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HomeMy WebLinkAbout14-3564 Supreme Cou U, ennsylvania Cour f.Cdinmo leas For Prothonotary Use Only: Cll 1lZb04 Vei'asll et Docket No: ` CUM6 RLQN County q,, -3 s-b The infortnalion collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S El Complaint � Writ of Summons ? Petition Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Brenda Charest and David Charest Corey Limongello and Corey Ryan Limongello T Dollar Amount Requested: Owithin arbitration limits I Are money damages requested? x] Yes 0 No (check one) xl outside arbitration limits O N Is this a Class Action Suit? El Yes Excil No Is this an MDJAppeal? X; Yes M No A Name of Plaintiff/Appellant's Attorney: John M. Dodig, Esquire Check here if you have no attorney(are a Self-Represented [Pro Se] 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 `--1 Intentional 0 Buyer Plaintiff Administrative Agencies E] Malicious Prosecution 0 Debt Collection:Credit Card ( Board of Assessment x Motor Vehicle [3 Debt Collection: Other Board of Elections 0 Nuisance _ Dept.of Transportation S Premises Liability ❑ Statutory Appeal: Other =i Product Liability(does not include E mass tort) � Employment Dispute: Slander/Libel/Defamation Discrimination C Other: J Employment Dispute:Other 0 Zoning Board T Other: I J Other: O MASS TORT _ 0 Asbestos _ N E] Tobacco 0 Toxic Tort-DES 0 Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS E] Toxic Waste 0 Other: 0 Ejectment 0 Common Law/Statutory Arbitration B 0 Eminent Domain/Condemnation 0 Declaratory Judgment 0 Ground Rent n Mandamus Landlord/Tenant Dispute Non-Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure: Commercial 0 Quo Warranto 0 Dental 0 Partition 0 Replevin Legal Quiet Title 0 Other: 0 Medical ❑ Other: Other Professional: Updated 1/1/2011 NOTICE Pennsylvania Rule of Civil Procedure 205.5. (Cover Sheet) provides, in part: Rule 205.5. Cover Sheet (a)(1) This rule shall apply to all actions governed by the rules of civil procedure except the following: (i) actions pursuant to the Protection from Abuse Act, Rules 1901 et seq. (ii) actions for support, Rules 1910.1 et seq. (iii) actions for custody, partial custody and visitation of minor children, Rules 1915.1 et seq. (iv) actions for divorce or annulment of marriage, Rules 1920.1 et seq. (v) actions in domestic relations generally, including paternity actions, Rules 1930.1 et seq. (vi) voluntary mediation in custody actions, Rules 1940.1 et seq. (2) At the commencement of any action, the party initiating the action shall complete the cover sheet set forth in subdivision (e) and file it with the prothonotary. (b) The prothonotary shall not accept a filing commencing an action without a completed cover sheet. (c) The prothonotary shall assist a party appearing pro se in the completion of the form. (d) A judicial district which has implemented,an electronic filing system pursuant to Rule 205.4 and has promulgated those procedures pursuant to Rule 239.9 shall be exempt from the provisions of this rule. (e) The Court Administrator of Pennsylvania, in conjunction with the Civil Procedural Rules Committee, shall design and publish the cover sheet. The latest version of the form shall be published on the website of the Administrative Office of Pennsylvania Courts at www.pacourts.us. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Brenda Charest and David Charest Plaintiff t Vs No. f T1 rr-i U,r Corey Limongello and Corey Ryan Limongello 1 w ` ) , Defendant "CD xf _ } C3 1. NOTICE TO DEFEND 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 AN 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 M 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. i THIS OFFICE CAN PROVIDE YOU WITH 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 REDUECED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOL"TH BEDFORD STREET CARLISLE,PA 17013 ,r 1-800-990-9108 G �GI�. 717-249-3166 �' Feldman, Shepherd, Wohlgelernter Tanner, Weinstock & Dodig By: John M. Dodig, Esquire/Jason A. Daria, Esquire I.D. No. 51092/73360 1845 Walnut Street 21st Floor Philadelphia, PA 19103 (215) 567-8300 Attorneys for Plaintiffs Brenda Charest COURT OF COMMON PLEAS 271 Buttonwood Lane CUMBERLAND COUNTY Cinnaminson, NJ 08077 And David Charest 271 Buttonwood Lane Cinnaminson, NJ 08077 NO. V. Corey Limongello 2207 Jane Street Pittsburgh, PA 15203 And Corey Ryan Limongello 2207 Jane Street Pittsburgh, PA 15203 COMPLAINT - CIVIL ACTION 2V - MOTOR VEHICLE ACCIDENT COUNT PLAINTIFF, BRENDA CHAREST V. ALL DEFENDANTS 1. Plaintiffs, Brenda Charest and David Charest, are adult individuals who reside at 271 Buttonwood Lane, Cinnaminson, New Jersey 08077. 2. Defendant, Corey Limongello, is an adult individual who resides at 2207 1 Jane Street, Pittsburgh, Pennsylvania 15203. 3. Defendant, Corey Ryan Limongello, is an adult individual who resides at 2207 Jane Street, Pittsburgh, Pennsylvania 15203. 4. On June 24, 2012, at approximately 5:00 p.m., Plaintiff, David Charest, was the operator of a motor vehicle traveling west on Harrisburg Pike in Middlesex Township, Cumberland County, Pennsylvania when his vehicle was struck in the rear by the motor vehicle being operated by the Defendant, Corey Limongello and owned by the Defendant, Corey Ryan Limongello. Plaintiff, Brenda Charest, was a passenger in the vehicle being operated by Plaintiff, David Charest. As a result of the collision, Plaintiffs sustained serious and permanent injuries more specifically set forth below. 5. The accident as aforesaid was caused by the carelessness, recklessness and negligence of the Defendants and was in no manner whatsoever due to any act or failure to act on the part of the Plaintiffs. 6. The carelessness, recklessness and negligence of the Defendants included the following: a. Operating the said motor vehicle at a high and excessive rate of speed under the circumstances; b. failure to keep a proper lookout ahead; C. failure to have said motor vehicle under such control as to be able to stop within the assured clear distance ahead; d. failure to make proper observations of traffic upon the roadway; e. failure to properly use the brakes; f. being otherwise negligent under the circumstances; 2 g. operating a motor vehicle in careless disregard for the safety of persons or property in violation of 75 Pa.C.S.A. §3714; and h. careless and reckless driving. 7. As a direct and proximate result of the carelessness, recklessness and negligence of the Defendants as aforesaid, Plaintiff, Brenda Charest, sustained severe and permanent injuries that include, but are not limited to triceps rupture of right elbow requiring multiple surgeries, shoulder, neck and back, as well as damage to her nerves and nervous system. 8. All of the aforesaid injuries are permanent and have imposed a serious impairment of a body function upon the Plaintiff and have caused, and in the future will cause the Plaintiff great pain and suffering and a serious impairment of bodily function. 9. As a further result of this accident and by reason of the injuries sustained, Plaintiff has in the past been obligated to receive and undergo medical attention and care and to expend various sums of money and/or incur various expenses for the injuries she has suffered, and she may in the future continue to be obliged to expend such sums or to incur such expenses which may exceed the amount recoverable under New Jersey motor vehicle laws. 10. As a further result of this accident and by reason of the injuries sustained, Plaintiff has sustained an impairment of her earning capacity and power. 11. As a further result of this accident and by reason of the injuries suffered, Plaintiff has in the past suffered and may in the future continue to suffer great pain, agony, mental anguish, embarrassment and humiliation, and has in the past been hindered and -3- may in the future continue to be hindered from attending to her daily duties, functions and occupation, to her great detriment and loss. 12. As a further direct and proximate result of the carelessness, recklessness and negligence of the Defendants, Plaintiff has suffered injuries which have caused her physical and mental impairment, preventing her from performing all or substantially all of the material acts and duties which constitute her usual and customary daily activities, constituting a loss of the enjoyment of the ordinary pleasures of life. 13. The negligence and recklessness of the Defendants as stated herein was the proximate cause or a substantial factor in causing the injuries and damages sustained by the Plaintiff. 14. Plaintiff is subject to the full tort threshold and is entitled to recover non-economic damages for her injuries. WHEREFORE, Plaintiff, Brenda Charest, demands judgment against the Defendants in a sum in excess of Fifty Thousand ($50,000.00) Dollars, together with interest and costs. COUNT II DAVID CHAREST V. DEFENDANTS 15. Plaintiff incorporates by reference paragraphs 1 through 14 as though same were fully set forth herein at length. 16. The accident as aforesaid was caused by the carelessness, recklessness and negligence of the Defendants and was in no manner whatsoever due to any act or failure to act on the part of the Plaintiffs. 17. The carelessness, recklessness and negligence of the Defendants -4- q included the following: a. Operating the said motor vehicle at a high and excessive rate of speed under the circumstances; b. failure to keep a proper lookout ahead; C. failure to have said motor vehicle under such control as to be able to stop within the assured clear distance ahead; d. failure to make proper observations of traffic upon the roadway; e. failure to properly use the brakes; f. being otherwise negligent under the circumstances; g. operating a motor vehicle in careless disregard for the safety of persons or property in violation of 75 Pa.C.S.A. §3714; and h. careless and reckless driving. 18. As a direct and proximate result of the carelessness, recklessness and negligence of the Defendants as aforesaid, Plaintiff, David Charest, sustained severe and permanent injuries that include, but are not limited to T7-T8 disc protrusion, T8-T9 annular disc bulging, T9-T10 left paracentral shallow disc protrusion, T10-T11 left lateral recess disc protrusion, C3-C4 disc bulging, C4-05 annular disc bulging, C5-C6 disc protrusion, C6-C7 disc bulging, C7-T1 disc bulging, headaches, and damage to his nerves and nervous system. 19. All of the aforesaid injuries are permanent and have imposed a serious impairment of a body function upon the Plaintiff and have caused, and in the future will cause the Plaintiff great pain and suffering and a serious impairment of bodily function. 20. As a'further result of this accident and by reason of the injuries sustained, Plaintiff has in the past been obligated to receive and undergo medical attention and care -5- and to expend various sums of money and/or incur various expenses for the injuries he has suffered, and he may in the future continue to be obliged to expend such sums or to incur such expenses which may exceed the amount recoverable under New Jersey motor vehicle laws. 21. As a further result of this accident and by reason of the injuries sustained, Plaintiff has sustained an impairment of his earning capacity and power. 22. As a further result of this accident and by reason of the injuries suffered, Plaintiff has in the past suffered and may in the future continue to suffer great pain, agony, mental anguish, embarrassment and humiliation, and has in the past been hindered and may in the future continue to be hindered from attending to his daily duties, functions and occupation, to his great detriment and loss. 23. As a further direct and proximate result of the carelessness, recklessness and negligence of the Defendants, Plaintiff has suffered injuries which have caused him physical and mental impairment, preventing him from performing all or substantially all of the material acts and duties which constitute his usual and customary daily activities, constituting a loss of the enjoyment of the ordinary pleasures of life. 24. The negligence and recklessness of the Defendants as stated herein was the proximate cause or a substantial factor in causing the injuries and damages sustained by the Plaintiff. 25. Plaintiff is subject to the full tort threshold and is entitled to recover non-economic damages for his injuries. -6- WHEREFORE, Plaintiff, David Charest, demands judgment against the Defendants in a sum in excess of Fifty Thousand ($50,000.00) Dollars, together with interest and costs. COUNT III BRENDA CHAREST V. DEFENDANTS 26. Plaintiff incorporates by reference paragraphs 1 through 25 as though same were fully set forth herein at length. 27. Plaintiff, Brenda Charest, is the wife of Plaintiff, David Charest. 28. As a result of Defendants' negligence and carelessness, as set forth above, Plaintiff, Brenda Charest, has been deprived of her husband's consortium, care, services, comfort, society, affection and support. WHEREFORE, Plaintiff, Brenda Charest, demands judgment in her favor and against the Defendants for damages in an amount in excess of$50,000.00. COUNT IV DAVID CHAREST V. DEFENDANTS 29. Plaintiff incorporates by reference paragraphs 1 through 28 as though same were fully set forth herein at length. 30. Plaintiff, David Charest, is the husband of Plaintiff, Brenda Charest. 31. As a result of Defendants' negligence and carelessness, as set forth above, Plaintiff, David Charest, has been deprived of his wife's consortium, care, services, comfort, society, affection and support. WHEREFORE, Plaintiff, David Charest, demands judgment in his favor and against the Defendants for damages in an amount in excess of $50,000.00. -7- a e COUNT V PLAINTIFFS V. ALL DEFENDANTS RECKLESSNESS/PUNITIVE DAMAGES 32. Paragraphs 1 through 31 above are incorporated herein by reference. 33. The incident, injuries, and damages described herein were caused by the recklessness of the Defendants, individually, jointly and/or severally, by and/or through their agents, workmen, servants and/or employees, both generally and in the following particular respects: a. Recklessly looking down at his GPS at the time of the accident. b. Driving recklessly in willful and wanton disregard for the safety of persons, in violation of 75 Pa. C.S.A. § 3736; C. Recklessly causing injury of another person while failing to comply with the laws of the Commonwealth of Pennsylvania concerning the operation or use of a vehicle or the regulation of traffic, in violation of 75 Pa. C.S.A. § 3732; d. Recklessly violating the acts of the General Assembly of the Commonwealth of Pennsylvania concerning the operation of vehicles, including the Pennsylvania Motor Vehicle Code and those set forth above; and e. Recklessly violating and failing to adhere to applicable statutes, ordinances, rules, regulations and standards governing or relating to the safe operation of vehicles, including those set forth above. 34. Defendants' acts and/or failures to act under the circumstances of this case were outrageous in that Defendants' conduct amounted to a reckless indifference to the safety of others. 35. Defendants knew and had reason to know that by using a GPS and taking his eyes off of the road that he created a high degree of risk of physical harm to another. -8- 36. Defendants knew and should have known his actions were dangerous and unsafe for those lawfully upon the highway. 37. Despite this knowledge, Defendants willfully, wantonly, deliberately, recklessly, and unlawfully proceeded to act and/or failed to act, as set forth specifically above, in reckless and conscious disregard of or with indifference to the safety and well-being of others, including Plaintiffs. 38. Defendants' willful, wanton, deliberate, reckless, and unlawful actions and/or inactions, as set forth above, increased the risk of harm and were substantial factors in causing the injuries to Plaintiffs, as well as damages as set forth more fully above. 39. Defendant, Corey Ryan Limongello, is also vicariously liable for the outrageous, willful, wanton, deliberate, reckless and unlawful conduct of his employee and agent, Defendant Corey Limongello, as set forth herein. Feldman, Shepherd, Wohlgelernte , Tanner, Wei ock & odig By: N M. DODIG, ESQUIRE JASON A. DARIA, ESQUIR -9- VITRIFICATION I, Brenda Charest, hereby state that I am the Plaintiff in this action and verify that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. a Wa H -, Brenda Charest Date: o 01 VERIFICATION I, David Charest,hereby state that I am'the Plaintiff in this action and verify that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowiedge, information and belief. The undersigned understands that the Istatements therein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. lJ David Charest Date: 60 - r _' L/ Feldman, Shepherd, Wohlgelernter Tanner, Weinstock & Dodig By: John M. Dodig, Esquire/Jason A. Dania, Esquire I.D. No. 51092/73360 1845 Walnut Street 21st Floor Philadelphia, PA 19103 (215) 567-8300 Brenda Charest and David Charest v. Corey Limongello And Corey Ryan Limongello r I iiE fii p IHONQTT AI 2014 JUL -9 411 10: CUMBERLD PENNS YL V CNUNT y VANIA Attorneys for Plaintiffs : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO. 14-3564 PRAECIPE TO REINSTATE CIVIL ACTION COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Civil Action Complaint in the above -captioned matter. FELDMAN, SHEPHERD, WOHLGELERNTER, Dated: July 1, 2014 TANNER, WEINSTOCK IG JOHN M. DODIG JASON A. DA Attorneys for P IRE UIRE Feldman, Shepherd, Wohlgelernter Tanner, Weinstock & Dodig By: John M. Dodig, Esquire/Jason A. Dania, Esquire I.D. No. 51092/73360 1845 Walnut Street 21st Floor Philadelphia, PA 19103 (215) 567-8300 Brenda Charest and David Charest v. Corey Limongello And Corey Ryan Limongello -OFF R0T faFd '��'. 2014 JUL 30 PH I: Ot IBER 0 PENNS C0LJNT y A Attorneys for Plaintiffs : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO. 14-3564 PRAECIPE TO REINSTATE CIVIL ACTION COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Civil Action Complaint in the above -captioned matter. FELDMAN, SHEPHERD, WOHLGELERNTER, TANNER, WEIN TOCK & DODIG BY: Dated: July 28, 2014 DODIG, ES JON A. DARIA, ES Attorneys for Plaintiffs IRE IRE \-nb, 3cR\°c Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY orFicEorTk mgRIFF ED -OFFICE OF THE PROTHONOTARY Mit JUL 31 A'PI!37 CUMBERLAND COUNTY PENNSYLVANIA Brenda Charest (et al.) vs. Corey Limongello (et al.) Case Number 2014-3564 SHERIFF'S RETURN OF SERVICE 06/13/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Corey Limongello, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the within Complaint & Notice according to law. 06/13/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Corey Ryan Limongello, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the within Complaint & Notice according to law. 07/11/2014 The Sheriff of Allegheny County, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Corey Ryan Limongello, but was unable to locate the Defendant in his bailiwick. The Allegheny County Sheriff therefore returns the within requested Complaint & Notice as "Not Served" at 2207 Jane Street, Pittsburgh, PA 15203. 07/22/2014 The Sheriff of Allegheny County, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Corey Limongello, but was unable to locate the Defendant in his bailiwick. The Allegheny County Sheriff therefore returns the within requested Complaint & Notice as "Not Served" at 2207 Jane Street, Pittsburgh, PA 15203. SHERIFF COST: $53.00 SO ANSWERS, July 22, 2014 RONNY R ANDERSON, SHERIFF (c} CountySuite Sheriff, Teleosoft. Inc. EXP: 07/11/2014 0 N Ronny R Anderson Sheriff Jody S Smith Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY 25Z ColObett OFFICE OF THE SHERIFF I'll') VII y�M Richard W Stewart Solicitor Brenda Charest (et al.) vs. Corey Limongello (et al.) Case Number 2014-3564 [Service Details: Category: Manner: Notes: SERVICE COVER SHEET Civil Action - Complaint & Notice Deputize Zone: Expires: 07/11720114H/ Warrant: Serve To: Name: rimary ddress: - Phone: 1-= w w • Alternate - Address: cow Q Phone: I,- 0 •0 N N 2014-3564 LIMONGELLO, COREY RYA Corey Ryan Limongello 2207 Jane Street Pittsburgh, PA 15203 DOB: rFinal Service: Served: Personally • Adult In Charge • Posted • Other Adult In Charge: Relation: Date: Deputy: Time: Mileage: L. Attorney / Originator: Name: John M Dodig Phone: 214-567-8300 'Service Attempts: Date: Time: Mileage: Deputy: 5 6 { Notes / Special Instruct ons: r /"I'k ul'v lk A-11- cpM Now, June 13, 2014 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Allegheny County to execute service of the documents herewith and make return thereof according to law. Return To: Cumberland County Sheriffs Office One Courthouse Square Carlisle, PA 17013 fcl CountySuite Sheriff, Teleoeo,t. Inc EXP: 07/11/2014 c) 0 N N - Serve To: Ronny R Anderson Sheriff Jody S Smith Chief Deputy SHERIFF'S OFFICE OF;CUMBERLAND COUNTYEXP �/�� �a��tity of Cauiabr.N/qnb �9 eA � � OFFICE OF THE $I•.ERIFF N5M Richard W Stewart Solicitor Brenda Charest (et al.) vs. Corey Limongello (et al.) Case Number 2014-3564 SERVICE COVER SHEET [Service Details: Category: Civil Action - Complaint & Notice Manner: Notes: 2014-3564, LIMONGELLO, COREY Deputize Zone: Expires: 07/11/2014 } Warrant: j ] [Final Service: Name: Corey Limongello Primary Address: Phone: Alternate Address: Phone: 2207 Jane Street Pittsburgh, PA 15203 DOB: Served: Adult In Charge: Relation: Date: Deputy: Personally Adult In Charge • Posted • Other L Time: Mileage: Attorney / Originator: Name: LJohn M Dodig Phone: 214-567-8300 1 Service Attempts: Date: - Time: Mileage: Deputy: !Notes / Special lnstru ecu tk I+( l(N;--1- CDAA/ e-211 1 Now, June 13, 2014 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Allegheny County to execute service of the documents herewith and make return thereof according to law. Return To: Cumberland County Sheriffs Office One Courthouse Square Carlisle, PA 17013 (c) :ountySune Sheriff Teleosof. Inc. Ronny R Anderson, Sheriff Feldman, Shepherd, Wohlgelernter Tanner, Weinstock & Dodig By: John M. Dodig, Esquire/Jason A. Darla, Esquire I.D. No. 51092/73360 1845 Walnut Street 21st Floor Philadelphia, PA 19103 (215) 567-8300 Brenda Charest and David Charest v. Corey Limongello And Corey Ryan Limongello .1 r. t r t THE PRCTHCNO Lf Lalli SEP —2 AN 9• CUMBERLAND COUNTY PENNSYLVANIA Attorneys for Plaintiffs : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO. 14-3564 PRAECIPE TO REINSTATE CIVIL ACTION COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Civil Action Complaint in the above -captioned matter. FELDMAN, SHEPHERD, WOHLGELERNTER, TANNER, WEINSTOCK & DODIG BY Dated: August 29, 2014 1/1 OHN M. DODIG, ESQUIRE JASON A. DARIA, ESQUIRE Attorneys for PlaintiffS d di 41 /2-6.3T 3/.4v7s, • J- 1 Feldman, Shepherd, Wohlgelernter Tanner, Weinstock & Dodig By: John M. Dodig, Esquire/Jason A. Darla, Esquire I.D. No. 51092/73360 1845 Walnut Street 21st Floor Philadelphia, PA 19103 (215) 567-8300 Brenda Charest and David Charest v. Corey Limongello And Corey Ryan Limongello [.ILEO -OFFICE uF THE PROTHOHO TAR 201R SEP 30 AN 10: 28 CUMBERLAND COUNTY PENNSYLVANIA Attorneys for Plaintiffs : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : NO. 14-3564 PRAECIPE TO REINSTATE CIVIL ACTION COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Civil Action Complaint in the above -captioned matter. Dated: September 29, 2014 FELDMAN, SHEPHERD, WOHLGELERNTER, TANNER. EINSTOCK & DODIG M. DODIG QUIRE SON A. DARIA, ESQUIRE ttorneys for PlaintiffS eavd_ §11 ./pen) odi3_ qUg. P--.4L(ktcpsi FELDMAN SHEPHERD WOHLGELERNTER TANNER WEINSTOCK & DODIG, LLP By: John Dodig/Ezra Wohlgelernter Identification No.: 51092/35955 1845 Walnut Street, 21St Floor Philadelphia, PA 19103 (215) 567-8300 27 PH 2: 12 Attorneys f© PlaintiffsND r , , kiiINSYLVANIA BRENDA CHAREST and DAVID CHAREST, h/w v. COREY LIMONGELLO and COREY RYAN LIMONGELLO TO THE CLERK OF COURT: COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-3564 Civil ENTRY OF APPEARNACE Kindly enter my appearance as co -counsel for the plaintiffs in the above matter. Date: October 23, 2014 FELDMAN SHEPHERD WOHLGELERNTER NER WEINSTOCK DODIG, LLP EZRA GELERNTE SQUIRE FELDMAN SHEPHERD WOHLGELERNTER TANNER WEINSTOCK & DODIG, LLP By: John Dodig/Ezra Wohlgelernter Identification No.: 51092/35955 1845 Walnut Street, 21st Floor Philadelphia, PA 19103 (215) 567-8300 e f n. f Attorneys falanjjtffs� BRENDA CHAREST and DAVID CHAREST, h/w v. COREY LIMONGELLO and COREY RYAN LIMONGELLO COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-3564 Civil AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF PHILADELPHIA Ezra Wohlgelernter, Esquire, being duly sworn according to law, deposes and says that a Complaint was reinstated on September 30, 2014. On October 7, 2014, an attested copy of the reinstated Complaint was served via certified mail on defendant Corey Limongello. A copy of the signed certified mail return card is attached hereto and marked as Exhibit "A". FELDMAN, SHEPHERD, WOHLGELERNTER TANNER, EI ►� TOCK & DODIG • E WOHLGELl TER, ESQUIRE At for Plaintiffs SENDER: COMPLETE THIS SECTION • Complete Items t, 2, and 3. Also complete Item 4 N 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: CD ikA416s\tA..0 CA. (\44 (44NAAL.C.a- 1%-s-\. E. (1)e.fikAek Ce. _ • M• ail ❑ Express Mail CSle—te,KDJO`t C,.Registered 0 Return Receipt for Merchandise • .\ { "Lt� ❑ Insured Mall 0 C.O.D. 1*�� 4. Restricted Delivery? (Extra Fee) 0 Yes 7012 2210 0002 6148 0521 COMPLETE THIS SECTION ON DELIVERY A. X Sig th AAgent ❑ Addressee C. Date of Delivery !?• ,./ D. Is del = address different from item 1? • Yes If YES, enter delivery address below: ;No 2. Article Number (Transferlrom service Iabeq PS Form 3811, February 2004 Domestic Return Receipt 102595-02•M-1540 PLAINTIFF'S a EXHIBIT a