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Home My WebLink About06-6219I ?I ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attorney ID# : 35956 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: dlutz@angino-rovner.com SHEILA and WADE REALL, Plaintiffs V. MARGIE CARSON and DORIS SHOWAKER, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01. -- 4,.21 1 ( jj U i L CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS To the Prothonotary of Cumberland County: Please issue a Writ of Summons against Margie Carson, 17 Peach Glen Road, Gardners, PA 17324 and Doris Showaker, 50 Fanus Road, Gardners, PA 17324. Please forward the Writ of Summons to the Sheriff for service on both Defendants, along with time-stamped copies of Plaintiffs' Request for Admissions to Defendant Margie Carson - Set No. 1. ANGINO & ROVNER, P.C. Date: fq-0)LP David L. Lutz I.D. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717) 235-6791- phone (717) 238-5610 - fax dlutz@angino-rovner.com Attorney for Plaintiffs ORIGINAL 339619 b p d 1 a Cn ca r 00- Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS SHEILA AND WADE REALL Plaintiff Vs. MARGIE CARSON 17 PEACH GLEN ROAD GARDNERS, PA 17324 AND DORIS SHOWAKER 50 FANUS ROAD GARDNERS, PA 17324 Defendant Court of Common Pleas No 06-6219 CIVIL TERM In CivilAction-Law To MARGIE CARSON AND DORIS SHOWAKER, You are hereby notified that SHEILA AND WADE REALL, the Plaintiff(s) has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Curtis"R. Lon , r hono f Date OCTOBER 25, 2006 By Deputy Attorney: Name: DAVID L. LUTZ, ESQUIRE Address: ANGINO & ROVNER, P.C. 4503 N. FRONT STREET HARRISBURG, PA 17110 Attorney for: Plaintiff Telephone: 717-238-6791 Supreme Court ID No. 35956 ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attorney ID# : 35956 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: dlutz@angino-rovner.com SHEILA and WADE REALL, Plaintiffs V. MARGIE CARSON and DORIS SHO WAKER, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-6219 CIVIL TERM CIVIL ACTION - LAW 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 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 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. 338530 ORIGINAL 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 St., Carlisle, 17013, (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se persentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n 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 acci6n 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 reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Used puede perder dinero o propiedad u otros derechos importantes para used. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USED 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 St., Carlisle, 17013, (717) 249-3166 338530 ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attorney ID# : 35956 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: dlutz@angino-rovner.com SHEILA and WADE REALL, Plaintiffs V. MARGIE CARSON and DORIS SHOWAKER, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-6219 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT 1. Plaintiffs Sheila and Wade Reall are citizens of the Commonwealth of Pennsylvania and adult individuals who reside in Gardners, Cumberland County, Pennsylvania. 2. Defendant Margie Carson is an adult individual and citizen of the Commonwealth of Pennsylvania who resides at 17 Peach Glen Road, Gardners, Cumberland County, Pennsylvania, 17324. 3. Defendant Doris Showaker is an adult individual and citizen of the Commonwealth of Pennsylvania who resides at 50 Fanus Road, Gardners, Cumberland County, Pennsylvania, 17324. 4. The facts and occurrences hereinafter related took place on or about December 8, 2004, at the intersection of Route 174 and Route 34, Cumberland County, Pennsylvania. 5. Mrs. Reall was operating her motor vehicle, a 1999 Honda CRV, traveling on Route 34. 6. At the same time, Defendant Carson or Defendant Showaker was operating a 1996 Ford Taurus, also traveling on Route 34. 7. After Mrs. Reall stopped at red light at the intersection of Route 174 and Route 34, the front of Defendant's vehicle collided into the rear of Mrs. Reall's vehicle. 338530 8. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff Sheila Reall are the direct and proximate result of the negligent, careless, wanton and reckless manner in which Defendant Margie Carson or Defendant Doris Showaker operated her motor vehicle as follows: a) failure to have her vehicle under such control as to be able to stop within the assured clear distance ahead; b) failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; c) failure to apply her brakes in sufficient time to avoid striking the rear of Plaintiff s vehicle; d) failure to travel at a safe speed; e) failure to keep a proper watch for traffic on the highway; f) driving her vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. CLAIM I Sheila Reall v. Margie Carson and Doris Showaker 9. Paragraphs 1 through 8 of the Complaint are incorporated herein by reference. 10. Mrs. Reall sustained painful and severe injuries, which include but are not limited to, chronic neck pain, back pain, left disc protrusion of C5-C6 encroaching upon the anterior lateral aspect of the thecal sac and an aggravation of the degenerative desiccation of the lumbar spine, burning across both shoulders, chronic shoulder pain, sporadic numbness and tingling in her left foot. Mrs. Reall has been advised that she may require surgery. 338530 2 11. By reason of the aforesaid injuries sustained by Mrs. Reall, she was forced to incur liability for medical treatment and will continue to incur medical expenses in an effort to restore herself to health, and claim is made therefor. 12. Because of the nature of her injuries, Mrs. Reall has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 13. As a result of the aforementioned injuries, Mrs. Reall has undergone and in the future may undergo physical and mental suffering, inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 14. As a result of the aforesaid injuries, Mrs. Reall has been and in the future may be subject to humiliation and embarrassment, and claim is made therefor. 15. Mrs. Reall continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefor. CLAIM II Wade Read v. Margie Carson and Doris Showaker 16. Paragraphs 1 through 15 of the Complaint are incorporated herein by reference. 17. As a result of the aforementioned injuries sustained by his wife, Plaintiff Wade Reall has been and may in the future be deprived of the care, companionship, consortium, and society of his wife, all of which will be to his great detriment, and claim is made therefor. 338530 3 WHEREFORE, Plaintiffs Sheila and Wade Reall demand judgment against Defendants Margie Carson and Doris Showaker in an amount in excess of Thirty-five Thousand ($35,000.00) Dollars, exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. ANGINO & ROVNER, P.C. Date: David 1-Lutz I.D. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791- phone (717) 238-5610 - fax dlutz@angino-rovner.com Attorney for Plaintiffs 338530 4 VERIFICATION We, Sheila and Wade Reall, Plaintiffs, have read the foregoing COMPLAINT and do hereby swear or affirm that the facts set forth in the foregoing are true and correct to the best of our knowledge, information and belief. We understand that this Verification is made subject to the penalties of 18 Pa. Cons. Stat. Ann. §4904, relating to unsworn falsification to authorities. WITNESS: Sheila Reall CAS Wade Reall Dated: A- 7- co) cO 338530 CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of the COMPLAINT upon all Defendants via postage prepaid first class United States mail addressed as follows: Ms. Margie Carson 17 Peach Glen Road Gardners, PA 17324 Ms. Doris Showaker 50 Fanus Road Gardners, PA 17324 Dated: ??" I ?- 338530 ?'^? ?'=? ? ? ?,? r-' ' -_? '}?l ?;Y ? --- -i %...J ?1 ?. 06HB-00167 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Margie Carson and Doris Showaker SHEILA AND WADE REALL, PLAINTIFFS VS. MARGIE CARSON AND DORIS SHOWAKER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06-6219 CIVIL ACTION - LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendants, Margie Carson and Doris Showaker. The Defendants reserve the right to otherwise plead in this matter. Date: December 7, 2006 Respectfully submitted, lJonalct K. I)orer, ;squire Attorney for Defendants Identification No. 39126 s/ 1 06HB-00167 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Margie Carson and Doris Showaker SHEILA AND WADE REALL, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. MARGIE CARSON AND DORIS SHOWAKER, DEFENDANTS No. 06-6219 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of the attached Entry of Appearance to be served by regular first class mail upon: David L. Lutz, Esquire Angino & Rovner, PC 4503 North Front Street Harrisburg, PA 17110 Attorney for Plaintiffs Date: December 7, 2006 j' Donald R. Dore squire Attorney for Defendants N_ C y ? -r? =-?- - ? -ice ? i rte.'- ? - ? ?? .,.r 4 j C?1 -`- ? -' ? ? ? 1 C , ...r-. ? ` F .... ? .. - jam ~ _ ? ? --C r . 06HB-00167 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Margie Carson and Doris Showaker SHEILA AND WADE REALL, PLAINTIFFS VS. MARGIE CARSON AND DORIS SHOWAKER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06-6219 CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER TO PLAINTIFFS' COMPLAINT WITH NEW MATTER 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted in part, denied in part. It is admitted that Defendant, Margie Carson, was operating a 1996 Ford Taurus, also traveling on Route 34. By way of further statement, however, it is specifically denied that Defendant, Doris Showaker, was operating said vehicle. 7. Admitted. 8. Denied. Paragraph 8 of Plaintiffs' Complaint is generally denied pursuant to Pa. R.C.P. §1029(e). WHEREFORE, Defendants, Margie Carson and Doris Showaker, respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. 9. Paragraphs 1 through 8 are incorporated herein by reference, and made a part hereof as if set forth in full. 10.45. Denied. Paragraphs 10 through 15 of Plaintiffs' Complaint are generally denied pursuant to Pa. R.C.P. § 1029(e). WHEREFORE, Defendants, Margie Carson and Doris Showaker, respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. 16. Paragraphs 1 through 15 are incorporated herein by reference, and made a part hereof as if set forth in full. 17. Denied. Paragraph 17 of Plaintiffs' Complaint is generally denied pursuant to Pa. R.C.P. §1029(e). WHEREFORE, Defendants, Margie Carson and Doris Showaker, respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. NEW MATTER 18. Paragraphs 1 through 17 are incorporated herein by reference, and made a part hereof as if set forth in full. 19. The Plaintiffs' claims for non-pecuniary damages may be barred by the limited tort option of the Pennsylvania Motor Vehicle Financial Responsibility Act pursuant to 75 Pa. C.S.A. §1705. 20. The Plaintiffs' claims for medical expenses and/or wage losses may be barred, or should be reduced, pursuant to § 1722 of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, Defendants, Margie Carson and Doris Showaker, respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. Respectfully submitted, .W OFFICE OF STS"F/R & DORER Date: December 22, 2006 By: l/l1?._. 9 U W Donald R. Dorer, E it Attorney for Defendants Identification No. 39126 06HB-00167 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Margie Carson and Doris Showaker SHEILA AND WADE REALL, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. MARGIE CARSON AND DORIS SHOWAKER, DEFENDANTS No. 06-6219 CIVIL ACTION - LAW JURY TRIAL DEMANDED VERIFICATION I, Doris Showaker, verify that the statements made in the foregoing Answer to Plaintiffs' Complaint with New Matter which are within the personal knowledge of the undersigned, are true and correct, and as to the facts based on the information of others, the undersigned, after diligent inquiry, believe them to be true. And further, this Verification is signed on the recommendation of my attorneys, who advise me that the allegations and language in this document are required legally to raise issues for resolution at trial, by the Court, or by continuing investigation and preparation for trial. I understand that some of these allegations may prove inappropriate after investigation and trial preparation are complete and I leave the determination of these matters to my attorneys on their advice. I understand that all statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsifications to authorities. Dated: Doris Showaker 06HB-00167 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Margie Carson and Doris Showaker SHEILA AND WADE REALL, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. MARGIE CARSON AND DORIS SHOWAKER, DEFENDANTS No. 06-6219 CIVIL ACTION - LAW JURY TRIAL DEMANDED VERIFICATION I, Margie Carson, verify that the statements made in the foregoing Answer to Plaintiffs' Complaint with New Matter which are within the personal knowledge of the undersigned, are true and correct, and as to the facts based on the information of others, the undersigned, after diligent inquiry, believe them to be true. And further, this Verification is signed on the recommendation of my attorneys, who advise me that the allegations and language in this document are required legally to raise issues for resolution at trial, by the Court, or by continuing investigation and preparation for trial. I understand that some of these allegations may prove inappropriate after investigation and trial preparation are complete and I leave the determination of these matters to my attorneys on their advice. I understand that all statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsifications to authorities. Dated: ` cc Margie C#arson- 06HB-00167 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Margie Carson and Doris Showaker SHEILA AND WADE REALL, PLAINTIFFS VS. MARGIE CARSON AND DORIS SHOWAKER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06-6219 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of the attached Answer to Plaintiffs' Complaint with New Matter to be served by regular first class mail upon: Date: December 22, 2006 David L. Lutz, Esquire Angino & Rovner, PC 4503 North Front Street Harrisburg, PA 17110 Attorney for Plaintiffs r` Donald R. Dorer, Esquire Attorney for Defendants -, ?..? C.: ?m:r: - ::--y -?r7 ?..?y N --r? f 'f T ; ? _ , 1 7 t l :.. ._ .. . .... _ 3 , .... ? . __s__ ..^ ? ? .? I '. SHERIFF'S RETURN - REGULAR CASE NO: 2006-06219 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REALL SHEILA ET AL VS CARSON MARGIE ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon CARSON MARGIE the DEFENDANT , at 1400:00 HOURS, on the 6th day of November , 2006 at 17 PEACH GLEN RD GARDNERS, PA 17324 MARGIE CARSON by handing to a true and attested copy of WRIT OF SUMMONS REQUEST FOR ADMISSIONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 10.56 Postage .39 Surcharge 10.00 R. Thomas Kline .00 38.95?` 11/07/2006 ANGINO & ROVNER Sworn and Subscibed to By: before me this day eputy Sheriff of , A.D. r CASE NO: 2006-06219 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REALL SHEILA ET AL VS CARSON MARGIE ET AL WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon SHOWAKER DORIS the DEFENDANT , at 1351:00 HOURS, on the 6th day of November , 2006 at 50 FANUS RD GARDNERS, PA 17324 by handing to DORIS SHOWAKER a true and attested copy of WRIT OF SUMMONS together with REQUEST FOR ADMISSIONS and at the same time directing Her attention to the contents thereof. SHERIFF'S RETURN - REGULAR Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 9.68 .00 So Answers: 10.00 R. Thomas Kline .00 25.68 11/07/2006 ANGINO & ROVNER Sworn and Subscibed to By: before me this day Zf)e'p-uty Sheriff of A. D. 06HB-00167 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Margie Carson and Doris Showaker SHEILA AND WADE REALL, PLAINTIFFS VS. MARGIE CARSON AND DORIS SHOWAKER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06-6219 CIVIL ACTION - LAW JURY TRIAL DEMANDED STIPULATION OF COUNSEL It is hereby stipulated between counsel for the parties hereto that the Defendant, Doris Showaker, be dismissed from this action, and the caption of the case be revised to read as follows: Sheila and Wade Reall vs. Margie Carson. ANGINO & ROVNER, P.C. David L. Lutz, Esquire 4503 North Front Street Harrisburg, PA 17110 Telephone No. (717) 238-6791 Court I.D. 35956 Attorney for Plaintiffs Date: LAW OFFICE OF SNYDEl & DORER l ?t Donald R. Dorer, Esquire 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone No. (717) 731-0988 Court I.D. 39126 Attorney for Defendants U f Date. (.? 4 t 06HB-00167 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Margie Carson and Doris Showaker SHEILA AND WADE REALL, PLAINTIFFS VS. MARGIE CARSON AND DORIS SHOWAKER, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06-6219 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of the attached Stipulation of Counsel to be served by regular first class mail upon: David L. Lutz, Esquire Angino & Rovner, PC 4503 North Front Street Harrisburg, PA 17110 Attorney for Plaintiffs r Date: January 11, 2007 i l Donald R. borer, Esquire Attorney for Defendants r-.,) 1 1.J e..? a V .? ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attorney ID# : 35956 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238-6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E-mail: dlutz@angino-rovner.com SHEILA and WADE REALL, Plaintiffs V. MARGIE CARSON and DORIS SHOWAKER, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-6219 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED ORDER AND NOW, this i6' day of sk!-_ ti , 2007, upon consideration of the attached Stipulation of Counsel, IT IS H REB ORDERED AND DECREED that Defendant Doris Showaker is dismissed from this action and the new caption shall read as follows: SHEILA and WADE REALL, Plaintiffs V. MARGIE CARSON, Defendant 344932 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 06-6219 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED RV TUP MTTRT- CL - `?- UZ C 0 C.7 lp J ANGINO & ROVNER, P.C. David L. Lutz, Esquire Attorney ID# : 35956 4503 North Front Street Harrisburg, PA 17110-1708 PHONE: (717) 238-6791 FAX: (717) 238-5610 Attorney for Plaintiff: E-mail: dlutzna Aneino rovner com SHEILA and WADE REALL, Plaintiffs V. MARGIE CARSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-6219 CIVIL TERM JURY TRIAL DEMANDED PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: David L. Lutz, Esquire, counsel for the Plaintiffs in the above action, respectfully represents that: The above-captioned action is at issue. 2. The claim of the Plaintiffs in the action is $50,000. The counterclaim of the Defendant in the action is $0. The following attorneys are interested in the case(s) as counsel or otherwise disqualified to sit as arbitrators: David L. Lutz, Esquire of Angino & Rovner and Donald Dorer, Esquire of Snyder & Dorer. 360927 WHEREFORE, your Petitioners pray Your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Date: ANGINO & ROVNER, P.C. David L. Lutz I.D. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791- phone (717) 238-5610 - fax dlutz@angino-rovner.com Attorney for Plaintiffs 360927 CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of the PETITION FOR APPOINTMENT OF ARBITRATORS upon all counsel of record via postage prepaid first class United States mail addressed as follows: Donald Dorer, Esquire Snyder & Dorer 214 Senate Ave., Suite 503 Camp Hill, PA 17011 Attorney for Defendant Dated: ' ( ' ? *'o 360927 ..i1/ ? _ _ ?a... ,. ?.., l T _ [? }T? Vl ? ? y?, fl ', ?1 ^A.! ? ? CA ? p - _ ? ?s _ E ?. w C : -. QUL 2 6 2001 ? ? SHEILA and WADE REALL, Plaintiffs V. MARGIE CARSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-6219 CIVIL TERM JURY TRIAL DEMANDED ORDER OF COURT JF00 ZA9647 AND NOW, this A_--day of , in consideration of the foregoing petition, , Esq. Esq. and ?4- • r Esq. are appointed arbitrators in the above- captioned action as prayed for. BY CO R P.J. 360927 C?3 Q7- C-D DO" ?j° D SHEILA REALL, et al., COURT OF COMMON PLEAS OF PLAINTIFFS CUMBERLAND COUNTY, PENNSYLVANIA V. MARGIE CARSON, et al., DEFENDANTS 06-6219 CIVIL TERM ORDER OF COURT AND NOW, this (7 day of November, 2007, the appointment of Nichole S. Chizmar, Esquire, to the Board of Arbitrators in the above-captioned case, IS VACATED. George H. Matangos, Esquire, is appointed in her place. Maria Cognetti, Esquire Chairman George H. Matangos, Esquire Court Administrator By the Edgar B. Bayley, J. sal Maned q130 no .... c ?- - ? .?.? ?,,,, ?_: o U It.' 1. 06HB-00167 ANGINO & ROVNER, P.C. David L. Lutz, Esquire 4503 North Front Street Harrisburg, PA 17110-1708 Telephone Number: (717) 238-6791 Attorneys for Plaintiffs SHEILA AND WADE REALL, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. MARGIE CARSON, DEFENDANT No. 06-6219 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Please mark the above-captioned case settled, discontinued and ended. Date: ANGINO & ROVNER, P.C. By: avid L. Lutz, Esquire 4503 North Front Street Harrisburg, PA 17105 Telephone No. (717) 238-6791 Attorney for Plaintiffs Court I.D.35956 YO . `w 06HB-00167 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Margie Carson SHEILA AND WADE REALL, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. MARGIE CARSON, DEFENDANT No. 06-6219 CIVIL ACTION - LAW f ? 5. ;„ i. +.JURY TRIAL DEMANDED' { CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Praecipe to Settle, Discontinue and End to be served by regular first class mail upon: David L. Lutz, Esquire Angino & Rovner, PC 4503 North Front Street Harrisburg. PA 17110 Attorney fc Date: November 21, 2007 Donald R. Dorer, Esquire Attorney for Defendant C°= -r- Co ?. ?.7