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HomeMy WebLinkAbout06-4502JEFFREY S. LAIRD, Plaintiff VS. PATRICIA CONLEY and ROGER PETERSON, Defendants To: Patricia Conley, Defendant Roger Peterson, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 64y - qZav 01cUC(,??'Jt JURY TRIAL DEMANDED NOTICE TO DEFEND 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 you defenses or opjections 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 of 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. Lawyer Referral Service of the Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 S L 1 654642v 1 /0069 56.00001 JEFFREY S. LAIRD, Plaintiff vs. PATRICIA CONLEY and ROGER PETERSON, Defendants IN THE COURT OF COMMON PLEAS OF CU MBERLAND COUNTY, PENNSYLVANIA NO. JURY TRIAL DEMANDED COMPLAINT COUNTI Jeffrey Laird v. Patricia Conley The amount in controversy is greater than the limits of compulsory arbitration, exclusive of interest and costs. 2. The plaintiff, Jeffrey Laird, is an adult individual residing at 293 Montebello Farm Road, Duncannon, Perry County, Pennsylvania 17020. Defendants, Patricia Conley and Roger Peterson are adult individuals residing at 4 Adams Street (Rear), Enola, Pennsylvania 17015. 4. On or about August 12, 2004, at approximately 6:00 a.m., the plaintiff was the operator of a Honda motorcycle traveling south on State Road in Perry County, Pennsylvania. 5. At the aforesaid time and place, the defendant, Patricia Conley, was operating a motor vehicle north on State Road and turned directly in front of plaintiff. 6. At the aforesaid time and place, the vehicle operated by defendant, Patricia Conley, caused plaintiff to lose control of his motorcycle, resulting in an accident. 7. The aforesaid accident was caused by the negligence, carelessness and recklessness of the defendant, said negligence, carelessness and recklessness consisting of the following: (a) Failing to see plaintiff, SLI 654642v1/006956.00001 (b) Failing to maintain control of the vehicle; (c) Turning into the path of plaintiff; (d) Failing to properly operate the vehicle; (e) Failing to yield the right of way; (f) Failing to have the motor vehicle under proper and adequate control; (g) Failing to operate the vehicle at a safe speed; (h) Being inattentive; (i) Failing to regard the rights, safety and position of the plaintiff at the point aforesaid; 0) Operating the motor vehicle in a reckless manner; (k) Failing to maintain a proper lookout; (1) Operating said motor vehicle in a manner likely to endanger the life and safety of others, including the plaintiff; (m) Failing to exercise due care; (n) Failing to obey the traffic signs or signals then and there existing; (o) Failing to see and observe plaintiffs vehicle in sufficient time to avoid an accident; (p) Otherwise being negligent, careless and reckless under the circumstances; and (q) Violating the laws of the Commonwealth of Pennsylvania as set forth in the Pennsylvania Motor Vehicle Code. 8. As a result of the aforesaid accident and the conduct of the defendant, the plaintiff, Jeffrey Laird, suffered numerous, severe, permanent, irreparable and disabling injuries, 3 SLl 654642v 1 /006956.00001 including but not limited to multiple contusions, broken thumb, right knee pain, multiple surgeries, emotional upset, severe shock to the nervous system and numerous other injuries. 9. As a further result of the aforesaid accident and the conduct of the defendant, plaintiff was or may be obligated to accumulate and to continue in the future to accumulate reasonable and necessary medical expenses for physicians' fees, hospital bills, therapeutic treatments, rehabilitation, medicines and various other expenses. 10. As a further result of the aforesaid accident and the conduct of the defendant, the plaintiff lost wages and may suffer an effect on future earning capacity, said amounts to be proven at time of trial. 11. As a further result of the aforesaid accident and the conduct of the defendant, plaintiff has undergone much pain, suffering and inconvenience, is undergoing much pain, suffering and inconvenience, and will in the future be required to undergo much pain, suffering and inconvenience. 12. As a direct result of the aforesaid accident and the conduct of the defendant, plaintiff was unable to follow his usual social and recreational activities, and may be unable to follow such usual social and recreational activities in the future. 13. As a direct result of the aforesaid accident and the conduct of the defendant, plaintiffs enjoyment of life has been impaired from the date of the accident until present and further may be impaired for some time in the future. WHEREFORE, plaintiff, Jeffrey Laird, demands judgment against the defendant, Patricia Conley, in an amount in excess of $30,000, plus costs, interest and delay damages. COUNT II Jeffrey Laird v. Roder Peterson 14. The plaintiff, Jeffrey Laird, incorporates paragraphs 1 through 14, inclusive, as if set forth in full. 4 SLl 654642v1 /006956.00001 15. At all times material hereto, defendant, Patricia Conley, was the agent, servant and/or employee of the defendant, Roger Peterson, acting within the scope and course of her agency and/or employment. 16. The negligence, carelessness and recklessness of the defendant, Patricia Conley, is imputed to the defendant, Roger Peterson, by way of the doctrine of respondeat superior and/or vicarious liability. 17. In the event that defendant, Roger Peterson, permitted defendant, Patricia Conley, to operate said vehicle at a time when Patricia Conley was not licensed to drive, not physically and/or mentally capable of safe or proper driving and/or at a time when the driving record of Patricia Conley made such permission unreasonable, then defendant, Roger Peterson, negligently entrusted said vehicle to defendant, Patricia Conley, and thereby caused said accident and the resulting injuries. WHEREFORE, plaintiff, Jeffrey Laird, demands judgment against the defendant, Roger Peterson, in an amount in excess of $30,000, plus costs, interest and delay damages. Dated: August y , 2006 STEVENS & LEE By ?K' oC AyPw'" + Kirk L. Wolgemuth Attorney I.D. No. 45792 25 North Queen Street P.O. Box 1594 Lancaster, Pennsylvania 17608-1594 717-399-6641 Attorneys for Plaintiff SLl 654642v1/006956.00001 VERIFICATION I, JEFFREY LAIRD, verify that I am the Plaintiff in the within action; that the attached Complaint is based upon the facts of which I have personal knowledge or information famished to me by counsel; that the language of the document is that of counsel and not my own; and that the facts set forth in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falssiWation to authorities. ?xWoj,4?. Ain Date: August '5„ 2006 08/02/06/SLl 654642v l /006956.00001 4R. I W 0 { BARLEY SNYDER Ronald H. Pollock, Jr., Esquire Court I.D. No. 52586 126 East King Street Lancaster, PA 17602 (717) 299-5201 JEFFREY S. LAIRD V. PATRICIA CONLEY and ROGER PETERSON, Plaintiff Defendants Attorneys for Defendants Patricia Conley and Roger Peterson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 06-4502 JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please enter the appearance of Ronald H. Pollock, Jr., Esquire, on behalf of Defendants Patricia Conley and Roger Peterson in the above matter. Kindly serve all papers at 126 East King Street, Lancaster, PA 17602-2893. BARLEY SNYDER LLC Dated: AtGgusf'z?? By:(G Ronald H. Pollock, Jr., Esquire Attorneys for Defendants 1695532_I.DOC CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document has been served this a/ day of f 2006, by first class mail, postage prepaid, upon: Kirk L. Wolgemuth, Esquire Stevens & Lee P.O. Box 679 Reading, PA 19603 BARLEY SNYDER LLC By: Ronald H. Pollock, Jr., Esquire Court I.D. 52586 Attorneys for Defendants Patricia Conley and Roger Peterson 126 East King Street Lancaster, PA 17602-2893 717-299-5201 ca 0 G, 0 c ? ,? ?- x -?. -?,??, ? nor .. - ?? ;- N rw i ?_' (: p S' ^? . SHERIFF'S RETURN - REGULAR CASE NO: 2006-04502 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LAIRD JEFFREY S VS CONLEY PATRICIA ET AL MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE CONLEY PATRICIA was served upon the DEFENDANT , at 1250:00 HOURS, on the 16th day of August , 2006 at 4 ADAMS STREET REAR ENOLA, PA 17025 PATRICIA CONLEY by handing to 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: So Answers: Docketing Service 18.00 13.20 Postage .39 P Surcharge 10.00 R. Thomas Kline .00 41.59 08/18/2006 C STEVENS & LEE Sworn and Subscibed to By: before me this day Deputy She iff of A. D. t A SHERIFF'S RETURN - REGULAR CASE NO: 2006-04502 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LAIRD JEFFREY S VS CONLEY PATRICIA ET AL MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon DV7VVQnrT Rnr_'PR the DEFENDANT , at 1250:00 HOURS, on the 16th day of August , 2006 at 4 ADAMS STREET REAR ENOLA, PA 17025 by handing to PATRICIA CONLEY, GIRLFRIEND 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: So Answers: Docketing 6.00 Service .00 Affidavit .00` Surcharge 10.00 R. Thomas Kline .00- 16.00/ 08/18/2006 91? I d(, STEVENS & LEE Sworn and Subscibed to By: ,- before me this day ----- Deputy Sheriff of A. D. ob . BARLEY SNYDER LLC Ronald H. Pollock, Jr., Esquire Court ID No. 52586 126 East King Street Lancaster, PA 17602-2893 717-299-5201 JEFFREY S. LAIRD, V. PATRICIA CONLEY and ROGER PETERSON, Plaintiff, Defendants, Attorneys for Defendants Patricia Conley and Roger Peterson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA i Civil Action - Law No. 06-4502 Civil Term Jury "Trial Demanded NOTICE TO PLEAD To: Jeffrey S. Laird c/o Kirk L. Wolgemuth, Esquire YOU ARE HEREBY NOTIFIED that you may need to file a written response to the attached New Matter and New Matter Pursuant to Pa.R.C.P. 2252(d) within twenty (20) days from service hereof. If a response is required and none is filed, a judgment may be entered against you. Dated: ?hw" / 200? BARLEY SNYDER LLC By: h e-1 Ronald H. Pollock, Jr., Esquire Court ID No. 52586 Attorneys for Defendants Patricia Conley and Roger Peterson 126 East King Street Lancaster, PA 17602-2893 717-299-5201 8/30/2006/RHP/ 1698438.1 JEFFREY S. LAIRD, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - Law V. PATRICIA CONLEY and ROGER PETERSON, No. 06-4502 Civil Term Jury Trial Demanded Defendants, ANSWER AND NEW MATTER OF DEFENDANTS PATRICIA CONLEY AND ROGER PETERSON TO COMPLAINT OF JEFFREY S. LAIRD ANSWER 1. Denied. The averments of Paragraph 1 are denied as conclusions of law to which no responsive pleading is required. 2. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of Paragraph 2 and strict proof thereof is demanded. 3. Admitted. 4. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of Paragraph 4 and strict proof thereof is demanded. 5. Denied as stated. Defendant Conway was operating a motor vehicle north on State Road. She was in the left-turn lane and intended to make a left turn into the gas station. She had just turned her wheel into the oncoming lane of travel when she saw Plaintiff's motorcycle go onto its side while still some distance from her car. 8/30/2006/RHP/1698438.1 2 4 6. Denied. Defendant is unable to state precisely why Plaintiff lost control of his motorcycle. By way of further answer, the averments of Paragraph 6 are denied as stating conclusions of law to which no responsive pleading is required. 7. Denied. The averments of Paragraph 7 are denied as conclusions of law to which no responsive pleading is required. 8.- 13. Denied. The averments of Paragraphs 8 through 13 inclusive are denied as conclusions of law to which no responsive pleading is required. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the remaining of these paragraphs and strict proof thereof is demanded. WHEREFORE, Defendants Patricia Conley and Roger Peterson respectfully request this Honorable Court to dismiss Count I of Plaintiffs Complaint with prejudice. COUNT II 14. Denied. Defendants hereby incorporate by reference Paragraphs I through 13 of this Answer and New Matter as if fully set forth herein at length. 15. Denied. The averments of Paragraph 15 are denied as conclusions of law to which no responsive pleading is required. 16. Denied. The averments of Paragraph 17 are denied as conclusions of law to which no responsive pleading is required. 17. Denied. It is specifically denied that Defendant Conley is not licensed to drive, not physically and/or mentally capable of safe or proper driving, or was otherwise at a time when her driving record made permission to drive a vehicle unreasonable. By way of further answer, the averments of Paragraph 17 are denied as conclusions of law to which no responsive pleading is required. 8/30/2006/RHP/ 1698438.1 3 WHEREFORE, Defendants Patricia Conley and Roger Peterson respectfully request this Honorable Court to dismiss Count II of Plaintiffs Complaint with prejudice. NEW MATTER 18. Plaintiff s claims are barred or limited by provisions of the Pennsylvania Comparative Negligence Act. 19. Plaintiff s claims are barred or limited by the doctrine of assumption of the risk. 20. Plaintiff s claims are barred or limited by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. WHEREFORE, Defendants Patricia Conley and Roger Peterson respectfully request this Honorable Court to grant judgment in their favor and against Plaintiff. Dated: / Zvd? BARLEY SNYDER LLC By: R'o'nald H. Pollock, Jr., Esquire Court ID No. 52586 Attorneys for Defendants Patricia Conley and Roger Peterson 126 East King Street Lancaster, PA 17602-2893 717-299-5201 8/30/2006/RHP/ 1698438.1 VERIFICATION I, Ronald H. Pollock, verify that I am the attorney for Defendants Patricia Conley and Roger Peterson, whose verification cannot be obtained within the time allowed for the filing of this pleading, and, based on information received from Patricia Conley and Roger Peterson, verify that the facts set forth in the foregoing Answer and New Matter are true and correct to the best of my knowledge, information and belief. This Verification is made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Dated: ` o2U 07 -kew onald H. Pollock, Esquire 8/3 0/2006/RH P/ 169843 8.1 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document has been , 2006, by first class mail, postage served this l S= day of 17 prepaid, upon: 410 Kirk L. Wolgemuth, Esquire Stevens & Lee PC P. O. Box 1594 Lancaster, PA 17608-1594 BARLEY SNYDER LLC By: Ronald H. Pollock, Jr., Esquire Court I.D. 52586 Attorneys for Defendants Patricia Conley and Roger Peterson 126 East King Street Lancaster, PA 17602-2893 717-299-5201 8/3 0/2006/R.HP/ 1698438.1 °y c;? i t ? _--1 -,^ "" "T. <'t??- ,C t;4;- 1 C ? ?; '_? .y ; ,?? f - -1 JEFFREY S. LAIRD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 06-4502 PATRICIA CONLEY and ROGER PETERSON, : JURY TRIAL DEMANDED Defendants PLAINTIFF'S REPLY TO DEFENDANTS' NEW MATTER The Plaintiff, Jeffrey S. Laird, responds to Defendants' New Matter as follows: 18. Denied. The averments of Paragraph 18 are conclusions of law to which no responses are required. 19. Denied. The averments of Paragraph 19 are conclusions of law to which no responses are required. 20. Denied. The averments of Paragraph 20 are conclusions of law to which no responses are required. WHEREFORE, the Plaintiff requests this Court to enter judgment in its favor and against the Defendants. Respectfully submitted, STEVENS & LEE Dated: February i.5, 2007 02/ 15/07/SL 1 6994100/006956.00001 By t 0 Kirk L. Wolgemuth Attorney I.D. No. 45792 25 North Queen Street P.O. Box 1594 Lancaster, Pennsylvania 17608-1594 717-399-6641 Attorneys for Plaintiff 1 CERTIFICATE OF SERVICE I, KIRK L. WOLGEMUTH, ESQUIRE, certify that on this date, I served a certified true and correct copy of the foregoing PLAINTIFF'S REPLY TO DEFENDANTS' NEW MATTER upon the following counsel of record, by depositing the same in the United States mail, postage prepaid, addressed as follows: Ronald H. Pollock, Jr., Esquire Barley Snyder LLC 126 East King Street Lancaster, Pennsylvania 17602-2893 Date: February 15, 2007 2 02/15/07/SLl 699410v 1/006956.00001 N + :F y ... r F7 f ?_ rn t£? r BARLEY SNYDER LLC Ronald H. Pollock, Jr., Esquire Court ID No. 52586 126 East King Street Lancaster, PA 17602-2893 717-299-5201 JEFFREY S. LAIRD, Plaintiff, V. PATRICIA CONLEY and ROGER PETERSON, Defendants, ORIGINAL No. 06-4502 Attorneys for Defendants Patricia Conley and Roger Peterson THE COURT OF COMMON PLEAS OF MBERLAND COUNTY, PENNSYLVANIA ,il Action - Law o. 06-4502 Civil Term ury Trial Demanded CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 TO: Kirk L. Wolgemuth, Esquire Stevens & Lee PC P. O. Box 1594 Lancaster, PA 17608-1594 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendants Patricia Conley and Roger Peterson, certify that: (1) a notice of intent to serve the subpoenas with a copy of the subpoenas attached thereto was mailed or delivered to each party at least twenty (20) days prior to the date on which the subpoenas are sought to be served, (2) a copy of the notice of intent, including the proposed subpoenas, is attached to this certificate, (3) no objection to the subpoenas has been received, and 1902541-1 No. 06-4502 (4) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoena. BARLEY SNYDER LLC Dated: tlc-:?? cig By: / Ronald Pollock, Esquire Attorney for Defendants Patricia Conley and Roger Peterson 126 East King Street Lancaster, PA 17602-2893 Court I.D. No. 52586 (717) 299-5201 1902541-1 No. 06-4502 CERTIFICATE OF SERVICE [Laird v. Conley and Peterson] I HEREBY CERTIFY that a true and correct copy of the foregoing Certificate of Prerequisite to Serve a Subpoena was served this day of , 2007 by first class mail, postage prepaid, upon the following: Kirk L. Wolgemuth, Esquire Stevens & Lee PC P. O. Box 1594 Lancaster, PA 17608-1594 BARLEY SNYDER LLC gonald Pollock, Esquire Attorney for Defendants Patricia Conley and Roger Peterson 126 East King Street Lancaster, PA 17602-2893 Court I.D. No. 52586 (717) 299-5201 1902541-1 No. 06-4502 r BARLEY SNYDER LLC Ronald H. Pollock, Jr., Esquire Court ID No. 52586 126 East King Street Lancaster, PA 17602-2893 717-299-5201 JEFFREY S. LAIRD, Plaintiff, V. PATRICIA CONLEY and ROGER PETERSON, Defendants, Attorneys for Defendants Patricia Conley and Roger Peterson THE COURT OF COMMON PLEAS OF MBERLAND COUNTY, PENNSYLVANIA vil Action - Law o. 06-4502 Civil Term ury Trial Demanded CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 TO: Kirk L. Wolgemuth, Esquire Stevens & Lee PC P. O. Box 1594 Lancaster, PA 17608-1594 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendants Patricia Conley and Roger Peterson, certify that: (1) a notice of intent to serve the subpoenas with a copy of the subpoenas attached thereto was mailed or delivered to each party at least twenty (20) days prior to the date on which the subpoenas are sought to be served, (2) a copy of the notice of intent, including the proposed subpoenas, is attached to this certificate, (3) no objection to the subpoenas has been received, and 1902541-1 No. 06-4502 (4) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoena. BARLEY SNYDER LLC Dated: By: / `" C *// Ronald Pollock, Esquire Attorney for Defendants Patricia Conley and Roger Peterson 126 East King Street Lancaster, PA 17602-2893 Court I.D. No. 52586 (717) 299-5201 1902541-1 No. 06-4502 r BARLEY SNYDER LLC Ronald H. Pollock, Jr., Esquire Court ID No. 52586 126 East King Street Lancaster, PA 17602-2893 717-299-5201 JEFFREY S. LAIRD, Plaintiff, Attorneys for Defendants Patricia Conley and Roger Peterson THE COURT OF COMMON PLEAS OF TMBERLAND COUNTY, PENNSYLVANIA vil Action - Law V. PATRICIA CONLEY and ROGER PETERSON, Defendants, TO: Navy Depot Code Osm Bldg 303 Mechanicsburg, PA 17055 06-4502 Civil Term Trial Demanded NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the subpoena issued on , 2007 have been produced. Date: By: 1902541-1 No. 06-4502 CERTIFICATE OF SERVICE [Laird v. Conley and Peterson] I HEREBY CERTIFY that a true and correct copy of the foregoing Certificate of Prerequisite to Serve a Subpoena was served this day of , 2007 by first class mail, postage prepaid, upon the following: Kirk L. Wolgemuth, Esquire Stevens & Lee PC P. O. Box 1594 Lancaster, PA 17608-1594 BARLEY SNYDER LLC Ronald Pollock, Esquire Attorney for Defendants Patricia Conley and Roger Peterson 126 East King Street Lancaster, PA 17602-2893 Court I.D. No. 52586 (717) 299-5201 1902541-1 C? C~-7 0 C ? -n -'; ) -rt m: 7 C 7 4"-y s"rt JEFFREY S. LAIRD, ; IN THE COURT OF COMMON PLEAS OF Plaintiff, ; CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - Law V. No. 06-4502 Civil Term PATRICIA CONLEY and ROGER PETERSON, ; Jury Trial Demanded Defendants, PRAECIPE TO SETTLE, DISCONTINUE AND END; n ? To: Prothonotary Please mark the above matter settled, ended, discontinued and costs paid. STEVENS & LEE PC C-) --- m --t Dated: By: e, Koe? Kirk L. Wolgemuth, Esquire Court ID No. ?' 5 7 `?Z . Attorneys for Plaintiff Jeffrey S. Laird P.O. Box 1594 Lancaster, PA 17608-1594 717-399-6641 DISCONTINUANCE CERTIFICATE AND NOW, this 54 day of ?¢r hor , 2007, suit has been marked as above directed. Prothonotary 2056005.1 C r? w 1 Cs"?