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Ronald Marrero, Esquire
Identification Number 87362
Robert J. Casey, Jr. & Associates
Centre Square West
1500 Market Street, Suite 2500
Philadelphia, PA 19102
(215) 841-3000

ATTORNEY FOR DEFENDANT, WILLIE SHU
AND SHENG SHU-WANG

SHAUNTAE GIDDINGS,
PLAINTIFF

JULY TERM, 2013

VS.

NO. 1307 01767

WILLIE SHU,
DEFENDANT
PLASARD ALVAREZ AND VLADIMIR
DUBUC AND ADONIS ELLIOTT,
PLAINTIFFS

JANUARY TERM, 2014

VS.

NO. 1401 00702

WILLIE SHU AND SHENG SHU-WANG
AND SHAUNTAE GIDDINGS,
DEFENDANTS

MOTION OF DEFENDANT, WILLY SHU FOR CONSOLIDATION OF ACTIONS
Defendant, Willy Shu and Sheng Shu-Wang, by and through their attorney, Ronald
Marrero, Esquire, hereby request this Honorable Court, pursuant to Rule 213(a) of the
Pennsylvania Rules of Civil Procedure, for an Order joining the above-captioned actions for all
purposes including, but not limited to, discovery, arbitration, trial and appeal as follows:
1.

The actions brought by all Plaintiffs arise out of the same July 8, 2012 automobile
accident.

2.

The above-captioned cases are based on theories of negligence.

3.

The above actions all involve common questions of law and fact.

4.

The first lawsuit filed, Giddings v. Shu, et al., PCCP1307 01767, is a negligence action
brought to recover damages for personal injuries allegedly sustained in the July 8, 2012
motor vehicle accident. This is an Arbitration matter which is scheduled to be heard on

Case ID: 140100702
Control No.: 14030737