Loading...
HomeMy WebLinkAbout06-6487IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - (XX) Law ( ) Equity Patricia Seeger and John Olson James Seeger, her husband 100 Round Ridge Road 35 West Simpson Mechanicsburg, PA 17055 Mechanicsburg, PA 17055 and JoAnn R. Olson 100 Round Ridge Road Mechanicsburg, PA 17055 PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue A Writ of Summons in the above-captioned action. X Writ of Summons Shall be issued and forwarded to ()Attorney (XX)Sheriff Stephen G. Held, Esquire 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Name/Address/Telephone No. of Attorney -xto Sg-n- V1 f Attorney Supreme ourt ID No. 72663 Date: November 6, 2006 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANTS: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Aq 'd Al Proth0 0 ry Date: IZ)ivu *7 by Deputy ( ) Check here if reverse is used for additional information PROTHON. - 55 L. ! v 3 77 , v 1 - ?- Its ? . 60 V Stephen G. Held, Esquire I.D.#72663 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiff Fax: (717) 233-3029 E-mail: HELD(&-hhrlaw.com PATRICIA SEEGER and : IN THE COURT OF COMMON PLEAS JAMES SEEGER, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : No.: 06-6487 JOHN OLSON and JOANN OLSON, . Defendants : CIVIL ACTION - LAW PRAECIPE TO REINSTATE WRIT TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Please reinstate the enclosed Writ in the above referenced matter. Defendant can be served at the following address: John M. Olson 1636 North 3' Street Apartment 1 Harrisburg, PA 17102 HANDLE, HENNING & ROSENBERG BY Date: Step en WZl, Esq. I.D. #726 3 1300 Linglestown Road Harrisburg, PA 17110 1 . 4W& SHERIFF'S RETURN - NOT' FOUND CASE NO: 2006-06487 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEEGER P.ATRICIA ET AL VS OLSON JOHN ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT OLSON JOHN but was unable to locate Him in his bailiwick. He therefore returns the T.7Tl TT /-'\ T1 r' T TT RT iTrITT(I the within named DEFENDANT , OLSON JOHN NOT FOUND , as to So answ 18.00 9.68 5.00 R. Thomas Kline 10.00 Sheriff of Cumberland County 100 ROUND RIDGE ROAD MECHANICSBURG, PA 17055 DEFENDANT IS BELIEVED TO BE LIVING IN HARRISBURG. Sheriff's Costs: Docketing Service Not Found Surcharge Postage .39 43.07,- f Sworn and Subscribed to before me this day of 00/00/0000 A. D. I • .4% SHERIFF'S RETURN - REGULAR CASE NO: 2006-06487 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SEEGER PATRICIA ET AL VS OLSON JOHN ET AL JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon OLSON JOANN R the DEFENDANT at 2039:00 HOURS, on the 17th day of November , 2006 at 100 ROUND RIDGE ROAD MECHANICSBURG, PA 17055 by handing to JOANN OLS ON a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Af f idavi?-- Surcharge Sworn and Subscibed to before me this of So Answers: 6.00 oo ?.,???' . ?aa?C . 0 10.00 R. Thomas Kline .00 16.0V 11/27/2006 HANDLER HENNING ROSENBERG By: day A. D. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA- ' t No. p'T el Lot j Civil Action - (XX) LawTS °- ( ) Equity - - Patricia Seeger and John Olson `"` James Seeger, her husband 100 Round Ridge Road 35 West Simpson Mechanicsburg, PA 17055 Mechanicsburg, PA 17055 and JoAnn R. Olson 100 Round Ridge Road Mechanicsburg, PA 17055 PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue A Writ of Summons in the above-captioned action. X Writ of Summons Shall be issued and forwarded to ()Attorney (XX)Sheriff Stephen G. Held, Esquire 1300 Linglestown Road Harrisburg,. PA 17110 Sign e f Attorney (717) 238-2000 Supreme ourt ID No. 72663 Name/Address/Telephone No. of Attorney Date: November 6, 2006 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANTS: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED A ACTION AGAINST YOU. Prothon ry Date: _,??U by Deputy ( ) Check: here if reverse is used for additional information PROTHON. - 55 TRUE COPY FROM REGUi _, in Te nony whereof, I here undo set my hall,- And the adm' of said Court at Carlisle, ft, *h Je-lfj Lot, r Prothund?Ir'v Stephen G. Held, Esquire I.D.#72663 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax: (717) 233-3029 E-mail: HELDO-hhrlaw.com Attorney for Plaintiff PATRICIA SEEGER and JAMES SEEGER, Plaintiffs V. JOHN OLSON and JOANN OLSON, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA : NO.: 06-6487 : CIVIL ACTION - LAW PRAECIPE TO REISSUE WRIT TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Please reissue the enclosed Writ in the above referenced matter. Defendant, John Olson, can be served at the following address: John Olson 105 East Allen Street, Apt. 207 Mechanicsburg, PA 17055 HANDLER, HENNING & ROSENBERG By Date: 311 a I u1 Ste An 4Wd r-,a -71 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.41.t7 nivil, l `' Civil Action - (XX) Law h?`r• ( 1 Equity _ U .< Patricia Seeger and John Olson James Seeger, her husband 100 Round Ridge Road 35 West Simpson Mechanicsburg, PA 17055 Mechanicsburg, PA 17055 and JoAnn R. Olson 100 Round Ridge Road Mechanicsburg, PA 17055 PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue A Writ of Summons in the above-captioned action. X Writ of Summons Shall be issued and forwarded to ()Attorney (XX)Sheriff Stephen G. Held, Esauire 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Name/Address/Telephone No. of Attorney Ir 1'e e f Attorney Sign Supreme ourt ID No. 72663 Date: November 6, 2006 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANTS: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED A ACTION AGAINST YOU. Prothono ry Date: ,??a _aneo e by Deputy ( ) Check here if reverse is used for additional information PROTHON.-55 f S UE PY FROM RECOHL, nj Testimony whereof, l here unto set 1111 ad the sea 0f said Court at Carlyle, Prit. ?? r-? ? d C __., w ,. ?, ?, ?F ? ?? ??? € r?. j.. ?? 1 ?-- F - ? ± ? i ? ., .? Cyr ? ? ?.. = ?i =G. ..? ?,- SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-06487 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SEEGER PATRICIA ET AL VS OLSON JOHN ET AL R. Thomas Kline , duly sworn according to law, say; and inquiry for the within named OLSON JOHN but was unable to locate Him deputized the sheriff of DAUPHIN serve the within WRIT OF SUMMONS Sheriff or Deputy Sheriff ho being that he made a diligent earch and DEFENDANT to wit: in his bailiwick. He the fore County, Penns 1 ania, to On January 10th , 2007 , t attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin County 35.25 Postage .87 s office was in receip So answers: R.`Thomas Klin / Sheriff of CuZerland / . . 12 V- 01/10/2007 HANDLER HENNING ROSENBERG Sworn and subscribe to before me this day of , f the ty A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania Patricia Seeger et al vs. John Olson No. 06-6487 ci ' Now, December 21, 2006 , I, SHERIFF OF CUMBERLAND C hereby deputize the Sheriff of Dauphin County to exec deputation being made at the request and risk of the Plaintiff. s Sheriff of Cumberland Now, Within upon at by handing to and made known to the So answers, Sworn and subscribed before me this day of , 20 Affidavit of Service ,20 ,at o'clock copy of the original Sheriff of COSTS SERVICE $ MILEAGE _ AFFIDAVIT ,, PA, do Writ, this sty, PA ?1. served the thereof. County, PA Office of ?r,,S4Eriff 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 SEEGER PATRICIA vs • OLSON JOHN Sheriff's Return No. 2109-T - - -2006 OTHER COUNTY NO. 06-6487 I, Jack Lotwick, Sheriff of the County of Dauphin, State o Pennsylvania, do hereby certify and return, that I made dili search and inquiry for OLSON JOHN the DEFENDANT named in the within REISSUED WRIT OF SUMMONS and that I am unable to find him/her in the County of Dauphi therefore return same NOT FOUND, January 4, 2007 E. Sheaffer f Deputy W. Rinehart Chief Deputy t and PER CURRENT RESIDENT, TODD STAMBAUGH OF: 1636 NORTH 3RD ST, A 1, HBG,PA 17102 STATED THAT THE DEFT, JOHN OLSON DID NOT LIVE THERE. NO URTHER INFORMATION. Sworn and subscribed to before me this 4TH day of JANUARY, 2007 NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept 1, 2010 So Answers, sneritt of Dauphin CountyJjPa. By Deputy Sheriff Sheriff's Costs:$35.25 PD 2/28/2006 RCPT NO 22 915 SHERIFF'S RETURN - REGULAR CASE NO: 2006-06487 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SEEGER PATRICIA ET AL VS OLSON JOHN ET AL SHARON LANTZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon OLSON JOHN the DEFENDANT at 1931:00 HOURS, on the 30th day of March , 2007 at 105 EAST ALLEN STREET MECHANICSBURG, PA 17055 by handing to JOHN OLSON a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 19.20 Postage .39 Surcharge 10.00 o (4) b 7 00 47.59 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 04/02/2007 HANDLER HENNING ROSENBERG By. eputy Sheriff A.D. MON PLEAS COURT OF COM PENNSYLV ANIA IN T COUNTY OF CUMBERLAND CIVIL TERM NO.. 06-6478 - EMNATION BY 11 IA IN RE? COND OF PENNS AL'gj RANSPORT ATIO OF 15, DEPARTMENT OF ST ATE ROUTE00 GIRT OF W AY FO LIMITED ACCESS IN RI 006 R/ W, ILL AND SECTIO ROUGH OF CAI -04 AND LOWER THE B? EIIPS OF FIAMPD TOWN . MAIN PRpCEEDING EMINENT DO IN REM ALLEN TO THE AMENDMs EU Ulm SE Or C? 1 i+ Condemnee, to petition the ETITION FOR ?ELEA P Foot Locker specialty, Inc•, comes on deposit, with interest. AND NOW lust coinpensati ase the estimated issues in the above- to rele an other Honorable Court court has not ruled upon The I3on°rable 1• York, has after. known party of interest, The First Bank of New referenced x The only 2• hen release document. concurred per thepreviously submitted Respectfully submitted, Young Sr Patterson, P.C. Lavery, Fahe?, DAB' F aherty Esquire By Michael f No. 55860 Atty Market Street, Suite 304 225 P .O. Box 1245 1245 PA 17108' ecialty, Inc. AtHaterys b ? Foot Locker Sp CERTIFICATE OF SERVICE L Kelly M. Mazer, an employee with the law firm of Lavery, Fahe Patterson, P.C., do hereby certify that rtY? Young & Y ton this Eday f D true and oecember, 2007, I served a correct copy of the foregoing Amendment Estimated J nt to the Petition for Release of just Compensation Deposit via U. addressed as follows: S. First Class mail, postage Prepaid, Foot Locker, Inc. Randolph Brodwin, Esquire 112 West 34th Street 4th Floor New York, NY 10120-0101 The Bank of New York 1 Wall Street, 18f Floor North New York, NY 10286 r' Kelly M. azer Paralegal to Michael F. Faher ty, Esquire N ??? c-::? C::_:] ?--..d ??? ?`1 `.....' f. r4.J e :.. _.. ?..o?: C `V, `?y ? t t'. M • Johnson, Duffle, Stewart & Weidner Attorney for Defendants By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com (717) 761-4540 PATRICIA SEEGER and JAMES IN THE COURT OF COMMON PLEAS OF SEEGER, her husband, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO: 06=6487 CIVIL TERM CIVIL ACTION - LAW JOHN OLSON and JoANN R. OLSON, : Defendants : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: PLEASE enter the appearance of the undersigned on behalf of the Defendants in the above-captioned matter. JOHNSON, DUFFIE, STEWART & WEIDNER fferson J. Shipman, E quire I.D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Defendants t CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on February 25, 2008: Stephen G. Held, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 Attorneys for Plaintiffs JOHNSON, DUFFIE, STEWART & WEIDNER 4 erson J. Ship an, Esquire D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Defendants 324892 c Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com (717) 761-4540 Attorney for Defendants PATRICIA SEEGER and JAMES IN THE COURT OF COMMON PLEAS OF SEEGER, her husband, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO: 06=6487 CIVIL TERM CIVIL ACTION - LAW JOHN OLSON and JoANN R. OLSON, : Defendants : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: PLEASE issue a Rule upon the Plaintiffs to file a Complaint within twenty (20) days or suffer judgment of non pros. DATE: ;-/,45 /000 TO: Stephen G. Held, Esquire 1300 Linglestown Road Harrisburg, PA 17110 Attorneys for Plaintiffs qJJVeeffe0rs ON, DUFFIE, STEWART & WEIDNER onJ. Shipma , Esquire RULE And now, this eday of Reb , 2008, you are hereby notified to file a Complaint within twenty (20) days of service in the above-captioned matter or a default judgment will be entered against you. Curtis Long, Pr otary IN- CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on February 25, 2008: Stephen G. Held, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 Attorneys for Plaintiffs JOHNSON, DUFFIE, STEWART & WEIDNER J fferson J. Shipman, squire I.D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Defendants 324890 -T1 :771 QIJ Stephen G. Held, Esq. I.D.#72663 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiffs Fax : (717) 233-3029 E-mail: Held@HHRLaw.com PATRICIA SEEGER and : IN THE COURT OF COMMON PLEAS JAMES SEEGER, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. 06-6487 Civil JOHN OLSON and JOANN OLSON, CIVIL ACTION - LAW Defendants NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 Stephen G. Held, Esq. I.D.#72663 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiffs Fax : (717) 233-3029 E-mail: Held@HHRLaw.com PATRICIA SEEGER and : IN THE COURT OF COMMON PLEAS JAMES SEEGER, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : NO. 06-6487 Civil JOHN OLSON and JOANN OLSON, CIVIL ACTION - LAW Defendants AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar 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, [as 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 contra 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 LISTED 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 LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 Stephen G. Held, Esq. I.D.#72663 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiffs Fax : (717) 233-3029 E-mail: Held@HHRLaw.com PATRICIA SEEGER and : IN THE COURT OF COMMON PLEAS JAMES SEEGER, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : NO. 06-6487 Civil JOHN OLSON and JOANN OLSON, CIVIL ACTION - LAW Defendants COMPLAINT AND NOW comes the Plaintiffs, Patricia Seeger and James Seeger, by and through their attorneys, HANDLER, HENNING & ROSENBERG, LLP, by Stephen G. Held, Esq., and makes the within Complaint against the Defendants, John Olson and JoAnn Olson, and avers as follows: 1. Plaintiffs, Patricia Seegerand James Seeger, are competent adult individuals currently residing at 35 West Simpson, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant, John Olson, is an adult individual currently residing at 105 East Allen Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Defendant, JoAnn Olson, is an adult individual currently residing at 100 Round Ridge Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 4. At all times material hereto, Plaintiff, Patricia Seeger, was the owner and operator of a 2000 Chevrolet K1500 bearing the Pennsylvania registration number YJM 7397 (hereinafter referred to as "Plaintiff's vehicle") 5. At all times material hereto, Defendant, John Olson, was the operator of a 1996 Chevrolet CZ2 bearing Pennsylvania registration number FLJ 2999, owned by JoAnn Olson. (hereinafter referred to as "Defendant's vehicle") 6. At the time of the motor vehicle crash on November9, 2004, Defendant, John Olson, was a minor and seventeen (17) years old. 7. At all times material hereto, Plaintiff was a named insured under an automobile insurance policywith State Farm Insurance Company and was covered bythe full-tort option. 8. At all times material to this action, there were no adverse weather or road conditions. 9. On or about November 9, 2004, at about 7:47 a.m., Plaintiff, Patricia Seeger, was lawfully traveling westbound on Marble Street in Mechanicsburg Borough, Cumberland County, Pennsylvania. 10. At approximately the same time and place, Defendant, John Olson, was traveling southbound on High Street, approaching the intersection with Marble Street, in Mechanicsburg Borough, Cumberland County, Pennsylvania. 2 11. At approximately the same time and place, Defendant, John Olson, failed to obey the properly posted Stop sign for southbound High Street traffic and yield the right-of- way to traffic lawfully traveling on Marble Street, and pulled directly into the path of Plaintiff's vehicle. 12. Defendant's front bumper violently struck Plaintiff's vehicle in the right front quarter panel forcing Plaintiff's vehicle across the intersection where it came to rest after striking and knocking down a street sign. 13. As a direct and proximate result of the negligence of the Defendant, John Olson, Plaintiff, Patricia Seeger, sustained extensive and serious personal injuries, as set forth more specifically below. COUNT I - NEGLIGENCE Patricia Seeger v. John Olson 14. Plaintiff, Patricia Seeger, incorporates and makes part of this Count paragraphs 1 through 13 above, as if the same were set forth fully below 15. The aforementioned collision and the resultant injuries to the Plaintiff, Patricia Seeger, were caused directly and proximately by the negligence of Defendant, John Olson, generally and more specifically as set forth below: (a) In failing to keep a proper lookout for vehicles lawfully traveling on Marble Street in Mechanicsburg Borough, Cumberland County, Pennsylvania; (b) In failing to be reasonably vigilant and slowly pull forward to a point where he had a clear view of approaching traffic, in violation of 75 Pa. C.S.A. § 3323(b); 3 (c) In failing to yield the legal right-of-way to Plaintiff's vehicle in the intersection, in violation of 75 Pa. C.S.A. § 3323(b); (d) In negligently driving his vehicle into the intersection of Marble and High Streets without properly stopping; (e) In entering a roadway without first looking both ways for approaching traffic and in failing to continue to look as he advanced into the intersection; (f) In driving his vehicle in careless disregard for the safety of persons or property, in violation of 75 Pa. C.S.A. §3714; (g) In failing to exercise the high degree of care required of a motorist entering an intersection; (h) In failing to stop at a properly posted Stop sign controlling the intersection, in violation of Pa. C.S.A. §3323(b); (i) In failing to drive at a careful and prudent speed that prevented the Defendant's vehicle from coming to a stop within the assured clear distance ahead, in violation of 75 Pa. C.S.A. § 3361; (j) In disregarding the speed of vehicles, the condition of the highway, and the traffic upon the highway, in violation of 75 Pa. C.S.A. § 3310(a); and (k) In failing to have sufficient control of his vehicle, which would have allowed the vehicle to be stopped before doing injury to any person or thing likely to arise under the circumstances. 4 16. As a direct and proximate result of the negligence of Defendant, John Olson, the Plaintiff, Patricia Seeger, sustained personal injuries including, but not limited to, injuries to her back in the form of moderate spinal stenosis and leg pain. 17. As a direct and proximate result of the negligence of Defendant, John Olson, the Plaintiff, Patricia Seeger, has been, and will in the future be, hindered from performing to her daily duties and chores, to her loss, humiliation and embarrassment. 18. As a direct and proximate result of the negligence of Defendant, John Olson, the Plaintiff, Patricia Seeger, has suffered physical pain, discomfort and mental anguish and will continue to endure the same for an indefinite period of time in the future, to her physical, emotional and financial detriment and loss. 19. As a direct and proximate result of the negligence of Defendant, John Olson, the Plaintiff, Patricia Seeger, has been compelled, and will in the future be compelled, in order to effect a cure for the aforementioned injuries, to expend money for medicine and medical attention to her detriment and loss. 20. As a direct and proximate result of the negligence of Defendant, John Olson, the Plaintiff, Patricia Seeger, has suffered a loss of life's pleasures and he will continue to suffer the same in the future, to her detriment and loss. WHEREFORE, Plaintiff, Patricia Seeger, seeks damages from the Defendant, John Olson, in an amount in excess of the compulsory arbitration limits of Cumberland County, exclusive of interest and costs. 5 COUNT II - LOSS OF CONSORTIUM James Seeger v. John Olson 21. Plaintiff, James Seeger, incorporates and makes part of this Count paragraphs 1 through 20 of this Complaint as if fully set forth within. 22. As a direct and proximate result of Defendant's negligence, the Plaintiff, James Seeger, has suffered a loss of consortium, society, and comfort from his wife, Patricia Seeger, and he will continue to suffer a similar loss in the future. 23. As a direct and proximate result of Defendant's negligence, the Plaintiff, James Seeger, has been compelled, in order to effect a cure for his wife's injuries, to expend money for medicine and medical attention and will be required to expend money for the same purposes in the future, to his detriment and loss. WHEREFORE, Plaintiff, James Seeger, seeks damages from the Defendant, John Olson, in an amount in excess of the compulsory arbitration limits of Cumberland County, exclusive of interest and costs. Date: 1--t IN G Respectfully Submitted, HANDLER, HENNING & ROSENBERG, LLP By: qzv Stephen G. Held, Esq. I.D. No. 72663 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorney for Plaintiffs 6 VERIFICATION The undersigned hereby verifies that the statements in the foregoing document are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language of the document is of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the document are that of counsel, I have relied upon my counsel in making this Verification. The undersigned also understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. P01?WIA Patricia Seeger J mes Seeger Date: q/.7-/Oy, CERTIFICATE OF SERVICE I, Stephen G. Held, attorney for Plaintiffs Patricia Seeger and James Seeger, hereby certify that I have served the foregoing Complaint by Certified Mail, Return Receipt Requested on the day of April 2008, upon the following: Jefferson J. Shipman, Esq. Johnson, Duffie, Stewart & Weidner, P.C. 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Date: t 91" Stephen it. He quire Attorney for Plaintiffs ?? r? f ?.. Cf ? ??"y 4.? t, I'f??` t ' i/ ? ?? "'17 i ?, . ? ??? r k PATRICIA SEEGER and JAMES IN THE COURT OF COMMON PLEAS OF SEEGER, her husband, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO: 06=6487 CIVIL TERM CIVIL ACTION - LAW JOHN OLSON and JoANN R. OLSON, : Defendants : JURY TRIAL DEMANDED VOLUNTARY DISCONTINUANCE PURSUANT TO Pa. R.C.P. 229 It is hereby stipulated and agreed by and between Stephen Held, Esquire, counsel for Plaintiffs, and Jefferson J. Shipman, Esquire, counsel for Defendants, that JoAnn Olson is dismissed from the case. HANDLER, HENNING & ROSENBERG By Stephen G. Held, Esquire 1300 Linglestown Road Harrisburg, PA 17110 DATE: " t l WON Attorneys for Plaintiffs JOHNSON, DUFFIE, STEWART & WEIDNER J e Io J. Ship an, Esquire 1. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Date: q12 y/d 6v Attorneys for Defendants 329945 R, Fri r op = ' c o L n :?i Johnson, Duffie, Stewart & Weidner Attorney for Defendants By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com (717) 7614540 PATRICIA SEEGER and JAMES IN THE COURT OF COMMON PLEAS OF SEEGER, her husband, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO: 06=6487 CIVIL TERM CIVIL ACTION - LAW JOHN OLSON and JoANN R. OLSON, : Defendants : JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Stephen G. Held, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 Attorneys for Plaintiff YOU ARE REQUIRED to plead to the within Answer and New Matter within 20 days of s service hereof or a default judgment may be entered against you. , DUFFIE, STEWART & WEIDNER F' ftrgon J. Shipman, Esquire 1. D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Defendants DATE: May 9, 2008 330479 Johnson, Duffe, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com (717) 761-4540 Attorney for Defendants PATRICIA SEEGER and JAMES IN THE COURT OF COMMON PLEAS OF SEEGER, her husband, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO: 06=6487 CIVIL TERM CIVIL ACTION - LAW JOHN OLSON and JoANN R. OLSON, : Defendants : JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANTS AND NOW, come the Defendants, John Olson and Joann Olson, by and through their counsel, Johnson, Duffie, Stewart & Weidner, and Jefferson J. Shipman, Esquire, and file the following Answer and New Matter to Plaintiffs' Complaint: 1. Admitted upon information and belief. 2. Admitted. 3. Admitted. 4. Denied. After reasonable investigation, the Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 4 and the same are therefore denied. 5. Admitted. 6. Admitted. 7. Denied. After reasonable investigation, the Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 7 and the same are therefore denied. 8. Admitted. 9. Admitted in part, denied in part. It is admitted only that on or about November 9, 2004 at about 7:47 A.M., Plaintiff Patricia Seeger was operating a vehicle westbound on Marble Street, Mechanicsburg, Cumberland County, Pennsylvania. The remaining averments of Paragraph 9 are conclusions of law and fact to which no response is required. 10. Admitted. 11. Admitted in part, denied in part. It is admitted only that there was an impact between the vehicles. The remaining averments of Paragraph 11 are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. 12. Admitted in part, denied in part. It is admitted only that there was an impact between the vehicles. The remaining averments of Paragraph 12 are conclusions of law and fact to which no response is required. 13. Denied. The averments contained in Paragraph 13 are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. COUNT I - NEGLIGENCE Patricia Seeger v. John Olson 14. That the Defendants incorporate herein by reference their answers to Paragraphs 1 through 13 above as though fully set forth herein at length. 15. Denied. The averments contained in Paragraph 15, and each and every subparagraph (a) through (k), are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained in Paragraph 15, and subparagraphs (a) through (k), are specifically denied. (a). Denied. It is specifically denied that Mr. Olson failed to keep a proper lookout for vehicles lawfully traveling on Marble Street; (b). Denied. It is specifically denied that Mr. Olson failed to be reasonably vigilant and slowly pull forward to a point where he had a clear view of approaching traffic; (c) Denied. It is specifically denied that Mr. Olson was negligent in allegedly failing to yield the right-of-way to Plaintiffs' vehicle; (d). Denied. It is specifically denied that Mr. Olson negligently drove his vehicle into the intersection of 'Marble and High Streets without properly stopping; (e). Denied. It is specifically denied that Mr. Olson entered the roadway without first looking both ways for approaching traffic and that he allegedly failed to continue to look as he advanced into the intersection; (f). Denied. It is specifically denied that Mr. Olson acted in careless disregard for the safety of persons or property; (g). Denied. It is specifically denied that Mr. Olson failed to exercise the high degree of care required of a motorist entering an intersection; (h) Denied. It is specifically denied that Mr. Olson failed to stop at the posted stop sign; (i). Denied. It is specifically denied that Mr. Olson failed to drive at a careful and prudent speed allegedly preventing him from coming to a stop within the assured clear distance ahead; Q). Denied. It is specifically denied that Mr. Olson disregarded the speed of vehicles and conditions of the highway; and (k). Denied. It is specifically denied that Mr. Olson failed to have sufficient control over his vehicle; it is further specifically denied that Mr. Olson violated any section of the Motor Vehicle Code as alleged by Plaintiff. 16. Denied. The averments contained in Paragraph 16 are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. By way of further response, Mr. Olson is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph 16, relating to Plaintiffs alleged Injuries, and the same are therefore denied and strict proof demanded at the time of trial. 17. Denied. The averments contained in Paragraph 17 are, in part, conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. After reasonable investigation, Mr. Olson is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph 17 and the same are therefore denied and strict proof demanded at the time of trial. 18. Denied. The averments contained in Paragraph 18 are, in part, conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. After reasonable investigation, Mr. Olson is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph 18 and the same are therefore denied and strict proof demanded at the time of trial. 19. Denied. The averments contained in Paragraph 19 are, in part, conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. After reasonable investigation, Mr. Olson is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph 19 and the same are therefore denied and strict proof demanded at the time of trial. 20. Denied. The averments contained in Paragraph 20 are, in part, conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. After reasonable investigation, Mr. Olson is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph 20 and the same are therefore denied and strict proof demanded at the time of trial. WHEREFORE, the Defendant John Olson, respectfully requests that judgment be entered in his favor and that Plaintiff's Complaint be dismissed with prejudice. COUNT II - LOSS OF CONSORTIUM James Seeger v. John Olson 21. That the Defendant incorporate herein by reference his answers to Paragraphs 1 through 20 above as though fully set forth herein at length. 22-23. Denied. The averments contained in Paragraphs 22 and 23, are, in part, conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. After reasonable investigation, Mr. Olson is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraphs 22 and 23 and the same are therefore denied and strict proof demanded at the time of trial. WHEREFORE, the Defendant John Olson, respectfully requests that judgment be entered in his favor and that Plaintiffs Complaint be dismissed with prejudice. NEW MATTER By way of additional answer and reply, the Defendant interposes the following New Matter defenses: 24. That the Plaintiffs' alleged cause of action may be barred in whole or in part by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law and by the Limited Tort Option. 25. That if it should be found that there was any negligence on the part of the answering Defendants, which is denied, then in that event any such negligence was not a proximate cause of damages to the Plaintiffs. 26. That the Plaintiff's alleged cause of action may be barred in whole or in part by the Pennsylvania Comparative Negligence Act. 27. That the Plaintiffs' alleged cause of action may have been caused in whole or in part by the negligence of third parties or entities not presently involved in this action. 28. That the Plaintiffs' injuries may have been pre-existing. WHEREFORE, the Defendants, John Olson and Joann Olson, respectfully requests that judgment be entered in their favor and that Plaintiffs' Complaint be dismissed with prejudice. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER +Aorneys J. Ship an, Esquire for Defendants Date: 330479 VERIFICATION I, John Olson, have read the foregoing Answer, hereby affirm that it is true and correct to the best of my personal knowledge, or information and belief. This Verification and statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. DATE: 33-523 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on May 9, 2008: Stephen G. Held, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 Attorneys for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER Je C J. Shipman, squire I. D. #: 51785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendants In t 1 Stephen G. Held, Esq. I.D.#72663 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiffs Fax : (717) 233-3029 E-mail: Held HHRLaw.com PATRICIA SEEGER and : IN THE COURT OF COMMON PLEAS JAMES SEEGER, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : NO. 06-6487 Civil JOHN OLSON and JOANN OLSON, CIVIL ACTION - LAW Defendants : PLAINTIFFS' REPLY TO NEW MATTER 24. This averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby deniedBy way of amplification, Plaintiffs' cause of action is not barred in whole or in part by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility law and the limited tort option. 25. This averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby deniedBy way of amplification, Defendants' negligence was the proximate cause of the damages to Plaintiffs. 26. This averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby deniedBy way of amplification, Plaintiffs' cause of action is not barred in whole or in part by the Pennsylvania Comparative Negligence Act. 27. This averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby deniedBy way of amplification, Plaintiffs' cause of action has been caused by negligence of the instant Defendants. 28. This averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby deniedBy way of amplification, Plaintiffs' injuries are not pre-existing. WHEREFORE, Plaintiffs request this Honorable Court enter judgment in their favor against Defendants. Date: v Respectfully Submitted, HANDLER, HENNING & ROSENBERG, LLP By-- __ AO St he G. eld, Esq. I.D. No. 72663 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorney for Plaintiffs 2 VERIFICATION PURSUANT TO PA R.C.P. NO. 1024 (c) STEPHEN G. HELD, ESQUIRE, states that he is the attorney for the party filing the foregoing document; that he makes this affidavit as an attorney, because the party he represents lacks sufficient knowledge or information upon which to make a verification and/or because he has greater personal knowledge of the information and belief than that of the party for whom he makes this affidavit; and that he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa C.S. §4904 relating to unsworn falsification to authorities. Date: Step An G. Hel , Esquire 3 CERTIFICATE OF SERVICE I, Stephen G. Held, attorney for Plaintiffs Patricia Seeger and James Seeger, hereby certify that I have served the foregoing Complaint by Certified Mail, Return Receipt Requested on the day of May 2008, upon the following: Jefferson J. Shipman, Esq. Johnson, Duffie, Stewart & Weidner, P.C. 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 oate S ?4 Stephen G. Held, Esquire Attorney for Plaintiffs 4 PATRICIA SEEGER and JAMES SEEGER, herhusband, Plaintiffs V. JOHN OLSON and JoANN R. OLSON, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-6487 CIVIL TERM CIVIL ACTION - LAW RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in the Following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Jefferson J. Shipman, counsel for the Defendant in the above action respectfully represent that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiffs in the action is under $50,000. There is no counterclaim. The following attorneys are interested in the case as counsel, or are otherwise disqualified to sit as arbitrators: Steven G. Held, Esquire (Plaintiffs) and Jefferson J. Shipman, Esquire (Defendants) WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. y submitted, , DUFFIE, S ART & WEIDNER i J. Shipman, E for Defendants ORDER OF COURT AND NOW, this day of 2008, in consideration of the foregoing petition, , Esq., and Esq. and Esq. are appointed arbitrators in the above captioned action as prayed for. By the Court, P.J. 337716 m 0 PATRICIA SEEGER and JAMES SEEGER, her husband, Plaintiffs V. JOHN OLSON and JoANN R. OLSON, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-6487 CIVIL TERM CIVIL ACTION - LAW RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in the Following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Jefferson J. Shipman, counsel for the Defendant in the above action respectfully represent that: The above-captioned action is at issue. 2. The claim of the Plaintiffs in the action is under $50,000. There is no counterclaim. The following attorneys are interested in the case as counsel, or are otherwise disqualified to sit as arbitrators: Steven G. Held, Esquire (Plaintiffs) and Jefferson J. Shipman, Esquire (Defendants) WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. pectfully submitted, INSON, DUFFIE, STEWART & WEIDNER i J. Shipman, Esqu for Defendants ORDER OF COURT AND NOW, this 15 day of 2008, in consideration of the foregoing petition, Esq., and Esq. and Esq. are appointe arbitrators in the above captioned action as prayed for. By th C urt, N 337716 P. J. CV U i 3 _ > a ' , r ? N I t 3 C14 f-4 m C - :13 - Z'I CO I s1s. ( ee - 'y Cs :7f7 V ° 1 Plaintiff c?Hn/ ?L Soy/ Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. C%a - 64k Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office M#th fidelity. Name (Chairman) 1AVYAli?&V Law Firm 64 s ?? st Address La Firm 39(2 ///ar7?P7? SJ? Address <J . C/"'?O- Signature Name Sn1;lh eahfwrtl? L(,P Law Firm 300q Nf2r, Sf: Address 0-10,4 s A A /7,0,',3 ?e PI4 / ? / / &mg JW /! P# ? 7D/1 City, zip City- 1 Zip City, Zip At '//y08 --40203 a a We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) (/yF f/ iy q , 4.1 AftAe L c r- 7z?,& Aili.c/ l/FfS ! o/ _cl= 'SLa0O , y6 . Arbitrator, dissents. (Insert name if Date of Hearing: Lo IS & 5 Date of Award: ?<j J k &,P Notice of Entry of Award Now, the day of 200a_, at 1 4jy , _.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ 3S70t4co By. Deputy iZ5?n -( ? Signature Name 3 1 ct HANDLER HENNING & ROSENBERG, LLP By: Stephen G. Held, Esquire 1300 Linglestown Road Harrisburg, PA 17110 Phone: (717) 238-2000 E-mail: Held@hhrlaw.com PATRICIA SEEGER and JAMES SEEGER, her husband, Plaintiffs V. JOHN OLSON, Defendant Attorneys for Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-6487 Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: PLEASE mark the above-captioned matter settled and discontinued with prejudice. Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP By: Ste n eld, Esquire 1300 Linglestown Road Harrisburg, PA 17110 Telephone (717) 238-2000 Attorneys for Plaintiffs Date