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Home My WebLink About00-02172 Law Offices of Hazlett & Oesterling 20 South Market Street Mechanicsburg, PA 17055 (717)-790-0490 IN THE COURT OF COMMON PLEAS FOR THE NINTH JUDICIAL DISTRICT, CUMBERLAND COUNTY, PENNSYL VANIA KAREN S. MONNIER Plaintiff, No. ()O -,;2/7 d t;~ v. BO KYONG KIM Defendant , Civil Action - Law Personal Injury JURY TRIAL DEMANDED 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 Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS 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 (717) 249-3166 -'"'f;l!Jl1" . ,~, ~~~H ~ 1.-~~='" IN THE COURT OF COMMON PLEAS FOR THE NINTH JUDICIAL DISTRICT, CUMBERLAND COUNTY, PENNSYLVANIA KAREN S. MONNIER Plaintiff, No. fH - .2 / '7.2- Clu:.1 J b--- v. BO KYONG KIM Defendant Civil Action - Law Personal Injury JURY TRIAL DEMANDED CIVIL COMPLAINT 1. The Plaintiff is Karen S. Monnier, an adult individual, sui juris, who resides at 85 Eagle Lane, City of Etters, County, of York, Commonwealth of Pennsylvania, 17319. 2. The Defendant is Bo Kyong Kim, an adult individual, sui juris, who resides at 43 Hadley Road, Apt. 89, City of Sunderland, State of Massachusetts, 01375. 3. On or about April 13, 1998, at or about 7:55 a.m" plaintiff was travelling in the northbound lane of State Road 1025 (Erford Road), in East Pennsboro Township, Cumberland County, Pennsylvania. 4. Plaintiff was wearing her seat belt. 5. At the same time and general location, defendant, Bo Kyong Kim, was operating a vehicle owned by him which was also travelling in the northbound lane of State Road 1025 (Erford Road), inunediately behind the vehicle being operated by plaintiff. 6. At the same time and general location, defendant Bo Kyong Kim, was operating his vehicle in a negligent, careless and reckless manner, so as to cause his vehicle to collide with the rear of the vehicle being operated by plaintiff, and further initiating a chain of events in which plaintiff s vehicle collided violently with the vehicle in front of her, 7. The negligence, carelessness, and recklessness of defendant Bo K yong Kim consisted of the following: (a) operating his vehicle at a high and excessive rate of speed under the circumstances; ~--,- - , .~ (b) failing to maintain the vehicle under proper and adequate control at the time; (c) failing to keep a proper lookout for other traffic; (d) operating the vehicle in such a manner, as to collide with the automobile being operated by plaintiff and setting in motion a chain of events leading to the collision between plaintiff and the vehicle in front of her; (e) operating the vehicle without due regard for the rights, safety, well being, and position of plaintiff under the aforesaid circumstances; (f) operating the vehicle in violation of the statutes of the Commonwealth of Pennsylvania pertaining to the operation of motor vehicles on the public highways, which conduct constitutes negligence as a matter of law; (g) such other acts of negligence, carelessness and recklessness as may be determined through the process of discovery and/or at trial. 8. As a direct and proximate result of the collision and defendant Bo Kyong Kim's negligent and reckless conduct, plaintiff was thrown violently against the interior of her automobile and sustained injuries to her neck and spine and was otherwise injured internally and externally in and about her head, body, arms, and legs, 9, As a direct and proximate result of the collision and defendant Bo Kyong Kim's negligent and reckless conduct, plaintiff has suffered and will suffer in the future, substantial pain and inconvenience. 10. As a direct and proximate result of the collision and defendant Bo K yong Kim's negligent and reckless conduct, plaintiff has been and in the future will be diminished in her abilities to perform certain types of work and activities incidental to daily living, to her detriment, damage and loss. 11. As a direct and proximate result of the collision and defendant Bo K yong Kim's negligent and reckless conduct, plaintiff has incurred and will in the future incur, expenses for medical treatment and physical therapy in an amount not yet ascertained. ;"" f ","," ~ -- , " 12. As a direct and proximate result of the collision and defendant Bo Kyong Kim's negligent and reckless conduct, plaintiff has suffered and will continue to suffer from the shock and emotional distress attendant to the collision. COUNT I Plaintiff, Karen S. Monnier v. Defendant, Bo Kyong Kim 13. The allegations contained in paragraphs 1-12 are incorporated herein by reference as though set forth at length, 14, Defendant, Bo K yong Kim, is liable for plaintiff's injuries described herein, inasmuch as plaintiff's injuries are the direct and proximate result of defendant's negligence and recklessness as set forth. WHEREFORE, plaintiff demands damages against defendant listed herein in an amount greater than $25,000.00 but not in excess of $100,000.00 exclusive of interest and costs. Respectfully Submitted, HAZLETT & OESTERLING by' Lee E, Oesterlmg, Esquire Attorney I.D.# 71320 20 South Market Street Mechanicsburg, PA 17055 (717) 790-0490 Attorney for Plaintiff, Karen Monnier .~ VERIFICATION I verify that upon personal knowledge or information and belief that the statements Made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. & 4904, relating to unsworn falsification to authorities Date: ~[U) li/-~ It-- aintiff !'"", ~1 . o'~ - ~~ ~~~ .....~ Law Offices of Hazlett & Oesterling 20 South Market Street Mechauicsburg, PA 17055 (717)-790-0490 IN THE COURT OF COMMON PLEAS FOR THE NINTH JUDICIAL DISTRICT, CUMBERLAND COUNTY, PENNSYLVANIA KAREN S. MONNIER Plaintiff, No. 00-2172 v. BO KYONG KIM Defendant Civil Action - Law Personal Injury JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I hereby certify that on the 18th day of May, 20...illL a true and correct copy of the Verified Complaint and Notice to Defend in the above-captioned matter, was served upon the persons and in the manner listed below: Service by Certified Mail, Return Receipt # P405056874, and, Service by First Class Mail Postage Prepaid addressed to the following: Mr. Bo Kyong Kim 43 Hadley Road, Apt. 89 Sunderland, MA 1375 The original Return Receipt and copy of first class mailing is attached hereto, marked as Exhibit "A", and incorporated by reference. Lee E. Oesterling, J.D. # 71320 Attorney for Plaintiff """ .~~ ,"' '-', , rn J,,"-~, I"W"l"lJ . r"~" 0 C) r~ c: C;) ',-) <':' " utD ,- r:: [}l. rn -,~.. 7-.', i- &5~~ ,yo, -<:?: 'W c:_~' r:: l'-~ ;~) C<~ ..l;-J ~C' .::) -',-, ...". -::rS - t.. ) )>- ;:--"'; IT! c: :.~ :2: :<! 1> V1 5:J -< "'- r_TIl'i!ll!!f[f!l1J~~}"'I.~~~~,~~II!'Jll-"lJ!'iiW'~~fliii~~~~'U~I~!ffl.~~,,"~ II ... SElMl!Jlt !,., -8 "OOi!iPlet.!t$mS 1 ""dlor 2 ~~oIf.IIe/"Ivl"., : -; .eompf~(fitems'3. 48, arid 40. . 11 .Print your'name 8I'\d-addtees on the reverse of this form so that we can ret~ this '-& card to yOu; ~ .~ch this form to the front of the mBilpiece, or on the back If space does not l! permn, lit .W~te.RBtumRecsipt Rtfqf/sstsrr on the mallplece below the article number. 'fi _The ,Ret,um Receipt will show to whom the article was delivered and the date e delivered. o . I 3. ArtlcleAddressed to: a. 'E o o Ul I al... wiSh to receive the IoIl~wiIIlJ services (lor an aJ!lIa Iali): 1. 0 Addressee's Address 2. 0 Restricted Delivel)! Consult postmaster lor fee. 4a. Article Number 814 II ! .. ' Ul a, 'ii &! c ~ ::I ~, II: 01 C ;; ::I .e ::I g, ... c .. .c .. ~ ::I g, !Il + !\ll_ ".- . ,.- -''''''; 'z"'1" <_, _ ~ ", ,~ KAREN S. MONNIER, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. .: NO. 00-2172 : CIVIL ACTION - AT LAW BO KYONG KIM, DEFENDANT : JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Karen S. Monnier, and her attorney, Lee E. Oesterling, Esquire LAW OFFICES OF HALZETT & OESTERLING 20 South Market Street Mechanicsburg, PA 17055 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 Date: 07/17/00 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 ~ """'-~",','-' . "~, -,. '-' -., ~"-,~ , -~- - ',:"" '",<':'C'_ ',"'\'" """~--"- '..,--' '-'.',-,;","-'_"_"f",,_,_-^~I',~ 0', -_ _ "", _H . KAREN S. MONNIER, PLAINTIFF v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-2172 CIVIL ACTION - AT LAW : JURY TRIAL DEMANDED ANSWER WITH NEW MATTER BO KYONG KIM, DEFENDANT AND NOW, comes Bo Kyong Kim, by his attorneys, Nealon & Gover, P.C., and files the following Answer: 1. - 2. Admitted. 3. - 7. Denied pursuant to Pa.R.Civ.P. 1029(e). 8. - 12. Denied. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the matters asserted and proof is demanded at trial. COUNT I KAREN S. MONNIER V. BO KYONG KIM 13. Paragraphs 1 through 12 of Defendant's Answer are incorporated herein by reference thereto. 14. Denied pursuant to Pa.R.Civ.P. 1029(e). WHEREFORE, Bo Kyong Kim, respectfully requests that the Complaint be dismissed with costs of this action. 1'-,_, ',' ~" . -, -., '-,-"",'-''',''" ',,:,-,'-';' '-.'(,,' ,'-"" - .." , =--, ". - .~~- - "' NEW MATTER 15. Paragraphs 1 through 14 of Defendants' Answer are incorporated herein by reference thereto. 16. Plaintiff's claims may be barred in whole or in part by application of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, Bo Kyong Kim, respectfully requests that the Complaint be dismissed with costs of this action. Respectfully submitted, Ma hew R. Gover, Esquire Attorney I.D. #47593 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 Date: 07/17/00 , " 'J "";'--"_,,,~:-"'?',,!?'~"~'- ,-"-~,,~"-'-" ~/""-':~' ~ ,-",,",..,,.. - ~ --,,,,_,,~ ~",jf,';-._ _ 0'", '.'_ .,,, _ ,~_ 0.. " '''1 VERIFICATION I, Bo Kyong Kim, 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. ~' Bo Kyong Kim H' _, >-,',~ ~, ..._,~_" "__'''''_'_~';'~'~ ,~,__",_'_ ,,_,,_,_. .' '-"~'~_ '. ' ,_. 'u'o_ '" , _' '0 _ _~_','~ CERTIFICATE OF SERVICE AND NOW, this 17th day of July, 2000, I hereby certify that I have served the foregoing Answer with New Matter to Plaintiff's Complaint on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Lee E. Oesterling, Esquire LAW OFFICES OF HALZETT & OESTERLING 20 South Market Street Mechanicsburg, PA 17055 ~~~~1? att ew R. Gover, Esquire - , ,- -c", ,~,:~~ ,""Pc;-,. '-', -<"''-''''-','",'- --';74-:.,01" "?--_'' ,,-; ,-c_ _'.<tJ-<" __,,::,,-,_,__;, _'_'-' ~ ,,"=, _4 ~_ _ - ",,-__~. '''17,''-' ' " .. KAREN S. MONNIER, PLAINTIFF v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-2172 .CIVIL ACTION - AT LAW BO KYONG KIM, DEFENDANT JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Bo Kyong Kim, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER Date: fit 111 0 By 1/d.tU!~ Matt ew R. Gover, Esquire. Attorney I.D. #47593 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 ,~ '.". ~.~ -, ,~__, ".,_~'__' ","~"""r"~ -'--,"",0 .-?-t',''!'--'':'''~'---''r-,r~o/:,:_,,_.!_o/<,,_-~,,: t' -, -', '. ~- , ,.- c/ CERTIFICATE OF SERVICE AND NOW, this 19th day of May, 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: Lee E. Oesterling, Esquire LAW OFFICES OF HALZETT & OESTERLING 20 South Market Street Mechanicsburg, PA 17055 'i. . ,',~"- ~ . .,. '_,' - ,." ,c' _'~., .'_"~'__~ ,_",,'. " ~ :; ~~Q co OOh :c P--:-,':. .0: ~'b 2:,C: en l..UO-. , ::=!lU (..11 u-:L ~ !-. or.>: tJ.~ 0 o C> ..... w ?: z :::lS; o "Z '-'~ o2i 2'>":- <.;::W -,2 cr;z uJLLI COo.. :::e; :::l U ',' (- ,-~-- ,.~-",. -".,." -~." , - ,+-~" -"~'"-',,~- , '0, _,,, '-. ~!\'!.~.- , " - coo, l",.";,~,.'1'~ _ ~)_ ~~""'~ _ __'~;: I!!II! .. Law Offices of Hazlett & Oesterling 20 South Market Street .'." ,-, . Mechanicsburg, PA 17055 (717)-790-0490 IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT, CUMBERLAND COUNTY, PENN"SYL VANIA KAREN S. MONNIER Plaintiff, No. 00-2172 v. Civil Action - Law Negligence / Personal Injury BO KYONG KIM Defendant( s) JURY TRIAL DEMANDED PLAINTIFF'S ANSWER TO NEW MATTER The following paragraphs correspond numerically to those in defendant's New Matter: 15. Paragraph 15 requires no answer. 16. Paragraph 16 is denied. WHEREFORE, Plaintiff respectfully requests that Defendant's New Matter be dismissed and judgment be entered in favor of Plaintiff on the issue of liability with damages to be determined. Respectfully Submitted, HAZLETT & e E. Oesterling, Attorney LD.# 71320 20 South Market Street Mechanicsburg, PA 17055 (717) 790-0490 :'" " ,I _, . Law Offices of Hazlett & Oesterling 20 South Market Street Mechanicsburg, PA 17055 (717)-790-0490 IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT, CUMBERLAND COUNTY, PENNSYL VANIA KAREN S. MONNIER Plaintiff, No. 00-2172 v. Civil Action - Law Negligence I Personal Injury BO KYONG KIM Defendant(s) JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Lee E. Oesterling, Esquire, attorney for the plaintiff, Karen S. Monnier, do hereby certify that a true and correct copy of plaintiff's Answer to Defendants New Matter was served upon the following counsel by first class mail, postage prepaid, on this date: Matthew R. Gover, Esquire NEALON & GOVER 301 Market Street, PO Box 865 Harrisburg, PA 17108-0865 BX' Dated: 9-20-00 1~h .r - , "",~-~ ." ~" _o~.. ., m 1; .A1MIl _ Co JIII!,~..,- ~" (') C 7" ."OO~' mrT', 2::q m):: "<-"- r<. C) ~Q ..~,~c.j :J>C ~ ( .. <..":> Cl (/') ,..,1 -0 N '" -0 :J1: (') 'r, t:" (1' ;~i:~J1 ~-:gt3 l,:JC' -:'::1-t, .~ _to: S~'~ S ."c~ 5:l "< . _ ~~:Jll~.!Jl!"~!f..,.." '. ~,.~~~~~",~..JI~"~Ii_ ~ , ~, KAREN S. MONNIER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW 1 BO KYONG KIM, Defendant NO. 00-2172 CIVIL TERM ORDER OF COURT AND NOW, this 22nd day of November, 2000, upon consideration of Defendant's Motion To Compel Answers to Discovery by Plaintiff, a Rule is hereby issued upon Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, Lee E. Oesterling, Esq. 20 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff lcrp~ 1Y1~ 11- 2~-OO 'K~~ Matthew R. Gover, Esq. 301 Market Street - 9th Fl. P.O. Box 865 Harrisburg, P A 17108-0865 Attorney for Defendant :rc :', ", "" -" ,_.,-, _, H_, <. ,<- ~- .,- . . " "., '- , , \f!\" ;'\l J n' 'N- j ,[-,Vi lJ\\)j\ii :ic, 1 f!\V)('.."-'1 ''''~'!'~I-'lJ-!''''''jn^ 1\..1, ,! i\.,.\ '._1:', I ",>_~'_!:,-!;i\, f0 r.- 1Jl!lM,! o(~. /.I:-J\i. :11 rnl h'J :::- ';f --', "i::,J ('.I". 1_, t.. [;l.Ji~ l_"'(j '''''.. _,.,,"'M,'"'' ,- ~ .~ . . ,,..,. -~ rJ~~'f!i:ilj,l~W~ , ,,,~, ",'," "-~, ",~~",~,-,=....-=~".,,,> .'" _0. -;h, ,_~. ..1. "~~ ,,_~!'J!I ldllm1 ";: , v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-2172 CIVIL ACTION -AT LAW KAREN S. MONNIER, PLAINTIFF BO KYONG KIM, DEFENDANT JURY TRIAL DEMANDED ORDER AND NOW, this day of , 2000, it is hereby ordered that the Plaintiff will furnish Answers to the Interrogatories and Request for Production of Documents propounded on them on June 5, 2000, within 20 days upon service of this --,-~-- Order. Failure to comply with this Order will subject Plaintiff's counsel to sanctions. J. Distribution: Matthew R. Gover, Esquire, 2411 North Front Street, Harrisburg, PA 17110 Lee E. Oesterling, Esquire, 20 South Market Street, Mechanicsburg, PA 17055 ~ r ,,' ~,'" ,',,_.,'-'.-.-,v' ',---"7'_'--- -",,', ,1;:"',' --).-,,,,"-"1'~~-_,-1H- ,,<:,-.c,- .,c,O -__';_,")f_~,'_" ')' - -- __ "ce- ~.,.' ,_ _ .,... ,,_,~"~ '-n .; _~___ - ,'. KAREN S. MONNIER, PLAINTIFF v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-2172 CIVIL ACTION - AT LAW BO KYONG KIM, DEFENDANT : JURY TRIAL DEMANDED DEFENDANT'S MOTION TO COMPEL ANSWERS TO DISCOVERY BY PLAINTIFF AND NOW, comes the Defendant, Bo Kyong Kim, by and through his attorneys, Nealon & Gover, P.C., and files a Motion to Compel Plaintiff's Answers to Discovery as follows: 1. The above-captioned matter arises out of an automobile accident that occurred on April 13, 1998, in East Pennsboro Township, Cumberland County, Pennsylvania. 2. Suit was commenced by the filing of a Complaint on April 10, 2000, in the Court of Common Pleas of Cumberland County, Pennsylvania.. 3. The Defendant filed an Answer With New Matter to the Complaint on July 17, 2000. The Plaintiff filed an Answer to New Matter on September 20, 2000. 4. The Plaintiff is represented by Lee E. Oesterling, Esquire, of the Law Offices of Halzett & Oesterling, located at 20 South Market Street, Mechanicsburg, Pennsylvania, 17055, (717)790-0490. 5. On June 5, 2000, the Defendant's counsel(hereinafter Defendant) properly served Plaintiff's counsel (hereinafter Plaintiff) with Interrogatories and Request for Production of Documents. ",F"__.,O;>,_",,,, "':'O_~'_'._ .^' ~-"-_';"r"_~__':' .c_',,'/'<' _,.,..yP._...._..~ __,,_".__.__~_,'__'_\C_"',_, T 1 .",:~l " ,',",' ,~- ~-, ." " 6. True and correct copies of said Interrogatories and Request for Production of Documents, accompanied by Certificates of Service, are attached hereto as Exhibits "A" and "B" respectively. 7. No objections were made to the Interrogatories or Request for Production of Documents. 8. On September 27,2000, having not received Plaintiff's Discovery Responses, the Defendant sent Plaintiff correspondence notifying Plaintiff that Discovery is overdue. In that correspondence, Defendant notified Plaintiff that unless said Discovery Responses were received by Defendant within two weeks, Defendant would file a Motion to Compel Discovery with the Court. 9. A true and correct copy of the September 27, 2000, correspondence is attached hereto as Exhibit "C". 1 O. As of the date of this Motion, Plaintiff has failed to respond in any manner to Defendant's discovery requests. WHEREFORE, the Defendant respectfully requests that this Court enter an Order compelling the Plaintiff to respond fully to Defendant's outstanding Interrogatories and Request for Production of Documents within twenty (20) days of the date of said Order, under penalty of further sanctions pursuant to Pa.R.C.P. 4019. I I I I i'_ -'--'-~ -"-,,","' ~-'=-.~-~ :<:-"Je'-'- -"~-'/"_"'-'>-'-"',; ,-~""--",,,", -_~_,_,~--,.) ,." ,~ ..-____~, "',_ "., c_.. ,. _~ .,'e.' "_'~__'-'_"_' .r.____ . ,.' . ~ . I I ~ " _'''_''''_:'_~$_o,___ ,',--", _:_C-P_~'_;\"" P""'O-C"""e_',, .". '" -Pc;.' -. ^-"'''7",;;>~:~,Fc'p'." "__ T'I _ Respectfully submitted, B: tth R. Gover, Atty.I.D.#47593 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 . ' , -'<" ..".,1'_'' '-'--"-'-':'~"'1_'-'":T '-,' .r_'~0__-_~~-"- i.>'-~ . . v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-2172 : CIVIL ACTION - AT LAW KAREN S. MONNIER, PLAINTIFF BO KYONG KIM, DEFENDANT : JURY TRIAL DEMANDED INTERROGATORIES PROPOUNDED BY DEFENDANT TO BE ANSWERED BY THE PLAINTIFF. FIRST SET TO: Karen S. Monnier, and her attorney, Lee E. Oesterling, Esquire LAW OFFICES OF HALZETT & OESTERLING 20 South Market Street Mechanicsburg, PA 17055 PURSUANT TO THE PROVISIONS of Pa. RC.P. 4005 and 4006, as amended, you are required to file the original, and serve a copy on the undersigned, of your Answers and Objections, if any, in writing and under oath, to the following Interrogatories within thirty (30) days after service of the Interrogatories. The Answers shall be inserted in the spaces provided following each Interrogatory. If there is insufficient space to answer an Interrogatory, the remainder of the Answer shall follow on a supplemental sheet. "'1>1, r -' -- ~ , . . These Interrogatories shall be deemed to be continuing in nature pursuant to - Pa. RC.P. 4005 and 4006. If between the time of filing your original Answers to these Interrogatories and the time of trial of this malte~, you or anyone acting in your behalf learns the identity and location of additional persoos having knowledge of discoverable facts and the identity of persons expected to be called as an expert witness at trial not disclosed in your Answers, or if you or an expert witness obtains information upon the basis of which you or he knows that an Answer was incorrect when made, or know that an Answer though correct when made is no longer true, promptly supplement your original Answers under oath to include such information thereafter acquired, and promptly furnish such a Supplemental Answer on the undersigned. Respectfully submitted, NEALON & GOVER Ma thew R Gover, Esquire Attorney I.D. #47593 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 Date: 06/05/00 .. . I ,~ CERTIFICATE OF SERVICE AND NOW, this 5th day of June, 2000, I hereby certify that I have served the foregoing Interrogatories on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Lee E. Oesterling, Esquire LAW OFFICES OF HALZETT & OESTERLING 20 South Market Street Mechanicsburg, PA 17055 --, v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-2172 CIVIL ACTION - AT LAW KAREN S. MONNIER, PLAINTIFF SO KYONG KIM, DEFENDANT JURY TRIAL., DEMANDED REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO PLAINTIFF - FIRST REQUEST TO: Karen S. Monnier, and her attorney, Lee E. Oesterling, Esquire LAW OFFICES OF HALZETT & OESTERLING 20 South Market Street Mechanicsburg, PA 17055 PLEASE TAKE NOTICE THAT PURSUANT TO Pa. RC.P. 4009, you are required to furnish at our office, on or before thirty (30) days of service hereof, a photostatic copy or like reproduction of the materials concerning this action or its subject matter which are in your possession, custody or control and which are not protected by the attorney/client privilege; or, in the alternative, produce the said matter at said time to permit inspection and copying thereof: REQUEST FOR PRODUCTION OF DOCUMENTS 1. The entire contents of any investigation file(s) and any other documentary ~ material in your possession which support or relate to the allegations contained in Plaintiff's Complaint (excluding references to. mental impressions, conclusions or opinions representing strategy or tactics and privileged communications from and to counsel). .~ , , ~ 2. Any and all statements concerning the action, as defined by Rule 4003.4, from all witnesses including any statements from the parties herein, or their respective agents, servants or employees. 3. All photographs taken or diagrams prepared of .the scene of the accident or any instrumentality involved therein. 4. Any and all documents containing the names and home and business addresses of all individuals contacted as potential witnesses. 5. Reports of any and all experts who will testify at trial. 6. Any and all medical records; physician's reports and bills, hospital records or abstracts of same which relate in any way to the injuries allegedly sustained by Plaintiff, as well as the treatment of any similar injuries prior or subsequent to the occurrence in question. 7. All federal, state and local income tax returns for the past five years. Respectfully submitted, NEALON & GOVER n Date: 06/05/00 M tthew R. Gover, Esquire Attorney I.D. #47593 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 -- , '-l"- ~ CERTIFICATE OF SERVICE AND NOW, this 5th day of June, 2000, I hereby certify that I have served the foregoing Request for Production of Documents on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: lee E. Oesterling, Esquire LAW OFFICES OF HALZETT & OESTERLING 20 South Market Street Mechanicsburg, PA 17055 c$l~~ Matthew R. Gover, Esquire :-'",", ~i. - Nealon ~.over ~~~~.~ ..' 'J . September 27, 2000 Lee E. Oesterling, Esquire LAW OFFICES OF HALZETT & OESTERLING 20 South Market Street Mechanicsburg, PA 17055 IRE: Monnier v. Kim Cumberland County 00-2172 Civil Dear Lee: 2411 North Front Street HARRISIlURG, PA 17110 (717) 232-9900 FAX: (717) 236-9119 JAMES G. NEALON, III MATTHEW R. GOVER BRIAN W. PERRY DAVIDJ.FREED CHRISTOPHER]. KNIGHT Unless we have your discovery in our office within the next two weeks, we will proceed to file 81 motion to compel. Very truly yours, ufM u;r.. Matthew R. Gover NEALON & GOVER MRG/slf .0- ., ., . CERTIFICATE OF SERVICE AND NOW, this 1~ day of November, 2000 I hereby certify that I have served the foregoing Motion To Compel Answers to Discovery By Plaintiff on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Lee E. Oesterling, Esquire LAW OFFICES OF HALZETT & OESTERLING 20 South Market Street Mechanicsburg, PA 17055 Matthew R. Gover, Esquire -, ,",-,~, -~~ _"';_>:;"1 ___5, _~_,,,,,_,. - c..e,'., ..~,_,<:_,-,,__ "..!:-. '_'",0'---' ",:", _:<,o~. -',I' _. " ," - _ ,'0, _ .",__ ___,~~ ---,'C"," _ _, _.., lO'- ,_" ,..''''' "",'.," ,,' _, c' KAREN S. MONNIER, PLAINTIFF v. BO KYONG KIM, DEFENDANT TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-2172 CIVIL ACTION - AT LAW JURY TRIAL DEMANDED PRAECIPE Please mark the above-captioned matter settled, satisfied, and discontinued. Date: (J -?. 7 - 6/ , , Respectfully submitted, ".. ",,,.--'- ,v ":",,";~,,,,- '__"" ,'_~ " ,"_,_ eo','_, -C"""'_ _O''''''"':.''_I~____,__'~--'.'_'_' _, --l- , Lee E. Oesterling, Esquire 1.0. #: 1J/..3ZO 20 South Market Street Mechanicsburg, PA 17055 717/790-0490 - " '"" ~ "'7..,-8~--'" -\___~",,;_ -,' -_ ,."" CERTIFICATE OF SERVICE AND NOW, this VI day of September, 2001, 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 mail, postage prepaid, addressed to: Lee E. Oesterling, Esquire LAW OFFICES OF HALZETT & OESTERLING 20 South Market Street Mechanicsburg, PA 17055 cJfl:ir ~~ M tttie R. Gover, Esquire , '~-----", -~ ""'~, -, 'F' ^,;'~"_-,',"f:: ,__:,C'_~'_ "",. '-_" ~,- ","__'--',," _ " __.A__\:,.n"~,, ,C"'_~"I_'" ,- - ._,_~,,,,__,,,"",,_,..,,,_.___,,~,_ " "c,',_.,,^ "'._ "'~ '=.'''17.-' . ~_'r>'-,; -_~,-" ,,'.-~'_ " ~l'I~,1'l "-'-"~" .. 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