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Home My WebLink About00-01489 '~~"~ '0 .",,".~.I '! JOHN CHRISTOPHER AND ANDRONICKI CHRISTOPHER, HIS WIFE 137 Yellow Breeches Drive Camp Hill, PA 17011, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW JURY TRIAL DEMANDED -vs- QUIRlNO D'ANGELO 821 North Walnut Street Mechanicsburg, P A 17055, Defendant 00 - I'tPC; CVll 2000 - CIV. - ........................................................................................................................................... ............................................................................................................................................ NOTICE 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 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 notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. 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. COURT ADMINISTRATOR 4TH FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 PHONE: (717) - 240-6200 .-~~ ~,~ - JOHN CHRISTOPHER AND ANDRONICKI CHRISTOPHER, HIS WIFE 137 Yellow Breeches Drive Canlp Hill, PA 17011, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW JURY TRIAL DEMANDED -vs- QUIRINO D'ANGELO 821 North Walnut Street Mechanicsburg, P A 17055, Defendant 2000 - CIV. - 1'1 'j'CJ ........................................................................................................................................... ........................................................................................................................................... COMPLAINT i " i' , NOW, comes the Plaintiffs, John Christopher and Andronicki Christopher, his wife, by and through their Attorneys, Robert A. Mazzoni, Esquire, and William Costopoulos, Esquire, il and hereby files the above Action against the above-named Defendant in accordance with the following allegations: 1. At all times relevant hereto, the Plaintiffs, John Christopher and Andronicki Christopher, his wife, are and were adult, competent individuals, who reside at 137 Yellow Breeches Drive, Camp Hill, Pennsylvania 170 II. 2. At all times relevant hereto, the Defendant, Quirino D'Angelo, is and was an adult, competent individual, who resides at 821 North Walnut Street, Mechanicsburg, Pennsylvania 17055. -2- I'r ~~I "1~ , I: 3. At all times relevant hereto, but more specifically, on April 13, 1998, the Plaintiff, I John Christopher, was walking/jogging along West bound S.R. 2027, Gettysburg Road, in the Township of Lower Allen, County of Cumberland, and Commonwealth of Pennsylvania. 4. At all times relevant hereto, but more specifically, on April 13, 1998, the Defendant, Quirino D'Angelo, was operating a motor vehicle and was traveling West bound on S.R. 2027, Gettysburg Road, in the Township of Lower Allen, County of Cumberland, and Commonwealth of Pennsylvania. 5. At all times relevant hereto, but more specifically, on April 13, 1998, the Defendant, Quirino D'Angelo, struck the Plaintiff, pedestrian, John Christopher, with his vehicle, thereby causing serious and permanent injuries as described herein. 6. As a direct and foreseeable result of the negligence of the Defendant, Quirino D' Angelo, as described herein, the Plaintiff, John Christopher, was caused to suffer serious and permanent injuries, all of which include, but are not limited to the following: A. Post-concussion syndrome, which manifests itself in mood and anxiety changes, with corresponding depression, decreased attention and I I I concentration, and increased frustration and intolerance, and vulnerability to stress. B. Closed-head injury and post-concussive symptoms. C. Coccydynia with resulting residual myofacial pain in the cervical, upper thoracic, and lumbosacral areas. -3- ~}rjlf, _ _ ~ 'z. ",-,,"__, __"_ ~, ~- "irlij:l" )"^ ,["'. ~ ;1 D. Closed-head injury and subarachnoid hemorrhage. E. Right-sided parotid pain and swelling. F. Parotiditis. G. Multiple bruises and abrasions. 7. As a direct and foreseeable result of the negligence of the Defendant, Quirino D' Angelo, as described herein, the Plaintiff, John Christopher, was caused to suffer serious and permanent pain, suffering, embarrassment, and humiliation, and will continue to suffer same indefinitely into the future. 8. As a further result of the negligence of the Defendant, Quirino D'Angelo, as described herein, the Plaintiff, John Christopher, has been caused to incur expenses for medical services and will continue to incur medical expenses indefinitely into the future. 9. As a direct and foreseeable result ofthe negligence of the Defendant, Quirino D' Angelo, as described herein, the Plaintiff, John Christopher, was caused to sustain a loss of enjoyment of life and will continue to suffer and sustain said loss of enjoyment of life indefinitely into the future. 10. As a direct and foreseeable result of the negligence of the Defendant, Quirino D' Angelo, as described herein, the Plaintiff, John Christopher, was also caused to suffer and sustain a permanent and total disability, which will remain unresolved indefinitely into the future. -4- ,~~,-,- < COUNT ONE PLAINTIFF. JOHN CHRISTOPHER -VS- DEFENDANT. I OUlRINO D'ANGELO NEGLIGENCE 1 I. The Plaintiff, John Christopher, hereby incorporates Paragraphs One (I) through Ten (10) as if the same were fully set forth at length herein. 12. The Plaintiff, John Christopher, hereby maintains that the injuries and damages specified herein were the direct and foreseeable result of the negligence of the Defendant, Quirino D'Angelo, said negligence consisting of the following: A. Failure to yield the right-of-way to the Plaintiff, John Christopher. i i:1 B. Failure to keep a proper lookout. C. Failure to stop his vehicle within the clear distance ahead. D. Failure to obey the traffic signals and/or markings in the vicinity of the subject accident. E. Failure to warn the Plaintiff, John Christopher, of his approach. F. Failure to otherwise avoid the subject collision. G. Failure to otherwise prevent his vehicle from striking the Plaintiff, John Christopher. -5- .1 .~ 1- -}_~TI H. Failure to otherwise remove any obstructions in his view, or take the necessary measures to have the obstructions otherwise removed or abated. WHEREFORE, the Plaintiff, John Christopher, hereby demands Judgment against the Defendant, Quirino D'Angelo, in an amount in excess of Twenty-five Thousand ($25,000.00) Dollars, plus interest and costs. COUNT TWO PLAINTIFF. ANDRONICKI CHRISTOPHER -VS- DEFENDANT. OUlRINO D'ANGELO LOSS OF CONSORTIUM 13. The Plaintiff, Andronicki Christopher, hereby incorporates Paragraphs One (1) through Twelve (12), as if the same were fully set forth at length herein. 14. As a direct and foreseeable result of the aforesaid negligence of the Defendant, Quirino D'Angelo, and also as a direct and foreseeable result of the injuries sustained by the Plaintiff, John Christopher, the Plaintiff, Andronicki Christopher, has been deprived ofthe assistance, services, and society of her husband, John Christopher, and will continue to be so deprived indefinitely into the future to her great damage and loss. WHEREFORE, the Plaintiff, Andronicki Christopher, by and through her respective Attorneys, Robert A. Mazzoni, Esquire, and William Costopoulos, Esquire, hereby -6- , ,- -R. ~- -, 11 demands Judgment against the Defendant, Quirino D'Angelo, in an amount in excess of Twenty- i II five Thousand ($25,000.00) Dollars, plus interest and costs. ROBER . MAZZONI, ESQUIRE ATTORNEY FOR PLAINTIFFS, JOHN CHRISTOPHER AND ANDRONICKI CHRISTOPHER, HIS WIFE Suite 201 Bank Towers 321 Spruce Street Scranton, Pennsylvania 18503 Telephone - (570) - 348-0776 I I' t:du _ WILLIAM ~TOPOULOS, ESQUIRE ATTORNEY FOR PLAINTIFFS, JOHN CHRISTOPHER AND ANDRONICKI CHRISTOPHER, HIS WIFE 831 Market Street P. O. Box 222 Lemoyne, Pennsylvania 17043-0222 Telephone - (717) -761-2121 -7- --- :,"ift!~ '.' II AFFIDA VIT COMMONWEALTH OF PENNSYLVANIA: : SS. COUNTY OF LACKA W ANNA JOHN CHRISTOPHER AND ANDRONICKI CHRISTOPHER, HIS WIFE, being duly sworn according to law, depose and say that the facts set forth in the foregoing Complaint, are true and correct, to the best of their knowledge, information, and belief. io.v~ ~ ANDRONICKI CHRISTOPHER I I ,I Sworn to and subscribed before me, this G it day of 'YJ16...<..J..- ,2000. ~e~, . NOTARYPUBL NOTARIAL SEAl.: KAREN 7i.. PALUSZESKI, Notary PubU<< Scranton, LacUlwanna County Iii1rColnmlulllO Expir.......1\. 19, 2002 -8- (SEAL) (SEAL) - 7;?0 ft. f' t. ~ ~ ~ ~ ~ ~ ~ t h~ k1 0 ~ \J 9 ~ ~~ J p -'" ,,~ --0' rXJ mrn Z:IJ zc ~z r:CJ <: ;';;0 ~o .Pc ~ o o :!It "" ::>::J ~ ~:n 118 d6 ......:...t:~. I-H 0("). am ~ Q 'L JUllllJllll .^ ~ _ ~ . ,_..-_11 _UIlfl' , ....,~) . 0 ~,Il'~_ _" J~m~,~"~~j!;~~~~~J!Iil-.~<l~m~~~~[~_ ~! ~~ .c- ." :x: c:- .. '0 ..' .. JOHN CHRISTOPHER and ANDRONICKI CHRISTOPHER PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-1489 CIVIL ACTION - AT LAW QUIRINO D'ANGELO, DEFENDANT : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Quirino D'Angelo, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER Date: '7 hD( 0 (J By: cflA~~ ~~{~hew R. Gover, Esquire Attorney 1.0. #47593 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 -- -~, . "'-'1"-~~ - ""..",..-"~~~,,, ~..,- ,"--,','>>d-_'"'i,'-' ,,< ""', '-' "~- -,'-- :"'cr':_f_';",,: o""'j l-_~,---_--"'C,<--__ - "." ,,-- ,. _''',>'.". _;0__,_..._ _.,," - 0" .r ~ . CERTIFICATE OF SERVICE AND NOW, this 30th day of March, 2000, I hereby certify that I have served the foregoing Praecipe on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Robert A. Mazzoni, Esquire Suite 201 Bank Towers 321 Spruce Street Scranton, PA 18503 William Costopoulos, Esquire 831 Market Street P.O. Box 222 Lemoyne, PA 17043-0222 1fL~ I"'N" , . ;"',. ~,' "n' .,_<,. .;!?'"','_'_-'o_" ,-,. ',.>'c-'. .,,0-' ' - '-",^" - "<-," r- "-~'~" '.-" "., ,....... "', ,,' --',.-,.> SHERIFF'S RETURN - REGULAR Cl\.SE NO: 2000-01489 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHRISTOPHER JOHN ET AL VS D'ANGELO QUIRINO RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland county, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon D'ANGELO QUIRINO the DEFENDANT , at 0014:43 HOURS, on the 16th day of March , 2000 at 821 N. WALNUT ST MECHANICSBURG, PA 17055 by handing to QUIRINO D'ANGELO a true and attested copy of COMPLAINT & NOTICE together with and at the sa-me time directing His attention to the contents thereof. Sheriff's coets: Docketing Service l\.ffidavit Surcharge 18.00 6.20 .00 10.00 .00 34.20 So Answers: f?"'~~f R. Thomas Kline 03/21/2000 ROBERT A. MAZZO Sworn and Subscribed to before By: r:u me this "7- day of -.J~ J-HV A.D. ~ (; hut;,; ~ P othonotary , "'l'Jl'jlI'!'iiI - , ~I\ JOHN CHRISTOPHER and ANDRONICKI CHRISTOPHER PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-1489 : CIVIL ACTION - AT LAW QUIRINO D'ANGELO, DEFENDANT : JURY TRIAL DEMANDED NOTICE TO PLEAD TO: John Christopher and Andronicki Christopher, and their attorney, William Costopoulos, Esquire 831 Market Street P.O. Box 222 Lemoyne, PA 17043-0222 YOU ARE HEREBY NOTIFIED, that the Answer to Complaint set forth herein contains averments against you to which you are required to respond within twenty (20) days after service thereof. Failure by you to do so may constitute an admission. Respectfully submitted, NEALON & GOVER -1t!~)(J By: Matthew R. Gover, Esquire Attorney 1.0. #47593 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 Date: L{ /'7(oJ ;,,-- ". -~:,,~,f.',";,,-:-_.'t,'"._,,_", " ,-",-,_ ,,' - -,s-~" -~ ~-- .', ," ,. - ",'~r:~':\-_...I"" ',-'~',' ~-~ ,--, ",,-'- --,' . "''''''-'''''''-'' -<,', JOHN CHRISTOPHER and ANDRONICKI CHRISTOPHER PLAINTIFFS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-1489 : CIVIL ACTION - AT LAW QUIRINO D'ANGELO, DEFENDANT : JURY TRIAL DEMANDED ANSWER AND NOW, comes the Defendant, Quirino D'Angelo, by and through his attorneys, NEALON & GOVER, P.C., and files the following Answer: 1. -4. Admitted. 5. Denied pursuant to Pa.R.Civ.P. 1029(e). 6. -10. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted and proof is demanded at trial. COUNT ONE JOHN CHRISTOPHER V. QUIRINO D'ANGELO NEGLIGENCE 11. Paragraphs 1 through 10 of Defendant's Answer are incorporated herein by reference thereto. 12. Denied pursuant to Pa.R.Civ.P. 1029(e). I"..., " .- "--p.f;~~ : ~._~._v~.'"-' -.'_."~ - '-""_C:_"_'.' "~('q:_?'Y,:",_,:<<.' "". n_' --:~ ---,,-.,... COUNT TWO ANDRONICKI CHRISTOPHER V. QUIRINO D'ANGELO LOSS OF CONSORTIUM 13. Paragraphs 1 through 12 of Defendant's Answer are incorporated herein by reference thereto. 14. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted and proof is demanded at trial. NEW MATTER 15. Paragraphs 1 through 14 of Defendant's Answer are incorporated herein by reference thereto. 16. Plaintiffs claims may be barred in whole or in part by application of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, Defendant, Quirino D'Angelo, respectfully requests that the Complaint be dismissed with costs of this action. Respectfully submitted, NEALON & GOVER - fA J -/lJ1 By: LfJV(JJ elf' Matthew R. Gover, Esquire Attorney I.D. #47593 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 Date: ~/7~O "-~,"- ,or ,o~"_,~,__".-_, - . ",' ',"' - ,-~-",-,--", ~ "'----:'-':_'-:T",'^I":"'~'---~- ,-- " . " ", ',~i - " -v __, __ _" , ,_',', _, "~' ,__ " v VERIFICA liON \, QUIRINO D'ANGELO, verify that the statements made in the foregoing Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.SA 4904 relating to unsworn falsification to authorities. f /11'/71~ /) '1?-e4; QUIRINO D'ANGELO '-<.~-"'~"_~" ;".,,_" -y",~_,_, ..-__,_..,._~,,- C'_.' " "-''_..".",".- :Y__I '--~-~,._-"- -. -, '''.'" ~" CERTIFICATE OF SERVICE AND NOW, this a day of April, 2000, I hereby certify that I have served the foregoing Answer with New Matter on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Robert A. Mazzoni, Esquire Suite 201 Bank Towers 321 Spruce Street Scranton, PA 18503 William Costopoulos, Esquire 831 Market Street P.O. Box 222 Lemoyne, PA 17043-0222 0AI(;x;f4/4- Matthew R. Gover, Esquire ' I.. I" '.~ . '" ,'."_?";'~? {.".-"r:c',_!._.. ". y.- ;-j'-."~ '" '-,"'-"-', ,-c.<'_" -,0--'1'-' - - ,. -, ---, c '_ __ _ ,~_ . _ . - ' ~--, ,--," I''''.n'~ . , , ! JOHN CHRISTOPHER AND ANDRONICKI CHRISTOPHER, HIS WIFE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiffs CIVIL ACTION - LAW -vs- JURY TRIAL DEMANDED QUlRINO D'ANGELO, Defendant No. 2000 - CIVIL - 1489 ........................................................................................................................................... ........................................................................................................................................... PLAINTIFFS' ANSWER TO DEFENDANT'S NEW MATTER 16. Denied. It is specifically denied that the Plaintiffs' claims are barred, in whole or in part, by the application of the Pennsylvania Motor Vehicle Financial Responsibility Act. RESPECTFULLY SUBMITTED: ~,i~ R ERT A. MAZZONI,. QUIRE ATTORNEY FOR PLAINTIFFS, JOHN CHRISTOPHER AND ANDRONICKI CHRISTOPHER, HIS WIFE Suite 201 Bank Towers 321 Spruce Street Scranton, Pennsylvania 18503 Telephone - (570) - 348-0776 . . I!\'I!llJ!lll!U :~,"= , .,'~ ~ --~~,,=~ '; i AFFIDA VIT . COMMONWEALTH OF PENNSYLVANIA: : SS. COUNTY OF LACKA W ANNA JOHN CHRISTOPHER AND ANDRONICKI CHRISTOPHER, IDS WIFE, being duly sworn according to law, depose and say that the facts set forth in the foregoing Plaintiffs' Answer To Defendant's New Matter, are true and correct, to the best of their knowledge, information, and belief. Sworn to and subscribed before me, this loet day of May, 2000. ~ tfL rA.P"~~ NOTARYPUBLI NOTARIAL SEAL KAReN A. PALUSZESKI, Not..y Pubn<< Scranton, Lackawanna County l>lyColnlniui... Ex]!i'.. API!, 19, 2~ -2- }}-~J? ~HN CHRISTOP R ~.~ ANDRONICKI CHRISTOPHER (SEAL) '''"'" ,'.-- i! CERTIFICATE OF SERVICE I, ROBERT A. MAZZONI, ESQUIRE, hereby certify that on the ;O-t:L day of May, i 2000, a copy of the foregoing Plaintiffs' Answer To Defendant's New Matter, was mailed, by regullIT mail, postage prepaid, to Counsel for the Defendant, Quirino D' Angelo, to wit: Matthew R. Gover, Esquire, at 301 Market Street, 9th Floor, P. O. Box 865, Harrisburg, Pennsylvania 17108-0865. ~ I ROBERT A. MAZZONI, UIRE ATTORNEY FOR PLAINTIFFS, JOHN CHRISTOPHER AND ANDRONICKl CHRISTOPHER, HIS WIFE Suite 201 Bank Towers 321 Spruce Street Scranton, Pennsylvania 18503 Telephone - (570) - 348-0776 -3- I II 1\ ", , - Mii1l ..tII~_fi:'11 "h (') (::;J 0 c: Gl -T1 ~::::.... -1!' .-' -~ -<" -at:::J :<,;''11'1 -~.:: -n r1"1 p-: .-c i11F Z~1:} Q~ Zl,:' N _v SQ:f (3 r;: e.1 -0 :~".-' -'h _l--n >r; ~ 03 :be) zrn Pc.: r:-? S'; z ~ ~ '" L~~.~~~\'!!l!l~11f.!1!,flM!llf~~~"__~~lmml!.m-~~~fJ:oi!!i!l~~ . -, - ! . ~. , JOHN CHRISTOPHER and ANDRONICKl CHRISTOPHER PLAINTIFFS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-1489 CIVIL ACTION - AT LAW QUIRINO D'ANGELO, DEFENDANT JURY TRIAL DEMANDED CERTIFICATE PREREOUISITE TO SERVICE OF 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, Quirino D'Angelo, certifies that: 1. A Notice of Intent to Service of a Subpoena with a copy of the Subpoena attached thereto was mailed or delivered to each party at least 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 (see attached correspondence dated January 5, 2001, of Plaintiffs counsel, Robert A. Mazzoni), and 4. The Subpoena which will be served is identical to the Subpoena which is attached to the Notice ofIntent to Serve the Subpoena. DATE: 01/09/01 M~TTHEW R. GOVER, ESQUIRE ATTORNEY FOR DEFENDANT "C"",' -'._'o.,_:-::~',7':;".':!.~,';_~~;,.c- "," ~. ';-, .-0' ~ ~~ ~ -''''-",. ".,'1"- ~ _'I.,.'''''','' - " ."."" . '.~ -- _'" .. -, 1- _ -, r~,~' . ,,-.=- , JOHN CHRISTOPHER and ANDRONICKl CHRISTOPHER PLAINTIFFS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-1489 : CIVIL ACTION -AT LAW QUIRINO D' ANGELO, DEFENDANT : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant, Quirino D'Angelo, intends to serve Subpoenas identical to the ones that are 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. Date: 01/02/01 ~((~ MP Matthew R. Gover, Esquire ' NEALON & GOVER, P.C. Atty. I.D. #47593 2411 North Front Street Harrisburg, P A 1711 0 (717) 232-9900 Attorney for Defendant. Quirino D'Angelo ','''- " _"_~r__ _C_"'__=~',_,,' __," ",__" . ,_, .- -",--;-<" ,,~ "--IT" '_'.'_F"' .0':>.'__',___ - , ", . .,,', .~- JOHN CHRISTOPHER and ANDRONICKI CHRISTOPHER PLAINTIFFS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-1489 : CIVIL ACTION -AT LAW QUIRINO D'ANGELO, DEFENDANT : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Hershey Medical Center 500 University Drive Hershey, P A 17033 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 2411 North Front Street, Harrisburg, pennsylvania 17110. 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 of preparing the copies or producing the things s.ought. 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 (;omply with it. This Subpoena was issued at the request of the following person: Matthew R. Gover, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant Seal of the Court BY THE COURT: f:~J~ ~f'(Y1' .~ DATED:'JO.rll.l.C\rv:'l ;;I(X"l1 { '%' ;-V' .. ~. "~ --~ EXPLANATION OFREOUIRED RECORDS TO: Hershey Medical Center ATTENTION: RECORDS CUSTODIAN 500 University Drive Hershey, PA 17033 ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and Including the Present John Christopher 141-22-5085 08/25/29 -m..,..., .' ~ :_1' ." -~ '1":'- JOHN CHRISTOPHER and ANDRONICKI CHRISTOPHER PLAINTIFFS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-1489 : CIVIL ACTION -AT LAW QUlRINO D'ANGELO, DEFENDANT : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR TIDNGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Lower Allen Township Ambulance 1993 Hummel Avenne Camp Hill, P A 17011 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 2411 North Front Street, Harrisburg, Pennsylvania 17110. 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 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: Matthew R. Gover, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant Seal of the Court BY THE COURT: /Ji/~uJMff1~ PROTHONOT Y j<..fIt1f!, L/fr;. -~~ DATED:Januc:v"v .')~ C)txJl ( !;,~, , ~ ,~,-,,- - ~ -_Il ,_..~, EXPLANATION OF REOUIRED RECORDS TO: Lower Allen Township Ambulance ATTENTION: RECORDS CUSTODIAN 1993 Hummel Avenue Camp Hill, PA 17011 ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and Including the Present John Christopher 141-22-5085 08/25/29 I~-.- -1-- JOHN CHRISTOPHER and ANDRONICKl CHRISTOPHER PLAINTIFFS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-1489 : CIVIL ACTION - AT LAW QUIRINO D'ANGELO, DEFENDANT : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DlSCOVERYPURSUANT TO RULE 4009.22 TO: West Shor,e Emergency Medical Services 1200 Good Hope Road Mechanicsburg, P A 17050 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 2411 North Front Street, Harrisburg, Pennsylvania 17110. 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 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 I;omply with it. This Subpoena was issued at the request of the following person: Matthew R. Gover, Esquire NEALON & GOVER, P.c. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: Seal of the Court /-ldwJM .,f {%:!f PRRTHONOTAR,/? JJ.. Kdteu-a 1fIl'~. ~ DATED,,1dnuarv5; Q.CoI { 1?'7!" "' EXPLANATION OF REOUIRED RECORDS TO: West Shore Emergency Medical Services ATTENTION: RECORDS CUSTODIAN 1200 Good Hope Road Mechanicsburg, P A 17050 ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE PORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and Including the Present John Christopher 141-22-5085 08/25/29 . . . I' I" ,~ , , JOHN CHRISTOPHER and ANDRONICKI CHRISTOPHER PLAINTIFFS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-1489 : CIVIL ACTION - AT LAW QUIRINO D'ANGELO, DEFENDANT : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Albers Chriopractic 4732 Old Gettysburg Road Mechanicsburg, P A 17055 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 2411 North Front Street, Harrisburg, Pennsylvania 17110. 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 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: Matthew R. Gover, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant Seal of the Court BY THE COURT: /.51 (!, h du:. .f{. t1f ~'j PROTHONOTARY f.t>JS ~1ln..~D;q DATED(J;;n. AL'>\r"V 5 'Jt)()/ ( . j~ ~ - .. .. 1~' 1 ' ~ ,- EXPLANATION OF REOUlRED RECORDS TO: Albers Chriopractic ATTENTION: RECORDS CUSTODIAN 4732 Old Gettysburg Road Mechanicsburg, P A 17055 ANY AND ALL MEDICAL. RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and Including the Present John Christopher 141.22-5085 08/25/29 I"~ ~. ~ , "-r -I ~, MAZZONI & KARAM A~ rd $aeu- Paul R. Mazzoni Robert A. Mazzoni Oerard M. Karam Jolm Petorak Julia K. Munley Andrew S. Quinu Rocco V Valvano, Jr. Suite 201 Bank Towers 321 Spruce Street Scranton, PA 18503 Phoue: (570) 348-0776 Fax: (570) 348-2755 January 5, 2001 Matthew R. Gover, Esquire Nealon & Gover, P.C. 2411 North Front Street Harrisburg, P A 1711 0 ATTENTION SHARON L. FRIDY RE: CHRISTOPHER v. D'ANGELO CUMBERLAND COUNTY 00-1489 Dear Ms. Fridy: I am in receipt of your Notices of Intent to Serve Subpoena on Hershey Medical Center, Lower Allen Township Ambulance, West Shore Emergency Medical Services and Albers Chiropractic. Kindly be advised that I do not have any objections to the serving of these Subpoenas. Please forward to my attention copies of any and all documents and/or records you receive by way of this process. Thank you for your anticipated cooperation. Very respectfully yours, RAM:rt 'I~~ "" ' ,"~ CERTIFICATE OF SERVICE AND NOW, this 9th day of January, 2001, I hereby certify that I have served the foregoing Certificate Prerequisite to Service of a Subpoena on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Robert A. Mazzoni, Esquire MAZZONI & KARAM Suite 201 Bank Towers 321 Spruce Street Scranton, PA 18503 ~~Mf Mat ew R. Gover, EsqUIre '.'~ c,' . r-~'-._~'R -, _~"'-'"' '-:~,,/' ',-,;'..=::',,", "." .. '---" _ C" "':''"'"I'''':~- 'd'_, , .< '""~^.'^ I i ,,- - ~~-____, '- "" , . y: "".' .' - -",'---'~ ~" = I" .. '~ ~" " JOHN CHRISTOPHER and ANDRONICKI CHRISTOPHER, his wife Plaintiffs .vs- QUIRINOD'ANGELO, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY : CNIL ACTION - LAW : ruRY TRIAL DEMANDED Defendant : NO. 2000-CNIL-1489 ........................................................................................................................................... ........................................................................................................................................... PRAECIPE TO DISCONTINUE ACTION I i I TO: CLERK OF JUDICIAL RECORDS PLEASE DISCONTINUE AND MARK THE ABOVE-CAPTIONED MATTER SETTLED AND ENDED WITH PREJUDICE. DATED: I~~ I q. 03 q t<;o U (/~rVw i ROCCO V. VALVANO, JR., ESQ. ATTORNEY FOR PLAINTIFFS 321 Spruce Street Suite 201 - Bank Towers Scranton, PA 18503 (570) 348-0776 ..." r .. ~-, II CERTIFICATE OF SERVICE AND NOW, this ~y of ~/rvk2003, I, ROCCO V. VALVANO, JR., ESQUIRE hereby certify that I served a true and correct copy of a Praecipe to Discontinue Action, by regular mail, postage prepaid to the following: James G. Nealon, III, Esquire 2411 North Front Street Harrisburg, P A 17110 rJ(JC! U() ~tVJ-# RO CO V. VALVANO, JR, ESQ. Attorney for Plaintiffs 321 Spruce Street Suite 201 - Bank Towers Scranton, PA 19503 Telephone (570) 348-0776 'I. " " ~I ,~'-, -~ -,,~-~~-'"' ~~_"_NI!i!II.~IJ~JPf!.II~~'W~W~m'l:l4~' -,,~ ._.."'-'"-'~- . ,~. ~. '''-'" ...... to. , '-11> t.) ,...., 0 = "'C:: = " ?: ....., --t <:::l '--:'3([; r<1 :C....., :\1 I'T"' f11p .. ,> -ern L'! "''' ,1<9 ~ N ~o !.'.....--~ -0 :x:'::f-j ;> Q(~ ...... ---.. 1'~,IT\ -,;,~ C'-.: 0.> ~.. S~ ~:''"J :I1 .-< \..CJ ~.. R\!i!!!l,""_!1iY~~-] r"""'""!l!tM\&!Ili'i