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HomeMy WebLinkAbout00-01804 :~.'W0_ ~ II ,"", ,. '.~,' <-. r HEIDI L. SHAFER, . IN THE COURT OF COMMON PLEAS . Plaintiff . OF CUMBERLAND COUNTY . . PENNSYLVANIA . vs. . NO. 00- 1ft)L/ (1Ch(~ . . . . CIVIL ACTION - LAW . NATHAN ALAN RUFF, . . Defendant . JURY TRAIL DEMANDED . NOTICE T 0 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 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 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 Court House Court Administrator 1 Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 ~)1~dL Matthew D.Strohm, Esquire Attorney for Plaintiff . '. .' vs. IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : . NO. {)1J- /i!1JV CW:1/~ . . CIVIL ACTION - LAW . . . . JURY TRIAL DEMANDED . HEIDI L. SHAFER, Plaintiff NATHAN ALAN RUFF, Defendant COMPLAINT Plaintiff, Heidi L. Shafer, a citizen of the Commonwealth of Pennsylvania, is an adult individual who resides at 119 Second Street, Enola, Cumberland County, Pennsylvania. 1. Defendant Nathan Alan Ruff, is an adult individual and citizen of the Commonwealth of Pennsylvania who resides at 1011 North Second Street, Harrisburg, Dauphin County, Pennsylvania. 2. The facts and occurrences hereinafter related took place on or about March 08, 1999, at approximately 5 o'clock P.M. on Industrial Road, Dauphin County, Pennsylvania. 3. At that time and place, Plaintiff was traveling south on Industrial Road, had stopped at HACC Drive, and was attempting a left turn into HACC Drive. . , 4. At that time and place, Defendant was traveling south on HACC Drive and failed to observe Plaintiff's vehicle andthe front portion of the Defendant's vehicle violently collided with the rear portion of Plaintiff's vehicle. 5. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff are the direct and proximate result of the negligent, careless, wanton and reckless manner in which Defendant operated his motor vehicle and that is as follows: a. b. c. d. e. f. g. h. !--" failure to have his vehicle under such control as to be able to stop within the assured clear distance ahead in violation of 75 Pa.C.S.A. S3361; failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; failure to apply his brakes in sufficient time to avoid striking the rear of Plaintiff's vehicle; failure to travel at a safe speed; failure to keep a proper watch for traffic on the highway; failure to keep proper and adequate control over his vehicle; and driving his vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania; driving a vehicle in careless disregard for the safety of persons or property in violation of 75 PA C.S.A. S3714. - ~ CLAIM I PLAINTIFF V. DEFENDANT 6. Paragraphs L through 5. of the Complaint are incorporated herein by reference. 7. Plaintiff sustained painful and severe injuries which include but are not limited to lower back pain, headaches, shoulder neck and back pain, central disk protrusion or bulge at C3-4, sprains and strains of the neck or cervical area carpal tunnel syndrome, severe pain, depression, and chronic muscular pain. 8. By reason of the aforesaid injuries sustained by Plaintiff she was forced to incur liability for medical treatment, medications, hospitalizations and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 9. Because of the nature of her injuries, Plaintiff has been advised and, therefore, avers that she may be forced to incur , similar expenses in the future, and claim is made therefor. 10. As a result of the aforementioned injuries, Plaintiff has undergone and in the future will undergo great physical and - . i mental suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 11. As a result of the aforesaid injuries, Plaintiff has been and in the future will be subject to great humiliation and embarrassment, and claim is made therefor. 12. As a result of the aforementioned injuries, Plaintiff has sustained work loss, loss of opportunity and a permanent diminution of her earning power and capacity, and claim is made therefor. 13. As a result of the aforesaid injuries, Plaintiff has sustained uncompensated work loss, and claim is made therefor. 14. Plaintiff continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefor. WHEREFORE, Plaintiff demands judgment against Defendant in an amount in excess of TWo Hundred Fifty Thousand Dollars ($250,000.00) exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. ~ ff , r- DISSINGER & DISSINGER By: C",,",, ~~g Matthew D. Strohm I.D. No. 76724 Dissinger & Dissinger 28 N. Thirty Second Street Camp Hill, PA 17011 (717) 975-2840 Counsel for Plaintiff ~ 11 r ..... ~.. . " ,.' ".. VERIFICATION I, Heidi L. Shafer, Plaintiff, have read the foregoing Complaint and do hereby swear or affirm that the facts set forth in the foregoing are true and correct to the best of my knowledge, information and belief. I understand that this Verification is made subject to the penalties of 18 Pa.C.S.A. section 4904, relating to unsworn falsification to authorities. ~'dA' L.~~o^ He1d1 L. Shafer Dated:3!d{)! Do - ,~,~,,-,. . """'l".,.."~ _","r~ rlll'll!ll .:;<<-'re' , ,,' - ~''''.<'''''''-_k ~"',"'-:,"".,~-, ~I '; , "i.. <-,-r .' 0 0 0 C 0 -n -&, "6q, s::: ::Jl: :.:;J ~ ""Om ::l~ '"P .~ ..t nlrTl ::4 .-:;1 :JJ 2.:.1J "r ~ Q zs;; N '-1"~m 8 Jt.:. (j) . w '~y & -<2 0 8 ~o --i'C) 0 ~C) ..,., :+:=-H c.v ~"'''' ~ ;Sc.. ."- ~3o ~ ;Pc f.:J ."....m I . 0 "- ~ z $ () ~ ~ 0 () \D ~ -- J - '" lJ7"1~1~~~~~'\,"\!i!i!?lt~~~~rnfit!___lHiI/Iil~Il1!1t'lqi~~ <' SHERIFF'S RETURN - OUT OF COUNTY .. CASE NO: 2000-01804 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SHAFER HEIDI L VS RUFF NATHAN ALAN 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: RUFF NATHAN ALAN but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN serve the within COMPLAINT & NOTICE County, Pennsylvania, to On April 17th, 2000 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge DEP. DAUPHIN CO 18.00 9.00 10.00 25.50 .00 62.50 04/17/2000 DISSINGER & ~~,,:~ ' -~ ' - R. 'Thomas Kline Sheriff of Cumberland County DISSINGER Sworn and subscribed to before me this /q2 day of ff'J ~ A.D. Q1'" 0 ~,~- Prothonotary '''"'' ~,.-, .. ... In The Court of Common Pleas of Cumberland County, Pennsylvania Heidi L. ShafeyS. Nathan Alan Ruff No. 20-1804 Civil Now, 3/28/00 , 20 0 () , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to exe,cute this Writ, this deputation being made at the request and risk of the Plaintiff. " r;~~-~~! Sheriff of Cumberland County, P A Affidavit of Service Now, , 20_, at o'clock M. served the within upon at by handing to a copy of the original and made mown to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before methis_dayof ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ ~, . ','. "" - i~llIi'''''''''''''.io.lIo~d,". iIIIt",",=~-"",~ ~~[_\IIH;lI!ll'''IO:I~~ ,~~""~~ '~~ r".~ iJ'PH1N Cl'.i0':iT 'f I...' >~ .'", ~"'.[:"Cf (\{ERlf" F c. Ut; I . _' . '''''~I,'H COU..p'"'y CUUR \ H;.\l:',; ....I.fri.;H\i'~~3\l:.:r, :',\ :';:(,11 ,.,j i-'i,~\n 3C r'" ;:: i;,)' ,-<i D'-C"E'.,'tii.fj nt:. .1" ~,," " 60 .......~""""'=-- ~,~'. .-, '-j , ( .... @ititt of :tlr~ ~4~riff William T. Tully Solicitor Ralph G. McAllister Chief Deputy Michael W. Rinehart Assistant Chief Deputy Mary Jane Snyder Real Estate Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania SHAFER HEIDI L vs County of Dauphin RUFF NATHAN ALAN Sheriff's Return No. 0724-T - -2000 OTHER COUNTY NO. 20-1804 AND NOW: April 5, 2000 at 8:15PM served the within COMPLAINT upon RUFF NATHAN ALAN by personally handing to DEFT 1 true attested copy(ies) of the original COMPLAINT and making known to him/her the contents thereof at 1011 NORTH 2ND ST HBG, PA 17102-0000 Sworn and subscribed to So Answers, ?I!~ before me this 12TH day of APRIL, 2000 r\ /', ~ ! " ~(.,...... f ! oJ LeD lfJ/Jt) (f'l I.r:. J i~'".. -v 1 J ~......""~ i ~ f,U,~"~'_;;'/Y'l1"l ) \ '....." ""'''1' VL--.fo.....' , PROTHONOTARY By a. Sheriff's Costs: $25.50 PD 04/04/2000 RCPT NO 135330 ET/TS I """"""'_.'" F:\FILES\DATAFILE\Prgdoc_cur\120-pra.1/nlm Created: 04/26fOOOS:OS:42AM 'Revised: 04/26fOOOS:27:18AM 7837_120 , , HEIDI L. SHAFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 00-1804 Civil Term CIVIL ACTION-LAW NATHAN ALAN RUFF, Defendant JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Defendant in the above matter. Defendant hereby demands a twelve juror jury trial in the above captioned action. MARTSON DEARDORFF WILLIAMS & OTTO By , George B. Faller, Jr., Esquire LD. No. 49813 Ten East High Street Carlisle, P A 17013 (7l7) 243-3341 Attomeys for Defendant Dated: April 26, 2000 I I I I I I" ^" , , CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Matthew D. Strohm, Esquire DISSINGER & DISSINGER 28 N. Thirty Second Street Camp Hill, PA 17011 MARTSON DEARDORFF WILLIAMS & OTTO BYN~~Ye::71Up>> Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: April 26, 2000 i''-' ..,., , "~ '0 ,~, _'_ "."' ,~,,"'~' '" , ' -Ot;; . 111;'T Z::, ~1;',~ r-:O~,- I ~,~.; :C~ .,,;" :::j -<, ,,,'~ () <:,;: - .~~~ - ~- . ,--' ,---J (-:' -:;:-,-=" -on ;".,) ()" "~C1 :..~) ::d C:t , , . ~ "- Wl_~l~.,., _~~, ~~~~l i'",..-.....""'~I!!r: HEIDI L. SHAFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. . . ' NATHAN ALAN RUFF, Defendant NO. 00-1804 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE T 0 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 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 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 PA 17013 m/;~A~ Matthew D. Strohm Attorney for Plaintiff - HEIDI L. SHAFER, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. NATHAN ALAN RUFF, Defendant NO. 00-1104 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED AMENDED COMPLAINT 1. Plaintiff, Heidi L. Shafer, a citizen of the Commonwealth of Pennsylvania, is an adult individual who resides at 119 Second Street, Enola, Cumberland County, Pennsylvania. 2. Defendant, Nathan Alan Ruff, is an adult individual and citizen of the Commonwealth of Pennsylvania who resides at 1011 North Second Street, Harrisburg, Dauphin County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on or about March 08, 1999, at approximately 5:00 o'clock P.M. on Industrial Road, Dauphin County, Pennsylvania. 4. At that time and place, Plaintiff was traveling South on Industrial Road, had stopped at HACC Drive, and was attempting a left turn into HACC Drive. 5. At that time and place, Defendant was traveling South on HACC Drive and failed to observe Plaintiff's vehicle and the front portion of the Defendant's vehicle violently collided with the rear portion of Plaintiff's vehicle. !, I'~ 6. The foregoing, accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff are the direct and proximate result of the negligent, careless, wanton and reckless manner in which Defendant operated his motor vehicle and that is as follows: a. failure to have his vehicle under such control as to be able to stop within the assured clear distance ahead in violation of 75 Pa.C.S.A. ~3361; b. failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; c. failure to apply his brakes in sufficient time to avoid striking the rear of Plaintiff's vehicle; d. failure to travel at a safe speed; e. failure to keep a proper watch for traffic on the highway; f. failure to keep proper and adequate control over his vehicle; g. driving his vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania, and h. driving a vehicle in careless disregard for the safety of persons or property in violation of 75 PA C.S.A. ~3714. 2 .' ....... CLAIM I PLAINTIFF V. DEFENDANT 7. Paragraphs 1. through 6. of the Complaint are incorporated herein by reference. 8. Plaintiff sustained painful and severe injuries which include but are not limited to lower back pain, headaches, shoulder, neck and back pain, central disk protrusion or bulge at C3-4, sprains and strains of the neck or cervical area, carpal tunnel syndrome, severe pain, depression, and chronic muscular pain. 9. By reason of the aforesaid injuries sustained by Plaintiff she was forced to incur liability for medical treatment, medications, hospitalizations and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 10. Because of the nature of her injuries, Plaintiff has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 11. As a result of the aforementioned injuries, Plaintiff has undergone and in the future will undergo great physical and 3 " 1- mental suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 12. As a result of the aforesaid injuries, Plaintiff has been and in the future will be subject to great humiliation and embarrassment, and claim is made therefor. 13. As a result of the aforementioned injuries, Plaintiff has sustained work loss, loss of opportunity and a permanent diminution of her earning power and capacity, and claim is made therefor. 14. As a result of the aforesaid injuries, Plaintiff has sustained uncompensated work loss, and claim is made therefor. 15. Plaintiff continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefor. WHEREFORE, Plaintiff demands judgment against Defendant in an amount in excess of Twenty-five Thousand Dollars ($25,000.00) 4 -,,-, r! ,- exclusive of interest and costs and therefore exceeding compulsory arbitration limits. DISSINGER & DISSINGER By' ~J?l~ I.D. No. 76724 Dissinger & Dissinger 28 N. Thirty Second Street Camp Hill, PA 17011 (717) 975-2840 Counsel for Plaintiff - q I'~ VERIFICATION I, Heidi L. Shafer, Plaintiff, have read the foregoing Complaint and do hereby swear or affirm that the facts set forth in the foregoing are true and correct to the best of my knowledge, information and belief. I understand that this Verification is made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. ~-~~QA eidi L. Shafer ' ~ II r- HEIDI L. SHAFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY : PENNSYLVANIA NO. 00-11!04 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED vs. NATHAN ALAN RUFF, Defendant CERTIFICATE OF SERVICE I, Matthew D. strohm, Esquire, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document upon the attorney for Defendant, by First Class United States mail addressed as follows: George B. Fuller, Jr., Esquire Martson Deardorff Williams & otto Ten East High Street Carlisle, PA 17013 Date: S-Iz-!o() m~)hL, Matthew D. Strohm . ~ . n : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA HEIDI L. SHAFER, Plaintiff . . NO. (Jol80vl LC'fd T eYI---t vs. : CIVIL ACTION - LAW NATHAN ALAN RUFF, Defendant : JURY TRIAL DEMANDED NOTICE OF DEPOSITION TO: Dr. Steven E. Morganstein PLEASE TAKE NOTICE that pursuant to Pa.R.C.P. 4007.1, the attorney for Plaintiff will take the deposition of Dr. Steven E. Morganstein, a witness in the above-captioned action, upon oral examination, for purposes of discovery and/or for use at trial, before a Notary Public or some other person authorized to administer oaths, at Arlington Rehab of Sports Medicine, 805 Sir Thomas Court, Harrisburg, Pennsylvania, on Monday, July 31, 2000 at 3:00 p.m., on all matters not privileged which are relevant and material to the issues and subject matter involved in the above- captioned action, and that the above-named is requested to appear at the aforesaid time at the above address and submit to examination under oath. The court reporter/notary public will be from Geiger & Loria. :::S~4Gha Matthew D. Strohln LD. No. 76724 Dissinger and Dissinger 28 North 32nd Street Camp Hill, PA 17011 (717) 975-2840 Counsel for Plaintiff MDS:rj cc: George Dated: B. Faller ,~ , , II ,- J " HEIDI L. SHAFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA V6. NO. CIVIL ACTION - LAW NATHAN ALAN RUFF, Defendant JURY TRAIL DEMANDED CERTIFICATE OF SERVICE I, Matthew D. Strohm, hereby certify that on the date set forth below I served a true and correct copy of the foregoing document, by First Class United states mail addressed as follows: Mr. George B. Faller 10 East High street Carlisle PA 17013 i Date: -t.l 'j /t7~ C/Ii-/bO IJJ1A/lbkJ bulv Matthew D. Strohm- , -. _. "' , ~- ,--.... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HEIDI L. SHAFER, Plaintiff vs. NO. c2000 -()/ fo4 CIVIL ACTION - LAW NATHAN ALAN RUFF, Defendant JURY TRIAL DEl<fANDED NOTICE OF DEPOSITION TO: Dr. Steven E. Morganstein PLEASE TAKE NOTICE that pursuant to Pa.R.C.P. 4007.1, the attorney for Plaintiff will take the deposition of Dr. Steven E. Morganstein, a witness in the above-captioned action, upon oral examination, for purposes of discovery and/or for use at trial, before a Notary Public or some other person authorized to administer oaths, at Arlington Rehab and Sports Medicine, 805 Sir Thomas Court, Harrisburg, Pennsylvania, on Monday, November 13, 2000 at 3:00 p.m., on all matters not privileged which are relevant and material to the issues and subject matter involved in the above- captioned action, and that the above-named is requested to appear at the aforesaid time at the above address and submit to examination under oath. The court reporter/notary public will be from Geiger & Loria Reporting Service. DISSINGER' DISSINU By: ~A-.~ ) Matthew D. Strohm Attorney for Plaintiff LD. No. 76724 28 North 32nd Street Camp Hill, PA 17011 (717) 975-2840 Dated: J ,___...,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, : PENNSYLVANIA HEIDI L. SHAFER, Plaintiff NO. vs. CIVIL ACTION - LAW I NATHAN ALAN RUFF, ! Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE , I, Matthew D. Strohm, Esquire, hereby certify that on 'the date set forth below I served a true and correct copy of 'the foregoing document upon George B. Faller, Jr., attorney for Defendant, Nancy Salak, of Progressive Insurance, and ,Steven E. Morganstein, D.O., by First Class United States imail addressed as follows: George B. Faller, Jr., Esquire Martson Deardorff Williams & Otto 10 East High Street Carlisle, PA 17013 Nancy J. Salak Progressive Companies 801 East Park Drive Suite 105 Harrisburg, PA 17111 Steven E. Morganstein, D.O. Arlington Rehab & Sports Medicine 805 Sir Thomas Court Harrisburg, PA 17109 Date: !JMIfj;; A~ Matthew D. Strohm, Esquire Attorney for Plaintiff " ., ~"'""~ " ,"'"' "~~~r,...~~",--qJl!lfi., Tl~ ' ~ ' ~ ~,- ~' -".; ,,,,,' , o .'~ .~>~,_ (') c <" -p;:::r ~~ti (n ).'" -<" ~, .. [::C"-' -^ ;:f; ~:.~~; )> (~~ ~ -<. -" - .~," ....--, '.. ~-,/') :'1 '"v r<' m C:) ~"~~~~~~~~~~!IIllJII~J_~ff!I~!m Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA HEIDI L. SHAFER, v. NO. 00-1804 Civil Term CIVIL ACTION-LAW NATHAN ALAN RUFF, Defendant JURY TRIAL OF TWELVE 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 Rille 4009.22, Nathan Alan Ruff (defendant) certifies that: (1) Plaintiff has waived the 20 day notice period, (2) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to this Certificate Prerequisite to Service of a Subpoena. Attorneys for Defendant Nathan Alan Ruff Date: October 6, 2000 ~~~,,, J. - ^'~ ., ~ .~...-tf'f""H'; ~ OF PID1SYLVANIA rouNl'Y OF CI.JMBERU\ND HEIDI L. SHAFER, Plaintiff : v. ,File No. 00-1804 CIVIL TERM NATHAN ALAN RUFF, Defendant JURY TRIAL DEMANDED SUBPOENA TO PROOUCE [)()QJf3ffS OR lH I NGS FOR OISOOVERY PURSUANT TO RULE 4009.22 TO: Geico Insurance Company 1 Geico Blvd. (Nane of Person or Entity) Fredericksbury, VA 22412-0002 Within twenty (20) days after service of this subpoena, you are ordered by the court t prodlce the following doct.ments or things: Entire PIP File regarding your insured, Heidi L Shafer, Date of Accident 3/8/99 at MARTSON DEARDORFF WILLIAMS & Ol'TO, Ten East High Street, Carlisle PA 17013 by 9:00 ".m. on November 10, 2000. (Address ) You may deliver or mail legible copies of the doctments or produce things requested this subpoena, together with the certificate of ~1iance, to the party making th request at the address listed above. You have the right to seek in advance the reasonabl cost of pr89aring the copies or producing the things sought. If you fail to produCe the docunents or things required by this subpoena within twent (20) days after its serv~ce, the party serving this subpoena may seek a court ordE canpelling you to carply with it. lHlS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Georqe B. Faller, Jr., ESQUire AOORESS: MARTSON DEARDORFF WILLIAMS & Ol'TO Ten East High Street, Carlisle, PA 17013 TELEPHONE: (717) 243-3341 SUPREt'E OXJRT 10 # 49813 ATTORNEY FOR: Defendant Nathan Alan Ruff DATE: (jr1o'oe.r 1), JOQ() Sea 1 of the Court BY THE OOURT: p/ (}pNJfi f ,~~ ~~2~~t~r"~ Deputy (Eff. 7/91] ,.;It!IlI.,..,~-,? , .'? ~TH OF PBlNSYLVANIA rouNl'Y OF CUMBERIAND HEIDI L. SHAFER, Plaintiff v. ,Fi le No. nQ_.' ~OLl. t"T1fTf IfIIn)M NATHAN ALAN RUFF, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PROOUCE DClClJ'ENTS OR lH I NGS FOR D I SOOVERY PURSUANT TO RULE 4009.22 TO: DBA Orthopedic Institution of PA 875 Popular Church Road (Nane of Person or Entity) Camp Hill, PA 17011 Within twenty (20) dayS after service of this subpoena, you are ordered by the court 1 produce the following doct.ments or things: Your comolete records of all services provided to Heidi L. Shafer, D.O.B. 3/3/63, S.S.#160-54-4493 and the. billing for same, inCluding at MARTSON DEARDORFF WILLIAMS & OTTO, on November 10, 2000. without limitation all admission and discharge summaries, results of tests or studies,* . , Carlisle, PA 17013 bY 9:00 a.m. 'Ten East High Street, . (Address) You may deliver or mail legible copies of the docunents or produce things requested th;s subpoena, together with the certificate. of CCIJl)liance, to the party making th request at the address 1 isted above. You have the right to seek in advance the reasonab cost of pr89aring the copies or produc;ng the things sought. If you fail to produce the docunents or things required by this subpoena within twel'1 (20) days after its serv~ce, the party serving this subpoena may seek a court ord ~l1ing you to ~ly with it. lHlS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAI'E: George B. Faller, Jr., Esquire ADORESS:MARTSON DEARDORFF WILLIAMS & arTO * - operative notes, consultations, referra forms, reports I as well as all correspon- dence and memoranda or the like, but EXCLUDING only actual films and routine nurses notes. Ten East Hiqh Street, Carlisle, PA 17013 TELEPHONE: (717) 243-3341 SUPREt'E CXlURT 10 # 49813 ATTORNEY FOR: Defendant Nathan Alan Ruff DATE: OcAo1Jer 5. JaJO Sea I of the Court BY lHE OOURT: bJ ~~ ,x:~ ' Prothonot 'y/~}er'k, 9ivil Division 1lI/f//AIJ? ~,~~ . , uty (Eff. 1/97 ,;:liC'"",~'" "~- -, -~= ('(Mi)NWFAtlrn OF PID1SYLVANIA rouNl'Y OF CI.JMBERU\ND HEIDI L. SHAFER, Plaintiff v. "File No. 00-1804 CIVIL TERM NATHAN ALAN RUFF, Defendant JURY TRIAL DEMANDED SUBPOENA TO PROOUCE 00Cl..t1ENTS OR lH I NGS FOR 0 I SOOVERY PURSUANT TO RULE 4009.22 TO: Poly Medical Center Ourtpatients 2601 North 3rd Street (Nane of Person or Entity) Harrisburg, PA 17110 Within twenty (20) dayS after service of this subpoena, you are ordered by the court t produce the following docunents or things: VMr ~~mnlQt-e records of all services nrovided t Heidi L. Shafer, D.O.B.3/3/63, s.S.#160-54-4493 and the billing .for same, including without limitation all admission and diScharqe summaries, results of tests or studies, operative * at MARTSON DEARDORFF WILLIAMS & 0l'TQ, Ten East High Street, Carlisle, PA 17013 by 9:00 a.m. on November 10, 2000. (Address) You may deliver or mail legible copies of the doct.ments or produce things requested this subpoena, together wH:h the certificate of OOl\l)liance, to the party making th request at the address 1 isted above. You have the right to seek in advance the reasonab cost of preparing the copies or producing the things sought. If you fail to produCe the docunents or things reQUired by this subpoena within twen' (20) days after its serv~ce. the party serving this subpoena may seek a court ord canpelling you to carply with it. lHlS SUBPOENA WAS ISSUED AT lHE REQUEST OF THE FOLLQ'lING PERSON: NAME:Georqe B. faller, Jr., Esquire AODIRESS: MARTSON DEARDORFF WILLIAMS & orTO Ten East High Street, Carlisle, PA 17013 TELEPHONE: (717) 243-3341 SUPREt'E CXlURT 10 #4QR1'l ATTORNEY FOR: Defendant Nathan Alan Ruff * - notes, consultations, referrals, forms, reports, as well as all correspondence an' memoranda or the like, but EXCLUDING only actual films and routine nurses notes. DATE: (J)ohe( 5,)006 Sea 1 of the' Court BY THE OOURT: ./j) /5)f~-p\ ~ Prothonotary!CI.. Civi 1 Oivision ~lKan I1f/ ~~~~ . Deputy (Eft. 1/97: ~~ ~~,~,~,~.~ ;>J, _. _ . J. _l>'~- ~TH OF PlHlSYLVANIA aJUNl'Y OF CUMBERU\ND HEIDI L. SHAFER, Plaintiff : v. .File No. 00-1804 CIVIL TERM NATHAN ALAN RUFF, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PROOUCE DC:ICl.tENTS OR lHlNGS FOR 0 I SOOVERY PURSUANT TO RULE 4009.22 TO: River Rescue Ambulance Service, Community Gener"l Osthpo Hn~ir"l 4300 Londonderry Road (Name of Person or Entity) Harrisburg, PA 17105 Within twenty (20) days after service of this subpoena, you are ordered by the court 1 produce the following doct.ments or things: Your complete records of all services provided t, Heidi L. Shafer, D.O. B. 3/3/63, S.S.i160-54-4493 and the billinqfor same, including without limitation all admission and discharge summaries, results of tests or studies, operative * at MARTSON DEARDORFF WILLIAMS & arro, Ten East High Street, Carlisle, FA 17013 bv 9:00 a.m. on November 10, 2000. (Address) You may deliver or man legible copies of the docunents or produce things requestecl this subpoena, together wit.'l the certificate of carp liance , to the partv making th request at the address 1 isted above. You have the right to seek in advance the reasonab cost of pre9aring the copies or producing the things sought. If you fail to produCe the docunents or things required by this subpoena within twen (20) days after its serv~ce, the party serving this subpoena may seek a court ord canpelHng you to carply with it. llilS SUBPOENA WAS ISSUEO AT THE REQUEST OF THE FOLLOWING PERSON: NAME: George B. Faller, Jr., Esquire ADDIRESS: MARTSON DEARDORFF WILLIAMS & OTTO * - notes, consultations, referrals, forms, reports, as well as all correspondence an memoranda or the like, but EXCLUDING only actual films and routine nurses notes. Ten East Hiqh Street, Carlisle, PA 17013 TELEPHONE: (717) 243-3341 SUPflEI'E CXlURT 10 # 49813 ATTORNEY FOR: Defendant Nathan Alan Ruff Prothonotary Clerk, C' Division Ao~o 87?;'/7?Arrl Deputy DATE: ~ -t ~O,.)(') Sea 1 of the Court "-.... (Eff. 7/97 :'''f~''--'~ ., ~ - COMK)NWEAIIm OF PENNSYLVANIA COONl'Y OF aJMBERIAND HEIDI L. SHAFER, Plaintiff v. Fi Ie No. 00-1804 CIVIL TERM NATHAN ALAN RUFF, Defendant JURY TRIAL DEMANDED SUBPOENA TO PROOUCE OOCl.t1ENTS OR lH 1 NGS FOR DISOOVERY PURSUANT TO RULE 4009.22 TO: Geico Insurance Company 1 Geico Plaza (Name of Person or Entity) Washington D.C., PA 20076 Within twenty (20) days after service of this subpoena. you are ordered by the court to produce the following docunents or things: Entire PIP File reqardinq your insured, Heidi L. Shafer, Date of Accident 3/8/99. at MARTSON DEARDORFF WILLIAMS & 0l'TQ, Ten Ea~t High Street, Carlisle PA 17013.by 9:00 a.m. on November 10, 2000. (Address) You may de liver or ma i1 legib Ie copies of the doct.ments or produce things requested b this subpoena, together with the certificate of CO'il'liance, to the party making thL 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. 1 f you fai 1 to produce the docunents or things required by this subpoena within twer.t~ (20) days after its serv~ce, the party serving this subpoena may seek a court. order caTllelling you to CO'il'ly with it. lH I S SUBPOENA WAS I SSUEO AT lHE REQUEST OF lHE FOLLOW 1 NG PERSON: NA/'E: George B. Faller, Jr., Esquire ADDRESS: M"1>'l'':;nN np.l\ROORF'F' WILI.TAMS & 0l'TQ Ten East High Street, Carlisle PA 17013 TELEPHONE: (717) 243-3341 SUPREt'E COURT 10 # 49813 ATTORNEY FOR:Def~nnant Nathan Alan Ruff DATE: (Jd ~ ;;;)000 Sea 1 of the Court A-6 prothono~arY/Clerk, C' Division ~~tho P~,r--- Deputy (Eff. 1197) ~ -- ,:,~,,",--~~~~' ~ ~ OF :PJ.HlSYLVANIA rouNl'Y OF CUMBERLAND HEIDI L. SHAFER, Plaintiff v. ,File No. 00-1804 CIVIL TERM NATHAN ALAN RUFF, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PROOUCE [l()Cl.tENTS OR lH I NGS FOR 01 SOOVERY PURSUANT TO RULE 4009.22 TO: David E. Tanner, D.O., Family Physician -- General Practice P.O.Box 10 (Nane of Person or Entity) Newport, PA 17074 Within twenty (20) days after service of this subpoena. you are ordered by the court 1 produce the following doct.ments or things: your complete records of all services provided to Heidi L. Shafer, D.C.B. 3/3/63, S.S.#l60-54-4493 ann the billing for ""m... inrlllning without limitation all office notes, correspondence, memoranda, reports I forms, results of at MARTSON DEARDORFF WILLIAMS & 0l'T0, Ten East High Street, Carlisle, PA 17013 by 9:00 a.m. on November 10, 2000. (Address) You may deliver or mail legible copies of the docunents or produce things requested this subpoena, together with the certificate of OCI'I"Pliance, to the party making t\1 request at the address 1 isted above. You have the right to seek in advance the reasonab cost of pr89aring the copies or producing the things sought. .If you fail to produCe the docunents or things requ'ired'by this subpoena within twe" (20) days after its serv~ce, the party serving this subpoena may seek a court ord CCIlllelHng you to carply with it. 'THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLaNING PERSON: NA/'E: Georqe 13. Faller. Jr.. EsQUire ADDRESS: MARTSON DEARDORFF WILLIAMS & 0l'T0 Ten East High Street, Carlisle, PA 17013 * - tests or studies (but not actual films) consultations, referrals and the like. TELEPHONE: (717) 243-3341 SlJPflEt'E CXll.JIT 10 # 49813 ATTORNEY FOR: Defendant Nathan Alan Ruff OATE: (0J ~ o?aJO Seal of the Court (Eff. 7/91 -,~~-' ,~ a:HI:>NNEA'LTH OF PENNSYLVANIA rouNl'Y OF ClJMBERU\ND HEIDI L. SHAFER, Plaintiff v. ,F; Ie No. ()()_ 1 $:tnA ('lTVTT IJ1~RM NATHAN ALAN RUFF, Defendant : : JURY TRIAL DEMANDED SUBPOENA TO PROOUCE lXlCU'ENTS OR lHl NC3S FOR 01 SOOVERY PURSUANT TO RULE 4009.22 TO: pinnacle Health Hospital, Harrisburg Hospital III South Front Street (Name of Person or Entity) Harrisburg, PA 17101 W;thin twenty (20) days after service of this subpoena, you are ordered by the court 1 produce the following doct.ments or things: Your complete records of all services provided t Heidi L. Shafer, D.O.B.3/3/63, S.S.#160-54-4493, and the billing for same, including withou limitation all admission and discharge summaries, results of tests or studies, operative * at MARTSON DEARDORFF WILLIAMS & 0l'T0, Ten East High Street, Carlisle, PA 17013 by 9:00 a.m. on November 10, 2000. (Address) You may deliver or mail legible copies of the docunents or produce things requested this subpoena, together w;th the certificate of CCl11)liance, to the party making th request at the address listed above. You have the right to seek in advance the reasonab cost of preparing the copies or producing the things sought. If you fail to produCe the docunentsor th;ngs required by this subpoena w;thin twen (20) days after its serv~ce. the party serv;ng this subpoena may seek a court ord CCl11)elling you to carply with ;t. lHlS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOl..LQVING PERSON: NAME:George B. Faller, Jr., Esquire * - notes, consultations, referrals, forms, reports, as well as all correspondence an memoranda or the like, but EXCLUDING only actual films and routine nurses notes. AOOiRESS:MARTSON DEARDORFF WILLIII.MS & 0l'T0 Ten East Hiqh Street, Carlisle, PA 17013 TELEPHONE: (717) 243-3341 SUPREf'E <XlURT 10 #49813 ATTORNEY FOR: Defendant Nathan Alan Ruff OATE: {f).d 3 f!/)O{) Seal of the Court Division Deputy (Eff. 7/91 -. -""'" i_-_~~,.-..=- ,~- ~= ~ OF Pl'1iINS'1I}1AN rouNl'Y OF CUMBERIAND HEIDI L. SHAFER, Plaintiff : v. ,Fi le No. 00-1804 CIVIL TERM NATHAN ALAN RUFF, Defendant JURY TRIAL DEMANDED SUBPOENA TO PROOUCE 00CU1ENTS OR lH I NGS FOR 01 SOOVERY PURSUANT TO RULE 4009.22 TO: Fry Communications BUU West Church Road (Nana of Person or Entity) Mechanicsburg, PA 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court produce the following docunents or things: Your coltll?lete recorda pertaining to Heidi L. Shafer, D.O.B. 3/3/63, S.S. *160-54-4493 , includinq without limita ion re corres ondence, mel,llOranda, h sicals or other at MARTSON DEARDORFF WILLIAMS & Ol'TO, Ten East Hi on November 10, 2000. (Address) * You may deliver or mail legible copies of the docunents or produce things requested this subpoena, together with the certificate of OClIIl>liance, to the party making th request at the address listed above. You have the right to seek in advance the reasonab cost of pr89aring the copies or producing the things sought. I f you fail to produCe the docunentsorth ings requ'ire<! 'bY' this' subpoena with i~ twen (20) days after its serv~ce, the party serving this subpoena may seek a court ord OClIIl>l'lll1ing you to carply with it. lHlS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: George B. Faller, Jr., Esquire AOORESS: MARTSON DEARDORFF WILLIAMS & 0l'T0 Ten East Hiqh Street, Carlisle, PA TELEPHONE: (717) 243-3341 SUPREt'E CXlURT 10 # 49813 ATTORNEY FOR: Defendant Nathan Alan Ruff *- evaluations, promotions, disciplinary matters, claims arising out of illness or 17013 injury, whether on or off the jOb, job descriptions, and the like. DATE: (() /' i . t) :2 (J(J[) Sea 1 of the Court 'fn ~' lr . Clvl1 D;v;sl~ nf~ /Yl1/)/J hYJ ~ I 1 ty (Eff. 1/97 - :W"!@!lIl-~. C<MirJNWFAtTH OF PDlNSYLVANIA <DUNl'Y OF CUMBERLI\ND HEIDI L. SHAFER, Plaintiff : : v. .Fi Ie No. 00-1804 CIVIL TERM : NATHAN ALAN RUFF, Defendant : : JURY TRIAL DEMANDED SUBPOENA TO PROOUCE DOClt'ENTS OR lH I NGS FOR 0 I SCXNERY PURSUANT TO RULE 4009.22 TO: Arlinoton Rehab and Sports Medicine P.O.Box 6507, 805 Sir Thomas (NlI1le of Person or Entity) Harrisburg, FA 17112 Within twenty (20) days after service of this subpoena, you are ordered by the court 1 produce the fo I lowing docunents or things: YOUIC - et-." records of all sprvices nrovid"d t Heidi L. Shafer, D.O.B.3/3/63, S.S.#160-54-4493 and the billing ,for same, including without limitation all admission and disdharqe summaries, results of tests or studies, operative * at MARTSON DEARDORFF WILLIAMS & 0l'TQ, Ten East Hiqh Street, Carlisle, FA 17013 bv 9:00 a.m. on November 10, 2000. (Address) You may deliver or mail legible copies of the docunents or produce things requested this subpoena, together with the certificate of c::arpliance, to the party making th request at the address listed above. You have the right to seek in advance the reasonab' cost of preparing the copies or producing the things sought. If' you fall to produCe the docunents or things required by this subpoena within twenl (20) days after its serv~ce, the party serving this subpoena may seek a court orck CCIt1Pelling you to carply with it. lHlS SUBPOENA WAS ISSUED AT 1HE REQUEST OF THE FOLLOWING PERSON: NAME:George B. Faller, Jr., Esquire AOORESS:MARTSON DEARDORFF WILLIAMS & OTTO Ten East Hioh Street, Carlisle, PA 17013 TELEPHONE: (717) 243-3341 SUPREfoE CXXJRT 10 # 49813 ATTORNEY FOR:Defendant Nathan Alan Ruff * - notes, consultationst referrals, forms, reports, as well as all correspondence anc memoranda or the like, but EXCLUDING only actual films and routine nurses notes. DATE: tfJe:;(. 5. d~~ Sea I of the Court BY THE OOURT: /5/ &d. ,P~ Prothonotary/CJ ,Civil Division rd! -C' ~( 9~ty (Eff. 7/91J ,,~-~~ ~ . - "~ -~~ ~ OF PmNSYLVANIA rouNl'Y OF (DMllERU\ND HEIDI L. SHAFER, Plaintiff v. ,File No. 00-1804 CIVIL TERM NATHAN ALAN RUFF, Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOClJIENTS OR lHl NGS FOR 0 I SOOVERY PURSUANT TO RULE 4009.22 TO: Pinnacle Health Hospital 860 North US 15 (Nane of Person or Entity) Dillsburg, PA 17019 Within twenty (20) days after service of this subpoena, you are ordered by the court Pf"OClace the following docI.ments or things: Your complete records of all services provided Heidi L. Shafer, D.O.B.3/3/63. SoS ilfiO~4-44q, ~nn the bil1ino same, includi wi limitation all admission and dischar e summaries re ul 0 rative * at MARTSON DEARDORFF WILL lAMS & orro, on November 10, 2000. Ten East Hiqh Street, (Address) Carlisle, PA 17013 bv 9:00 a.m. You may deliver or mail legible copies of the docunents or produce things requested this subpoer,a, together with the certificate of cat1lliance, to the party making th request at the address I isted above. You have the right to seek in advance the reasonab cost of preparing the copies or producing the things sought. I f you fai I to produCe the docunents or things required by this subpoena within t'rlen; (20) days after its serv~ce, the party serving this subpoena may seek a court ord cat1lelling you to cat1l1y with it. lHlS SUBPOENA WAS ISSUED AT lHE REQUEST OF lHE FOLLOWING PERSON: NAME: George B. Faller, Jr., Esquire * - notes, consultations, referrals, forms, reports, as well as all correspondence and 17013 memoranda or the like, but ~CLUDING only actual films and routine nurses notes. ADORESS: MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street, Carlisle, PA TELEPHONE: (717) 243-3341 SUPREt'E <XXJRT 10 #49813 ATTORNEY FOR: Defendant Nathan Alan Ruff DATE: tJ/. .5 c~ Sea 1 of the Court BY THE OOURT: IsI ;Ja;t,- K~ Prothonotary/Clerk, Civi 1 Division ~~ Ie y~. 9~ty (Eff. 1/91 -. ~ '*-. " CERTIFICATE OF SERVICE I, Jennifer L. Kelley, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Certificate Prerequisite to Service of a Subpoena was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Matthew D. Strohm, Esquire DISSINGER & DISSINGER 28 North Thirty Second Street Camp Hill,PA 17011 MARTSONDEARDORFF WILLIAMS & OTTO BY~W' ~. '1'Arpj~ nnifer Kelley en East High Street Carlisle, P A 17013 (717) 243-3341 Dated: October 6, 2000 f-'~' ; - ., ,," ,_,,<,,, ,'r - -,~ -~~ ~- "-- '.' 0 0 () C 0 " s: a -v n.:: n IT' f"I': -~ ~ ::rJ ?-- C" \.0 (0," -(..::-- ~i:) ?" " ;to> ;~:i c ~ ~. ~ c,) .~ . ~" ',0"_. ,~~' ~ '''' ~..,..,~--~ ~~~~ ",~!f!Iq~_,,,,,,,,,....,.,, _.~~."""",~...... =';'" ~'1''': _' ,~?'-"!'l1~i vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA l~'i NO. OO-i~ CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED HEIDI L. SHAFER, Plaintiff NATHAN ALAN RUFF, Defendant PRAECIPE TO: Prothonotary Cumberland County Court of Cornmon Pleas Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Please mark the above-captioned action as settled and .. discontinued, and remove it from the docket. DISSINGER & DISSINGER By: l/JU~tlkz-A JLi Matthew D. Strohm Supreme Court ID # 76724 28 North Thirty-second Street Camp Hill, PA 17011 (717) 975-2840 Attorney for Plaintiff Dated: cc: George B. Faller, Jr., Esquire Martson, Deardorff, Williams & otto 10 East High Street Carlisle, PA 17013 Nancy J. Salak Progressive 5053 Ritter Road Mechanicsburg, PA 17055 ",." - - ~-- ~~I " !.....~-,~~''''''''_.~.(1);l::;."'C_ . "'_~__." ~~ LJI lIf o c- ~ -oC1~' ("11 fT~ ~:T~: 65C;::~ "<:<, r-"r:~: "S:'-J ~(~ <: - j;":~,? ~ ~ ~ f~" C,.;, c:::. c-:;' "" j";"", C-; !~'", ~"'--' ii [~~] :?ElJ .~;\ (:'1 .\-~;'i :':',::;r~ C) rn ::;::-1 55 -< - 1..0 :::-,., - -'- i~_'iw.l;'l;l%l:;_!I'IW'mjIf4;f~4!'i!l'~A1!'ii'mli!'~~ifJji~ifflf_"-r~!ljU!1