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Home My WebLink About02-1592COMMONWEALTH OF PENNSYLVANIA NOTICE OF APPEAL COURT OF COMMON PLEAS JUDICIAL DISTRICT FROM DISTRICT JUSTICE JUDGMENT NOTICE OF APPEAL ~ is ~ ~ ~ ~t ~s fi~ in ~ a~ Co~t of C~ ~s ~ ~1 ~in~c~~~ ~ ~ck ~11 ~ ~ ONLY ~n this ~fi~ is mqui~ u~ P~ R.C~J~. ~ I~11~'~ CLAIMANT (S~ ~. R.C.P.J.P, No. 1008B. This Notice of Appeal, when received by the District Justice, will operate as a SUPERSEDEAS to the judgment for possessio~ in this cas~ Signature of Prothonotary or Deputy 1001 (6) in action before District Justice, he MUST FILE A COMPLAINT within twenty (20) days after filing his NOTICE of APPEAL. PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee). PRAECIPE, To Prothonotary ,u Irt, [2A u o L' Enter ru~ upon , appellee{s), ta file a complaint in this appeal Nerne of al~pelee~s) Name of appel~s) ) ' (!) You am notified that a rule is hereby entered upon you to file a complaint in th/s apl:md within twenty (20) days after the date of service of this rule upon you by personal service or by ceetified or registered mail (2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU. (3) The date of servic, of this rule if servlce was by mail is the date of maili~ AOPC312-90 COURT FILE TO BE FILED WITH PROTHONOTARY PROOF OF SERVICE OF NOTICE OF APPEAL AND RULETO FILE COMPLAINT (This proof of service MUST BE FILED Wi THIN TE~ (1¢) DAYS AFTER firing the notice of appeal. Check applicable boxes) COMMONWEALTH OF PENNSYLVANIA. COUNTYOF (]~,,~--~'~'~.~Z~/' . ;$,S'~' , · AFFIDAVIT: I hereby swear or affirm that I served a copy of the Not ce of Appeal Common. Pleas .No, _ , upon the District Justice designated therein on [] (date of service) ' i. - ' ~ [] bv personal servicA [~"'by(certified) (registered) mail, sender's · -""'"- ' ~v~ on receipt attached hereto, and upon the appetlee (name) , [] by personal servic; ~ ~-(certifie4-('~) mail, ~nder's receipt attached hereto. [] and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom the Rule was addressed on . [] by personal service [] by (certified) (registered) mail, sender's receipt attached hereto. SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS DAY OF Title of officia/ My commission expires on ......................................... OnJL y COMMONWEALTH OF PENNSYLVANIA · *~ '~'0,OUNTY OF: CUMBERLAND Mag. Dist. No 09-2-01 DJ Name men ~dd ..... I COURTHOUSE SQUARE CARLISLE, PA r.i.p. .... ~717) 240-6564 17013-0000 ROBERT J. GRIFFIN 323 WEST FIRST STREET BOILING SPRINGS, PA 17007 CIVIL CASE PLAINTIFF: NAME and ADDRESS FPAVIOL, DMD, JOHN M., ET AL. 542 S. HANOVER ST. CARLISLE, PA 17013 VS. DEFENDANT: NAME and ADDRESS FGRIFFIN, ELIZABETH J., ET AL. 323 WEST FIRST STREET BOILING SPRINGS, PA 17007 NOTICE OF JUDGMENT/TRANSCRIPT J Dockel No.: CV-0000059-02 Date Filed: 2/01/02 THIS IS TO NOTIFY YOU THAT: ....... Uudgment,: -- ........... ,FOR PLAINTIFF_ _ , .... ~-] Judgment was entered for: (Name) PAVTdT,: nM'O; ,'rnR'Kr M_ ;. ~ AT,_ ~ Judgment wa:~'r/~ntered~against: (Name) , ,CIRT~'~'TN.. ~0~? J. in the amourS, Of $ - I .. '74"/_ q-ti on: Defendants a~,jointty and.severally h~.~e. Damages will be assessedon: This case dismissed without prejudice. Amount of Judgment Subject to Attachment/Act 5 of 1996 $ Levy is stayed for Objection to levy has been filed and hearing will be held: Date: (Date of Judgment) (Date & Time) Amount of Judgment $ 1,683.00 Judgment Costs $ 64 o 50 Interest on Judgment $ o O0 Attorney Fees $ o 00 Total $ 1,747.50 Post Judgment Credits $ Time: __ days or ~ generally stayed. ,L?L~ ~ ~' ~' Place: L.POst, ~mp~t/Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT~RA~SCRIPT FORM WITH YOUR NOTICE OF APPEAL. ' '/I.l, Jf&2, Date ('~ ~-:~¢._j¢~ ,"~/.4.'t~ ~ ~,'"]"~'~t~i~ ~st ce I' 'cedifY that t~is is a true~~a py of~he, r~~bedings. My commission expi~ first Monday of January, 2006 ~"j.~ .,.-", , AOPC 315-99 ~, -"~ ' .COMMONWEALTH OF PENNSYLVANIA COUNTY OF: COLBERT,AND Mag. Dist. NO.: 09-2-01 DJ Name: Hon. P~OL~ P. COP~EE~[~ Address: 1 COURTHOUSE SQUARE CARLISLE, PA Teleph ....(717) 240-656& 17013-0000 ROBERT J. GRIFFIN 323 WEST FIRST STREET BOILING SPRINGS, PA 17007 CIVIL CASE PLAINTIFF: NAME and ADDRESS ~AVIOL, DMD, JOHN M., ET AL. 542 S. HANOVER ST. CARLISLE, PA 17013 VS. DEFENDANT: NAME and ADDRESS FGRIFFIN, ELIZABETH J., ET AL. 323 WEST FIRST STREET BOILING SPRINGS, PA 17007 NOTICE OF JUDGMENT/TRANSCRIPT Docket No.: CV-0000059-02 Date F ed: 2/01/02 J J THIS IS TO NOTIFY YOU THAT: Judgment: Judgment was entered fur: Judgment w~tered?~gainst: (Namo)~.-~RTFFTN_. in the amour~,~f $ . 1~"/4'7 _*~:~:: on: 'Date of Judgment) Defendants ~oin~y and~Severally ha~¢. Damages will be assessed.on: This case dismmsed withoU?prejudice. FOR P[JkIN~IFF (Name) DAVT~'tT.: T3MT3: .1'f3~3~,3 M_: R~ AT._ Amount of Judgment Subject to Attachment/Act 5 of 1996 $. Levy is stayed for days or ~ generally ~tayed. Objection to levy has been filed and hearing will be held: (Date & Time) Amount of Judgment $ 1,683.00 Judgment Costs $ 6~ o 50 Interest on Judgment $ o 00 Attorney Fees $ o 00 Total Post Judgment Credits Post Judgment Costs Certified Judgment Total 1,747.50 Date: Time: Place: ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30:DAYSAFTER ~HE 'E'N'~Y OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT~RANSORIPT FORM WITH YOUR NOTICE OF APPEAL. 3/[[/02 Date ( ~~z ~(~...~"~.45~'~ /~l,'.',~JJi~'tfi'et Justice I certify that this is a true an~.cJ,eO~y of t~t~e'/.p~.~flings co.nt¢.~ the. jud, gment'. I 3/t llOl Date / .~/.~./¢~[ /~~¢-~'. :' , Disirict Justice My commission expides first/' Monday of January, 2006 . ,' SEAL" AOPC 315-99 DOUGLAS, DOUGLAS & DOUGLAS 27 W. HIGH ST. POB 261 CARLISLE PA 17013 TELEPHONE 717-243-1790 George F. Douglas, III, Esquire. Supreme Court I.D.# 61886 Cumberland County Pennsylvania Plaintiff Vs. ROBERT J. GRIFFIN and ELIZABETH J. GRIFFIN No. I lYqil, Civil 2002 Civil Action Law Defendants 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 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 2 Liberty Ave. Carlisle, PA 17013 717-249-3166 BY . Atto{ney for ~laintiff DATE: April 5, 2002 COMPLAINT 1. The plaintiff, John M. Paviol, DMD, is an adult individual residing at 201 S. Orange St., Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendants, Robert J. and Elizabeth J. Griffin, are individuals who reside at 323 West First Street, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. The plaintiff, John M. Paviol, DMD, is a dentist with a place of business located at 542 S. Hanover St., Carlisle, Cumberland County, Pennsylvania 17013. 4. Between the dates of April 12,1999, and July 25, 2001, the defendants received professional dental services from the plaintiff, as is set forth in the attached Exhibit A. 5. Despite demands made to them, the defendants, Robert J. and Elizabeth J. Griffin, have failed to pay for the professional services rendered, which is due and owing in the amount of $1,683.00. 6. As a result of the failure of the defendants to pay the plaintiff's bill for professional services, the plaintiff has sustained $1,683.00 in damages and $57.50 in costs to date. WHEREFORE, the plaintiff claims of the defendants the sum of $1,740.50 plus any additional costs of suit, an amount within the sum requiring compulsory referral to arbitration under the local rules of court. Douglas, Douglas & Douglas George F~ D~ouglas, III, E~squire Attorney for plaintiff AFFIDAVIT I hereby swear or affirm that the foregoing is true and correct to the best of my knowledge and/or information and belief. This is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Jo~hnM. Paviol, DMD Date: April 5, 2002 RENT$CHLER PAVIOL 542 S, HANOVER ST. CARLISLE PA i7013 DENTISTS NAME DATE ELIZABETH J 04/13/99 ROBERT J 05/06/99 ROBERT 3 05/06/99 ROBERT J 05/06/99 ROBERT 3 05/06/99 05/06/99 08/05/99 ELIZABETH J 09/2q/99 11/02/99 01/03/00 ROBERT J 02/10/00 ROBERT J 02/10/00 ELIZABETH J 02/16/00 ELIZABETH J 02/21/00 ELIZABETH 3 02/22/00 ELIZABETH 3 03/11/00 04/07/00 ELIZABETH J 04/12/00 ROBERT J 05/23/00 ELIZABETH 3 06/06/~0 06/20/00 07/19/00 ELIZABETH J 0?/2?/O0 ELIZABETH J 09/13/00 ELIZABETH J 09/13/00 12/06/00 02/12/01 03/19/01 ELIZABETH J 03/19/01 ELIZABETH J 03/19/01 ELIZABETH J 03/19/01 03~28/01 ELIZABETH J 04/24/01 ELIZABETH J 04/24/01 05/01/01 ELIZABETH J 03/01/01 07/25/01 ELIZABETH J 07/25/01 ELIZABETH J 02/14/02 DESCRIPTION INSRNC CHG PMT 8ALANC£ BALANCE FORWARO .OC COMP 4 SFC ANT 135.00 135.0¢ REPLACE PART BR 55,00 220,0¢ ADD CLASP PART 95.00 315,0¢ PERIODIC EXAM 20.00 335.0¢ PROPHY AOULT 35,00 370,00 CHK RCVD-THRNKS 68.00 302.0¢ PERIODIC EXAM 20,00 322.0C PROPHY ADULT 35.00 357.0¢ PAID-INSURANCE 55.00 302.0( CHK RCVD-THANKS 150.00 152.0¢ CROWN PORC SPM 530,00 682.0¢ PAID-INSURANCE 265.0~ 417,0¢ CHK RCVD-THANK$ 150.00 267.0( CHK RCVD-THANKS 150.00 liT.O( PERIODIC EXAM 20.00 137.0( PROPHY ADULT 35.00 172.0( PERIODIC EXAM 20.00 192.0( PROPHY ADULT .. ~5.00 .......... 227.0( CI4K RCVO-THANK$ 117.00 COHP 4 SFC ANT 85,00 195,0< INTERNAL ROOT ~ 165.00 360.0( CHK RCVD-THANKS 150.00 210.0( 3 SFC AMAL PERM 85,00 29E,0~ CHK RCVD-THANK$ 150.00 145.0~ CROWN PORC SPM 560.00 705,01 CROWN PORC SPA 560.00 126&.0~ CROWN PORC SPA 560,00 1825,0t CROWN PORC SPA 560.00 2355.0( ROOT CANAL 2 458.00 2843.0( CHK RCVD-THANKS 150.00 2393,0( CHK RCVD-TMANKS 500,00 2193,0( CROWN PORC SPM 560.00 2753.01 PERIODIC EXAM 20.00 2773,0~ PROPHY ADULT 33.00 2808.0~ CHK RCVD-THANKS 300.00 250E.0~ CHK RCVD-THANKS 500.00 2008.0~ CHK RCVD-TMANK$ 300.00 1708.0( CHK RCVD-THANK$ 145.00 1563.0( LIMITED EXAM 35.00 1598,0( XRAYS PAX 25.00 1623.0( EXTRACTION $IN~ 85.00 CHK RCVO-THANKS 200.00 1508.0( PERIODIC EXAM 2E,O0 1533,0( PROPHY ADULT 40.00 1573.0( CMK RCVD-THANK$ 60.00 i5~3.0( COMP 4 5FC ANT 135.00 1648,0< CMK RCVD-TMANKS 100.00 1548.0( COMP 4 SFC ANT 135.00 i683.0( CHK RCVD-THANK$ 100.00 1583.0[ UNSPEC ADJ PROC 65,00 1648.0( TOTAL BALANCE 1648.00 PLEASE PAY THIS AMOUNT z~zzz 1648.0( ELIZABETH GRIFFIN 323 WEST FIRST ST BOILING SPRINGS PA 17007 APR-04--02 11:48 PM RENTSCHLER PA¥IOL 245 7158 P. 05 RENTSCHLER PAVIOL 542 S. HANOVER ST. CARLISLE PA 17013 DENTISTS NAME DATE DESCRIPTION INSRNC CHG PMT BALANCE FORWARD BALANCE 1648.00 TOTAL BALANCE 1648.00 PLEASE PAY THIS AMOUNT ELIZABETH GRIFFIN 323 WEST FIRST ST BOILING SPRINGS PA 17007 164B .00 JOHN M. PAVIOL, DMD : V. : ROBERT J. GRIFFIN and : ELIZABETH J. GRIFFIN : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CML ACTION - LAW NO. 1592 CIVIL 2002 PROOF OF SERVICE Please file this proof of service on the defendants, Robert J. Griffin and Elizabeth J. Griffin, in this case. DOUGLAS, DOUGLAS & DOUGLAS April 11, 2002 George F. Douglas, III, Esquire Attorney for Plaintiff Atty. I.D. #61886 27 West High Street P.O. Box 261 Carlisle, PA 17013 717-243-1790 · Complete itemS 1,2, and 3. Also comptete item. 4 it Restricted Delive~ is desired. · print your name and address on the reverse we can return the card to you so that _. ~o,~ to the back of the maitpieOe, · Attach tins ~,~ or ~n the front if space permits. 1. A~ticle Addressed to: ;. SignAture r~ Agent ~from item 17 '3 yes if YES, ether delivery address below: :~^^~ I~'1~) ~uu "-P~-Form 3811, July 1999 t~ , ouuress, and ZIP+4 in this box · DOUGLAS, DOUGLAS & DOUGLAS P,O. BOX 261 CARLISLE, PA 17013 I'"llh"lll"""ll,,ll,ll,,,,,hl,lh,,,,ll,ll,,,,,ih,l,ii JOHN M. PAVIOL, DMD, Plaintiff ROBERT J. GRIFFIN & ELIZABETH J. GRIFFIN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1592 CIVIL TERM :CIVIL ACTION - LAW NOTICE TO PLEAD TO: John M. Paviol, DMD C/o George F. Douglas, III, Esquire DOUGLAS, DOUGLAS & DOUGLAS 27 West High Street P.O. Box 261 Carlisle, PA 17013 You are hereby notified to file a written response to the enclosed New Matter and Counterclaims within twenty (20) days from service hereof or a judgment may be entered against you. Respectfully Submitted TURO LAW OFFICES J~n~s M. Robeson, Esquire 2l~outh Pitt~treet C~rlisle, PA '17013 (717) 245-9688 Attorney for Defendant JOHN M. PAVIOL, DMD, Plaintiff ROBERT J. GRIFFIN & ELIZABETH J. GRIFFIN, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1592 CIVIL TERM : CIVIL ACTION - LAW ANSWER, NEW MATTER AND COUNTERCLAIMS Defendants, Robert J. Griffin and Elizabeth J. Griffin (the "Griffins"), by and through their attorneys, Turo Law Offices, respectfully submits the following Answer, New Matter and Counterclaims with respect to the Complaint of Plaintiff John M. Paviol, DMD, ("Paviol"), and in support thereof avers as follows: 2. 3. 4. ANSWER Admitted. Admitted. Admitted. Admitted with further explanation. Much of the work performed on Defendant Robert Griffin's upper plate and the crowns installed on May 23, 2000 was defective and require replacement. 5. Denied. By way of further answer, Defendants have paid Plaintiff for all effective professional services rendered. The Defendants notified Plaintiff that the amount requested in Plaintiffs pleading would not be paid because of the problems experienced with the plate and crowns. In addition, Defendants made several telephone calls to the Plaintiff about this matter in which they left messages at Plaintiffs place of business, which telephone calls were never returned. 6. Denied. By way of further answer, the amount requested by Plaintiff represents payment for dental service that must be corrected or replaced at additional cost to Defendants. Any damage suffered by Plaintiff was the direct result of Plaintiffs poor quality service and was not caused by Defendants. WHEREFORE, for all the reasons set forth above, the Defendants, Robert J. and Elizabeth J. Griffin request judgment in their favor and respectfully request this Honorable Court to dismiss Plaintiff's Complaint. NEW MATTER AND COUNTERCLAIMR In further response to the Complaint, the Griffins aver the following new matter: 7. The Griffins hereby incorporate the foregoing answers to the preceding paragraphs as if set forth fully herein. 8. On May 6, 1999, Plaintiff completed repairs on Robert Griffin's upper plate, which repairs held for one (1) week. After Plaintiff repaired the plate again, the repairs held for about one (1) month. This upper plate has caused Defendant constant discof.;ort. Defendant must now replace the upper plate at a cost of $850.00. 9. On September 29, 1999, Plaintiff installed a porcelain crown in Elizabeth Griffin for which he charged $530.00. This crown was not properly installed, causing Elizabeth constant discomfort. 10. Because of the constant pain and discomfort caused by a crown installed by Plaintiff, Defendant Elizabeth Griffin went to Casey J. Williams, D.M.D. for examination. Dr. Williams ordered that a root canal be performed as soon as possible. 11. On February 27, 2002, a root canal was performed by Endodontics Associates at its office located at 395 St. John's Church Road, Camp Hill, Pennsylvania at a cost to the Defendant of $195.00. 12. On March 4, 2002, after further examination revealed that the root canal was ineffective, the tooth was extracted by Donald E. Santy, D.M.D. of Miller Oral Surgery, Inc. at a cost to Defendants of $235.00. 13. On July 27, 2000, Plaintiff installed a crown in Defendant Elizabeth Griffin, which crown was not properly installed and causes Defendant constant pain and disco,,;'ort. This crown must be replaced, which replacement will cost Defendant approximately $625.00. 14. At present, Defendant Elizabeth Griffin is under the care of Marianna Clougherty, D.D.S., who is in the process of formulating a plan of care for Mrs. Griffin's dental problems. This plan of care is not yet complete. 15. On May 23, 2000, Plaintiff installed three (3) crowns on Robert Griffin's upper jaw, for which he charged $560.00 per crown. The porcelain broke off of one of these crowns within thirty (30) days. 16. Prior to installing the crowns on May 23, 2000, Plaintiff did not take a set of full-mouth x-rays. 17. All of the crowns installed on May 23, 2000 must all be replaced at a cost to Defendant of $625.00 per crown. 18. On or about April 9, 2002 and April 25, 2002, Defendant Robert Griffin was examined by Thomas S. DeSantis, D.M.D. Dr. DeSantis composed a Primary Treatment Plan for Mr. Griffin, in part to correct errors made by Plaintiff. This Primary Treatment Plan is attached hereto as Exhibit A. 19. forth herein. 20. COUNTERCLAIM Robert J. Griffin v. John M. Paviol, DMD Defendants hereby incorporate paragraphs 1 through 18 as if fully set As a result of Plaintiff's actions as set forth above, Defendant Robert J. Griffin has experienced continual physical discomfort and has suffered damages totaling $2,530.00, which amount represents the cost of correcting the Defendant's upper plate and three (3) crowns. WHEREFORE, for all the reasons set forth above, the Defendant Robert J. Griffin requests judgment in his favor and against Plaintiff in the amount of $2,530.00, along with costs and attorneys' fees in defending this action, and further relief as this Court deems just and proper. 21. forth herein. 22. COUNTERCLAIM Elizabeth J. Griffin v. John M. Paviol, DMD Defendants hereby incorporate paragraphs I through 18 as if fully set As a result of Plaintiff's actions as set forth above, Defendant Elizabeth J. Griffin has experienced continual physical discomfort and has suffered damages totaling $1,055.00, which amount represents the cost of correcting the Defendant's defective crowns. WHEREFORE, for all the reasons set forth above, the Defendant Elizabeth J. Griffin requests judgment in his favor and against Plaintiff in the amount of $1,055.00, along with costs and attorneys' fees in defending this action, and further relief as this Court deems just and proper. Respectfully Submitted, Date a~ oR~l~l~sSOn, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Exhibit A Patient: (112401) Robert Griffin TOTAT~: &DSnlONAI. COMmeNTS Financial Arrangements: Patient Signature: Date: VERIFICATION I verify that the statements made in the foregoing Answer, New Matter and Counterclaim are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. {}4904 relating to unsworn falsification to authorities. Date Date Robert J. Griffin Elizab'~th J. Gr~ft~ ' CERTIFICATE OF SERVICF I hereby certify that I served a true and correct copy of the Answer, New Matter and Counterclaims upon George F. Douglas, III, Esquire, by depositing same in the United States Mail, first class, postage pre-paid on the 8th day of May, 2002, from Carlisle, Pennsylvania, addressed as follows: George F. Douglas, III, Esquire Douglas, Douglas & Douglas 27 West High Street P.O. Box 261 Carlisle, PA 17013 TURO LAW OFFICES JaMs M. Robinson, Esquire 28~outh Pi~ Street Carlisl-" 'e, PA 17013 (717) 245-9688 Attorney for Defendants John M. Paviol, DMV Plaintiff Robert J. Griffin & Elizabeth J. Griffith, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-1592 · CIVIL TERM PRAECIPE TO THE PROTHONOTARY OF THE SAID COURT: Please settle, withdraw and mark satisfied the above-captioned action on behalf of the Plaintiff, John M. Paviol, DMV. Respectfully Submitted TURO LAW OFFICES Date /George ~=. Douglas, III, Esquire Attorney for Plaintiff John M. Paviol, DMV Plaintiff Robert J. Gdffin & Elizabeth J. Gdfrffh, Defendants IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1592 CIVIL TERM PRAECIPE TO THE PROTHONOTARY OF THE SAID COURT: Please withdraw, settle and mark satisfied the above-captioned matter and counterclaim filed therein on behalf of the Defendants, Robert J. Griffin and Elizabeth J. Gdffin. Respectfully Submitted TURO LAW OFFICES ~o may ~o r °l~;~eSn°~l~ nEt~quire