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HomeMy WebLinkAbout06-3838DEBBIE SMITH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW :NO: - 0&,-3P3'P ??ULIr PHYLLIS SHARO, Defendant : JURY TRIAL DEMANDED ?tOW" YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following Complaint, 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 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. Pennsylvania Bar Association 100 South Street, P.O. Box 186 Harrisburg, PA 17108 1-800-692-7375 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. DEBBIE SMITH, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW //?? /I Cj NO: - O?o' 3P3? C tCvLC G?Z"" 1 PHYLLIS SHAKO, Defendant : JURY TRIAL DEMANDED COMPLAINT AND NOW, this 27 h Day of June, 2006, comes the Plaintiff, Debbie Smith, through her counsel, ROMINGER & WHARF, and respectfully files the following Complaint, and in support thereof avers the following: 1. Plaintiff, Debbie Smith, is an adult individual residing at 344 Old State Road, Gardners, Pennsylvania 17324. 2. Defendant, Phyllis Sharo, is an adult individual residing at 1318 Asper Drive, Boiling Springs, Pennsylvania 17007. 3. The events hereinafter complained of occurred on or about the evening of June 20, 2005, at the intersection of Front Street and State Route 174 in Carlisle, Pennsylvania. 4. At said time and place, Plaintiff, Debbie Smith was traveling west on State Route 174. 5. At said time and place, Defendant, Phyllis Sharo was traveling north on Front Street. 6. At said time and place, Defendant failed to yield the right of way to the Plaintiff. 7. Said incident caused the Plaintiff's vehicle to hook onto a post near the roadway. 8. Plaintiff was immediately flown by life line to Hershey Medical Center. 9. Plaintiffs injuries and damages set forth herein were the direct and proximate result of the negligence of the Defendant both directly and vicariously as a result of said employs actions. 10. Defendant was negligent generally as may be adduced at trial and in the following particulars: (a) She failed to yield when proper warning was posted; (b) She failed to keep an assured clear distance; (c) She failed to keep alert and maintain a proper and adequate watch for the presence of other vehicles on the roadway (d) She drove a vehicle in a manner endangering persons and property and in a reckless manner with careless disregard for the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. (e) She was otherwise generally negligent. 12. As a direct and proximate result of the negligence of Defendant(s) and their employ(s), jointly and severally then and there occurring, Plaintiff sustained the following serious and severe injuries, some of which may be permanent: a. Injuries and damages in and about the rib area; b. Injuries and damages in and about the head and neck; and c. Injuries and damages in and about the lower back and other body parts. 13. As a result of the injuries aforesaid, Plaintiff has been damaged as follows: a. She has suffered and will continue to suffer great pain, inconvenience, embarrassment, shock to the nervous system, and mental anguish; b. She has been required to expend significant sums of money for medical care; C. She has suffered lost wages and earnings. WHEREFORE, Plaintiffs respectfully request that this Honorable Court find in favor of the Plaintiff and against the Defendant, for an amount in excess of the statutory limits for compulsory arbitration, including costs of this suit and attorney's fees. Datel?-G Respectfi ally submitted, C ROMINGER & WHARE Karl E. Rominger, Esquire Attorney I.D. No. 81924 155 South Hanover Street Carlisle, Pennsylvania 17013 Tel: (717) 241-6070 Fax: (717) 241-6878 Attorney for Plaintiff DEBBIE SMITH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW NO: - PHYLLIS SHARO, Defendant : JURY TRIAL DEMANDED VERIFICATION I, Debbie Smith, the Plaintiff herein, verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. " au w O Date Debbie Smith, Plaintiff r-; C_ fi ?? O \? r?? U IP 4 r', l (\} ?+Y :, r T \},\ 1 ?/ l _r Ali .? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBBIE SMITH, Plaintiff, Civil Action - Law V. No. 06-3838 PHYLLIS SHARO, JURY TRIAL DEMANDED Defendant. PRAECIPE FOR ENTRY OF APPEARANCE PURSUANT TO Pa.R.C.P.1012 TO THE PROTHONOTARY: Kindly enter the appearance of Michael B. Scheib, Esquire, of Griffith, Strickler, Lerman, Solymos & Calkins, as attorneys for the Defendant, Phyllis Sharo, in the above-captioned matter and mark the docket accordingly. Hereby demands a twelve (12) juror jury trial in the above-captioned action. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINSn Date: at BY: Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 Attorney for Defendant, Phyllis Sharo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBBIE SMITH, V. Plaintiff, Civil Action - Law No. 2004-SU-366-Y01 PHYLLIS SHARO, JURY TRIAL DEMANDED Defendant. CERTIFICATE OF SERVICE AND NOW, this day of July, 2006, I, Michael B. Scheib, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of the Praecipe for Entry of Appearance by United States Mail, addressed to the party or attorney of record as follows: Karl E. Rominger, Esquire Rominger & Whare 155 South Hanover Street Carlisle, PA 17013 (plaintiffs counsel) GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS BY: MICHAEL B. SCHEIB, ESQUIRE Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 Attorney for Defendant, Phyllis Sharo -_? ?> ..;; _.. .? _? ?? - ?::- .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBBIE SMITH, Civil Action - Law Plaintiff, V. No. 06-3838 PHYLLIS SHARD, JURY TRIAL DEMANDED Defendant. NOTICE TO PLEAD TO: Debbie Smith, Plaintiff c/o Karl E. Rominger, Esquire Rominger & Whare 155 South Hanover Street Carlisle, PA 17013 You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS Dated: F/92. 0(to BY: MICHAEL B. SCHEIB, ESQUIRE Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 Attorney for Defendant, Phyllis Sharo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBBIE SMITH, Plaintiff, Civil Action - Law V. PHYLLIS SHARO, Defendant. No. 06-3838 JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANT. PHYLLIS SHARO. TO PLAINTIFF'S COMPLAINT COME NOW Defendant, PHYLLIS SHARO, by her attorneys Griffith, Strickler, Lerman, Solymos & Calkins and MICHAEL B. SCHEIB, Esquire, and responds to the allegations in Plaintiffs Complaint as follows: 1. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph no. 1 of Plaintiffs Complaint and same are denied and strict proof thereof is demanded. 2. Admitted. 3. Admitted in part and denied in part. It is admitted the accident occurred at said intersection. The remaining allegations are denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph no. 3 of Plaintiffs Complaint and same are denied and strict proof thereof is demanded. 4. Admitted in part and denied in part. The date and time are incorrect. The remaining allegations are admitted. 5. Admitted in part and denied in part. The date and time are incorrect. The remaining allegations are admitted. 6. Denied. This paragraph states a legal conclusion to which no response is required. 7. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph no. 7 of Plaintiffs Complaint and same are denied and strict proof thereof is demanded. 8. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph no. 8 of Plaintiffs Complaint and same are denied and strict proof thereof is demanded. 9. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required the allegations are denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph no. 9 of Plaintiffs Complaint and same are denied and strict proof thereof is demanded. 10. Denied. This paragraph states a legal conclusion to which no response is required. On the contrary, and at all times relevant the Defendant, Phyllis Sharo acted in a lawful, careful, safe and prudent manner and with due care as required by the circumstances. 11, Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required the allegations are denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph no. 11 of Plaintiffs Complaint and same are denied and strict proof thereof is demanded. 2 12. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph no. 12 of Plaintiffs Complaint and same are denied and strict proof thereof is demanded. 13. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph no. 13 of Plaintiffs Complaint and same are denied and strict proof thereof is demanded. WHEREFORE, Defendant, Phyllis Sharo respectfully request this Honorable Court to enter judgment in her favor, together with costs of suit. BY WAY OF FURTHER DEFENSE NEW MATTER 14. Paragraphs 1-13 of Defendant's Answer with New Matter are incorporated herein, as though fully set forth at length. 15. Plaintiffs recovery, if any, maybe barred or limited by the Motor Vehicle Financial Responsibility Law. 16. Plaintiffs recovery, if any, maybe barred or limited by the limited tort selection. 17. Plaintiffs injuries, if any, were caused by the acts and omissions of a third party over whom Defendant, Phyllis Sharo had no control. 18. Plaintiffs injuries, if any, were caused by events which either predated or postdated the motor vehicle accident which is the subject of this lawsuit. 3 % Plaintiffs injuries, if any, were caused by the Plaintiff's contributory or comparative negligence. 20. Plaintiff has selected the limited tort option. WHEREFORE, Defendant, Phyllis Sharo respectfully request this Honorable Court to enter judgment in her favor, together with costs of suit. Date: o'? D4 Respectfully submitted, GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS BY ]&Ad/r- MICHAEL B. SCHEIB, ESQUIRE Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 Attorney for Defendant, Phyllis Sharo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBBIE SMITH, V. PHYLLIS SHARD, Plaintiff, Defendant. Civil Action - Law No. 06-3838 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this day of August, 2006, I, MICHAEL B. SCHEIB, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of the Answer and New Matter of Defendant, Phyllis Sharo to Plaintiffs' Complaint via first-class mail, postage prepaid, addressed to the party or attorney of record as follows: Karl E. Rominger, Esquire Rominger & Whare 155 South Hanover Street Carlisle, PA 17013 (plaintiffs counsel) GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS prij, 14 /JM I BY: MICHAEL B. CHEI , ESQUIRE Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 Attorney for Defendant, Phyllis Sharo VERIFICATION 1, Phyllis Sharo, hereby verify that the statements made in the foregoing Answer and New Matter to Plaintiffs' Complaint, are true and correct to the best of my personal knowledge or information and belief, as well as reports, records, conferences and other investigatory material made available to me. To the extent that the foregoing contains averments which are inconsistent in fact, I verify that my knowledge or information is sufficient to form a belief that one or more of them is true, although I am currently unable, after reasonable investigation, to ascertain which of the inconsistent averments are true. To the extent that the foregoing contains legal conclusions or opinions, I hereby state that my Verification is made upon the advice of counsel, upon whom I have relied in the filing this document. This Verification is made subject to the penalties of 18 Pa. C.S. § 4904 related to unsworn falsifications to authorities. Dated: 8 ?a By: 4LPIS ARO m O ? {4;- 3 ! T Mii ? ?O TI ? 4 L O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBBIE SMITH, Plaintiff CIVIL ACTION - LAW V. PHYLLIS SHARD, Defendant NO. 06-3838 JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a Subpoena for documents and things pursuant to Rule 4009.22, Defendant, Phyllis Sharo, certifies that: 1. the twenty (20) day period has been waived by opposing counsel as per the attached letter to opposing counsel; 2. a copy of the letter, including the proposed Subpoenas, is attached to this certificate; 3. no objections to the Subpoenas have been received; and, 4. the Subpoenas which will be served are identical to the Subpoenas which are attached to this Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS Date: n 0 U e-r L7-, 2006 i r By: ` MI EL B. CHEIB, ES UIRE Supreme Court I.D. No. 63868 110 South Northern Way York, PA 17402-3737 (717) 757-7602 Attorney for Defendant, Phyllis Sharo LAW OFFICES GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS 110 S. NORTHERN WAY YORK, PENNSYLVANIA 17402-3737 ROBERT M. STRICKLER TELEPHONE: (717) 757-7602 ANN MARGARET GRAB ROBERT A. LERMAN° FAX: (717) 757-3783 DAVID E. COOK PETER D. SOLYMOS EMAIL: info0aslsc.com LORI M. PETERS CHARLES B. CALKINS WEBSITE: asisc.com PAUL G. LUTZ OF COUNSEL MICHAEL B. SCHEIB* THOMAS B. SPONAUGLE Michael B. Scheib's E-MAIL: Mscheib fpsimoom ROBERT H. GRIFFITH MICHAEL P. BIANCHINI "Also Member MD Bar -LL.M (Taxation); also Member CT Bar 'Also Member NY and D.C. Bars November 15, 2006 Karl E. Rominger, Esquire Rominger & Whare 155 South Hanover Street Carlisle, PA 17013 Re: Debbie Smith v. Phyllis Sharo Cumberland County Docket 06-3838 Dear Attorney Rominger: This letter will confirm that you will waive the 20-day notice in connection with the three Subpoenas. I thank you in advance for your cooperation. If this letter does not accurately reflect your understanding, please contact my office immediately. Very trul yours, MICHAEL B. SCHEIB L cs/sharo/ltr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBBIE SMITH, CIVIL ACTION - LAW Plaintiff V. NO. 06-3838 PHYLLIS SHARD, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Milton S. Hershey Medical Center, Health Information Services, HU-24, P.O. Box 850, Hershey, PA 17033-0850 (Name of Person or Entity) Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: Any office notes, reports, records, memoranda, correspondence, diagnostic tests and/or reports, consultation reports, x-rays, progress notes, hospital records, nurses notes, admission and discharge summaries and records and reports of examinations and any other medical records of any kind for the period July 1, 2000, to the present pertaining to Debra Smith a/k/a Debra Kay Wiley, Social Security No. 202-46-7418, Date of Birth: 04/14/1955. at Griffith, Strickler, Lerman, Solymos & Calkins, 110 S. Northern Way, York, PA 17402-3737 (Address) You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL B. SCHEIB, ESQUIRE ADDRESS: GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS 110 South Northern Way, York, PA 17402-3737 TELEPHONE: (717) 757-7602 SUPREME COURT ID: 63868 ATTORNEY FOR: Defendants, Joshua D. Stiles and Henkels & McCoy, Inc. BY THE COURT: DATE: Seal of Court Prothonotary / Clerk, Civil Division IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBBIE SMITH, Plaintiff CIVIL ACTION - LAW V. PHYLLIS SHARO, Defendant NO. 06-3838 JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Three Springs Family Practice 303 North Baltimore Avenue Mount Holly Springs, PA 17065 (Name of Person or Entity) Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: Any office notes, reports, records, memoranda, correspondence, diagnostic tests and/or reports, consultation reports, x-rays, progress notes, hospital records, nurses notes, admission and discharge summaries and records and reports of examinations and any other medical records of any kind for the period July 1, 2000, to the present pertaining to Debra Smith a/k/a Debra Kay Wiley, Social Security No. 202-46-7418, Date of Birth: 04/14/1955. at Griffith Strickler Lerman Solymos & Calkins 110 S Northern Way, York, PA 17402-3737 (Address) You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL B SCHEIB ESQUIRE ADDRESS: GRIFFITH STRICKLER LERMAN, SOLYMOS & CALKINS 110 South Northern Way York PA 17402-3737 TELEPHONE: (717) 757-7602 SUPREME COURT ID: 63868 ATTORNEY FOR: Defendants Joshua D Stiles and Henkels & McCoy, Inc. BY THE COURT: DATE: Seal of Court Prothonotary / Clerk, Civil Division IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBBIE SMITH, Plaintiff CIVIL ACTION - LAW V. PHYLLIS SHARD, Defendant NO. 06-3838 JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Penn's Wood Physical Thergpy, 419 Stonehedge Drive Suite 3, Carlisle, PA 17013 (Name of Person or Entity) Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: Any office notes, reports, records, memoranda, correspondence, diagnostic tests and/or reports, consultation reports, x-rays, progress notes, hospital records, nurses notes, admission and discharge summaries and records and reports of examinations and any other medical records of any kind for the period July 1, 2000, to the present pertaining to Debra Smith a/k/a Debra Kay Wiley, Social Security No. 202-46-7418, Date of Birth: 04/14/1955. at GriffithStrickler Lerman Solymmos & Calkins 110 S. Northern Way, York, PA 17402-3737 (Address) You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL B. SCHEIB, ESQUIRE ADDRESS: GRIFFITH STRICKLER, LERMAN, SOLYMOS & CALKINS 110 South Northern Way, York, PA 17402-3737 TELEPHONE: (717) 757-7602 SUPREME COURT ID: 63868 ATTORNEY FOR: Defendants Joshua D. Stiles and Henkels & McCoy, Inc. BY THE COURT: DATE: Seal of Court Prothonotary / Clerk, Civil Division IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBBIE SMITH, Plaintiff . V. PHYLLIS SHARO, Defendant . CIVIL ACTION - LAW NO. 06-3838 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 17`t' day of November, 2006, I, Michael B. Scheib, Esquire, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of Certificate Prerequisite to Service of Subpoenas Pursuant to Rule 4009.22 by United States Mail, postage prepaid, addressed to the party or attorney of record as follows: Karl E. Rominger, Esquire Rominger & Whare 155 South Hanover Street Carlisle, PA 17013 (Counsel for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS/+ 11 By: MICHAEL B. SCHEIB, ESQL Supreme Court I.D. No. 63868 110 South Northern Way York, PA 17402-3737 (717) 757-7602 Attorney for Defendant, Phyllis Sharo r._? s? ---f ? -i't _ '---, r c-: N ,.?, - °-e €.,.3 '.f r v Y9 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBBIE SMITH, N0.06-3838 Plaintiff V. PHYLLIS SHARO, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE TO: Prothonotary Please mark this matter settled, discontinued and ended. Date: , 2008 ROMINGER & WHARF By: K ZRominger, . Esquire Attorney I.D. No. 81924 155 South Hanover Street Carlisle, PA 17013 Telephone (717) 241-6070 Fax (717) 241-6878 Attorney for Plaintiff I -TI