229 (B)

In the Court of Common Pleas of Bucks County, Pennsylvania
CARL ILLENBERGER ET AL. Docket №.
Plaintiffs,
v. ORDER
STEVEN KORNOCK, ET AL.

Civil Action
Defendants.
RULE TO SHOW CAUSE

Doylestown, Pennsylvania 18902
ORDER
AND NOW, this _______ day of __________________, 2010, upon
consideration of the foregoing Petition it is hereby ORDERED
that:
MICHAEL J. BROOKS, ESQUIRE
1. A Rule is issued upon the Respondent(s) to show cause why

(215) 230-3761
the Petitioner is not entitled to the relief requested:

Attorney-at-Law
LAW OFFICES
2. The Respondent(s) may file an Answer to the Petition on

or before ___________________;
3724 East Brandon Way
3. In the event of a response, the Petition shall be decided

under Pa.R.C.P. No. 208.3(b);
4. Depositions shall be completed within ________ days of
the date of response; and
5. Notice of the entry of this order shall be provided to
all parties by the Petitioner.
BY THE COURT:
__________________________________
J.
Plaintiffs,
v. ORDER

Civil Action
Defendants.
MOTION FOR ORDER PURSUANT TO RULE 229(b)
ORDER
AND NOW, this _______ day of __________________, 2010, upon

consideration of the within Motion of the Law Offices of Michael

(215) 230-3761
Attorney-at-Law
LAW OFFICES
J. Brooks, Esquire, it is hereby ORDERED the Prothonotary mark
the above captioned action Settled, Discontinued and Ended, upon

payment of costs, as to the following Defendants: Christopher
Cazier, Donovan Chung, Russell Freer, Anthony Grillo, Eric
Halberstadt, John Kalis, Kyle Lynch, Oliver Deanco, Freddie
Pantini, Steven Park, Zachary Raffle, Thomas Romeo, and Beau
Ziegler.
BY THE COURT:
__________________________________
J.
Plaintiffs,
MOTION FOR ORDER PURSUANT
v. TO RULE 229(b)

Civil Action
Defendants.
MOTION FOR ORDER PURSUANT TO RULE 229(b)

AND NOW, comes the Law Offices of Michael J. Brooks,
Esquire, attorney for Plaintiffs, who moves this Honorable Court

to enter an appropriate Order under the provisions of Rule

(215) 230-3761
Attorney-at-Law
LAW OFFICES
229(b) of the Pennsylvania Rules of Civil Procedure for the
following reasons:
1. On or about October 20, 2009 the above referenced
matter was to be tried. As the result of settlement
negotiations on or about that date and prior thereto,
Plaintiffs were able to reach numerious settlements and
avoid a trial.
2. Since that time, defendants Christopher Cazier,
Donovan Chung, Russell Freer, Anthony Grillo, Eric
Halberstadt, John Kalis, Kyle Lynch, Oliver Deanco, Freddie
Pantini, Steven Park, Zachary Raffle, Thomas Romeo, and
Beau Ziegler, have all complied with the terms of
settlement and such settlements are complete.
3. Since that time either due to the extended terms of

the settlement or otherwise, other settlements remain
outstanding, and it is anticipated will remain outstanding
for a continuing period.
4. The defendants who have completed the terms of their
settlement, appropriately and continuously, request
Plaintiffs file discontinuance so such compiling defendants
may close their files. Accordingly, Plaintiffs seek leave
to file discontinuance as to less than all defendants.

DATED: March 31, 2010 LAW OFFICES

Attorney-at-Law
(215) 230-3761
Attorney-at-Law
LAW OFFICES

(215) 230-3761
By:___________________________________
Michael J. Brooks, Esquire

Attorney for Plaintiffs
Supreme Court I.D. No. 74630
Plaintiffs,
MEMORANDUM IN SUPPORT OF
v. PLAINTIFFS’ MOTION FOR
ORDER PURSUANT TO RULE
229(b)
Civil Action
Defendants.
MEMORANDUM IN SUPPORT OF PLAINTIFFS’ MOTION FOR ORDER

PURSUANT TO RULE 229(b)
I. HISTORY OF THE CASE
1. On or about October 20, 2009 the above referenced matter

was to be tried. As the result of settlement negotiations on or

(215) 230-3761
Attorney-at-Law
LAW OFFICES
about that date and prior thereto, Plaintiffs were able to reach
settlements and avoid a trial.

2. Since that time, defendants Christopher Cazier, Donovan
Chung, Russell Freer, Anthony Grillo, Eric Halberstadt, John
Kalis, Kyle Lynch, Oliver Deanco, Freddie Pantini, Steven Park,
Zachary Raffle, Thomas Romeo, and Beau Ziegler, have all
complied with the terms of their respective settlements and such
settlements are complete.
3. Since that time either due to the extended terms of the
settlement or otherwise, several other settlements remain
outstanding, and it is anticipated will remain outstanding for a
continuing period.
II. HOW THE QUESTION IS RAISED
The defendants who have completed the terms of their
settlement, appropriately, seek to have Plaintiffs file
discontinuance and close their files. Accordingly, Plaintiffs
seek leave to file discontinuance as to less than all
defendants.
III. QUESTION INVOLVED

A. WHEATHER PLAINTIFFS MAY OBTAIN LEAVE TO FILE

DISCONTINUANCE AS TO LESS THAN ALL DEFENDANTS.
IV. ARGUMENT
Pennsylvania Rule of Civil Procedure 229(b), although

(215) 230-3761
preventing the Prothonotary from entering discontinuance as to

Attorney-at-Law
LAW OFFICES
less than all defendants, allows the Plaintiffs to seek leave of

court after notice to all parties. Accordingly, in order that
defendants, who have long since completed the terms of their
respective settlements, may have a discontinuance filed, and
formally close their files, Plaintiffs seek to file a
discontinuance to less than all defendants.

V. CONCLUSION
For all the above reasons, Plaintiffs respectfully request
pursuant to Pa. R. Civ. P. 229(b) the Court Order that the
Prothonotary mark the above captioned action Settled,
Discontinued and Ended, upon payment of costs, as to the
following Defendants: Christopher Cazier, Donovan Chung,
Russell Freer, Anthony Grillo, Eric Halberstadt, John Kalis,
Kyle Lynch, Oliver Deanco, Freddie Pantini, Steven Park, Zachary

Raffle, Thomas Romeo, and Beau Ziegler.
DATED: March 31, 2010 Respectfully submitted,

LAW OFFICES
(215) 230-3761
Attorney-at-Law
LAW OFFICES

Attorney-at-Law
(215) 230-3761
By:___________________________________
Plaintiffs,
VERIFICATION
v.

Civil Action
Defendants.
ATTORNEY VERIFICATION
This will certify that I, Michael J. Brooks, Esquire, am
the attorney of record for the Plaintiffs, with regard to the
MOTION FOR ORDER PURSUANT TO RULE 229(b); that I am authorized

to take this verification on behalf of said Plaintiffs, and that

(215) 230-3761
Attorney-at-Law
LAW OFFICES
the facts set forth are true and correct to the best of my
knowledge, information, and belief.

I understand statements herein are made subject to the
penalties of 18 Pa. C.S.A. '4904, relating to unsworn
falsification to authorities.
DATED: March 31, 2010 LAW OFFICES

Attorney-at-Law
(215) 230-3761
By:___________________________________
Plaintiffs,
CERTIFICATION OF SERVICE
v.

Civil Action
Defendants.
I, Michael J. Brooks, Esquire, hereby certify that on March
31, 2010, I served a true and correct copy of the within Motion
on the following:
(215) 230-3761
Attorney-at-Law
LAW OFFICES
See Attached Service List
All counsel of record, via electronic mail and/or first class

mail, postage prepaid, all pro se first class mail, postage

prepaid.
DATED: March 31, 2010

LAW OFFICES
Attorney-at-Law
(215) 230-3761
By:___________________________________

229 (B)

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In the Court of Common Pleas of Bucks County, Pennsylvania

CARL ILLENBERGER ET AL. Docket №.

STEVEN KORNOCK, ET AL.

RULE TO SHOW CAUSE

1. A Rule is issued upon the Respondent(s) to show cause why

the Petitioner is not entitled to the relief requested:

2. The Respondent(s) may file an Answer to the Petition on

3. In the event of a response, the Petition shall be decided

CARL ILLENBERGER ET AL. Docket №.

STEVEN KORNOCK, ET AL.

MOTION FOR ORDER PURSUANT TO RULE 229(b)

AND NOW, this _______ day of __________________, 2010, upon

consideration of the within Motion of the Law Offices of Michael

J. Brooks, Esquire, it is hereby ORDERED the Prothonotary mark

the above captioned action Settled, Discontinued and Ended, upon

payment of costs, as to the following Defendants: Christopher

Cazier, Donovan Chung, Russell Freer, Anthony Grillo, Eric

Halberstadt, John Kalis, Kyle Lynch, Oliver Deanco, Freddie

Pantini, Steven Park, Zachary Raffle, Thomas Romeo, and Beau

CARL ILLENBERGER ET AL. Docket №.

STEVEN KORNOCK, ET AL.

MOTION FOR ORDER PURSUANT TO RULE 229(b)

AND NOW, comes the Law Offices of Michael J. Brooks,

Esquire, attorney for Plaintiffs, who moves this Honorable Court

to enter an appropriate Order under the provisions of Rule

229(b) of the Pennsylvania Rules of Civil Procedure for the

1. On or about October 20, 2009 the above referenced

matter was to be tried. As the result of settlement

negotiations on or about that date and prior thereto,

Plaintiffs were able to reach numerious settlements and

2. Since that time, defendants Christopher Cazier,

Donovan Chung, Russell Freer, Anthony Grillo, Eric

Halberstadt, John Kalis, Kyle Lynch, Oliver Deanco, Freddie

Pantini, Steven Park, Zachary Raffle, Thomas Romeo, and

Beau Ziegler, have all complied with the terms of

settlement and such settlements are complete.

3. Since that time either due to the extended terms of

outstanding, and it is anticipated will remain outstanding

for a continuing period.

4. The defendants who have completed the terms of their

settlement, appropriately and continuously, request

Plaintiffs file discontinuance so such compiling defendants

may close their files. Accordingly, Plaintiffs seek leave

to file discontinuance as to less than all defendants.

DATED: March 31, 2010 LAW OFFICES

Doylestown, Pennsylvania 18902

Michael J. Brooks, Esquire

CARL ILLENBERGER ET AL. Docket №.

MEMORANDUM IN SUPPORT OF PLAINTIFFS’ MOTION FOR ORDER

PURSUANT TO RULE 229(b)

I. HISTORY OF THE CASE

1. On or about October 20, 2009 the above referenced matter

was to be tried. As the result of settlement negotiations on or

settlements and avoid a trial.

2. Since that time, defendants Christopher Cazier, Donovan

Chung, Russell Freer, Anthony Grillo, Eric Halberstadt, John

Kalis, Kyle Lynch, Oliver Deanco, Freddie Pantini, Steven Park,

Zachary Raffle, Thomas Romeo, and Beau Ziegler, have all

complied with the terms of their respective settlements and such

settlements are complete.

3. Since that time either due to the extended terms of the

settlement or otherwise, several other settlements remain

AND NOW, this _ day of ____________, 2010, upon