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HomeMy WebLinkAbout05-4871IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DIANE DURBOROW-GOODLING LONNIE GOODLING 107 KESTREL COURT HUMMELSTOWN, PA 17036 Plaintiff(s) & Address(es) No.(?)g = {007/ Civil Action - (XX) Law ( ) Equity HOWARD HOUSTON 421 CROGHAN DRIVE CARLISLE, PA 17103 C11oLL Defendant(s) & Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue A Writ of Summons in the above-captioned action. X Writ of Summons Shall be issued and forwarded to ( )Attorney (XX)Sheriff David H Rosenberg, Esquire 1300 Linglestown Road Signature of A orney Harrisburg, PA 17110 (717) 238-2000 Supreme Court ID No. 20569 Name/Address/Telephone No. of Attorney Date: 9/14/2005 WRIT OF SUMMONS TC '711-11E ABOVE IANIIED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS AVE COMMENC AN ACTION AGAINST YOU. Prothonotary Date: 19, ,-2y0s by ' Deputy ( ) Check here if reverse is used for additional information PROTHON. - 55 '6cJ. C`i SO: V Yl'•(' ;- ' of o ° 0 -0 r- fV LTI U SHERIFF'S RETURN - REGULAR CASE NO: 2005-04871 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GOODLING DIANE DURBOROW VS HOUSTON HOWARD HAROLD WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon HOUSTON HOWARD DEFENDANT the at 1433:00 HOURS, on the 28th day of September, 2005 at 421 CROGHAN DRIVE SLE. PA 17013 HOWARD HOUSTON by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.00 Postage .37 Surcharge 10.00 .00 32.37 Sworn and Subscribed to before me this I ,4k day of !J A.D. Pr ota So Answers: R. Thomas Kline 09/29/2005 HANDLER HENNING ROSENBERG By. 7L? `J5, X71 eputy Sher' f ORIGINAL 11. BENNETT, BRICKLIN & SALTZBURG LLP BY: Jeffrey P. Ouellet, Esquire I.D. No. 80170 222 EAST ORANGE STREET LANCASTER, PA 17602 (717) 397-7000 DIANE DURBOROW-GOODLING and LONNIE GOODLING vs. HOWARD HOUSTON ATTORNEY FOR DEFENDANT Howard Houston COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOCKET No. 05-4871 JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Jeffrey P. Ouellet, Esquire on behalf of the Defendant in this matter. BENNETT, BRICKLIN & SALTZBURG, LLP BY: Jeffry . O llet, Attorneys or Defendant Howard Houston J r.- t CERTIFICATE OF SERVICE I hereby certify that I have this day served a true and correct copy of the foregoing Entry of Appearance upon the person listed below and in the manner indicated: Service by first class mail: David H. Rosenberg, Esquire Handler, Henning & Rosenberg, LLP 1300 Lingelestown Road Harrisburg, PA 17110 BENNETT, BRICKLIN & SALTZBURG, LLP Date: LO c: BY: Jeffre P. ue t, Attorneys for Defendant Howard Houston ?_, - =?' - -- c? --_{ .?..: =?: DIANE M. DURBOROW-DOODLING Plaintiff V. HOWARD HOUSTON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-4871 CIVIL ACTION -LAW COMPLAINT AND NOW, come the Plaintiffs, Diane M. Durborow-Goodling and Lonnie Durborow- Goodling, her husband, by and through their attorneys, HANDLER, HENNING & ROSENBERG, LLP, by David H Rosenberg, Esq., and make the within Complaint against the Defendant, Howard Houston, and aver as follows: 1. Plaintiff, Diane M. Durborow-Goodling, is an adult individual currently residing at 107 Kestrel Court, Hummelstown, PA 17036. 2. Defendant, Howard Houston, is an adult individual currently residing at 421 Croghan Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. At all times material hereto, Plaintiff, Diane M. Durborow-Goodling, was the operator of a motor vehicle (hereinafter, "Plaintiffs vehicle"). 4. At all times material hereto, Defendant, Howard Houston, was the operator of a motor vehicle (hereinafter, "Defendant's vehicle"). 5. At all times material hereto, Plaintiff, Diane M. Durborow-Good ling, was insured under an automobile insurance policy with Erie Insurance Group and covered by the full tort option. 6. At all times material to this action, there were no adverse weather or road conditions. a 7. On or about September 30, 2003, at approximately 7:40 a.m., Plaintiffs vehicle was lawfully stopping for traffic as she was traveling on the route 581 exit ramp for routes 11/15 in Camp Hill, Cumberland County, Pennsylvania. 8. At approximately that same time and place, suddenly and without any warning, Defendant, Howard Houston, who had been traveling behind Plaintiffs vehicle, violently struck the rear of Plaintiffs stopped vehicle. 9. As a direct and proximate result of the negligence of Defendant, Howard Houston, the Plaintiff, Diane M. Durborow-Goodling, sustained serious and extensive injuries. COUNT I - NEGLIGENCE Diane M. Durborow-Goodling v. Howard Houston 10. Plaintiff, Diane M. Du rborow-Good ling, incorporates and makes part of this Count paragraphs 1 through 10 above, as if the same were set forth fully below. 11. The occurrence of the aforementioned collision and all the resultant injuries to Plaintiff, Diane M. Durborow-Good ling, are the direct and proximate result of the negligence of the Defendant, Howard Houston, generally and more specifically, as setforth below: (a) In failing to be reasonably vigilant to observe the road and traffic conditions then and there existing; (b) In failing to have due regard for the speed of the vehicles and the traffic upon the road and the condition of the highway, in violation of 75 Pa. C.S.A. § 3310(a); 1) (c) In failing to operate his vehicle in such a manner that would allow him to apply the brakes and stop before striking the rear of Plaintiffs stopped vehicle; (d) In failing to operate his vehicle under proper and adequate control so that he could have avoided striking Plaintiffs stopped vehicle; (e) In failing to properly regulate the speed of his vehicle so as to prevent a rear-end collision; (f) In failing to operate his vehicle at a speed and under such control so as to be able to stop within the assured clear distance, in violation of 75 Pa. C.S.A. § 3361; (g) In failing to operate his vehicle at a speed that was safe for existing conditions, in violation of 75 Pa. C.S.A. § 3361; (h) In following another vehicle more closely than is reasonable and prudent; (i) In failing to keep a proper lookout for vehicles lawfully stopped for traffic on the route 581 exit ramp for routes 11/15 in Camp Hill, Cumberland County, PA; 0) In failing to exercise reasonable care in the operation and control of his vehicle, in violation of 75 Pa. C.S.A. § 3714; (k) In operating his vehicle with a careless disregard for the safety of others, in violation of 75 Pa. C.S.A. § 3714; (1) In failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in failing to have his 3 vehicle under such control that injury to persons or property could be avoided; and (m)ln driving his vehicle upon the route 581 exit ramp for routes 11/15 in Camp Hill, Cumberland County, PA, in a manner endangering persons and property and in a manner with careless disregard to the rights and safety of others in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 12. As a direct and proximate result of the negligence of the Defendant, Howard Houston, the Plaintiff, Diane M. Durborow-Goodling, has suffered serious injuries, including, but not limited to, headaches, neck and back pain radiating down to her lower left side, a whiplash injury, a cervical, thoracic and shoulder strain, rib somatic dysfunction, herniated discs, and cranial somatic dysfunction. 13. As a direct and proximate result of the negligence of Defendant, Howard Houston, the Plaintiff, Diane M. Durborow-Goodling, has suffered lost wages and will in the future continue to suffer a loss of income and/or loss of earning capacity. 14. As a direct and proximate result of the negligence of Defendant, Howard Houston, the Plaintiff, Diane M. Durborow-Goodling, has suffered great physical pain, discomfort, and mental anguish, and she will continue to endure the same for an indefinite period of time in the future, to her great physical, emotional, and financial detriment and loss. 15. As a direct and proximate result of the negligence of Defendant, Howard Houston, the Plaintiff, Diane M. Durborow-Goodling, has been compelled, in orderto effect a cure for aforesaid injuries, to expend money for medicine and/or medical attention, and 4 will be required to expend money for the same purposes in the future, to her great detriment and loss. 16. As a direct and proximate result of the negligence of Defendant, Howard Houston, the Plaintiff, Diane M. Durborow-Goodling, has suffered a loss of life's pleasures, and she will continue to suffer the same in the future, to her great detriment and loss. 17. As a direct and proximate result of negligence of Defendant, Howard Houston, the Plaintiff, Diane M. Durborow-Good ling, has been, and will in the future be, hindered from attending to her daily duties, to her great detriment, loss, humiliation, and embarrassment. 18. Plaintiff, Diane M. Durborow-Goodling, believes and, therefore, avers that her injuries are permanent in nature. WHEREFORE, Plaintiff, Diane M. Durborow-Goodling, seeks damages from Defendant, Howard Houston, in an amount in excess of the compulsory arbitration limits of Cumberland County exclusive of interest and costs. Date: (01311151 _T 7- Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP By: 5 V Davi H Rosenberg, Esquire A rney I. D. # 20569 00 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorney for Plaintiff VERIFICATION The undersigned hereby verifies that the statements in the foregoing document are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language of the document is of counsel and not my own. 1 have read the document and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the document are that of counsel, I have relied upon my counsel in making this Verification. The undersigned also understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Diane M. Durborow-Goodling L/ Date: _ DIANE M. DURBOROW-GOODLING Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-4871 HOWARD HOUSTON, Defendant CIVIL ACTION -LAW CERTIFICATE OF SERVICE On the 31" day of October, 2005, 1 hereby certify that a true and correct copy of Plaintiffs Complaint was served upon the following by depositing in U.S. Mail; Jeffrey P. Ouellet, Esq. Bennett, Bricklin & Saltzburg, LLP 222 E. Orange Street Lancaster, PA 17602 Respectfully submitted, /o13qla HANDLER, HENNING & ROSENBERG, LLP DATE H Rdsenberg, Esquire 1300 estown Road I.D. #7burg, 9 Harri PA 17110 717-238-2000 Attorney for Plaintiff rt ?? €'• ri? r.- -'.v .' ,, --a C ? ? =a ? ? ?s, '? ' ? , ?, _ `N ? ? CI-05-08389 ORIGINAL BENNETT, BRICKLIN & SALTZBURG LLP BY: Jeffrey P. Ouellet, Esquire I.D. No. 80170 222 EAST ORANGE STREET LANCASTER, PA 17602 (717) 397-7000 DIANE M. DURBOROW-GOODLING, PLAINTIFF vs. HOWARD HOUSTON, DEFENDANT To the within named parties, you are hereby notified to plead to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. JEFFREY P. OUELLET, ESQUIRE ATTORNEY FOR DEFENDANT Howard Houston COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION - LAW DOCKET No. 05-4871 JURY TRIAL DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER Admitted in part, denied in part. Based on information and belief, it is admitted that Plaintiff is an adult individual. After reasonable investigation„ Defendant is without sufficient information to form a belief as to the truth of the allegation about Plaintiff's present address. 2. Admitted. Admitted based upon information and belief. Admitted based upon information and belief. 5. After reasonable investigation, Defendant is without sufficient information to form a belief as to the truth of the allegations in this Paragraph. Accordingly, these allegations are denied. CI-05-08389 Admitted based upon information and belief. Admitted in part, denied in part. It is admitted that Plaintiff was traveling in the vicinity of route 11/15 and approaching the Route 581 exit ramp. It is further admitted that Plaintiff was traveling at the time and date stated in the Complaint. It is denied that the accident occurred at the precise location noted in the Complaint, and that Pllaintif 's vehicle was "lawfully" stopped. This statement is denied as a conclusion of law to which no responsive pleading is required. To the extent any part of it may be construed as an averment of fact, that averment is denied in accordance with Pa.R.C.P. 1029(e). 8. This Paragraph is denied as a conclusion of law to which no responsive pleading is required. To the extent any part of it may be construed as an averment of fact, these averments are denied in accordance with Pa.R.C.P. 1029(e). 9. Admitted in part, denied in part. It is admitted that there was an accident. It is denied that the collision involved was violent, and that Plaintiff's vehicle was stopped at the time of the accident. To the extent that this Paragraph contains conclusions of law, no responsive pleading is required pursuant to the Pennsylvania Rules of Civil Procedure. COUNTI - NEGLIGENCE 10. The responses contained in Paragraphs One (1) through Nine (9) are hereby incorporated by reference as though fully set forth herein. I l(a)-(m). The Paragraph, and all of its various subparts, are denied as conclusions of law to which no responsive pleading is required. To the extent any aspect of this Paragraph or its various subparts are construed to be an averment of fact, these averments are denied in accordance with Pa.R.C.P. 1029(e). 2 CI-05-08389 12. This Paragraph is denied as a conclusion of law to which no responsive pleading is required. To the extent any part of it may be construed as an averment of fact, these averments are denied in accordance with Pa.R.C.P. 1029(e). 13. This Paragraph is denied as a conclusion of law to which no responsive pleading is required. To the extent any part of it may be construed as an averment of fact, these averments are denied in accordance with Pa.R.C.P. 1029(e). 14. This Paragraph is denied as a conclusion of law to which no responsive pleading is required. To the extent any part of it may be construed as an averment of fact, these averments are denied in accordance with Pa.R.C.P. 1029(e). 15. This Paragraph is denied as a conclusion of law to which no responsive pleading is required. To the extent any part of it may be construed as an averrnent of fact, these averments are denied in accordance with Pa.R.C.P. 1029(e). 16. This Paragraph is denied as a conclusion of law to which no responsive pleading is required. To the extent any part of it may be construed as an averment of fact, these averments are denied in accordance with Pa.R.C.P. 1029(e). 17. This Paragraph is denied as a conclusion of law to Ahich no responsive pleading is required. To the extent any part of it may be construed as an averment of fact, these averments are denied in accordance with Pa.R.C.P. 1029(e). 18. This Paragraph is denied as a conclusion of law to which no responsive pleading is required. To the extent any part of it may be construed as an averment of fact, these averments are denied in accordance with Pa.R.C.P. 1029(e). 3 CI-05-08389 WHEREFORE, Defendant Howard Houston respectfully requests that this Honorable Court enter judgment in his favor and against Plaintiff Diane M. Durborow-Goodling with costs and fees as allowed by law. NEW MATTER 19. The averments in Paragraphs One (1) through Eighteen (18) are hereby incorporated by reference as though fully set forth herein. 20. Defendant was not negligent. 21. Any acts or omission of Defendant alleged to constitute negligence were not substantial causes or facts of the incident and/or did not result in the injuries or losses alleged by Plaintiff. 22. The negligent acts or omissions of other individuals may have constituted intervening, superceding causes of the damages or injuries alleged to have been sustained by the Plaintiff. 23. The Plaintiff may have been contributorily negligent. 24. The damages claimed by Plaintiff, if any, are limited by the provisions of Moorhead v. Crozer Chester Medical Center, 765 A.2d 786 (Pa. 2001). 25. Plaintiff's claimed damages and injuries, if any, may have pre-existed and were not caused by aggravated by the accident for which Plaintiff has brought suit. 4 CI-05-08389 WHEREFORE, Defendant Howard Houston respectfully requests that this Honorable Court enter judgment in his favor and against Plaintiff Diane M. Durborow-Goodling with costs and fees as allowed by law. BY: 6J Jeff e ellet, Attorneys for Defendant Howard Houston VERIFICATION I verify that the statements made in the foregoing Answer with New Matter which are within the personal knowledge of the undersigned, are true and correct, and as to facts based on the information of others, the undersigned, after diligent inquiry, believes them to be true. And further, as to language and averments which may constitute legal conclusions, I sign this verification on the recommendation of my attorneys who advise that the allegations and language in the Answer with New Matter constituting legal conclusions are required legally to raise issues for resolution at trial, by the Court, or by continuing investigation and preparation for trial. I understand that some of these allegations may prove inappropriate after investigation and trial preparation are complete and I leave determination of these matters to my attorneys on their advice. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. Ec /7 Date Howard Houston CI-05-08389 CERTIFICATE OF SERVICE I hereby certify that I have this day served a true and correct copy of the foregoing Defendant's Answer With New Matter on the person listed below and in the manner indicated: Service by first class mail: David H. Rosenberg, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, Pennsylvania 17110 BENNETT BRICKLIIN & SALZBURG, LLP Date: oC (? BY: Jef e ellet, Attorney for Defendant Howard Houston {J r-? c? c_7 `n ? _:. ,:gin ,-1 r7 T -n _r. ??1 ??z;-= c'? _n?n f i f t ? '. C T7 )' t'/ ?;? { ?? _1 David H Rosenberg, Esq. I.D.#20569 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax: (717) 233-3029 E-mail: Rosenberg@hhrlaw.com DIANE M. DURBOROW-GOODLING Plaintiff V. HOWARD HOUSTON, Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-4871 CIVIL ACTION - LAW PLAINTIFF'S REPLY TO NEW MATTER AND NOW, come the Plaintiff, Diane M. Durborow-Goodling, by and through her attorneys, HANDLER, HENNING & ROSENBERG. LLP, by David H Rosenberg, Esquire and reply to Defendant's New Matter as follows: 19. This Paragraph does not require a response. 20. Denied. This averment is denied pursuant to Pennsylvania Rules of Civil Procedure 1029(e). 21. Denied. This is conclusion of law to which a response is not required. Should a response be required, this is specifically denied. 22. Denied. This is conclusion of law to which a response is not required. Should a response be required, this is specifically denied. 23. Denied. This is conclusion of law to which a response is not required. Should a response be required, this is specifically denied. 24. Denied. This is conclusion of law to which a response is not required. Should a response be required, this is specifically denied. 25. Denied. This averment is denied pursuant to Pennsylvania Rules of Procedure 1029(e) WHEREFORE, Plaintiff, Diane M. Durborow-Goodling, seeks damages from Defendant, Howard Houston, in an amount in excess of the compulsory arbitration limits of Cumberland County exclusive of interest and costs. Respectfully submitted, 0-2 3'05? HANDLER, HENNING & ROSENBERG, LLP DATE David H Ro nberg, Esquire I.D. #2056 1300 Lin estown Road Harrisbu g, PA 17110 717-238-2000 Attorney for Plaintiff 2 DIANE M. DURBOROW-GOODLING : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 05-4871 HOWARD HOUSTON, Defendant CIVIL ACTION -LAW CERTIFICATE OF SERVICE On the 22"d day of December, 2005, 1 hereby certify that a true and correct copy of Plaintiffs Complaint was served upon the following by depositing in U.S. Mail; Jeffrey P. Ouellet, Esq. Bennett, Bricklin & Saltzburg, LLP 222 E. Orange Street Lancaster, PA 17602 Respectfully submitted, 12-23--05- HANDLER, HENNING & ROSENBERG, LLP DATE David H Rose erg, Esquire I.D. #20569 1300 Ling stown Road Harrisburg, PA 17110 717-238-2000 Attorney for Plaintiff VERIFICATION The undersigned hereby verifies that the statements in the foregoing document are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language of the document is of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the document are that of counsel, I have relied upon my counsel in making this Verification. The undersigned also understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Diane M. Durborow-Good ling Date: Q / ?.? ??, o ?,, -?, ?-? --? h ???, -?? -?, 4' C "?i? _ L '.' _, rti •? Diane Durborow-Goodling, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, Plaintiff PENNSYLVANIA V. CIVIL ACTION-LAW Howard Houston, No. 05-4871 Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 13" day of March of 2006, 1 hereby certify that I have, on this date, served the within Plaintiff's Answers to Defendants First Set of Interrogatories Addressed To Plaintiff and Request for Production of Documents, via first class mail by sending a true and correct copy of same to their attorney and including copies to all parties of interest as follows: Jeffrey P. Ouellet, Esquire Attorney for Defendants 222 East Orange Street Lancaster, PA 17602 By: `l G & ROSENBERG David H Wosenberg, Esquire AttornID# 20569 1300 mglestown Road Harrisburg, PA 17110 (717)238-2000 ORIGINAL BENNETT, BRICKLIN & SALTZBURG LLP BY: Jeffrey P. Ouellet, Esquire I.D. No. 80170 222 EAST ORANGE STREET LANCASTER, PA 17602 (717) 397-7000 ATTORNEY FOR DEFENDANT Howard Houston DIANE DURBOROW-GOODLING and LONNIE GOODLING VS. HOWARD HOUSTON COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOCKET No. 05-4871 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I hereby certify that I have this day served a true and correct copy of the Notice of Deposition of Diane Durborow-Goodling and Lonnie Goodling upon the person listed below and in the manner indicated: Service by first class mail: David H. Rosenberg, Esquire Handler, Henning & Rosenberg, LLP 1300 Lingelestown Road Harrisburg, PA 17110 BENNETT, BRICKLIN & SALTZBURG, LLP Date: s (? BY: U14 Jeffrey . ell , Attorneys for Defendant Howard Houston S? apgaeg?? u c_ p se• Z L-' c ?o -? N $-n rn ORIp"!j?':1 David H Rosenberg, Esq. I.D.#20569 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone. (717) 238-2000 Fax: (717) 233-3029 E-mail: Rosenberg@hhrlaw.com Attorney for Plaintiff DIANE M. DURBOROW-GOODLING : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 05-4871 HOWARD HOUSTON, Defendant CIVIL ACTION -LAW PRAECIPE TO THE PROTHONOTARY: Please mark the Docket in the above captioned matter as Settled, Discontinued and Satisfied. Respectfully submitted, Date: HANDLER, HENNING & ROSENBERG, LLP By David eRonberg, Esquire I.D. #32298 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorneys for Plaintiff rz) * _,. : . 'ma'y !