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HomeMy WebLinkAbout06-5134Gregory R. Reed, Esquire 3120 Parkview Lane Harrisburg, PA 17111 (717) 238-0434 E-mail: lawoffice(&,epix.net ROBERT VIDACS and DOROTHY PETERS VIDACS Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. D(c - 5134 0,i m Term KAUSAR MOOSA, Defendant JURY TRIAL DEMANDED NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COUNT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Defendant. 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas quese presentan mas adelante en las siguientes paginas, debe toma accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en constra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Date:Wj elo Gregory R. eed, Esquire Attorney for Plaintiffs 3120 Parkview Lane Harrisburg, PA 17111 (717) 238-0434 Attorney I.D. No. 23705 ROBERT VIDACS and IN THE COURT OF COMMON PLEAS DOROTHY PETERS VIDACS OF CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA V. NO. 0 ( - Sl3Y 014;?_j TZ, KAUSAR MOOSA, Defendant JURY TRIAL DEMANDED COMPLAINT COMES NOW Robert Vidacs and Dorothy Peters Vidacs, by and through their attorney, Gregory R. Reed, Esquire, and for their causes of action allege: 1. Robert Vidacs and Dorothy Peters Vidacs (hereinafter collectively referred to as "Plaintiffs"), are adult individuals, presently residing at 122 East Coover Street, Mechancisburg, Cumberland County, Pennsylvania. 2 Kausar Moosa (hereinafter referred to as "Defendant'), is an adult individual who presently resides at 1426 North Second Street, Harrisburg, Dauphin County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on January 17, 2006 at or near the intersection of State Road and Beltsville Drive in Silver Spring Township, Cumberland County, Pennsylvania at approximately 7:30 P.M. 4. At about that time and place Plaintiff Robert Vidacs was the operator of a 1992 Dodge Dakota pick-up truck that was traveling north on State Road approaching the intersection with Beltsville Drive. 5. At about that time and place Defendant was the operator of a 2001 Mitsubishi automobile and was traveling south on State Road. 6. Upon reaching the Beltsville Drive intersection, Defendant's vehicle suddenly made a left turn across State Road and into the path of Plaintiff, Robert Vidacs' vehicle, causing Plaintiff's vehicle to collide with Defendant's vehicle. 7. As a direct result of the aforesaid collision Plaintiff, Robert Vidacs sustained severe, painful and disabling injuries. 8. The aforesaid collision and all the hereinafter mentioned injuries and damages sustained by Plaintiffs are the direct result of the negligence, carelessness and recklessness of Defendant as follows: (a) In failing to keep alert and maintain a proper lookout for the presence of other motor vehicles on the highway; (b) In failing to keep proper and adequate control of her vehicle; (c) In failing to stop her vehicle from colliding with Plaintiff's vehicle; (d) In operating her vehicle without due regard for the rights, safety and position of Plaintiff's vehicle at the time and place of the aforesaid collision; (e) In failing to give a signal or other warning to alert Plaintiff that Defendant's vehicle would cross into the path of Plaintiff's vehicle. (f) In failing to keep her vehicle from becoming an obstacle and barrier to oncoming traffic, including Plaintiff s vehicle; (g) In failing to yield the right of way to Plaintiffs vehicle; (h) In failing to apply the brakes of her vehicle in time to avoid striking Plaintiff s vehicle; (i) In failing to take measures to avoid striking Plaintiffs vehicle; and 0) In causing and/or allowing her vehicle to make an improper turn. Count I Robert Vidacs v. Kausar Moosa 9. Paragraphs 1 through 8 inclusive of this Complaint are incorporated herein by reference as though fully set forth herein. 10. As a result of the aforesaid collision Plaintiff, Robert Vidacs, was thrown and jostled about, thereby sustaining painful, permanent, sever and disabling injuries and serious impairment of bodily function including, but not limited to, a closed head injury, left thigh contusion and chest wall contusion. 11. Some of the aforesaid injuries are permanent in nature, and claim is made therefore. 12. By reason of the aforesaid injuries sustained by Plaintiff, Robert Vidacs, he is forced to incur the costs of medical treatment and medicine and other similar expenses in and about an effort to restore himself to health; and because of the nature of said injuries he will be forced to incur similar expenses in the future, and claim is made therefore. 13. As a result of the aforesaid injuries Plaintiff, Robert Vidacs, has suffered permanent loss of enjoyment of life's pleasures, emotional distress, embarrassment, humiliation and disfigurement; and he will continue to do so in the future. 14. As result of the aforesaid injuries, Plaintiff, Robert Vidacs, has and will suffer a loss of earnings and earning power. WHEREFORE, Plaintiff, Robert Vidacs, demands judgment, including costs, against the Defendant, Kausar Moosa, in a sum in excess of the jurisdictional amount requiring compulsory arbitration in Cumberland County, Pennsylvania. COUNT II - CONSORTIUM Dorothy Peters Vidacs v. Kausar Moosa 15. Paragraphs 1 through 14 inclusive of this Complaint are incorporated herein by reference as though fully set forth herein. 16. As a result of the aforesaid injuries sustained by her husband, Robert Vidacs, resulting from the aforesaid negligence of the Defendant, Plaintiff, Dorothy Peters Vidacs, has been deprived of the companionship, comfort, and society of her husband and has been advised that she will be deprived of the same in the future, and claim is made therefore. WHEREFORE, Plaintiff, Dorothy Peters Vidacs, demands judgment, including costs, against the Defendant, Kausar Moosa, in a sum in excess of the jurisdictional amount requiring compulsory arbitration in Cumberland County, Pennsylvania. Date: 2A IR a I/ r Gregory R. Reed, Esquire Attorney for Plaintiffs 3120 Parkview Lane Harrisburg, PA 17111 (717) 238-0434 Attorney I.D. #23705 VERIFICATION We, Robert Vidacs and Dorothy Peters Vidacs, hereby verify that the statements in the foregoing Complaint are based upon information which we have provided to our attorney. We have read the Complaint and the allegations are true and correct to the best of our knowledge, information, and belief. However, the language of the Complaint is that of counsel, and not our own. To the extent that the contents of this Complaint are that of our attorney, we have relied upon him in making this verification. We understand that the statements therein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unswom falsification to authorities. Date: Z/8%oG Date: s-AY/0.6, 0 o rt Vidacs Dorothy Peters 'dacs J t q..r'v t1'1 T=- (.? 4 U 1 Vt ; , 70 _ ' tU 0 J v 7 N ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ROBERT VIDACS and DOROTHY CASE NUMBER: 06-5134 PETERS VIDACS, ISSUE NUMBER: Plaintiffs V. PLEADING: KAUSAR MOOSA, PRAECIPE FOR APPEARANCE Defendant CODE AND CLASSIFICATION: FILED ON BEHALF OF: KAUSAR MOOSA, Defendant. COUNSEL OF RECORD: DENNIS J. BONETTI, ESQUIRE Pa. ID# 34329 CIPRIANI & WERNER, P.C. 1011 Mumma Road, Suite 201 Lemoyne, PA 17043 (717) 975-9600 ti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ROBERT VIDACS and DOROTHY PETERS VIDACS, Plaintiffs V. KAUSAR MOOSA, Defendant CASE NO: 06-5134 PRAECIPE FOR APPEARANCE TO: PROTHONOTARY OF CUMBERLAND COUNTY Kindly enter my appearance on behalf of the Defendant, KAUSAR MOOSA, in the above-captioned matter. BY: Respectfully submitted, CIPRIANI & WWRNER. P.C. /D IS J. BONETTI, ESQUIRE &USAR sel for the Defendant, A JURY TRIAL IS DEMANDED MOOSA CERTIFICATE OF SERVICE That counsel for the Defendant, KAUSAR MOOSA, hereby certifies that a true and correct copy of its PRAECIPE FOR APPEARANCE has been served on all counsel of record, by first class mail, postage re-paid, according to the Pennsylvania Rules of Civil Procedure, on the /4 day of 52006. Gregory R. Reed, Esquire 3120 Parkview Lane Harrisburg, PA 17111 Respectfully submitted, CIPRIQNIA9i WERNER, P.C. BY: DE S J. BONETTI, ESQUIRE Col el for the Defendant, KA SAR MOOSA C`7 r''' c? T" -. CJ _ __ a'+ il + - i . ? ?7°. . . -?`} ?? ,,,? - - • - --i j =` `:'3 --C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ROBERT VIDACS and DOROTHY PETERS VIDACS, Plaintiffs CASE NUMBER: 06-5134 ISSUE NUMBER: V. PLEADING: KAUSAR MOOSA, DEFENDANT'S ANSWER WITH NEW MATTER TO PLAINTIFF'S Defendant COMPLAINT CODE AND CLASSIFICATION: TO: ROBERT VIDACS AND DOROTHY PETERS VIDACS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED ANSWER WITH NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREO?? OR EFAULT JUDGMENT MAY BE EN TEA fNST YOU. DENNISIJ. BONETTI, ESQUIRE FILED ON BEHALF OF: KAUSAR MOOSA, Defendant. COUNSEL OF RECORD: DENNIS J. BONETTI, ESQUIRE Pa. ID# 34329 CIPRIANI & WERNER, P.C. 1011 Mumma Road, Suite 201 Lemoyne, PA 17043 (717) 975-9600 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ROBERT VIDACS and DOROTHY PETERS VIDACS, CASE NO: 06-5134 Plaintiffs V. KAUSAR MOOSA, Defendant JURY TRIAL DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER TO PLAINTIFFS' COMPLAINT AND NOW, comes Defendant, KAUSAR MOOSA, by and through her counsel, Cipriani & Werner, and hereby files the following Answer with New Matter to Plaintiffs' Complaint. 1. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in paragraph I of Plaintiff's Complaint and the same are therefore denied. 2. Admitted. 3. Denied. The averments contained in paragraph 3 are denied pursuant to Pa.R.C.P. 1029(e). 4. Denied. The averments contained in paragraph 4 are denied pursuant to Pa.R.C.P. 1029(e). 5. Denied. The averments contained in paragraph 5 are denied pursuant to Pa.R.C.P. 1029(e). 6. Denied. Defendant is advised by counsel and therefore avers that the allegations contained in paragraph 6 of Plaintiffs' Complaint state conclusions of law to which no answer is required. To the extent that a further answer is required, the averments contained in paragraph 6 are denied pursuant to Pa.R.C.P. 1029(e). 7. Denied. The averments contained in paragraph 7 are denied pursuant to Pa.R.C.P. 1029(e). By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments concerning the nature and extent of injuries suffered by Plaintiff and the same is therefore denied. 8. Denied. Defendant is advised by counsel and therefore avers that the allegations contained in paragraph 8 including sub-paragraphs (a) through 0) inclusive state conclusions of law to which no answer is required. To the extent a further answer is required, the averments contained in paragraph 8 including sub-paragraphs (a) through 0) inclusive are denied pursuant to Pa.R.C.P. 1029(e). COUNTI Robert Vidacs v. Kausar Moosa 9. Denied. Defendant hereby incorporates the answers to paragraphs 1 - 8 as though the same were fully set forth herein at length. 10. Denied. The averments contained in paragraph 10 are denied pursuant to Pa.R.C.P. 1029(e). By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments concerning the nature and extent of injuries suffered by Plaintiff and the same is therefore denied. 11. Denied. The averments contained in paragraph 11 are denied pursuant to Pa.R.C.P. 1029(e). By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments concerning the nature and extent of injuries suffered by Plaintiff and the same is therefore denied. 12. Denied. The averments contained in paragraph 12 are denied pursuant to Pa.R.C.P. 1029(e). By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments concerning the nature and extent of injuries suffered by Plaintiff and the same is therefore denied. 13. Denied. The averments contained in paragraph 13 are denied pursuant to Pa.R.C.P. 1029(e). By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments concerning the nature and extent of injuries suffered by Plaintiff and the same is therefore denied. 14. Denied. The averments contained in paragraph 14 are denied pursuant to Pa.R.C.P. 1029(e). By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments concerning the nature and extent of injuries suffered by Plaintiff and the same is therefore denied. WHEREFORE, Kausar Moosa demands judgment in his favor and against Plaintiffs without costs. COUNT II - CONSORTIUM Dorothy Peters Vidacs v. Kausar Moosa 15. Denied. Defendant hereby incorporates the answers to paragraphs 1 - 14 as though the same were fully set forth herein at length. 16. Denied. The averments contained in paragraph 16 are denied pursuant to Pa.R.C.P. 1029(e). By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments concerning the nature and extent of injuries suffered by Plaintiff and the same is therefore denied. WHEREFORE, Kausar Moosa demands judgment in his favor and against Plaintiffs without costs. NEW MATTER 17. Plaintiffs' claims may be barred by the applicable statute of limitations. 18. Any damages Plaintiff may recover in this action should be reduced or barred, in whole or in part, by the Pennsylvania Motor Vehicle Responsibility Act, as amended. 19. Plaintiffs' alleged injuries and damages, if any, which are specifically denied, may have been caused, either in whole or in part by the acts or omissions of third parties other than Defendant. 20. Plaintiffs' alleged injuries and damages, if any, which are specifically denied, may have been pre-existing, either in whole or in part and are not causally related to the accident giving rise to the present litigation. 21. Plaintiffs' claims are reduced or barred by the Comparative Negligence Act. Plaintiffs' contributory negligence consisted of, but is not limited to: a. Failing to keep a proper lookout; b. Failing to pay attention to vehicles on the roadway; and c. Failing to take evasive maneuvers in an attempt to avoid the alleged impact. 22. Discovery may reveal that Plaintiffs' claims may be barred in whole or in part by one or more affirmative defenses set forth in Pa. R.C.P. 1030, which are incorporated herein by reference including, but not limited to, assumption of the risk, collateral estoppel, res judicata, release or immunity from suit. WHEREFORE, Kausar Moosa demands judgment in his favor and'against Plaintiffs without costs. Respectfully submitted, & WERNER, P.C. BY: DENAIS T BONETTI, ESQUIRE Co sel for the Defendant A JURY TRIAL IS DEMANDED VERIFICATION I hereby affirm that the following facts are correct: I am a Defendant in the foregoing action. The attached Answer with New Matter is based upon information which I have furnished to my counsel and information which has been gathered by my counsel in preparation for this lawsuit. The language of the Answer with New Matter is that of counsel and not of me. I have read the Answer with New Matter and to the extent that the Answer with New Matter is based upon information which F have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the Answer with New Matter is that of counsel, I have relied upon counsel in making this verification. I hereby acknowledge that the facts set forth in the aforesaid Answer with New Matter is made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Dated: N©`IP,IMJW-r V+f+ 2COC Aambila ?02? . Kausar Moosa CERTIFICATE OF SERVICE That counsel for the Defendant, KAUSAR MOOSA, hereby certifies that a true and correct copy of DEFENDANT'S ANSWER WITH NEW MATTER TO PLAINTIFFS' COMPLAINT been served on all counsel of record, by first class mail, postage pre-paid, accordin to the Pennsylvania Rules of Civil Procedure, on the day of 2006. Gregory R. Reed, Esquire 3120 Parkview Lane Harrisburg, PA 17111 Respectfully submitted, CIPRIANI & WERNER, P.C. BY: DEI)MIS J. BONETTI, ESQUIRE C nsel for the Defendant Gregory R. Reed, Esquire 3120 Parkview Lane Harrisburg, PA 17111 (717) 238-0434 e-mail: lawoffice(cepix.net ROBERT VIDACS and DOROTHY PETERS VIDACS Plaintiffs V. KAUSAR MOOSA, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5134 JURY TRIAL DEMANDED W MA AND NOW, comes Plaintiffs, Robert Vidacs and Dorothy Peters Vidacs, by and through their attorney, Gregory R. Reed, Esquire, and reply to New Matter as follows: 17. Said allegation is a conclusion of law to which no responsive pleading is required. 18. Said allegation is a conclusion of law to which no responsive pleading is required. 19. Denied. Said allegation; is denied pursuant to Pennsylvania Rule of Civil Procedure No. 1029(e). 20. Denied. Said Procedure No. 1029(e). 21. Said allegation ed pursuant to Pennsylvania Rule of Civil of law to which no responsive pleading is w required. Nevertheless the same al a denied pursuant to Pennsylvania Rule of Civil Procedure No. 1029(e). 22. Said allegations are co clusions of law to which no responsive pleading is required. WHEREFORE, Plaintiffs demand judgment in their favor and against Defendant Gregory R. Reed, Esquire Attorney for Plaintiffs 3120 Parkview Lane Harrisburg, PA 17111 (717) 238-0434 Attorney I.D. #23705 2 CERTIFICATE OF SERVICE II AND NOW, this 28th day of November, 2006, I, Gregory R. Reed, Esquire, Attorney for Plaintiffs, do hereby certify that I have this day served by first class mail a copy of the attached Reply to New (Matter, to the following address: Dennis J. Bonetti, Esquire Cipriani & Werner 1011 IIIMumma Road, Suite 201 Lemoyne, PA 17043-1145 II I'I I Gregory R. Reed, Esquire Attorney for Plaintiffs 3120 Parkview Lane Harrisburg, Pennsylvania 17111 (717) 238-0434 Attorney I.D. 23705 O "T7 - i s m .rte ?" SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-05134 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND VIDACS ROBERT ET AL VS MOOSA KAUSAR R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: MOOSA KAUSAR but was unable to locate Him deputized the sheriff of DAUPHIN in his bailiwick. He therefore serve the within COMPLAINT & NOTICE County, Pennsylvania, to On November 22nd , 2006 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: So ans.W.er Docketing 18.00 y Out of County 9.00 Surcharge 10.00 R` Thomas K1Ce Dep Dauphin County 29.25 Sheriff of C berland County Postage 1.02 6 7 . 2 7 ? 1130 ?(w ?- 11/22/2006 / GREGORY REED Sworn and subscribe to before me this day of , A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania Robert Vidacs et al vs. Kausar Moosa No. 06-5134 civil Now September 6, 2006 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to So answers, the contents thereof. Sheriff of County, PA copy of the original Sworn and subscribed before nee this day of .20 COSTS SERVICE $ MILEAGE AFFIDAVIT 20 , at o'clock M. served the r (Pifire Of f4-e o`??hrriff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin : VIDACS DOROTHY PETERS AND MOOSA KAUSAR Sheriff's Return vs No. 1505-T - - -2006 OTHER COUNTY NO. 06 5134 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy AND NOW:September 20, 2006 at 11:20AM served the within REINSTATED MORTGAGE FORECLOSURE upon MOOSA KAUSAR by personally handing to DEFENDANT 1 true attested copy(ies) of the original REINSTATED MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 1426 NORTH SECOND STREET HARRISBURG, PA 00000-0000 Sworn and subscribed to before me this 17TH day of NOVEMBER, 2006 NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. 1, 2010 So Answers, e17 YX 7 ? Sheriff of Dauplin County, Pa. e,- N1 Y ,,,rte E By R? Deputy Sher f Sheriff's Costs:$29.25 PD 09/12/2006 RCPT NO 221400 MARTIN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ROBERT VIDACS and DOROTHY PETERS VIDACS, Plaintiffs V. KAUSAR MOOSA, Defendant CASE NUMBER: 06-5134 ISSUE NUMBER: PLEADING: PRAECIPE FOR WITHDRAWAL/ENTRY OF APPEARANCE CODE AND CLASSIFICATION: FILED ON BEHALF OF: KAUSAR MOOSA, Defendant. COUNSEL OF RECORD: DENNIS J. BONETTI, ESQUIRE Pa. ID# 34329 MARK R. ZOGBY, ESQUIRE Pa. ID# 84032 CIPRIANI & WERNER, P.C. 1011 Mumma Road, Suite 201 Lemoyne, PA 17043 (717) 975-9600 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ROBERT VIDACS and DOROTHY PETERS VIDACS, Plaintiffs V. KAUSAR MOOSA, Defendant CASE NO: 06-5134 A JURY TRIAL IS DEMANDED PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO: PROTHONOTARY OF CUMBERLAND COUNTY Kindly withdraw my appearance on behalf of the Defendant, KAUSAR MOOSA, in the above-captioned matter. P.C. BY: J. BONETTI, ESQUIRE for the Defendant PRAECIPE FOR ENTRY OF APPEARANCE TO: PROTHONOTARY OF CUMBERLAND COUNTY Kindly enter my appearance on behalf of the Defendant, KAUSAR MOOSA, in the above-captioned matter. BY: MARK R. GB , ESQUIRE Counsel for the Defendant CERTIFICATE OF SERVICE That counsel for the Defendant, KAUSAR MOOSA, hereby certifies that a true and correct copy of its PRAECIPE FOR WITHDRAWAL/ENTRY OF APPEARANCE has been served on all counsel of record, by first class mail, postage pre-pa! according to the Pennsylvania Rules of Civil Procedure, on the -2-3--- day of 2008. , Gregory R. Reed, Esquire 3120 Parkview Lane Harrisburg, PA 17111 Respectfully submitted, CIPRIANI_O,,XERNER, P BY: / ARK R. ZO , ESQUIRE DENNIS J. BONETTI, ESQUIRE Counsel for the Defendant C"+ ?c3%, ?,,. ? n ,?c ?= _ ? ? ,,? ??. ?' ?? ;. . ?- ? ? > `v?_ :?? ? .? c. t.+ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ROBERT VIDAC5 and DOROTHY PETERS VIDACS, CASE NUMBER: 06-5134 ISSUE NUMBER: Plaintiffs v. KAUSAR MOOSA, PLEADING: PRAECIPE TO SETTLE DISCONTINUE AND END Defendant ._ c,= 1*- w~ ~ ~c ~ c..a ~~ ~> -_ ~ -~ ~~. ~' tom- ~ ,, ~ i ca ~~ sn a.. ~~ ~ ~- r- ~ ~: c:.. ~ h 0 1``iw~ ~ ~ c-~ CODE AND CLASSIFICATION: FILED ON BEHALF OF: KAUSAR MOO5A, Defendant. COUNSEL OF RECORD: MARK R. ZOGBY, ESQUIRE Pa. ID# 84032 CIPRIANI & WERNER, P.C. 1011 Mumma Road, Suite 201 Lemoyne, PA 17043 (717) 975-9600 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ROBERT VIDACS and DOROTHY PETERS VIDACS, CASE NO: 06-5134 Plaintiffs v. _... ___ ----- ._,_r_ KAUSAR MOOSA, Defendant P'RAECIPE TO SETTLE. DISCONTINUE and END TO: PROTHONOTARY OF CUMBERLAND COUNTY Kindly mark the above-referenced action settled, discontinued and ended. BY: - GREGORY R. D, E DIRE Date: ~ZUBg Attorney for the Plaintiff CERTIFICATE OF SERVICE That counsel for the Defendant hereby certifies that a true and correct copy of its PRAECIPE TO SETTLE, DISCONTINUE and END has been served on all counsel of record, by' first class mai postage pre-paid, arc rding to the Pennsylvania Rules of Civil Procedure on the day of --~g 2099' /0 Gregory R. Reed, Esquire 3120 Parkview Lane Harrisburg, PA 17111 Respectfully submitted, CIP & WERNER, P.C. BY: r- MARK R. BY SQUIRE Attorney for the Defendant