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Home My WebLink About14-2532 Supreme Courf ofTennsylvania Court f Common' -Pleas For Prothonotary Use Only: Civil Covers_heet Docket No: curw�8 O County 3oL The information collected on rNs forum is used sole!: for court administration purposes. This form does not supplement or replace the filing and seri of pleadings or other papers as required by lain or rules of court. Commencement of Action: S [I Complaint 0 Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lea Plai tiff's Name: Lead Defendant's Na C �� T nBr1 /g� /� l9 *` DolTar Amount Requested: [:]within arbitration limits I Are money damages requested? $ Yes ❑ No (check one) outside arbitration limits O Q N Is this a Class Action Suit? El Yes No Is this an MDJAppeal? ❑ Yes fi No A Name of Plaintiff /Appellant's Attorney: ❑ ('lreelc here if }ou have no attornes (are a Self- Represented [Pro Sel Litivant) 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 riot include Judgnnents) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability (does not include ❑ Employment Dispute: E mass tort) Discrimination ❑ Slander /Libel/ Defamation ❑ C Employment Dispute: Other El Zoning Board � Other: r T , � 4 'e [I Other: I ❑ Other: O MASS TORT ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment B ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Plaintiff(s) & Address(es) Anthony M. Armada 1 Oak Drive Hurricane, WV 25526 z Case No. / 7 — c� c 3c)— Civil Term VS. Civil Action - MVA 4/25/2012 Defendant(s) & Address(es) c Taylor A. Abel3 T ' 40 Honeysuckle Drive r n Co Mechanicsburg, PA 17050 z_'0 C) A a� PRAECIPE FOR WRIT OF SUMMONS' TO THE PROTHONOTARY /CLERK OF SAID COURT: Issue summons in the above case Writ of Summons shall be issued and forwarded to AttorB riff. lease it le choice Date: Signature of Attorney Print Name: R. Mark Thomas, Esquire Address: 101 S. Market Street Mechanicsburg, PA 17055 Telephone #: 717- 796 -2100 Supreme Court ID Number: 41301 WRIT OF SUMMONS TO: Taylor A. Abel YOU ARE NOTIFIED THAT THE ABOVE -NAMED PLAINTIFFS) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. D. a ti Prothonotary/Clerk, Civil Division Date: Deputy _f 3. 2 J �� a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ' 1 t i E D_ ,t t=1 Sheriff T r sod CTP0P'0`_, F<J FH1'ti i Jody S Smith 2014 APR 30 PM 3. 0 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA Anthony M Armada Case Number vso 2014-2532 Taylor A Abel SHERIFF'S RETURN OF SERVICE 04/25/2014 06:45 PM- Deputy Dawn Kell, being duly sworn according to law, served the requested Writ of Summons by handing a true copy to a person representing themselves to be Nicole Abel, Sister of defendant,who accepted as"Adult Person in Charge"for Taylor A Abel at 40 Honeysuckle Drive, Silver Spring Township, Mechanicsburg, PA 17050. C 1.J r3.Ly�'1 �.1✓�K.X_.__ DAWN KELL, DEPUTY SHERIFF COST: $39.79 SO ANSWERS, April 28, 2014 RbNW R ANDERSON, SHERIFF (c)CcuntySuite Sheriff,Teleosoft.Inc. Law Offices of Hubshrnan, Flood & Bullock By: Andrea J. Bullock, Esquire Attorney ID #203240 5165 Campus Drive, Suite 200 Plymouth Meeting, PA 19462 Telephone #(61o) 276-4963 An drea_J_Bull ock P rogressive. com Our File #124118534-001 Anthony Armada V. Taylor Abel TO THE PROTHONOTARY: Attorney for Defend Taylor A. Abel : Court of Common Pleas : Cumberland County : 2014-2532 ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Taylor A. Abel in the above -captioned matter. Law Offices of Hubshman, Flood & Bullock By: Andrea J. Bullock, Esqui e Attorney for Defendant Law Offices‘of Hubshman, Flood & Bullock By: Andrea J. Bullock, Esquire Attorney ID #203240 5165 Campus Drive, Suite 200 Plymouth Meeting, PA 19462 Telephone #(610) 276-4963 Andrea_J_Bullock@Progressive.com Our File #124118534-001 Anthony Armada v. Taylor Abel Attorney for Defendant Taylor A. Abel : Court of Common Pleas : Cumberland County : 2014-2532 PRAECIPE TO FILE COMPLAINT TO THE PROTHONOTARY: Please enter a Rule upon the Plaintiff to file a Complaint within twenty (20) days hereof or suffer the Entry of Judgment Non Pros. Law Offices of Hubshman, Flood & Bullock By: o,46(ALA Andrea J. Bullock, Esq ire Attorney for Defendant RULE TO FILE COMPLAINT AND NOW, lilt 14 , ()OI H a Rule_ is hereby granted upon Plaintiff to file a Complaint within twenty (20) days hereof or suffer the Entry of Judgment Non Pros. . PROTHONOTARY ANTHONY M. ARMADA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. TAYLOR A. ABEL Plaintiff Defendant : CIVIL ACTION at LAW : Civil No. 2014-2532 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717)-249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans With Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ANTHONY M. ARMADA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. TAYLOR A. ABEL Plaintiff Defendant • • • : CIVIL ACTION at LAW : Civil No. 2014-2532 AVISO USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia escrita en person o por abogado y presentar en la Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificacion por cualquier dinero reclamado en la demanda o por cualquier otra wueja o compensacion reclamados por el Demandant. USTED PUEDE PERDER DINERO, 0 PROPIEDADES U OTROS DERCHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENT. SI USTED NO TIENE 0 NO CONOCE UN ABOGADO, VAYA 0 LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717)-249-3166 ANTHONY M. ARMADA v. TAYLOR A. ABEL : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : CIVIL ACTION at LAW Defendant : Civil No. 2014-2532 COMPLAINT AND NOW, comes the Plaintiff, Anthony M. Armada, by and through his counsel, R. Mark Thomas, Esquire, and files this Complaint against the above captioned Defendant and in support thereof respectfully represents: 1. Plaintiff, Anthony M. Armada, is an adult individual who resides at 1 Oak Drive, Hurricane, West Virginia, 25526. 2. Defendant, Taylor A. Abel, is an adult individual who resides at 40 Honeysuckle Drive, Mechanicsburg, Pennsylvania, 17050. 3. On April 25, 2012, at approximately 10:30 p.m., a car driven by the Defendant struck the rear end of a car proceeding in the same direction in which Plaintiff was a passenger. 4. This collision occurred in the southbound lanes of 1-81 in the proximity of I -81's intersection with Sample Bridge Road, Silver Spring Township, Cumberland County. 5. Due to the impact from the collision, Plaintiff suffered severe personal injury. 6. The collision of these two cars on I-81 south was caused by the negligence, carelessness, and/or recklessness of the Defendant, consisting of the following: a. his failure to remain focused upon the road ahead of him while driving a car; b. falling too closely behind the car in which Plaintiff was a passenger; c. operating his car in a careless and reckless manner without due regard for the rights and safety of those lawfully upon the roadway, one of whom was Plaintiff; d. his failure to maintain control of his car and avoid colliding with the car in which Plaintiff was a passenger; and e. driving his car at a speed in excess of the maximum speed limit allowed by law. 7. Due to the aforesaid negligence, carelessness, and/or recklessness of the Defendant, Plaintiff suffered severe and permanent injuries to his spinal column, including a thoracic compression fracture, and a thoracic disc herniation, along with all muscle and nerve related injuries relative to the thoracic fracture and disc herniation. 8. By reason of the aforesaid carelessness, recklessness, and negligence of the Defendant, Plaintiff has in the past, and will in the future, undergo severe pain and suffering. 9. In addition to the aforesaid physical injuries, Plaintiff, as a direct result of Defendant's carelessness, recklessness, and negligence has been caused to suffer loss in the form of anxiety, humiliation, frustration, loss of the feeling of well-being, limitation of activities, and loss of enjoyment of life. 10. As a further result of Defendant's carelessness, recklessness, and negligence, Plaintiff has been and will be obliged to undergo continuing medical care, to expend various sums of money and to incur various expenses for the injuries which he suffered. WHEREFORE, Plaintiff, Anthony M. Armada, prays that this Honorable Court will enter judgment in favor of Plaintiff and against Defendant in an amount that exceeds the jurisdictional amount requiring compulsory arbitration pursuant to local rule. Respectfully submitted, R. Mark Thomas, Esquire iD# 41301 101 S. Market Street Mechanicsburg, PA 17055 (717) 796-2100 VERIFICATION I, Anthony M. Armada, hereby verify that the statements made in the forgoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Dated: July 3,2O14 Law Offices of Hubshman, Flood & Bullock By: Andrea J. Bullock, Esquire Attorney ID #203240 5165 Campus Drive, Suite 200 Plymouth Meeting, PA 19462 Telephone #(610) 276-4963 Our File #124118534-001 Attorney for Defendant, Taylor A. Abel ANTHONY ARMADA : COURT OF COMMON PLEAS : CUMBERLAND COUNTY V. TAYLOR ABEL : 2014-2532 DEMAND FOR JURY TRIAL TO THE PROTHONOTARY: Defendant, Taylor Abel, hereby demands trial by twelve (12) jurors. Law Offices of Hubshman, Flood & Bullock By: Andrea J. Bullock, Esquire Attorney for Defendant NOTICE TO PLEAD TO:. Plaintiff You are hereby notified to file a written response to the enclosed Answer with New Matter within twenty (20) days from service hereof or a judgment may be entered against yo By a J. Bullock, Esq. Attorney for Defendant Law Offices of Hubshman, Flood & Bullock By: Andrea J. Bullock, Esquire Attorney ID #203240 5165 Campus Drive, Suite 200 Plymouth Meeting, PA 19462 Telephone #(610) 276-4963 Our File #124118534-001 Anthony Armada v. Taylor Abel CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the attached pleading upon all other parties or their attorneys by: regular mail certified mail By ot6�h r o;%// Andr . Bullock, Esq. Attorney for Defendant Attorney for Defendant Taylor A. Abel : Court of Common Pleas : Cumberland County : 2014-2532 DEFENDANT'S ANSWER AND NEW MATTER TO PLAINTIFF'S COMPLAINT 1. Denied. After reasonable investigation, answering defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph, and strict proof thereof is demanded at the time of trial. 2. Admitted. 3. Denied. After reasonable investigation, answering defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph, and strict proof thereof is demanded at the time of trial. 4. Denied. After reasonable investigation, answering defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in this paragraph, and strict proof thereof is demanded at the time of trial. 5. Denied. The allegations contained in this paragraph are conclusions of law, and no response is required. 6. Denied. The allegations contained in this paragraph are conclusions of law, and no response is required. 7. Denied. The allegations contained in this paragraph are conclusions of law, and no response is required. 8. Denied. The allegations contained in this paragraph are conclusions of law, and no response is required. 9. Denied. The allegations contained in this paragraph are conclusions of law, and no response is required. 10. Denied. The allegations contained in this paragraph are conclusions of law, and no response is required. WHEREFORE, answering defendant demands judgment in his favor and dismissal of plaintiff's complaint with prejudice. NEW MATTER 1. Plaintiffs Complaint fails to state a claim upon which relief may be granted. 2. Plaintiff failed to mitigate their damages. 3. If Plaintiff's sustained the injuries and damages as alleged in the Complaint, then same were caused by other entities or parties over which answering Defendant had no control. 4. Plaintiffs claims are barred, in whole and/or in part, by the appropriate Statute of Limitations. 5. Plaintiffs voluntarily adopted a dangerous and hazardous method or manner of performing the actions that they were then undertaking when there was a safe method available and they thereby assumed the risk of injury in performing their actions. 6. Plaintiffs claims are barred, or must be reduced, as a result of Plaintiffs own negligence, which was the proximate cause of the incident described in Plaintiff's Complaint, pursuant to the Pennsylvania Comparative Negligence Act, 42 Pa. C.S.A. Section 7100. 7. Plaintiffs claims are barred and/or limited by the Motor Vehicle Financial Responsibility Law, 75 Pa. C.S. Section 1701, et seq. 8. Plaintiffs claims are barred and/or limited by the Pennsylvania Motor Vehicle No -Fault Insurance Act. 9. This Court lacks jurisdiction over the subject matter of the within action. 10. If Plaintiff sustained the injuries and damages as alleged in the Complaint, then same were not proximately caused by any action or failure to act on behalf of answering Defendant. 11. Answering Defendant avers that Plaintiffs cause of action is barred or limited by the Sudden Emergency Doctrine. 12. Plaintiffs claims are barred and/or limited by the New Jersey Deemer Statute, N.J.S.A. 17:28-1.4. WHEREFORE, answering Defendant demands judgment in his favor. BY: DATE: July 25, 2014 Law 0 ces of Hubshman, Flood & Bullock drea J. Bullock, Esquire Attorney for Defendant VERIFICATION I, Andrea J. Bullock, Esquire, aver that I am the attorney for the answering Defendant in this case, and I aver that the averments contained in the foregoing pleadings are true and correct to the best of my knowledge, information and belief; and that the statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Andrea J. Bullock, Esquire ANTHONY M. ARMADA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. TAYLOR A. ABEL Plaintiff : CIVIL ACTION at LAW Defendant : Civil No. 2014-2532 PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER 1. Denied. This allegation is a conclusion of law to which no responsive pleading is required and therefore same is denied. 2. Denied. This allegation is a conclusion of law to which no responsive pleading is required and therefore same is denied. 3. Denied. Plaintiff is without sufficient knowledge, information, or belief following reasonable investigation to either affirm or deny the existence of those entities or parties to which defendant makes reference in this paragraph. 4. Denied. This allegation is a conclusion of law to which no responsive pleading is required and therefore same is denied. 5. Denied. Plaintiff has no knowledge of having undertaken any course of action which could have been considered dangerous and hazardous at any time relevant to the collision in this case. Further, the rest of this allegation is a conclusion of law to which no responsive pleading is required and therefore same is denied. 6. Denied. This allegation is a conclusion of law to which no responsive pleading is required and therefore same is denied. 7. Denied. This allegation is a conclusion of law to which no responsive pleading is required and therefore same is denied. 8. Denied. This allegation is a conclusion of law to which no responsive pleading is required and therefore same is denied. 9. Denied. This allegation is a conclusion of law to which no responsive pleading is required and therefore same is denied. 10. Denied. The injuries for which plaintiff has sought recovery were proximately caused by the collision which resulted from the defendant's negligence. 11. Denied. This allegation is a conclusion of law to which no responsive pleading is required and therefore same is denied. 12. Denied. This allegation is a conclusion of law to which no responsive pleading is required and therefore same is denied. WHEREFORE, Plaintiff, Anthony M. Armada, prays that this Honorable Court will enter judgment in favor of Plaintiff as previously set forth in Plaintiff's Complaint. Respectfully submitted, a,diff R. Mark Thomas, Esquire ID# 41301 101 S. Market Street Mechanicsburg, PA 17055 (717) 796-2100 VERIFICATION I, Anthony M. Armada, hereby verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: August 2014 Law Offices of Hubshman, Flood & Bullock By: Andrea J. Bullock, ESquire Attorney ID #203240 5165 Campus Drive, Suite 200 Plymouth Meeting, PA 19462 Telephone #(61o) 276-4963 Our File #124118534-001 Anthony Armada v. Taylor Abel Cl,+�f�'i?; J///1/` Attorney for Defendant ,,G4 o�� 2 /�0� r�' C Taylor A. Abel ` �i``��J r? ,P8 f; ; r Court of Common Pleas Cumberland County : 2014-2532 DEFENDANT, TAYLOR ABEL'S, MOTION TO COMPEL PLAINTIFF'S, ANTHONY ARMADA, RESPONSES TO DISCOVERY REQUESTS Defendant moves this Honorable Court to enter an Order pursuant to Pa. R.C.P. 4019 compelling Plaintiff to answer certain discovery propounded upon them by moving Defendant in this matter. In support of this motion, Defendant aver the following: 1. On June 11, 2014, Defendant served Plaintiffs counsel Interrogatories and Request for Production of Documents to be answered within thirty (30) days. See Exhibit "A" attached hereto. 2. On July 16, 2014, counsel for Defendant sent correspondence to Plaintiff s counsel in follow up to the initial request. See Exhibit "B" attached hereto. 3. As of this date, Plaintiff has not fully answered these Interrogatories or Request for Production of Documents, which is in violation of the Pennsylvania Rules of Civil Procedure. 4. The said Interrogatories are relevant, material and necessary and Defendant will be prejudiced if full and complete Answers to the Interrogatories are not filed. 5. If Plaintiff do not provide the information requested in the Request for Production of Documents, Defendant will be severely prejudiced in the defense of this case. The said Request for Production of Documents are relevant, material and necessary to the defense of this case. 6. Plaintiffs counsel has not provided responses. WHEREFORE, it is respectfully requested that this Honorable Court enter an Order directing Plaintiff to file full, complete and specific Answers to Interrogatories and Request for Production of Documents. Law Offices of Hubshman, Flood & Bullock C-2 By: Andrea J. Bullock, Esquire Attorney for Defendant Law Offices of Hubshman, Flood & Bullock By: Andrea J. Bullock, Esquire Attorney ID #203240 5165 Campus Drive, Suite 200 Plymouth Meeting, PA 19462 Telephone #(61o) 276-4963 Our File #124118534-001 Anthony Armada V. Taylor Abel Attorney for Defendant Taylor A. Abel : Court of Common Pleas : Cumberland County : 2014-2532 DEFENDANT'S MEMORANDUM OF LAW IN SUPPORT OF MOTION TO COMPEL PLAINTIFF'S, ANTHONY ARMADA, RESPONSES TO DISCOVERY REQUESTS 1. Matter before the Court: Before the Court is Defendant's Motion to Compel Discovery in the form of a Motion to Compel Answers to Interrogatories and Request for Production of Documents. 2. Statement of Question Involved: Are Defendant entitled to an Order compelling Plaintiff to answer Interrogatories and Request for Production of Documents where Interrogatories and Request for Production of Documents were forwarded more than thirty (30) days ago and are now overdue? Suggested answer: Yes 3. Facts: On June 11, 2014, Defendant's counsel served Interrogatories and Request for Production of Documents on counsel for Plaintiff. More than thirty (30) days have now elapsed and Plaintiff have failed to respond to the requested discovery. 4. Argument: Pa. R.C.P. 4005, titled, Written Interrogatories to a party permits one party to serve any other party with written interrogatories. Pa. R.C.P. 4006 requires a party to provide written, verified interrogatories within thirty (30) days after service of the interrogatories. Pa. R.C.P. 4009.1, titled, Production of Documents and Things, permits a party to serve or request upon any party to produce designated documents, including writings, drawings, grafts, charts, photographs, electronically created data, and other compilations of data from which information can be obtained. Pa. R.C.P. 4009.12 provides that a party shall respond to said request within thirty (30) days. Thirty days have now elapsed since Defendant forwarded Interrogatories and Request for Production of Documents to Plaintiff and they have failed to respond or otherwise object to these discovery requests. 5. Relief: Wherefore, Defendant respectfully requests this Court grant the Motion and issue an Order compelling Plaintiff to respond to Defendant's discovery requests within twenty (20) days. Law Offices of Hubshman, Flood & Bullock By: Andrea J. Bullock, Esquire Attorney for Defendant Law Offices of Hubshman, Flood & Bullock By: Andrea J. Bullock, Esquire Attorney ID #203240 5165 Campus Drive, Suite 200 Plymouth Meeting, PA 19462 Telephone #(610) 276-4963 Our File #124118534-001 Anthony Armada V. Taylor Abel Attorney for Defendant Taylor A. Abel : Court of Common Pleas : Cumberland County : 2014-2532 CERTIFICATE OF SERVICE I, Andrea J. Bullock, attorney for Defendant, hereby certify that I caused a true and correct copy of Motion to Compel Responses to Discovery Requests and Memorandum of Law in Support of the same to be mailed this date by First Class, U.S. Mail, postage prepaid, to the following: Date: 9/18/14 R. Mark Thomas, Esquire R. Mark Thomas Law Practice 101 S. Market Street Mechanicsburg, PA 17055 (717) 796-2100 Law Offices of Hubshman, Flood & Bullock By: Andrea J. Bullock, Esquire Attorney for Defendant VERIFICATION Andrea J. Bullock, Esquire, aver that I am the attorney for the Defendant in this case, and I aver that the averments contained in the foregoing pleadings are true and correct to the best of my knowledge, information and belief; and that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Andrea J. Bullock, Esquire ExmBIT "A" LAW OFFICES OF HUBSHMAN, FLOOD & BULLOCK Not a Partnership, Not a Corporation 5165 CAMPUS DRIVE, SUITE 200 PLYMOUTH MEETING, PA 19462 Andrea J. Bullock, Esquire Direct #(61o) 276-4963 Andrea_J_Bullock@Progressive.com Facsimile #(866) 842-1482 June 13, 2014 R. Mark Thomas, Esquire R. Mark Thomas Law Practice 101 S. Market Street Mechanicsburg, PA 17055 SALARIED EMPLOYEES OF PROGRESSIVE CASUALTY INSURANCE COMPANY RE: Armada v. Abel Cumberland County Court of Common Pleas No. 2014-2532 File No. 124118534-001 Dear Mr. Thomas: I represent the Defendant, Taylor A. Abel, in the above -captioned matter. If you served any documents on my client, please provide me with a copy. Enclosed please find the following: Entry of Appearance; Praecipe/Rule to File Complaint; Interrogatories Addressed to Plaintiff(s); Request for Production Addressed to Plaintiff(s); and Notice of Deposition. It is the goal of this office to expedite the resolution of litigation against my clients in an efficient manner by scheduling depositions early in the discovery process. With notice well in advance, I believe that scheduling conflicts can be easily recognized and avoided. Enclosed is a Notice of Deposition directed to your client to take place on September 23, 2014, at 10:00 a.m. at The American Red Cross, 79 E. Pomfret Street, Carlisle, PA 17013. I will provide a court reporter at that time. If you would like to depose my client at the same time, kindly forward a Notice of Deposition. If this date is inconvenient, please contact my office to re -schedule the deposition for another date. If I do not hear from you, I will assume that the deposition will proceed on that date. Thank you for your anticipated professional courtesies. Very truly yours, /s/ajb Andrea J. Bullock, Esquire AJB/ajp Enclosure EXHIBIT "B" LAW OFFICES OF HUBSHMAN, FLOOD & BULLOCK Not a Partnership, Not a Corporation 5165 CAMPUS DRIVE, SUITE 200 PLYMOUTH MEETING, PA 19462 Andrea J. Bullock, Esquire Direct #(61o) 276-4963 Andrea_J_Bullock@Progressive.com Facsimile #(866) 842-1482 July 16, 2014 Via Fax 717-796-3600 Only R. Mark Thomas, Esquire R. Mark Thomas Law Practice 101 S. Market Street Mechanicsburg, PA 17055 SALARIED EMPLOYEES OF PROGRESSIVE CASUALTY INSURANCE COMPANY RE: Armada v. Abel Cumberland County Court of Common Pleas No. 2014-2532 File No. 124118534-001 Dear Counsel: Please allow this correspondence to serve as a follow-up to my previous letter wherein I enclosed Interrogatories and a Request for Production of Documents addressed to your client. To date, I have not received your client's responses. Please forward your client's discovery responses within ten days from the date of this letter, or I will file a motion to compel. Thank you for your anticipated cooperation with regard to this matter. Very truly yours, /s/ Andrea J. Bullock, Esquire AJB/bea ANTHONY M. ARMADA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. TAYLOR A. ABEL Plaintiff Defendant : CIVIL ACTION at LAW : Civil No. 2014-2532 r -G :a r r` -0 rr7 U ` GC; PETITION TO WITHDRAW AS COUNSEL AND NOW, comes counsel for the Plaintiff, R. Mark Thomas, Esquire, and files this Petition for withdrawal of his appearance as counsel for the Plaintiff in the above -captioned matter, and in support thereof, respectfully represents: 1. Plaintiff, Anthony M. Armada is an adult individual who resides at 1 Oak Drive, Hurricane, WV 25526. 2. The Defendant, Taylor A. Abel is represented by Andrea J. Bullock, Esq., whose office is located at 5165 Campus Dr., Suite, 200, Plymouth Meeting, PA 19462. 3. On or about April 25, 2012, Plaintiff claims that he suffered injuries as a result of a car accident negligently caused by the Defendant. The accident occurred in Cumberland County, Pennsylvania. 4. On or about April 21, 2014, Plaintiff's father, an attorney who practices in the state of West Virginia, contacted Petitioner and requested legal assistance in pursuing the Plaintiff's claim for personal injury. 5. Out of professional courtesy and reliance upon representations made by Plaintiff's father, Petitioner filed a Writ of Summons to prevent the statute of limitations from expiring. 6. Subsequently, pursuant to a Rule to file Complaint, Petitioner filed a Complaint in this matter. 7. Counsel for the Defendant has requested Discovery in the form of Interrogatories and has also scheduled a Deposition of the Plaintiff to take place in October. 8. Despite requests from Petitioner to actually meet with Plaintiff to go over liability and potential damages, Petitioner has yet to meet with the client. 9. Despite requests by Petitioner for the Discovery responses, the Petitioner has yet to receive the answers to the Interrogatories posed by defense counsel. 10. Defense counsel following numerous efforts to obtain Discovery, has now filed a Motion to Compel Discovery with the court and we are currently awaiting an Order from the court regarding the Motion to Compel. 11. Under the terms of the Fee Agreement, a copy of which is attached hereto as Petitioner's Exhibit A, Petitioner reserved the right to withdraw from this case and withdraw as counsel for the Plaintiff if counsel has reason to believe that the case lacks merit. 12. Although liability would appear to be clear on the part of the Defendant, damages are much less clear and Plaintiff has not provided counsel with sufficient information within which to formulate an opinion as to the extent of Plaintiff s damages, if any. 13. Under the Pennsylvania Rules of Professional Conduct No. 1.16, a lawyer may petition to withdraw from representing a client if: (a) withdraw can be accomplished without material adverse affect on the interest of the client; (b) the client fails substantially to fulfill an obligation to the lawyer regarding the lawyer's services and has been given reasonable warning that the lawyer will withdraw unless the obligation is fulfilled; 14. At this stage of the proceedings, withdraw of current counsel would not have a prejudicial or adverse effect on the interest of the client. 15. Petitioner has on several occasions made requests to meet with the Plaintiff, to have Plaintiff provide counsel with information concerning the Plaintiffs' injuries in order to comply with the defense Discovery request, and Plaintiff has failed to cooperate with counsel in this regard. WHEREFORE, Petitioner, R. Mark Thomas, Esquire, prays that this Honorable Court will enter a Rule upon the Plaintiff to show cause, if any, as to why counsel should not be allowed to terminate his representation of Plaintiff. Respectfully submitted, R. Mark Thomas, Esquire Attorney No. 41301 101 South Market Street Mechanicsburg, PA 17055 Telephone: 717-796-2100 Attorney for Plaintiff CERTIFICATE OF SERVICE I, R. Mark Thomas, hereby certify that a true and correct copy of the within Petition to Withdraw as Counsel was served on the following individuals by placing the same in the United States mail at Mechanicsburg, Pennsylvania, first class postage prepaid, on the fday of September, 2014, and addressed as follows: Andrea J. Bullock, Esquire Law Offices of Hubshman, Flood & Bullock 5165 Campus Drive, Suite, 200 Plymouth Meeting, PA 19462 Anthony M. Armada 1 Oak Drive Hurricane, WV 25526 DATED: � 25—, 2014 R. Mark homas, Esquire 4,0 CONTINGENT FEE AGREEMENT The undersigned hereby retains and employs the Law Office of R. Mark Thomas, Esquire, as counsel to institute suit, adjust or settle claims or actions as he deems advisable for the recovery of damages with regard to the above captioned matter, hereby givina the said attorney the right to take all legal steps to enforce said claims. It is also hereby understood and aareed that following investigation and evaluation of the undersigned client's case, R. Mark Thomas, Esquire, reserves the right to withdraw his representation of the client if, in his legal opinion, the case lacks legal and/or factual merit. It is further understood and agreed that client reserves the right to terminate the services of the Law Office of R. Mark Thomas, Esquire, as counsel, provided the client reimburses the Law Office of R. Mark Thomas, Esquire for all costs and expenditures that have been advanced or prepaid by counsel. Tn Esquire, follows: CONTINGENT FEE consideration of services rendered by R. Mark Thomas, the terms of this Contingent Fee Agreement are as (a) In the event of settlement before the filing of suit by the attorney, the attorney shall retain percent of any sums received from any verdict or settlement. (b) In the event of settlement or verdict after seit has been filed, the attorney shall retain L,ca percent of any sums received from any verdict or settlement. (c) It is hereby understood and agreed that if any of the claimants are minors or decedent's estates, such claim is subject to the approval of the Court. COSTS AND EXPENSES (a) It is hereby understood and agreed that all expenses incident to the investigation, institution, prosecution and trial of the case shall be borne by the undersigned client. (b) If costs are required to be advanced by the attorney to investigate, institute, prosecute or facilitate settlement or trial, it is hereby understood and agreed that all advanced costs will be reimbursed by the undersigned client. (c) Any sums due and owing to physicians, hospitals, nurses, or other professional services rendered as a result of this case shall be deducted and paid by the undersigned client, if applicable. SHOULD NO MONEY BE RECOVMED BY SUIT OR SETTLEMENT, THE ATTORNEY HAS NO CLAIM AGAINST THE UNDERSIGNED CLIENT FOR ANY SERVICES RENDERED, EXCEPT FOR TEE RECOVERY OF ANT COSTS ADVANCED BY TEE ATTORNEY ON CLIENT'S BEHALF. hereby acknowledge receipt of aduplicate original of this Agreement. Dqe2,2o/' i11- c.„ Anthony Armada v. Taylor Abel : Court of Common Pleas : Cumberland County : 2014-2532 s4 ORDER AND NOW, this ,6 day of , 2014, upon consideration of Defendant's Motion to Compel Responses to Discovery Requests Addressed to Plaintiff, Anthony Armada, it is hereby ORDERED that the Plaintiff shall provide complete and verified answers to Defendant's Interrogatories and complete responses to Request for Production of Documents within twenty (20) days of the date of this Order. BY THE COURT: 'es fiLuAR.1. 194 • fittidc: ilkoirtb4 04-IAf +• us' gAZSAY J. LT Law Offices of Hubshman, Flood&Bullock rkt �� By:Joseph A.Juliana,Esquire r f C ' Attorney ID #59523 i'1]/i1 5165 Campus Drive,Suite 200 Attorney for Defendant, -2 1i, Plymouth Meeting,PA 19462 Taylor A.Abel ill)- Telephone#(610) 276-4979 j osephjuliana@progressive.com Our File#124118534-001 Anthony Armada : Court of Common Pleas •. Cumberland County v. • Taylor Abel • •. 2014-2532 PRAECIPE FOR ENTRY/WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Defendant, Taylor A. Abel, in the above-captioned matter. Law Offices of Hubshman, Flood&Bullock By: j,Lc1fr — Josep A. Ju ana, squire Attorney for Defen ant TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of Defendant, Taylor A. Abel, in the above-captioned matter. Law Offices of Hubshman, Flood&Bullock B 1 Y Andrea J. Bullock, Esquire Attorney for Defendant ANTHONY M. ARMADA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff : CIVIL ACTION at LAW : Civil No. 2014-2532 cD TAYLOR A. ABEL �_ — ^ • cr=rY N) Defendant ' -c r RULE Aod AND NOW, this2 day of a�� , 2014, a Rule is issued upon the Plaintiff and counsel for the Defendant to show cause, if any, as to why the relief requested by Petitioner should not be granted. Rule returnable within k, days of service of this Rule upon Plaintiffs. Service of the Rule may be by personal service or First class mail, postage pre-paid. By the Court, J. cc: R. Mark Thomas, Esquire ,ndrea J. Bullock, Esq., Law Offices of Hubshman, Flood& Bullock, 5165 Campus give, Suite, 200, Plymouth Meeting, PA 19462 thony M. Armada, 1 Oak Drive, Hurricane, WV 25526 Pal l�£S Ll ) CI :Yap y I r9 Law Offices of Hubshman, Flood & Bullock By: Joseph A. Juliana, Esquire Attorney ID #59523 5165 Campus Drive, Suite 200 Plymouth Meeting, PA 19462 Telephone #(610) 276-4979 Our File #124118534-001 Attorney for Defendant, Taylor A. Abel CIF iollioc CUM 'iSERI YLvAN Anthony Armada : Court of Common Pleas : Cumberland County V. Taylor Abel : 2014-2532 CERTIFICATE OF SERVICE I, Joseph A. Juliana, attorney for Defendant, Taylor A. Abel, hereby certify that I caused a true and correct copy of Court's Order dated September 26, 2014 to be mailed this date by First Class, U.S. Mail, postage prepaid, to the following: Date: 10/9/14 R. Mark Thomas, Esquire R. Mark Thomas Law Practice 101 S. Market Street Mechanicsburg, PA 17055 (717) 796-2100 Law Offices of Hubshman, Flood & Bullock By: Joseph A. Juliana, Esquire Attorney for Defendant ANTHONY M. ARMADA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : CIVIL ACTION at LAW v. : Civil No. 2014-2532 TAYLOR A. ABEL • Defendant • PETITION TO MAKE RULE ABSOLUTE rn rri co � D <7-7 cJ AND NOW, comes R. Mark Thomas, Esquire, and files this Petition to Make Rule Absolute with regard to the previously filed Petition to Withdraw Appearance and in support thereof respectfully represents: 1. On September 25, 2014, your Petitioner, R. Mark Thomas, Esquire, filed a petition to withdraw his appearance as counsel of record for the Plaintiff, Antony M. Armada, under the above -captioned case number. (A copy of the Petition to Withdraw Appearance is attached hereto as Exhibit "A" and is incorporated herein as if set forth at length.) 2. On October 2, 2014, this Court issued a Rule upon the Plaintiff and the Defendant to show cause, if any, as to why Petitioner should not be allowed to withdraw his appearance as counsel. The Rule was returnable within twenty (20) days of service of this Rule. (A copy of the Rule is attached here to as Exhibit "B and is incorporated herein as if set forth at length.) 3. It has been more than twenty (20) days since the service of this Rule upon opposing counsel, Joseph A. Juliana, Esquire, and the Plaintiff and neither of them has filed an answer to the Rule. WHEREFORE, the Petitioner prays that this Honorable Court will grant this Petition to Make Rule Absolute and sign the Order attached hereto granting the withdraw of appearance of R. Mark Thomas, Esquire, as counsel for the Plaintiff. Respectfully submitted, R. Mark Thomas, Esquire ID# 41301 101 S. Market Street Mechanicsburg, PA 17055 (717) 796-2100 ANTHONY M. ARMADA v. TAYLOR A. ABEL Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION at LAW : CiviI No. 2014-2532 C) rn �f-1 • <� y c v1 PETITION TO WITHDRAW AS COUNSEL AND NOW, comes counsel for the Plaintiff, R. Mark Thomas, Esquire, and files this Petition for withdrawal of his appearance as counsel for the Plaintiff in the above -captioned matter, and in support thereof, respectfully represents: 1. Plaintiff, Anthony M. Armada is an adult individual who resides at 1 Oak Drive, Hurricane, WV 25526. 2. The Defendant, Taylor A. Abel is represented by Andrea J. Bullock, Esq., whose office is located at 5165 Campus Dr., Suite, 200, Plymouth Meeting, PA 19462. 3. On or about April 25, 2012, Plaintiff claims that he suffered injuries as a result of a car accident negligently caused by the Defendant. The accident occurred in Cumberland County, Pennsylvania. 4. On or about April 21, 2014, Plaintiff's father, an attorney who practices in the state of West Virginia, contacted Petitioner and requested legal assistance in pursuing the Plaintiff's claim for personal injury. ExII;LtiAti 5. Out of professional courtesy and reliance upon representations made by Plaintiffs father, Petitioner filed a Writ of Summons to prevent the statute of limitations from expiring. 6. Subsequently, pursuant to a Rule to file Complaint, Petitioner filed a Complaint in this matter. 7. Counsel for the Defendant has requested Discovery in the form of Interrogatories and has also scheduled a Deposition of the Plaintiff to take place in October. 8. Despite requests from Petitioner to actually meet with Plaintiff to go over liability and potential damages, Petitioner has yet to meet with the client. 9. Despite requests by Petitioner for the Discovery responses, the Petitioner has yet to receive the answers to the Interrogatories posed by defense counsel. 10. Defense counsel following numerous efforts to obtain Discovery, has now filed a Motion to Compel Discovery with the court and we are currently awaiting an Order from the court regarding the Motion to Compel. 11. Under the terms of the Fee Agreement, a copy of which is attached hereto as Petitioner's Exhibit A, Petitioner reserved the right to withdraw from this case and withdraw as counsel for the Plaintiff if counsel has reason to believe that the case lacks merit. 12. Although liability would appear to be clear on the part of the Defendant, damages are much less clear and Plaintiff has not provided counsel with sufficient information within which to formulate an opinion as to the extent of Plaintiff's damages, if any. 13. Under the Pennsylvania Rules of Professional Conduct No. 1.16, a lawyer may petition to withdraw from representing a client if: (a) withdraw can be accomplished without material adverse affect on the interest of the client; (b) the client fails substantially to fulfill an obligation to the lawyer regarding the Iawyer's services and has been given reasonable warning that the lawyer will withdraw unless the obligation is fulfilled; 14. At this stage of the proceedings, withdraw of current counsel would not have a prejudicial or adverse effect on the interest of the client. 15. Petitioner has on several occasions made requests to meet with the Plaintiff, to have Plaintiff provide counsel with information concerning the Plaintiffs' injuries in order to comply with the defense Discovery request, and Plaintiff has failed to cooperate with counsel in this regard. WHEREFORE, Petitioner, R. Mark Thomas, Esquire, prays that this Honorable Court will enter a Rule upon the Plaintiff to show cause, if any, as to why counsel should not be allowed to terminate his representation of Plaintiff. Respectfully submitted, R. Mark Thomas, Esquire Attorney No. 41301 101 South Market Street Mechanicsburg, PA 17055 Telephone: 717-796-2100 Attorney for Plaintiff CERTIFICATE OF SERVICE 1, R. Mark Thomas, hereby certify that a true and correct copy of the within Petition to Withdraw as Counsel was served on the following individuals by placing the same in the United States mail at Mechanicsburg, Pennsylvania, first class postage prepaid, on thegrday of September, 2014, and addressed as follows: Andrea J. Bullock, Esquire Law Offices of Hubshman, Flood & Bullock 5165 Campus Drive, Suite, 200 Plymouth Meeting, PA 19462 Anthony M. Armada 1 Oak Drive Hurricane, WV 25526 DATED: , 2014 R. Mark o as, Esquire CONTINGENT FEE AGREEMENT The undersigned hereby retains and employs the Law Office of R. Mark Thomas, Esauire, as counsel to institute suit, adjust or settle claims or actions as he deems advisable for the recovery of damages with regard to the above captioned matter, hereby giving the said attorney the right to take all legal steps to enforce said claims. It is also hereby understood and agreed that following investigation and evaluation of the undersigned client's case, R. Mark Thomas, Esquire, reserves the right to withdraw his representation of the client if, in his legal opinion, the case lacks legal and/or factual merit. It is further understood and agreed that client reserves the right to terminate the services of the Law Office of R. Mark Thomas, Esquire, as counsel, provided the client reimburses the Law Office of R. Mark Thomas, Esquire for all costs and expenditures that have been advanced or prepaid by counsel. CONTINGENT FEE in consideration of services rendered by R. Mark Thomas, Esquire, the terms of this Contingent Fee Agreement are as follows: (a) In the event of settlement before the filing of suit by the attorney, the attorney shall retain percent of any sums received from any verdict or settlement. (b) In the event of settlement .or verdict after suit has been filed, the attorney shall retain percent of any sums received from any verdict or settlement. (c) It is hereby understood and agreed that if any of the claimants are minors or decedent's estates, such claim is subject to the approval of the Court. COSTS AND EXPENSES (a) It is hereby understood and agreed that all expenses incident to the investigation, institution, prosecution and trial of the case shall be borne by the undersigned client. (b) If costs are required to be advanced by the attorney to investigate, institute, prosecute or facilitate settlement .or trial, it is hereby understood and agreed that all advanced costs will be reimbursed by the undersigned client. (c) Any sums due and owing to physicians, hospitals, nurses, or other professional services rendered as a result of this case shall be deducted and paid by the undersigned client, if applicable. SHOULD NO MONEY BE RECOVERED BY SUIT OR SETTLEMENT, THE ATTORNEY HAS NO CLAIM AGAINST THE UNDERSIGNED CLIENT FOR ANY SERVICES RENDERED, EXCEPT FOR THE RECOVERY OF ANT COSTS ADVANCED BY TEE ATTORNEY ON CLIENT'S BEHALF. hereby acknowledge receipt of a duplicate original of this Agreement. Date D t- A /. tfealL 2014( ANTHONY M. ARMADA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA • v. TAYLOR A. ABEL Plaintiff Defendant : CIVIL ACTION at LAW : Civil No. 2014-2532 RULE 1 AND NOW, thisgaAJellay of od,r)17f7t 42014, a Rule is issued upon the Plaintiff and counsel for the Defendant to show cause, if any, as to why the relief requested by Petitioner should not be granted. Rule returnable within c2 0 days of service of this Rule upon Plaintiffs. Service of the Rule may be by personal service or First class mail, postage pre -paid. By the Court, cc: R. Mark Thomas, Esquire Andrea J. Bullock, Esq., Law Offices of Hubshman, Flood & Bul ock, 5165 Campus Drive, Suite, 200, Plymouth Meeting, PA 19462 Anthony M. Armada, 1 Oak Drive, Hurricane, WV 25526 it '1 CERTIFICATE OF SERVICE I, R. Mark Thomas, hereby certify that a true and correct copy of the within Petition to Petition to Make Rule Absolute was served on the following individuals by placing the same in the United States mail at Mechanicsburg, Pennsylvania, first class postage prepaid, on the day of November, 2014, and addressed as follows: Joseph A. Juliana, Esquire Law Offices of Hubshman, Flood & Bullock 5165 Campus Drive, Suite, 200 Plymouth Meeting, PA 19462 Anthony M. Armada 1 Oak Drive Hurricane, WV 25526 DATED: /14.v. , 2014 R. Mark Thomas, Esquire ANTHONY M. ARMADA v. TAYLOR A. ABEL Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSIVA$IA4cD -s-, 'orf: U) O C-1 : CIVIL ACTION at LAW ma(-.--.) : Civil No. 2014-2532 • ORDER AND NOW, this10 V day of November, 2014, upon p consideration of the Petition to Make Rule Absolute, the Petition is granted, and R. Mark Thomas, Esquire, is hereby permitted to withdraw his appearance as counsel of record for the above -captioned Plaintiff. By the Court, ccri-R. Mark Thomas, Esquire, 101 S. Market Street, Mechanicsburg, PA 17055 i Joseph A. Juliana, Esq., Law Offices of Hubshman, Flood & Bullock, 5165 Campus Drive, Suite, 200, Plymouth Meeting, PA 19462 Anthony M. Armada, 1 Oak Drive, Hurricane, WV 25526 e2 pi`'e6: ri44.1 /e/ //Lel //y' ANTHONY M. ARMADA : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : CIVIL ACTION at LAW V. : Civil No. 2014-2532 TAYLOR A. ABEL 4-= _L— rnJ c =1"1 rn Defendant (/) r- i\D r - PRAECIPE TO WITHDRAW APPEARANCE >5_ L.) CD TO THE PROTHONOTARY: Pursuant to the Court Order dated November 20, 2014 kindly enter this Praecipe to Withdraw my Appearance as counsel for the Plaintiffs in the above -captioned matter. Respectfully submitted, R. Mark Thomas, Esquire Attorney No. 41301 101 South Market Street Mechanicsburg, PA 17055 Telephone: 717-796-2100 CERTIFICATE OF SERVICE I, R. Mark Thomas, hereby certify that a true and correct copy of the within Praecipe to Withdraw Appearance was served on the following individuals by placing the same in the United States mail at Mechanicsburg, Pennsylvania, first class postage prepaid, on the 2nd day of December, 2014, and addressed as follows: Joseph A. Juliana, Esquire Law Offices of Hubshman, Flood & Bullock 5165 Campus Drive, Suite, 200 Plymouth Meeting, PA 19462 Anthony M. Armada 1 Oak Drive Hurricane, WV 25526 DATED: a9C. oZ , 2014 R. Mark Thomas, Esquire 1 ANTHONY M. ARMADA v. TAYLOR A. ABEL Plaintiff Defendant h AND NOW, this.V day of November, 2014, upon consideration of the Petition to : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSVVAANIA:2: rri 'c rn • : CIVIL ACTION at LAW : Civil No. 2014-2532 ORDER Make Rule Absolute, the Petition is granted, and R. Mark Thomas, Esquire, is hereby permitted to withdraw his appearance as counsel of record for the above -captioned Plaintiff. By the Court, cc: R. Mark Thomas, Esquire, 101 S. Market Street, Mechanicsburg, PA 17055 i Joseph A. Juliana, Esq., Law Offices of Hubshman, Flood & Bullock, 5165 Campus Drive, Suite, 200, Plymouth Meeting, PA 19462 Anthony M. Armada, 1 Oak Drive, Hurricane, WV 25526