROUP OF
MECHANICSBURG, INC. D/B/A THE :
ANIMAL EMERGENCY CENTER OF JURY TRIAL DEMANDED
MECHANICSBURG,
Defendants.
ACCEPTANCE OF SERVICE
AND NOW comes Stephen L. Grose, Esquire, attorney for Defendants,
Thomas W. Munkittrick, DVM, Renee D. Richards, VMD, Shaka Monroe, DVM and
Monroe Veterinary Emergency Group of Mechanicsburg, Inc. d/b/a The Animal Emergency
Center of Mechanicsburg, who, pursuant to Pa.R.C.P. No. 402(b), states:
I accept service of the Complaint on behalf of Defendants Thomas W.
Munkittrick, DVM, Renee D. Richards, VMD, Shaka Monroe, DVM and Monroe
Veterinary Emergency Group of Mechanicsburg, Inc. cl/b/a The Animal Emergency Center
of Mechanicsburg and certify that I am authorized to do so.
Date:
4,„
Stephen . Grose, Esquire
Caldwell & Kearns, P.C.
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661 (phone)
(717) 232-2766 (fax)
pgood@cklegal.net
jmercy@cklegal.net
Attorneys for Plaintiffs
r ,LLD -OFFICE
L FI
OFTHEP ROJHCNOi r�, r
i't (
2MRMAY —7 MI 9:46
CUMBERLAND COUNTY
PENNSYLVANIA
Peter M. Good, Esq.
I.D. No. 64316
Jessica E. Mercy, Esq.
I.D. No. 206405
MARK D. MEYERHOFF, DVM,
and ANIMAL EMERGENCY
MEDICAL CENTER, LLC,
Plaintiffs,
: IN THE COURT OF COMMONS PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. 14-1453
THOMAS W. MUNKITTRICK, DVM,
RENEE D. RICHARDS, VMD,
SHAKA MONROE, DVM and
MONROE VETERINARY
EMERGENCY GROUP OF
MECHANICSBURG, INC. D/B/A THE
ANIMAL EMERGENCY CENTER OF
MECHANICSBURG,
Defendants.
TO THE PROTHONOTARY:
: CIVIL ACTION — LAW
JURY TRIAL DEMANDED
PRAECIPE TO DISCONTINUE
Please mark this action settled, dismissed, and discontinued with prejudice.
Respectfully submitted,
Date: 5 ( 7 (ILj By:
Peter M. Good, Esquire I.D. #64316
Jessica E. Mercy, Esquire, I.D. #206405
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
Attorneys for Plaintiff
CERTIFICATE OF SERVICE
I hereby certify that a copy of the Praecipe to Discontinue was served upon the following,
by depositing a true and correct copy in the first-class mail, postage prepaid in an envelope
addressed as follows:
Date: S 1V-1
Stephen L. Grose, Esquire
Saidis, Sullivan & Rogers, P.C.
635 North 12th Street, Suite 400
Lemoyne, PA 17043
By:
CAL LL KEARNS, P.C.
Peter M. Good, Esquire I.D. #64316
Jessica E. Mercy, Esquire, I.D. #206405
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
Attorneys for Plaintiff