March 28, 2014 at 9:15 a.m. See Exhibit "A".
The second lawsuit filed, Alvarez et al v Shu et al., PCCP 1401 00702, is a personal
injury action brought by Plaintiffs Plasard Alvarez, Vladimir Dubuc and Adonis Elliott,
rising out of the same July 8, 2012 motor vehicle accident. This is an Arbitration matter
scheduled to be heard on September 25, 2014 at 9:15 a.m. See Exhibit "B".
Consolidation of the above actions will not prejudice any substantial rights of any party
to the actions and will alleviate the danger of inconsistent verdicts, and will avoid the cost
and inconvenience of separate discovery, arbitrations and trials.
WHEREFORE, Defendants, Willy Shu and Sheng Shu-Weng, respectfully request this
Honorable Court to consolidate the above-captioned actions for purposes of discovery,
arbitration, trial and appeal by entering the Order in the form attached hereto.
Ronald Marrero, Esquire
Attorney for DEFENDANTS, WILLIE SHU AND
Case ID: 140100702
Control No.: 14030737