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Home My WebLink About06-0953IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GLISSET BETANCOURT and ANGEL BETANCOURT, husband No. U~ - Q~ ~t u t~~~'1 810 Glenmore Way York, PA 17402 Plaintiffs vs. SHERRY HOLLAND 108 Hemlock Court Mechanicsburg, PA 17055 Defendant JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Kindly issue a Writ of Summons in the above-captioned case. X Writ of Summons shall be issued and forwarded to the Sheriff. Writ of Summons shall be issued and forwarded to the Attorney. Respectfully submitted, ~~~_ G~-ai R. Milsten, Esquire ~dfherman, Briggs & Greenberg, LLP Attorney for Plaintiffs I.D. #77065 7 East Market Street York, PA 17401 Date: ~ /~ ~% ~ (717) 848-3838 SUMMONS IN CIVIL ACTION TO: Sherry Holland, 108 Hemlock Court. Mechanicsbure, PA 17055 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLA TIFFS HAV-~ C ENCED AN ACTION AGAINST YOU. /s~ L (~ . Prothonotary/Clerk, Civil Di i on Date: ~ ~ n„~,~ . / ~/ /!/Li-~ Deputy M0118647.1 ~- W w W U"t a '_ 4p ` r~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA GLISSET BETANCOURT and ANGEL BETANCOURT, her husband, Plaintiffs, CIVIL DIVISION NO. 06-953 v. SHERRY HOLLAND, Defendant. PRAECIPE FOR RULE TO FILE COMPLAINT (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, L.L.P. Firm #911 1017 Mumma Road, Suite 300 Lemoyne, PA 17043 (717)901-5916 #14509 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLISSET BETANCOURT and CIVIL DIVISION ANGEL BETANCOURT, her husband, Plaintiffs, NO. 06-953 v. SHERRY HOLLAND, Defendant. (Jury Trial Demanded) PRAECIPE FOR RULE TO FILE COMPLAINT TO: The Prothonotary Kindly rule the Plaintiffs, Glisset Betancourt and Angel Betancourt, her husband, to file a Complaint in Civil Action within twenty (20) days. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & KE , L.L.P. By: I evin D. Rauch, Esquire ounsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR RULE TO FILE COMPLAINT has beenzmailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this `-~ ~~ day of R;~ , 2006. Craig R. Milsten, Esquire CGA Law Firm 29 North Duke Street York, PA 17401-1282 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & KEEL, Q.L.P. By: K vin D. Rauch, Esquire Counsel for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLISSET BETANCOURT and ANGEL BETANCOURT, her husband, Plaintiffs, v. CIVIL DIVISION NO. 06-953 (Jury Trial Demanded) SHERRY HOLLAND, Defendant. RULE AND NOW, this °~~ ~~ day of ~ 2006, upon consideration of Defendant's Praecipe for Rule to File a Complaint, a Rule is hereby granted upon Plaintiffs to file a Complaint within twenty (20) days of service, or suffer judgment Non Pros. Rule issued this °Y ' ~ day of , 2006. .. Proth'on tary ~, = r ~ ; ., - ~ ~_t M ;'<<~ ~~ ; - . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLISSET BETANCOURT and ANGEL BETANCOURT, her husband, Plaintiffs, CIVIL DIVISION NO. 06-953 v. SHERRY HOLLAND, Defendant. PRAECIPE FOR APPEARANCE (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, L.L.P. Firm #911 1017 Mumma Road, Suite 300 Lemoyne, PA 17043 (717)901-5916 #14509 ( + IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLISSET BETANCOURT and CIVIL DIVISION ANGEL BETANCOURT, her husband, Plaintiffs, NO. 06-953 v. SHERRY HOLLAND, Defendant. (Jury Trial Demanded) PRAECIPE FOR APPEARANCE TO: THE PROTHONOTARY Kindly enter the Appearance of the undersigned, Kevin D. Rauch, Esquire, of the law firm of Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P., on behalf of the Defendant, Sherry Holland, in the above case. JURY TRIAL DEMANDED Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE ~ SKEEL, L.L.P. By: Kevin D. Rauch, Esqui Counsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR APPEARANCE has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this ~~ day of '-. , , 2006. Craig R. Milsten, Esquire CGA Law Firm 29 North Duke Street York, PA 17401-1282 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. By: Rauch, Esqui for Defendant ~~ L ~~l ..l ~~ rl? ~.:._ ~Y e... ~ ft .~_ J `~ -ti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Glisset Betancourt and Angel Betancourt, CIVIL ACTION -LAW her husband, PLAINTIFF v. NO. 06-953 Sherry Holland, DEFENDANT JURY TRIAL DEMANDED NOTICE TO PLEAD NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth against you in the following pages, you must take action within twenty (20) days after this Complaint and Notices are served, by entering a written appeazance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You aze warned that if you fail to do so, the case may proceed without you and a defaultjudgment 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 THIS OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. A VISO USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenerse de las quejas expuestas en las paginas siguientes, debe tomaz action dentro de veinte (20) dial a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentaz compazecencia escrita en persona o por abogado y presentaz en la Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decide en su contra sin mas aviso o notification por cualquier dinero reclamado en la demanda o por cualquier otta queja o compensation reclamados por el Demandante. Usted puede perder dinero, o propriedades o otros derechos importantes pars usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O NO CONOCE UN ABOGADO, VAYA O LLAME ALA OFICINA EN LA DHtECCION ESCRITA ABAJO PARR AVERIGUAR DONDE PUEDE OBTENDER ASISTENCIA LEGAL. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 717-249-3166 M0126270 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Glisset Betancourt and Angel Betancourt, her husband, PLAINTIFF v. Sherry Holland, DEFENDANT COMPLAINT CIVIL ACTION -LAW No. 06-953 JURY TRL4L DEMANDED AND NOW, Plaintiffs, Glisset Betancourt and Angel Betancourt, by and through their attorneys, Kathennan, Briggs & Greenberg, LLP, file this Complaint and state the following: 1. Plaintiffs, Glisset Betancourt and Angel Betancourt, husband and wife, are adult individuals residing at 810 Glenmore Way, York, York County, Pennsylvania 17402. 2. Defendant is Sherry Holland ("Defendant"), an adult individual who resides at 108 Hemlock Court, Mechanicsburg, Cumberland County, Pennsylvania 17055.. 3. On March 13, 2004, at approximately 4:07 p.m., Plaintiff Glisset Betancourt was driving her 2003 Toyota Corolla on an entrance ramp to State Route 11/15 in Camp Hill, Cumberland County. 4. Plaintiff Glisset Betancourt brought her vehicle to a stop at the end of the ramp as she waited for traffic to clear so she could merge onto State Route 11/15. M0126270 At the aforesaid time and place, Defendant was driving a 1992 Chevrolet Lumina on the same entrance ramp behind Plaintiff Glisset Betancourt's vehicle. 6. At the aforesaid time and place, Defendant failed to stop her vehicle and crashed into the reaz of Plaintiff Glisset Betancourt's vehicle causing injuries to Plaintiff Glisset Betancourt. COUNT I - NegliPence Glisset Betancourt x Sherry Holland The paragraphs set forth above are incorporated by reference. 8. As a result of the accident, Plaintiff Glisset Betancourt suffered permanent bodily injuries, including, but not limited to, a cervical strain, a concussion, cephalgia, thoracic myofascitis, lumbaz radiculitis and radiculaz left arm pain.. 9. As a result of the accident and his injuries, Plaintiff Gusset Betancourt sustained or may sustain the following damages: a. past and future pain and suffering; b. past and future embarrassment, humiliation, and mental anxiety; c. past and future loss of life's enjoyment; d. past and future incidental costs; e. past and future scarring and disfigurement; f. past and future loss of earnings and/or earning capacity as may be recovered under the Pennsylvania Motor Vehicle Financial Responsibility Law; and g. past and future medical expenses as may be recovered under the Pennsylvania Motor Vehicle Financial Responsibility Law. M0126270 10. Defendant had a duty to use reasonable caze and avoid causing harm to others, including Plaintiff Glisset Betancourt. 11, Defendant breached her duty of caze and was negligent, cazeless, and reckless in the following manner: a. failing to maintain proper control of her vehicle; b. operating her vehicle in a cazeless and reckless manner; c. failing to keep alert and maintain a proper lookout for other traffic on the roadway; d. failing to keep alert and observe road conditions then existing; e. failing to maintain an assured cleaz distance in which to safely stop her vehicle; f. spiking a vehicle on the road; g. driving her vehicle too fast for the roadway conditions; and h. failing to comply with the provisions of the Pennsylvania Vehicle Code, Title 75 of the Pennsylvania Code, specifically as they relate to the above mentioned acts and, in particular, 75 Pa.C.S. §3714. 12. Defendant's negligence, recklessness and cazeIessness was a factual cause and/or substantial factor in causing the accident and Plaintiff Glisset Betancourt's injuries, for which the Defendant is solely liable. 13. Plaintiff Glisset Betancourt's damages exceed the applicable limits of azbitration and a jury trial is demanded. M0126270 WHEREFORE, Plaintiffs demand judgement against Defendant for compensatory damages in an amount in excess of $30,000, together with interest, costs of suit, and delay damages. COUNT II -LOSS OF CONSORTIUM Angel Betancourt a Sherry Holland 14. The pazagraphs set forth above aze incorporated by reference. 15. As a result of the aforesaid accident which caused personal injuries to Plaintiff, Glisset Betancourt, Plaintiff, Angel Betancourt, has suffered and may continue to suffer the loss of companionship, comfort, society, services and other forms of consortium of his wife. WHEREFORE, Plaintiff Angel Betancourt demands judgment against Defendant for compensatory and punitive damages in an amount in excess of $30,000.00, together with interest, costs of suit, and delay damages. Date: -5~/O(P T~ Respectfully Submitted, KATHERMAN, BRIGGS & GREENBERG ~~. C , . Milsten, Esquire Attorney ID No. 77065 John D. Briggs, Esquire I.D. #52987 7 East Mazket Street York, PA 17401 717-848-3838 Tele 717-854-9172 Fax Attorneys for Plaintiffs M0126270 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Glisset Betancourt and Angel Betancourt, CIVIL ACTION -LAW her husband, Plaintiffs No. 06-953 vs. Sherry Holland, Defendant Jury Trial Demanded VERIFICATION Craig R. Milsten, Esquire hereby states that he is an attorney for Plaintiffs in this action and, based upon facts and information received, states that the facts set forth in the foregoing Complaint are true and correct to the best of his 1Q-owledge, information and belief. The undersigned understands that the foregoing statements aze subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom falsification to authorities. Dated: ~~ ~ C R. Milsten, Esquire M0126270 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLISSET BETANCOURT and CIVIL DIVISION ANGEL BETANCOURT, her husband Plaintiffs, NO. 06-953 v. SHERRY HOLLAND, Jury Trial Demanded Defendant. CERTIFICATE OF SERVICE I hereby certify that the original of the within Complaint was served upon the following counsel of record via U.S. first class mail, postage prepaid this b day of ~, 2006: Kevin D. Rauch, Esq. Summers, McDonnell, Hudock, Guthrie and Skeel, LLP 1017 Mumma Road Lemoyne, PA 17043 KATHERMAN, BRIGGS & GREENBERG, LLP BY: g R. Milsten, Esquire I.D. #77065 John D. Briggs, Esquire I.D.#52987 Attorneys for Plaintiffs 7 East Market Street York, PA 17401 717-848-3838 717-854-9172 (fax) M0126270 ~ o O ~. ~"` i~ mr_~ ~ m~ ~ n(`~~{''~~{ V 1 ~ ~ }~~ _ ~~~ J ~'D V /~~~ ~- y ~rn ~_~ c ~ -r ._~ N P SHERIFF'S RETURN - REGULAR CASE NO: 2006-00953 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BETANCOURT GLISSET ET AL VS HOLLAND SHERRY ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon HOLLAND SHERRY the DEFENDANT at 1910:00 HOURS, on the 1st day of March 2006 at 108 HEMLOCK COURT MECHANICSBURG, PA 17055 by handing to SHERRY HOLLAND a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.68 Affidavit .39 Surcharge 10.00 .00 38.07 Sworn and Subscribed to before me this -ll.a-E day of ~,a.u.{._ a p i~ L A. D. Pro t ry~ So Answers: ~'~~-.-~ R. Thomas Kline 03/03/2006 KATHERMAN BRIGGS GREENBERG By: D putt' Sherif IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLISSET BETANCOURT and CIVIL DIVISION ANGEL BETANCOURT, her husband, Plaintiffs, NO. 06-953 v. SHERRY HOLLAND, Defendant. (Jury Trial Demanded) ANSWER AND NEW MATTER AND NOW, comes the Defendant, Sherry Holland, by and through her counsel, Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P., and Kevin D. Rauch, Esquire, and files the following Answer and New Matter and in support thereof avers as follows: 1. After reasonable investigation, the Defendant has insufficient information as to the truth or falsity of said averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 2. Admitted. 3. Admitted. 4. After reasonable investigation, the Defendant has insufficient information as to the truth or falsity of said averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 5. Admitted. 6. Admitted in part, denied in part. It is admitted that a collision occurred between the vehicles identified. The remainder of the allegations in paragraph 6 are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict. proof thereof is demanded at the time of trial. COUNT I -NEGLIGENCE GLISSET BETANCOURT v. SHERRY HOLLAND 7. In response to paragraph 7, the Defendant reiterates and repeats all her responses in paragraphs 1 through 6 as if fully set forth at length herein. 8. Paragraph 8 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 9. Paragraph 9 and all of its subparts state legal conclusions to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 10. Admitted. 11. Admitted in part, denied in part. It is admitted that the accident occurred as a result of the Defendant's negligent operation of her motor vehicle on the date, time, and place of the subject accident. The remainder of the allegations in paragraph 11 and all of its subparts state legal conclusions to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 12. Paragraph 12 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 13. Paragraph 13 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant, Sherry Holland, respectfully requests this Honorable Court enter judgment in her favor and against the Plaintiffs with costs and prejudice imposed. COUNT II -LOSS OF CONSORTIUM ANGEL BETANCOURT v. SHERRY HOLLAND 14. In response to paragraph 14, the Defendant reiterates and repeats all her responses in paragraphs 1 through 6 as if fully set forth at length herein. 15. Paragraph 15 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant, Sherry Holland, respectfully requests this Honorable Court enter judgment in her favor and against the Plaintiffs with costs and prejudice imposed. r NEW MATTER 16. The motor vehicle accident in controversy is subject to the Pennsylvania Motor Vehicle Financial Responsibility Law and this Defendant asserts, as affirmative defenses, all rights, privileges and/or immunities accruing pursuant to said statute. 17. Some and/or all of Plaintiffs' claims for damages are items of economic detriment which are or could be compensable pursuant to either the Pennsylvania Motor Vehicle Financial Responsibility Law and/or other collateral sources and same may not be duplicated in the present lawsuit. 18. To the extent that the Plaintiffs have selected the limited tort option or are deemed to have selected the limited tort option then this Defendant sets forth the relevant provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law as a bar to the Plaintiffs' ability to recover non-economic damages. 19. This Defendant pleads any and all applicable statutes of limitation under Pennsylvania law as a complete or partial bar to any recovery by Plaintiffs in this action. WHEREFORE, Defendant, Sherry Holland, respectfully requests this Honorable Court enter judgment in her favor and against the Plaintiffs with costs and prejudice imposed. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE ~ SKEEL, ~.,L.P. BY~ ~ ~~~~~rU~- evin D. `Rauch, Esquire ounsel for Defendant VERIFICATION Defendant verifies that she is the Defendant in the foregoing action; that the foregoing ANSWER AND NEW MATTER is based upon information which she has furnished to her counsel and information which has been gathered by her counsel in the preparation of the lawsuit. The language of the ANSWER AND NEW MATTER is that of counsel and not of the Defendant. Defendant has read the ANSWER AND NEW MATTER and to the extent that the ANSWER AND NEW MATTER is based upon information which she has given to her counsel, it is true and correct to the best of her knowledge, information and belief. To the extent that the content of the ANSWER AND NEW MATTER is that of counsel, she has relied upon counsel in making this Affidavit. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: rn Sherry. olland #14509 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing ANSWER AND NEW MATTER has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this -~~ day of , 2006. Craig R. Milsten, Esquire Katherman, Briggs & Greenberg 7 East Market Street York, PA 17401 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. in D. Rauch, Esquire nsel for Defendant ~~ ~ : ' .,~ . «, -~7 ~'ri __ .~._ ~ -~ = ' :-r ; `~ - -, _ --+~, __ - _ .~.. : ~- .- ~J '.._ r7 T _. .• ;-! ~ *" `: C"~ --~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLISSET BETANCOURT and ANGEL BETANCOURT, her husband Plaintiffs, CIVII, DIVISION NO. 06-953 v. SHERRY HOLLAND, Defendant. NRY TRIAL DEMANDED PLAINTIFFS' REPLY TO DEFENDANT'S NEW MATTER Plaintiffs, Glisset Betancourt and Angel Betancourt, by and through their attorneys, Craig R. Milsten, Esquire and Katherman, Briggs & Greenberg, LLP, hereby respond to Defendant's New Matter as follows: 16. - 19. Denied. Pazagraphs 16 through 19 of Defendant's New Matter set forth conclusions of law to which no responsive pleading is required. To the extent facts aze deemed to be alleged, they are denied as stated. WHEREFORE, Plaintiffs respectfully request that this Honorable Court dismiss Defendant's New Matter and enter judgement as requested in Plaintiffs' Complaint. Respectfully submitted, ~ ~ Date KATHERMAN, BRIGGS & GREENBERG By: R. Milsten, Esquire ttorney for Plaintiffs Supreme Court I.D. #77065 7 East Market Street York, PA 17401 (717)848-3838 M0126270 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLISSET BETANCOURT and CIVIL DIVISION ANGEL $ETANCOURT, her husband Plaintiffs, NO. 06-953 v. SHERRY HOLLAND, JURY TRIAL DEMANDED Defendant. CERTIFICATE OF SERVICE I hereby certify that the original of the within Plaintiffs' Reply to Defendant's New Matter was served upon the following counsel of record via U.S. first class mail, postage prepaid this a a~ day of ~.s~1 _, 2006: Kevin D. Rauch, Esq. Summers, McDonnell, Hudock, Guthrie and Skeel, LLP 1017 Mumma Road Lemoyne, PA 17043 KATHERMAN, BRIGGS & GREENBERG, LLP BY: (~'aig R, Milsten, Esquire I.D.#77065 John D. Briggs, Esquire I.D. #52987 Attorneys for Plaintiffs 7 East Mazket Street York, PA 17401 717-848-3838 717-854-9172 (fax) M0126270 r: ~, ~. -_, -. ';, -' c=_ ~~,, c~;, _,., =: _. ::.: c- "" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA Glisset Betancourt and N0:2006-00953 Angel Betancourt, her husband Plaintiffs v. CIVIL ACTION -LAW Sherry Holland . Defendant. JURY TRIAL DEMANDED PRAECIPE TO DISMISS ' To the Prothonotary: Please dismiss the above case and mark the docket settled and satisfied. Respectfully submitted, KATHERMAN, BRIGGS & GREENBERG ,Date: April 18, 2007 By. ~~~-- Craig R. Milsten, Esquire Attorney for Plaintiffs Supreme Court I.D. #77065 7 East Market Street York, PA 17401 ('17) 848-:838 CERTIFICATE OF SERVICE I hereby certify that I have this date served a copy of the foregoing PRAECIPE TO DISMISS, as set forth below by first class United States postage: Kevin D. Rauch, Esq., Esquire Summers, McDonnell, Hudock, Guthrie and Skeel, LLP 1017 Mumma Road Lemoyne, PA 17043 Respectfully submitted, KATHERMAN, BRIGGS & GREENBERG ~ ~~.. Date: April 18, 2007 By: ~ aig R. Milsten, Esquire Attorney for Plaintiffs Supreme Court I.D. #77065 7 East Market Street York, PA 17401 (717) 848-3838 C ° d _ o ~~~; ^v n -~ --- ~_ -' t ., ~ N ~~-r~ C7, , AJ r_ ' ~ -ter -~-, -r' 1r. - -.' ~ 7 -C l~ L W ~ m :~ ~ "'~ ,, ~~