Preview
z
PAGE 1
REPORT :: ZDRDOCT First Judicial District RUN DATE 04/03/23
USER ID: DXS CIVIL DOCKET REPORT RUN TIME 09:23 AM
CASE ID 221201534
23-03815
~--------~----~-~---~-~-~~---~-~~----~-~----~~----~---~-~~----~~~----~~~----~----
+--+
CASE NUMBER CASE CAPTION
221201534 KI VS MERCEDES
oc ™N
FILING DATE COURT LOCATION JURY a
16-DEC-2022 JE CH J a
3
on
CASE TYPE: MOTOR VEHICLE ACCIDENT 6
STATUS: TRANSFER TO OTHER JURISDICTION
tm:
PG =
Seq # Assoc Expn Date Type ID Party Name / Address & PhosECNo. a
a
1 APLF A314774 BRESLIN, MATTHEW nm
RODDEN & RODDEN
125 NORTH 20TH STREET
PHILADELPHIA PA 19103
(215) 940-2155
msbreslin@gmail.com
PLE @11499300 KI, DOUGLAS
128 HUNTINGWOOD DRIVE
LANCASTER PA 17602
DET @11499301 MERCEDES, YORKEL GUILLEN
816 N.LIME STREET
LANCASTER PA 17602
TL J485 CARPENTER, LINDA
294 CITY HALL
PHILADELPHIA PA 19107
30-JAN-23 ADFT A317027 DURSO, NICOLE MARIE
HUBSHMAN, FLOOD, BULLOCK & DOR
5165 CAMPUS DRIVE
SUITE 200
PLYMOUTH MEETING PA 19462
(610) 276-4995
(866) 842-1482 — FAX
Nicole_M Durso@progressive.com
ADFT A307120 NOSARI, KATHERINE K
HUBSHMAN & FLOOD
5165 CAMPUS DRIVE
SUITE 200
PLYMOUTH MEETING PA 19462
(610) 276-4972
(866) 842-1482 - FAX
knosaril@progressive.com
Filing Date / Time Docket Entry Date Entered
6¢ 023
PID Evil?
Chek 2Y(F
tript- M571
. a PAGE 2
REPORT :: ZDRDOCT First Judicial District RUN DATE 04/03/23
USER ID: DXS CIVIL DOCKET REPORT RUN TIME 09:23 AM
CASE ID 221201534
Filing Date / Time Docket Entry Date Entered
16-DEC-22 09:54:03 ACTIVE CASE 16-DEC-22
E-Filing Number: 2212033689
16-DEC-22 09:54:03 COMMENCEMENT CIVIL ACTION JURY 16-DEC~22
BRESLIN, MATTHEW
16-DEC-22 09:54:03 COMPLAINT FILED NOTICE GIVEN 16-DEC-22
BRESLIN, MATTHEW
COMPLAINT WITH NOTICE TO DEFEND WITHIN TWENTY (20) DAYS
AFTER SERVICE IN ACCORDANCE WITH RULE 1018.1 FILED.
16-DEC-22 09:54:03 JURY TRIAL PERFECTED 16-DEC-22
BRESLIN, MATTHEW
8 JURORS REQUESTED.
16-DEC-22 09:54:03 WAITING TO LIST CASE MGMT CONF 16-DEC-22
BRESLIN, MATTHEW
05-JAN-23 13:05:24 AFFIDAVIT OF SERVICE FILED 05-JAN-23
BRESLIN, MATTHEW
AFFIDAVIT OF SERVICE OF PLAINTIFF'S COMPLAINT UPON
YORKEL GUILLEN MERCEDES BY PERSONAL SERVICE ON
12/20/2022 FILED. (FILED ON BEHALF OF DOUGLAS KI)
20-JAN-23 11:14:09 ENTRY OF APPEARANCE 20-JAN-23
DURSO, NICOLE MARIE
ENTRY OF APPEARANCE OF NICOLE MARIE DURSO FILED. (FILED
ON BEHALF OF YORKEL GUILLEN MERCEDES)
30-JAN-23 12:29:32 WITHDRAWAL/ENTRY OF APPEARANCE 30-JAN-23
NOSARI, KATHERINE K
WITHDRAWAL OF APPEARANCE OF NICOLE MARIE DURSO AND
ENTRY OF APPEARANCE OF KATHERINE NOSARI FILED. (FILED
ON BEHALF OF YORKEL GUILLEN MERCEDES)
31-JAN-23 15:31:08 PRELIMINARY OBJECTIONS 01-FEB-23
NOSARI, KATHERINE K
66-23020066 PRELIMINARY OBJECTIONS TO COMPLAINT FILED.
RESPONSE DATE: 02/21/2023 (FILED ON BEHALF OF YORKEL
GUILLEN MERCEDES)
31-JAN-23 15:31:08 JURY TRIAL PERFECTED 01-FEB-23
NOSARI, KATHERINE K
8 JURORS REQUESTED.
13-FEB-23 16:32:15 LISTED FOR CASE MGMT CONF 13-FEB-23
15-FEB-23 00:30:42 NOTICE GIVEN 15-FEB-23
OF CASE MANAGEMENT CONFERENCE SCHEDULED FOR
03-MAR-2023.
s PAGE 3
REPORT :: ZDRDOCT First Judicial District RUN DATE 04/03/23
USER ID: DxXS CIVIL DOCKET REPORT RUN TIME 09:23 AM
CASE ID 221201534
Filing Date / Time Docket Entry Date Entered
23-FEB-23 11:31:38 PRELIM OBJECTIONS ASSIGNED 23-FEB-23
66-23020066 PRELIMINARY OBJECTIONS ASSIGNED TO JUDGE:
CARPENTER, LINDA . ON DATE: FEBRUARY 23, 2023
28-FEB-23 14:55:31 ORDER ENTERED/236 NOTICE GIVEN 28-FEB-23
CARPENTER, LINDA
66-23020066 AND NOW, THIS 28TH DAY OF FEBRUARY, 2023,
UPON CONSIDERATION OF THE FOREGOING PRELIMINARY
OBJECTIONS, IT IS HEREBY ORDERED THAT: 1. A RULE IS
ISSUED UPON THE RERSPONDENT TO SHOW CAUSE WHY THE
PETITIONER IS NOT ENTITLED TO THE RELIEF REQUESTED.
2. THE PETITION SHALL BE DECIDED UNDER PA.R.C.P.
206.7; ARGUMENT SHALL BE HELD REMOTELY, VIA ZOOM, ON
THE 2TH DAY OF APRIL 2023 AT 10:00 A.M. COUNSEL MAY
ACCESS THE HEARING THROUGH THE COURT WEBPAGE AT
WWW.COURTS.PHILA.GOV BY OPENING THE "CALENDARS" MENU
AND SELECTING "COMMON PLEAS-CIVIL REMOTE HEARING
INFORMATION". THE ZOOM CREDENTIALS ARE ALSO PROVIDED
BELOW FOR DIRECT LOG-IN. 4. NOTICE OF THE ENTRY OF
THIS ORDER SHALL BE PROVIDED TO ALL PARTIES BY THE
PETITIONER. *ZOOM/VIRTUAL COURTROOM MEETING ID: 476
595 9315. https; //zoom.us/i/4765959315 MEETING ID:
476 595 9315 DIAL BY YOUR LOCATION: +1 267 831 0333
US (PHILADELPHIA) 888 475 4499 US TOLL FREE 887 853
5257 US TOLL FREE. ALL BRIEFS, SUPPLEMENTAL BRIEFS
AND/OR SUPPLEMENTAL DISCOVERY SHALL BE FILED BEFORE
APRIL 24, 2023. BY THE COURT: HON. LINDA
CARPENTER, 11-15-2023.
28-FEB-23 14:55:32 NOTICE GIVEN UNDER RULE 236 03-MAR-23
NOTICE GIVEN ON 03-MAR-2023 OF ORDER ENTERED/236 NOTICE
GIVEN ENTERED ON 28-FEB-2023.
28-FEB-23 14:56:58 LISTED RULE RETURNABLE DATE 28-FEB-23
03-MAR-23 13:06:23 CASE MGMT CONFERENCE COMPLETED 03-MAR-23
GIAMPAOLO, ANTHONY
03-MAR-23 13:06:23 CASE MANAGEMENT ORDER ISSUED 03-MAR~23
CASE MANAGEMENT ORDER EXPEDITED TRACK - AND NOW,
03-MAR-2023, it is Ordered that: 1. The case
management and time standards adopted for expedited
track cases shall be applicable to this case and are
hereby incorporated into this Order. 2. All discovery
on the above matter shall be completed not later than
02-OCT-2023. 3. Plaintiff shall identify and submit
curriculum vitae and expert reports of all expert
witnesses intended to testify at trial to all other
parties not later than 02-OCT-2023. 4. Defendant
and any additional defendants shall identify and
submit curriculum vitae and expert reports of all
expert witnesses intended to testify at trial not
44
PAGE 4
REPORT :z ZDRDOCT First Judicial District RUN DATE 04/03/23
USER ID: DXS CIVIL DOCKET REPORT RUN TIME 09:23 AM
CASE ID 221201534
Filing Date / Time Docket Entry Date Entered
later than 06-NOV-2023. 5. All pre-trial motions
shall be filed not later than 06-NOV-2023. 6. A
settlement conference
may be scheduled at any time
after 06-NOV-2023. Prior to the settlement conference
all counsel shall serve all opposing counsel and file
a settlement memorandum containing the following: (a)
A concise summary of the nature of the case if
plaintiff or of
the defense if defendant or additional
defendant; (b) A
statement by the plaintiff or all
damages accumulated, including an itemization of
injuries and all special damages claimed by categories
and amount; (c) Defendant shall identify all
applicable insurance carriers, together with
applicable limits of liability. 7. A pre-trial
conference will be scheduled any time after
01-JAN-2024. Fifteen days prior to pre-trial
conference, all counsel shall serve all opposing
counsel and file a pre-trial memorandum containing the
following: (a) A concise summary of the nature of the
case if plaintiff or the defense if defendant or
additional defendant; (b) A list of all witnesses who
may be called to testify at trial by name and address.
Counsel should expect witnesses not listed to be
precluded from testifying at trial; (c) A list of all
exhibits the party intends to offer into evidence.
All exhibits shall be pre-numbered and shall be
exchanged among counsel prior to the conference.
Counsel should expect any exhibit not listed to be
precluded at trial; (d) Plaintiff shall list an
itemization of injuries or damages sustained together
with all special damages claimed by category and
amount. This list shall include as appropriate,
computations of all past lost earnings and future lost
earning capacity or medical expenses together with any
other unliquidated damages claimed; and (e) Defendant
shall state its position regarding damages and shall
identify all applicable insurance carriers, together
with applicable limits of liability; (£) Each counsel
shall provide an estimate of the anticipated length of
trial. 8. It is expected that the case will be ready
for trial 05-FEB-2024, and counsel should anticipate
trial to begin expeditiously thereafter. 9 All
counsel are under a continuing obligation and are
hereby ordered to serve a copy of this order upon all
unrepresented parties and upon all counsel entering an
appearance subsequent to the entry of this order.
.+-BY THE COURT: LINDA CARPENTER, Je
03-MAR-23 13:06:23 LISTED FOR SETTLEMENT CONF 03-MAR-23
* ae te PAGE 5
REPORT :: ZDRDOCT First Judicial District RUN DATE 04/03/23
USER ID: DxXS CIVIL DOCKET REPORT RUN TIME 09:23 AM
CASE ID 221201534
Filing Date / Time Docket Entry Date Entered
03-MAR~23 13:06:23 LISTED FOR PRE-TRIAL CONF _03-MAR-23
03-MAR-23 13:06:23 LISTED FOR TRIAL 03-MAR-23
03-MAR-23 13:06:24 NOTICE GIVEN UNDER RULE 236 08-MAR-23
NOTICE GIVEN ON 08-MAR-2023 OF CASE MANAGEMENT ORDER
ISSUED ENTERED ON 03-MAR-2023.
13-MAR-23 16:06:09 STIPULATION FILED 14-MAR-23
KATHERINE K NOSARI,
15-23039015 STIPULATION TO WITHDAW RECKLESSNESS AND
TRANSFER FILED. (FILED ON BEHALF OF YORKEL GUILLEN
MERCEDES) STIPULATION APPROVED. JUDICIAL APPROVAL NOT
REQUIRED AS ALL PARTIES HAVE CONSENTED.
29-MAR-23 15:06:43 STIPULATION ASSIGNED 29-MAR-23
15-23039015 STIPULATION FILED ASSIGNED TO JUDGE:
CARPENTER, LINDA : ON DATE: MARCH 29, 2023
31-MAR-23 16:07:23 TRANSFER TO OTHER JURISDICTION 31-MAR-23
CARPENTER, LINDA
15-23039015 IT IS HEREBY STIPULATED BY ALL PARTIES THAT
THE ABOVE MATTER SHALL BE TRANSFERRED TO LANCASTER
COUNTY. IT IS FURTHER STIPULATED THAT ALL COSTS OF
TRANSFER ARE TO BE PAID BY THE PLAINTIFF. IT 1s
FURTHER STIPULATED THAT ALL REFERENCES TO RECKLESSNESS
AND RECKLESS BEHAVIOR ARE WITHDRAWN FROM THE
PLAINTIFF'S COMPLAINT. BY THE COURT: HON. LINDA
CARPENTER, 3-31-2023.
* * * End of Docket * * *
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if save nedORD
APR ~ 5.2023
.
DIRECTOR, OFFICE OF AUDICIAL
Grit
RECORDS
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KI VS MERCEDES
221201534
Docket: COMMENCEMENT CIVIL ACTION JURY
DECEMBER 16, 2022 09:54:03
Sequence:
File: 1 Final Cover
airppaf 2/27/2013 #11350927
04/04/23 02:01 PM
Ez a a =
Court of Common Pleas of-Philadelphia ‘County’ Prot thon a i
Trial Division Is ie 7 ie
534 |
9029,
Civil Cover Sheet E-Filing Number
=
689Satsa Ges Ss
PLAINTIFF'S NAME. DEFENDANT'S NAME
DOUGLAS KI YORKEL GUILLEN MERCEDES
PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS
128 HUNTINGWOOD DRIVE . IME STREET
LANCASTER PA 17602 LANCASTER PA 17602
PLAINTIFF'S NAME, DEFENDANT'S NAME
.
PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS
PLAINTIFF'S NAME DEFENDANT'S NAME
'
PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS
TOTAL NUMBER OF PLAINTIFFS. ‘TOTAL NUMBER OF DEFENDANTS ‘COMMENCEMENT OF ACTION.
iP aint ,, © Petition Action D1 Notice of Appeal
1 oO Transfer From Other Jurisdictions
é jummon!
are
AMOUNT IN CONTROVERSY ‘COURT PROGRAMS, ie ie
wie.
C2 arbitration Re 0 . ‘Commerce Settlement
D2 $50,000.00 or less Jury Wingsone
Action: Minor Court Appeal O Minors
EX More than $50,000.00 1 non-Jury, PS,
SSN) ‘tatutory Appeals 0 wosurvival
Other: a i
CASE TYPE AND CODE. i % aay F
2V - MOTOR VEHICLE ACCIDI N Ph af
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STATUTORY BASIS FOR GAUSE OF ACTION Ti Fae
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RELATED PENDING CASES (LIST BY CASE CAPTION AND DOCKET NUMBER) 1S CASE SUBJECT TO
COORDINATION ORDER?
PROPROTHY YES NO
DEC 16 2022
C. PERRY
TO THE PROTHONOTARY: .
Kindly enter my appearance on behalf of. Plaintiff/Petitioner/Appellant: DOUGLAS _KI
Papers may be served at the address set forth below.
NAME OF PLAINTIFF'S/PETITIONER'S/APPELLANT'S ATTORNEY ADDRESS
RODDEN & RODDEN
MATTHEW BRESLIN
125 NORTH 20TH STREET
PHONE NUMBER FAX NUMBER PHILADELPHIA PA 191 03
(215) 940-2155 none entered
‘SUPREME COURT IDENTIFICATION NO. E-MAIL ADDRESS
314774 msbreslin@gmail.com
‘SIGNATURE OF FILING ATTORNEY OR PARTY DATE SUBMITTED
MATTHEW BRESLIN Friday, December 16, 2022, 09:54.am
FINAL COPY (Approved by the Prothonotary Clerk)
KI VS MERCEDES
221201534
Docket: COMPLAINT FILED.NOTICE GIVEN
DECEMBER 16, 2022 09:54:03
Sequence:
File: 1 A - Complaint.pdf
‘irppaf 2/27/2013 #11350927
04/04/23 02:01 PM
BONO 7,
MAJOR JURY
RODDEN RODDEN & BRESLIN
By: MATTHEW S. BRESLIN, ESQUIRE Filed
S
a feet y the
Office
Aes fi, cords
LD. #:° 314774
_
16
125 NorTH 20™ STREET
PHILADELPHIA, PA 19103 Sa
aot
TELEPHONE: 215-940-2155 ATTORNEY FOR PLAr
DOUGLAS KI COURT OF COMMON PLEAS
128 HUNTINGWOOD DRIVE PHILADELPHIA COUNTY
LANCASTER, PA 17602
-VS.-
YORKEL GUILLEN MERCEDES December Term, 2022
816 N. LIME STREET
LANCASTER, PA 17602 NO.
CIVIL ACTION COMPLAINT
2V—MOTOR VEHICLE ACCIDENT
NOTICE AVISO
You have been sued in court. If you wish to defend Le han demandado a usted en la corte. Si usted
against the claims set forth in the following pages, you must take quiere defenderse de estas demandas expuestas en la paginas
action within twenty (20) days after this complaint and notice are siguientes, usted tiene veinte (20) dias de piazo al-partir de la
served, by entering a written appearance personally ot by attomey fecha de la demanda y las notificacion. Hace falta asentar una
and filing in writing with the court your defenses or objections to comparesencia escrita sus defensas 0 sus objeciones a las
the claims set forth against you. You are warned that if you fall to demandas en contra de su persona. Sea continuar la demanda
do so the case may proceed without you and a judgment may be en contra suya sin previo aviso o notificacion, Ademas la corte
entered against you by the court without further notice for any puede. decidir a favor del demandante y requiere que usted
money claimed in the complaint or for any other claim or relief ‘cumpla contodas las provisiones de esta demanda. Usted puede
requested: by the plaintiff. You may lose money or property or perder dinero 0 sus propiedades 0 otros derechos importantes
other rights important to you. para usted.
YOU SHOULD TAKE THIS PAPER TO YOUR LLEVE ESTA DEMANDA A UN ABOGADO
LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER INMEDIATAMENTE. SI NO TIENE ABOGADO O SINO
OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIENE ‘EL DINERO SUFICIENTE DE PAGAR TAL
THE OFFICE SET FORTH BELOW TO FIND OUT SERVICIO, VAYA EN PERSONA O LLAME POR
WHERE YOU CAN GEL LEGAL HELP. TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUMENTRA ESCRITA ABAJO PARA AVERIGUAR
Lawyers Reference Service DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
One Reading Center
Philadelphia, PA 19107 Servicio de Referencia Legal
(215) 238-6333 Uno Reading Centro
TTY (215) 451-6197 Filadelfia, PA 19107
Telefono: (215) 238-6333
TY (215) 451-6197
Case ID: 221201534
Plaintiff, Douglas Ki, is an adult individual residing at the above address.
2 Defendant, Yorkel Guillen Mercedes, is an adult individual residing at the above address.
3 At all times material hereto, plaintiff, Douglas Ki, was the owner, and/or operator of a
motor vehicle, involved in the accident hereinafter described.
4 At all times material hereto, defendant, Yorkel Guillen Mercedes, was the owner, lessee,
and/or operator of a motor vehicle, involved in the accident hereinafter described.
5 On or about March 31, 2021, plaintiff, Douglas Ki, was operating the aforementioned
vehicle westbound on State Highway Rt. 30 near mile marker 268.6, when they were suddenly and
without warning struck in the rear of their vehicle by the vehicle operated by Defendant, Yorkel Guillen
Mercedes.
6 As a result of the collision, Plaintiff sustained serious personal injuries, the exact nature
and extent of which are more particularly described hereinafter.
COUNT I—-NEGLIGENCE
PLAINTIFF, DOUGLAS KI ys. DEFENDANT, YORKEL GUILLEN MERCEDES
7. Plaintiff incorporates by reference, the allegations contained in the foregoing Paragraphs as
fully as though the same were fully set forth at length herein.
8. The accident was caused solely by the negligence, carelessness and recklessness of the
defendant, Yorkel Guillen Mercedes, and consisted of but was not necessarily limited to the following:
@ Operating her vehicle at an excessive rate of speed under the circumstances;
(b) Failing to keep a proper lookout;
(©) Failing to keep a safe following distance;
@ Failing to keep a clear and assured distance ahead;
) Failing to make proper observations;
@ Violating the various ordinances of the Statutes of the Commonwealthof PA pertaining to
the proper operation of motor vehicles on public trafficways; and
(g) Being otherwise negligent under the circumstances.
Case ID; 221201534
9. Solely as a result of the aforesaid occurrence, Plaintiff has been rendered sick, sore, lame and
prostrate and has sustained injuries about the neck, back, spine, and shoulder, resulting to a possible
injury to the muscles, nerves, disks, bones and ligaments connected thereto; and a shock to the nerves
and nervous system. Plaintiff has endured and continues to endure great pain and suffering and/or
aggravation of pre-existing conditions.
10. Plaintiff alleges that all of the aforesaid injuries are serious and/or permanent in nature and
were a result of a serious impairment of a body function as defined in Pa. C.S.A. § 1702. Plaintiff also
makes claims hereinafter for injuries, damages or consequences of which they have no present
knowledge.
11. As a further result of this accident, Plaintiff has been or will be obliged to receive and
undergo medical attention and care, and to expend various sums of money and/or incur expenses for the
injuries they have suffered; and they may be obliged to continue to expend such sums for an indefinite
period of time in the future, perhaps permanently.
12. As a further result of this accident, Plaintiff has or may suffer a severe loss of their
earnings, and impairment of earning capacity or power for which a claim is hereby made.
13. As a direct and reasonable result of the aforementioned accident, Plaintiff has or may in
the future incur other financial expenses and/or losses, which do or may exceed amounts which Plaintiff
may otherwise be entitled to recover under contract, or in accordance with the Law.
14. As a result of the aforementioned accident, and by reason of the injuries, as aforesaid,
Plaintiff has or may in the future continue to suffer great pain and agony, mental anguish and
humiliation, and. has been and may in the future be hindered from attending to their daily duties,
functions, avocations and occupations(s) all to Plaintiff's great damage and loss.
15, Plaintiff alleges that they have full tort under PaMVFRA 75 Pa. C.S.A. §1702 et seq,
either by way of election and/or by applicable law.
WHEREFORE, Plaintiff, Douglas Ki, demands judgment against defendant, Yorkel Guillen
Mercedes, in an amount in excess of Fifty Thousand ($50,000.00) Dollars, together with attorney fees,
Case ID: 221201534
cost of suit, and any and all such other relief 'as this Honorable Court deems just and appropriate
Rodden Rodden & Breslin,
By: /s/
Matthew S. Breslin, Esquire
Attorney for Plaintiff
Dated: December 16, 2022
Case ID: 221201534
VERIFICATION
The undersigned, subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification
to authorities, hereby verifies and states that they are a Plaintiff herein, and that the facts set forth in the
foregoing document are true and correct to the best of their knowledge, information and belief.
Hf
DOUGLAS KI
7_
Dated: December 16, 2022
Case ID: 221201534
KI vs MERCEDES
221201534
Docket: FFIDAVIT OF SERVICE FILED
- JANUARY 5, 2023 13:05:24
Sequence:
File: 1 A - Return of Service.pdf
azlrppaf 2/27/2013 #11350927
04/04/23 02:01 PM
Ki vs. Mercedes; Philadelphia CCP; 221201534
saat
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RETURN iL SERVICE
hereby certify and return that‘on the’ x Oo” dayof Dec. 202) athe" 5° ange)
served the Complaint; Summons, ‘and Civil Cover-Sheet, by handing copies‘of such documents to'the’
following: yy) / /) cTio1 Comp D#H 2120/5 84
_Vorkel G. Mercedes (pet)
ee of Individual served and Position/Title:
ckel CMe ced es
Name’ Defendant served:
Lime Sst Len cestic fs L7602, PE ef. # oN
SIGN
Address where service was made: f
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| incurred the following costs in service: sol 0. © f
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| DECLARE YNDER PENALTY .OF PERJURY
THAT THE FOREGOING:IS TRUE AND CORRECT: '
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Signature of Process ever
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Preview
z PAGE 1 REPORT :: ZDRDOCT First Judicial District RUN DATE 04/03/23 USER ID: DXS CIVIL DOCKET REPORT RUN TIME 09:23 AM CASE ID 221201534 23-03815 ~--------~----~-~---~-~-~~---~-~~----~-~----~~----~---~-~~----~~~----~~~----~---- +--+ CASE NUMBER CASE CAPTION 221201534 KI VS MERCEDES oc ™N FILING DATE COURT LOCATION JURY a 16-DEC-2022 JE CH J a 3 on CASE TYPE: MOTOR VEHICLE ACCIDENT 6 STATUS: TRANSFER TO OTHER JURISDICTION tm: PG = Seq # Assoc Expn Date Type ID Party Name / Address & PhosECNo. a a 1 APLF A314774 BRESLIN, MATTHEW nm RODDEN & RODDEN 125 NORTH 20TH STREET PHILADELPHIA PA 19103 (215) 940-2155 msbreslin@gmail.com PLE @11499300 KI, DOUGLAS 128 HUNTINGWOOD DRIVE LANCASTER PA 17602 DET @11499301 MERCEDES, YORKEL GUILLEN 816 N.LIME STREET LANCASTER PA 17602 TL J485 CARPENTER, LINDA 294 CITY HALL PHILADELPHIA PA 19107 30-JAN-23 ADFT A317027 DURSO, NICOLE MARIE HUBSHMAN, FLOOD, BULLOCK & DOR 5165 CAMPUS DRIVE SUITE 200 PLYMOUTH MEETING PA 19462 (610) 276-4995 (866) 842-1482 — FAX Nicole_M Durso@progressive.com ADFT A307120 NOSARI, KATHERINE K HUBSHMAN & FLOOD 5165 CAMPUS DRIVE SUITE 200 PLYMOUTH MEETING PA 19462 (610) 276-4972 (866) 842-1482 - FAX knosaril@progressive.com Filing Date / Time Docket Entry Date Entered 6¢ 023 PID Evil? Chek 2Y(F tript- M571 . a PAGE 2 REPORT :: ZDRDOCT First Judicial District RUN DATE 04/03/23 USER ID: DXS CIVIL DOCKET REPORT RUN TIME 09:23 AM CASE ID 221201534 Filing Date / Time Docket Entry Date Entered 16-DEC-22 09:54:03 ACTIVE CASE 16-DEC-22 E-Filing Number: 2212033689 16-DEC-22 09:54:03 COMMENCEMENT CIVIL ACTION JURY 16-DEC~22 BRESLIN, MATTHEW 16-DEC-22 09:54:03 COMPLAINT FILED NOTICE GIVEN 16-DEC-22 BRESLIN, MATTHEW COMPLAINT WITH NOTICE TO DEFEND WITHIN TWENTY (20) DAYS AFTER SERVICE IN ACCORDANCE WITH RULE 1018.1 FILED. 16-DEC-22 09:54:03 JURY TRIAL PERFECTED 16-DEC-22 BRESLIN, MATTHEW 8 JURORS REQUESTED. 16-DEC-22 09:54:03 WAITING TO LIST CASE MGMT CONF 16-DEC-22 BRESLIN, MATTHEW 05-JAN-23 13:05:24 AFFIDAVIT OF SERVICE FILED 05-JAN-23 BRESLIN, MATTHEW AFFIDAVIT OF SERVICE OF PLAINTIFF'S COMPLAINT UPON YORKEL GUILLEN MERCEDES BY PERSONAL SERVICE ON 12/20/2022 FILED. (FILED ON BEHALF OF DOUGLAS KI) 20-JAN-23 11:14:09 ENTRY OF APPEARANCE 20-JAN-23 DURSO, NICOLE MARIE ENTRY OF APPEARANCE OF NICOLE MARIE DURSO FILED. (FILED ON BEHALF OF YORKEL GUILLEN MERCEDES) 30-JAN-23 12:29:32 WITHDRAWAL/ENTRY OF APPEARANCE 30-JAN-23 NOSARI, KATHERINE K WITHDRAWAL OF APPEARANCE OF NICOLE MARIE DURSO AND ENTRY OF APPEARANCE OF KATHERINE NOSARI FILED. (FILED ON BEHALF OF YORKEL GUILLEN MERCEDES) 31-JAN-23 15:31:08 PRELIMINARY OBJECTIONS 01-FEB-23 NOSARI, KATHERINE K 66-23020066 PRELIMINARY OBJECTIONS TO COMPLAINT FILED. RESPONSE DATE: 02/21/2023 (FILED ON BEHALF OF YORKEL GUILLEN MERCEDES) 31-JAN-23 15:31:08 JURY TRIAL PERFECTED 01-FEB-23 NOSARI, KATHERINE K 8 JURORS REQUESTED. 13-FEB-23 16:32:15 LISTED FOR CASE MGMT CONF 13-FEB-23 15-FEB-23 00:30:42 NOTICE GIVEN 15-FEB-23 OF CASE MANAGEMENT CONFERENCE SCHEDULED FOR 03-MAR-2023. s PAGE 3 REPORT :: ZDRDOCT First Judicial District RUN DATE 04/03/23 USER ID: DxXS CIVIL DOCKET REPORT RUN TIME 09:23 AM CASE ID 221201534 Filing Date / Time Docket Entry Date Entered 23-FEB-23 11:31:38 PRELIM OBJECTIONS ASSIGNED 23-FEB-23 66-23020066 PRELIMINARY OBJECTIONS ASSIGNED TO JUDGE: CARPENTER, LINDA . ON DATE: FEBRUARY 23, 2023 28-FEB-23 14:55:31 ORDER ENTERED/236 NOTICE GIVEN 28-FEB-23 CARPENTER, LINDA 66-23020066 AND NOW, THIS 28TH DAY OF FEBRUARY, 2023, UPON CONSIDERATION OF THE FOREGOING PRELIMINARY OBJECTIONS, IT IS HEREBY ORDERED THAT: 1. A RULE IS ISSUED UPON THE RERSPONDENT TO SHOW CAUSE WHY THE PETITIONER IS NOT ENTITLED TO THE RELIEF REQUESTED. 2. THE PETITION SHALL BE DECIDED UNDER PA.R.C.P. 206.7; ARGUMENT SHALL BE HELD REMOTELY, VIA ZOOM, ON THE 2TH DAY OF APRIL 2023 AT 10:00 A.M. COUNSEL MAY ACCESS THE HEARING THROUGH THE COURT WEBPAGE AT WWW.COURTS.PHILA.GOV BY OPENING THE "CALENDARS" MENU AND SELECTING "COMMON PLEAS-CIVIL REMOTE HEARING INFORMATION". THE ZOOM CREDENTIALS ARE ALSO PROVIDED BELOW FOR DIRECT LOG-IN. 4. NOTICE OF THE ENTRY OF THIS ORDER SHALL BE PROVIDED TO ALL PARTIES BY THE PETITIONER. *ZOOM/VIRTUAL COURTROOM MEETING ID: 476 595 9315. https; //zoom.us/i/4765959315 MEETING ID: 476 595 9315 DIAL BY YOUR LOCATION: +1 267 831 0333 US (PHILADELPHIA) 888 475 4499 US TOLL FREE 887 853 5257 US TOLL FREE. ALL BRIEFS, SUPPLEMENTAL BRIEFS AND/OR SUPPLEMENTAL DISCOVERY SHALL BE FILED BEFORE APRIL 24, 2023. BY THE COURT: HON. LINDA CARPENTER, 11-15-2023. 28-FEB-23 14:55:32 NOTICE GIVEN UNDER RULE 236 03-MAR-23 NOTICE GIVEN ON 03-MAR-2023 OF ORDER ENTERED/236 NOTICE GIVEN ENTERED ON 28-FEB-2023. 28-FEB-23 14:56:58 LISTED RULE RETURNABLE DATE 28-FEB-23 03-MAR-23 13:06:23 CASE MGMT CONFERENCE COMPLETED 03-MAR-23 GIAMPAOLO, ANTHONY 03-MAR-23 13:06:23 CASE MANAGEMENT ORDER ISSUED 03-MAR~23 CASE MANAGEMENT ORDER EXPEDITED TRACK - AND NOW, 03-MAR-2023, it is Ordered that: 1. The case management and time standards adopted for expedited track cases shall be applicable to this case and are hereby incorporated into this Order. 2. All discovery on the above matter shall be completed not later than 02-OCT-2023. 3. Plaintiff shall identify and submit curriculum vitae and expert reports of all expert witnesses intended to testify at trial to all other parties not later than 02-OCT-2023. 4. Defendant and any additional defendants shall identify and submit curriculum vitae and expert reports of all expert witnesses intended to testify at trial not 44 PAGE 4 REPORT :z ZDRDOCT First Judicial District RUN DATE 04/03/23 USER ID: DXS CIVIL DOCKET REPORT RUN TIME 09:23 AM CASE ID 221201534 Filing Date / Time Docket Entry Date Entered later than 06-NOV-2023. 5. All pre-trial motions shall be filed not later than 06-NOV-2023. 6. A settlement conference may be scheduled at any time after 06-NOV-2023. Prior to the settlement conference all counsel shall serve all opposing counsel and file a settlement memorandum containing the following: (a) A concise summary of the nature of the case if plaintiff or of the defense if defendant or additional defendant; (b) A statement by the plaintiff or all damages accumulated, including an itemization of injuries and all special damages claimed by categories and amount; (c) Defendant shall identify all applicable insurance carriers, together with applicable limits of liability. 7. A pre-trial conference will be scheduled any time after 01-JAN-2024. Fifteen days prior to pre-trial conference, all counsel shall serve all opposing counsel and file a pre-trial memorandum containing the following: (a) A concise summary of the nature of the case if plaintiff or the defense if defendant or additional defendant; (b) A list of all witnesses who may be called to testify at trial by name and address. Counsel should expect witnesses not listed to be precluded from testifying at trial; (c) A list of all exhibits the party intends to offer into evidence. All exhibits shall be pre-numbered and shall be exchanged among counsel prior to the conference. Counsel should expect any exhibit not listed to be precluded at trial; (d) Plaintiff shall list an itemization of injuries or damages sustained together with all special damages claimed by category and amount. This list shall include as appropriate, computations of all past lost earnings and future lost earning capacity or medical expenses together with any other unliquidated damages claimed; and (e) Defendant shall state its position regarding damages and shall identify all applicable insurance carriers, together with applicable limits of liability; (£) Each counsel shall provide an estimate of the anticipated length of trial. 8. It is expected that the case will be ready for trial 05-FEB-2024, and counsel should anticipate trial to begin expeditiously thereafter. 9 All counsel are under a continuing obligation and are hereby ordered to serve a copy of this order upon all unrepresented parties and upon all counsel entering an appearance subsequent to the entry of this order. .+-BY THE COURT: LINDA CARPENTER, Je 03-MAR-23 13:06:23 LISTED FOR SETTLEMENT CONF 03-MAR-23 * ae te PAGE 5 REPORT :: ZDRDOCT First Judicial District RUN DATE 04/03/23 USER ID: DxXS CIVIL DOCKET REPORT RUN TIME 09:23 AM CASE ID 221201534 Filing Date / Time Docket Entry Date Entered 03-MAR~23 13:06:23 LISTED FOR PRE-TRIAL CONF _03-MAR-23 03-MAR-23 13:06:23 LISTED FOR TRIAL 03-MAR-23 03-MAR-23 13:06:24 NOTICE GIVEN UNDER RULE 236 08-MAR-23 NOTICE GIVEN ON 08-MAR-2023 OF CASE MANAGEMENT ORDER ISSUED ENTERED ON 03-MAR-2023. 13-MAR-23 16:06:09 STIPULATION FILED 14-MAR-23 KATHERINE K NOSARI, 15-23039015 STIPULATION TO WITHDAW RECKLESSNESS AND TRANSFER FILED. (FILED ON BEHALF OF YORKEL GUILLEN MERCEDES) STIPULATION APPROVED. JUDICIAL APPROVAL NOT REQUIRED AS ALL PARTIES HAVE CONSENTED. 29-MAR-23 15:06:43 STIPULATION ASSIGNED 29-MAR-23 15-23039015 STIPULATION FILED ASSIGNED TO JUDGE: CARPENTER, LINDA : ON DATE: MARCH 29, 2023 31-MAR-23 16:07:23 TRANSFER TO OTHER JURISDICTION 31-MAR-23 CARPENTER, LINDA 15-23039015 IT IS HEREBY STIPULATED BY ALL PARTIES THAT THE ABOVE MATTER SHALL BE TRANSFERRED TO LANCASTER COUNTY. IT IS FURTHER STIPULATED THAT ALL COSTS OF TRANSFER ARE TO BE PAID BY THE PLAINTIFF. IT 1s FURTHER STIPULATED THAT ALL REFERENCES TO RECKLESSNESS AND RECKLESS BEHAVIOR ARE WITHDRAWN FROM THE PLAINTIFF'S COMPLAINT. BY THE COURT: HON. LINDA CARPENTER, 3-31-2023. * * * End of Docket * * * s > . if save nedORD APR ~ 5.2023 . DIRECTOR, OFFICE OF AUDICIAL Grit RECORDS Pal > Lo SN KI VS MERCEDES 221201534 Docket: COMMENCEMENT CIVIL ACTION JURY DECEMBER 16, 2022 09:54:03 Sequence: File: 1 Final Cover airppaf 2/27/2013 #11350927 04/04/23 02:01 PM Ez a a = Court of Common Pleas of-Philadelphia ‘County’ Prot thon a i Trial Division Is ie 7 ie 534 | 9029, Civil Cover Sheet E-Filing Number = 689Satsa Ges Ss PLAINTIFF'S NAME. DEFENDANT'S NAME DOUGLAS KI YORKEL GUILLEN MERCEDES PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS 128 HUNTINGWOOD DRIVE . IME STREET LANCASTER PA 17602 LANCASTER PA 17602 PLAINTIFF'S NAME, DEFENDANT'S NAME . PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS PLAINTIFF'S NAME DEFENDANT'S NAME ' PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS TOTAL NUMBER OF PLAINTIFFS. ‘TOTAL NUMBER OF DEFENDANTS ‘COMMENCEMENT OF ACTION. iP aint ,, © Petition Action D1 Notice of Appeal 1 oO Transfer From Other Jurisdictions é jummon! are AMOUNT IN CONTROVERSY ‘COURT PROGRAMS, ie ie wie. C2 arbitration Re 0 . ‘Commerce Settlement D2 $50,000.00 or less Jury Wingsone Action: Minor Court Appeal O Minors EX More than $50,000.00 1 non-Jury, PS, SSN) ‘tatutory Appeals 0 wosurvival Other: a i CASE TYPE AND CODE. i % aay F 2V - MOTOR VEHICLE ACCIDI N Ph af NE a “e h n se yy ei ses S ss Uda ey aoe Ee STATUTORY BASIS FOR GAUSE OF ACTION Ti Fae "Sis Aoeg has kee i srsx RELATED PENDING CASES (LIST BY CASE CAPTION AND DOCKET NUMBER) 1S CASE SUBJECT TO COORDINATION ORDER? PROPROTHY YES NO DEC 16 2022 C. PERRY TO THE PROTHONOTARY: . Kindly enter my appearance on behalf of. Plaintiff/Petitioner/Appellant: DOUGLAS _KI Papers may be served at the address set forth below. NAME OF PLAINTIFF'S/PETITIONER'S/APPELLANT'S ATTORNEY ADDRESS RODDEN & RODDEN MATTHEW BRESLIN 125 NORTH 20TH STREET PHONE NUMBER FAX NUMBER PHILADELPHIA PA 191 03 (215) 940-2155 none entered ‘SUPREME COURT IDENTIFICATION NO. E-MAIL ADDRESS 314774 msbreslin@gmail.com ‘SIGNATURE OF FILING ATTORNEY OR PARTY DATE SUBMITTED MATTHEW BRESLIN Friday, December 16, 2022, 09:54.am FINAL COPY (Approved by the Prothonotary Clerk) KI VS MERCEDES 221201534 Docket: COMPLAINT FILED.NOTICE GIVEN DECEMBER 16, 2022 09:54:03 Sequence: File: 1 A - Complaint.pdf ‘irppaf 2/27/2013 #11350927 04/04/23 02:01 PM BONO 7, MAJOR JURY RODDEN RODDEN & BRESLIN By: MATTHEW S. BRESLIN, ESQUIRE Filed S a feet y the Office Aes fi, cords LD. #:° 314774 _ 16 125 NorTH 20™ STREET PHILADELPHIA, PA 19103 Sa aot TELEPHONE: 215-940-2155 ATTORNEY FOR PLAr DOUGLAS KI COURT OF COMMON PLEAS 128 HUNTINGWOOD DRIVE PHILADELPHIA COUNTY LANCASTER, PA 17602 -VS.- YORKEL GUILLEN MERCEDES December Term, 2022 816 N. LIME STREET LANCASTER, PA 17602 NO. CIVIL ACTION COMPLAINT 2V—MOTOR VEHICLE ACCIDENT NOTICE AVISO You have been sued in court. If you wish to defend Le han demandado a usted en la corte. Si usted against the claims set forth in the following pages, you must take quiere defenderse de estas demandas expuestas en la paginas action within twenty (20) days after this complaint and notice are siguientes, usted tiene veinte (20) dias de piazo al-partir de la served, by entering a written appearance personally ot by attomey fecha de la demanda y las notificacion. Hace falta asentar una and filing in writing with the court your defenses or objections to comparesencia escrita sus defensas 0 sus objeciones a las the claims set forth against you. You are warned that if you fall to demandas en contra de su persona. Sea continuar la demanda do so the case may proceed without you and a judgment may be en contra suya sin previo aviso o notificacion, Ademas la corte entered against you by the court without further notice for any puede. decidir a favor del demandante y requiere que usted money claimed in the complaint or for any other claim or relief ‘cumpla contodas las provisiones de esta demanda. Usted puede requested: by the plaintiff. You may lose money or property or perder dinero 0 sus propiedades 0 otros derechos importantes other rights important to you. para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LLEVE ESTA DEMANDA A UN ABOGADO LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER INMEDIATAMENTE. SI NO TIENE ABOGADO O SINO OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIENE ‘EL DINERO SUFICIENTE DE PAGAR TAL THE OFFICE SET FORTH BELOW TO FIND OUT SERVICIO, VAYA EN PERSONA O LLAME POR WHERE YOU CAN GEL LEGAL HELP. TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUMENTRA ESCRITA ABAJO PARA AVERIGUAR Lawyers Reference Service DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. One Reading Center Philadelphia, PA 19107 Servicio de Referencia Legal (215) 238-6333 Uno Reading Centro TTY (215) 451-6197 Filadelfia, PA 19107 Telefono: (215) 238-6333 TY (215) 451-6197 Case ID: 221201534 Plaintiff, Douglas Ki, is an adult individual residing at the above address. 2 Defendant, Yorkel Guillen Mercedes, is an adult individual residing at the above address. 3 At all times material hereto, plaintiff, Douglas Ki, was the owner, and/or operator of a motor vehicle, involved in the accident hereinafter described. 4 At all times material hereto, defendant, Yorkel Guillen Mercedes, was the owner, lessee, and/or operator of a motor vehicle, involved in the accident hereinafter described. 5 On or about March 31, 2021, plaintiff, Douglas Ki, was operating the aforementioned vehicle westbound on State Highway Rt. 30 near mile marker 268.6, when they were suddenly and without warning struck in the rear of their vehicle by the vehicle operated by Defendant, Yorkel Guillen Mercedes. 6 As a result of the collision, Plaintiff sustained serious personal injuries, the exact nature and extent of which are more particularly described hereinafter. COUNT I—-NEGLIGENCE PLAINTIFF, DOUGLAS KI ys. DEFENDANT, YORKEL GUILLEN MERCEDES 7. Plaintiff incorporates by reference, the allegations contained in the foregoing Paragraphs as fully as though the same were fully set forth at length herein. 8. The accident was caused solely by the negligence, carelessness and recklessness of the defendant, Yorkel Guillen Mercedes, and consisted of but was not necessarily limited to the following: @ Operating her vehicle at an excessive rate of speed under the circumstances; (b) Failing to keep a proper lookout; (©) Failing to keep a safe following distance; @ Failing to keep a clear and assured distance ahead; ) Failing to make proper observations; @ Violating the various ordinances of the Statutes of the Commonwealthof PA pertaining to the proper operation of motor vehicles on public trafficways; and (g) Being otherwise negligent under the circumstances. Case ID; 221201534 9. Solely as a result of the aforesaid occurrence, Plaintiff has been rendered sick, sore, lame and prostrate and has sustained injuries about the neck, back, spine, and shoulder, resulting to a possible injury to the muscles, nerves, disks, bones and ligaments connected thereto; and a shock to the nerves and nervous system. Plaintiff has endured and continues to endure great pain and suffering and/or aggravation of pre-existing conditions. 10. Plaintiff alleges that all of the aforesaid injuries are serious and/or permanent in nature and were a result of a serious impairment of a body function as defined in Pa. C.S.A. § 1702. Plaintiff also makes claims hereinafter for injuries, damages or consequences of which they have no present knowledge. 11. As a further result of this accident, Plaintiff has been or will be obliged to receive and undergo medical attention and care, and to expend various sums of money and/or incur expenses for the injuries they have suffered; and they may be obliged to continue to expend such sums for an indefinite period of time in the future, perhaps permanently. 12. As a further result of this accident, Plaintiff has or may suffer a severe loss of their earnings, and impairment of earning capacity or power for which a claim is hereby made. 13. As a direct and reasonable result of the aforementioned accident, Plaintiff has or may in the future incur other financial expenses and/or losses, which do or may exceed amounts which Plaintiff may otherwise be entitled to recover under contract, or in accordance with the Law. 14. As a result of the aforementioned accident, and by reason of the injuries, as aforesaid, Plaintiff has or may in the future continue to suffer great pain and agony, mental anguish and humiliation, and. has been and may in the future be hindered from attending to their daily duties, functions, avocations and occupations(s) all to Plaintiff's great damage and loss. 15, Plaintiff alleges that they have full tort under PaMVFRA 75 Pa. C.S.A. §1702 et seq, either by way of election and/or by applicable law. WHEREFORE, Plaintiff, Douglas Ki, demands judgment against defendant, Yorkel Guillen Mercedes, in an amount in excess of Fifty Thousand ($50,000.00) Dollars, together with attorney fees, Case ID: 221201534 cost of suit, and any and all such other relief 'as this Honorable Court deems just and appropriate Rodden Rodden & Breslin, By: /s/ Matthew S. Breslin, Esquire Attorney for Plaintiff Dated: December 16, 2022 Case ID: 221201534 VERIFICATION The undersigned, subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities, hereby verifies and states that they are a Plaintiff herein, and that the facts set forth in the foregoing document are true and correct to the best of their knowledge, information and belief. Hf DOUGLAS KI 7_ Dated: December 16, 2022 Case ID: 221201534 KI vs MERCEDES 221201534 Docket: FFIDAVIT OF SERVICE FILED - JANUARY 5, 2023 13:05:24 Sequence: File: 1 A - Return of Service.pdf azlrppaf 2/27/2013 #11350927 04/04/23 02:01 PM Ki vs. Mercedes; Philadelphia CCP; 221201534 saat 1h eee Vs Filed yy the office ie) Records 05 LeaTRICt pea gee RETURN iL SERVICE hereby certify and return that‘on the’ x Oo” dayof Dec. 202) athe" 5° ange) served the Complaint; Summons, ‘and Civil Cover-Sheet, by handing copies‘of such documents to'the’ following: yy) / /) cTio1 Comp D#H 2120/5 84 _Vorkel G. Mercedes (pet) ee of Individual served and Position/Title: ckel CMe ced es Name’ Defendant served: Lime Sst Len cestic fs L7602, PE ef. # oN SIGN Address where service was made: f J é “og $. | incurred the following costs in service: sol 0. © f ToT? & a | DECLARE YNDER PENALTY .OF PERJURY THAT THE FOREGOING:IS TRUE AND CORRECT: ' £ ingen a Oe, eng ( wen ca Signature of Process ever a7 vo fe fy! INSTABLE. cEVIN PRESTON _