`BY: ROBERT N. BRAKER, ESQUIRE
`MICHAEL R. MANARA, ESQUIRE
`IDENTIFICATION NO. 62583/318343
`52ND FLOOR, 1650 MARKET STREET
`PHILADELPHIA, PA 19103
`
`(215) 496-8282
`
`WENDY DAGOSTINO
`
`Vv.
`
`URBAN AIR TRAMPOLINE AND
`ADVENTURE PARK,et al.
`
`
`PHILADELPHIA COUNTY
`COURT OF COMMON PLEAS
`
`AUGUSTTERM,2023
`No. 02214
`
`PRAECIPE FOR CONTESTED DISCOVERY MOTION
`
`To the Office of Judicial Records:
`
`I, Michael R. Manara, am counsel for the movantin the discovery motion filed on May31,
`2024, with E-File number 2405070772 seeking complete and verified responses to Plaintiff's
`Interrogatories and Requests for Production of Documents against Defendants, Iron Hill Company
`d/b/a Iron Hill Construction, Iron Hill Company, and The Louderback Group LLC d/b/a
`Louderback Construction Services.
`
`I certify that I have conferred or made reasonable attempts to confer with opposing counsel
`for respondent, Defendants, Iron Hill Company d/b/a Iron Hill Construction, Iron Hill Company,
`and The Louderback Group LLC d/b/a Louderback Construction Services, in an effort to resolve
`the aforementioned motion. However, despite reasonable and goodfaith efforts, the parties are
`unable to resolve this dispute without Court intervention. I makethis certification subject to the
`penalties of 18 Pa.C.S.A. § 4904 regarding unswornfalsifications to authorities.
`
`This Praecipe shall serve as NOTICE to respondentto respondto the contested discovery
`motion within 10 days of the date of this Praecipe.
`
`SALTZ MONGELUZZI BENDESKY
`
`By: Michael R. Manara /s/
`ROBERT N. BRAKER, ESQUIRE
`MICHAEL R. MANARA, ESQUIRE
`Attorneysfor Plaintiff
`
`Case ID: 230802214
`Case ID: 230802214
`
`
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