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HomeMy WebLinkAbout05-6746Casey G. Shore, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 cshore@ngplawfirm.com WILLIAM M. HICKS TRUCKING COMPANY, INC. Plaintiff, V. STAR TRANSPORT, INC., AND ANTHONY ST. GEORGE REID Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. DS-io7?? ?iv?L?E1? CIVIL ACTION - LAW JURY TRIAL DEMANDED 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 32 South Bedford Street Carlisle, Pennsylvania (717) 249-3166 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted Debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo a viso o notificacion, y por cualquier quejai o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania (717) 249-3166 Casey G. Shore, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 cshore@ngplawfirm.com WILLIAM M. HICKS TRUCKING COMPANY, INC. Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA V. STAR TRANSPORT, INC., AND ANTHONY ST. GEORGE REID Defendants. NO. 05-6746 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the above captioned matter. Date: 1 Respectfully submitted, NEALON & GOVER, P.C. By: Front Street Harrisburg, PA 17110 (717) 232-9900 X" ey . Ca 2411 North Shore, Esquire Attor .D. No. 85321 c_, _ , _} Casey G. Shore, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 cshore@ngplawfirm.com WILLIAM M. HICKS TRUCKING COMPANY, INC. Plaintiff, A. STAR TRANSPORT, INC., AND ANTHONY ST. GEORGE REID Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA :NO. D5- ?7?1(0 (20L?C-?11? CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT AND NOW, comes Plaintiff, William M. Hicks Trucking Company, Inc., by and through its undersigned counsel, Nealon Gover & Perry, who avers the following: 1. Plaintiff, William M. Hicks Trucking Company, Inc., is a Texas Corporation with its principle place of business at 10252 Pleasant Hollow Road, Tyler, Texas, 75709. 2. Defendant, Star Transport, Inc., is an Illinois Corporation with its principle place of business at 240 Ashland Avenue, P.O. Box 909, Morton, Illinois, 61550. 3. Defendant, Anthony St. George Reid is an adult individual who at all times pertinent hereto was employed by Defendant Star Transport, Inc., with an address of 32 Cottonwood Building, Middletown, Pennsylvania, 17057. 4. On or about October 25, 2004, a truck tractor trailer owned and operated by Plaintiff had been legally parked at the Petro Travel Plaza in Carlisle, Cumberland County, Pennsylvania. 5. At or about 9:44 p.m., as the driver was in the sleeper cab, Plaintiff's vehicle was struck by another truck tractor trailer which was owned and operated by Defendant Star Transport, Inc., that fled the scene of the accident. 6. It was thereafter discovered that Defendant Anthony St. George Reid (hereinafter "Defendant St. George") was the driver of the Star Transport vehicle that struck the vehicle owned and operated by Plaintiff. 7. At all times relevant hereto, Defendant St. George, was the agent, servant, workman, officer and/or employee of Defendant Star Transport, Inc., and was operating the aforementioned truck tractor trailer in the course and scope of his employment. 8. As a result of the aforementioned vehicle accident, Plaintiff has suffered extensive financial losses including loss of revenue; and various other costs associated with delivering the load hauled by the immobilized truck tractor to its final destination. COUNT I - Negligence Hicks Trucking v. Defendant Anthony St. George Reid 9. Paragraphs 1-8 above are incorporated herein by reference as if fully set forth at length. 10. The aforesaid vehicle accident was due solely to the negligent conduct, careless conduct and gross, wanton and reckless conduct of Defendant St. George and in no way due to any negligent act or failure to act on the part of the Plaintiff. 11. The negligent conduct, careless and gross, wanton and reckless conduct of Defendant St. George consisted of the following: a. failure to properly brake his vehicle; b. failure to properly observe the roadway; C. operating his vehicle without due regard for the rights, safety and position of Plaintiff's vehicle; d. operating his vehicle so as to bring it into sudden, forcible contact with Plaintiff's vehicle; e. failure to maneuver his vehicle so as to avoid collision; f. failure to maintain adequate control over his vehicle; g. failure to obey the rules of the road and the statutes of the Commonwealth of Pennsylvania. 12. As a result of the aforementioned acts and omissions, Plaintiff has suffered great financial hardship as has been previously stated herein. WHEREFORE, Plaintiff William M. Hicks Trucking Company Inc. respectfully requests judgment in its favor against Defendant Anthony St. George Reid, jointly and severally in an amount that does not exceed the requirements of compulsory arbitration, together with any costs and interest. COUNT II - Respondeat Superior Hicks Trucking v. Defendant Star Transport, Inc. 13. Paragraphs 1-12 above are incorporated herein by reference as if fully set forth at length. 14. Defendant Star Transport, Inc., is vicariously liable for the aforementioned vehicle accident due to the actions of its agents, servants, workmen and/or employees. 15. As a result of the aforementioned acts and omissions, Plaintiff has suffered such harm as previously stated herein. WHEREFORE, Plaintiff William M. Hicks Trucking Company Inc. respectfully requests judgment in its favor against Defendant Star Transport, Inc., jointly and severally in an amount that does not exceed the requirements of compulsory arbitration, together with any costs and interest. Date: L5 NEALON GOVER & PERRY By: L'4-? - Cie G. Shore, Esquire Attorney I.D. No. 85321 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 VERIFICATION I, William M. Hicks, verify that the statements made in the foregoing COMPLAINT are true and correct. 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. Date: 6/ dz"? /ll k William M. Hicks William M. Hicks Trucking Company Inc. cz) -60- _ 9. ZD n U RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Matthew J. McLees Identification No.: 71592 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 Attorneys for Defendant, Star Transport, Inc. WILLIAM HICKS TRUCKING COMPANY, INC. Plaintiff, VS. STAR TRANSPORT, INC. and ANTHONY ST. GEORGE REID Defendants. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 05-6746 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance on behalf of defendant, Star Transport, Inc., in the above- referenced matter. Date: 1 - t 3 RAWLE & HENDEI SON LLP By: tewart, Esquire Matthew J. McLees, Esquire Attorney for Defendant, Star Transport, Inc. 1252735 v.l CERTIFICATE OF SERVICE appearance was served by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: I hereby certify that on today's date, a true and correct copy of the foregoing entry of Casey G. Shore, Esquire Nealon Gover & Perry 2411 North Front Street, Harrisburg, PA 17110 Date: RAWLE & HE>?ERSON LLP By: ?A- Matthew J. McLees, Esquire Attorney for Defendant, Star Transport, Inc. 1252735 v] 1-.J ^ ? f?) 1 4 _ ? ? (. .Y ?'? H Casey G. Shore, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 cshore@ngplawfirm.com IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. o? S - i> /"/- ' J CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this ,i day of January, 2006, 1 hereby certify that a copy of the foregoing COMPLAINT was served upon the following via certified mail on January 6, 2006: Star Transport, Inc. 240 Ashland Avenue P.O. Box 909 Morten, Illinois, 61550 Casty Shore, Esquire WILLIAM M. HICKS TRUCKING COMPANY, INC. Plaintiff, V. STAR TRANSPORT, INC., AND ANTHONY ST. GEORGE REID Defendants. ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Adlrased to: OIL f? 4l3 f aS1?1C,11?G ?L ITV aux qCP mvr+r?, girl A. X by 0 Agent D. Is delivery address dlflerant from term 11 U yes If YES, enter delivery address below: 0 No 3. Service Type IO(Certified Mail 0 Express Mail ? Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 yes 2. Article Number (Transfer from service iebef) 7004 2890 0000 6575 4850 PS Form 3811, March 2001 Domestic Return Receipt 102595411-M-1424 B. Date of Delivery CJ -ti t:_ ,? ` ' ? !? _._ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-06746 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HICKS WILLIAM M TRUCKING CO VS STAR TRANSPORT INC ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: REID ANTHONY ST GEORGE but was unable to locate Him deputized the sheriff of DAUPHIN serve the within COMPLAINT & NOTICE in his bailiwick He therefore County, Pennsylvania, to On January 17th , 2006 this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: So answers:. Docketing 18.00 Out of County 9.00 Surcharge 10.00 R. Thomas Kline Dep Dauphin County 35.25 Sheriff of Cumberland County Postage 1.17 01/17/2006 NEALON & GOVER Sworn and subscribed to before me this ?4 l?- day o AUDI, .D. Pro nota y In The Court of Common Pleas of Cumberland County, Pennsylvania William M. Hicks Tricking Company Inc vs. Star Transport Inc et al SERVE: Anthony St George Reid No. 05-6746 civil Now, December 30, 2005 hereby deputize the Sheriff of I, SHERIFF OF CUMBERLAND COUNTY, PA, do Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to copy of the original the contents thereof. So answers, Sheriff of Sworn and subscribed before me this _ day of 20 20 , at o'clock M. served the COSTS SERVICE $ MILEAGE AFFIDAVIT County, PA (Of fitre of t4r oShpxrff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph:(717)780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania WILLIAM M HICKS TRUCKING COMPANY INC vs County of Dauphin • ST GEORGE ANTHONY REID Sheriff's Return No. 0003-T - - -2006 OTHER COUNTY NO. 05-6746 CIVIL I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for ST GEORGE ANTHONY REID the DEFENDANT named in the within NOTICE & COMPLAINT and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, January 5, 2006 AS PER RENTAL OFFICE, NO TENANTS LISTED UNDER THAT NAME IN COMPLEX. Sworn and subscribed to before me this 10TH day of JANUARY, 2006 pGt/ NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept 1, 2006 So Answers, ,kAlc-- Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs:$35.25 PD 01/03/2006 RCPT NO 213454 SS To Plaintiff: RAWLE & HENDERSON t.t.P By: Gary N. Stewart Identification No.: 67353 By: Matthew J. McLees Identification No.: 71592 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 WILLIAM HICKS TRUCKING COMPANY, INC. Plaintiff, vs. STAR TRANSPORT, INC. and ANTHONY ST. GEORGE REID Defendants. You are hereby notified to file a written response to the new matter within twenty (20) days from service hereof or a judgment may be entered against you. RAWLE&(?\HENDERSON LLP By: Matthew . McLees, Es Attorneys for Defendant, Star Transport, Inc. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 05-6746 ANSWER AND NEW MATTER OF DEFENDANT STAR TRANSPORT, INC. TO THE COMPLAINT OF PLAINTIFF WILLIAM HICKS TRCKING COMPANY INC. Defendant Star Transport, Inc., by and through its attorneys, Rawle & Henderson, LLP, hereby answers the complaint of plaintiff and asserts new matter as follows: After a reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph and they are, accordingly, denied and strict proof thereof is demanded. 2. Admitted. 1255335 v.1 After a reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph and they are, accordingly, denied and strict proof thereof is demanded. 4. Denied. After a reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph and they are, accordingly, denied and strict proof thereof is demanded. 5. Denied. After a reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph and they are, accordingly, denied and strict proof thereof is demanded. 6. Denied. After a reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph and they are, accordingly, denied and strict proof thereof is demanded. Denied. Under the Pennsylvania Rules of Civil Procedure, no answer is required to this paragraph as the averments therein state conclusions of law which are deemed denied. By way of further answer, but not in derogation of the foregoing, it is admitted that defendant Anthony St. George Reid was an employee of defendant Star Transport at the time material hereto. Denied. After a reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph and they are, accordingly, denied and strict proof thereof is demanded. 1255335 v.l COUNT I - NEGLIGENCE HICKS TRUCKING v. ANTHONY ST. GEORGE REID 9. Defendant incorporates herein by reference its answers to the allegations contained in paragraphs 1 through 8 of plaintiff's complaint as though same were set forth fully herein at length. 10. Denied. Under the Pennsylvania Rules of Civil Procedure, no answer is required to this paragraph as the averments therein state conclusions of law which are deemed denied. 11. (a) - (g), inclusive. Denied. Under the Pennsylvania Rules of Civil Procedure, no answer is required to this paragraph as the averments therein state conclusions of law which are deemed denied. 12. Denied. Under the Pennsylvania Rules of Civil Procedure, no answer is required to this paragraph as the averments therein state conclusions of law which are deemed denied. Additionally, after reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph concerning plaintiff s alleged damages and said averments are, accordingly, denied and strict proof thereof is demanded. WHEREFORE, defendant Star Transport, Inc. denies liability to plaintiff for any sum or sums and demands judgment in its favor together with attorneys' fees and costs. 1255335 v.1 COUNT II - RESPONDEAT SUPERIOR HICKS TRUCKING v. STAR TRANSPORT, INC. 13. Defendant incorporates herein by reference its answer to the allegations contained in paragraphs 1 through 12 of plaintiff's complaint as if though same were set forth fully herein at length. 14. Denied. Under the Pennsylvania Rules of Civil Procedure, no answer is required to this paragraph as the averments therein state conclusions of law which are deemed denied. 15. Denied. Under the Pennsylvania Rules of Civil Procedure, no answer is required to this paragraph as the averments therein state conclusions of law which are deemed denied. Additionally, after reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph concerning plaintiff's alleged damages and said averments are, accordingly, denied and strict proof thereof is demanded. WHEREFORE, defendant Star Transport, Inc. denies liability to plaintiff for any sum or sums and demands judgment in its favor together with attorneys' fees and costs. NEW MATTER OF DEFENDANT STAR TRANSPORT, INC. DIRECTED TO PLAINTIFF HICKS TRUCKING COMPANY. INC. Defendant Star Transport, Inc. hereby sets forth the following new matter directed to plaintiff Hicks Trucking Company, Inc.: 16. Plaintiffs Complaint fails to state a cause of action upon which relief can be granted. 17. No omissions or conduct on the part answering defendant contributed to plaintiff's damages, if any. 18. Plaintiff failed to mitigate its damages. 1255335 v.1 19. The damages complained of by plaintiff pre-existed, or are unrelated to, the accident which is the subject of this Complaint. 20. Plaintiff's claims are barred as plaintiff's alleged damages were, or may have been, caused by the negligent acts or omissions of plaintiff and/or plaintiff's agents, servants, employees and/or workmen, which caused or contributed to the alleged damages and/or loss, if any. 21. Plaintiff's claims are barred in whole or in part by the doctrine of contributory negligence and/or comparative negligence and in accordance with 42 Pa. Cons. Stat. Ann. § 7102, in that the negligence of plaintiff and/or plaintiffs agents, servants, employees and/or workmen caused or contributed to the alleged damages. 22. Plaintiffs claims are barred as plaintiffs alleged damages were, or may have been, caused by the acts of others for whom defendant is not responsible, and the negligent acts or omissions of individuals and/or entities other than defendant may have caused or contributed to the alleged damages and/or loss, if any. 23. The negligent acts and/or omissions of individuals other than defendant may constitute intervening superseding acts of negligence, which caused plaintiffs alleged damages and/or loss, if any. 24. Plaintiff's claims are barred or limited by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa.C.S.A. §§ 1701, et M. 1255335 v.I WHEREFORE, defendant Star Transport, Inc. respectfully requests this Honorable Court to dismiss plaintiff s Complaint with prejudice, and deny the relief requested therein, grant judgment in favor of said defendant and against plaintiff, and grant such other and further relief as this Honorable Court deems just and proper. RAWLE & HENDERSON LLP By1 he J. McLees, Esquire efendant, for D qAey' Star Transport, Inc. Date: 2 J •Z 2 I DG 1255335 vA VERIFICATION I, MATTHEW J. MCLEES, ESQUIRE, hereby state that I am an attorney of the law firm of Rawle & Henderson 1 l P, attorneys for defendant, Star Transport, Inc., and that I am authorized to make this Verification on behalf of said defendant. The undersigned verifies that the statements made in the foregoing Answer to the Complaint of Plaintiff With New Matter are true and correct to the best of his knowledge, information, and belief. The undersigned understands that the statements set forth in said pleading are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. M TTHE . MCLEES, ESQUIRE 1255335 v.l CERTIFICATE OF SERVICE I hereby certify that on today's date, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Casey G. Shore, Esquire Nealon Gover & Perry 2411 North Front Street, Harrisburg, PA 17110 RAWLE & HENDERSON LLP By: ?t 1 Matth w J. McLees, Esquire Attom y for Defendant, Star Transport, Inc. Date: 7- i 0 h 1255335 v.I ,. ,., ' ._? ; ,.; -.> ,' , ?..,: ? Casey G. Shore, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 cshore@ngplawfirm.com WILLIAM M. HICKS TRUCKING COMPANY, INC. Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA V. STAR TRANSPORT, INC., AND ANTHONY ST. GEORGE REID Defendants. NO. 05-6746 CIVIL ACTION - LAW JURY TRIAL DEMANDED REPLY TO NEW MATTER OF DEFENDANT STAR TRANSPORT. INC. AND NOW, comes Plaintiff, William M. Hicks Trucking Company, Inc., by and through its undersigned counsel, Nealon Gover & Perry, who avers the following: 16.-24. The averments contained in Paragraphs 16 - 24 of the New Matter of Star Transport, Inc. are conclusions of law to which no response is required. To the extent a response is deemed required, they are denied. WHEREFORE, Plaintiff William M. Hicks Trucking Company Inc. respectfully requests judgment in its favor against Defendant Star Transport, Inc., jointly and severally in an amount that does not exceed the requirements of compulsory arbitration, together with any costs and interest. NEALON GOVER & PERRY Date: a? 'Al By: C se G. Shore, Esquire Attorney I.D. No. 85321 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 VERIFICATION I, William M. Hicks, verify that the statements made in the foregoing REPLY TO NEW MATTER OF DEFENDANT STAR TRANSPORT, INC., are true and correct. 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. Date: /, C???. , /i/• ?ffl William M. Hicks William M. Hicks Trucking Company Inc. CERTIFICATE OF SERVICE AND NOW, this I day of March, 2006, 1 hereby certify that I have served the foregoing REPLY TO NEW MATTER OF DEFENDANT STAR TRANSPORT, INC., on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, return receipt requested, addressed to: Star Transport, Inc. 240 Ashland Avenue P.O. Box 909 Morton, Illinois, 61550 L )L Ca Shore, Esquire ,_.> <- ? _ f f. r.n -11 ?? ?] illT . 'D ?'1 l?? ? ??_) ? l T ) ?t °..?f? GJ -1 --- :SJ -. ?< r' RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Matthew J. McLees Identification No.: 71592 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 Attorneys for Defendant, Star Transport, Inc. WILLIAM HICKS TRUCKING COMPANY, INC., Plaintiff, vs. STAR TRANSPORT, INC. and ANTHONY ST. GEORGE REID, Defendants. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 05-6746 MOTION TO APPROVE THE STIPULATION REGARDING DISMISSAL OF CERTAIN ALLEGATIONS IN THE PLAINTIFF'S COMPLAINT Defendant Star Transport, Inc., by and through its attorneys, Rawle & Henderson, LLP, respectfully move this Court to enter an Order Approving the Stipulation entered into by the parties in the above captioned action and, in support thereof, avers as follows: On December 27, 2005, plaintiff William M. Hicks Trucking Co., Inc. (hereinafter "Hicks Trucking") initiated this action against defendants with the filing of a complaint under Civil Action No. 05-6746. This action arises out of an October 25, 2004 alleged accident at the Petro Travel Plaza in Carlisle, Cumberland County, Pennsylvania. The plaintiff alleges that it suffered financial losses in connection with this motor vehicle accident. 2. Plaintiff Hicks Trucking and defendant Star Transport, Inc. entered into a stipulation whereby it was agreed that all allegations of "gross, wanton and reckless conduct" in paragraphs 10 and 11 of the plaintiff s complaint are dismissed with prejudice. See Stipulation, attached hereto and incorporated herein by reference as Exhibit "A." 1271669 v.I r' The parties desire to have this Stipulation approved and entered of record in this matter. 4. Co-defendant driver Anthony St. George Reid has not yet been served in this matter. When service is made upon Mr. Reid, he will be represented by counsel for Star Transport, Inc. WHEREFORE, Star Transport, Inc. respectfully requests that the Stipulation entered into by the parties be approved and the same be made part of the record of this civil action. RAWLE & HENDERSON By: ? . Gary . Stewart, Esquire Matthew J. McLees, Esquire Attorneys for Defendant Star Transport, Inc. 25 North Front Street, First Floor Harrisburg, PA 17101 (717) 234-7700 Date: 2 I -Z A 6C 1271669 v.l CERTIFICATE OF SERVICE I hereby certify that on today's date, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Casey G. Shore, Esquire Nealon Gover & Perry 2411 North Front Street, Harrisburg, PA 17110 RAWLE & HENDERSON LLP By: kI Gary . Stewart, Esquire Matthew J. McLees, Esquire Attorneys for Defendants, Star Transport, Inc. Date: ' 1 T7 ) O L 1271669 v.l RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Matthew J. McLees Identification No.: 71592 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 Attorneys for Defendant, Star Transport, Inc. WILLIAM HICKS TRUCKING COMPANY, INC. Plaintiff, vs. STAR TRANSPORT, INC. and ANTHONY ST. GEORGE REID Defendants. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 05-6746 STIPULATION Plaintiff, William Hicks Trucking Co., Inc., and Defendant, Star Transport, Inc., hereby stipulate and agree that all allegations of "gross, wanton and reckless conduct" in paragraphs 10 and 11 in the complaint of the plaintiff are hereby dismissed with prejudice. Cam ore, Esquire Attorney for Plaintiff, William Hicks Trucking Co., Inc. Nealon, Gover & Perry 2411 North Front Street Harrisburg, PA 17110 L,--- MattheAMcLees, Esquire Attorney for Defendant.. Star Transport, Inc. Rawle & Henderson 25 North Front Street, First Floor Harrisburg, PA 17101 2-12 7/06 1258860 v.I h-: r, ? - , ? `.M c> °i': u 7006 --_J L:BY 5 WILLIAM HICKS TRUCKING COMPANY, INC., Plaintiff, VS. STAR TRANSPORT, INC. and ANTHONY ST. GEORGE REID, Defendants. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 05-6746 ORDER C? AND NOW, this 3 day of A ec•\ , 2006, it is hereby ORDERED and DECREED that the Stipulation and Agreement by and between the parties to this action is APPROVED as worded. Accordingly, it is hereby ordered that all allegations of "gross, wanton and reckless conduct" in paragraphs 10 and 11 in the Complaint of the plaintiff are hereby DISMISSED with prejudice. Dated: 9 1271669 v.I oa ,? , r ?, ?' ,? ?t, .? ,,; ?_ .• st.? y?. ? -??) G v'.:3 '??? ??il? .. :-i r1:. ?V ...... '..J'?i .e. ._, RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Matthew J. McLees Identification No.: 71592 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 Attorneys for Defendant, Star Transport, Inc. WILLIAM HICKS TRUCKING COMPANY, INC. Plaintiff, VS. STAR TRANSPORT, INC. and ANTHONY ST. GEORGE REID Defendants. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 05-6746 WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdrawal the appearance of Matthew J. McLees, Esquire as co-counsel for defendant, Star Transport, Inc., in the above-captioned action. Date: 3T K RAWLE & HENDERSON LLP By: Matth w J. McLees, Esquire Attorn y for Defendant, Star Transport, Inc. 1285201 v.1 CERTIFICATE OF SERVICE I hereby certify that on today's date, a true and correct copy of the foregoing withdrawal of appearance was served by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Casey G. Shore, Esquire Nealon Gover & Perry 2411 North Front Street, Harrisburg, PA 17110 Date: RAWLE & HENDERSON LLP By: Wl---- Matthe J. McLees, Esquire Attorn for Defendant, Star Transport, Inc. 1285201 vA J :( CJ f 7 I i \CJ `. RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Jeffrey C. Mickletz Identification No.: 87531 25 North Front Street, First Floor Harrisburg, Pennsylvania 17101 (717) 234-7700 WILLIAM HICKS TRUCKING COMPANY, INC. Plaintiff, vs. STAR TRANSPORT, INC. and ANTHONY ST. GEORGE REID Defendants. Attorneys for Defendant, Star Transport, Inc. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO: 05-6746 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance as co-counselor with Gary N. Stewart on behalf of defendant, Star Transport, Inc., in the above-referenced matter. RAWLE LLP N. tewart, Esquire ey . Mickletz, Esquire ey for Defendant, Transport, Inc. Date: 1289577 v.1 4k CERTIFICATE OF SERVICE I hereby certify that on today's date, a true and correct copy of the foregoing entry of appearance was served by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Casey G. Shore, Esquire Nealon Gover & Perry 2411 North Front Street, Harrisburg, PA 17110 RAWLE-&-HENDERSON LLP e C. Mickletz, Esquire ney for Defendant, Transport, Inc. Date: 14 1289577v.1 Casey G. Shore, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 cshore@ngplawfirm.com WILLIAM M. HICKS TRUCKING COMPANY, INC. Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA V. NO. 05-6746 STAR TRANSPORT, INC., AND : CIVIL ACTION - LAW ANTHONY ST. GEORGE REID Defendants. : JURY TRIAL DEMANDED PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned matter. Respectfully submitted, Date:? NEALON GOVER & PERRY By: , ' L - Cas@ . Shore, Esquire Attorne I.D. No. 85321 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 ,., ,>, WILLIAM M. HICKS TRUCKING : IN THE COURT OF COMMON PLEAS COMPANY, INC. : CUMBERLAND COUNTY PENNSYLVANIA Plaintiff, V. : NO. 05-6746 STAR TRANSPORT, INC., AND : CIVIL ACTION - LAW ANTHONY ST. GEORGE REID Defendants. : JURY TRIAL DEMANDED TO: Anthony St. George Reid DATE OF NOTICE: July 19, 2006 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 "ISO IMPORTANTE A: Anthony St. George Reid FECHA DEL AVISO: July 19, 2006 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARECENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA LISTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y LISTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORTANTES. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 CERTIFICATE OF SERVICE AND NOW, this 141* day of July, 2006, 1 hereby certify that a copy of the foregoing NOTICE OF DEFAULT JUDGMENT was served upon the following via certified mail on January 6, 2006: Anthony St. George Reid 1800 Austin Lane York, PA 17404 Qj? y hore, Esquire WILLIAM M. HICKS TRUCKING COMPANY, INC. Plaintiff, V. STAR TRANSPORT, INC., AND ANTHONY ST. GEORGE REID Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. 05-6746 CIVIL ACTION - LAW JURY TRIAL DEMANDED TO: Anthony St. George Reid DATE OF NOTICE: August E, 2006 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 ¦ J AVISO IMPORTANTE A: Anthony St. George Reid FECHA DEL AVISO: August V), 2006 LISTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARECENCIA ESCRITA POR SI MISMO 0 A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA USTED. A MENOS QUE LISTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 ,` c? c ?- ?. c ??? << ?,> n? -,:-?, s? ?'; -r] Q?'? ?? ???1.,;. W "a _},' _J !;i .+ G e. ^" SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2005-06746 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HICKS WILLIAM M TRUCKING CO VS STAR TRANSPORT INC ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: REID ANTHONY ST GEORGE but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK serve the within COMPLAINT & NOTICE County, Pennsylvania, to On May 22nd , 2006 , t attached return from YORK Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep York County 28.34 Postage .78 s office was in receipt of the So answe R. Thomas Kline Sheriff of Cumberland County on . La ve 05122/2006 - 613°1134 NEALON & GOVER YORKTOWNE BUSINESS FORMS, INC. Ph. (717) 845-5955 Fax (717) 848-8906 email: ybf@blazenet.net f COUNTY OF YORK OFFICE OF THE SHERIFF 45 N. GEORGE ST., YORK, PA 17401 i SERVICE CALI. (717) 771-9601 SHERIFF SERVICE iTRl1CT10NS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLO$* 1 If OWY LM 1 THRU 12 OLMACH ANY COPES 1 PLAINTIFF/S/ William M. Hicks Trucking Company Inc 3 DEFENDANT/S/ Star Transport Inc et al 2 COURT NUMBER __ 05-6746 civil 4- TYP66Iy ?RIT„pt2/COMPLAINT Notice and, 11C1. HHCmplaint SERVE 5 NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED. ATTAGHED. UH bULU Anthony St George Reid 6 ADDRESS (STREET OR RFO WITH BOX NUMBER, APT NO, CITY, BORO, TWP . STATE AND ZIP CODE) AT 1880 Austin Lane York, PA 17404 7 INDICATE SERVICE U PERSONAL U PERSON IN CHARGE U DEPUTIZE U CERT MAIL U 1ST CLASS MAIL U POSTED U OTHER NOW April 25 .20 06 I, SHERIFF O NTY, PA ,,do hereby d? the sheriff of York COUNTY to execute thi mac tur ording to law. This deputization being made at the request and risk of the plaintiff., ` SHERIFF OF 1AW000NTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING R I EO F COUNTY Cumberland Please mail return of service to Cumberland County Sheriff. Thank you. ADVANCE FEE PAID BY ATTY. NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss. destruction. or removal of any property before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATUREC A S E Y G. SHORE, ESQ. 2411 NORTH FRONT ST., HARRISBURG, PA 17110 12 SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed d notice ms to be mated) CUMBERLAND COUNTY SHERIFF SPACE BELOW FOR USE OF THE SHERIFF - DO Wt - MLOW THIS LME 11 1 acknowledge receipt of the writ 14. DATE RECEIVED 15 Expiration/Hearing Date or complaint as indicated above. M.1 M r r t I I Y r S n a i 2 6/ 2 n n h 5/24/2006 16. HOW SERVED PERSONAL SIDENCE POSTED( ) POE ( ) SHERIFFS OFFICE ( ) OTHER( ) SEE REMARKS BELOW IT O I hereby certitf and r n O D use I am unable to locate the individual, company, etc named above. (See remarks below.) NAME AND AL E LIST DRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendang 19 a of nice 20 Ti ervice r ? ion a 6 1 EMPTS Date Time M' s nt. D e Int Date Time Miles Int. Date Time Mies h* Date Time iles Int Dale Time Miles Int. 22 23. Advance Costs 21 ice Costs 25. N/F 26 Mileage 127 Postage 28 Sub Tula 29. Pound 30 NOINY 31. Surchg. 32 Tot. Cost 33 Costs Due Refund heck No $100.00 3 LA ,3 .3 28:3 .co 34. Foreign County Costs 35 Advance Costs 36 Service Costs 37 NotaryCert. 38. Mieage/Posu g~ Found 39 Total Coils 40 Costs Due or Refund 41. AFFIRI [ED ttl7Yt/WW a time"`?' 1113 42. day of . 20 LISA L. BOWMA , N v RY CITY OF YORK, YORK COUNTY MY COMMISSION EXPIRES AUG. 12, 2009 S 41. Signat of . -? r 45c r, Dep. S (p 46. Signature Y 47 DATE County Sheriff William ose Sh if 'f Je _ 5/16/06 48 Signature of Foreign 49 DATE 10. TELEPHONE NUMBER 11 DATE FILED 717-232-9900 4/24/2006 4 WILLIAM M. HICKS TRUCKING COMPANY, INC. Plaintiff, V. STAR TRANSPORT, INC., AND ANTHONY ST. GEORGE REID Defendants. TO: Anthony St. George Reid 1880 Austin Lane York, PA 17404 DATE OF NOTICE: November 20, 2006 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA NO. 05-6746 CIVIL ACTION - LAW JURY TRIAL DEMANDED IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 WILLIAM M. HICKS TRUCKING COMPANY, INC. Plaintiff, Vi. STAR TRANSPORT, INC., AND ANTHONY ST. GEORGE REID Defendants. A: Anthony St. George Reid 1880 Austin Lane York, PA 17404 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA NO. 05-6746 CIVIL ACTION - LAW JURY TRIAL DEMANDED FECHA DEL AVISO: November 20, 2006 AVISO IMPORTANTE USTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARECENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA LISTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y LISTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 . .. CERTIFICATE OF SERVICE AND NOW, this -16 day of November, 2006, 1 hereby certify that a copy of the foregoing NOTICE OF DEFAULT JUDGMENT was served upon the following via certified and regular mail: Anthony St. George Reid 1880 Austin Lane York, PA 17404 Star Transport Inc. c/o Gary N. Stewart, Esquire Rawle & Henderson, LLP 25 North Front Street, Floor 1 Harrisburg, PA 17101 Nicole M. Werner, Esquire RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Jeffrey C. Mickletz Identification No.: 87531 25 North Front Street, First Floor Attorneys for Defendants, Harrisburg, Pennsylvania 17101 Star Transport, Inc. and (717) 234-7700 Anthony St. George Reid WILLIAM HICKS TRUCKING COURT OF COMMON PLEAS OF COMPANY, INC. CUMBERLAND COUNTY Plaintiff, vs. NO: 05-6746 STAR TRANSPORT, INC. and ANTHONY ST. GEORGE REID Defendants. ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance on behalf of defendant, Anthony St. George Reid, in the above-referenced matter. Date: 414106 RAWLE & HENDERSON LLP By: Gay N. S ,*wart, Esquire effrey . Mickletz, Esquire Att ey for Defendants, tar Transport, Inc. Anthony St. George Reid 1401155 v.1 a CERTIFICATE OF SERVICE I hereby certify that on today's date, a true and correct copy of the foregoing entry of appearance was served by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Casey G. Shore, Esquire Nealon Gover & Perry 2411 North Front Street, Harrisburg, PA 17110 RA By: Date: 1401155 v.l f? ? '? ?? x ?? '^Ct r is ;(? r^a '?. ?? ?? .? i ?a s 'w RAWLE & HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 By: Andrew D. Zeiter Identification No.: 93601 Payne Shoemaker Building 240 N. Third Street, 9ch Floor Attorneys for Defendants, Harrisburg, Pennsylvania 17101 Star Transport, Inc. and 17) 234-7700 Anthony St. George Reid WILLIAM HICKS TRUCKING COURT OF COMMON PLEAS OF COMPANY, INC. CUMBERLAND COUNTY Plaintiff, VS. NO: 05-6746 STAR TRANSPORT, INC. and ANTHONY ST. GEORGE REID Defendants. TO THE PROTHONOTARY: WITHDRAWAL OF APPEARANCE Kindly withdraw the appearance of Jeffrey C. Mickletz, Esquire as co-counsel for the defendants, Star Transport, Inc. and Anthony St. George Reid, in the above-captioned action. RAWLE & HENDERSON LLP By: 7 _ e rey C. Mickletz, Esquire ttomey for Defendants, Star Transport, Inc. and Anthony St. George Reid ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter Andrew D. Zeiter, Esquire as co-counsel with Gary N. Stewart, Esquire on behalf of the defendants, Star Transport, Inc. and Anthony St. George Reid, in the above-captioned action. RAWLE & HENDERSON LLP 67 B Gary N. Stewart, Andrew D. Zeiter, squire Attorneys for Defendants, Star Transport, Inc. and Date: Anthony St. George Reid 2022025-1 . , y CERTIFICATE OF SERVICE I hereby certify that on today's date, a true and correct copy of the foregoing withdrawal/entry of appearance was served by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Casey G. Shore, Esquire Nealon Gover & Perry 2411 North Front Street, Harrisburg, PA 17110 Date: RAWLE & HENDERSON LLP By. ::a?7` An-drew D. Zeiter 2022025-1 -rs co 16 WILLIAM M. HICKS TRUCKING : IN THE COURT OF COMMON PLEAS COMPANY, INC. : CUMBERLAND COUNTY PENNSYLVANIA Plaintiff, V. : NO. 05-6746 STAR TRANSPORT, INC., AND : CIVIL ACTION - LAW ANTHONY ST. GEORGE REID o Defendants. : JURY TRIAL DEMANDED,- ca - -tr -n PETITION TO WITHDRAW AS COUNSEL 1. James G. Nealon, III, Esquire is counsel of record for Plaintiff, William M. Hic ts? Trucking Company, Inc., in the above captioned matter. 2. Effective February 1, 2010, Attorney Nealon will be taking an in-house legal position with the Erie Insurance Company. The position will prevent Attorney Nealon from continuing to represent the Plaintiff in the matter. 3. No hearing or other proceedings are currently scheduled in the above captioned matter. 4. No prejudice will result to Plaintiff in permitting Attorney Nealon to withdraw as counsel of record. 5. Attorney has notified Plaintiff of his new employment. A copy of the correspondence is attached hereto and incorporated herein by reference as Exhibit "A". WHEREFORE, Petitioner, James G. Nealon, III, urges this Honorable Court to permit him to withdraw as counsel of record for the Plaintiff. Date:.. Respectfully submi NEALON PC ..l t By: James G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 NEALON LAW FIRM, P.C. James G. Nealon, III 2411 North Front Street Attorney at Law Harrisburg, PA 17110 (717) 232.9900 Fax: (717) 236.9119 jnealonenealon-law.com January 28, 2010 101 South Duke Street William M. Hicks York, PA 17401 William M. Hicks Trucking Company, Inc. (717) 852.7888 10252 Pleasant Hollow Road Tyler, Texas 75709 RE: William M. Hicks Trucking Company Inc. v. Star Transport, Inc., and Anthony St. George Reid Cumberland County Court of Common Pleas Docket No. 05-6746 Dear Mr. and Mrs. Hicks: As you are aware, our office has been representing you in the law suit against Star Transport. Please be advised that I am taking an in-house legal position with an insurance company which will prevent me from. handling private legal matters. You will have to retain new counsel regarding this law suit. I can keep your file and make it available to the attorney that you retain. You were referred to our office through your contract with Pre-paid Legal Services; therefore, you need to contact them to get another referral. I am required to file a Petition to Withdraw as Counsel, a copy of which is enclosed herewith. If you have any questions regarding this, please do not hesitate to call. Very truly N Enclosure EXHIBIT "A" James G. Nealon, III WILLIAM M. HICKS TRUCKING COMPANY, INC. Plaintiff, V. STAR TRANSPORT, INC., AND ANTHONY ST. GEORGE REID Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA . NO. CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this day of January, 2010, 1 hereby certify that a copy of the foregoing Withdrawal of Appearance was served upon the following via First Class US Postal Service. Star Transport, Inc. 240 Ashland Avenue P.O. Box 909 Morton, Illinois, 61550 William M. Hicks William M. Hicks Trucking Company, Inc. 10252 Pleasant Hollow Road Tyler, Texas 75709 James G. Nealon, III t James G. Nealon, III, Esquire Attorney ID No. 46457 P.C. Box 771 Hummelstown, PA 17036 inealon(aD-nealon-law.com WILLIAM M. HICKS TRUCKING COMPANY, INC. Plaintiff, V. STAR TRANSPORT, INC., AND ANTHONY ST. GEORGE REID Defendants. 2010 FEB 17 All 11: 51 C' rr FEB 16 2010 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA NO. 05-6746 CIVIL ACTION - LAW JURY TRIAL DEMANDED RULE TO SHOW CAUSE AND NOW, this day of F 0A tQ O t 2010, upon consideration of James G. Nealon, III, Petition to Withdraw as Counsel, iT IS HEREBY ORDERED that a Rule is hereby issued upon all parties to show cause, if any, why the requested relief should not be granted. Rule returnable within 10 days of service. BY THE COURT: Distribution: ./J?es G. Nealon, III, P.O. Box 771, Hummelstown, PA 17036 S r Transport, Inc. 240 Ashland Avenue, Morton, IL 61550 /illiam M. Hicks, 10252 Pleasant Hollow Road, Tyler, TX 75709 ?'tZ f ca FILED---?Fl Cc 2 IN THE COURT OF COMMON PLS (LP CUMBERLAND COUNTY, PENNS , AN M - WILLIAMS HICKS TRUCKING COMPANY, INC., ° ' Plaintiff NO.05-6746 - ' vs. ?mot ,.n STAR TRANSPORT, INC. and ANTHONY ST. GEORGE REID, Defendant RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in the Following form: PETITION FOR APPOINTMENT OF ARBITRATORS '` TO THE HONORABLE, THE JUDGES OF SAID COURT: sb31 O Herbert P. Henderson, II, Esquire counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $ 30,000 The counterclaim of the defendant in the action is none The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Herbert P. Henderson, II, Esquire, Gary N. Stewart, Esquire, and Andrew D. Zeiter, Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, ORDER OF COURT AND NOW, petition, 200 , in consideration of the foregoing Esq., and Esq., and captioned action (or actions) as prayed for. Esq., are appointed arbitrators in the above By the Court, Kevin A. Hess, P.J. CERTIFICATE OF SERVICE I, Herbert P. Henderson, II, Esquire, do hereby certify that on this the 18th day of November, 2010, I served a true and correct copy of the foregoing Petition for Appointment of Arbitrators by United States First Class Mail, postage prepaid, addressed as following: Gary N. Stewart, Esquire Andrew D. Zeiter, Esquire Rawle & Henderson, LLP 240 N. Third Street, 9t' Floor Harrisburg, PA 17101 Date: November 18, 2010 Herbert P. Henderson, II, Esquire PA ID No.: 56304 Pecht & Associates, P.C. 1205 Manor Drive Suite 200 Mechanicsburg, PA 17055 (717) 691-9808 Attorney for Plaintiff 4 WILLIAMS HICKS TRUCKING COMPANY, INC., Plaintiff . vs. STAR TRANSPORT, INC. and ANTHONY ST. GEORGE REID, IN THE COURT OF COMMON PLOS QP CUMBERLAND COUNTY, PENNSYI::VATgA NO.05-6746 20 Defendant RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in the Following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Herbert P. Henderson, II, Esquire , counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. The claim of plaintiff in the action is $ 30,000 The counterclaim of the defendant in the action is none Respectfully submitted, ORDER OF COURT d-R ?'1`l' •so3l AND NOW, L" P nt h_9AJ 1 92006 , iq-consideration of the foregoing petition, A- ta- Esq., and _ ._ .9::p 14M Esq., and Esq., are appointed arbitrators incthe apve.? c Q ?? captioned action (or actions) as prayed for. M r?7 Lg.S isJ- -, .ter By the Court, r- I CD?d --I ' -rl A+ 41. I/ _-? x F5 Kevin .Hess, P.J. Q`'i 000 -3 Z c r\) C:) f ?. ? ? `C CJl ? The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Herbert P. Henderson, Il, Esquire, Gary N. Stewart, Esquire, and Andrew D. Zeiter, Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. CERTIFICATE OF SERVICE I, Herbert P. Henderson, II, Esquire, do hereby certify that on this the 18th day of November, 2010, I served a true and correct copy of the foregoing Petition for Appointment of Arbitrators by United States First Class Mail, postage prepaid, addressed as following: Gary N. Stewart, Esquire Andrew D. Zeiter, Esquire Rawle & Henderson, LLP 240 N. Third Street, 9 h Floor Harrisburg, PA 17101 Date: November 18, 2010 ?--- Herbert P. Henderson, II, Esquire PA ID No.: 56304 Pecht & Associates, P.C. 1205 Manor Drive Suite 200 Mechanicsburg, PA 17055 (717) 691-9808 Attorney for Plaintiff WILLIAM HICKS TRUCKING : IN THE COURT OF COMMON PLEAS OF COMPANY, INC. : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • vs. : CIVIL ACTION - LAW .-d3 —� : NO. 05-6746 CIVIL z rti i -` STAR TRANSPORT, INC. and : 11E73' ° ANTHONY ST. GEORGE REID, : Defendants : <c' ,p. >(--) a 4.2_.! ORDER Cli AND NOW, this Z 1 day of April, 2013, the appointment of a Board of Arbitrators in the above-captioned case is VACATED. BY THE COURT, , `741°/- Kevin Hess, P. J. V William Costopoulos, Esquire V Thomas A. Capper, Esquire ✓ Eric R. David, Esquire Court Administrator :rim Ldpr C3 /?'t,CL•/e7( 430 WILLIAM HICKS TRUCKING : IN THE COURT OF COMMON PLEAS OF c COMPANY, INC. : CUMBERLAND COUNTY, PENNSYLVANJ Plaintiff cc+ +. 1` • Cnr- CO 1C • vs. : CIVIL ACTION - LAW ter ` : NO. 05-6746 CIVIL =c; - - STAR TRANSPORT, INC. and v co ANTHONY ST. GEORGE REID, : -� Defendants ORDER AND NOW, this 2"' day of April, 2013, in consideration of the attached letter, Ron Turo, Esquire; Mark Mateya, Esquire; and Seth Moseby, Esquire, are appointed arbitrators in the above-captioned action. BY THE COURT, /V4Z Kevin A. ess, P. J. ✓` Ron Turo, Esquire Court Administrator :rlm ref% ma, '// '2'3 pv1 PECHT&ASSOCIATES, PC Suite 200 1205 Manor Drive Mechanicsburg, PA 17055 Wayne M. Pecht Telephone: 717-691-9808 Member of California Bar Fax: 717-691-2070 CPA/LLM in Taxation www.pechtlaw.com wpecht @pechtlaw.com Rob Bleecher April 11, 2013 The Honorable Kevin A. Hess, President Judge Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Re: William Hicks Trucking Company, Inc. v Star Transport, Inc. and Anthony St. George Reid Cumberland County Court of Common Please Docket No.: 05-6746 Dear Judge Hess: On December 1, 2010 you signed an Order of Court appointing Williams Costopoulos, Thomas A Cooper, and Eric R. David, Arbitrators with regard to the above-referenced matter. Mr. Costopoulos has been involved in lengthy litigation both in Allegheny and Dauphin counties, and this arbitration has never been scheduled. William Hicks, our client, would like to move this matter forward to arbitration. We respectfully request that you vacate the current Order, a copy of which is enclosed for your reference, and appoint a new arbitration panel at your convenience. The Honorable Kevin A. Hess, President Judge April 11, 2013 Page 2 If you have any questions, please call me. Thank you for your anticipated cooperation. Very truly yours, PECHT &ASSOCIATES, P.C. Wayne M. cht WMP/gf Enclosure cc: William Costopoulos, Esquire (w/encl.) Thomas A. Cooper (w.encl.) Eric R. David(w/encl.) Gary N. Stewart, Esquire (w/encl.) Andrew D. Zeiter, Esquire (w/encl.) : IN THE COURT OF COMMON PLEAS OF , . CUMBERLAND COUNTY,PENNSYLVANIA WILLIAMS HICKS TRUCKING COMPANY,INC., Plaintiff : NO.05-6746 20 VS. . STAR TRANSPORT,INC.and ANTHONY ST.GEORGE REID, Defendant RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in the Following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Herbert P. Henderson, II, Esquire , counsel for the plaintiff/defendant in the above action(or actions), respectfully represents that: 1. The above-captioned action(or actions)is(are)at issue. 2. The claim of plaintiff in the action is $30,000 The counterclaim of the defendant in the action is none The following attorneys are interested in the case(s)as counsel or are otherwise disqualified to sit as arbitrators: Herbert P. Henderson,II, Esquire, Gary N. Stewart, Esquire, and Andrew D. Zeiter,Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three(3)arbitrators to whom the case shall be submitted. Respectfully submitted, ORDER OF COURT AND NOW,-1 e_yleit._ I , 2096 , in consideration of the foregoing petition, LO<tlt*Iv ', �05 Esq., and (---g �5 D. c Esq., and 321 , � Esq., are appointed arbitrators in the above captioned action (or actions)as prayed for. By the ourt, Q Kevin A.Hess,P.J. RAWLE & HENDERSON LLP By: Gary N. Stewart >t r. Identification No.: 67353 Payne Shoemaker Building �.. D ��� 240 N. Third Street, 9th Floor Attorneys for'>sddrit/arrts t '4 1 r Harrisburg, Pennsylvania 17101 Star Transport, Inc. and (717)234-7700 Anthony St. George Reid WILLIAM HICKS TRUCKING • COURT OF COMMON PLEAS OF COMPANY, INC. • CUMBERLAND COUNTY Plaintiff, • vs. • NO: 05-6746 STAR TRANSPORT, INC. and ANTHONY ST. GEORGE REID • Defendants. • MOTION FOR LEAVE OF COURT OF RAWLE & HENDERSON LLP FOR LEAVE OF COURT TO WITHDRAW AS COUNSEL FOR STAR TRANSPORT,INC. AND ANTHONY ST. GEORGE REID Rawle & Henderson LLP hereby requests leave of Court pursuant to Rule 1012 to withdraw as counsel for defendant, Star Transport, Inc. and Anthony St. George Reid in the above-captioned matter. In support thereof, counsel has not received any contact from Anthony St. George Reid from approximately July, 2007. Furthermore, Star Transport, Inc. does not respond to communications for assistance in the above-captioned matter. The last known address for Anthony St. George Reid was 1880 Alston Lane, York, PA, 17404 and Star Transport, Inc., upon information and belief, does business at 240 Ashland Avenue, P.O. Box 909, Morton, IL, 61550. Counsel hereby certifies that notice in accordance with Rule 440 has been served on Anthony St. George Reid and Star Transport, Inc. On Star Transport, Inc. was made by regular mail, facsimile and email. Respectfully submitted, 6657985-1 RAWLE & HENDERSON L By: r <�� Gary N. Stewart, Esquire Attorneys for Defendants, `7 Star Transport, Inc. and Date: 2'� Anthony St. George Reid 6657985-1 CERTIFICATE OF SERVICE I hereby certify that on today's date, a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon all attorneys of record, addressed as follows: Mr. Anthony St. George Reid 1880 Austin Lane York, PA 17404 Star Transport, Inc. P.O. Box 909 Morton, IL 61550 Rob Bleecher, Esquire Pecht and Associates, P.C. 1205 Manor Drive, Suite 200 Mechanicsburg, PA 17055 Attorney for Plaintiff RAWLE & HENDERSON LLP r, ,--9 ij//r By. Gary. Stewart, Esquire Attorneys for Defendants, Star Transport, Inc. and Date: 7 Z-J/� j 3 Anthony St. George Reid 6657985-1 RAWLE &,HENDERSON LLP By: Gary N. Stewart Identification No.: 67353 Payne Shoemaker Building 240 N.Third Street, 91h Floor Attorneys forlDefendants, Harrisburg,Pennsylvania 17101 Star Transport,Inc. and (717)234-7700 Anthony St. George Reid WILLIAM HICKS TRUCKING COURT OF COMMON PLEAS OF COMPANY, INC. CUMBERLAND COUNTY Plaintiff, i VS., NO: 05-6746 STAR TRANSPORT, INC. and ANTHONY ST. GEORGE REID Defendants. ORDER AND NOW, this I S}day of 2013, it is hereby ORDERED and DECREED that the Motion of Rawle & Henderson LLP for Leave of Court to withdraw as counsel for defendants, Anthony St. George Reid and Star Transport, Inc. in the above-captioned I matter is hereby GRANTED. Counsel in accordance with Rule 1012 will notify both Anthony St. George Reid and Star Transport, Inc. by ordinary mail of this Order.. i r-- c�n Dated: _ Z: � CD �. 6657985-1 J Wayne M. Pecht, Esquire Attorney I.D.No. 38904 Rob Bleecher, Esquire `` AUG _ Attorney I.D.No. 32594 `ry11M3 -, 'r 1 ;v J I Pecht&Associates, P.C. PENNSYLVANIA 650 North Twelfth Street, Suite 100 Lemoyne,PA 17043 (717)691-9808 Attorneys for Plaintiff WILLIAM M. HICKS TRUCKING : IN THE COURT OF COMMON PLEAS COMPANY, INC. : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff • v. : No.: 05-6746 — CIVIL STAR TRANSPORT, INC. and • ANTHONY ST. GEORGE REID Defendants ENTRY OF APPEARANCE To: David D. Buell, Prothonotary Please enter the appearances of Wayne M. Pecht, Esquire and Rob Bleecher, Esquire, of Pecht & Associates, P.C., as counsel for Plaintiff, William M. Hicks Trucking Company, Inc., in the above-captioned matter. Respectfully Submitted, PECHT& ASS ' PATES. P.C. Dated: August 7, 2013 B : g Y Wayne". Pec t, Esquire Attorney I.D. No. 38904 Rob Bleecher, Esquire Attorney I.D. No. 32594 650 North Twelfth Street, Suite 100 Lemoyne, PA 17043 (717) 691-9808 Attorneys for Plaintiff CERTIFICATE OF SERVICE I, Rob Bleecher, Esquire, the attorney for Plaintiff, hereby certify that I have served the foregoing document this date by depositing a true and correct copy of the same in the United States mail, first-class postage prepaid, addressed as follows: Star Transport, Inc. 240 Ashland Avenue P.O. Box 909 Morton, IL 61550 Anthony St. George Reid 32 Cottonwood Building Middletown, PA 17057 411110 Dated: August -7 , 2012 �® Rob 3leecher, Esquire WILLIAM M. HICKS TRUCKING IN THE COURT OF COMMON PLEAS COMPANY, INC. CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No.: 05-6746 — CIVIL STAR TRANSPORT, INC. and ANTHONY ST. GEORGE REID Defendants ORDER AND NOW, this L 8` day of Arw9 �' , 2013, the appointment of the Board of Arbitrators in the above-captioned case is VACATED. BY THE COURT, Kevin ess, P.J. /Rob Bleecher, Esquire j/Ron Turo, Esquire �✓ Mark A. Mateya, Esquire Seth T. Mosebey, Esquire Court Administrator C. r`PS ji4a P C-) 'Er rnq)= �� N CD < 31- r =C:) WILLIAM HICKS TRUCKING IN THE COURT OF COMMON PLEAS OF COMPANY, INC. CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. CIVIL ACTION - LAW NO. 05-6746 CIVIL STAR TRANSPORT, INC. and ANTHONY ST. GEORGE REID, Defendants IN RE: BOARD OF ARBITRATORS ORDER AND NOW, this 30' day of August, 2013, the Prothonotary is directed to pay the Chairman of the Board of Arbitrators, Ron Turo, Esquire,the sum of$50.00. BY THE COURT, 7i Kevi . Hess, P. J. Ron Turo, Esquire /'Court Administrator :rlm �►Q�y ma led <-'130113 M C=