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HomeMy WebLinkAbout00-01200 ROYDEN A, MERCADO and NANCY T. MERCADO, his wife, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-119~ CIVIL TERM v. CIVIL ACTION - LAW STEVEN D. GRASLEY, SR. and TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED PRAECIPE FOR A WRIT OF SUMMONS TO CURTIS R. LONG, PROTHONOTARY: Please enter my appearance on behalf of the plaintiffs and issue a Writ of Summons against the defeudants, Steven D. Grasley, Sr. and Terry Jary Rosenberry. Please direct the Sheriff to serve the defendants as follows: Steven D. Grasley, Sr. 1595 Lindsey Lot Road Shippensburg, P A 17257 Terry Jay Rosenberry P. O. Box 197 Newburg, PA 17240 Respectfully submitted, IRWIN, McKNIGHT & HUGHES Marcns By: Date: March 2, 2000 To: Steven D. Grasley, Sr. and Terry Jay Rosenberry You are hereby notified that Royden A. Mercado and Nancy T. Mercado, the plaintiffs, have commenced an action against you which you are required to defend or a default judgment may be entered against you. By: Date:;? 1114.1{1:d- DEPUTY .2000 f , ." "';'C, ,~," 1- ~,' ,.., '_:-:':'3"" ~""'"__' . ." ,,_~ '''''___~'' .~~"_"',,""'_"'__'~' . _, ~~ _~___ ,",0., ,.", ",,, _ _ '_'0 .,__ ~~~,~ ~w, < _~" ~~,. ~ _,_ ,~" ,- '. ~ "..>- ~ -- "".--'-",~",; , 8 0 0 0 "(, s:: x :!' 'Tl ~"~ :I> ::0 rl1F 3i.~ I 8~ ~,Z N "-::0 -0 ::::l, ~8 :J: 15~ - iSm ~ .. ~ ~ 0'1 -< SHERIFF'S RETURN - OUT OF COUNTY " .~ .. CASE NO: 2000-01199 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MERCADO ROYDEN A ET AL VS GRAS LEY STEVEN D SR ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: GRAS LEY STEVEN D SR but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within WRIT OF SUMMONS On March 29th , 2000 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge Dep. Franklin CO 18.00 9.00 10.00 41. 28 .00 78.28 03/29/2000 IRWIN, MCKNIGHT Se~~ R. 'Thomas Kline Sheriff of Cumberland County & HUGHES Sworn and subscribed to before me this (, ~ day of ~J 'I ,;2IJ1r0 A . D . ~a.~/~' Prothonotary SHERIFF'S RETURN - REGULAR ; CASE NO: 2000-01199 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MERCADO ROYDEN A ET AL VS GRAS LEY STEVEN D SR ET AL CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon ROSENBERRY TERRY JAY the DEFENDANT at 0018:14 HOURS, on the 23rd day of March , 2000 at 1010 THREE SQUARE HOLLOW ROAD NEWBURG, PA 17240 by handing to TERRY J. ROSENBERRY a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 13.02 .00 10.00 .00 29.02 ~~nA~~,t R. homas Kline me this t" rt:' day of 03/29/2000 >RWIN, ~,KNIGHT &,~~ By: . 0 / ~/, Deputy eriff Sworn and Subscribed to before ~ oUviJ A.D. ~ tZ 7n., P#,. ,~ Prothonotary ,- / SHERIFF'S RETURN - REGULAR CASE NO: 2000-01199 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF FRANKLIN MERCADO ROYDEN A ET AL VS GRAS LEY STEVEN D ET AL THEODORE L KONCSOL , Deputy Sheriff of FRANKLIN being duly sworn according to law, was served upon County, Pensylvania, who says, the within SUMMONS GRAS LEY STEVEN D SR the DEFENDANT at 1027:00 Hour, on the 14th day of March 2000 at 1595 LINDSEY LOT ROAD SHIPPENSBURG, PA 17257 SAME by handing to SAME a true and attested copy of SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge Mileage So Answers: 9.00 9.00 4.00 10.00 9.28 'LL..<tj By 03/17/~~8~CY bherlcc CUMBERLAND COUNTY SHERIFF Sworn and Subscribed to before of~~ me ph~s It:;' day ~~~ ' . ./ ~ i ary f 1 A.D. NOTARIAL SEAL PATR1G\A A STAINE. Notary Public ChC\\',~~.lr'sburg, Franklin County Mil Commission E""lres NOli. 4. 2000 -""- I -~ f In The Court of Common Pleas of Cumberland County, Pennsylvania Royden A.' Steven D. Serve: Steven Mercado, et. al. VS. Gras ley, Sr. , et. D. Grasley, Sr. al. NQ 20-1199 Civil Now, 3/6/00 , 200 () , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Franklin County to exe,cute this Writ, this deputation being made at the request and risk of the Plaintiff. , d', , , ,~n'.d.f~ Sheriff of Cumberland County, PA Affidavit of Service Now, ,20-, at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ .. ROYDEN A. MERCADO and NANCY T. MERCADO, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-1199 CIVIL TERM STEVEN D. GRAS LEY , SR., and TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED PRAECIPE Sir: Please enter our appearance for Defendant Terry Jay Rosenberry in the above captioned matter and issue a rule on the plaintiffs to file a complaint within twenty (20) days or suffer judgment of non pros. TO: Curtis R. Long, Prothonotary DATE: May 23, 2000 ADDAMS & RUNDLE BY:~~ William A. Addams Supreme Court I.D. No. 06265 28 South pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 RULE AND NOW, issued on the this 2-?/U-Lnay of -F'Nt plaintiffs in accordance w'th the , ~lOOO, Rule is above Praecipe. k/ , , a/>:4 JP~ Prothonofa. ~ "",",,- I - j' II il Ii ji ;i il ili j ,I ,. "j, ~ ~O 'u' ,- ~"'__" .. C) ~ -01'::-':-: QJiH ~.?:; ~~j ~~' S --< ~ , - (~ e. :Jt :-;Jl) o ''1 :::i -~ ':nH:.r: :: ~-j t;J ~=:;(~ ,'5~ om ::;-1 ::D -< N w :;::;-., C3 ''V 0' ,~~&""""l.~ r,-'1!f4'I!1IImf'l11;1''''~''':~')"R'''U'''~''''lMl'I'lY''''''-i'f~~~'if!'liIiI'l!'-~~~~~ ROYDEN A. MERCADO and : IN THE COURT OF COMMON PLEAS OF NANCY T. MERCADO, his wife, PLAINTIFFS : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW STEVEN D. GRASLEY, SR. and 2000-1199 CIVIL TERM TERRY JAY ROSENBERRY, DEFENDANTS JURY TRIAL DEMANDED NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint, order and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlige, Pennsylvania 17013 717-249-3166 1-800-990-9108 Americans with Disabilities Act of 1990 The Court of Common Pleas of Dauphin County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. -T^~--~ -C"'_~-'__,,"-,_ _ -,.r" ,~.> -,": 'U_H.:_-_~,;~",~!~.t'~"""_ __"-_P' _,,~,_,_,,__" .,. - !"- .',( . "'''''''-''''' -"'_;l"__~,-_',_'"r'~'I~~_'_ -'" -~ ROYDEN A. MERCADO and : IN THE COURT OF COMMON PLEAS OF NANCY T. MERCADO, his wife, PLAINTIFFS : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW STEVEN D. GRASLEY, SR. and 2000-1199 CIVIL TERM TERRY JAY ROSENBERRY, DEFENDANTS JURY TRIAL DEMANDED COMPLAINT AND NOW, this IOth day of July 2000, comes the plaintiffs, Royden A. Mercado and Nancy T. Mercado, his wife, by their attorneys, Irwin, McKnight & Hughes, and makes the following Complaint against the defendants, Steven D. Grasley, Sr. and Terry Jay Rosenberry, as follows: 1. The plaintiffs are Royden A. Mercado and Nancy T. Mercado, his wife, adult individuals residing at 212 Garland Drive, Carlisle, Pennsylvania 17013. 2. The defendant is Steven D. Grasley, Sr., an adult individual residing at 1595 Lindsey Lot Road, Shippensburg, Pennsylvania 17257. 3. The defendant is Terry Jay Rosenberry, an adult individual residing at P. O. Box 197, Newburg, Pennsylvania 17240. 2 ! ,;-'_~',1~ ,0'1 ' ""'~_"', '~'" >,~_r_ ,"_,,'_"""''''f'an,,--. ',,~ ~,-~ ,-, ~ "-~7,'-- "",~""'-_'~<""",,-',,_,_ ,_,-_~_,_ "_;";.d -','0,-""- -"'1"- -- - ~.;' ,-~" ., "-,'f"__" """ - 4. The plaintiff, Royden A. Mercado, was operating a 1995 Blazer automobile eastbound on Walnut Bottom Road in Shippensburg Township, Cumberland County, on March 5, 1998, at 3:18 p.m. 5. As the plaintiff, Royden A. Mercado, neared the entrance of the Kmart shopping center, a vehicle operated by defendant, Terry Jay Rosenberry, entered his lane of travel and a collision occurred. COUNT I ROYDEN A. MERCADO AND NANCY T. MERCADO v. TERRY JAY ROSENBERRY 6. The averments offact contained in paragraphs one (1) through five (5) of this Complaint are hereby incorporated by reference and made a part of this Count. 7. The cause of the collision was the negligence of the defendant, Terry Jay Rosenberry, which consisted of the following: a. Failure to keep his automobile under proper control; b. Failure to yield the right of way to the plaintiff; c. Failure to warn the plaintiff of the collision; d. Traveling in excess of the speed limit; e. Traveling in excess of a safe speed for the traffic and for the conditions of the highway; and f. Operating in a careless and reckless manner. 3 '-,-"1' .". "!,,<c~,,","~,_c,, _'~_""""'1"'_;; .,-\~"~'- 'f -" -'" , "'._,'"'-_~_-~,_, ,_ -,-~__, ,_ 'l" - .".~.'''--'' _,_~,""o,,,"~~_,,,,-',.,.,,, ^""'-',!,, ,,-'.', __ I,c <. . -,~_~ '_,'-', """"'-, .'l, '.., , -~- -, 8. The negligence of the defendant as specified above was the proximate cause of the collision. He is jointly and severally liable for the collision and the damages sustained by the plaintiff, Royden A. Mercado. 9. Another vehicle was involved in the accident which driver was operating his vehicle while under the influence of alcohol. Limited tort does not apply in this case. 10. The plaintiff, Royden A. Mercado, also sustained serious personal injuries to his face and head. The plaintiff still suffers from headaches and neck pain due to the injuries. 11. The plaintiff, Royden A. Mercado, seeks payment of his damages for pain and suffering as well as his unpaid lost wages and future damages for pain and suffering. 12. The plaintiff, Nancy T. Mercado, was married to Royden A. Mercado at the time of the collision. She suffered the loss of comfort and society of her husband as a direct consequence of the actions of the defendant, Terry Jay Rosenberry. WHEREFORE, the plaintiffs, Royden A. Mercado and Nancy T. Mercado, his wife, request damages less than Twenty-Five Thousand and no/lOO ($25,000.00) against the defendant, Terry Jay Rosenberry, plus costs and interest as provided by law. 4 "'1'--":_"-~,; "',"":" ^ -"<.,' '--~~-- .. .,.,",,~y, '-"'nc"e'-.'<:',-w, "--5--,"_-_~____,__~',_7'T'-~~''f 'I"Y~ " - ~ , ,C COUNT II ROYDEN A. MERCADO AND NANCY T. MERCADO Y: STEVEN D. GRASLEY. SR. 13. The averments of fact contained in paragraphs one (1) through twelve (12) of this Complaint are hereby incorporated by reference and made a part ofthis Count. 14. At the time of the collision, the defendant, Steven D. Grasley, Sf., was operating a 1987 Chevrolet Astro Van while under the influence of alcohol. 15. The defendant, Steven D. Grasley, Sr., did strike the rear of the vehicle operated by Terry Jay Rosenberry which forced him into the lane of travel of the plaintiff, Royden A. Mercado. 16. The cause of the collision was the negligence of the defendant, Steven D. Grasley, Sr., which consisted of the following: a. Failure to keep his automobile under proper control; b. Failure to pay proper attention to the traffic ahead; c. Failure to warn the plaintiff of the collision; d. Traveling in excess of the speed limit; 5 , r '_/'o",,~"'"',',C"_~_ -"'-"_'_W'8''''_' ,~:_"K"_ """ _."_V .~~ ~,_"' .~,""_ .""'_"'."'''''''''',. , '-~ ~, ~ -,,, ,~ . L e. Traveling in excess of a safe speed for the traffic and for the conditions of the highway; f. Operating in a careless and reckless manner; and g. Operating his vehicle while under the influence of alcohol. 17. The negligence of the defendant as specified above was the proximate cause of the collision. He is jointly and severally liable for the collision and damages sustained by the plaintiff, Royden A. Mercado. 18. The plaintiff also sustained serious personal injuries to his face and head. The plaintiff still suffers from headaches and neck pain due to the injuries. 19. The plaintiff, Royden A. Mercado, seeks payment of his damages for pain and suffering as well as payment of his lost wages and future damages for pain and suffering. 20. The plaintiff, Nancy T. Mercado, was married to Royden A. Mercado at the time of the collision. She suffered the loss of comfort and society of her husband as a direct consequence of the actions of the defendant, Terry Jay Rosenberry. 6 I ^" 'I Yv~" ~'_'__ ""'~ "-~'~-", -,- -<.~"-""',,~,-,,,,,,'''''--" .,,,,,, ,-~~,~-,--,'(- ,~~- '_.,~,--:,," - . ~ ~.. ~,~ ,~, ~~ ~ ~ - WHEREFORE, the plaintiffs, Royden A. Mercado and Nancy T. Mercado, his wife, request damages less than Twenty Five Thousand and noli 00 ($25,000.00) against the defendant, Steven D. Grasley, Sf., plus costs and interest as provided by law. Respectfully submitted, IRWIN, MCKNIGHT & HUGHES A.Mc i , 60 W t Pomfret Street Carlisle, (717) 249-2353 Supreme Court LD. No. 25476 Attorney for plaintiffs, Royden A. Mercado and Nancy T. Mercado, his wife By: Date: July 10, 2000 7 '"-.,,,,- - - I -, -'-.,,',~~"'~_ ~."o_,,,~c'1',,~_-,_o"_ ,c,___,~o<~ , ~___"~~^r _ _ _~ ~--,'-~" ,.,- ~, ~- . . -~. ~ VERIFICATION The foregoing Complaint is based upon information which has been gathered by counsel and us in the preparation of this action. We have read the statements made in this document and they are true and correct to the best of our knowledge, information and belief. We understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. J;:3.~ ~~ NAN T. MERCADO Date: July 10 .2000 I '1 . ,,~,. ."~""Y"_"'_ .,,-,_, -- c'~_.'_" -' ,-,'>-' '''''"_. ~_ ,"'0__ . ,c'l. ,," " ROYDEN A. MERCADO and : IN THE COURT OF COMMON PLEAS OF NANCY T. MERCADO, his wife, PLAINTIFFS : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW STEVEN D. GRASLEY, SR. and NO. 2000-1199 CIVIL TERM TERRY JAY ROSENBERRY, DEFENDANTS JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Marcus A. McKnight, Ill, Esquire, hereby certifY that a copy of attached Complaint was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: William A. Addams, Esquire ADDAMS & RUNDLE 28 South Pitt Street P. O. Box 208 Carlisle, PA 17013 Attorney for Defendant Terry Jay Rosenberry Steven D. Grasley, Sr. 1595 Lindsey Lot Road Shippensburg, P A 17257 IRWIN, McKNIGHT & HUGHES By: Date: July 11, 2000 ..',. :v_,--_~-,.,"_"._. ",'-~,"-'''''~~ ,}" . ~ 1 - .~,,~ -~,-- '." '_;~!l!'~""_"1IlIIl!I r.~l!1'1!1_-!I1Il (') C'J () f..:;: c,) " :s... , '"TJr~- S q [l]U"i r-- L...">.) " ~'l ? ....--- ", (rJ " , ~, ~) r:: '-.-' ~T' ~ " C. -,-\ Z j , J :;,-; C"J CJ r~n C s! 2: /.:'"' =< :.u <'::J -< - ,~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA ROYDEN A. MERCADO and NANCY T. MERCADO, Plaintiffs Civil Action - Law vs. No. 2000-1199 STEVEN D. GRASLEY, SR. and TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please enter a Rule upon ROYDEN A. MERCADO and NANCY T. MERCADO, Plaintiffs, to file a Complaint within twenty (20) days from the date of the service of this Rule or suffer Judgment non-pros. BY: ~'-:J Dated: ,July /3 . ;;JC)O(J . Robert A. Lerman, Superior Court ID No.: 0749 110 South Northern Way York, PA 17402 Telephone: (717) 757-7602 Attorney for the Defendant, Steven D. Grasley, Sr. NOW, ~)(.L L y /..1 , 2000, RULE ISSUED AS ABOVE. !t/;a,,-k~k~ 1> THONOTARY :ay: .a~~g p 7f~ DEPUTY !"i T'~;:~' J' , -'--":-'~"-'~-,,:;,-~-.- ~, "f"._ , , -', -~~- ~., p.'''''' "' z " ~ " u .. ~ "' M 0 ~ " > M 0. '>- r-. ~ ~ ~ 0 i:1: 0 ~ (,'.: z :: :"~ z: "' "' . W Z' w " ;;:.:-, ~-<~ u z Z 0...; ~ " ~ ~:- ~~~ ~ " 0 ~ 0 ~ z " w z >- ':.i... ~ ~ "' :I ~. 0 z 0 z >.~ >:: "j "' w (-'") " l,Q'~ " ~ ~ u >i -''<::'" '" ~ .Cz. >- 0 : - '.': ~--!.J "' >- --'. ,JJ 0- ,; , ~ >- :5 u: S!; C:) ~ ' , C,:) U '" - '" .~, "--... '". . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROYDEN A. MERCADO and NANCY T. MERCADO, Plaintiffs Civil Action - Law vs. No. 2000-1199 STEVEN D. GRASLEY, SR. and TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED PRAECIPE AND ENTRY OF APPEARANCE PURSUANT TO PaRC.P. 1012 TO THE PROTHONOTARY: Kindly enter the appearance of Robert A. Lerman, Esquire and Thomas B. Sponaugle, Esquire of Griffith, Strickler, Lerman, Solymos & Calkins as attorneys for the Defendant ,Steven D. Grasley, Sr., in the above-captioned matter and mark the docket accordingly. /~ e, Dated: qlrt/oo f ' 110 South Northern Way York, PA 17402 Telephone: (717) 757-7602 Attorney for the Defendant, Steven D. Grasley, Sr. . I , , '" .' . ,<_~_,,_ '" _m. .'--. - ,,' ~,t_ -,-, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROYDEN A. MERCADO and NANCY T. MERCADO, Plaintiffs Civil Action - Law vs. No. 2000-1199 STEVEN D. GRASLEY, SR. and TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, ilij, }l'tl;;y of ~ ,2000, I, Rnbort A Lo._, "m~"'" of the firm of GRIFFITH, STRICKLER, LE N, SOL YMOS & CALKINS, hereby certIfy that I have this date served a copy of Praecipe for Entry of Appearance by United States Mail, addressed to the party or attorney of record as follows: Marcus A. McKnight, III, Esquire 60 W. Pomfret Street Carlisle, P A 17013 (counsel for Plaintiffs) BY: William A. Addams, Esquire Addams & Rundle 28 S. Pitt Street Carlisle, PA 17013 (c sel for Defendant, Terry Jay Rosenberry) Robert A. Lerman Superior Court ID 0.: 0 490 110 South Northern Way York, PA 17402 Telephone: (717) 757-7602 Attorney for the Defendant, Steven D. Grasley, Sr. accltbs/grasley ,prp.z 'r" "1 . -"." . ~ ". ~---, , -~ . - "' z " ~ t5 '" ~ "' ro 0 ~ " i "' N >- ~ 0 r--. ~ 0 ~ ~:; Z ~ (": "' "' . -7 w Z w < 1.:::':'- z '5 u " Z ,~ a: "" "" ~ " . ~ ~.L ~ r~-' <!' 0 0 ~ z &~' t- ,>:)2 ~ w z > -- '~ ~ " "' " '" ~ z (~) - ~~]~ w 0 z c ~ "' w " ~ ~ C") u >i --' z: '" . .... 0 ,:r: z "' > -, :.:S LULU I- I- ~-') ;:0,0- .... :~ a: I"., ~ ('~ :::J '" () CJ 0 '" ~ . . . . ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROYDEN A. MERCADO and NANCY T. MERCADO, Plaintiffs Civil Action - Law vs. No. 2000-1199 STEVEN D. GRASLEY, SR. and TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw the appearance of Robert A. Lerman, Esquire and Thomas B. Sponaugle, Esquire, as attorneys for Defendant, Steven D. Grasley, Sr., in the above-captioned matter and mark the docket accordingly. BY: ~J _ obert A. Lerman, Esquire Superior Court ID No. 07490 BY~ Thomas B. S gle, Esquire Supreme Court LD. No. 64584 110 South Northern Way York, PA 17402 Telephone: (717) 757-7602 Attorney for Defendant, Steven D. Grasley, Sr. " T--C, ..-0',-".1'"'7'+,,".'""""'-' - ., ,."",.- ",..,-,.- ,- .. d.[t~;j,lf~~,,'~; :t!f'l~ PRAECIPE FOR ENTRY OF APPEARANCE PURSUANT TO Pa.R.C.P. 1012 TO THE PROTHONOTARY: Kindly enter the appearance of C. Kent Price, Esquire of Thomas, Thomas & Hafer as attorney for the Defendant, Steven D. Grasley, Sr., in the above-captioned matter and mark the docket accordingly. THOMAS, THOMAS & HAFER, LLP Dated: '1 lab 100 BY: (1 ~~.;b ~ C. Kent Price, Esquire Superior Court ID No.: 305 North Front Street Harrisburg, PA 17101 Telephone: (717) 255-7632 Attorney for the Defendant, Steven D. Grasley, Sf. ;i" ~ '_I'~ ~ 1','~,"'-' ." " ,-.' - - ~, 0:.:; c.,J ~~ '~i~ ]2 'V"-:-7 ..1Jw ~~CL 5 o r~' -~j " ',~ (L-- ;--' --; " '.:) C) CJ , !. ~ ~ 0- -0 ~ w w on ~ a: 0 0- .. Ul m EO ~ ... 0- m gO ~ z m 0 :;.. a: " c>' I:> ... 0 a: ~ ~ r on :> E 0- 6 on a: Ul ~ 0 " ;;: .. ~ z a: Ul " I;j 0 r E '" I:> , ~ . . ROYDEN A. MERCADO and NANCY T. MERCADO, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-1199 CIVIL TERM STEVEN D. GRAS LEY , SR., and TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED NOTICE To the Plaintiff: You are hereby notified to plead to the enclosed Preliminary Objection within twenty (20) days from service thereof or a default judgment may be entered against you. ADDAMS & RUNDLE By: ~~ Willi m A. Addams Supreme Court I.D. No. 06265 28 South pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 Attorneys for Defendant Terry Jay Rosenberry ''''''' , 'l'~'-~- __e . ROYDEN A. MERCADO and NANCY T. MERCADO, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-1199 CIVIL TERM STEVEN D. GRASLEY, SR., and TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED PRELIMINARY OBJECTION AND NOW, comes the Defendant, Terry Jay Rosenberry, by his attorneys, Addams & Rundle, and in accordance with Pa. R.C.P. 1028 files a preliminary objection in the nature of a motion to strike, and in support thereof asserts the following: 1. In this action arising out of an automobile accident, the Plaintiffs allege that Defendant Rosenberry's negligence consisted of his: a. Failure to keep his automobile under proper control; b. Failure to yield the right of way to the plaintiff; c. Failure to warn the plaintiff of the collision; d. Traveling in excess of the speed limit; e. Traveling in excess of a safe speed for the traffic and for the conditions of the highway; and f. operating in a careless and reckless manner. 2. The complaint in Paragraph 7f, "Operating in a careless and reckless manner," does not put the defendant on notice of the material facts on which the cause of action is based and is in violation of Pa. R.C.P. 1019(a). 3. In accordance with Connor v. Alleqhenv General Hospital, 501 Pa. 306, 461 A.2d 600 (1983), this vague, ambiguous and general allegation of negligence should be stricken. -J,~ - '-,+, .' ,~- - WHEREFORE, Defendant Terry Jay Rosenberry requests your Honorable Court to strike Paragraph 7f of the complaint. ADDAMS & RUNDLE By: William A. Addams Supreme Court I.D. No. 06265 28 South Pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 Attorneys for Defendant Terry Jay Rosenberry 1,-- ,--,- CERTIFICATE OF SERVICE AND NOW, this 31st day of July, 2000 I, Mary M. Price, hereby certify that I have served a copy of the Preliminary Objection by mailing a copy of the same by United States mail, postage prepaid, addressed as follows: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 C. Kent Price, Thomas, Thomas P.O. Box 999 Harrisburg, PA Esquire & Hafer 17108 ~) it O~ -~ 1_ "'~, . ~tri!~~~lltl1>i"~ -"';ii'b\!U;;,<<~~, <.iJ;~,~2<""Wlcl;h,^'1>'," '-l:ilalli.IM ' _'AllUM +1 ~~ ., ~i ::::","lH'f ',i ~i JUt ~; :-- " c~" )j ,,1' ,) (, "I"'" ry,: [','frY ....l.... './'""'~: v"..'... " PENNSYLYA[,~l.A - PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and subnitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter far the next Argunent Court. --------------------------------------------------------------------------------------- CAPTION OF CASE (entire caption must be stated in full) ROYDEN A. MERCADO and NANCY T. MERCADO, (Plaintiff) ~ 0 ~ 0 E: .';J J-'i1- -0 to r."1c mrn CO) -(1m :Z::D I :zc :.D'b CP () ~?~. ':-=::i"'""\"i .? ,<:0 ~ ts:!J "Z8 ~~ - is - :P'C - "" ~ U1 ~ r-:> vs. STEVEN D. GRASLEY, SR. and TERRY JAY ROSENBERRY ( Defendant) No. 1199 Civil lHi 2000 1. State matter to be argued (Le., plaintiff's lII:ltion for new trial. defendant's demurrer to canplaint. etc.): Preliminary Objection of Defendant Terry Jay Rosenberry 2. Identify =unse1 who will argue case: (al far plaintiff: Marcus A.McKnight,III, Esq. ~s: 60 West Pomfret Street, Carlisle, PA 17013 (bl for defendant: William A. Addams, Esquire ~s: 28 South Pitt Street, Carlisle, PA 17013 (c) for Defendant Grasley, Sr., - C. Kent Price, Esq. P.O. Box 999 Harrisburg, PA 17108 3. I will notify all parties in writing within hie days that this case has been listed for argurent. 4. ArgI.r1Ent Court Date: August 30, 2000 Dated: August 8, 2000 BY:~~ Atto far Def~ndant Rosenberry ~I " , ,,"- ROYDEN A. MERCADO and NANCY T. MERCADO, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-1199 CIVIL TERM STEVEN D. GRAS LEY , SR., and TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED ANSWER AND NOW, comes the Defendant, Terry Jay Rosenberry, by his attorneys, Addams & Rundle, and makes the following answer to the Plaintiffs' complaint: 1-5. Admitted. COUNT I PLAINTIFFS v. TERRY JAY ROSENBERRY 6. The answers to Paragraphs 1-5 are incorporated herein by reference. 7. The allegations in Paragraph 7a-e are denied in accordance Pa. R.C.P. 1029(e). Paragraph 7f has been withdrawn by stipulation of counsel. 8. The conclusion of law is denied. 9. After reasonable investigation, the Defendant is without knowledge sufficient to form a belief as to the truth of the averment. The same is therefore denied. 10. After reasonable investigation, the Defendant is without knowledge sufficient to form a belief as to the truth of the averments regarding the Plaintiff's injuries and damages. The same are therefore denied. ,~~ .-~~'~ _"T - 11. The answer to Paragraph 10 is incorporated herein by reference. 12. The answer to Paragraph 10 is incorporated herein by reference. WHEREFORE, the Defendant requests Count I be dismissed. COUNT II PLAINTIFFS v. STEVE D. GRASLEY, SR. 13-20. The allegations of Paragraphs 13-20 are not applicable to Defendant Rosenberry. WHEREFORE, the Defendant requests the complaint be dismissed. ADDAMS & RUNDLE By: ~~ Willi' . Addams Supreme Court I.D. No. 06265 28 South Pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 Attorneys for Defendant Terry Jay Rosenberry "" r 'T~.' .., ." VERIFICATION Terry Jay Rosenberry hereby verifies that the facts set forth in the foregoing Answer are true and correct to the best of his knowledge, information and belief, and understands that false statements herein are made subject to the penalties of 18 Pa. C.S. !;4904 relating to unsworn falsifications. f",??J W"C7 DATE: 8/Sq/tTO '-<>_;!\Io..... I - ",' UiliL -: ,'.~ liIiIil;:~~!j<J~~ ]li.ln': -il\i~'ililMIiI!~OOi;~i_ ~, ~.. -..;.;0, ,"" ,_. I~":C;P -\ \",d '~"" ' - ";;:-{ I ~, ~I!iji (':: "-~I~;: :':}i./\Sy '''''11' '-I ,t.\!, ~ '. ) ~+ ',', ',"',' ',-I\y ('I \1.\.i,LJ:~,'\i i'J \)...)!..-1l.1 vV 'I~,,.,-, ..- ' PENNSYLVi\NiA . ~ ,- ~< "d " . ": ROYDEN A. MERCADO and : IN THE COURT OF COMMON PLEAS OF NANCY T. MERCADO, his wife, PLAINTIFFS : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW STEVEN D. GRASLEY, SR. and 2000-1199 CIVIL TERM TERRY JAY ROSENBERRY, DEFENDANTS JURY TRIAL DEMANDED NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint, order and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 Americans with Disabilities Act of 1990 The Court of Common Pleas of Dauphin County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. 1 ~- <-- ROYDEN A. MERCADO and : INTHE COURT OF COMMON PLEAS OF NANCYT.MERCADO,mswU~ PLAINTIFFS : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW STEVEN D. GRASLEY, SR. and 2000-1199 CIVIL TERM TERRY JAY ROSENBERRY, DEFENDANTS JURY TRIAL DEMANDED AMENDED COMPLAINT AND NOW, this 18th day of September 2000, comes the plaintiffs, Royden A. Mercado and Nancy T. Mercado, his wife, by their attorneys, Irwin, McKnight & Hughes, and makes the following Complaint against the defendants, Steven D. Grasley, Sr. and Terry Jay Rosenberry, as follows: 1. The plaintiffs are Royden A. Mercado and Nancy T. Mercado, his wife, adult individuals residing at 212 Garland Drive, Carlisle, Pennsylvania 17013. 2. The defendant is Steven D. Grasley, Sr., an adult individual residing at 1595 Lindsey Lot Road, Shippensburg, Pennsylvania 17257. 3. The defendant is Terry Jay Rosenberry, an adult individual residing at P. O. Box 197, Newburg, Pennsylvania 17240. 2 "'''':-':'." .-""," ..~-.~,"_-->_", _.~__,_,_,~ '~_^_ '\'_, ,,,_,,,,_<\- _ .'<'d,", ~_/_'_ ,,~.__"",~., .,. , .-,-, -- ,.~ ,~,-, .,,~~, " -',- " 4. The plaintiff, Royden A. Mercado, was operating a 1995 Blazer automobile eastbound on Walnut Bottom Road in Shippensburg Township, Cumberland County, on March 5, 1998, at 3:18 p.m. 5. As the plaintiff, Royden A. Mercado, neared the entrance of the Kmart shopping center, a vehicle operated by defendant, Terry Jay Rosenberry, entered his lane of travel and a collision occurred. COUNT I ROYDEN A. MERCADO AND NANCY T. MERCADO v. TERRY JAY ROSENBERRY 6. The averments off act contained in paragraphs one (1) through five (5) of this Complaint are hereby incorporated by reference and made a part of this Count. 7. The cause of the collision was the negligence of the defendant, Terry Jay Rosenberry, which consisted of the following: a. Failure to keep his automobile under proper control; b. Failure to yield the right of way to the plaintiff; c. Failure to warn the plaintiff of the collision; d. Traveling in excess of the speed limit; and e. Traveling in excess of a safe speed for the traffic and for the conditions of the highway. 3 " :f., ""'",;'." "~,_;- , .,~~ . --/' ~. "","-~"' -," ,-__,",' "T~ 8. The negligence of the defendant as specified above was the proximate cause of the collision. He is jointly and severally liable for the collision and the damages sustained by the plaintiff, Royden A. Mercado. i i I I L , I I I I 9. Another vehicle was involved in the accident which driver was operating his vehicle while under the influence of alcohol. Limited tort does not apply in this case. 10. The plaintiff, Royden A. Mercado, also sustained serious personal injuries to his face and head. The plaintiff still suffers from headaches and neck pain due to the injuries. II. The plaintiff, Royden A. Mercado, seeks payment of his damages for pain and suffering as well as his unpaid lost wages and future damages for pain and suffering. 12. The plaintiff, Nancy T. Mercado, was married to Royden A. Mercado at the time of the collision. She suffered the loss of comfort and society of her husband as a direct consequence of the actions of the defendant, Terry Jay Rosenberry. WHEREFORE, the plaintiffs, Royden A. Mercado and Nancy T. Mercado, his wife, request damages less than Twenty-Five Thollsand and no/lOO ($25,000.00) against the defendant, Terry Jay Rosenberry, plus costs and interest as provided by law. 4 , "r '-'-'~-":'"~~'O'f"",~"" - _'O'_~=_ .",. '-.~--o>:,' ._ "~"'___",. ,,__~.~...e_,. , ",' - ., - ~. -,. " '-~ -- -t-!.:_~' /l' COUNT II ROYDEN A. MERCADO AND NANCY T. MERCADO v. STEVEN D. GRASLEY. SR. 13. The averments of fact contained in paragraphs one (1) through twelve (12) of this Complaint are hereby incorporated by reference and made a part of this Count. 14. At the time of the collision, the defendant, Steven D. Grasley, Sr., was operating a 1987 Chevrolet Astro Van while under the influence of alcohol. 15. The defendant, Steven D. Grasley, Sr., did strike the rear of the vehicle operated by Terry Jay Rosenberry which forced him into the lane of travel of the plaintiff, Royden A. Mercado. 16. The cause of the collision was the negligence of the defendant, Steven D. Grasley, Sr., which consisted of the following: a. Failute to keep his automobile under proper control; b. Failute to pay proper attention to the traffic ahead; c. Failute to warn the plaintiff of the collision; d. Traveling in excess of the speed limit; e. Traveling in excess of a safe speed for the traffic and for the conditions of the highway; and f. Operating his vehicle while under the influence of alcohol. 5 ,',.,. " , "'-'--:~. "" :'. ,- - ~', - r<_'__ ,,,",.,, ,,__.,.,~. ',";:""" W, ,-< I "._~ '" "',"i"" 17. The negligence of the defendant as specified above was the proximate cause of the collision. He is jointly and severally liable for the collision and damages sustained by the plaintiff, Royden A. Mercado. 18. The plaintiff also sustained serious personal injuries to his face and head. The plaintiff still suffers from headaches and neck pain due to the injuries. 19. The plaintiff, Royden A. Mercado, seeks payment of his damages for pain and suffering as well as payment of his lost wages and future damages for pain and suffering. 20. The plaintiff, Nancy T. Mercado, was married to Royden A. Mercado at the time of the collision. She suffered the loss of comfort and society of her husband as a direct consequence of the actions of the defendant, Terry Jay Rosenberry. , , , I i I I I I , I I I I r,il' 6 - " ~.>c(~",,,,","'.'f"'_"'( --,," ,,'-'."~ ,",--"""". ' ',." _." '.'r'. ,T"''-- '.'" " , ~_ -~ ''0' ,- , " '>"~;' ;.~.' ,.~',~ \i,'}:_, WHEREFORE, the plaintiffs, Royden A. Mercado and Nancy T. Mercado, his wife, request damages less than Twenty Five Thousand and no/IOO ($25,000.00) against the defendant, Steven D. Grasley, Sr., plus costs and interest as provided by law. Respectfully submitted, IRWIN, MCKNIGHT & HUGHES Marc A. 60 West Po Carlisle, P (717) 249-2 Supreme Court I. . Attorney for plaintiffs, Royden A. Mercado and Nancy T. Mercado, his wife By: Date: September 18, 2000 7 ~ .- - -', -:-"~,,_,, ,','3;,--m,>;"_-,_,:"_,__^_~,, ~"-'~'h' ~,.- _,,_>,~~ ",l,,,~,,='."'W'T"<" "_~'~""'~'" ' _" ~ . ,,~~," ,- -,~ , VERIFICATION The foregoing Amended Complaint is based upon information which has been gathered by counsel and us in the preparation of this action. We have read the statements made in this document and they are true and correct to the best of our knowledge, information and belief. We understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. <"""-,Ii ~ ~t~ NANC T. MERCADO 1//rjdlJ . I Date: ;..,.,. - -, -" ~I - - "~""'~'~-__'_,A" ".-,,""""'_, __,,~,,< 'V." ^<- ,'-.-, ~_. ~_~''''_''~''__'''''"~ ,~',"" __~" , ._,. ,> " -. . ,~ > -" '<. "'. ~-"",,- ROYDEN A. MERCADO and : IN THE COURT OF COMMON PLEAS OF NANCY T. MERCADO, his wife, PLAINTIFFS : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW STEVEN D. GRASLEY, SR. and 2000-1199 CIVIL TERM TERRY JAY ROSENBERRY, DEFENDANTS JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Amended Complaint was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: William A. Addams, Esquire ADDAMS & RUNDLE 28 South Pitt Street P. O. Box 208 Carlisle, PA 17013 Attorney for defendant, Terry Jay Rosenberry C. Kent Price, Esquire Thomas, Thomas & Hafer LLP 305 North Front Street, Sixth Floor P. O. Box 999 Harrisburg, PA 17108 Attorney for defendant, Steven D. Grasley, Sr. By: Marc A. 60 West Po t Street Carlisle, P A 17013 (717) 249-2353 Supreme Court J.D. No. 25476 Date: September 19.2000 8 f" " .,. --I' , ~~, _ '''',;C>',r-4''i-,,~_'"___,_, . "_~_"" ~.,. . .. _, . ~, '"' ,,_"'4'" "" "0'" ,~, ' ' ft_ _ _ ..c-' - Co", ._",." ,,~,~~ _ - ., """ ,~" . . ., _, 'r'. ROYDEN A. MERCADO and NANCY T. MERCADO, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-1199 CIVIL TERM STEVEN D. GRAS LEY , SR., and TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED ANSWER TO AMENDED COMPLAINT AND NOW, comes the Defendant, Terry Jay Rosenberry, by his attorneys, Addams & Rundle, and makes the following answer to the Plaintiffs' amended complaint: 1-5. Admitted. COUNT I PLAINTIFFS v. TERRY JAY ROSENBERRY 6. The answers to Paragraphs 1-5 are incorporated herein by reference. 7. The allegations in Paragraph 7a-e are denied in accordance Pa. R.C.P. 1029(e). 8. The conclusion of law is denied. 9. After reasonable investigation, the Defendant is without knowledge sufficient to form a belief as to the truth of the averment. The same is therefore denied. 10. After reasonable investigation, the Defendant is without knowledge sufficient to form a belief as to the truth of the averments regarding the Plaintiff's injuries and damages. The same are therefore denied. 11. The answer to Paragraph 10 is incorporated herein by reference. _~4'lIh"':""" . 12. The answer to Paragraph 10 is incorporated herein by reference. WHEREFORE, the Defendant requests Count I be dismissed. COUNT II PLAINTIFFS v. STEVE D. GRAS LEY , SR. 13-20. The allegations of Paragraphs 13-20 are not applicable to Defendant Rosenberry. WHEREFORE, the Defendant requests the amended complaint be dismissed. ADDAMS & RUNDLE By: .~~~ William A. Addams Supreme Court I.D. No. 06265 28 South Pitt Street P.O. Box 208 Carlisle, PA 17013 (717) 249-8300 Attorneys for Defendant Terry Jay Rosenberry ;;,....-.,....,.... ~ -, , CERTIFICATE OF SERVICE AND NOW, this 20th day of September, 2000 I, Mary M. Price, hereby certify that I have served a copy of the Answer to Amended Complaint by mailing a copy of the same by United States mail, postage prepaid, addressed as follows: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 C. Kent Price, Thomas, Thomas P.O. Box 999 Harrisburg, PA Esquire & Hafer 17108 ~ttO~ ',~,,,,,,,,_\4"" T .w" ,~ ~$IliJf*ihiililIMltiiMI,wili/lil~~I!MSii~""'..11!ll.\:M;~~","""'Lh."",oi%l<lii!~~'LHI.-< "~ "' >' ~ -& (r'i: ~ l' n'~" Fit. re,! '.()j:'F1CE C-F "-":!'~Cl'lOTARY r<.... S"''rj 'I t., UiJ t.1 t.'::: Pi1 2: 06 CUrvIBUiLN~D COUN1Y PENNSYLv'llNIA ,I; v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2000-1199 CIVIL TERM JURY TRIAL DEMANDED ROYDEN A. MERCADO and NANCY T. MERCADO, his wife, Plaintiffs STEVEN D. GRASLEY,SR. and : TERRY JAY ROSENBERRY, Defendants CERTIFICATE OF PREREQUISITE TO SERVE A SUBPOENA PURSUANT TO RULE 4009.22 As a Prerequisite to service of a Subpoena for Documents and Things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve the Subpoena with a copy of the Subpoena attached thereto was mailed to each party at least twenty (20) days prior to the date on which the Subpoena is sought to be served. 2. A copy of the Notice of Intent including the proposed Subpoena is attached to this Certificate. 3. No objection to the Subpoena has been received. 4. The Subpoena which will be served is identical to the Subpoena which is attached to the Notice of Intent THOMAS, THOMAS & HAFER, LLP C-~~ C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 I.D. No. 06776 ATTORNEYS FOR DEFENDANT STEVEN D. GRASLEY, SR. , ~~", "< / "~<. .' ,,_ . <.r";" - "-'..^~-' ,~____< ',_.".'",,^'-' ,_<_,.",,,. .",o.~,,,"~',_, ROYDEN A. MERCADO and NANCY T. MERCADO, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. 2000-1199 CIVIL TERM STEVEN D. GRASLEY, SR. and TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Counsel of Record Defendant intends to serve a Subpoena identical to the one attached to this Notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the Subpoena. If no objection is made, the Subpoena may be served. THOMAS, THOMAS & HAFER, LLP ij !1 11 i' i! ii iJ iJ " ,I) :1 C--~ C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 1.0. No. 06776 ATTORNEYS FOR DEFENDANT STEVEN D. GRASLEY, SR. :1 I ;:i :.1 " i i :i ,I 1'1 1 !I '-I DATE: January 2,2001 i;! . ,~- ~~ > . ~. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROYDEN A. MERCADO and NANCY T. MERCADO, Plaintiffs IN THE COURT OF COMMON PLEAS CIVIL ACTION - LAW v. NO. 2000-1199 STEVEN D. GRAS LEY, SR. and TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: State Farm Insurance Company (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: A complete COpy of the first-party claim file for your insured, Rov A. Mercado. Policv No. 6072-833-38F. Claim No. 38-1662-290. arisina out of an accident on March 5 or 6, 1998, includina but not limited to applications for benefits. waae loss verifications, summaries of benefits paid. medical records and reports, bills submitted. independent medical examination reports, peer reviews, peer review reconsiderations. correspondence, and policv declaration paae showina coveraaes and tort option election. at: Thomas. Thomas & Hafer. LLP, 305 N. Front Street. Harrisbura. PA 17101 (Addressl You may deliver CJr mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: C. Kent Price, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7632 SUPREME COURT ID#: 06776 ATTORNEY FOR: Defendant DA TE: f).!/' cJ9 c7CCeJ Seal of the Court BY THE COURT: /5i d- . ~ Prothonotary/Clerk. Ci De~'cL k.):;!k 9-7 (4/97) I "~~ CERTIFICATE OF SERVICE AND NOW, this 2nd day of January, 2001, I, C. KENT PRICE, ESQUIRE, for the firm of THOMAS, THOMAS & HAFER, LLP, attorneys for Defendant Steven D. Grasley, Sr., hereby certify that I have this day served the within Notice of Intent to Serve a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 William A. Addams, Esquire ADDAMS & RUNDLE 28 South Pitt Street Carlisle, PA 17013 THOMAS, THOMAS & HAFER, LLP C-~~ C. Kent Price, Esquire " i.: i~'~ ,~ ",- CERTIFICATE OF SERVICE AND NOW, this Z S~ay of January, 2001, I, C. KENT PRICE, ESQUIRE, for the firm of THOMAS, THOMAS & HAFER, LLP, attorneys for Defendant Steven D. Grasley, Sr., hereby certify that I have this day served the within Certificate of Prerequisite to Serve a Subpoena Pursuant to Rule 4009.22 by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 William A. Addams, Esquire ADDAMS & RUNDLE 28 South Pitt Street Carlisle, PA 17013 THOMAS, THOMAS & HAFER, LLP r_~~ C. Kent Price, Esquire I~i'- - . ~-_J-"''''_ -, -- " , -,-_----~,- .-",.. ""_~'"'" ?0"""' .'.';0" - " "-".' >.,'.h" c _ ,-- "'c",,,,,, 'nM"_ ' ~~ UJliI!!!! . ~-. ^~ <:) Ci 0 c: ~, """",,' :c_ -rJ tx; ~ ~r:r mrn :-:r-: Z:1J N =::-;~3 zc ~;~ 0') -'-, . ::~{S:J r:::-........i ~.t,l ,'- " );: :~ ~i~ zC) ~o w 0 c: :;;:j z C> ~. Co &'" =< "..1'- 'J- ., ROYDEN A. MERCADO and NANCY T. MERCADO, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. 2000-1199 CIVIL TERM STEVEN D. GRASLEY, SR. and TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED CERTIFICATE OF PREREQUISITE TO SERVE SUBPOENAS PURSUANT TO RULE 4009.22 As a Prerequisite to service of Subpoenas for Documents and Things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve Subpoenas with copies of the Subpoenas attached thereto was mailed to each party at least twenty (20) days prior to the date on which the Subpoenas are sought to be served. 2. A copy of the Notice of Intent including the proposed Subpoenas are attached to this Certificate. 3. No objection to the Subpoenas has been received. 4. The Subpoenas which will be served are identical to the Subpoenas which are attached to the Notice of Intent II I, ii ::j I" i1 ':] i,_ :1 i1 ) II ii [1 !j f? THOMAS, THOMAS & HAFER, LLP 0-0)~ C. Kent Price, Esquire 305 North Front Street P.O, Box 999 Harrisburg, PA 17108 (717) 255-7632 I.D. No. 06776 ATTORNEYS FOR DEFENDANT STEVEN D. GRASLEY, SR. "".__,""".'O,,_.er; S-' q ., " - ' " . -1- . .. . ~ ,~~_"- it ;1 ,I , ,[ ;1 II :1 -', !'"'~.... ROYDEN A. MERCADO and NANCY T. MERCADO, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2000-1199 CIVIL TERM v. STEVEN D. GRASLEY, SR. and : TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Counsel of Record Defendant intends to serve Subpoenas identical to the ones attached to this Notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the Subpoenas. If no objection is made, the Subpoenas may be served. THOMAS, THOMAS & HAFER, LLP ~~\~ C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 I.D. No. 06776 ATTORNEYS FOR DEFENDANT STEVEN D. GRASLEY, SR. DATE: June 4,2001 - ---.~ , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND v. IN THE COURT OF COMMON PLEAS CIVIL ACTION - LAW NO. 2000-1199 ROYDEN A. MERCADO and NANCY T. MERCADO, Plaintiffs STEVEN D. GRASLEY, SR. and TERRY JAY ROSENBERRY, Defendants : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Inaersoll-Rand Co. (Name of Person or Entityl Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: A comolete COOy of the emoloyment/oersonnel file for RoYden A. Mercado. includina but not limited to emoloyment evaluations. oerformance records. attendance records. medical records. oayroll records and Worker's Comoensation records for the oeriod from Januarv 1. 1998 to the oresent date. at: Thomas. Thomas & Hafer. LLP. 305 N. Front Street. Harrisbura. PA 17101 (Addressl You ma~ deliver or mall legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the addressnsted above. You have the right to seek In advance, the reasonable cost of preparing the copies or producing the things sought . If you fall to produce the documents Dr things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: C. Kent Price, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7632 SUPREME COURT ID#: 06776 ATTORNEY FOR: Defendant --- DATE: m:::J;(. )0 .:lr.,..." Seal of the Court ' "" ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND v. IN THE COURT OF COMMON PLEAS CIVIL ACTION - LAW NO. 2000-1199 ROYDEN A. MERCADO and NANCY T. MERCADO, Plaintiffs STEVEN D. GRASLEY, SR. and TERRY JAY ROSENBERRY, Defendants : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURsuANT TO RULE 4009.22 TO: Jav A. Townsend. M.D. (Name of Person or Enlityl .'; 'i t] i'l Within twenly (20) days after service of this subpoena, you are ordered by Ihe court to produce Ihe following documents or things: A comolete coov of all records oertainina to Rovden A. Mercado. includina but not limited to notes of office visits. records of other health care oroviders. hosoital records. reoorts of diaanostic studies and bills, for the oeriod from March 1. 1998 to the present date. at: Thomas. Thomas & Hafer. LLP. 305 N. Front Street. Harrisbura. PA 17101 (Addressl You may deliver or mall legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, 10 Ihe party making this requesl althe address listed above. You have the righllo sael< In advance,the reasonable cosl of preparing the copies or producing the things soughl If you fall 10 produce the documents or things required by this subpoena, within twenly (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with It fi :'i ;1 ~1 THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: C. Kent Price, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7632 SUPREME COURT 10#: 06776 ATTORNEY FOR: Defendant ............ DA TE:fi a*, J 0 .::l ^'" , Seal of e Cou'rt CERTIFICATE OF SERVICE AND NOW, this 4- ~ day of June, 2001, I, C. KENT PRICE, ESQUIRE, for the firm of THOMAS, THOMAS & HAFER, LLP, attomeys for Defendant Steven D. Grasley, Sr., hereby certify that I have this day served the within Notice of Intent to Serve a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 THOMAS, THOMAS & HAFER, LLP 0-~)~ C. Kent Price, Esquire .;, ,~~ - r" , ".> CERTIFICATE OF SERVICE AND NOW, this 31st day of July, 2001, I, C. KENT PRICE, ESQUIRE, for the firm of THOMAS, THOMAS & HAFER, LLP, attorneys for Defendant Steven D. Grasley, Sr., hereby certify that I have this day served the within Certificate of Prerequisite to Serve Subpoenas Pursuant to Rule 4009.22 by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 THOMAS, THOMAS & HAFER, LLP C--~~ C. Kent Price, Esquire 't-' ~'" r ~ '.",q,'-F,,,"." -, " '1_, _ _. "'~'_ _ ,_., _ e -j-' i ""IlIII!IIIIII. , , >~ - '- _c-_~_~, ~~ , - (") C> C ;;: :0- -OeD ~ "ln1 G5 'l Z:u -.-- :ZC' I ..,"_,:",'1 ~z ~_;'~C.J ~CJ ~ -:~; {":-.} -v '"""1, ~(") :1:. ;;~?5 -0 )>c C),Tl :z ---1" U1 )> =< ~ ...J -< ~~ , ~~""! ROYDEN A. MERCADO and NANCY T. MERCADO, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. 2000-1199 CIVIL TERM STEVEN D. GRASLEY, SR. and : TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED CERTIFICATE OF PREREQUISITE TO SERVE SUBPOENAS PURSUANT TO RULE 4009.22 As a Prerequisite to serVice of Subpoenas for Documents and Things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve Subpoenas with copies of the Subpoenas attached thereto was mailed to each party at least twenty (20) days prior to the date on which the Subpoenas are sought to be served. 2. A copy of the Notice of Intent including the proposed Subpoenas are attached to this Certificate. 3. No objection to the Subpoenas has been received. 4. The Subpoenas which will be served are identical to the Subpoenas which are attached to the Notice of Intent THOMAS, THOMAS & HAFER, LLP c.-~~ C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 I.D. No. 06776 ATTORNEYS FOR DEFENDANT STEVEN D. GRASLEY, SR. I, ~ c- , '. ',,~ . ,,_.___,,0.' -," .;". --~< "",", -- .0."" -'r ,_ '~,_ . ,"-"'-' . , '-, ..'~' v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2000-1199 CIVIL TERM JURY TRIAL DEMANDED ROYDEN A. MERCADO and NANCY T. MERCADO, his wife, Plaintiffs STEVEN D. GRASLEY, SR. and : TERRY JAY ROSENBERRY, Defendants NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Counsel of Record Defendant intends to serve Subpoenas identical to the ones attached to this Notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the Subpoenas. If no objection is made, the Subpoenas may be served. THOMAS, THOMAS & HAFER, LLP C. Kent Price, Esquire 305 North Front Street P.O. Box 999 Harrisburg, PA 17108 (717) 255-7632 LD. No. 06776 ATTORNEYS FOR DEFENDANT STEVEN D. GRASLEY, SR. DATE: March 14,2002 I., _~'"~I - ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROYDEN A. MERCADO and NANCY T. MERCADO, Plaintiffs IN THE COURT OF COMMON PLEAS CIVIL ACTION - LAW v. NO. 2000-1199 STEVEN D. GRASLEY, SR. and TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: State Farm Insurance Company (Name of Person or Entityl Within twenty (20) days after service ofthis subpoena, you are ordered by the court to produce the following documents or things: A complete copy of the first-party claim file forvour insured, Roy A. Mercado, Policv No. 6072-833-38F. Claim No. 38-1662-290. arisino out of an accident on March 5 or 6. 1998. includino but not limited to applications for benefits. waoe loss verifications, summaries of benefits paid. medical records and reports, bills submitted. independent medical examination reports. peer reviews. peer review reconsiderations, correspondence. and policv declaration oao.e showino coveraoes and tort option election from January 25. 2001 to the present. at: Thomas. Thomas & Hafer. LLP. 305 N. Front Street. Harrisburo. PA 17101 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost 01 preparing the copies or producing the things sought. If you fail to produca the documents or things required by this subpoena, within twenty (20) days after fis service, the perty serving this sUbpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: C. Kent Price, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7632 SUPREME COURT 10#: 06776 ATTORNEY FOR: Defendant DATE: (Y(-::llJrL I:> ;:;uY>"-. Seal of the Court ' '-........ Prothonotary/Clerk, Civil sion 7?rflA'A'''n' J (4/97) ~~<<-v Deputy .,~ , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROYDEN A. MERCADO and NANCY T. MERCADO, Plaintiffs IN THE COURT OF COMMON PLEAS CIVIL ACTION - LAW v. NO. 2000-1199 STEVEN D. GRASLEY, SR and TERRY JAY ROSENBERRY, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THING~ FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Herman Chiropractic (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: A complete copy of all records pertainino to ROYden A. Mercado. includino but not limited to notes of office visits, records of other health care providers. hospital records, reports of diaonostic studies and bills. for the period from March 1. 1998 to the present date. at: Thomas. Thomas & Hafer. llP. 305 N. Front Street. Harrisburo. PA 17101 (Addressl You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. Vou have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOllOWING PERSON: NAME: C. Kent Price, Esquire ADDRESS: _P.D. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7632 SUPREME COURT 10#: 06776 ATTORNEY FOR: Defendant DATE: fl7J)/Lrl... t:) ~rY,~ Seal of the Court' Prothonotary/Clerk, CiVil Oi n '- D~Q,J -P ~l1hAtc-1 (4/97) CERTIFICATE OF SERVICE AND NOW, this Il.f~ay of March, 2002, I, C. KENT PRICE, ESQUIRE, for the firm of THOMAS, THOMAS & HAFER, LLP, attomeys for Defendant Steven D. Grasley, Sr., hereby certify that I have this day served the within Notice of Intent to Serve Subpoenas to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 THOMAS, THOMAS & HAFER, LLP (l~~ C. Kent Price, Esquire '-'~"~ ~~~ . CERTIFICATE OF SERVICE AND NOW, this J B~ay of April, 2002, I, C. KENT PRICE, ESQUIRE, for the firm of THOMAS, THOMAS & HAFER, LLP, attorneys for Defendant Steven D. Grasley, Sr., hereby certify that I have this day served the within Certificate of Prerequisite to Serve Subpoenas Pursuant to Rule 4009.22 by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013-3222 THOMAS, THOMAS & HAFER, LLP C-~~ C. Kent Price, Esquire r, '. ." ",' <e_._ _~ ~_~, - , . I - ::r- L e, 'e ,.~ .~--, ,.~ ~~[1'I!'~_ (') c ?;: vC"--) rn;-T' '7::T; 2.1...=' ~!) <: :~~-~,' ~;:~~: ~ Q {'",) ~ '"""t.1 ;:---0 (') -'1 "-.0 --C) T';:-;: ;:0-:"':' 'M '",0 .-1 v ROYDEN A. MERCADO and NANCY T. MERCADO, his wife Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-1199 CIVIL TERM STEVEN D. GRASLEY, SR., and TERRY JAY ROSENBERRY, Defendants CIVIL ACTION - LAW PRAECIPE TO SETTLE AND DISCONTINUE To Curtis R. Long, Prothonotary: Please mark the above-captioned case settled and discontinued and issue a Settlement Certificate to Marcus A. McKnight, ill, Esquire, at 60 West Pomfret Street, Carlisle, Pennsylvania 17013. Respectfully submitted, Date: July 17, 2002 [,."" ~,~_ r,",.- y. _., , ~ .".,' , ,. -,,-~ ... "_"~no"~ . '-'. ROYDEN A. MERCADO and NANCY T. MERCADO, his wife Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-1199 CIVIL TERM STEVEN D. GRASLEY, SR., and TERRY JAY ROSENBERRY, Defendants CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Marcus A. McKnight, ill, Esquire, hereby certify that a copy of attached Praecipe to Settle and Discontinue was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: C. Kent Price, Esquire Thomas, Thomas & Hafer, LLP 305 North Front Street, Sixth Floor P. O. Box 999 Harrisburg, PA 17108 By: Date: July 17, 2002 l~-~-, _ _ <_e~___~,,__,..___~_,,~_ _ ,,_~ " _ ,e'_ ~ :1 "'-"""'" 0 C> 0 C N -'n ~ <- ""Vi;:; ~ ?J mfT; Z:':f~: --,'"n Zs:: CD .~~~ U)~., -< ~,:: !::=C,:: -u ;E;c:, ~ (-) 5~ ~':;) Ci j-n :.,.) ;S~ =< -'. uJ -< ." ,,~