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HomeMy WebLinkAbout95-06872 ~ ~ ~cJ 'i c- \!) ( 1 J ~ ~ 0::( ~ j ...~ .& d '. ',~ ~~,~ '.i. . " /(:: -',,' .' :J;;. r."" " ;,j "',' ,,'; ,T" ,', <. Y,; " "'~ .- , .~\:~:~.\"t ;;C~i~'{~) -- ,~f:Y.t"J~~I:i\,:j::~ ~ '\,.;.' ,:';" }~ . ~~,<\~ ',," .';" ;.1",. ':;(, ,. '. ...;.',' . . - -~ ,- ",. : . - ",~! I ,", , ;". "-'-";: -~ - ~.?:-.~~'-~~i~ .::~:;~~.~~~t~,~~~< :::-,.' ,.t;~::"::'.l;S~:., ." :1' " , ',- ''"-" '<~\,'~it:\? ':;-;'~::. 0;.: ';'" .:' ," "" '-:.;~ -".' ".1'; \:- -'e --...-.~.. .,~...... ..........., -;.:...; v. I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I CIVIL ACTION - LAW : I NO. 95-7228 CIVIL TERM I I I I HERBERT, ROWLAND and GRUBIC, INC.. Plaintiff STEVEN D. SHUGHART. Dafendant NOTICE OF MEETING OF ARBITRATORS Pleese take notice thet the arbitrators appointed in the above-captioned action will eit for the purpose of their appointment on Wednesday, July 10. 1996 at 10:00 a.m. in the Second Floor Hearing Room of the Old Cumberland County Court House, Carlisle, Pennsylvania. Date 5-10-96 TO: Barbara Sumple-Sullivan, Eaquire 549 Bridge Street New Cumberland. PA 17070 Arbitrator Edward L. Schorpp, E.quire 36 S, Hanover Str'~t Carlisle, PA 17013 Attorney for Plaintiff Philip H. Spare, Esquire 44 W. Main Street Mechanicsburg, PA 17055 Arbitrator Richard K. Morris, Jr., Esquire 318 E. King Street Shippensburg, PA 17257 Attorney for Defendant Thomas F. Cheffins 1 Courthouse Square Carlisle, PA 17013 Court Administrator SHERIPP'S RETURN - REGULAR CASE NOI 199~-06672 P CO~~ONWEALTH OP PENNSYLVANIA, COUNTY OP CU~BERLAND HERBERT ROWLAND AND GURBIC VS. SHUGHART STEVEN D ~ICHAEL BARRICK CU~BERLAND County, Pennsylvania, who to law, says, the within CO~PLAINT upon SHUGHART STEVEN D defendant, at 1126100 HOURS, on the -Zih day of December 19~ at 116 PINE KNOB ROAD NEWVILLE, PA 17241 , Sheriff or Deputy Sheriff of being duly sworn according was served County, Pennsylvania, by handing to STEVEN D. a true and attested copy of the CO~PLAINT and at the same time directing ~ attention to the contents thereof, Sheriff's Costs, Docketing Service Affidavit Surcharge So an~ ~ ~ ~.~<<~ H. omas Kline, - er1 16.00 9.52 .00 2.00 ~~~.~z LANDIS BLACK AND SOH 12111/1995 by Sworn and subscribed to before me this 11 I!: day of M.~...(,......... 19 'J 0( A. D. ( J~" If ?J1'VPt, .~' rot ono ar)' the . HERBERT, ROWLAND and GRUBIC, INC., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. 95- 6872 CIVIL TERM STEVEN D. SHUGHART, Defendant CIVIL ACTION - LAW ORDER OF COURT AND NOW. IJ7I1R.LA ). 7 , 1996, in consideration of the foregoing Petition, I.>> , . 11, 'Il /Yl Y1 t,l/ /Y}, Esquire, A9 /l.br1$1 i J11IfL - . Esquire, 7-..1 'j' -9 "4 /? c u./// v"lA./ and r n. , r -.:l r /'11'- Co- , Esquire, are appointed Arbitrators in the above- captioned action, as prayed for. J~~~ J. , . ,<'" .. ~;.",'}-:.;,:,"<,' 1:-.,: , .' -,. '." '~':'h'.,;,"if'~~r;::~_.?;_:"i:1'Yl;Tr.,}~.n..;::;.1L.-;.-.~~.-r;}~~.,~'4:/;.-4.'.Al:,i".,"?,i:':/'~---#.- /. ~-;.,~"p'v~(,. i'lfi'" ii',',2- '.. _.."....~.'-... -'-' .-'-W!t":';'__".- HERBERT. ROWLAND and GRUBIC, INC.. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA 95- 6872 CIVIL TERM v. STEVEN D. SHUGHART. Defendant CIVIL ACTION - LAW PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Herbert, Rowland and Grubic, Inc" the Plaintiff in the above action, filed to No. 95-6872 Civil Tenn, respectfully represents that: (I) The above-captioned action is at issue as of January 16, 1996; (2) The claim of the Plaintiff in the action is $11,485,25; the counterclaim of the Defendant in the action is $0.00; (3) Selection of arbitrators by the Prothonotary from the alphabetiCal roll is waived, and the Court is requested to appoint said Arbitrators, The following allomeys are interested in the case as counsel, or are otherwise disqualified to sit as Arbitrators: Edward L, Schorpp, Esq,; Robert R. Black, Esq.; and Richard M. Morris, Jr" Esq. WHEREFORE, your Petitioner prays Your Honorable Court to appoint three (3) Arbitrators to whom the case shall be submilled, LANDIS, BLACK & SCHORPP BY~~~ Edward L, CHORPP, Esq. Allomey for Plaintiff ._".' , < HERBERT, ROWLAND and GRUBIC, INC., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, : PENNSYLVANIA : 95- 687) CIVIL TERM v. . . STEVEN D. SHUGHART, Defendant : CIVIL ACTION - LAW . . NOTICB 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(s). You may lose money or property or other rights important to you. YOU SHOULD TAD TH:IS PAPBR TO YOUR LAWYBR AT ONCB. II' YOU DO NOT HAVE A LAWYBR OR CANNOT AFFORD ONB, GO TO OR TBLBPHONB THB OI'I':ICB SBT FORTH BBLOW TO FIND OUT WHBRE YOU CAN GBT LBGAL HBLPI Cumber1an4 county Court Administrator One Courthouse square Carlisle, Pennsylvania 17013 Telephone I (717) 240-6200 . . HERBERT, ROWLAND and GRUBIC, INC., plaintiff IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : 95-lC!'R1~ CIVIL TERM . . : CIVIL ACTION - LAW . . v. STEVEN D. SHUGHART, Defendant COMPLAINT 1. Plaintiff is Herbert, Rowland and Grubic, Inc., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania with offices at 369 East Park Drive, Harrisburg, Pennsylvania 17111. 2. Defendant is Steven D. Shughart, an adult individual who resides at R.D. 2, Box 154F, Newville, Cumberland County, Pennsylvania 17241. 3. On september 21, 1994, a 1993 Chevrolet Lumina automobile owned by Plaintiff and being operated by Plaintiff's agent, servant and employee, Kenneth S. Knowlton, was traveling in a westerly direction on Interstate 81 approaching segment marker 495 and entering a curve into a southerly direction. 4. At that time and place, a vehicle being operated immediately in front of Plaintiff's vehicle slowed to approximately five miles per hour behind another vehicle which was stopping on the right side of the roadway because of mechanical problems. 5. At that time and place, operator Knowlton slowed Plaintiff's vehicle to approximately five miles per hour. 6. At that time and place, Defendant was operating a 1974 , Ford pick-up truck (F-250) immediately behind the vehicle owned by Plaintitt. 7. At that time and place, Defendant did drive his vehicle into the rear of Plaintiff's vehicle, in turn forcing Plaintiff's vehicle into the rear of the vehicle immediately in front of Plaintiff's vehicle. 8. The collision with Plaintiff's vehicle was caused by the negligence, recklessness and carelessness of Defendant as follows: A. In being inattentive and failing to observe the slowing and stopping of vehicles in front of Defendant's vehicle in time to avoid a collision with the same; B. In failing to have his vehicle under such control as to be able to stop in the assured clear distance ahead; c. In failing to operate his vehicle with due regard for the traffic conditions then and there existing on the highway; D. In failing to operate his vehicle under such control as to be able to stop his vehicle prior to colliding with Plaintiff's vehicle; E. In failing to use due care under the circumstances. 9. As a result of said negligence, recklessness and carelessness of Defendant, the vehicle owned by Plaintiff was damaged, whereby the cost of repairs exceeded its value, -3- resulting in said vehicle being totaled. 10. The fair market value of Plaintiff's vehicle at the time of the accident was $12,512.50 plus sales tax in the amount of $750.75 less salvage value of $1,778.00 for a net total loss of $11,485.25. 11. There has been paid, on Defendant's behalf, the sum of $5,000 toward the damages set forth in the preceding paragraph, whereby there is now due and owing the total sum of $6,485.25. WHEREFORE, Plaintiff demands of the Defendant the sum of $6,485.25, which sum is within the limit requiring compulsory arbitration under local Rules of Court. LANDIS, BLACK & SCHORPP By.ff~~~ Edward L. Schorp , Esquire Attorneys for Plaintiff Attorney I.D. #17495 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 243-3727 -4- .' VERIFICATION I verify that the answers and statements contained herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 14904, relating to unsworn falsification to authorities. Dated: 1/ h1 hs- I I 2k~~e:U1 5~ /,(tw$^- K nneth s. Knowlton ,,_.' .' "),_.,~, ", ',-' ':', ,-< ':i '. i -f ',' ,,' HERDER'!', ROWLANIJ and GRUOIC. INC., I'lalntiff v. : IN 1'1I~; COURT O~' COMMON I'I,EAS : CUAlfn;RLANIJ COUNTY : 1'~;NNSYl.VANIA : 95 6872 CIVil, n;RM : CIVIL ACTION I.AW 51'EVEN IJ. SHUGHART. Defendant NOTIC~: 1'0 PLEAIJ TO: HERn~:RT. ROWI.ANI) and GRUIIIC. INC, You arc hereby notified to file a wrillen response to the enclosed New MaUer within twenty (20) days from service hereof or a judgment may be entered against you. s~~~:~~~~~~==== . /. . "i :$ , i; .:,1 .-. ,. H ., 1IJ;IUIt:R'I', ROWLANU and GRUBIC. INC.. l'lainliff IN 'I'II~ COURT 0... COMMON I'U:AS CUMBEIlLANU COUNTY, PENNSYLVANIA V. U5 6812 CIVil, 'I'I':RM STJ;VEN U. SIIUGHAll'r, Ilefendllnt CIVil, ACTION I,AW ANSWER ANIl NEW MATTJ;R ANSWEIl 1. The Uefendant has no knowledl\'l' as to the averments in Paragraph 1. 2. Uenied in PlIrt. Ilefendant's JlIlIne is Steven Shughurt. /lis correct address is 116 Pine Knoll Rd.. Newville. I'A 17241. 3. Ilenled In Part. The Ilefendunt udmllll the Pluintiff's cur wus a Chevrolet I.umlna and that the cars were travI!ling west (Southbound) on Route 81, The defendant has no knowledge as to who was driving IIII! Pluintiff's vehicle or the mile marker where the accident occurl'ed. 4. Denied. The Ilcfendant has no knowlcdge as to the averments In Paragraph 4. 5. Ilenicd. 6. Admitted. 1. Uenied in Part. Uefendant udmits thut his vehicle did hit the rellr of Plaintiff's vehicle. 1I0wevel'. Plaintiff's vehicle hit the car in front of II because it was being drivcn too fust under the conditions. 8. The uvernll'nts in I'arugrllph 8 lire conclusions of law which need not be answered. 9. '1"0 the extent thut the IIverments in Paragraph 9 arc conclusions of IlIw no answel' IS requil'ed, The llefl!llIlant admits that Plaintiff's cur was totaled. . t 4; ._..._.o._.......,.'...~'.._..,+~.". , .. ,.-..,., -..','.' , 10. Denied In Part. The Ilefendant hns no knowledge as to the vlIlue of Plaintiff's car. Ilefendant admits thnl the cnr WlIS IllIlvlIged for $1,7711.00. Since the Defendant docs not know the vnlue 01' Plaintiff's car, Defendant can not calculate the total 10119. 11. Uenied in Part. The Ilefendnnt admits Ihe $5,000 has been paid on his behalf. ~'or the reason stated in l'aralrraph 10 nbove Uefelldant can not calculate Plaintiff's damuges. Furthermore. Defendunt specificnlly denies being responsible for nU of Plaintiff's damages, , NEW MA TTWt AJo'FIRMA'I'IV~; IlI~FJo:NS" COMPARATIVI\ NI~G1,J(HmC" 12. The averments set forth in Pllragrllphs I to IJ of this document (captioned as ANSWER) arc hereb,V incorporated by reference as if set forth herein. 13. The driver 01' Plainlil'f's vehicle did drive his vehiele into the rear of the vehicle in front of him. 14. That Plaintiff's driver did drive inlo the rear of tbe vehicle in front of him caused much of the damage to Plaintiff's car. 15. Plaintiff's driver would have hit lhe vehicle in front of him even had he not been hit by Defendant, 16. PlainlJrr's collision with the ear in front of it was primllrily eallsed by the negligence. I'ecklessness anti clIl'elessness of Plaintiff's driver in that: A. Plaintiff's driver WIIS driving to fast for the conditions. U, Plaintiff's drivel' did fail to he suffjcienll~' attentive to the slowing of vehicles in fronl 01' Plllintifl"s vehicle so as to avold collision. C. Plaintiff's driver foiled be keep on assured safe distance between himself and the vehicle in front 01" him so os to ovoid collision. 11. The negligence. recklessness and carelessness of the Plaintiff's driver. IS responsible for IIn amount 01" damage to PllIintiff's vehicle whil:h exceeds the amount sued 1'01' herein. iliki~: at.m~u[; Ru:IIIII.tI M. Jo~ t. A!lol'Ill:,\' 1"01' Ilel"l'ndllnl Atl<)/'lll',\' # 744:,4 3tH I':. Kin~ SI, ShippcnsllllI'G'. PA t7257 (717) 5:m H570 FAX: (7t71 5:1tJ HOH . 'd-::~,,,,,....~."7~-.' ~."""L"':'F'.-' ., i< VER1~'IC:A'I'ION I verity that the averments and statements contained herein arc true and correct. I understand that Calse statements herein arc made subject to the penalties ot 18 Jla. C.S.A. Sec. 4004. relating to unsworn tlllsmcation to authorities. ~rIR~_ 1;2 -aa- 'is' Steven D. Sh:~;~_MN VA'rE: , . . ,.__...,.."._<"",.."."':'."~\i'...~'t~;,,. .,-.:..,I_, '~,o,f_"",-~""'.""""_""~'~"" ._~,.,....., VJ,;RU'ICA'1'ION 0... SlmVICI> COMMONW~:ALTII Of' pJ,;NNSnVANIA COUNTY 0... CUMUJ,;Rt.ANIl : SS A....'IVAVI1': I do hereby affirm IIl1lt I Ilervl!d the attached Anllwer and New Matter upon the law offices of I(dward I.. Sehorpp, altorne)' for the Plainliff =~\~ \ b= Richard M. Morris~f OA Y 0... OJ,;CEMBER 10115. Af'~'IRMf:O AND SUUSCRJUEIl UJ,;...ORE ME TillS ~=~W==== ~=p~===== TITI,E MY COMMISSION EXPIRES ON~+ ' llI'il'l . Nolanal Seal Suaan K. Guyer, Nolary Public MCeoanllla BolO, Cumbartarid CounlY y mmlaalon Explras Sept. 4, 1999 em or. nnay vanta .~al on 0 Diaries ~ ":-'''~.>fN':"'''l"'':-''''''''_''" .,.-. ~ N ~ M .. :;):;; II - 8:-: ::r: ..,: cc G~ '" ~Y') N ffiCfi t-, t...J c:::a.; i5 c ~ ~ In a- U HERBERT, ROWLAND and :IN THE COURT OF COMMON PLEAS GRUBIC, INC., . CUMBERLAND COUNTY, . plaintiff . PENNSYLVANIA . . . v. . 95- 6872 CIVIL TERM . STEVEN D. SHUGHART, . CIVIL ACTION - LAW . Defendant REPLY TO lIB. MATTBR NOW COMES the Plaintiff, Herbert, Rowland and Grubic, Inc., by and through its attorneys, Landis, Black & Schorpp, and replies to the New Matter of Defendant as follows: 12. paragraphs 1. through 11. inclusive of plaintiff's Complaint are incorporated herein by reference as if fully set forth. 13. Denied. It is denied that Plaintiff's driver drove into the rear of the vehicle preceding Plaintiff's vehicle. On the contrary, at all relevant times herein, plaintiff's driver was operating Plaintiff's vehicle in a careful and prudent manner allowing sufficient distance between Plaintiff's vehicle and the preceding vehicle so as to be able to stop without causing a collision. Plaintiff's vehicle was forced into the rear of the preceding vehicle by the impact of Defendant's vehicle striking Plaintiff's vehicle from the rear. 14. Denied. Plaintiff's driver did not drive into the rear of the preceding vehicle. The averments of Paragraph 13. of this Reply are included herein by reference. All of the damage to Plaintiff's car was caused by the actions of Defendant, all as is set forth in Plaintiff's Complaint. 15. Denied. The averments of Paragraph 13. of Plaintiff's Reply are incorporated herein by reference. The sole and proximate cause of the collision between plaintiff's vehicle and the preceding vehicle was the negligence and recklessness of Defendant, all as is set forth in Plaintiff's Complaint. 16. Denied. These averments are conclusions of law requiring no answer herein. To the extent that answer is required,it is denied that Plaintiff's driver was in any way negligent, reckless or careless in the operation of Plaintiff's vehicle. Additionally, Plaintiff replies as follows: A. Denied. At all relevant times herein, Plaintiff's driver was operating Plaintiff's vehicle at a safe and prudent speed under the conditions then and there existing, and had full ability to stop within the assured clear distance ahead. B. Denied. At all relevant times herein, Plaintiff's driver was operating Plaintiff's vehicle with full attention to the other vehicles on the highway. As is set forth in Plaintiff's Complaint, Plaintiff's driver was operating the vehicle at a slow, safe and prudent speed. C. Denied. At all relevant times herein, Plaintiff's driver operated Plaintiff's vehicle at a safe and prudent speed with full ability to stop within the assured clear distance ahead. Plaintiff's driver was in .no way responsible for any damage to Plaintiff's vehicle. 17. Denied. The averments of this paragraph are conclusions of law requiring no answer herein. By way of further answer, plaintiff's driver is not responsible for any damage to Plaintiff's vehicle, all of said damages being caused by the actions of Defendant as set forth in Plaintiff's Complaint. WHEREFORE, Plaintiff demands judgment against the Defendant, all as set forth in Plaintiff's Complaint. LANDIS, BLACK & SCHORPP BY'~~~ Edward L. Sc orpp, Esquire 36 South Hanover Street Carlisle, PA 17013 (717) 243-3727 Attorneys for Plaintiff '. . VERIFICATION I verify that the statements contained herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 54904, relating to unsworn falsification to authorities. ~V/i1i15 XJ~ - Kenneth S. Knowlton Dated: I / " /9~ f , . -. .".,.-,.....:..-...... ........ .. ,....._>r _">""'. '~'. . ..,'...... _..' _"",.;"i,,""""'~;-,,"m~.<m'~l; r.l1] ii'~.irr'lll,.ll~m~.~~ HERBERT, ROWLAND and . IN THE COURT OF COMMON PLEAS . GRUBIC, INC., . CUMBERLAND COUNTY, . plaintiff . PENNSYLVANIA . . . v. . 95- 6872 CIVIL TERM . . . STEVEN D. SHUGHART, . CIVIL ACTION - LAW . Defendant . . CBRTIP:ICATB 01' SBRVICB I, EDWARD L. SCHORPP, ESQUIRE, hereby certify that I have, on the below date, caused a true and correct copy of the foregoing REPLY TO NEW MATTER to be served upon the person and in the manner indicated below: FIRST CLASS MAIL. POSTAGE PREPAID, ADDRESSED AS FOLLOWS: Richard M. Morris, Jr., Esq. 318 East King Street Shippensburg, PA 17257 By: -'~~~~~ Edward L. schorpp, Esq. LANDIS, BLACK & SCHORPP 36 South Hanover Street Carlisle, PA 17013 (717) 243-3727 Attorneys for plaintiff Date: /-/16'-96' HF.AMFAT Ant.rr AtJn tin" ~UllaT"'. TbJ" Plaintiff In The Court of CQcmon Plees of STEVEN D. SHUGHART ) ) ) ) ) ) , ./ Cumberland County, ?ennaylvania ~~1"'- ~O.95-'~ (t(:..J. T.J...L-- 19 VS. v Dsfendant OA4B ~e do lolemDly svear (or affirm) that ve will support, obey and deiend the CODatieution of ehe Unieed Seaee. and ehe CQnstirutioD oi chi. Com=on- ...... ... ,,., .. vill '''''or,_ 'b_'U'i_~~Y' - ~/(~~ AWARD (or We, the undersigned arbitrators, having been duly appointed and sworn a!!1rmed), make the following avard: (Note: If damages for delay are awarded, chey shall be separately stated.) /n- iAf J6p YAP C// J :If J,/() ~h'J . /Jf)IPhJ,~1 /1-, o f> 1r/l1'1/J-.J I . l/:>II'~/'/ .7h.J :J5 :Jrh;:f ;71?~/,Aj- ~ (' ,p]tOI?,t?o .#JIb r V apPlicable.~;I~ :late of !Iear:L,'lg: I) ~1t9- '11/ :late of Award: ~ -/Ii- qt Arbitrator, dissents. (Insert name 1: ~OTIC~ OF ENTRY OF AWARD ~ow, the Ib '=" day of Q""4 . 19 '1(.. , at 10.'09 , ~. .:1., che above avard was entered upon the docket and ~otice :hereof gIVen bY-=ail co che ?arties or thei= attorneys. Arbitrators' cocpensation :0 be paid upon appeal: 'fa.tu.... t.- I t... P tvu.k...-, ~ !'rothonota'fy Q. /!.11 ~p~_ :le';lucy $ flllO.aU 5y: L.lyl.o I ~:;J >- o. rr r:: ...~ c; 1-- ~~~: :=:: ; ~:t: ;- . -, .<~ g~_: ...:.:::; .oa.;. ~~ a ':3 ~' ..~i; u:~'. S 1Ji"iJ r.: -.'J .:]"- l' <.a .:) Cl U-l ~-..) ~ Jl -< ~ Jj ~ 1 j .- r ..-0'\7'(:' .......",f". 't! · ......Jr-1I'~ 'J- U If'? ~"'7J'\' . T,I;""" (" 'J ~ ~P' r '~II HERBERT, ROWLAND and GRUBIC, INC" Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO. 95-6872 CIVIL TERM CIVIL ACTION - LAW v, STEVEN D. SHUGHART, Defendant JURY TRIAL DEMANDED PRAECIPE Pursuant to the award of arbitrators entered in this matter on July 10, 1996, please enter judgment in favor of the Plaintiff and against the Defendant in the amount of Five Thousand Five Hundred and no/loo ($5,500.00) Dollars plus costs of record. To LAWRENCE E, WELKER. Prothonotary Date: ~-...i't:>- 9(;' LANDIS, BLACK & SCHORPP BY:~~ Edward L. Schorpp, Esquire Attorney for Plaintiff 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 243-3727 ~ CI IQ e ~ ~ o CI 8:: M ~ e f- ::J ..., :5 \D en ~ 1{. 8 cr ~ ~ 5~ o~ :s- o;:] ~1ii i'?~ lnCiJ ~o... ~ r- !j) 7- ~ E: J 11 -:j:j -6 of. ..J J .) ..1(]" 1D ' "2.0 t<) ]~ :g ., ,