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HomeMy WebLinkAbout06-0279 MENKA KAYAN and NEERAJ DEORAH, her husband, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. CIVIL ACTION - LAW NO. 0(" - ;;2 "/9 CI{.J~L '-r~ PATRICIA NORMAN Defendant. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AVISO USTED HA smo DEMANDADO / A EN CORTE, Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, de be tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso radicando personalmente 0 por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya, Se Ie advierte de que si usted faHa de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un faHo por cualquier suma de dinero reclamada en la demanda 0 cualquier otra reclamaci6n 0 remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero 0 propiedad u otros derechos importantes para usted. 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 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 0 BAJO COSTO A PERSONAS QUE CUALIFICAN, CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 MENKA KAYAN and NEERAJ DEORAH, her husband, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. CIVIL ACTION - LAW Defendant. NO.O/.. - 02.'79 C;u~L'I~ PATRICIA NORMAN JURY TRIAL DEMANDED COMPLAINT AND NOW, come the Plaintiffs, Menka Kayan and Neeraj Deorah, by and through their attorneys, SCHMIDT, RONCA & KRAMER, P,C., and respectfully set forth as follows: 1, Plaintiffs Menka Kayan and Neeraj Deorah are adult individuals, husband and wife, currently residing at 5 Robin Court, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2, Defendant Patricia Norman is an adult individual whose last known address is 40 N. Old Gettysburg Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 3, The facts and events hereinafter stated took place on or about 8:42 a,m, on October 6, 2004, at the intersection of East Main Street and South Locust Street in Shiremanstown, Cumberland County, Pennsylvania, 4. At the aforementioned time and place, PlaintiJf Menka Kayan was a passenger in a vehicle traveling East on East Main Street, which was approaching the intersection with Locust Street. 5, At the aforementioned time and place, Defendant Patricia Norman was stopped on Locust Street at the intersection with East Main Street, waiting to make a left turn. 6. The collision occurred when Defendant Patricia Norman failed to observe the vehicle in which Plaintiff Menka Kayan was a passenger and pulled out onto East Main Street. 7, The driver of Plaintiff Menka Kayan's vehicle attempted to swerve around the Defendant's vehicle, but did not clear it and was struck in the right rear of the vehicle, This caused the vehicle in which Plaintiff Menka Kayan was a passenger to strike a third vehicle, which in turn collided with another vehicle. 8, The collision caused the injuries to the Plaintiffs as set forth below, COUNT I MENKA KAYAN v. PATRICIA NORMAN NEGLIGENCE 9, Paragraphs 1 through 8 of the Plaintiff's complaint are incorporated herein by reference and made a part thereof as if set forth in full, 10, The accident was caused by the negligence and carelessness of Defendant Patricia Norman and was in no way caused or contributed to by Plaintiff Menka Kayan, 11. The negligence and carelessness of Defendant Patricia Norman consisted of the following: a, inattentiveness; b, distraction; c, failing to have her vehicle under proper and adequate control; d, negligently applying the brakes; e, failing to apply the brakes in time to avoid the collision; f. failing to observe the vehicle in which Menka Kayan was a passenger and that was lawfully on the roadway; g, operating the vehicle at an excessive rate of speed under the circumstances; h, failing to operate the vehicle in accordance with existing traffic conditions and traffic controls; I. failing to keep a reasonable lookout for other vehicles lawfully on the roadway; and j, operating her vehicle so as to create a dangerous situation for other vehicles on the roadway, 12, As a factual result of the accident, Plaintiff Menka Kayan suffered injuries which are severe and what are believed to be permanent, which include the following: a, severe neck pain; b, low back pain; c, upper back pain; d, contusion; e, left knee pain; f, ecchyomosis of her left calf; and g, chonromalacia of her left patella, 13, As a factual result of the accident, Plaintiff Menka Kayan, has incurred medical expenses to date and will continue to incur medical expenses into the future, and thus, a claim for these expenses is made, 14, As a factual result of the accident, Plaintiff Menka Kayan has been advised and, therefore avers, that the aforementioned injuries may be permanent in nature and effect and, thus, a claim for these injuries is made, 15, As a factual result of the accident, Plaintiff Menka Kayan has undergone in the past, and will continue to undergo in the future, great pain and suffering, and thus, a claim for these injuries is made, 16, As a factual result of the accident, Plaintiff Menka Kayan has been obliged to spend various sums of money and to incur various expenses for the injuries that she has suffered and may continue to incur the same in the future, and thus, a claim for these losses is made, 17, As a factual result of the accident, Plaintiff Menka Kayan suffered a loss of earnings and an impairment of her earning power and capacity in the future, and thus, a claim for these losses is made, 18, As a factual result of the accident, Plaintiff Menka Kayan suffered a permanent diminution of her ability to enjoy life and life's pleasures, and thus, a claim for these losses is made, WHEREFORE, Plaintiff Menka Kayan demands judgment on Defendant Patricia Norman, in an amount in excess of an amount requiring compulsory arbitration, COUNT II NEERAJ DEORAH V. PATRICIA NORMAN LOSS OF CONSORTIUM 19, Paragraphs 1 through 18 of the Plaintiffs' Complaint are incorporated herein by reference and made a part thereof as if set forth in full. 20, Plaintiff Neeraj Deorah has suffered from the loss of services and companionship and consortium of his wife, Plaintiff Menka Kayan as a factual result of the negligence of Defendant Patricia Norman, WHEREFORE, Plaintiff Neeraj Deorah demands judgment on Defendant Patricia Norman, in an amount in excess of an amount requiring compulsory arbitration, Respectfully submitted, SCHMIDT, RONCA & KRAMER, P.C. DATED: /IIU /()& e---- rard C, Kramer Attorney at Law LD, no, 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs VERIFICATION BASED UPON PERSONAL KNOWLEDGE AND INFORMATION OBTAINED THROUGH COUNSEL I, MENKA KAYAN, verify that I am the Plaintiff in the foregoing action and that the attached Complaint is based upon information which has been gathered by my counsel in the preparation of this lawsuit, The language of the Complaint to the extent that it is based upon information that I have given to my counsel is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the Complaint are that of counsel, I relied upon counsel making this Verification, I understand that intentional false statements herein are subject to the penalties of 18 Pa, C,S,A, 84904 relating to unsworn falsifications to authorities, Date: O{ 0(" 06 J'1~. --- MENKA KAY AN VERIFICATION BASED UPON PERSONAL KNOWLEDGE AND INFORMATION OBTAINED THROUGH COUNSEL I, NEERAJ DEORAH, verify that I am the Plaintiff in the foregoing action and that the attached Complaint is based upon information which has been gathered by my counsel in the preparation of this lawsuit, The language of the Complaint to the extent that it is based upon information that I have given to my counsel is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the Complaint are that of counsel, I relied upon counsel making this Verification, I understand that intentional false statements herein are subject to the penalties of 18 Pa, C.S,A, 94904 relating to unsworn falsifications to authorities, Date: 6//0' r 06 w-j}<-.oodl NEERAJ DEORAH ~ .jq. 7:J ~ lrt \l "- ~ V't - ~ 0 ~ ~ F! r;, ~~ ~,! '-) : 'T1 ',,": --1 (,,- ~'!~.. p t ~ . '_.~ , n~~ l'.J J,; {;'? - ":< ~,; L 8 SHERIFF'S RETURN - REGULAR CASE NO: 2006-00279 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND KAYAN MENKA ET AL VS NORMAN PATRICIA SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon NORMAN PATRICIA the DEFENDANT , at 1825:00 HOURS, on the 23rd day of January 2006 at 4010 OLD GETTYSBURG ROAD CAMP HILL, PA 17011 by handing to PATRICIA NORMAN a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof, Sheriff's Costs: Docketing Service Postage Surcharge 18,00 12.32 .39 10.00 .00 40.71 So Answers: ~g~~<.,(~::~.J R. Thomas Kline , 30F 01/24/2006 SCHMIDT RONCA KRAMER By: (' i (// ) ~~~'~tj~he4(if/ Sworn and Subscribed to before me this day of Johnson, Duffie, Stewart & Weidner By: Jefferson J, Shipman, Esquire I.D, No, 51785 301 Market Street P,O, Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com (717) 761-4540 MENKA KAYAN and NEERAJ DEORAH, her husband, Plaintiff v, PATRICIA NORMAN, Defendant Attorney for Defendant IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 06-279 CIVIL TERM JURY TRIAL DEMANDED NEW MATTER NOTICE TO: Gerard C, Kramer, Esquire Schmidt, Ronca & Kramer 209 State Street Harrisburg, PA 17101 Attorneys for Plaintiffs YOU ARE REQUIRED to plead to the within Answer and New Matter within 20 days of s service hereof or a default judgment may be entered against you, DATE: :J-/I'-0v:..: ,'L./(., '-1~!- erson J, Shipman, Esq re ,#: 51785 301 Market Street P,O, Box 109 Lemoyne, PA 17043-0109 Attorneys for Defendant Johnson, Duffie, Stewart & Weidner By: Jefferson J, Shipman, Esquire 1.0, No, 51785 301 Market Street P,O, Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com (717) 761-4540 MENKA KAYAN and NEERAJ DEORAH, her husband, Plaintiff Attorney for Defendant v, IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 06-279 CIVIL TERM PATRICIA NORMAN, Defendant JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANT. PATRICIA NORMAN AND NOW, comes the Defendant, Patricia Norman, by and through her counsel, Johnson, Duffie, Stewart & Weidner, and Jefferson J, Shipman, Esquire, and files the following Answer and New Matter to Plaintiffs' Complaint: 1, Denied, after reasonable investigation, Ms, Norman is without sufficient knowledge or information to form a belief as to the truth of the averments in Paragraph 1 and the same are therefore denied, 2, Admitted, except as to the address, 3, Admitted, 4, Admitted, 5, Admitted.. 6, Denied, The averments contained in Paragraph 6 are conclusions of law and fact to which no response is required, If a response is deemed to be required, the averments contained therein are specifically denied, 7, Admitted in part, denied in part, It is admitted that there was contact between the vehicles, After reasonable investigation, Mrs, Norman is without sufficient knowledge or information to form a believe as to the truth of the remaining averments of Paragraph 7, relating to what the Kayan vehicle attempted to do, and the same are therefore denied, 8, Denied, After reasonable investigation, Mrs, Norman is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 8, relating to Plaintiff's alleged injuries, and the same are therefore denied, COUNT I MENKA KAVAN v, PATRICIA NORMAN NEGLIGENCE 9, Mrs, Norman incorporates herein by reference her answers to 1 through 8 above as though fully set forth herein at length, 10, Denied, The averments contained in Paragraph 10, are conclusions of law and fact to which no response is required, If a response is deemed to be required, the averments contained therein are specifically denied, 11, Denied, The averments contained in Paragraph 11, and subparagraphs a, through j" are conclusions of law and fact to which no response is required, If a response is deemed to be required, the averments contained in Paragraph 11 and each and every subparagraph. a, through j,. are denied and strict proof thereof demanded at the time of trial. 12, Denied, After reasonable investigation Mrs, Norman is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 12 and subparagraphs a, through g" relating to Plaintiff's alleged injuries and the same are therefore denied and strict proof demanded at the time of trial, 13, Denied, After reasonable investigation Mrs, Norman is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 13 and the same are therefore denied and strict proof demanded at the time of trial. 14, Denied, After reasonable investigation Mrs, Norman is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 14 and the same are therefore denied and strict proof demanded at the time oftrial. 15.. Denied, After reasonable investigation Mrs, Norman is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 15 and the same are therefore denied and strict proof demanded at the time of trial. 16, Denied, After reasonable investigation Mrs, Norman is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 16 and the same are therefore denied and strict proof demanded at the time of trial. 17, Denied, After reasonable investigation Mrs, Norman is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 17 and the same are therefore denied and strict proof demanded at the time oftrial. 18, Denied, After reasonable investigation Mrs, Norman is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 18 and the same are therefore denied and strict proof demanded at the time of trial. WHEREFORE, the Defendant, Patricia Norman, respectfully requests that judgment be entered in her favor and that Plaintiffs' Complaint be dismissed with prejudice, COUNT II NEERAJ DEORAH v, PATRICIA NORMAN LOSS OF CONSORTIUM 19, Mrs, Norman incorporates herein by reference her answers to 1 through 18 above as though fully set forth herein at length, 20, Denied, The averments contained in Paragraph 20, are, in part, conclusions of law and fact to which no response is required, After reasonable investigation Mrs, Norman is without sufficient knowledge or information to form a belief as to the truth of the remaining averments contained in Paragraph 20 and the same are therefore denied and strict proof demanded at the time of trial. WHEREFORE, the Defendant, Patricia Norman, respectfully requests that judgment be entered in her favor and that Plaintiffs' Complaint be dismissed with prejudice, NEW MATTER By way of additional answer and reply, the Defendant, Patricia Norman, interposes the following New Matter defenses: 21, That the Plaintiff's alleged cause of action may be barred in whole or in part by the Pennsylvania Motor Vehicle Financial Responsibility Law, 22, That the Plaintiff's alleged cause of action may be barred in whole or in part by the Pennsylvania Comparative Negligence Act. 23, That the Plaintiffs alleged cause of action may have been caused by third parties or entities not presently involved in this action, 24, That the accident may have been unavoidable, 25, That the Plaintiffs may have failed to mitigate their damages, 26, That the Plaintiffs' alleged injuries and damages may have been pre- existing, WHEREFORE, the Defendant, Patricia Norman, respectfully requests that judgment be entered in her favor and that Plaintiffs' Complaint be dismissed with prejudice, Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER DATE: J) (L/ jer; 268844 ' ,Byu _ - 1Ad..t.A...- J fferson J. Ship an, Esquire ttorneys 1.0, #: 51785 301 Market Street P,O, Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com Attorneys for Defendant VERIFICATION I, Patricia Norman, have read the foregoing Answer with New Matter and hereby affirm that it is true and correct to the best of my personal knowledge, or information and belief, This Verification and statement is made subject to the penalties of 18 Pa, C,S, ~4904 relating to unsworn falsification to authorities; I verify that all the statemints made in tforegOing are true ,-- I ] and correct and that false statements may subject mito re penalties of 1 Pa, C,S, ~4804, / I ~/;~ L/ i~ ULf' {~~,' ~~___/ Patricia Norman DATE: 268851 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on .9 / /'-f JOe" I ( Gerard C, Kramer, Esquire Schmidt, Ronca & Kramer 209 State Street Harrisburg, PA 17101 Attorneys for Plaintiffs JOHNSON, DUFFIE, STEWART & WEIDNER B Je rson J, Shipman, Esquire I. ,#: 51785 P,O, Box 109 Lemoyne, PA 17043 Attorneys for Defendant I ' CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on IX! /1'-/ /()4cc I ( Gerard C, Kramer, Esquire Schmidt, Ronca & Kramer 209 State Street Harrisburg, PA 17101 Attorneys for Plaintiffs JOHNSON, DUFFIE, STEWART & WEIDNER , B~.-v Je rson J, Shipman, Esquire 1.,#: 51785 P,O, Box 109 Lemoyne, PA 17043 Attorneys for Defendant f-" r-.~ ~' ) " -.-: ~:j -n '-_c' ( , SCHMIDT, RONCA & KRAMER, P.C. By: Gerard C, Kramer, Esquire 209 State Street Harrisburg, PA 17101 (717) 232-6300 Fax (717) 232-6467 gkramer(cV,srklaw.com Attorneys for Plaintiffs MENKA KAYAN and NEERAJ DEORAH, her husband, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Pla.intiffs v. CIVIL ACTION - LAW PATRICIA NORMAN NO. 06-279 CIVIL TERM Defendant. JURY TRIAL DEMANDED PLAINTIFFS' ANSWER TO DEFENDANT'S NEW MATTER AND NOW, comes the Plaintiffs, Menka Kayan and Neeraj Deorah, her husband, by and through their attorneys, SCHMIDT, RONCA & KRAMER, P.C" and respectfully responds to Defendant's New Matter as follows: 21, Paragraph 21 states a conclusion of law to which no responsive pleading is necessary. 22, Paragraph 22 states a conclusion of law to which no responsive pleading is necessary, 23, Paragraph 23 states a conclusion of law to which no responsive pleading IS necessary, 24, Paragraph 24 states a conclusion of law to which no responsive pleading is necessary, 25, Paragraph 25 states a conclusion of law to which no responsive pleading is necessary, 26, Paragraph 26 states a conclusion of law to which no responsive pleading IS necessary, WHEREFORE, the Plaintiffs request that the New Matter of the Defendant be dismissed and judgment be entered in favor of the Plaintiffs. Respectfully submitted, SCHMIDT, RONCA & KRAMER, P.C. DATED: ,.;: III I Ov ~ erard C. Kramer Attorney at Law I.D, No, 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs ATTORNEY VERIFICATION I, Gerard C, Kramer, Esquire, verify that I am attorney of record for the Plaintiff. I verify that the facts contained in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that intentional false statements herein are made subject to the penalties of 18 Pa,C,S,A. 1'14904 relating to unsworn falsifications to authorities. Date: :.:;) J ( 71 OCt ---------- . CERTIFICATE OF SERVICE AND NOW, this /7fL day of F..e br-v,:Ji 'I ,2006, I, Gerard C. I Kramer, Esq" hereby certify that I have this day served a true and correct copy of the Plaintiffs' Answer to Defendant's New Matter by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Jefferson J. Shipman, Esquire Johnson Duffie 30 I Market Street Lemoyne, PA 17043-1628 Attorneys for Defendant Respectfully submitted, SCHMIDT, RONCA & KRAMER, P.C. ~ erard C. Kramer Attorney at Law Attorney I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs ~... " r.' ,-~ ", \ '-'~I .. t SCHMIDT KRAMER PC By: Gerard C. Kramer, Esquire 209 State Street Harrisburg, PA 17101 (717) 232-6300 Fax (717) 232-6467 gkramer@schmidtkramer.com Attorneys for Plaintiffs MENKA KAYAN and NEERAJ DEORAH, her husband, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. CIVIL ACTION - LAW PATRICIA NORMAN NO. 06-279 CIVIL TERM Defendant. JURY TRIAL DEMANDED PLAINTIFFS' PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Gerard C. Kramer, counsel for the Plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiff in the action is an unliquidated amount of damages and Plaintiff consents to the $35,000.00 arbitration limit. The Defendant does not have a counterclaim. The following attorneys are interested in the case as counselor are otherwise disqualified to sit as arbitrators: Gerard C. Kramer Schmidt Kramer PC 209 State Street Harrisburg, Pa 17109 Jefferson Shipman Johnson & Duffie 301 Market Street Lemoyne, Pa 17043-1628 f WHEREFORE, your Petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, SCHMIDT KRAMER PC DATED: tflJOlP ~ erard C. Kramer Attorney at Law I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs << , CERTIFICATE OF SERVICE AND NOW, this (~/Jf day of Cljo.st ,2006, I, Gerard C. Kramer, Esq., hereby certify that I have this day served a true and correct copy of the Plaintiff Petition for Appointment of Arbitrators by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Jefferson J. Shipman, Esquire Johnson Duffie 301 Market Street Lemoyne, PA 17043-1628 Attorneys for Defendant Respectfully submitted, SCHMIDT KRAMER PC /~ erard C. Kramer Attorney at Law Attorney I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs ~~~ ~i~ -.. t....) C> " :s; D ki )\.J - ) ~ ~ ~ ~ \ ~ ~ >=') co r i"i -i.) I 01 I -.j ~::I Co.) :~ --< (J -T1 ... SCHMIDT KRAMER PC By: Gerard C. Kramer, Esquire 209 State Street Harrisburg, PA 17101 (717) 232-6300 Fax (717) 232-6467 gkrameI@schmidtkramer.com Attorneys for Plaintiffs MENKA KAYAN and NEERAJ DEORAH, her husband, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vi. CIVIL ACTION - LAW PATRICIA NORMAN NO. 06-279 CIVIL TERM Defendant. JURY TRIAL DEMANDED AND NOW, this 1~ , Esq., and , Esq., ~ f<.. uJ~ESq., are appointed arbitrators in the above-captioned action as prayed for. 'leel40 :.l_~ ~r ~~~ ,ty\lX--1 jUloV V \--' COple.? {\ {.Lfc1 C 3\-liP~ "er n J J~ q,\\,~~e, ~~ ~.J. >;:: c~, ...-.:::[' 1-; ,,,,,; ~~ OCt::' HICJ :::J - w:: LU -,- j:::: tL () (',j U'J (V') a: i-- I :'''' :::1 (..I) '-C> c::.::J c:::) c"'", MfA) J<A 1< ~ Y AilE, 11J. Plaintiff In The Court of Common Pleas of Cumberland County, Pennsylvania No. 2. Del t_ .... ~,,2 7 'I ?ATo.lefA 1V~f(M4)') Defendant Civil Action - Law. O~ ~ We do solemnly swear (or affirm) that we will support, obey and defend the Constitution Of~he Uni States and the Constitution of this Commonwealth and that we will dischargf{{ithe tirs fAu~ e with fidelity. r M~ j ~)1\. . ~ ~ 10:. c..&.-r L Si~ Signature SIgnature JOlt-tV fl1. f.I}WII/ ~"r... V. WaAI...r 11 (~f:;'l. 1? WAL~ S Name (Chairman) Name Name Law Firm Law Firm Law Firm H () f I( j;- J S~ '7?1. () G.- Address ~ If N, ..l.l"It. If". Address -)~ t; ;#A,;f' sf Address I1~N f:tnJ1es~lIl:& (j City, Zip n/)S~ c--> "'; If "'A I 'b I' City, I Zip :fI: llolBl '=h= J DB (p/.p Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If da ages for delay are awarded, they shall be separately stated.) f1t-{jILlti(f~f)( {11( (1rJ :)}- City, Zip "* I~q t3 Date ofHearing:~-", I) 'J.,(J66 Date of Award: ~ I, 't-v(..' . Arbitrator, dissent~.. ~Insert name if applicable.) ~ . ~~\ _''t:: '-,l(~ITman) 1If) -- he 10 _ '-T fl tjfJ Notice of Entry of Award Now, the to -th day of j)cf\C.N\~r, 20 D/.p , at 3: a. B , P.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ ~ qlJ . 00 ~wJ:~roilionomy By: Deputy ~ _,vJ- . {>",,,0',r?'~ O 'ff? ~ r.A.C' \ ~ .alp opl Q;p-O' ,,+ '.J' ' :>- _OIP,{).. ~'" I OW Dv..-~ J' ~~~~ / ~(OO\ Q c ;T"" ~~r ......,;.' (1} ,~~ . 1,~": ;- >" ..."C? ,. .. l" ~I. , .... ,.' ,....., ~ c:::> c:;ro o f"l'1 CJ t CJ"'1 o 11 :i!-n me -om ~u9' (J '-4C~ --r1'i ;~~ ~ ~ -0 - c,.) N C1} t, (' ,. ~.. )<..,.\ '