J-S69008-15

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA IN THE SUPERIOR COURT OF

PENNSYLVANIA

Appellee

v.

ROBERT E. COUSAR

Appellant No. 327 EDA 2015

Appeal from the Judgment of Sentence December 3, 2014

In the Court of Common Pleas of Philadelphia County

Criminal Division at No(s): CP-51-CR-0003053-2012

BEFORE: GANTMAN, P.J., FORD ELLIOTT, P.J.E., and OLSON, J.

MEMORANDUM BY GANTMAN, P.J.: FILED MARCH 03, 2016

Appellant, Robert E. Cousar, appeals from the judgment of sentence 

entered in the Philadelphia County Court of Common Pleas, following his 

conviction of accidents involving death or personal injury.1 We affirm. 

In its opinion, the trial court fully and correctly sets forth the relevant 

facts and procedural history of this case. Therefore, we have no reason to 

restate them. 

Appellant raises the following issues for our review: 

WHETHER THE TRIAL COURT ERRED IN FAILING TO 

CONSIDER APPELLANT’S “SUBSTANTIAL COMPLIANCE” 

WITH THE HIT-AND-RUN STATUTES[?]

WHETHER THE EVIDENCE WAS INSUFFICIENT TO 

____________________________________________

1 75 Pa.C.S.A. § 3742. 
J-S69008-15

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SUPPORT THE TRIAL COURT’S VERDICT[?]

WHETHER THE TRIAL COURT’S VERDICT WAS AGAINST 

THE WEIGHT OF THE EVIDENCE[?]

(Appellant’s Brief at 4). 

After a thorough review of the record, the briefs of the parties, the 

applicable law, and the well-reasoned opinion of the Honorable Giovanni 

Campbell, we conclude Appellant’s issues on appeal merit no relief. The trial 

court opinion comprehensively discusses and properly disposes of those 

questions. (See Trial Court Opinion, filed April 7, 2015, at 5-10) (finding: 

(issues 1 and 2) evidence established Appellant was driver of vehicle that 

struck and injured victim, and Appellant failed to remain at scene of accident 

until he fulfilled requirements of 75 Pa.C.S.A. § 3744; Appellant’s argument 

that he met his statutory obligation because his father called police to report 

Appellant’s involvement in accident fails because Appellant’s own conduct 

did not constitute substantial compliance with hit-and-run statute; 

specifically, Appellant did not supply his name, address, and vehicle 

registration number to anyone at scene, or provide anyone opportunity to 

request Appellant’s driver’s license and information relating to financial 

responsibility; further, Appellant failed to render reasonable assistance to 

victim or make arrangements for transport of victim to hospital when it was 

apparent that victim required medical treatment; Appellant also did not wait 

for police to arrive at accident scene, even though Appellant knew police 

were responding to 911 call placed by victim’s friend; additionally, Appellant, 
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failed to report his involvement in accident promptly and give his pertinent 

information to police by phone or in person; under these circumstances, 

evidence was sufficient to establish Appellant’s non-compliance with hit-andrun statute and to support Appellant’s conviction of accidents involving death 

or personal injury; (issue 3) Appellant was non-compliant with hit-and-run 

statute in several ways; Appellant fled scene of accident and while he might 

have experienced remorse, this did not compel Appellant to return to scene 

of accident, present himself promptly to police, or call police to report 

accident as required by hit-and-run statute; instead, Appellant left his father 

to call police while Appellant went to sleep and then went to work in 

morning; Appellant’s actions demonstrated complete disregard of duties 

imposed on drivers by law; based on these facts, court finds no basis to 

conclude that verdict was against weight of evidence). Accordingly, we 

affirm on the basis of the trial court’s opinion. 

Judgment of sentence affirmed. 

Judgment Entered.

Joseph D. Seletyn, Esq.

Prothonotary

Date: 3/3/2016
On March 30, 2015, Defendant filed an amended Rule 1925(b) statement. 

Statement of Matters Complained of on Appeal. 

On March 17, 2015, the Court entered an order directing the filing of an Amended 

On March 2, 2015, appellate counsel filed a Rule 1925(b) statement. 

Matters Complained of on Appeal, pursuant to Pa.R.A.P. l 925(b ). 

On February 9, 2015, the Court entered an order directing the filing of a Statement of 

A timely Notice of Appeal was filed on January 16, 2015. 

denied on December 17, 2014. 

On December 15, 2014, a Defendant filed a post-sentence motion, which motion was 

to 6-23 months to be served on house arrest, followed by five years probation 

On December 3, 2014, the motion to reconsider was denied and Defendant was sentenced 

On October 10, 2014, Defendant filed a motion to reconsider. 

of a presentence investigation report. 

(75 Pa.C.S. § 3742(A)), as a felony of the third degree. Sentencing was deferred for preparation 

sitting without a jury. Defendant was convicted of accident involving death or personal injury 

On September 30, 2014, Defendant Robert Cousar proceeded to trial before this Court, 

Procedural History 

CAMP BELL, J. 

ROBERT COUSAR APR O 7 2015 

Criminal Appeals Unit 

First Judicial District of PA 

April 1 . , 2015 

MEMORANDUM OPINION 

FILED v. 

COMMONWEALTH OF PA CP-51-CR-0003053-2012 

IN THE COURT OF COMMON PLEAS 

FOR THE FIRST JUDICIAL DISTRICT OF PENNSYLVANIA 

TRIAL DIVISION - CRIMINAL 

Circulated 02/08/2016 03:19 PM
2 

Factual History 

On July 4th weekend in 2011, Coralee Jackson and her husband Terry Crantshaw were 

their friend Anthony Kelley and Mr. Crantshaw's brother Dwight, returning home from watching 

fireworks and visiting the Sugar House Casino. N.T. 9/30/14, pp. 11-14, 29, 47-48. Anthony 

Kelley, was crossing the street in the vicinity of 2"d and Spring Garden Streets in Philadelphia 

when he was struck by a car. N.T. 9/30/14, pp. 15-17, 37, 48-49. The driver of the car was 

· Defendant, Robert Cousar. N.T. 9/30/14, p. 17. Defendant stopped and exited his vehicle as Ms. 

Jackson came over to see Mr. Kelley, then she called 911. N.T. 9/30/14, pp. 21-23, 40-41, 51, 

57. Mr. Kelley was lying on the side of the roadway with his leg twisted, glass and gravel in his 

head and leg, and bleeding from the head. N.T. 9/30/14, pp. 21, 25, 52. 

At some point the passenger in Mr. Cousar's car exited the vehicle and started hollering 

at Mr. Cousar telling him "this looks bad" and saying "we got to go". N.T. 9/30/14, pp. 23, 41, 

44, 45. Defendant and his passenger then got back in the car and Defendant drove off. N.T. 

9/30/14, pp. 23-24, 50-52, 57. 

Police Officer Jimmy Brown testified that he was the assigned accident investigator. 

N.T. 9/30/14, p. 59. On July 4, 2011, Office Brown received a message from Defendant's father 

that his son had been involved in an accident. N.T. 9/30/14, pp. 67-68. The call came in about 

12 hours after the accident. N.T. 9/30/14, pp. 70-71. Officer Brown went to 4168 Poplar 

Avenue, where he observed the vehicle and took photographs. N.T. 9/30/14, pp. 63-64. The car 

windshield was smashed. N.T. 9/30/14, p, 68. 

On July 7, 2011, Defendant met with Officer Brown at police headquarters and gave a 

statement. N.T. 9/30/14, p. 65. His statement (Exhibit C-13) was, in relevant part: 
3 

records were introduced as business records through an appropriate custodian. C-14, N.T. 

ran out. N.T. 9/30/14, p. 80-81. Mr. Kelley's Thomas Jefferson University Hospital medical 

week, and then stayed in a rehabilitation center for approximately 2 Y2 months until his insurance 

and ankle fractures. N.T. 9/30/14, pp. 78-80. He underwent surgery, was hospitalized for a 

torn/scraped skin on his shoulder, elbows, forearm and knees, a fractured vertebra, multiple leg 

N.T. 9/30/14, pp. 77-78. His injuries included skin and scalp injuries, fractured left shoulder, 

about to step up on to the median, and the next thing he recalls was waking up in the hospital. 

Complainant Kelley testified that that the last thing he remembers was crossing the street, 

do so. 

Defendant's statement also stated that he did not call the police because his father said he would 

I WAS TRAVELING W/B ON SPRING GARDEN IN THE LEFT LANE WHEN ALL 

OF A SUDDEN A B/M DARTED IN FRONT OF ME. I TRIED TO STOP BY 

SLAMMING ON MY BRAKES AND SWEARVING (sic) TO THE RIGHT BECAUSE 

I THOUGHT I WOULD BE ABLE TO MISS HIM. ONCE CONTACT WAS MADE, 

HE HIT THE WINDSHIELD AND ROLLED OFF INTO THE ST. I STOPPED 

IMMEDIATLEY, SET THE HAND BRAKES AND GOT OUT. I WENT TO THE 

. GUY AND TRIED TO GET A RESPONSE FROM HIM BY SHACKING (sic) HIM. 

HE DIDN'T RESPOND, SO I TRIED TO LIFT HIM UP AND PUT HIM IN THE CAR 

AND TAKE HIM TO THE HOSPITAL. THEN PEOPLE BEGAN TO GATHER 

AROUND AND SAID, DON'T MOVE HIM AND AT THAT TIME I STOOD BACK 

AND STARTED TELLING PEOPLE TO CALL 911. I WAITED AROUND FOR 

ABOUT 5 MIN AND MY FRIEND DOUG SAID, YO WHAT ARE YOU GOING TO 

DO? IT'S NOT LOOKING GOOD. I TOLD HIM I NEEDED TO GET THE CAR 

BACK TO MY FATHER. AT THAT POINT WE JUMPED IN THE CAR AND LEFT. I 

CALLED MY DAD AND TOLD HIM WHAT HAD HAPPENED. DOUG WANTED 

TO GET OUT A FEW BLOCKS A WAY, SO I DROPPED HIM OFF AND I TRIED TO 

MAKE IT HOME BECAUSE MY WINDSHIELD WAS COMPLETELY 

SHATTERED. I MADE IT TO 33RD & GIRARD A VE WHEN I SIDE SWIPED A 

TREE STUMP THAT WAS HANGING OUT INTO THE STREET FROM THE CURB. 

AT THAT POINT THE CAR WOULDN'T MOVE. I CALLED MY DAD AGAIN AND 

TOLD HIM THAT THE CAR WOULDN'T MOVE. A SHORT TIME LATER MY 

DAD SHOWED UP IN MY AUNTS CAR AND TOOK ME HOME. ONCE WE 

ARRIVED HOME MY DAD CALLED A TOW TRUCK TO GO PICK UP THE CAR. I 

WENT TO SLEEP BECAUSE I HAD TO GO TO WORK THAT MORNING lOAM 
1 Within his challenges to the sufficiency and weight of the evidence, Defendant also criticizes 

the verdict for lack of a description of evidence considered, explanation or justification for the 

verdict by the Court. There is no such requirement in the law. Whether a judge or a jury, a 

factfinder simply renders a verdict of guilty or not guilty on the crimes charged. "[T]here is no 

authority for special verdicts in criminal trials, and '[t]he proposal of special verdicts in criminal 

trials to determine what issues the jury actually resolved has been almost universally 

condemned.' Commonwealth v. Samuel, 599 Pa. 166, 961 A.2d 57, 64 (Pa. 2008)." 

Commonwealth v. Jacobs, 614 Pa. 664, 681, 39 A.3d 977, 987 (Pa. 2012). Although there may 

be circumstances where the factfinder will answer special interrogatories (see Commonwealth v. 

4 

evidence; whether it was error to admit evidence of the extent of the complainant's injuries; and 

whether the verdict was against the weight of the evidence. 1 

errors. However, on close examination, Defendant's challenge is to: the sufficiency of the 

Defendant's Amended Statement of Errors Complained of on Appeal purports to raise 10 

Discussion 

calls, ultimately leaving a message for Officer Brown. N.T. 9/30/14, pp. 101-102. 

Defendant went to sleep because he had to work in the morning. Mr. Cousar made multiple 

After they got home, Mr. Cousar got information about the incident from Defendant, after which 

went to get Defendant and made arrangements for the car to be towed. N.T. 9/30/14, pp. 99-100. 

He then called again to say he could not get home and asked to be picked up. Mr. Cousar 

N.T. 9/30/14, p. 108. 

accident at approximately 2:40 in the morning on July 3, 2011. Defendant told his father that he 

had been involved in an accident at 2"d and Spring Garden that he had hit a person with the car. 

Defendant's father, Robert Cousar, Jr., testified that Defendant called him following the 

members for basic tasks such as grocery shopping. N.T. 9/30/14, p. 82. 

walks with a cane, that he is no longer able to play sports, and he requires help from family 

9/30/14, pp. 85-86. Kelley testified that he had a total of three surgeries on his right leg, that he 
5 

Baker, 72 AJd 652, 656 (Pa. Super. 2013), this is not such a circumstance, nor were any special 

interrogatories requested. Defendant also complains that the court erred in denying his post-trial 

motion for reconsideration as a matter of law and for failing to respond. First, we note that there 

is no such motion for reconsideration of a verdict under the Pennsylvania Rules of Criminal 

Procedure. If the motion was intended to be for extraordinary relief pursuant to Pa.R.Crim.P. 

704(b ), then it did not conform to the requirements of that rule. Moreover, it is axiomatic that 

"Where a trial court refuses to reconsider an order, appeal lies only from the underlying order 

and not from the refusal to reconsider. City of Philadelphia v. Glim, 613 A.2d 613 (Pa. Cmmw. 

1992). 

death or personal injury, provides: 

The statute for which Defendant stands convicted, § 3742, relating to accidents involving 

Commonwealth v. Thomas, 65 A.3d 939, 943 (Pa.Super. 2013). 

[TJhe facts and circumstances established by the Commonwealth need not 

preclude every possibility of innocence. Any doubts regarding a defendant's guilt 

may be resolved by the fact-finder unless the evidence is so weak and 

inconclusive that as a matter of law no probability of fact may be drawn from the 

combined circumstances. Moreover, in applying the above test, the entire record 

must be evaluatedand all evidence actually received must be considered. Finally, 

the trier of fact while passing upon the credibility of witnesses and the weight of 

the evidence produced, is free to believe all, part or none of the evidence. 

Commonwealth v. Ratsamy, 594 Pa. 176, 934 A.2d 1233, 1236 n. 2 (2007). 

Our Supreme Court has instructed: 

properly could have based its verdict." Id. 

evidence and all reasonable inferences therefrom upon which, if believed, the fact finder 

in the light most favorable to the Commonwealth as the verdict winner, and accept as true all 

Commonwealth v. Hughes, 521 Pa. 423, 555 A.2d 1264, 1267 (1989). We "must view evidence 

the evidence is sufficient to prove every element of the crime beyond a reasonable doubt." 

Commonwealth v. Widmer, 560 Pa. 308, 744 A.2d 745, 751 (2000). We must determine "whether 

A claim challenging the sufficiency of the evidence presents a question of law. 

1. The evidence was sufficient to support Defendant's conviction. 
6 

2. Defendant did not remain at the scene of the accident until he had fulfilled the 

requirements of section 3 7 44; 

1. Defendant was the driver of a vehicle involved in an accident resulting in injury to 

another person; 

winner, and granting it the benefit of all reasonable inferences, establishes that: 

Here, the evidence, viewed in the light most favorable to the Commonwealth as verdict 

75 Pa.C.S. § 3744. 

(b) Report of accident to police. -- In the event that none of the persons specified are 

in condition to receive the information to which they otherwise would be entitled under 

subsection (a) and no police officer is present, the driver of any vehicle involved in the 

accident after fulfilling all other requirements of section 3742 (relating to accidents 

involving death or personal injury) and subsection (a), insofar as possible on his part to 

be performed, shall forthwith report the accident to the nearest office of a duly authorized 

police department and submit to the police department the information specified in 

subsection (a). 

(a) General rule. -- The driver of any vehicle involved in an accident resulting in 

injury to or death of any person or damage to any vehicle or other property which is 

driven or attended by any person shall give his name, address and the registration number 

of the vehicle he is driving, and shall upon request exhibit his driver's license and 

information relating to financial responsibility to any person injured in the accident or to 

the driver or occupant of or person attending any vehicle or other property damaged in 

the accident and shallgive the information and upon request exhibit the license and 

information relating to financial responsibility to any police officer at the scene of the 

accident or who is investigating the accident and shall render to any person injured in the 

accident reasonable assistance, including the making of arrangements for the carrying of 

the injured person to a physician, surgeon or hospital for medical or surgical treatment if 

it is apparent that treatment is necessary or if requested by the injured person. 

§ 3744, relating to duty to give information and render aid, provides, in pertinent part: 

75 Pa.C.S. § 3742 

(a) General rule. -- The driver of any vehicle involved in an accident resulting in injury 

or death of any person shall immediately stop the vehicle at the scene of the accident or 

as close thereto as possible but shall then forthwith return to and in every event shall 

remain at the scene of the accident until he has fulfilled the requirements of section 3744 

(relating to duty to give information and render aid). Every stop shall be made without 

obstructing traffic more than is necessary. 
7 

(substantial compliance found when driver left accident scene after other party refused to accept 

substantial compliance. Compare Commonwealth v. Latshaw, 555 A.2d 1350 (Pa. Super. 1989) 

Defendant's conduct was not within the letter or the spirit of the statute, nor did it constitute 

father to report the accident while he went off to bed and thence to work the next morning. 

man he struck bleeding and unconscious on the road without rendering aid, and then left it to his 

Essentially, Defendant fled the scene without leaving any identifying information, left the 

somehow satisfied Defendant's obligations. It did not. 

father about the accident, after having fled the scene, and his father made calls to the police, this 

nonetheless argued at trial, and implicitly in his Rule 1925(b) Statement, that because he told his 

Despite having failed to comply with any of these statutory requirements, Defendant 

9. Defendant did not call the police to provide department his name, address and the 

registration number of the vehicle was driving, or provide the opportunity to request of 

him his driver's license and information relating to financial responsibility. 

8. Defendant did not forthwith report the accident to the nearest office of a duly authorized 

police department and submit to the police department his name, address and the 

registration number of the vehicle was driving, or provide the opportunity to request of 

him his driver's license and information relating to financial responsibility; and 

7. Defendant did not wait for police which he knew were responding to the 911 call; 

6. Mr. Kelley was not in condition to receive Defendant's name, address and the registration 

number of the vehicle he was driving; 

5. It was apparent to Defendant that treatment for Mr. Kelley was necessary; 

4. Did not render reasonable assistance to Mr. Kelley, and did not make arrangements for 

the carrying of the injured Mr. Kelley for medical treatment; 

3. Defendant did not give his name, address and the registration number of the vehicle was 

driving, to any person at the scene, or provide the opportunity to request of him his 

driver's license and information relating to financial responsibility; 
8 

(1) Except as otherwise provided in this section, any person violating this section 

commits a misdemeanor of the first degree. 

(b) Penalties. 

The statute under which Defendant was prosecuted provides, in relevant part: 

Kelley's injuries was an appropriate exercise of the Court's discretion. 

1263, 1270 (Pa. Super. 2004). Admission of probative and relevant evidence of the extent of Mr. 

reversed only if the trial court has abused its discretion. Commonwealth v. Seilhamer, 862 A.2d 

The admissibility of evidence is solely within the discretion of the trial court and will be 

2. It was not error to admit evidence as to the extent of the complainant's injuries. 

severely injured victim, and to provide his information at the scene or in person to police. 

his obligations under the law to remain at the scene until medical aid was provided to the 

The evidence was clearly sufficient to demonstrate that Defendant completely disregarded 

that he was the driver until several days later). 

accident anonymously, but did not come forward with full information about himself and the fact 

a garbage bag on the highway, but later returned and found the victim's body. He reported the 

But see Commonwealth v. Long, 831 A.2d 737, 739 (Pa. Super. 2003) (Long believed he had hit 

the accident occurred to find a suitable place to park, and then returned to the accident scene). 

(substantial compliance found when appellant drove one and one-half miles down the road after 

accident); Commonwealth Dep't of Transp. v. Stamoolis, 297 A.2d 532 (Pa. Cmwlth. 1972) 

address, but failed to reveal that it was he who hit the victim, until six or seven hours after the 

(substantial compliance found when appellant stopped and aided victim and provided name and 

identification information); Commonwealth v. Gosnell, 476 A.2d 46, 47 (Pa. Super. 1984) 
9 

2 In a related ground Defendant alleges that it was error to permit Mr. Kelley to testify about his injuries (Amended 

1925(b) Statement, 15), while conceding that even if it were error, it was harmless in light of the testimony of the 

hospital record custodian 

A motion for new trial on the grounds that the verdict is contrary to the weight of 

the evidence, concedes that there is sufficient evidence to sustain the verdict. 

Commonwealth v. Whiteman, 336 Pa. Super. 120, 485 A.2d 459 (Pa. Super. 1984). Thus, 

the trial court is under no obligation to view the evidence in the light most favorable to 

the verdict winner. Tibbs, 457 U.S. at 38 n. 11. [footnote omitted] An allegation that the 

verdict is against the weight of the evidence is addressed to the discretion of the trial 

court. Commonwealth v. Brown, 53 8 Pa. 410, 648 A.2d 1177 (Pa. 1994 ). A new trial · 

should not be granted because of a mere conflict in the testimony or because the judge on 

the same facts would have arrived at a different conclusion. Thompson, supra. A trial 

judge must do more than reassess the credibility of the witnesses and allege that he would 

not have assented to the verdict ifhe were a juror. Trial judges, in reviewing a claim that 

the verdict is against the weight of the evidence do not sit as the thirteenth juror. Rather, 

The Pennsylvania Supreme Court has explained: 

Defendant asserts that the verdict was against the weight of the evidence. 

3. The verdict was not against the weight of the evidence. 

offense charged was admissible and relevant. 

and protracted loss or impairment. 2 This evidence, which went to an essential element of the 

Evidence from Mr. Kelley and the medical records established the severity of the injuries 

beyond a reasonable doubt, in order to prove the offense as a felony of the third degree. 

9/30/14, p. 75. Accordingly, the burden was on the Commonwealth to establish this element 

Here, whether the injuries constituted serious bodily injury was a fact in dispute. N.T. 

75 Pa.C.S. § 102 

"Serious bodily injury." =Any bodily injury which creates a substantial risk of death or 

which causes serious, permanent disfigurement or protracted loss or impairment of the 

function of any bodily member or organ. 

75 Pa.C.S. § 3742. The Vehicle Code defines "serious bodily injury" as follows: 

(2) If the victim suffers serious bodily injury, any person violating subsection (a) 

commits a felony of the third degree, 
10 

Accordingly, the judgment of sentence should be affirmed. 

contrary to the evidence and our sense of justice is not shocked by the verdict. 

imposed upon a driver by the law. We find no basis on which to conclude that the verdict was 

then going to work the next morning, demonstrates only his complete disregard of the duties 

to the police, or even call the police himself. Leaving the call to his father while going to sleep, 

remorse, he was not compelled by that remorse to return to the scene, promptly present himself 

compliance were without merit. Defendant fled the scene. While he may have experienced 

statutory obligations, and his attempts to excuse his wrongful conduct by asserting substantial 

Here, the evidence clearly established that Defendant in several ways violated his 

Commonwealth v. Chamberlain, 612 Pa. 107, 133-134, 30 A.3d 381, 396 (Pa. 2011). 

The decision of whether to grant a new trial on the basis of a challenge to the weight of 

the evidence is necessarily committed to the sound discretion of the trial court due to the 

court's observation of the witnesses and the evidence. Brown, 538 Pa. 410, 648 A.2d 

1177. A trial court should award a new trial on this ground only when the verdict is so 

contrary to the evidence as to shock one's sense of justice. Commonwealth v. Whitney, 

511 Pa. 232, 512 A.2d 1152 (Pa. 1986). A motion alleging the verdict was against the 

weight of the evidence should not be granted where it merely identifies contradictory 

evidence presented by the Commonwealth and the defendant. 

Commonwealth v. Widmer, 560 Pa. 308, 319-320, 744 A.2d 745, 751-752 (Pa. 2000). Further: 

the role of the trial judge is to determine that "notwithstanding all the facts, certain facts 

are so clearly of greater weight that to ignore them or to give them equal weight with all 

the facts is to deny justice. 11 Id. 
~es{.~ 

anessaA.Montone 

Judicial Secretary to 

Honorable Giovanni 0. Campbell 

Dated: April 7, 2015 

Type of Service (X) First Class Mail 

Hugh Burns, Esquire 

Office of the District Attorney 

Three South Penn Square 

Philadelphia, PA 19107 

District Attorney: 

Type of Service: (X) First Class Mail 

Edward Wiley, Esquire 

2449 Golf Rd Ste 12 

Philadelphia, PA 19131 

Defense Counsel/Party: 

I hereby certify that I am this day serving the foregoing upon the person( s ), and in the 

manner indicated above, which service satisfies the requirements of Pa.R.Crim.P.114: 

PROOF OF SERVICE 

Commonwealth v. Robert Cousar Case Number: CP-51-CR-3053-2012