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HomeMy WebLinkAbout14-1942 Apr. 1. 2014 2: 49PM No. 0470 P. 2 Supreme C9 ; :off„ ennsylvania I Lout' Q tcd o Fleas For Prothonotary Use Only. Vet' t C.t;: Docket No: = C Otlllt ,i l I '" The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the flip and service ofpleadings or other a ers as required bylaw or rules o court. [,Audrey ommencement of Action: S ® Complaint M Writ of Summons ❑ petition �J Transfer from Another Jurisdiction ❑ Declaration of Taking E C ead Plaintiff s Name: Lead Defendant's Name: T Polly and Wesco Insurance Company a /s /o AudLe Pilot Travel Centers T Are money damages requested? R1 Yes d No Dollar Amount Requested: Qwit arbitrat q1limits (check one) E]outside arbitra Is this a Class Action Suit? C) Yes El No Is this an MDJ'Appeal? ❑ Yes 0 No A Name of Plaintiff/Appellant's Attorney: Thomas E. Brenner, Esquire ❑ Check here if you have no Attorney (Are a Self - Represented [Pro So] Litigant) Nature of the Case Place an." X" to the left of the ONE case category that most accurately describes your PAWARF 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 include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious prosecution © Debt Collection: Credit Card El Board of Assessment E] Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections [] Nuisance Dept. of Transportation El Premises Liability Statutory Appeal: Other S ❑ Product Liability (does not include [I 1E mass tort) Employment Dispute: El Slander /Libel /Dofamation Discrimination C ❑ Other: © Employment Dispute: Other ❑ Zoning Board T ❑ Other: I ❑ Other: O MASS TORT 0 Asbestos N ❑ Tobacco © Toxic Tort - DES E] Toxic Tort -implant READ PROPERTY MI SCELLANEOUS Toxic Waste 0 Ejetxment ® Other: ❑ Common Lava /Statutory Arbitration B ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent Mandamus ❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations PROFESSIONAL LIABLITY [] Mortgage Foreclosure: Residential Restraining Order Mortgage Foreclosure: Commercial ❑ Quo Watranto ❑ Dental 0 Partition Q � Replevin Legal ❑ Quiet Title ❑ Other: [� Medical ❑ Other: ❑ Other Professional: Updated 1/1/2011 A � Thomas E. Brenner, Esquire GOLDBERG KATZMAN, P.C. _t 4250 Crums Mill Road, Ste. 301 : Harrisburg, Box ,PA CU' Efii.AND C OU""T Harrisburg, PA 17112 (717)234- 4161E Y I i� Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Audrey Polly and Wesco Insurance I Company a /s /o Audrey Polly Plaintiffs V . Pilot Travel Centers Defendant PRAECIPE FOR ISSUANCE OF WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please initiate an action by Writ of Summons against Pilot Travel Centers PO Box 10146 Knoxville, TN 37939 X Writ of Summons shall be issued and forwarded to (X)Attorney ()Sheriff GOLDBERG KATZMAN, P.C. By: renner, Esquire Attorney ID No. 32085 P.O. Box 6991 Harrisburg, PA 17112 Date: (717) 234 -4161 � 3" ilk {00691706;vl } v ��� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Audrey Polly and Wesco Insurance Company a /s /o Audrey Polly Plaintiffs, 1q a V. Pilot Travel Centers Defendant SUMMONS IN CIVIL ACTION TO: Pilot Travel Centers, PO Box 10146, Knoxville, TN 37939 YOU ARE NOTIFIED THAT THE ABOVE -NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. By - Prothonotary Date: Deputy {00691706;v1} Thomas E. Brenner, Esquire GOLDBERG KATZMAN, P.C. 4250 Crums Mill Road, Ste. 301 P. O. Box 6991 Harrisburg, PA 17112 (717) 234-4161 Attorney for fir PROTHONO list; ' 20i4 APR 17 PH et 33 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF COUNTY, PENNSYLVANIA Audrey Polly and Wesco Insurance Company a /s /o Audrey Polly Plaintiffs v. , Pilot Travel Centers Defendant • • AFFIDAVIT OF SERVICE The Complaint was served on Defendant, Pilot Travel Centers through their office in Knoxville, Tennessee as reflected in the attached Certificate of Mailing receipt dated April 7, 2014. GOLDBERG KATZMAN, P.C. - : Brenner, Esquire Attorney ID No. 32085 P.O. Box 6991 Harrisburg, PA 17112 (717)234 -4161 Attorney for Plaintiff Date: {00694027;v1} SENDER: COMPLETE THIS SECTION • Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. • Print your name and address on the reverse so that we can return the card to you. • Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Po einP (-((/ kiX.A ( -r1) '57'07 A. Si X B. Re THIS SECTION ON DELIVERY Agent Addressee Delivery me) xD. Is delivery address different from item 1 CI Yes If YES, enter delivery address below: ❑ No 3. S ice Type Certified Mail ❑ Express Mall ❑ Registered Return Receipt for Merchandise O Insured Mail ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) ❑ Yes 2. Article Number 1— 7010 10130 0000 3370 7384 , (Transfer from service lithe° Fu Form 3811, February 2004 Domestic Return Receipt 102595 -02•M -1540 ; CERTIFICATE OF SERVICE I hereby certify that I am this date serving a copy of the foregoing document upon the person(s) 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, with first -class postage, prepaid as follows: Wes Chamberlain Pilot Travel Centers PO BOX 10146 Knoxville, TN 37939 By: Thomas E. Brenner, Esquire Date: c-4 b {00694027;v1} Karl R. Hildabrand, Esquire Lavery Faherty Patterson 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108 -1245 (717) 233 -6633 (telephone) (717) 233 -7003 (facsimile) Attorney No. PA30102 khildabrand@laverylaw.com Attorney for Defendant AUDREY POLLY and WESCO IN THE COURT OF COMMON PLEAS INSURANCE COMPANY a /s /o CUMBERLAND COUNTY, AUDREY POLLY, PENNSYLVANIA Plaintiffs, v. NO.: 14 -1942 PILOT TRAVEL CENTERS, CIVIL ACTION - LAW Defendant. PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Defendant, Pilot Travel Centers, in the above matter. DATE: V` z Y /K. Respectfully submitted, LAVERY FAHERTY PATTERSON By7ti � c(2 Karl R. Hildabrand, Esquire 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108 -1245 (717) 233 -6633 (telephone) (717) 233 -7003 (facsimile) Attorney No. PA30102 khildabrand@laverylaw.com Attorney for Defendant CERTIFICATE OF SERVICE I, Karl R. Hildabrand, Esquire, with the law firm of Lavery Faherty Patterson, do hereby certify that on this 7-V day of April, 2014, I served a true and correct copy of the foregoing Praecipe to Enter Appearance, via U.S. First Class mail, postage prepaid, addressed as follows: Thomas E. Brenner, Esquire Goldberg Katzman 4250 Crums Mill Road, Suite 301 PO Box 6991 Harrisburg, PA 17112 Attorney for Plaintiff R. Hildabrand, Esquire AUDREY POLLY and WESCO IN THE COURT OF COMMON PLEAS INSURANCE COMPANY a/s/o CUMBERLAND COUNTY, AUDREY POLLY, PENNSYLVANIA Plaintiffs, V. NO.: 14-1942 PILOT TRAVEL CENTERS, CIVIL ACTION-LAW Defendant. RULE TO FILE A COMPLAINT mco C-- TO: Thomas E. Brenner, Esquire -< w Goldberg Katzman 4250 Crums Mill Road, Suite 301 _ PO Box 6991 ' Harrisburg, PA 17112 Attorney for Plaintiff You are hereby directed to file a Complaint in the above matter within twenty(20) days of service or non pros will be entered against you. Prothono DATE: 6,- /3/�/ Karl R.Hildabrand,Esquire 's ) a r Lavery Faherty Patterson 225 Market Street, Suite 304 w^14 AIN 13 Pm l: t P.O.Box 1245 ' { Harrisburg,PA 17108-1245 "UMBERLAN (717)233-6633(telephone) PENNSYLVANIA (717)233-7003 (facsimile) Attorney No.PA30102 khildabrand@laverylaw.com Attorney for Defendant AUDREY POLLY and WESCO IN THE COURT OF COMMON PLEAS INSURANCE COMPANY a/s/o CUMBERLAND COUNTY, AUDREY POLLY, PENNSYLVANIA Plaintiffs, V. NO.: 14-1942 PILOT TRAVEL CENTERS, CIVIL ACTION-LAW Defendant. PRAECIPE FOR RULE TO FILE A COMPLAINT TO THE PROTHONOTARY: Kindly enter Rule upon the Plaintiffs to file a Complaint within twenty(20) days of service or suffer judgment of non pros. Respectfully submitted, LAVERY FAHERTY PATTERSON DATE: - z-i`-� By: i,t`<!� Karl R. Hildabrand, Esquire 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 (717)233-6633 (telephone) (717) 233-7003 (facsimile) Attorney No. PA30102 khildabrand@laverylaw.com Attorney for Defendant CERTIFICATE OF SERVICE I, Karl R. Hildabrand, Esquire, with the law firm of Lavery Faherty Patterson, do hereby certify that on this 12,- day of June, 2014, 1 served a true and correct copy of the foregoing Praecipe for Rule to File a Complaint, via U.S. First Class mail, postage prepaid, addressed as follows: Thomas E. Brenner, Esquire Goldberg Katzman 4250 Crums Mill Road, Suite 301 PO Box 6991 Harrisburg, PA 17112 Attorney for Plaintiff R. Hildabrand, Esquire r v. FILED -OFF C THE BfO�' �HONO IN THE COURT OF COMMON PLEAS TA FS r OF CUMBERLAND COUNTY, PENNSYLVJ 4MIUL _ 7 pM 1: 59 Wesco Insurance Company a/s/o AudreyCU1BERLANC COI�rNT' Audrey Polly and r` Polly NO. 14-1942 PENNS YLVANIq Plaintiffs • • Pilot Travel Centers : CIVIL ACTION - LAW Defendant • • NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following paged, 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 800-990-9108 {00701309;v1} IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Audrey Polly and Wesco Insurance Company a/s/o Audrey Polly : NO. 14-1942 Plaintiffs v. Pilot Travel Centers : CIVIL ACTION - LAW Defendant • NOTICIA Le has demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguintes, useted tiene viente (20) dias de plaza al partir de las fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objectiones a las demandas en contra de su persona. Sea adisado que si usted no se defiende, la sin previo aviso o notificacion y por cualquier quja o puede perder dinero o sus propiendades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUGICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OPICINA CUYA DIRECCI9ON SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 800-990-9108 {00701309;v1} Thomas E. Brenner, Esquire GOLDBERG KATZMAN, P.C. 4250 Crums Mill Road, Ste. 301 P. 0. Box 6991 Harrisburg, PA 17112 (717) 234-4161 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Audrey Polly and Wesco Insurance Company a/s/o Audrey Polly : NO, 14-1942 Plaintiffs V. Pilot Travel Centers : CIVIL ACTION - LAW Defendant COMPLAINT AND NOW, comes the Plaintiffs, by their attorneys Goldberg Katzman, P.C. 1. Plaintiff, Audrey Polly as an adult individual residing at 436 Woodlawn Drive, Apt. H, North Vernon, Indiana. 2. Plaintiff, Wesco Insurance Company is a business entity with an address of P.O. Box 650767, Dallas, Texas. 3. Defendant, Pilot Travel Centers operate its gasoline station at 1501 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania. 4. This matter arises from an incident that occurred on April 7, 2012. 5. At that time, Plaintiff, Audrey Polly had arrived at the fuel pump at the Pilot facility. 6. She emerged from her vehicle to fuel that vehicle, at which point she slipped and fell on diesel fuel that was located on the ground in the fuel pumps. {00701309;v1} 7. This incident arose from the negligence and carelessness of Defendant, Flying J Travel Stop, in that they: a. Failed to monitor the conditions of the fuel island; b. Failed to clean up the spilled fuel; c. Failed to alert patrons of the danger posed by the fuel spilled; and d. Failed to maintain a fuel facility safe for patrons. 8. As' a result of the afore -said fall, Plaintiff, Audrey Polly sustained an injury to her left arm and shoulder necessitating medical care, and requiring her to lose time from her employment. 9. Ms. Polly has made a claim with Wesco Insurance, the workers' compensation carrier for her employer, Summit Trucking, and Wesco has paid the medical expenses and lost wages incurred by Ms. Polly, which amount to $40,447.70, medical expenses of $18,044.27, and lost wage payments of $22,403.43. WHEREFORE, Plaintiff demands judgment against Defendant, Flying J Truck Stop in the amount of less than $50,000.00, together with costs of suit. Date: 3 (� l� {00701309;v1} By: GOLDBERG KATZMAN, P.C. renner, Esquire Attorney ID No. 32085 P.O. Box 6991 Harrisburg, PA 17112 (717)234-4161 Attorney for Plaintiff VERIFICATION I, Thomas E. Brenner, Esquire, hereby acknowledge that I am the attorney for Plaintiffs Audrey Polly and Wesco Insurance Company a/s/o Audrey Polly. have read the foregoing document, and that the facts stated therein are true and correct based upon the knowledge, information, and belief provided to me by my clients. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: July 3, 2014 By: {00673527;v1} Thomas E. Brenner, Esquire CERTIFICATE OF SERVICE I hereby certify that I am this date serving a copy of the foregoing document upon the person(s) 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, with first-class postage, prepaid as follows: Karl Hildabrand, Esquire LAVERY FAHERTY PATTERSON 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 By: Date: {00701309;v1} Thomas E. Brenner, Esquire Karl R. Hildabrand, Esquire Lavery Faherty Patterson 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 (717) 233-6633 (telephone) (717) 233-7003 (facsimile) Attorney No. PA30102 khildabrand@laverylaw.com Attorney for Defendant • G',4 2% �� PM I: 9 PEE'RL COUNT VA N/A PENNSr AUDREY POLLY and WESCO INSURANCE COMPANY a/s/o AUDREY POLLY, Plaintiffs, v. PILOT TRAVEL CENTERS, Defendant. • • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 14-1942 CIVIL ACTION - LAW NOTICE TO PLEAD To: Plaintiffs c/o Thomas E. Brenner, Esquire Goldberg Katzman 4250 Crums Mill Road, Suite 301 PO Box 6991 Harrisburg, PA 17112 You are hereby notified to file a written response to the enclosed Answer and New Matter of Defendant within twenty (20) days from service hereof or a judgment may be entered against you. DATE: -7/(V/77 LAVERY FAHERTY PATTERSON By: Karl R. Hildabrand, Esquire 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 (717) 233-6633 Karl R. Hildabrand, Esquire Lavery Faherty Patterson 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 (717) 233-6633 (telephone) (717) 233-7003 (facsimile) Attorney No. PA30102 khildabrand@laverylaw.com Attorney for Defendant AUDREY POLLY and WESCO IN THE COURT OF COMMON PLEAS INSURANCE COMPANY a/s/o CUMBERLAND COUNTY, AUDREY POLLY, PENNSYLVANIA Plaintiffs, . v. PILOT TRAVEL CENTERS, Defendant. • • • NO.: 14-1942 CIVIL ACTION - LAW DEFENDANT'S ANSWER AND NEW MATTER 1. Denied. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments set forth in Paragraph 1 and the averments are therefore denied. 2. Admitted. 3. Denied. The averments of Paragraph 3 are specifically denied and proof thereof is demanded. 4. Denied. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments set forth in Paragraph 4 and the averments are therefore denied. 5. Denied. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments set forth in Paragraph 5 and the averments are therefore denied. 6. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments set forth in Paragraph 6 and the averments are therefore denied. 7. Denied. The averments of Paragraph 7 and subparagraphs 7a through 7d are specifically denied and proof thereof is demanded at trial. 8. Denied. The averments of Paragraph 8 are specifically denied and proof thereof is demanded at trial. 9. Denied. Defendant is without knowledge or information sufficient to foim a belief as to the truth of the averments set forth in Paragraph 9 and the averments are therefore denied. NEW MATTER 10. Plaintiffs' Complaint is barred by the Statute of Limitations. 11. Plaintiffs' Complaint is barred, in whole or in part, by the provisions of the Pennsylvania Comparative Negligent Statute. 12. Plaintiffs have failed to mitigate their damages. 13. Any injury alleged by the Plaintiff, which is denied, preexisted the alleged accident in question or occurred subsequent to the date of the accident in question. 14. Plaintiff assumed the risk of her alleged injuries. 2 15. Plaintiffs' claims are barred, in whole or in part, by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. Respectfully submitted, LA VERY FAHERTY PATTERSON DATE: --2/( By: arl R. Hildabrand, Esquire 225 Market Street, Suite 304 P.O. Box 1245 Harrisburg, PA 17108-1245 (717) 233-6633 (telephone) (717) 233-7003 (facsimile) Attorney No. PA30102 khildabrand@laveryl aw. corn Attorney for Defendant VERIFICATION I, Wesley D. Chamberlain, on behalf of Pilot Travel Centers LLC, verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief I understand that false statements herein are made subject to the penalties_afl&Ra._CS_§_4_9-04-relating-to-unsworn-falsi-fication-to-autheritie-s. Date: 711 C_) Wesley D. amberlain CERTIFICATE OF SERVICE I, Karl R. Hildabrand, Esquire, with the law firm of Lavery Faherty Patterson, do hereby certify that on this day of July, 2014, I served a true and correct copy of the foregoing Defendant's Answer and New Matter, via U.S. First Class mail, postage prepaid, addressed as follows: Thomas E. Brenner, Esquire Goldberg Katzman 4250 Crums Mill Road, Suite 301 PO Box 6991 Harrisburg, PA 17112 Attorney for Plaintiffs Karl R. Hildabrand, Esquire n Thomas E. Brenner,Esquire 1 /i _ GOLDBERG KATZMAN, P.C. Ztf!t JU, � 4250 Crums Mill Road, Ste. 301 Z P. O.Box 6991 (1 Harrisburg,17PA 17112 ��� J}'ND C��/y� ��� ( ) Lvrl Attorney for Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Audrey Polly and Wesco Insurance Company a/s/o Audrey Polly Plaintiffs No.: 14-1942 V. Pilot Travel Centers Defendant PLAINTIFFS' REPLY TO NEW MATTER AND NOW, come Plaintiffs by and through their attorneys, Goldberg Katzman, P.C., who states: 10. Denied. This paragraph states a legal conclusion to which no response is necessary. 11. Denied. This paragraph states a legal conclusion to which no response is necessary. 12. Denied. This paragraph states a legal conclusion to which no response is necessary. 13. Denied. 14. Denied. This paragraph states a legal conclusion to which no response is necessary. 15. Denied. This paragraph states a legal conclusion to which no response is necessary. {00711147;v1} WHEREFORE, Plaintiffs request that Defendant's New Matter be dismissed with prejudice. GOLDBERG KATZMAN, P.C. By: 1— Thomas E. Brenner, Esquire Atty No.: 32085 4250 Crums Mill Road, Ste. 301 P.O. Box 6991 Harrisburg, PA 17112 (717) 234-4161 (717) 234-6808 (facsimile) Date: 7� J i '� Attorney for Plaintiffs {00711147;v1} VERIFICATION I, Thomas E. Brenner, Esquire, hereby acknowledge that I am the attorney for Plaintiffs Audrey Polly and Wesco Insurance Company a/s/o Audrey Polly. I have read the foregoing document, and that the facts stated therein are true and correct based upon the knowledge, information, and belief provided to me by my clients. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: �(� l f By: Thomas E. Brenner, Esquire {00711147;v1} CERTIFICATE OF SERVICE I hereby certify that I am this date serving a copy of the foregoing document upon the person(s) 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, with first-class postage, prepaid as follows: Karl R. Hildabrand, Esquire Lavery Faherty Patterson 225 Market Street, Suite 304 PO Box 1245 Harrisburg, PA 17108-1245 By: (z 1�'_ Thomas E. Brenner, Esquire Date: -7 W( � {00711147;vl} Thomas E. Brenner, Esquire GOLDBERG KATZMAN, P.C. 4250 Crums Mill Road, Ste. 301 P. O. Box 6991 Harrisburg, PA 17112 (717) 234-4161 Attorney for Plaintiff 104: P 11 ��1 � Jilt 0 / f�r0 U rCoiroERLAIIito coo Ty IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Audrey Polly and Wesco Insurance Company a/s/o Audrey Polly Plaintiffs V. : No.: 14-1942 Pilot Travel Centers Defendant PRAECIPE TO APPEND VERIFICATION Please append the Verification of Paige Smith to the Complaint filed of Record in this matter. B Date: /' 7-g {00711297;v1} GOLDBERG KATZMAN, P.C. renner, Esquire Atty No.: 32085 4250 Crums Mill Road, Ste. 301 P.O. Box 6991 Harrisburg, PA 17112 (717) 234-4161 (717) 234-6808 (facsimile) Attorney for Plaintiffs VERIFICATION , a representative of Wesco Insurance Company 5 hereby acknowledge that I have read the foregoing document, and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. By: Date: {00673528;v1} Wesco Insurance Company CERTIFICATE OF SERVICE I hereby certify that I am this date serving a copy of the foregoing document upon the person(s) 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, with first-class postage, prepaid as follows: Karl R. Hildabrand, Esquire Lavery Faherty Patterson 225 Market Street, Suite 304 PO Box 1245 Harrisburg, PA 17108-1245 Thomas E. Brenner, Esquire Date: 7fq(ict {00711297;v1}